Professional Documents
Culture Documents
erm.com
or and on behalf of
Environmental Resources Management
Signed:
Position: Partner
Date: 01.11.12
1 INTRODUCTION .......................................................................................................... 1
1.1 UNDERSTANDING OF THE PROJECT .......................................................................... 2
1.2 STUDIES TO DATE ...................................................................................................... 6
1.3 UNDERSTANDING OF THE SCOPE OF WORK............................................................. 6
2 REGULATORY FRAMEWORK & INTERNATIONAL GOOD PRACTICE ..... 9
2.1 LOCAL REGULATIONS ............................................................................................... 9
2.2 ENVIRONMENTAL GUIDELINES FOR MINING OPERATIONS IN SIERRA LEONE ....... 9
2.3 INTERNATIONAL POLICIES, GUIDELINES AND STANDARDS .................................. 13
3 ERM PROFILE AND SELECTED PROJECT EXPERIENCE ................................ 17
3.1 INTRODUCTION ....................................................................................................... 17
3.2 ENVIRONMENTAL RESOURCES MANAGEMENT ..................................................... 17
3.3 DALAN DEVELOPMENT CONSULTANTS DDC .................................................... 20
4 ESIA APPROACH & METHOD ............................................................................... 23
4.1 OBJECTIVES.............................................................................................................. 24
4.2 PHASE 1 APPLICATION AND SCOPING................................................................. 25
4.3 PHASE 2 SPECIALIST BASELINE STUDIES .............................................................. 31
4.4 PHASE 3 IMPACT ASSESSMENT AND REPORTING ................................................ 74
4.5 PHASE 4 MANAGEMENT PLANS .......................................................................... 78
5 PUBLIC PARTICIPATION PROCESS ..................................................................... 83
5.1 PUBLIC PARTICIPATION AND CONSULTATION PROCESS ....................................... 83
6 PROJECT SCHEDULE ................................................................................................ 90
7 PROJECT TEAM STRUCTURE AND PROJECT MANAGEMENT .................. 91
7.1 TEAM STRUCTURE ................................................................................................... 91
7.2 PROJECT MANAGEMENT....................................................................................... 108
ANNEXES
We believe that the combination of our proposed team, ERMs expertise and
experience in undertaking similar ESIAs for the mining industry places us in a
good position to complete the ESIAs in an efficient and professional manner,
to the Sustainability Performance Standards of the International Finance
Corporate (IFC).
Phase 1
Phase 2
Phase 2 includes the expansion of the existing facilities at the mine to include
the following additional components:
Phase 2 also includes the development of a new railway spur (ca 40km) with
additional loops or dual track. This spur will diverge from the existing
railway line, in the area of Lungi Lol and connect to the port facilities at Tagrin
Point, near Lungi Airport. The RFT notes that alternative rail options were
considered (and discounted) prior to the current option being selected. The
ESIA process will therefore focus on the preferred option while also
communicating the option appraisal processes undertaken to date.
The RFT notes that three alternative options for port development have been
developed, assessed and discounted to date such that a preferred option at
Tagrin point has now emerged. The RFT notes that the ESIA process should
therefore include an appraisal of the various options that have been
considered and an impact assessment of the preferred port location and layout
at Tagrin.
Phase 3
According to the RFT, Phase 3 will comprise of mining and processing plant
facilities at the mine site linked by the narrow gauge rail to handling facilities
and stockyards at the new port area, which is to be located at Tagrin Point,
built as part of Phase 2.
Water resources (quantity and quality) data has been and is collected within
the Mawuru catchment. In addition, various ecological surveys have been
conducted that cover certain parts of the TSF, with a focus on ornithology and
general habitat appraisals, as precursors to more comprehensive surveys that
are required.
data held on the ED GIS which includes aerial photography (high res),
topography, mapped villages and Phase 1 infrastructure;
According to AML, two EIA licences are required for Phase 2 and that an EIA
and SIA are required as part of the application for each EIA licence under
Sierra Leonean law. However, the EIA and SIA will be undertaken under an
ESIA process and therefore the term ESIA is used in this document, where
appropriate.
The following deliverables are therefore required under this scope of work:
EIA and SIA for the Tagrin port option and rail extension spur; and
EIA and SIA for the Tonkolili saprolite plant, tailing storage facility (TSF)
and water resource infrastructure.
Compile an EIA and SIA for the Tagrin port the 40km rail spur from Lungi
Lol to Tagrin:
Port marine and landside
Considering each of the 3 Tagrin Port options, plus variations in
layout configuration and offshore infrastructure.
Railway, infrastructure
the rail spur ca. 40 km from Lungi Lol to Tagrin ,
a 200km corridor covering the standard gauge rail option from
Tagrin to Tonkolili; options appraisal.
Compile an EIA and SIA for the Tonkolili Mine, including water resources
studies concentrating on the two affected catchments. Consideration of
greenhouse gas emissions and climate change will also be factored into the
reports;
Develop the EIAs and SIAs to include a description of the project options
(for rail and port) considered to date and the rationale supporting the
selection of the preferred options;
The EIA, SIA and associated Management Plans for both the mine and rail
and port options will be submitted to the Authorities;
The EIAs and SIAs will be compiled to adhere to the local legislation,
International Finance Corporations Performance Standards and the Equator
Principles.
Contained under Part 3 of the NEPA are EIA guidelines. These guidelines
include three schedules. The first schedule describes projects requiring EIA
Licenses, the second schedule describes the factors determining if a project
requires an EIA and the third schedule states the contents of an EIA.
The promulgation of the Mines and Minerals Act (MMA) 2009 represented a
new era for minerals development in Sierra Leone. Replacing the Act of 1994,
it includes major changes to how the sector is to be governed. It is more
comprehensive with respect to the issues it addresses; more balanced between
the interests of investors and communities; and more rigorous in terms of
governance and oversight. It is intended to bring important benefits to the
economy, local communities and the country. The Mines and Minerals Act
2009 has four main objectives:
Additionally, the law is consistent with all the main Economic Community of
West African States (ECOWAS) Commission principles and policies
governing the mining sector, including the acquisition of mineral rights,
respecting the rights of landowners, protection of the environment, financial
terms and conditions and company reporting, access to information, state
participation in mining operations, respecting the rights of local communities,
and providing Government the right to acquire an interest in large-scale
mining operations.
The ESIA will take cognisance of both the Environmental Protection Act and
the Mines and Minerals Act.
2.2.2 The Environmental and Social Regulations for the Minerals Sector (2011)
Regulated Procedures
Information regarding the project area, its current uses and physical,
biological and social environment;
In addition, the forms contained in the fourteenth Schedule regarding the time
and date that documents have been placed on deposit for public inspection
must also be completed and submitted to the authorities. Thereafter, the
applicant must submit a scoping report to the Authorized officer according to
Section 27 of the Environmental and Social Regulations for the Minerals Sector.
The applicant is expected to receive comments from the Executive Chairman
within 21 days from the date of submission of the report.
As mentioned above, the Tonkolili Iron Ore Project is a Category A mine due
to the potential requirements for resettlement. The EPA-SL have agreed that
AML will submit an EIA and SIA along with the necessary management
plans; MCP, EMP, SMP, CDA and RMP. The EIA must describe the potential
impacts of the proposed project on the surrounding biophysical conditions.
Possible mitigation measures, avoidance recommendations and/or
compensation proposals must also be outlined. The SIA study and report
must describe the social, economic and health issues affecting the host
communities. The adverse social impacts associated with the proposed project
must be detailed and recommendations for avoiding, mitigating or
compensating these must be provided. A contingency plan including a risk
assessment will also be compiled as part of the ESIA process. The required
contents of both are clearly outlined in the draft regulations and will be
complied with.
The MCP must contain proposals for the management of the progressive
rehabilitation to be undertaken, including the restoration of mined out areas.
This Plan must ultimately provide a strategy for the closure and rehabilitation
of the mine and must also include a monitoring and reporting programme for
a minimum period of three years after final closure of the mine, according to
Part 5, Section 53 of the Act. Detailed closure cost estimations, including
restoration, rehabilitation and remedial works costs must also be provided in
accordance with Section 41 of the Act, which details financial assurance.
Financial assurance is the responsibility of the applicant and the mechanism
used must comply with the standards contained in the sixteenth Schedule of
the Act. In addition, proof of financial assurance must also be presented
together with the MCP; at least 6 months prior to the commencement of
mining activities.
The EMP must detail the applicants implementation plan with regard to the
measures recommended to avoid, mitigate or compensate for the potential
adverse impacts caused by the mining activities as identified in the EIA.
The SMP must also detail the implementation strategy regarding the
identified management/mitigation measure to avoid, mitigate or compensate
for the adverse impacts identified in the SIA. Furthermore, the SMP must
The CDA required as per Section 27, must contain details of the planned
agreement between the mine and landowners/local community (specified in
Twelfth schedule) and must also be included in the SMP together with the
RMP. The Executive Officer or Authorized Officer shall refer the SIA and SMP
(including RMP) to the Resettlement Committee for review. AML will
develop the CDA and ERM will provide overview support as required.
According to Part 3 of the Act, the mine must adhere to the following
principles and requirements:
Following this review, greater emphasis has been placed on the consideration
of greenhouse gases, human rights, community health, and safety and
security. Furthermore, there is greater emphasis on community engagement
and requirements for free, prior and informed consultation where there are
significant environmental or social effects on communities. There is an
increased focus on social and environmental performance of Projects that need
to be managed, and monitored through an action plan and/or a management
system on an on-going basis.
To supplement the above Performance Standards, the IFC has established both
general and industry specific environmental, health and safety guidelines
which are considered directly relevant to the project and are outlined in Table
2.1.
Title
Environmental, Health and Safety General Guideline
Environmental, Health and Safety Guidelines for Mining
Environmental, Health and Safety Guidelines for Water Management Facilities
Environmental, Health and Safety Guidelines for Water and Sanitation
The EHS Guidelines for Crude Oil and Petroleum Product Terminals (April 2007
The EHS Guidelines for Shipping (April 2007)
The EHS Guidelines for Railways (April 2007)
IFC PS1, which provides guidance on ESIA and management systems, does
not specify a specific process. It does, however provide detailed guidance on
the elements that should be included, as part of a wider environmental and
social management system. The ESIA process should meet the following
criteria:
Management Programme
A programme of mitigation and performance improvement measures must be established
which will address identified risks and impacts.; and
An Action Plan must be developed where specific mitigation measures and actions are
necessary for compliance with regulatory and IFI standards. This should reflect the
outcomes of consultation on proposed measures to address impacts, and should be
disclosed to communities (including any updates made over time).
Community engagement
ESIA community engagement should form part of a broader, ongoing process of
community engagement that will extend throughout the life of the Project (and should
include a grievance mechanism).
Monitoring
Procedures should be established as part of the management system, to monitor the
effectiveness of the management programme. The ESIA will develop monitoring measures to
support these monitoring procedures.
ERM has also worked extensively with the requirements of the Equator
Principles (which overlap with the IFC Performance Standards). Further
details of ERMs experience in this respect are provided in Annex A.
To meet international best practice, ERM would discuss and agree the use of a
collection of the standards and guidelines that the AML could apply for this
Project. These may potentially include:
3.1 INTRODUCTION
ERMs involvement in mining has encompassed the full mine life cycle from
pre-feasibility processes, Bankable Feasibility Studies, ESIAs to IFC standards,
environmental authorisation and permitting, through to operational
performance management, decommissioning and closure. We have assisted
mining companies with new ventures and operational improvements in a
range of projects throughout the world. In the mining sector, ERMs expertise
lies in managing social and environmental risk, reputation and regulatory
approvals and compliance.
ERM has a long history of helping clients ensure that projects meet
international environmental and social assessment standards (including those
of the International Finance Corporation (IFC), World Bank, African
Development Bank (AfDB) and JBIC and others. In recent years ERM has been
applying this expertise to develop bankable projects in compliance with the
Equator Principles (EPs) and IFC Performance Standards. This includes
working for project developers seeking finance from the Equator Principles
Financial Institutions (EPFIs) as well as acting on behalf of project lenders in
reviewing project compliance against the Equator Principles. Specific services
include development and review of:
ERM is one of only four firms globally that has been licensed to deliver IFCs
Training on Performance Standards on Environmental and Social
Sustainability to EPFIs. Every year ERM supports the development and
financing of hundreds of major projects around the globe.
In addition, ERM has carried out training in the IFC Performance Standards
for a variety of corporate organisations (e.g. Sasol, Chevron and Standard
Bank), financial institutions (banks, private equity firms), and governmental
organisations.
With regard to the above projects, ERM has worked with a number of
financial institutions. They include ABN, ANZ, Barclays, BTMU, Calyon,
Fortis, Goldman Sachs, HSBC, JPMorgan Chase, Mizuho, Royal Bank of
Scotland, SMBC, Standard Chartered, and West LB. We also have project
experience working with developmental finance institutions such as DBSA,
FMO, and DEG.
For the purpose of this Project, ERM will associate with Dalan Development
Consultants (DDC) Limited. DDC is a Sierra Leonean owned Management
and Development Consultancy firm, established in 2003. Over the last 8 years
DDC has provided consulting services including research, to the Government
of Sierra Leone Institutions and Agencies, non-governmental organizations
and multilateral development institutions to support project and programme
DDC will provide ERM with a range of local social and environmental
specialists. The following projects demonstrate DDCs experience in Sierra
Leone over the past three years:
These phases are summarised in Figure 4.1 below and corresponds to the
phases outlined in our methodology below.
The overall aim for the EIAs and SIAs will be to investigate the environmental
and social impacts of the Project, including the appraisal of alternatives, and
prepare robust EIA and SIA reports and guidelines for environmental and
social management, in compliance with Sierra Leone legislation and standards
and the requirements of international financing institutions as set out in
World Bank Guidelines and Operational Procedures, and IFC Performance
Standards.
The EIAs and SIAs will cover both the detailed local impacts of the individual
elements of the Project and cumulative impacts as a result of current and
neighbouring operations. The EIAs and SIAs will deal with the permanent
impacts arising from the creation of the Project (for example, the loss of
ecological or cultural resources), the often temporary short term impacts that
will arise during construction, and the long term impacts of the on-going
operation of the Project over the life of mine, once commissioning is complete.
During the course of the study ERM will work closely with AML to provide
advice on the implications of strategic and in-Project alternatives that will
need to be considered, so that informed decisions can be made about the
preferred alternative. Once this is decided, we will continue to provide advice
on the design and mitigation of impacts identified through our
investigations. The plan will be to discuss and agree those measures which
are feasible and affordable for the Project so that these can be taken into
account in assessing the residual impacts of the scheme. If at any stage the
potential for a fatal flaw in the proposals is identified, this will be immediately
communicated.
The results of this final assessment will be reported in the EIA and SIA reports
together with a description and appraisal of the alternatives considered and
the reasons for the choice of the preferred scheme. This will be supported by
detailed Specialist Studies and by reports on the consultation process, and
guidelines on the development of the Project Environmental Management
Plan (EMP). The EIA and SIA reports will include a schedule of proposed
mitigation measures including proposals for monitoring and management
during all stages of implementation. These will be set out in a framework for
the EMP including principles for resettlement, indigenous peoples and
community development, and we will provide guidelines for the completion
of this plan and for development of an ISO 14001 Environmental Management
System for the later stages of the Project. We will also provide proposals for
developing on-going stakeholder engagement undertaken during the EIAs
and SIAs into a longer term Public Consultation and Disclosure Plan (PDCP)
for the future of the Project.
Scoping is the process of determining the content and extent of future baseline data collection,
consultation and impact assessment to be included within an ESIA. Scoping is undertaken at an
early stage to ensure that the ESIA provides all the relevant information on:
The findings of a Scoping Study will help to determine the extent of the ESIA including:
Coverage, focus and methodology for the impact assessment and development of
management plans (e.g. influx management plan, site rehabilitation plan, environmental
monitoring plan, etc.).
Defining boundary limits for the project, for example those associated facilities such as
access roads and the projects area of influence.
After contract award, we will mobilise the team and arrange an Inception
Meeting with AML (assumed to be in London) to finalise the details of the
Phase I work plan.
discuss and agree on the work plan and proposed scope of work;
gather all available information on the Project and its history, including
possible data (such as satellite imagery);
ERM will support AML in compiling the application form for submission to
the authorities. The application form will be in compliance with the structure
and requirements established in the Second Schedule of the Environmental
and Social Regulations for the Minerals Sector.
It is understood that AML will provide in-country support and logistics with
respect to the submission of the application forms to the authorities and any
associated requirements in terms of authority engagement. No in-country
travel or meetings will be required by ERM for this task.
We understand that AML has a range of reports and data that will be made
available at commencement of the study. In addition to this data, we will also
gather other secondary data on the local area (from NGOs, government,
university publications, etc.). The data reviewed will include local, regional
and national level data for the following:
We will rely on the in-country consultants (as well as AMLs associated social
and environmental specialists mentioned in the RFT and personnel from
AMLs Environmental Department) to collect much of this data, especially that
to be sourced from government ministries. This secondary data review will
inform project planning and focus the activities of the Scoping Study. The
outputs from the desk review will also form the starting point for
development of the Specialist Reports prepared to support the ESIA.
Location alternatives for the port (considering the preferred option and the
alternatives);
Route selection for potential changes to the existing railway and planned
44 km railway extension; and
The analysis of alternatives will be a two-way process between the ESIA team
and AMLs design engineers. At some agreed point there will need to be a
design freeze. This design will then form the basis of assessment for the
subsequent EIA and SIA studies.
A scoping visit will be carried out by key project personnel at the proposed
sites to determine the geographical scope for the ESIAs and to develop an
understanding of the environment, communities and the infrastructure within
the projects area of influence. The team will also meet with key project
stakeholders. This will include AML, government officials and community
leaders who might be directly impacted by the development. It is assumed in
the budget that AML will be able to assist with setting up scoping meetings.
Time will also be included within the scoping visit to brief the local
consultants and carry out training in relation to the field tools and information
required during later phases of the project.
The site reconnaissance will involve senior technical social and environmental
experts to allow for an integrated approach to identification of key project
issues, valuable sharing of information across disciplines and a holistic
understanding of the full range of potential impacts associated with the
project.
visits to the mine site, rail and port looking at preferred routes and options
for the port and the rail, as well as to identify environmentally sensitive
sites (such as all river crossings, areas of undisturbed vegetation, protected
or sensitive areas, fisheries); and
areas preferable for routing of the rail and the various port options.
During scoping, ERM will also meet with the social development consultants,
Sullay Kamara, referred to by the RFT to assess their capability and
experience. For now, our Bid assumes that ERM will work with our local
partners Dalan Development Consultants (DDC) with whom we have
already developed a working relationship in the implementation of ESIAs in
Sierra Leone.
The main aim of the social studies described in this section is to determine the
gaps in social data identified during scoping, through the collection of
additional primary social data that may be required. ERM will work closely
with AML and DDC (or with Sullay Kamara depending on our findings
during scoping) to develop a targeted data collection plan to manage the
collection of this data.
At the end of the Scoping Trip, to integrate the work of all team members and
to optimise dialogue with AML, we envisage holding a Scoping Workshop to
agree on the issues and risks identified during the scoping phase. The
workshop will include the Core Environmental and Social Team and selected
specialists. The scope and approach for the specialist studies and the overall
direction of the ESIA process will be discussed and agreed at the Workshop.
4.2.7 Task 7- Development of TOR, Work Plan and Communications and Public
Participation Plan (CPPP)
Following the Scoping Workshop, the team will develop a detailed TOR,
Work Programme and CPPP. The scope and methodology for each specialist
Two separate draft Scoping Reports (one for port/rail and another for the
mine) will be prepared by ERM and will be based on ERMs understanding of
the Project context and key environmental and social risks.
Following the production of the scoping report, the team will carry out
scoping disclosure with all relevant stakeholders identified in the CPPP. This
stage of consultation will provide details of current and planned activities as
well as findings from the scoping study. As legally required in Sierra
Leone (1), the final scoping report will be published and made available in
publicly accessible places such as the African Minerals website. Copies shall
be provided to the district and chiefdom authorities. Additionally, ERM will
prepare a non-technical summary of the report which explains its key contents
in laymans terms, to ensure that the information is readily understood.
From ERMs experience of working in Sierra Leone, consideration will be need
to be given to the low levels of literacy and as such a participatory approach
will be used when consulting with communities.
This section describes the proposed methodology for each of the specialist
studies covering Tonkolili mine site, and the preferred options for the port
and rail sites. The specialist studies outlined below also cover associated
facilities including the Kasofoni rock dump areas, the water resource
management aspects of the saprolite processing, the Tailings Storage Facilities
(TSF) and the Mawuru River Impoundment footprint.
(1) Sierra Leone Environment and Social Regulations for Mining, March 2012, Sixth Schedule: SIA Standards. p. 73
ERM will conduct a groundwater assessment for the Port and rail Extension
and Mine areas separately, as described below.
Preliminary outputs from the modelling effort would be based on the water
balance within the defined drainage areas, and would be developed based on
digital elevation data obtained from the satellite imagery. This model can be
used to help identify potential no-go areas based on desired setback distances
from surface water bodies, flow paths from any point within the study area
towards known sensitive groundwater receptors, and optimize the placement
of groundwater monitoring wells if required. Furthermore the watershed and
hydrology model will assist in selecting sampling points for the surface water
baseline.
Hydrocensus
Selected water levels and water quality data will be collected during a wet and
dry season hydrocensus from the following source(s):
For the mine site, selected water levels and water quality data will be collected
during a wet and dry season hydrocensus from the following source(s):
Groundwater impacts will be identified and quantified for the different stages,
including: construction, commissioning, operational, decommissioning and
post-closure phases for the proposed project. Numerical modelling techniques
will be used in the quantification of potential water impacts, as required.
ERM is of the understanding that the ARD/ML assessment for the Tonkolili
Iron Ore Project is to consider only the following mine facilities:
ERM proposes to follow an approach for the Tonkolili Iron Ore Project
ARD/ML study which is based fundamentally on the recommended approach
to drainage-chemistry predictions in British Columbia, as published in Price et
al. (1997).
Waste rocks;
Ore;
Overburden;
Soils underlying or adjacent to mine-related facilities; and
Process tailings material.
ERM will develop a conceptual model of key geochemical and flow processes
associated with each of the mining facilities under consideration in this scope
of work, which ERM currently assumes to be the open pits, the waste rock
ERM will develop a strategy for sampling and analysis of geological materials,
mine wastes and water resources for the ARD/ML study. The sampling and
analytical strategy should aim to identify and characterise the following for
materials (geological and mine wastes) that will be exposed, disturbed or
deposited during the proposed mining activities:
Net acid generation (NAG) testing per the methodology of Miller et al.,
1997. This includes determination of paste pH, sulphur species and mobile
metals under conditions of complete sulphide oxidation, thereby
representing a worst-case scenario;
Statistical analysis of the above static test results will raise our understanding
of the spatial variability of key variables of concern. This understanding will
assist in deriving an appropriate protocol to generate composite rock samples,
which will then be subjected to further static testing, which may include:
These collected soil samples will be tested for geohydraulic properties such as
particle size distribution, moisture retention, bulk density and (possibly) in-
situ permeability by field test methods. This data will inform the geochemical
model.
Geochemical Modelling
ERM will ensure that the scheduling of the geochemical assessment ties in
with the overall ESIA / EMPR schedule. Note that humidity cell testing of
The numerical model will be the mathematical expression of the CSM. Field
data, such as groundwater levels, aquifer hydrogeological characteristics,
thickness, recharge and boundaries will be used to construct and calibrate the
groundwater flow and contaminant transport model. This calibrated model
will be used to carry out scenario modelling to develop a preliminary estimate
of the long-term groundwater quality and water level impacts.
Hydrologic and surface water quality data will be needed to support the
baseline analysis and impact assessment. Baseline water data are essential for
several reasons: stream flow hydrographs will assist in the development of the
mine water management plan and will establish a baseline hydrology to
compare to performance standards, and will drive the scope of the monitoring
program. The following key areas should be addressed with respect to surface
water management:
Water quality data are important not just for understanding the effects of mine
water and surface runoff discharges, but in establishing realistic performance
standards for the design. Surface water quality data are also essential for the
aquatic habitat and downstream water use analysis required in other specialist
studies, the EIA, and the EMP/monitoring program. If sufficient data are not
available, we will suggest a baseline water quality data campaign that will
address the other resource impact needs as well as the mine water
management design. Cognizance will be made as to the existing surface water
samples taken and analysed under the current scope. In addition to the above
mine-site related surface water considerations, activities associated with the
port facility have the potential of impacting the water quality of the Sierra
Leone Estuary.
ERM proposes to assess the impacts of these activities in the vicinity of the
Port facility. This analysis will quantify the impacts on water quality
characteristics such as turbidity, dissolved oxygen, temperature, and pH
associated with the operations. These impacts will be compared to baseline
conditions in order to assess the relative potential impairment of water quality
due to port activities.
Scope of Work
The water resources scope includes two elements: 1) the land-side hydrology
and water quality associated with the mine expansion, mine facilities and the
railway; and 2) the port and waterside facilities and activities including
dredging, dredge material management, waterside infrastructure and
maintenance. We understand that the landside conditions are largely an
expansion of current activities, including, we assume, a set of baseline data
and a monitoring program. We have therefore assumed minimal additional
data collection on the landside.
Drainage control to manage rainfall within the pit limits to be the focus of
mine pit water management, and this study will provide required inputs
to that process;
Surveying of three (3) stream cross-sections with three to four transects per
site to allow development of rating curves on the smaller streams and
water courses at appropriate positions for the purposes of high flood
water level calculations, and model calibration (hydrologic modelling by
the mine water engineer). We assume that AML or their in-country
surveyor will assist with the survey of such transects. We have included
the purchase of data loggers in our expenses. These points should be used
as sampling points for AMLs long-term water sampling programme. We
have assumed that gauging stations will be deployed at these sites. We
assume that the deployment and monitoring of these gauges will be
executed by in-country subcontractors after initial set-up and procedure
assistance from ERM. We have assumed that three such points will be
established in the mine expansion area and railroad area. The scoping,
data review and ToR process will refine the locations. If more sites are
required, the budget and scope will be updated to reflect such changes as
may be required by the data gap, scoping and ToR processes;
ADCP velocity survey of Tagrin Port. This survey will be conducted over
the course of at least 1 or 2 tidal cycles and will provide velocity profiles to
be used in the dredge plume analysis;
Some sampling was undertaken as part of the Phase 1 EIA. ERM assumes that
this data will be available and will be analysed and used to supplement the
any additional surveys proposed. We understand that data collection will
likely continue beyond the delivery of the EIA. Post ESIA, ERM will develop a
scope, sampling locations, work plan, parameter list and cost estimate for the
field campaign for a water quality and hydrologic data collection program
Impact Assessment
Assumptions
The following limitations and assumptions form an explicit part of this Technical Bid:
The surface water (hydrological study) requires that rivers and streams in the project area
be surveyed for accurate cross-sections; this for more accurate determination of flood lines
and flood volumes and for calibration of rainfall-runoff models. It is assumed that AML
will make a Surveyor available for such studies if required;
Assumes that baseline water quality and other hydrologic data from the Phase I ESIA are
adequate to allow only the supplemental landside sampling and monitoring described in
this Bid.
Long term monitoring and sampling campaign support including equipment will be
provided by AML or its in-country field sampling consultant and that ERM will provide 1
senior staff for 2 weeks to organize the initial long term campaign and oversee the initial
portion of the baseline data campaign, including a monitoring guidance document and 1
day of training in English;
Long term monitoring costs are not included in our Commercial Bid
Assumes no landside hydrologic modelling;
Assumes only dredge plume modelling for waterside facilities;
Assumes that the scoping or data gap analysis does not require significant changes to this
scope;
Similarly, it is assumed that the Sierra Leone Estuary Bathymetry in the vicinity of Tagrin
Port will be provided to ERM from AML or its contractors. In the absence of bathymetric
data, a one-time survey (not included in this scope) will be necessary;
Should monitoring of surface flows be required, it is assumed that V-notches on site will be
surveyed and monitored by AML staff. The cost of loggers at three sites has been provided
in our Commercial Bid and
It is assumed that precipitation data, Digital Elevation Model (DEM) and land cover data
for the study area and mine site are available.
The approach to the air quality impact assessment will be based upon
IFC/World Bank guidance and international best-practice guidance referred
to by the IFC.
describe the legislative and regulatory context for the proposed project;
assess the overall impact of the construction and operational phases of the
proposed project, using national and international Ambient Air Quality
Standards and guidelines to describe the impacts in terms of their nature,
duration and frequency of occurrence and the severity of the impact in the
ambient environment using a standardised impact rating system;
compile a specialist study report that includes a description of all data, the
methodology used, assumptions that have been made, model results
(including in the form of isopleth maps), assessment of impacts, and
recommendations for mitigation; and
compile an Air Quality Management Plan for air quality, taking into
consideration built in and committed mitigation.
emissions of particulate matter (as PM10 and PM2.5) and airborne and
deposited dust from the mining, processing, handling and transportation
of ore; and
ERM understand that there is only very limited exiting data available. Given
the importance of air quality for mining projects, and the sensitivity of the
receiving environment, ERM propose to design and implement a baseline air
quality monitoring survey. Consideration of the baseline will be made as
The key pollutants of interest identified at this stage include: PM10, PM2.5, dust,
NOx, NO2 and SO2. The baseline monitoring will identify the concentrations of
these pollutants at key receptor locations. For the purpose of the monitoring,
sensitive human receptors are primarily those communities identified as
living close to the mine or port infrastructure or rail route. Sensitive ecological
receptors in the form of the Ramsar site and protected forest have been
identified, and are included in the scope.
Deployment: secure site required, strapped to suitable post (i.e. fence post,
lamp post, telegraph pole etc.) or placed on ground and tethered,
depending on local ground conditions.
On the basis of the understanding of the sources identified for the mine,
railway and port, an emissions inventory will be developed. For the mine, the
emissions inventory will be developed primarily from guidance set out in NPi
produced by the Australian Government and USEPA AP-42 emissions
database. Key input data will include, the tonnages of ore produced, vehicle
specifications, distances travelled by vehicles, and fuel specifications and use.
For the railway, the emissions inventory will reflect emissions arising from the
locomotives and wagons, and will be based upon an understanding of the
numbers of train movements, locomotive specifications and fuel
specifications. If required, emission factors from NPi and AP-42 will be
utilised. For the port, the emissions inventory will need to consider the
tonnages of ore handled, equipment location and specification, stockpile size
and location, conveyor distances, and fuel specifications and use.
Definition of Significance
Input Information
The assessment process will not identify impacts before mitigation and after
mitigation but instead will present the predicted impacts with the inclusion of
built in mitigation. Using this approach in developing the assessment allows
focus on the key issues and identification of any critical or major residual
impacts. Following the identification of any significant impacts, any additional
mitigation, controls, or operational monitoring will be identified along with
the likely effectiveness of any such controls.
ERM assume that all mine design information will be available in a timely manner, will not
be subject to significant change, and where required, will be available in the correct format;
ERM assume that the design of the proposed mine operations and transport arrangements
will not be subject to significant change. Any such changes may necessitate reassessment
and remodelling, which may incur additional costs and delays; and
No detailed consideration will be made of cumulative impacts associated with other
schemes operational or proposed in the vicinity of the mine. It is anticipated that some
schemes may be in place that have the potential for cumulative impacts. However details of
such schemes are likely to be difficult to obtain in any meaningful manner. Where required,
cumulative impacts will be discussed in broad terms in line with the guidance set out by
the IFC. If specific requests are made for assessment of cumulative impacts, these may
incur additional costs.
Equipment costs for PM10 air quality monitoring are included as an optional extra to the
expenses provided in our Commercial Bid..
Scope of Assessment
Underwater noise;
the 200km corridor covering the standard gauge rail option from Tagrin to
Tonkolili, as there is no significant difference between a narrow gauge and
standard gauge railway in terms of noise emissions and that a significant
part of the corridor (160 km) has an existing railway in operation.
the preferred design option for Tagrin Port (October 2012) as described in
the Revised TOR for the Phase ESIA;
Expansion of mining from Phase 1 to Phase 2 - Kasafoni pit and new waste
rock dump areas.
Approach
Conduct a review of the Phase 1 ESHIA and other studies relevant to the
project or the area:
Assess the baseline noise environment of the (extended) project area and
evaluate the suitability of baseline data from Phase 1 to inform Phase 2
assessments;
Measure existing noise, sources on the mine site, railway and Pepel Port to
be used as inputs for predictive noise modelling;
Measurement locations for each area will be finalised when on-site and once
further information is provided on the various processes and production
phases and potential sensitive receptors have been established. ERM
recommends that long-term unattended measurements are undertaken over a
minimum period of 24 hours at the most sensitive (or most accessible
receivers); along with short-term (15-minute period) attended measurements
at all locations during the day and night period wherever possible to
characterise the existing ambient noise levels.
Measure existing railway noise, existing noise sources on the mine site to
be used as inputs for predictive noise modelling;
Measure existing noise emissions from the Pepel Port to inform the
cumulative impact assessment and predictive modelling for the Tagrin
Port operations;
ERM has allowed for up to two mining scenarios and a single railway
operational scenario to be modelled;
Compare the resultant noise levels to the noise impact assessment criteria
and determine the magnitude of potential impacts at noise sensitive
receiver locations;
Write a noise, vibration and blasting management and monitoring plan for
the operation.
Noise Modelling
Brel & Kjrs Predictor 7810 (Version 8.1) noise modelling software package
will be utilised to calculate noise levels using the ISO 9613.1 industrial noise
propagation algorithms (international method for general purpose, 1/1
octaves). The Predictor software package allows topographic details to be
combined with ground regions, water, grass, significant building structures
etc. and project specific assessment locations, to create a detailed and accurate
representation of the site and surrounding area. Noise emission sources
deemed representative of worst-case operating conditions under each scenario
can be placed at locations within the site area.
The noise model shall allow quantification of noise levels from multiple
sources, based on sound pressures or sound pressure levels emitted from the
key plant components, as defined in the project design. The model shall
Blasting Assessment
Blasting has two potential effects being blast overpressure noise and ground-
borne vibration. Both overpressure and ground-borne vibration from blasting
are in most cases related to the Maximum Instantaneous Charge (MIC) of the
blast and the distance from the blast to the receptor.
ERM will quantify overpressure noise and ground-borne vibration associated
with blasting within the site, and make in-principle recommendations to assist
blast engineers e.g. attention that should be adopted during the design of blast
patterns and MIC that should be used.
ERM propose to measure blasting emissions from existing operations.
Analysis of blast data allows the development of a specific prediction tool
called a site law and is able to provide a higher confidence levels in
predicted blasting emissions from future operations, rather than a generic
blasting assessment.
The following assumptions have been made to conduct the scope of works outlined.
Baseline noise survey for the Tagrin port options and railway extension is based from
Lungi and AML are assumed to provide vehicles, drivers and accommodation;
Mine, existing railway and Pepel port noise surveys are from being based at the mine
where AML are assumed to provide vehicle, drivers and accommodation;
All fee estimates are inclusive of travel costs and visa etc.
Additional Work
The assessment will be based on the proposed project design inclusive of noise
mitigation controls identified prior to the design freeze. Once the design is
fixed, the assessment will be undertaken and any changes to the design after
the design freeze could incur additional work. Where significant noise
impacts are identified and further assessment is required, such as modelling
the effect of additional noise mitigation would also been deemed as additional
work and is not included in the proposed scope of work. If source terms and
equipment data is deemed to be insufficient, ERM may need to conduct sound
power level measurements for relevant plant and equipment on site, if
required. Using measured data of the actual equipment in use on the site will
provide a high level of certainty in the predictions from the model.
With regards to the site visits ERM has not allowed for delays due to
unsuitable weather for noise monitoring or unplanned plant shutdowns or
breakdowns.
ERM understand that the mine area will amount to approximately 35km2,
including pits, tailings storage facility and water impoundments, and this area
lacks any soil baseline information. Conversely, intrusive soil investigations
have been undertaken for most of the landside port and rail areas (for Port
Options 1 and 3). This bid assumes that this data is available and is of
sufficient spatial coverage and includes analytical data to support a soil
mapping and soil resource evaluation. Therefore, ERM assume that only
intrusive soil sampling works are required for the mine area.
Results from the mine site investigations will be integrated and assessed
collectively with the existing data, utilising previous site investigation reports
and the updated satellite imagery supplied as part of the data package. The
soil study will focus on the rehabilitation potential of the soils in the study
areas as well as the potential impact resulting from the loss of actual or
A specialist soil survey will be conducted in the mine area in order to achieve
a consistent understanding of the soil patterns occurring across the study
areas. This will include the TSF and Mawuru river area. The objectives of the
integrated study will be to identify and determine the presence, distribution
and extent of soil types in the preferred port and rail areas in a detailed
manner.
ERM propose to undertake preliminary soil mapping using the existing site
investigation and mapping data for the port. This will develop a soil model for
the observed toposequences in these areas and extend to cover the mine and
the 40 km rail route.
The topsoil (0-300 mm) and subsoil (300-600 mm) of the dominant soil forms
will be sampled and analysed for soil acidity, fertility and textural indicators
as follows:
Soil properties of soil units mapped during the detailed soil assessment will be
evaluated and categorized in land capability classes. This serves as a metric of
resource value of the soil to be utilised in the understanding of the significance
Outputs
The soil mapping exercise will be documented in a Soils Baseline Report in the
EIA reports, including a Soils Map, Land Capability map, and details
contributing to the Land Use map.
Desktop Study
Following review of the existing data, ERM will establish a study area for
terrestrial ecology specific to the Phase 2 activities. Based on the RFT,
ecological data exist for approximately 40% of the Tagrin site, 20% of the rail
corridor spur, and 10% of the rail corridor. The extent of existing ecological
information at the TSF, the impoundment, and the mine sites will be
determined during this desktop study and ERM will define a study area for
Phase 2 to supplement the existing data and provide complete coverage of
ecological data.
The field reports from each of the sampling events, as well as the previous
ecological data collected for the project will be synthesized into a detailed
baseline study to be included in each EIA. The characterization of soils and
vegetation types (such as dominant flora elements and composition) will be
depicted on an annotated map to be included in the EIAs to show the
distribution of habitats over the affected area. Any sensitive areas, including
the RAMSAR site, will be identified relative to biological diversity, pristine,
rare or unique native habitats.
The mapping of mangroves, if any, within the study area surrounding Port
Pepel is anticipated to overlap with both the Aquatic Ecology study and the
social and cultural technical studies due to the potential sacred nature of
The major faunal habitats identified during a desktop review (using satellite
imagery) of the study area will be confirmed through in-field sampling. ERM
will prepare a detailed baseline study plan in concert with the AML specialists
to determine the most appropriate methodology that maximizes accessibility,
health, safety, and the opportunity to observe wildlife habitat and their signs.
The AML specialists will implement the field components of the plan with
oversight provided by ERM.
Where there is substantial overlap with faunal issues between the Aquatic
Ecology and Terrestrial Ecology technical disciplines, and ERM technical
specialists will work together to formulate effective inspection locations and
procedures to maximize field efforts for each technical discipline.
The main objective of the impact assessment is to assess the direct and indirect
environmental impacts of the project on the flora and vegetation communities
of the Terrestrial Ecology study area. Primary tasks will include:
Impact identification and assessment will focus on (but not be limited to) the
following:
The main objective of the impact assessment is to assess the direct and indirect
environmental impacts of the project on the mammals, reptiles and
amphibians, and rare and endangered species of the terrestrial ecology study
area. Primary tasks will include:
The main objective of the impact assessment is to assess the direct and indirect
environmental impacts of the project on birds and their habitat within the
terrestrial ecology study area.
Impact identification and assessment will focus on (but not be limited to) the
following:
The following limitations and assumptions form an explicit part of this assessment:
ERM understands that the AML specialists will implement the field sampling required for
terrestrial ecology, including the bird surveys, at no cost to ERM. ERM will provide
oversight with the field implementation;
The coverage of the high resolution satellite imagery that has been purchased already by
AML is not defined; therefore, budget has been included to cover the cost of remaining
portions of aerials with near infra-red sensor imagery.
Port Loading Facilities include aquatic systems. These will be assessed for
the preferred port option;
A total of 18 sites are therefore considered necessary for this study, and costs
assume the assessment of two aquatic sites per day. Aquatic assessments will
be conducted to meet the 2012 IFC Performance Standards, which require
environmental resources to be assessed through more than a single field visit,
in order to obtain an overview of seasonal variations and migratory species
dependent on the respective ecosystems. Separate High Flow (October /
November) and Low Flow (April) assessments are therefore proposed.
Methodology
The study needs to incorporate different seasons, and aquatic studies need to
include both High Flow (Oct / Nov) and Low Flow (Mar / Apr) assessments.
Timing for initiation of the study will determine which of these assessments
are in the first and second field visits.
As per the ToR, it is understood that this component required for the ESIA,
will be the subject of a separate tendered work package. The results of this
separate work package will be made available so as to incorporate them into
the ESIA for the Port and Rail.
A key consideration which must form the basis of baseline data pertaining to
the marine and coastal environment is the designation of the whole of the
Sierra Leone River Estuary as a Ramsar site (Box 4.2).
Sierra Leone River Estuary. 13/12/99; 295,000 ha; 0837'N 01303'W. The Estuary, near
Freetown Peninsula, is dominated by mangrove systems, with lowland coastal plains to the
north. As it enters the Atlantic Ocean, the estuary widens to about 11km and deepens to form a
natural harbour said to be the third largest in the world. 19% of Sierra Leone's total mangrove is
included within the site. The site exceeds the 1% threshold for at least eight water bird species,
namely Ringed and Kentish Plovers, Sanderling, Curlew Sandpiper, Whimbrel, Greenshank
and Redshank, and Western Reef Heron; breeding habitat is supported for some of these. More
than 20,000 individuals have been recorded for some water bird species, and in 1995 more than
10,000 were recorded for 36 species. The Estuary is threatened by vegetation clearance and
unsustainable fishing, and efforts are being made strictly to conserve certain core areas within
the site. Vast areas of untouched mangrove forest still exist, however, and traditional fishing
and agro-forestry for fuel wood can be managed sustainably in collaboration with an existing
EU-funded Artisanal Fishing Community Development Programme. Fine beaches in some
areas provide hope for well-managed tourist development, especially in light of the presence of
an historic slave castle on Bunce Island, and so ecotourism development is considering
promising. Ramsar site no. 1014. Most recent RIS information.
Source: http://ramsar.wetlands.org/Database/Searchforsites/tabid/765/Default.aspx
Social Baseline
There are a variety of elements which form a social baseline as provided in Box
4.3 below.
Pepel x 5 settlements
TOTAL 40 settlements
can they fish elsewhere and how easily could they move to other locations
to fish?
A fish catch survey will also be carried out. The social fisheries assessment
will complement the marine survey aspect of the baseline data collection that
will focus on the ecology of the fisheries and their importance.
Prior to social baseline data collection activities, ERM will work with AML
and DDC to plan fieldwork and to develop the field tools such as interview
protocols, survey forms and data entry spreadsheet. As mentioned in Section
4.2.6 these activities will be carried out at the same time as scoping disclosure.
(1) Government of Sierra Leone, Sierra Leone Integrated Household Survey (SLIHS) 2003/2004. Published November 2007. p. 3
Social team project manager to oversee all field activities and carry out
consultation meetings with the national and district level authorities
together with an experienced social development consultant provided by
AML;
The corridor will be divided into two areas; Mine lease area and rail east
and port area and rail west. Therefore ERM proposes two data collection
and consultation coordinators to manage activities in these areas; and
For each of the two teams described above, it is anticipate that ERM will
require the following DDC/Sullay Kamara consultants:
Public participation/consultation and focus group team x 8 people
Key informant interviews (district and local level) & settlement level
surveys x 2 people
Enumerators (household survey) x 8 people
Data entry team x 4 people
AML Field Officers will be required to assist with field planning and to
accompany social teams;
A local cultural heritage expert will also work closely with the social team
to provide local context with regard to archaeological and sacred areas.
Full details of the cultural heritage study are provided in Task 11.
The SIA will consider the following elements that have already been affected
by phase 1 and those that will potentially be impacted by Phase 2 of AMLs
operations, both positively and negatively:
Health;
In-migration;
Data related to these elements collected during the social baseline survey will
be used to inform the EIA and SIA. However, other impacts identified during
public participation activities will also be considered. All impacts will be
ranked using an integrated methodology. Mitigation measures will be
proposed to minimise impacts in accordance with the IFC Performance
Standards and local requirements.
ERM will conduct cultural heritage baseline surveys for the Tonkolili mine
site, and within the Tagrin port and 40km railway spur areas. This will
include an assessment of archaeological sites, cemeteries and other
sacred/religious sites. It will be important to visit Bunce Island, where a slave
castle is located, as this is a known tourist attraction located close to the
Ramsar site/Sierra Leone Estuary.
This survey will involve a ground truthing exercise comprising of visits to the
relevant sites in each community with a GPS to identify the exact locations of
cultural/sacred sites and assessing the types of sites to capture and an
understanding of their cultural significance and importance to local
communities. This will be undertaken by a local expert with knowledge of
Sierra Leones cultural heritage. This data from the study will inform the
assessment of potential impacts to cultural heritage during the EIA-SIA
process.
Note: There are secret sites in Sierra Leone which are established by
traditional groups to perform ceremonies. Gathering data on the
location of these sites may be difficult and as such it may not be
possible to locate all significant sites during the survey. The
process for identification of these areas prior to construction will
be outlined in the cultural heritage section of the Social Impact
Management Plan (SMP) to be developed.
At this stage is unknown how many sites will be included in the survey. This
will be assessed during scoping. Any implications to the budget will be
discussed and agreed with AML.
The main objective of this task is to identify, describe, classify and assess the
direct and indirect impacts Tagrin port and the 40km rail extension on the
regions transportation. The Traffic Impact Assessment will assess vehicular
(i.e., car and truck) traffic, as well as rail traffic along the transport corridor
described in the RFT. The assessment will also cover assessing traffic related
impacts around the mine.
Field Studies
Under ERMs supervision, DDC will also count traffic at up to four locations
(primarily in the Tagrin Basin area, as specified in the RFT), for two days each
(one weekend day and one weekday). This methodology has been used for
other EIAs in Sierra Leone, and will provide a generalized level of information
about traffic and transportation conditions.
ERM will prepare a baseline study report summarizing the findings of the
desktop and field studies.
With this in mind, it is important to investigate the risks climate change poses
to new developments. This Climate Change Specialist Study will:
This activity will review the organizational boundaries and establish the GHG
operating and reporting boundaries for the AMLs carbon footprint.
Organisational boundaries, in this instance, will determine which operations
will be included, while operating boundaries determine which emission
causing activities will be included in the Carbon Footprint, in terms of scopes
1 and 2 as illustrated in Figure 4.2.
It has been anticipated that Scope 3, or indirect, emissions will be excluded for
the purposes of this study. Scope 3 emissions would typically include
emissions from outsourced activities, such as contractor vehicles and
employee business travel. Given that the footprint will be calculated on a
hypothetical basis, the uncertainty associated with Scope 3 emissions is such
that these may not be quantifiable until the sites are operational. This is in line
with IFC Performance Standard 3 which indicates that the client will quantify
direct emissions from the facilities owned or controlled within the physical
project boundary and indirect emissions associated with the off-site
production of power used by the project (i.e. Scope 1 and 2 emissions).
In order to develop the footprint boundary, ERM will review the project
design information provided by AML and will discuss the project and
potential emission sources with African Minerals personnel in order to:
The carbon footprint calculations will be done for the operational phase of the
proposed project only. Emissions from construction and decommissioning
will not be quantified, as this type of assessment involves the assessment of
Scope 3 emissions which is outside the scope of the proposed footprint. An
operational Carbon Footprint will be determined for the development based
on the project description, project design specifications and information
collected from AML as outlined above.
ERM will provide for Geographic Information Systems (GIS) support during
the EIA and SIA processes. This shall include spatial data management, GIS
support and mapping for the proposed project.
Assumptions
The acquisition of data/information other than noted in this Bid is not provided for;
It is assumed that all data provided to ERM are digitally available in shape file format or
raster based formats and ready to use (i.e. no editing of raw data will be required and
spatially referenced);
No additional data capture is quoted for this Bid assumes that all the data is already
available in digital format (CAD, GIS and imagery) other than what is quoted above;
It is assumed that some of the data sets will have to be re-projected and/or converted from
other digital formats to ESRI shape file format; and
All data that has come from outside of ERM needs to referenced and contain metadata.
ERM will not be liable for the integrity of spatial data provided by other parties.
The project description will include descriptions of facilities and activities that
are essential for the successful operation of the Project. We note that this step
ERM will review and consider strategic Project alternatives and document the
Project history and alternatives that have been considered in the past or are
still under consideration during the current studies. This will form an
important part of the information developed to inform and engage
stakeholders in the process, and particularly to brief the affected communities
during the consultations.
Term Definition
Impact Direction
An impact that is considered to represent an improvement on the
Positive
baseline or introduces a positive change.
Negative An impact that is considered to represent an adverse change from the
ERM will complete a first round assessment to predict impacts and evaluate
their likely significance, so that mitigation of significant impacts can be
developed with the engineers and Client during the on-going design studies.
This will be an iterative process of identifying options for mitigation,
Once the initial assessment is complete the areas in which significant impacts
on the physical, natural, social, economic and cultural environment of the
Projects area of influence are likely to occur will be clearly identified with an
evaluation of their severity. The evaluation of significance will take into
account the scale, geographic extent and distribution, duration and frequency,
reversibility, and probability of occurrence of changes in environmental and
social conditions, and the value, sensitivity and ability to adapt (resilience) of
affected resources and receptors. It will also explicitly take account of the
perception of the importance of the impact by local communities. The criteria
for evaluation of significance will be clearly explained in relation to each type
of impact.
Where there is the potential for significant adverse impacts, options for
mitigation will be explored. These will include measures to prevent or reduce
impacts where possible, and where impacts are unavoidable, to remedy them
or to provide compensation or offsetting. Options for delivering or enhancing
benefits from the Project will also be identified.
Once the preferred scheme is defined and mitigation measures have been
agreed, ERM will review the findings of the initial assessment to provide a
prediction and evaluation of residual impacts after mitigation. The results
will be reported in a comprehensive EIA report. This will be supported by a
series of specialist study reports presenting detailed findings from the three
main strands of work. The draft reports will be prepared for internal review
and approval prior to its wider disclosure (see below). We have assumed that
there will be one round of review and comment and that we will be provided
with one set of consolidated comments from AML.
There are no fixed timeframes in terms of the review period by the authorities
in terms of the Environmental and Social Regulations for the Minerals Sector,
ERM will provide three weeks of project management support during the
review process in terms of addressing any modifications to the scope of the
assessment or additional information that may be required. Where additional
studies or requirements, outside the scope of work of this bid, are requested
by the authorities, this will be discussed with AML in terms of potential
variations. This may include additional studies, public meeting or
engagement.
Once the draft EIA and SIA reports have been developed, disclosure will need
to be undertaken. This process should be undertaken in collaboration with the
EPA-SL.
We have assumed that the same approach will be applied to the EIA-SIA
disclosure as was used during the initial round of engagement held during the
Scoping Phase (Section 4.2.9).
ERM will prepare the suite of management plans, which are required for
submission with the EIAs (Section 4.6.1) and SIAs (Section 4.6.2) in
compliance with the documentary requirement established in Section 29 of the
Environmental and Social Regulations for the Minerals Sector, (Draft) and
applicable schedules. At this stage, the suite of plans is limited to those
defined below. It is important to note that these will be framework
management plans.
4.5.2 Task 2- Mine Closure Plan (only applicable to Tonkolili Mine EIA)
ERM will update the current AML Mine Closure Plan (MCP) for joint
submission with the EIA and SIA. The MCP will comply with the
requirements established in Schedule 9 of the Regulations1 for the Minerals
Sector, which provide a guideline as to the contents of the Closure Plan.
Section 3 Description of social and local economic values and any sensitive
sites and potential impacts
Section 4 Management measures for each social and local economic value.
According to Section 139(1) of the Mines and Minerals Act 2009, and the
Regulations1, the holder of a mining license is required to have and implement
a community development agreement with the host community. The
Community development agreement is based on the Community
Development Plan (CDP) and must include:
The structure of the CDPs will follow the requirements of the Regulations.
This plan will assess the effectiveness of socio-economic and health control
measures (preventive measures, mitigation and compensation) set forth in the
SMP. Reference must be made to the socio-economic, health standards and
other applicable standards.
These plans will contain a Social and Economic Risk Assessment (SERA) and a
contingency plan. This will be compiled to analyse the likelihood of an
extreme accidental or natural event causing major effects on the social sector
and human health. Socio-Economic Contingency Plan (SECP) will set out
control measures to be applied in case of the emergency situations identified
in the SERA.
This is a conceptual closure plan for mining operations and this plan will form
the basis for developing a comprehensive MCP as required in Section 47 and
the Ninth Schedule of the Regulations.
In Sierra Leone, the 2009 Mines and Minerals Act states that any mining licence
applicant or mining licence holder required by this or any other law to submit
an environmental impact assessment, shall consult the public to introduce the
project to the public and to verify possible impacts of the project from
stakeholders perspectives.
The Environmental Protection Act 2000 states that the EIA should be circulated
to professional associations, Government Ministries and NGOs for comments.
The Director of the Ministry of Environment will make the EIA-SIA open to
comment through publication in 2 consecutive issues of the Gazette and 2
newspapers (with an interval of at least 7 days). Public comments shall be
submitted to the Director within 14 days of the last publication. Following
this process, AML they will have 21 days to respond.
The above is further supported in the draft Environmental and Social Regulations
for the Minerals Sector, 2011, and specifically with respect to Section 15 and 16
that mandates fair and transparent public consultation throughout the life of
the mine.
5.1.1 Communication and Public Participation Plans (otherwise known by the IFC
as Stakeholder Engagement Plans)
Additionally, the CPPPs will present the process for identifying and mapping
stakeholders according to their influence on the project, their level of interest
and the degree to which the project might affect them. It will also include
detail the best means by which to communicate with stakeholders. Those
living or working in the project vicinity, for example, will require more
information and dialogue regarding Project activities than those indirectly
affected, and the means by which this engagement is delivered will need to
differ.
Individuals or groups within the project area of influence who could experience adverse impacts from the
proposed project more severely than others based on their vulnerable or disadvantaged status. This status
may stem from an individual's or group's race, colour, sex, language, religion, political, or other opinion,
national or social origin, property, birth or other status. In addition other factors should be considered
such as gender, ethnicity, culture, sickness, physical or mental disability, poverty or economic
disadvantage, and dependence on unique natural resources.
Source: IFC Glossary of Terms (2006) (1)
(1) IFC Glossary of Terms. IFC Policy & Performance and Guidance Notes. July 2006. Available at:
http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/pol_PerformanceStandards2006_glossary/$FILE/Gloss
ary+of+Terms.pdf [Accessed 28.05.12]
Note: It is currently assumed that the 500m corridor is divided into 250m either side of
the centreline.
During the EIA-SIA process, ERM proposes to carry out two stages of
consultation in order to ensure information dissemination and participation in
Project planning and disclosure activities, as presented in Figure 5.1 below.
Consultation for the mine and for the port and rail areas will be carried out
concurrently. It should be noted that as part as the pre-scoping tour, ERM will
consult with national, district and local level representatives including the
Paramount Chiefs and community representatives such as youth, women and
other leaders.
(1) Sierra Leone Environment and Social Regulations for Mining, March 2012, Sixth Schedule: SIA Standards. p. 73
Stage 2: EIA-SIA Disclosure once the draft reports have been submitted to
the Environmental Protection Agency (EPA-SL) for review, all the
stakeholders will be re-visited and invited to comment on the impacts
identified, development benefits envisioned and the appropriateness of
proposed mitigation measures using the same that was taken during stage 1.
The reports will also be made publically available for comment through a
variety of mediums which may include periodic radio broadcasts, publication
at local town halls, community halls and/or public notice boards.
AML, with support from ERM, will have 21 days to address all the issues
raised and documented during EIA-SIA disclosure.
Question and answer (Q&A) document to ensure accuracy and consistency of responses to
questions. This will also aid the management of expectations raised by stakeholders.
PowerPoint presentation describing the project and EIA-SIA process, to be used with
regulatory authorities and NGOs where appropriate.
Participatory consultation tools to be used with local communities to describe potential project
impacts and seek feedback.
Excel consultation database for tracking issues raised. ERM will prepare a basic consultation
database in excel which will include contact details, dates of meetings, issues raised and by
who, actions and dates.
ERM will work closely with AML and DDC/Sullay Kamara to organise
meetings;
ERM will work with AML to cluster settlement in the 500m corridor in
order to reduce the number of meetings and time required to conduct
consultation. Clustering will be dependent on available transport to
communities to a central location, weather conditions and the ability to
access settlements and distance between settlements, clustering
settlements within a short walking distance;
Due to high levels of illiteracy in settlements in the Project area, ERM will
work with DDC/ Sullay Kamara to develop a participatory approach to
consultation to ensure a fully inclusive process of engagement.
Scoping disclosure will be carried out at the same time as social baseline data
collection activities as described in Section 4.3.10 of this Bid.
As mentioned in the ToR, dedicated representatives from the AML Community Liaison
Team will be available to assist DDC and ERM with stakeholder mapping and public
participation process, including national, district and settlement level meetings.
AML will finance all expenses associated with public participation meetings e.g. hire of
venues, adverts and radio announcements, printing and distribution of documentation and
notices, travel requirements, PA equipment, chairs, etc., libations for chiefs/elders, and
travel and subsistence costs for staff.
It is assumed that all on-site logistical support will be provided by AML during the
meetings e.g. car hire, provision of water, accommodation etc.
Our preliminary project schedule presented in Table 6.1 is a draft based on our
current knowledge of the project and dependent on AMLs timelines for
submitting the EIA and SIA reports to the authorities. All reports will be
prepared concurrently. Due to resourcing constraints over the Christmas
period, the 15th December to 15th January is not considered in this timeframe.
Milestone Date
Kick-off meeting Within 2 weeks of Notice to Proceed
Scoping Visit Within 4 weeks of Kick-off Meeting
Scoping Report Within 4 weeks of end of Scoping Visit
Environment Baseline Survey Dry season February 2013
Wet season August 2013
Social Baseline Survey April 2013
Public Participation Stage 1 April 2013
Draft EIA & SIAs September 2013
Public Participation Stage 2 November/December 2013
Final EIA & SIAs January 2014
The team has been structured to ensure that we have a mix of international
specialists that have extensive experience in managing ESIAs for large mining
developments to IFC standards.
ERM can offer a highly experience Project Management Team based in South
Africa who will be the key contacts throughout the duration of the project
managing the project schedule, the financial aspects of the project and alike.
We propose Mike Everett as Partner-in-Charge (PIC) who has experience of
managing project like this in Sierra Leone, who will be supported by a Project
Manager (Stephanie Gopaul) and a Programme Manager (Jonathan Van Gool).
The Project Manager supports the PIC with day-to-day client contact,
ensuring high quality outputs, team briefings, and resource and financial
monitoring..
In our approach, specialised subcontractors will carry out parts of the work
under the close management, control, and Quality Assurance oversight of
ERM. A system of controls will need to be in place to assure AML of the
smooth execution of the project and delivery of high quality deliverables.
Management of the following is thus of primary concern and focus:
Figure 7.1 presents our proposed overall core team which has been organised
to ensure a blend of local and international expertise with extensive
experience in ESIAs for large mining developments to international standards.
Our core social team is presented in Figure 7.2. The remainder of this section
provides a brief description of these team members. Full CVs are provided in
Annex B. CVs for other team members included in the budget, but not in the
core teams will be available upon request.
Partner in
Charge
Mike
Everett
Project Programme
Manager Manager
Dieter Jonathan
Rodewald Van Gool
Transportation Aquatic Terrestrial Groundwater Surface water Soils Air Quality Greenhouse Noise
Jessica Andrew gases
Ben Ward Chris Rod
Caldwell Kevin
Sussman Hazel- Simon
Stefan Leahy/ Linnett/
Harry Zahakos/ Marshall/ Clarke/
Muller Dale Justin
Shwet Prakash Ioanna Lisa
Dalan Hutton Kmelisch
Gegisan Constable
Development Field Survey
Consultants/ Natural
Sullay Kamara Scientific
Services
(NSS)
Dalan
Development
Consultants
Figure 7.2 Social Team Organogram
Social Lead
Tracey Draper
Tracey has benchmarked leading oil and gas and mining companies on
biodiversity and ecosystem services performance; worked in the forestry
sector in Botswana for the Ministry of Agriculture on Community Based
Natural Resource Management Projects; and worked in forest conservation
and livelihoods support in Nigeria. Recently she has also worked on SIAs for
mining projects in Greenland, Sierra Leone and Mali.
From her experience in Sub-Saharan Africa, the European Union and South
East Asia, three years of which spent in Malaysia, she has extensive experience
of managing both international and national large scale projects and surveys
and is an expert in socio-economic analysis, qualitative and quantitative
methods, participatory approaches, survey design and management, sampling
strategies and data analysis.
Over the last two years, Kim has also developed a retrospective compensation
action plan for a gas pipeline company in Nigeria, conducted a detailed due
diligence review of a Resettlement Policy Framework for a hydropower
project in Namibia & Angola, and has written a World Bank-compliant
resettlement action plan for a large-scale resettlement, also in Nigeria. She is
currently working on a RAP in Sierra Leone.
Mr. Sussman has prepared and managed EIS and EA evaluations of the land
use, transportation, visual/aesthetic, socioeconomic, and environmental
justice impacts of military airspace, natural gas drilling sites and pipelines,
hydroelectric projects, and other proposed facilities. He has also prepared
comprehensive plans and community plans for small and large cities and
unincorporated communities, with particular emphasis on the linkages
between land use, growth, and water resources. He has also developed and
evaluated regional land use scenarios; waterfront plans; and municipal
economic analyses. Mr. Sussman places emphasis on public presentations and
public engagement as a critical part of impact assessment and planning
projects. He is adept at managing public meetings, stakeholder interviews,
and other forms of information gathering.
Andrew has been the lead consultant in a number of projects in many parts of
Africa including South Africa, Tanzania, Mozambique, Botswana, Zambia,
Ethiopia, Sierra Leone and Liberia. His experience has involved baseline and
impact assessments for numerous Environmental and Social Impact
Assessment (ESIA) studies for the mining, oil and gas and infrastructure
sectors. His involvement has focussed on biodiversity conservation and
sustainable management of living natural resources. Andrews projects have
covered a diverse range of ecological studies including vegetation,
ornithological, other faunal, wetland and aquatic ecology assessments in a
diversity of habitats ranging from rainforests, savannahs, and grasslands to
extreme desert conditions.
Other project work has included life cycle planning for aluminium smelters,
environmental due diligence for a zinc mine in Ireland, numerous ESHIA
projects including a gold mine in Iran, a major LNG plant in Russia, oilfield
developments in Kazakhstan, Egypt and Libya, regional EIA and resource
assessment for offshore minerals in the Irish and North Seas, as well as
significant contribution to a community, health & safety and environment
guidebook for exploration geologists at a major global mining house. Kevin is
a proficient user of EVS/MVS (3D visualisation and animation software)
which, along with GIS and other geological software are powerful analysis
and presentation tools for geological structure and the disposition of
contaminants or resources within. Kevin will be responsible for the overall
management and execution of the soil specialist study.
She has completed a PhD in 2007 on the subject of air quality and
environmental justice, exploring sustainability issues of the UKs Local Air
Quality Management framework. Ioanna completed a placement during 2010
in the European Commissions Eco-Innovation Unit, working on a funding
stream for environmental technology projects for SMEs. The work included
the appraisal of environmental technology proposals, selected on the basis of
potential environmental benefits and with a clear focus on Life Cycle
Assessment. Ioanna has experience in a number of environmental disciplines
and endeavours to expand her knowledge base through continual
professional development and through collaborative work.
7.1.5 GIS
Ms. Yumkella has more than twenty years combined national and
International experience in the fields of demography, population studies and
public health. Ms. Yumkella has proven capability and experience in program
management, social science research and data collection, monitoring and
evaluation, program development, human resources for health (HRH),
Ms. Yumkella has also worked extensively in the private sector and lending
institutions and has consulted for World Bank, WHO, UNFPA, and
IntraHealth International /The Capacity Project during the past decade.
DDC will provide a field team who will carry out the collection of the baseline
data. They will also assist with stakeholder engagement, and with the
development of the impact assessment analysis and management plans.
Social Team
The social team will be responsible for conducting social surveys for the social
baseline report. They will also assist with stakeholder engagement and will
input into the development of the impact assessment analysis and
management plans in coordination with ERMs social specialists and Ms.
Yumkella. A sample of team names are listed below.
Environmental Team
The environment team will be responsible the environmental baseline data
collection. They will also input into the development of the impact
assessment analysis and management plans in coordination with ERMs
environmental specialists and Ms. Yumkella. The local team will include:
Every project is carried out under the oversight of a Partner in Charge. The
Partner in Charge is ultimately accountable for ensuring ERM understands
and applies the appropriate resources to meet the clients needs. The
Partner is required to maintain high-level contact with the client
throughout every project and is responsible for quality control and cost
management;
Effective project control systems are applied for monitoring and managing
project work plans and programmes, deliverables, resources and costs and
the Partner in Charge will undertake regular progress reviews with the
Project Manager to ensure these are working successfully to meet ERMs
obligations;
This regime is instituted for each and every project carried out by ERM.
Once the start-up work plan is complete, the Project Manager will brief the
team (internal and external). While task requirements and timing would have
been discussed in advance with each team member a final briefing will be
given using written team briefing notes or face-to-face.
If desired, we can include AMLs review and concurrence in the Work Order
process. This review process would ensure that we have a mutual
understanding of the work scope, schedule, and budgets and lays the
foundation for monitoring of task order performance.
Because of the technical nature of the work and schedule requirements of the
project, we will hold formal monthly status review meetings in which the task
manager and project manager will review technical, scheduling, and
budgetary progress assessments. The monthly status reviews will provide
inputs to the monthly progress reports, described below.