Mako Gold Project - rml.com.au · Mako Gold Project ESIA Non-Technical Summary FINAL REPORT 1- 1 I...

Environmental and Social Impact Assessment Report: Non-Technical Summary

FINAL REPORT

December 2015

Chapter 9 | Biological Impacts and Management Measures

MAKO GOLD PROJECT

Mako Gold Project

ESIA Non-Technical Summary

FINAL REPORT

EARTH SYSTEMS Environment | Water | Sustainability

Australian Business Number 42 120 062 544

RECORD DISTRIBUTION

Copy No. Company / Position Name

1 Toro Gold / Mako Exploration Company Paul Cannon

DOCUMENT REVISION LIST

Revision Status/Number Revision Date Description of Revision Approved By

Rev0 July 2015 Working Draft Nigel Murphy

Rev1 July 2015 Draft Nigel Murphy

Rev2 August 2015 Draft Nigel Murphy

Rev3 August 2015 Draft Nigel Murphy

Rev4 November 2015 Revised Nigel Murphy

Rev5 December 2015 Final Nigel Murphy

This report is not to be used for purposes other than that for which it was intended. Environmental conditions change with

time. The site conditions described in this report are based on observations made during fieldwork and on monitoring

results. Earth Systems does not imply that the site conditions described in this report are representative of past or future

conditions. Where this report is to be made available, either in part or in its entirety, to a third party, Earth Systems reserves

the right to review the information and documentation contained in the report and revisit and update findings, conclusions

and recommendations.

Mako Gold Project


FINAL REPORT

CONTENTS

1 INTRODUCTION ......................................................................................................... 1-1

1.1 Purpose of this Document .................................................................................................................................... 1-1

1.2 Project Overview ...................................................................................................................................................... 1-1

1.3 Project Proponent .................................................................................................................................................... 1-4

1.4 Environmental and Social Consultants ............................................................................................................. 1-4

1.4.1 Consultant‘s ESIA Experience ................................................................................................................ 1-4

1.4.2 Main Contributors to the ESIA ............................................................................................................... 1-5

1.5 ESIA Approach and Report Structure................................................................................................................ 1-5

1.5.1 ESIA Objectives ........................................................................................................................................... 1-5

1.5.2 Impact Assessment Approach .............................................................................................................. 1-5

1.5.3 ESIA Report Structure............................................................................................................................... 1-6

1.5.4 ESIA Specialist Studies and Data Sources ......................................................................................... 1-6

2 PROJECT BENEFITS AND NEEDS .............................................................................. 2-8

2.1 Benefits to Senegal .................................................................................................................................................. 2-8

2.1.1 Direct Economic Benefits ........................................................................................................................ 2-8

2.1.2 Indirect Economic Benefits .................................................................................................................... 2-9

2.2 Regional and Local Community Benefits ......................................................................................................... 2-9

3 POLICY, GUIDELINES AND LEGISLATIVE FRAMEWORK ....................................... 3-11

3.1 National Legislation and Regulations ............................................................................................................. 3-11

3.1.1 Senegalese ESIA Process and Permitting ........................................................................................ 3-11

3.1.2 Management of Water Resources ...................................................................................................... 3-12

3.1.3 Management of Land and Forest Resources .................................................................................. 3-12

3.1.4 Land Acquisition and Compensation ............................................................................................... 3-13

3.1.5 Management of Biodiversity ............................................................................................................... 3-13

3.2 Project Discharge Standards .............................................................................................................................. 3-14

3.3 Risk Assessment...................................................................................................................................................... 3-15

3.4 International Policies, Guidelines and Standards ........................................................................................ 3-15

3.5 Toro Gold Environmental and Social Commitments ................................................................................. 3-16

4 PROJECT DESCRIPTION ........................................................................................... 4-17

Mako Gold Project


FINAL REPORT

4.1 General Description .............................................................................................................................................. 4-17

4.1.1 Overview .................................................................................................................................................... 4-17

4.1.2 Mineral Resource ..................................................................................................................................... 4-17

4.1.3 Proposed Project Arrangement .......................................................................................................... 4-17

4.1.4 Project Development Area ................................................................................................................... 4-19

4.1.5 Mine Life and Schedule ......................................................................................................................... 4-19

4.2 Pre-Construction Phase ....................................................................................................................................... 4-19

4.3 Construction Phase ............................................................................................................................................... 4-20

4.4 Operation Phase ..................................................................................................................................................... 4-20

4.5 Decommissioning and Rehabilitation ............................................................................................................ 4-23

4.6 Staff 4-24

4.7 Accommodation ..................................................................................................................................................... 4-24

5 PROJECT ALTERNATIVES ......................................................................................... 5-25

5.1 Approach to Identification and Assessment of Alternatives .................................................................. 5-25

5.2 Mining Method ....................................................................................................................................................... 5-25

5.3 Waste Rock Management ................................................................................................................................... 5-25

5.4 Tailings Management Facility ............................................................................................................................ 5-26

5.5 Process Plant ............................................................................................................................................................ 5-27

5.6 Ore Stockpile ........................................................................................................................................................... 5-27

5.7 Water Supply and Management Options ...................................................................................................... 5-28

5.7.1 Water Supply Alternatives .................................................................................................................... 5-28

5.8 Access Roads............................................................................................................................................................ 5-28

5.9 Power Station .......................................................................................................................................................... 5-29

5.10 Workforce Accommodation Options .............................................................................................................. 5-29

5.11 Not Proceeding with the Project ...................................................................................................................... 5-29

6 PHYSICAL ENVIRONMENT SETTING ...................................................................... 6-31

7 BIOLOGICAL ENVIRONMENT SETTING .................................................................. 7-33

7.1 Priority Species and Habitats ............................................................................................................................. 7-33

7.2 The Niokolo-Koba National Park ....................................................................................................................... 7-35

7.3 West African Chimpanzee ................................................................................................................................... 7-35

7.4 The Gambia River ................................................................................................................................................... 7-37

8 SOCIO-ECONOMIC SETTING ................................................................................... 8-38

9 PHYSICAL IMPACTS ................................................................................................. 9-42

Mako Gold Project


FINAL REPORT

9.1 Hydrology, Hydrogeology and Water Quality .............................................................................................. 9-42

9.2 Other Key Environmental Aspects ................................................................................................................... 9-42

10 BIOLOGICAL IMPACTS .......................................................................................... 10-44

10.1 Terrestrial and Aquatic Biodiversity .............................................................................................................. 10-44

11 SOCIAL IMPACTS ................................................................................................... 11-46

11.1 Economic Development and Employment................................................................................................ 11-46

11.2 Displacement, Access and Land Use Impacts............................................................................................ 11-47

11.3 Cultural Heritage and Archaeology .............................................................................................................. 11-51

11.4 Other Community Impacts .............................................................................................................................. 11-51

12 NIOKOLO-KOBA NATIONAL PARK ....................................................................... 12-54

13 CUMULATIVE IMPACTS ......................................................................................... 13-56

14 STAKEHOLDER CONSULTATION AND PUBLIC INVOLVEMENT ......................... 14-57

14.1 Stakeholder Identification and Analysis ..................................................................................................... 14-57

14.2 Stakeholder Consultation Completed to Date ......................................................................................... 14-59

14.2.1 Summary of Consultation Outcomes ............................................................................................ 14-62

14.3 Continuing Consultation for the Life of the Project ................................................................................ 14-62

14.4 Grievance Management ................................................................................................................................... 14-62

14.5 Reporting to Stakeholders ............................................................................................................................... 14-63

15 MANAGEMENT AND MONITORING .................................................................... 15-64

15.1 Environmental Management System .......................................................................................................... 15-64

15.2 Monitoring............................................................................................................................................................. 15-65

15.3 Auditing and Review .......................................................................................................................................... 15-65

15.4 Rehabilitation and Closure .............................................................................................................................. 15-65

16 CONCLUSIONS ....................................................................................................... 16-66

Mako Gold Project


FINAL REPORT 1-1

1 INTRODUCTION

1.1 Purpose of this Document

An Environmental and Social Impact Assessment (ESIA) for the Mako Gold Project (hereafter 'the Project’) has

been prepared by Earth Systems for Mako Exploration Company. The Mako Gold Project consists of the

development of a gold ore mine and processing facility. The Project proponent, Mako Exploration Company

(hereafter ‘the Company’), is a fully-owned subsidiary of Toro Gold Limited, a gold exploration and development

company registered in the United Kingdom and focused on the West African region.

The ESIA, including management plans and other supporting documentation, has been prepared in

compliance with Senegalese regulatory requirements for environmental permitting of the Project, and in

accordance with Toro Gold’s internal Environmental and Social Performance Framework (ESPF) as well as

international best practice. The 2001 Environment Code, including the implementing Decree n° 2001-282 (12

April 2001), is Senegal’s principal environment law.

This Non-Technical Summary is intended to describe the proposed Project and outline in easily-understood

terms the key potential environmental and social impacts of the Project, and how likely and severe these

impacts are expected to be based on currently available Project information. The summary also presents an

overview of the management and mitigation programme to address the identified key impacts.

1.2 Project Overview

The Project is located in the Kedougou Region of south-eastern Senegal, approximately 650 km south-east of

Dakar (Figure 1-1). The Company proposes to develop the Petowal gold deposit (Figure 1-2), subject to receipt

of a certificate of environmental and social conformity by the Ministry of Environment and Sustainable

Development, and being granted a Mining Concession (the subject of a separate application to the Ministry of

Energy and Mines).

Mako Gold Project


FINAL REPORT 1-2

Figure 1-1 Mako Gold Project general location

Mako Gold Project


FINAL REPORT 1-3

Figure 1-2 Mako Gold Project Exploration Permit, proposed Mining Concession and Project Development Area

Mako Gold Project


FINAL REPORT 1-4

1.3 Project Proponent

The proponent of the Project is the Mako Exploration Company SA (MEC), a 100% owned subsidiary of Toro

Gold Ltd. Toro Gold is registered in Guernsey, a possession of the British Crown, with its head office in London.

It has been engaged in the exploration and development of gold projects throughout Africa since 2009.

The contact details for the project proponent are as follows:

Paul Cannon

Environment and Social Performance Manager Toro Gold Ltd / Mako Exploration Company SA

Boubacar Thera

General Manager Mako Exploration Company SA

Address:

UNITED KINGDOM

Toro Technical Services

Egyptian House

170-173 Piccadilly

London W1J 9EJ

United Kingdom

Email: [email protected]

Tel: +221 33 868 30 57

Web: http://www.torogold.com

Address:

SENEGAL

Mako Exploration Company SA

8 Route du Méridien Président

Almadies

Dakar

Sénégal

1.4 Environmental and Social Consultants

1.4.1 Consultant‘s ESIA Experience

The Company has engaged Earth Systems as a consultant to conduct the ESIA on its behalf.

Earth Systems holds a current EIA accreditation from the Government of Senegal. The company has over 25

years of experience conducting ESIAs for the mining sector and has completed a number of environmental and

social studies within Senegal. Mining clients in West Africa have included Teranga Gold, Mineral Deposits

Limited, Avocet Mining and Tawana Resources.

Earth Systems’ project team includes specialists in all of the areas required to complete an ESIA, including:

Project Managers with environmental expertise and experience in conduct of ESIAs of mining projects;

Soil scientist;

Hydrologist;

Hydrogeologist;

Ecologists including flora, fauna and aquatics specialisations;

Social / socio-economics specialist;

Health, safety, pollution and risk management expertise; and

GIS and mapping.

Mako Gold Project


FINAL REPORT 1-5

1.4.2 Main Contributors to the ESIA

Throughout the preparation of the ESIA, Earth Systems has engaged additional specialists and sub-consultants

from Senegal and abroad. Key contributors include:

Institut Fondamental d'Afrique Noire (IFAN) (Senegal);

Institut des Sciences de l'Environnement (ISE) at the Université de Cheikh Ante Diop (Senegal) ;

rePlan (Canada);

The Biodiversity Consultancy (UK); and

Royal Botanic Gardens, Kew (UK).

This report incorporates their findings.

1.5 ESIA Approach and Report Structure

1.5.1 ESIA Objectives

The objectives of this ESIA are to:

Provide a description of the proposed Project and alternatives;

Describe the physical, ecological and social setting of the proposed Project;

Identify key environmental and social management issues associated with the construction, operation

and closure of the Project within Senegal;

Describe how the Company will plan, construct and operate the Project to prevent and mitigate adverse

environmental and social impacts;

Describe how the Company will monitor and manage residual environmental and social impacts; and

Assess the risk of any significant environmental and social hazards associated with the proposed Project.

1.5.2 Impact Assessment Approach

The assessment of potential impacts of the Project has incorporated the following steps:

1. Baseline / Setting: Description of the current environmental and social situation and how this would

develop in the absence of the Project.

2. Assessment of Issues and Potential Impacts: Assessment of pre-mitigation impacts on sensitive

receptors for the preferred Project design, incorporating standard industry practice.

3. Mitigation: Proposed measures to avoid, reduce, remedy or compensate for adverse impacts or to

enhance benefits (i.e. beyond standard practice), as per the mitigation hierarchy.

4. Residual Impact: Identification of the potential residual impacts after application of proposed

mitigation measures, and the expected significance of the residual impact.

For the Mako Gold Project ESIA, three categories of impact significance have been adopted: Minor, Moderate

and Major. These categories are defined in the significance matrix presented below in Table 1-1. The impact

magnitude is predicted from the Project engineering and modelling, while the receptor sensitivity is

determined from existing environmental and social baseline conditions. Those expected impacts which are

considered to be negligible (i.e. minimal impact or no discernible impact; below “Minor” impact significance)

are noted, however, no specific mitigation measures are proposed for such impacts. Mitigation has been

proposed for all other impact significance levels.

Mako Gold Project


FINAL REPORT 1-6

Table 1-1 Overall impact significance for the ESIA

Receptor

Sensitivity /

Resource Value

Impact Magnitude

Minimal / Not discernible

Low Medium High

Low Negligible Minor Minor Moderate

Medium Negligible Minor Moderate Major

High Negligible Moderate Major Major

The ESIA predicts the impacts and assesses the risks associated with the project. The impacts/risks may be a

direct result of the project (e.g. generation of dust) or may be indirect (e.g. pressure on local resources caused

by an influx of migrants attracted by the project and other regional opportunities).

Project design has been guided by environmental and social design criteria that have been developed by the

Company. Wherever possible, environmental and social impacts and risks have been avoided by making

changes to the Project design in an iterative manner (e.g. relocation of a road to avoid a key environmental

feature). The process informing these changes and the various iterations of the Project design have been

documented in the ESIA Report.

1.5.3 ESIA Report Structure

The ESIA Non-Technical Summary is one component of the overall environmental and social impact

assessment report for the Project. The format of the ESIA volumes was agreed during a meeting held with DEEC

on 10 December 2014. Based on this, the ESIA is comprised of five volumes:

Volume A: ESIA Study

o ESIA Non-Technical Summary (this report);

o ESIA Report;

o ESIA Technical Appendices;

Volume B: Risk Assessment (Etude de Danger)

Volume C: Management Plans

o Environmental and Social Monitoring and Management Plan (ESMMP);

o Biodiversity Action Plan;

o Stakeholder Engagement Plan;

Volume D: Livelihood Restoration and Economic Participation

o Livelihood Restoration Plan;

o Local Economic Participation Plan; and

Volume E: Rehabilitation and Conceptual Mine Closure Plan.

1.5.4 ESIA Specialist Studies and Data Sources

This ESIA has built upon work previously undertaken by, or in collaboration with, the Company, the Government

of Senegal, non-governmental organisations (NGOs) and other projects in the region. Baseline studies,

stakeholder engagement and preliminary impact studies commenced in August 2012. The results of these

environmental and social studies have been compiled in the following reports (Table 1-2). This information has

been incorporated into Project scoping, pre-feasibility and feasibility design studies.

Mako Gold Project


FINAL REPORT 1-7

Table 1-2 Specialist studies commissioned as part of the ESIA

Specialist Study Title Author ESIA Technical

Appendix

ESIA Terms of Reference MEC / Earth Systems Appendix 1

Meteorology Baseline Earth Systems Appendix 2

Surface and Groundwater Resources Baseline Study Earth Systems Appendix 3

Air Quality, Noise and Vibration Study Earth Systems Appendix 4

Terrestrial Ecology and Biodiversity Baseline Study Earth Systems / UCAD Appendix 5

Aquatic Ecology and Biodiversity Baseline Study Earth Systems / UCAD Appendix 6

Archaeology and Cultural Heritage Study IFAN Appendix 7

Socio-Economic, Land and Water Use Baseline Study (including Transportation Study)

Earth Systems Appendix 8

Government and community engagement MEC, Earth Systems, rePlan, local consultants

Appendix 9

Visual Amenity Study Earth Systems ESIA Ch.9

Social Management Plans:

Livelihood Restoration Plan

Local Economic Participation Plan

rePlan Volume D

Mako Gold Project


FINAL REPORT 2-8

2 PROJECT BENEFITS AND NEEDS

This section presents the overall rationale for the Mako Gold Project and summarises the likely economic and

social benefits of the Project at the national, regional and local level.

2.1 Benefits to Senegal

Despite reserves of gold, phosphates and iron, Senegal’s mineral resources are largely undeveloped. The

Sabodala Gold Mine is the only large-scale gold mine currently in operation in Senegal, providing direct

employment for over 1,100 people (90% from Senegal). In 2014 the gold mining sector alone represented

approximately 13% of the value of exported goods in the country (KPMG, 2014). If the Mako Gold Project

proceeds, it will help to increase export value and employment, while realising Senegal’s resource wealth

potential, specifically that of the Birimian gold belt in eastern Senegal. The Project will contribute to supporting

and financing the development needs of Senegal, through both direct and indirect economic and community

benefits.

The anticipated economic benefits of the Mako Gold Project can be categorised as direct economic benefits

(e.g. dividends, royalties, taxes and duties, salaries and expenditure) and indirect economic benefits (e.g. flow

on effects, training and skill development, infrastructure development). The economic benefits to the economy

of Senegal will be significant during the life of the mine as detailed below.

2.1.1 Direct Economic Benefits

Revenues to be paid by the Project to the Government are based on the Mining Code (2003), the General Tax

Code (2012) and the Company’s Mining Convention with the Government.

Tax income associated with capital expenditure along with employment and material supply expenses will

make a significant contribution to the development of the Senegalese economy. Direct economic benefits to

the national Government and economy are likely to include:

Dividends: Government dividend on profits following debt repayment, is approximately 6 billion CFA1

(10 million USD) over the mine life;

Royalties: Approximately 2 – 2.5 billion CFA (3.5 – 4 million USD) per year of operations or 18 – 21 billion

CFA (30 – 35 million USD) over the mine life;

Payroll tax: Approximately 1.75 billion CFA (3 million USD) per year over the mine life;

Customs excise / Import duty: Approximately 1.75 - 3 billion CFA (3 – 5 million USD) per year of

operations;

Free issue of shares (10% of the Project ownership as a free carried interest);

Labour costs: Approximately 3.25 billion CFA (5.5 million USD) per year of operations; and

Payments to suppliers: Approximately 8.9 billion CFA (15 million USD) during the construction period

and 3 billion CFA (5 million USD) per year of operations.

The capital costs associated with the Project will result in flow-on effects to the Senegalese national economy.

1 Exchange rate taken on 28/07/2015 where 1 USD = 594.68 CFA

Mako Gold Project


FINAL REPORT 2-9

2.1.2 Indirect Economic Benefits

Indirect benefits from the Project will include flow-on benefits and external effects. Flow-on benefits include

local business development (i.e. businesses being created to provide goods and services to the Project and to

Project employees) and general increased consumption in the local communities resulting from the injection

of cash into the local economy. In addition these flow-on benefits will generate additional revenue to GRS

through taxes paid by businesses arising and on goods purchased in the expanded cash economy. The

‘multiplier effect’, which takes into account direct, indirect (e.g. supplier effects) and induced (e.g. spending by

employees and local households) contributions of mining projects to GDP can be significant. For example, in

Romania and Brazil one dollar of economic activity in the mining sector can generate three dollars or more of

activity elsewhere (ICMM, 2012), while in Peru studies suggest a multiplier of 1.9 to be applied to mining

contribution to GDP (World Gold Council, 2012).

External effects refer to costs or benefits not reflected in price, income or tax revenues. In the case of the Project,

these benefits are likely to include skill development, institutional capacity building, technology transfer, and

infrastructure development in the region surrounding the Project Development Area. While many of these

benefits will be realised at the local level, some, such as skill development and capacity building will also benefit

Senegal as a whole.

Source: Adapted from CIE, 2010 (page 9, Figure 1.3).

Figure 2-1 Indirect economic benefits of the Mako Gold Project

2.2 Regional and Local Community Benefits

The Project is expected to be a driver for economic growth in the local (Tomboronkoto Commune) and regional

(Kedougou Region) community, through employment expenditure, infrastructure development, and social

investment. A significant proportion of the capital expenditure and operating costs for the Project will be spent

in the Kedougou Region resulting in flow-on benefits to the local community.

Under its Environmental and Social Performance Framework (ESPF), the Company has committed to working to

ensure that local communities benefit on an enduring basis through opportunities such as employment, local

supply and contracting, and training. In the ESPF, the Company also commits to investment in environmental

and social projects, and has displayed this commitment throughout the exploration phase of the Project

through the implementation of a Biodiversity Fund to support conservation efforts in the PNNK, and a Social

Investment Programme to support community development in Tomboronkoto Commune.

Experience from large mines in Senegal (Sabodala Mine; Grande Côte) indicate that the flow-on from direct

expenditure and employment at the local level will result in broad economic development that extends

beyond the area immediately surrounding the Project.

The primary benefits of the Project to local communities are summarised briefly below.

Flow-on effects

Economic activity resulting from spending

Increased consumption from wage and salary income

Additional GRS revenue from flow on effects

External EffectsSkill development

Technology transfer

Infrastructure

Business development

Rural development

Community Infrastructure & services

Institutional capacity building

Mako Gold Project


FINAL REPORT 2-10

Project Employment

Employment within local and regional communities is one of the most visible economic impacts of the Project.

The Project will directly generate employment through the creation of jobs with the mine (construction,

operation, closure / rehabilitation) and will indirectly generate employment through the creation of jobs with

mine contractors and other service providers. During construction, the Project will employ approximately 900

staff during peak periods. It is estimated that at least 30 percent of these staff will be sourced from the

Kedougou Region. During operations, the Project will employ approximately 360 staff, of which it is estimated

that at least 45 percent will be sourced from the Kedougou Region.

It is estimated by the Company that approximately 2.5 billion CFA (4 million USD) will be paid to regional Project

personnel during the construction period. This is expected to increase during the operations period to 3.25

billion CFA (5.5 million USD) per year with local skill development and succession planning.

Training and Skill Development

Training and skill development is a significant contribution of the Project to the local and regional economy.

The Company will formalise processes for skills upgrading and the mentoring of Project staff. The Company

will collaborate with local and regional education providers to train Project personnel and will provide paid

apprenticeships for local and regional students. Training is likely to include technical skills training,

management and professional development training, environmental inductions, as well as health and safety

training.

Development of Local Businesses

The flow of revenue arising from Project development will provide an opportunity for new and existing

businesses to participate in the goods and services supply chain. The value of this revenue to local and regional

businesses is estimated to be in the range 9 billion to 12 billion CFA during Project construction, and 3 billion

to 4.5 billion CFA per annum during Project operations. The Company will assist local business development,

actively identify opportunities to outsource services and give preference to local businesses. This is expected

to support the formalisation of participating small to medium enterprises i.e. formal business registration and

book-keeping.

Social and Environmental Investment

The Company will establish a social and environmental investment fund to ensure that communities and more

broadly the State, share the benefits of the Mako Gold Project. The contributions of the Company to the Fund

will be over and above the budget allowance for impact mitigation. The contribution will be commensurate

with the phase of the Project, vis-à-vis exploration, construction, operations, and closure.

The fund will provide support to community development, particularly in the Commune of Tomboronkoto, and

biodiversity management both within and adjacent to the Niokolo-Koba National Park. Strategic areas of

investment will be in line with government policy and local priorities. Key to the success of the fund will be a

bottom-up participatory approach to decision-making. The mechanisms for establishment and operation of

the fund will be agreed with the Government.

Infrastructure and Services

Local infrastructure and services will be upgraded to directly support Project development. Elements of this

infrastructure and services will also benefit local communities, in particular the upgrade of local roads,

telephone networks, transportation services and access to markets. The Company will engage local authorities

in the preparation of its mine plan to ensure appropriate consideration has been given to the maintenance and

upkeep of this infrastructure and services post-closure of the mine.

Mako Gold Project


FINAL REPORT 3-11

3 POLICY, GUIDELINES AND LEGISLATIVE FRAMEWORK

Major projects require an ESIA for permitting under national law, to meet stakeholder requirements and for

project financing. This impact assessment has been undertaken to satisfy the requirements of both Senegalese

legislation and international standards such as the IFC Performance Standards.

In addition to the requirements relating to impact assessment, the Mako Gold Project will also comply with the

existing Mining Convention held with the Ministry of Energy and Mines and all other applicable Senegalese

legislation, including international conventions to which Senegal is a signatory. The Project will further operate

in keeping with international best practice and in particular IFC Performance Standards for environmental and

social performance. To this end, an overview of the regulatory structure, relevant national legislation and

international guidelines is provided below.

3.1 National Legislation and Regulations

The key agency responsible for the implementation of government policy relating to environmental

assessment is the Direction of Environment and Classified Establishments (Direction de l’Environnement et des

Etablissements Classés or DEEC). DEEC is an agency under the Ministry of Environment and Sustainable

Development (Ministère de l’Environnement et du Développement Durable or MEDD).

3.1.1 Senegalese ESIA Process and Permitting

Following submission of an ESIA draft report, a Technical Committee (Comité Technique or CT) is convened at

the regional level by the Governor (who is the Chair of the Committee) in association with the Regional Division

of Environment and Classified Establishments (Division Régionale de l’Environnement et des Etablissements

Classés or DREEC) to provide support with ESIA validation for the specific project. The Committee is created by

Governor Order and consists of invited technical services within the region(s) affected by project activities, as

well as local administrative representatives (Prefect, Sub-Prefect, Departmental Council, Commune Council).

The Committee is supported in its mission by DEEC and the key authorities that will be involved in the

implementation of the Project at the national level.

Key national authorities relevant to the ESIA process include, but are not limited to, the Direction of Mining and

Geology (Direction des Mines et de la Géologie or DMG), the Direction of Civil Protection (Direction de la Protection

Civile or DPC), the Direction of Water Resource Management and Planning (Direction de la Gestion et de la

Planification des Ressources en Eau or DGPRE) and the Direction of National Parks (Direction de Parcs Nationaux

or DPN).

A full list of legislation relevant to the Project is provided in the ESIA Report (Volume A). Key Senegalese

legislation relevant to Project permitting includes:

Mining Code (2003);

Environment Code (2001);

Water Code (1981);

Forestry Code (1998);

National Domain (1964).

Under Annex 1 of the Environment Code (2001) and under Article 83 of the Mining Code (2003), an ESIA is

required for all mining projects in Senegal.

In addition to the legislation, the Company has an agreement in place with the Government of the Republic of

Senegal (GRS) (represented by the Minister of Mines) under the Mining Convention (2007). This defines

Mako Gold Project


FINAL REPORT 3-12

additional legal, administrative, financial and fiscal conditions of the Project in both the exploration and

operation phases.

The Mining Code (2003) is the primary legislation regulating the mining industry in Senegal, covering both

exploration and mining activities. Sections of the code that are particularly relevant to the environmental and

social management of mining projects include:

Title IX, Chapter 5 ‘Environmental Protection’ – Specifies the requirement for an environmental impact

study; for setting funds aside for rehabilitation and closure; and compliance with the Forestry Code (Art.

L44).

Article 76 of the Mining Code requires the holder of the mining title to compensate owners or occupants

of land occupied by the mining title holder.

Article 81 covers compensation of third parties and the state.

Article 82 addresses the need for rehabilitation of mine sites.

The requirement for an EIA is in Article 83, which requires an EIA to be prepared when a permit of

exploitation or mining concession is requested. This is further elaborated in Article 26 of Decree No.

2004-647. Decree No. 2004-647 in article 93 stipulates compensation requirements for impacts.

Article 84 requires a Mine Site Rehabilitation Fund to be established with terms and conditions fixed by

decree.

The objective of the Environment Code (2001), Senegal’s principal environment law, is to establish a set of

fundamental principles designed to manage and protect the environment against all possible forms of

degradation. The Code defines procedures for environmental impact assessment. The Code also defines key

environmental terms and sets out the Government’s environmental policies for five key areas: classified

installations (any source, mobile or fixed, capable of posing a threat to the environment; divided into two classes

based on potential impact); water pollution; noise pollution; air pollution and unpleasant odours; and soil and

sub-surface pollution.

3.1.2 Management of Water Resources

The Water Code (Code de l’Eau, Law No. 81-13 of 4 March 1981) establishes the main legal framework for the

management and use of water resources in Senegal. The preamble to, and article 2 of, the Code state that water

resources are public goods, and any exploitation of this resource must be authorized and subject to control

and monitoring. Article 9 (Title I) states that authorisation must be sought from the Hydraulic and Sanitation

Ministry before installing infrastructure to exploit groundwater (boreholes etc. providing a flow-rate of greater

than 5 m3/h) or surface water resources. Title II regulates the protection of water quality, including all

discharges or deposits that may have an impact on surface and sub-surface water bodies. Article 75 establishes

that human consumption is the priority in the allocation of water resources. The Company will seek

authorisation from the DGPRE for the abstraction and storage of water.

The Company will require permission from OMVG for development within the Gambia River basin and to

abstract water and discharge to the Gambia River, in accordance with the Convention relating to the Status of

the River Gambia / Convention relating to the Creation of the Gambia River Basin Development Organisation

(Organisation de Mise en Valeur du fleuve Gambie or OMVG).

3.1.3 Management of Land and Forest Resources

Senegal’s legislation relevant to forestry and Protected Areas comprise a series of legal texts and regulations.

These laws include:

Law No. 93-06 of February 04, 1993 and its enforcement Decree No. 95-357 of 11 April 1995 put the

protection of Forests under the authority of the Direction des Eaux et Forêts, Chasse et de la

Conservation des Sols (DEFCCS). This law confers the primary responsibility for the conservation and

management of forests to the DEFCCS, with the exception of terroirs (where the management of forests

Mako Gold Project


FINAL REPORT 3-13

falls to the local community, on the basis of a management plan for all forests with an area greater than

20 ha or of a simple management plan when the area is between 5 and 20 ha. The management plans

are approved by the DEFCCS (Decree No. 98-164 du 20 February 1998. Title II. On forest management.

Chapiter 1. Article R11)

Law No. 64-46 of 17 June 1964 concerning the National Domain.

Decree No. 64-573 of 30 July 1964, Application of the Law on the National Domain.

Law no. 98-03 of 8 January 1998 regarding the Forestry Code.

Senegal‘s Mineral Policy Statement (2003) provides for the abandonment of state monopoly over mineral

resources and shifts the focus to regulating private mining companies. The policy statement limits the state‘s

participation in ventures to 20% and encourages participation of private investors, both domestic and foreign.

The state will also support the diversification of mineral production and the beneficiation (initial processing) of

mineral products before export in order to generate employment opportunities in the industry. The need for

an ESIA prior to mining operations is reiterated in the Statement.

3.1.4 Land Acquisition and Compensation

The Company is committed to mitigating the impacts from land acquisition by providing compensation for

loss of land, assets and livelihood with appropriate stakeholder engagement. The requirement to provide

compensation under Senegalese law is described in the following:

Article 76 of the Mining Code (2003) states that the holder of a permit (including exploration permits) is

required to compensate the owners or occupants of land “for all loss suffered”. This is reiterated in Articles

89, 90, 92 and 93 of the Mining Code Application Decree No. 2004-647 of 17 May 2004 and includes

compensation of the State for any damages or losses resulting from mining operations.

Decree for application (64-573) of 30 July 1964 fixes the application conditions of Law No. 64-46 of June

17, 1964 relating to national property. Article 23 of the decree specifies that where reallocation of land

occurs, the new land holder must pay the previous landholder compensation equal to the value of built

improvements and planted crops estimated on the day that the new allocation is pronounced.

Decree No 91-938 (22 August 1991) amends Section 38 of Decree No. 64-573 of 30 July 1964 on the

application of the Law of the National Domain. It permits illegal / informal occupants subject to

displacement to be eligible for compensation.

Circular no. 2237/DGPA (October 7, 1974), Price scale for calculation of compensation in case of

destruction of plantations/cultivated land or delocalisation from the National Domain.

3.1.5 Management of Biodiversity

Senegal’s legislation relevant to the protection of biodiversity includes the following laws and conventions:

The Hunting and Wildlife Protection Code (established by Law No. 86-04 of 24 January 1986 and

Decree No. 86-844 of July 14, 1986) provides for a system of reserves to protect fauna (including the

PNNK), regulates hunting and defines the types of offenses related to the destruction of wildlife.

Law No. 98-03 of 8 January 1998 regarding the Forestry Code.

Decree No. 96-1134 of 27 December 1996 provides for the implementation of Law No. 96-07 of March

22, 1996 concerning natural resources. This gives the responsibility for wildlife protection to local

authorities, particularly relating to the authority to create natural animal reserves.

A number of decrees relating to the management of the Niokolo-Koba National Park (PNNK) including

Decree No. 2002-271 of 7 March 2002 regarding the up-date of the PNNK boundary and periphery.

Mako Gold Project


FINAL REPORT 3-14

3.2 Project Discharge Standards

The Project will consider and comply with:

Discharge and emissions guidelines for off-site releases of water, waste and potential airborne

contaminants; and

Ambient guidelines for the protection of environmental values (e.g. protection of aquatic fauna and

fisheries, drinking water, etc.).

A list of relevant Senegalese standards, as well as international standards, is presented in Table 3-1. Where

standards or limits do not exist in Senegalese Law, often guidelines, standards or limits used by other countries

(e.g. EU, USEPA, UK etc.) or organisations (e.g. IFC, WHO etc.) are adopted in lieu.

Table 3-1 Relevant air quality, noise and water standards and guidelines

Source Relevant Guidelines Year

Water Discharge and Monitoring

Senegal Interministerial Decree no 1555 Discharge Water Guidelines / L’arrêté interministériel no.

1555 de 15 mars 2002 portant application de la norme NS 05-061 sur les rejets des eaux

usées

2002

Waste Water Discharge Standard, NS 05-061 / La norme sur les rejets des eaux (NS 05-

061)

2001

Draft Standard on Management of Solid Waste / Projet de Norme relative à la Gestion des

Déchets Solides

In

preparation

since 2005

IFC

Environmental Health and Safety Guidelines – Mining 2007

Environmental Health and Safety Guidelines – General – Environmental 2007

General EHS Guidelines: Wastewater and Ambient Water Quality. 2007

ICMI International Cyanide Management Code. 2009

Air Quality

Senegal Atmospheric Pollution Standard, NS 05-062 / La Norme de rejets NS 05-062 – pollution

atmosphérique

2004

IFC Environmental Health and Safety Guidelines for Mining. 2007

General EHS Guidelines: Air Emissions and Ambient Air Quality. 2007

WHO Air Quality Guidelines – Global Update 2005

Soil Quality

UK Soil Guideline Value 2009

Aquatic fauna / fresh waters

Senegal n/a n/a

United States National recommended water quality criteria; republication. United States Environmental

Protection Agency (USEPA)

2009

Mako Gold Project


FINAL REPORT 3-15

Source Relevant Guidelines Year

European

Union

Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008

on environmental quality standards in the field of water policy, amending and subsequently

repealing Council Directives 82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC,

86/280/EEC and amending Directive 2000/60/EC of the European Parliament and of the

Council.

2008

European

Union

Directive 2006/44/EC of the European Parliament and of the Council of 6 September 2006 on

the quality of fresh waters needing protection or improvement in order to support fish life (E.U.,

2006).

2006

Drinking water

Senegal n/a n/a

WHO Guidelines for Drinking Water Quality, fourth edition 2011

European

Union

Council directive 9883/EC of November 1998 on the quality of water intended for human

consumption.

1998

Noise and vibration

Senegal Environment Code (noise) / Code de l’Environnement 2001

UK British Standards (vibration) BS 6472:2008, 4866:2010 and 7385-2:1993 1993, 2008,

2010

IFC Environmental Health and Safety Guidelines for Mining. 2007

Senegal is a party to a number of international policies, conventions and agreements which have relevance to

the project. The Company will develop the Project in accordance with these commitments.

3.3 Risk Assessment

As per the Environment Code (2001), the ESIA report must include an assessment of the Project technological

risks. A Risk Assessment (known in Senegal as an Etude de Danger) was produced as part of the ESIA (refer

Volume B) to fulfil the statutory requirements. It focuses on the potential risks associated with the engineered

structures of the mine site and in particular the catastrophic events that could extend beyond the site

boundaries. The Risk Assessment evaluates the typical risks before controls are applied, describes controls to

reduce the risks and then evaluates the residual risks. The assessment was used to inform both the preliminary

Project design and the scope of the ESIA. It also forms the basis on which the Company will develop an

Emergency Response Plan (Plan d’Opération Interne – POI) and Local Authority Emergency Plan (Plan Particulier

d’Intervention – PPI).

3.4 International Policies, Guidelines and Standards

The Company will operate in keeping with international best practice. International agreements most relevant

to the Project are summarised in Table 3-2 below.

Table 3-2 International Environmental and Social Standards, Safeguards and Guidelines

Organisation Document Date Released

International Finance Corporation (IFC) Policy on Environmental and Social Sustainability and associated IFC Performance Standards

2012

Mako Gold Project


FINAL REPORT 3-16

Organisation Document Date Released

The World Bank General Environmental, Health and Safety Guidelines 2007

International Cyanide Management Code International Cyanide Management Code for the Manufacture, Transport and Use of Cyanide in the Production of Gold

2014

International Union on the Conservation of Nature (IUCN)

World Heritage Advice Note: Environmental Assessment;

World Heritage Advice Note: Mining and Oil/Gas Projects 2013

International Council on Metals and Minerals (ICMM)

Sustainable Development Framework 2003

Extractive Industries Transparency Initiative (EITI)

The EITI Standard 2013

USA and UK Governments Voluntary Principles on Security and Human Rights 2000

UN Guiding Principles on Business and Human Rights 2011

3.5 Toro Gold Environmental and Social Commitments

Toro Gold is committed to meeting international standards of good practice in the areas of environmental

protection, social development, and health, safety and security. Toro Gold’s Environmental and Social

Performance Framework (ESPF) governs the way the company and its subsidiaries operate with respect to

social and environmental issues. The ESPF consists of a set of Performance Standards drawn primarily from the

Performance Standards of the IFC, and supplemented as required by reference to the “UN Guiding Principles

on Business and Human Rights”, as well as the “Sustainable Development Framework” of the International

Council on Mining and Minerals. A dedicated team has been appointed to oversee compliance with the ESPF

across the Company’s projects.

Mako Gold Project


FINAL REPORT 4-17

4 PROJECT DESCRIPTION

4.1 General Description

4.1.1 Overview

The Mako Gold Project will consist of the development of the Petowal gold deposit, located in the Kedougou

region of Senegal, approximately 650 km south-east of Dakar. The Petowal deposit is located in the western

section of the proposed Mako Mining Concession (Figure 4-1). The preferred development scenario involves

standard gold extraction and processing methods, which involve mining of ore via an open pit, processing of

ore through carbon in leach (CIL), and construction of supporting infrastructure including a waste rock dump

(WRD), tailings management facility (TMF), water storage dam (WSD), power station and accommodation camp.

The Life of Mine is anticipated to be approximately eight years, with a total estimated production of

approximately 900 koz of gold (Toro Gold, 2015e). Construction is currently scheduled to commence in Quarter

4 of 2015 and commissioning in Quarter 1 of 2017.

The Project development is subject to continuing feasibility studies. The following Project Description is based

on Project information provided in the Definitive Feasibility Study (DFS) findings. The option selection process

for various facilities and operations is discussed in ESIA Report Chapter 5: Evaluation of Project Alternatives.

4.1.2 Mineral Resource

The Mako Gold Project contains a mineral resource of 13.9 Mt of ore, with a gold yield of 2.22g/t Au. There will

be 88.6 Mt of ore processed and 74.6 Mt of waste will be produced as a result. The schedule includes plant feed

of high grade ore which will produce an average 143 koz per annum during the first five years and 112 koz per

annum over the Operational Phase (Toro Gold, 2015e).

4.1.3 Proposed Project Arrangement

The site layout and project component configuration is depicted in Figure 4-1. The main mine facilities are

expected to include:

Mine Pit;

Haul route;

Run of Mine (ROM) Pad, ROM Pad stockpile and primary crusher;

Process Plant;

Tailings Management Facility (TMF) and sediment pond;

Waste Rock Dump (WRD);

Ore Stockpile;

Water Storage Dam (WSD);

Pump station and raw water pipeline;

Power Station and reticulation;

Project access infrastructure (including Main Access Road and WSD Access Road);

Mine Services Area (office / workshops / warehouse); and

Accommodation camp(s).

Mako Gold Project Environmental and Social Impact Assessment

REVISED REPORT 4-18

Figure 4-1 Project Development Area and Mine Layout

Mako Gold Project


FINAL REPORT 4-19

4.1.4 Project Development Area

The main area in which the Company are planning future mining operations is identified as the Project

Development Area (PDA), shown in Figure 4-1. This is some 541 ha in size, and is located entirely within the

proposed Mako Mining Concession, which covers an area of approximately 7700 ha. The PDA is located

immediately north of the Gambia River, approximately 1 km east of the Niokolo-Koba National Park (PNNK)

boundary (at its closest point) and is south of the N7 highway.

The primary purpose of the PDA is to define the footprint of the main area that could potentially be affected

by physical impacts that could occur over the Project life, as well as exclusion zones to protect community

safety. While the PDA includes the main components of the Project (e.g. mine pit, TMF, WRD, processing plant

etc.), some components such as the Mine Access Road, Water Storage Dam and Accommodation Camp are

located outside the PDA. Depending on the outcomes of consultations with local authorities, settlements and

some forms of land use and access will be excluded within the PDA and areas immediately downstream of dam

structures for safety and security reasons. The size of the PDA has been reduced through an iterative design process to ensure that impacts to land and

livelihoods are minimised.

Safety Exclusion Zones

The following security measures will be put in place to ensure the safety of local communities and personnel;

Fencing and/or other physical barriers will be erected around high security installations and other areas

where there are potential safety risks;

There will be no access to Badalla Valley upstream of the Mining Concession boundary (approx. 250 m

downstream of the TMF embankment). This includes areas around the TMF, WRD, Mine Pit, and Process

Plant. The Mine Pit will be surrounded by a berm to prevent access;

There will be a 500 m buffer around the Mine Pit to assist in maintaining the fly rock exclusion zone

during blasting. There will also be a 50 m exclusion zone around the Mine Pit at other times;

The TMF dam and WSD dam embankment will be surrounded by stock fencing to exclude access. No

swimming, fishing or livestock watering will be permitted; and

Community use of all Project roads will be permitted. However, there will be a control post just north of

Tambanoumouya to control access to the mine facilities.

4.1.5 Mine Life and Schedule

There will be an 18 month pre-construction and construction programme from the site access to the first gold

production. Production is expected to start in April 2017 (Toro Gold, 2015c). The Life of Mine is anticipated to

be approximately eight years. The mining plan includes a stockpiling strategy that is designed to preferentially

mine and treat the higher grade material. High grade ore will be mined and processed over a six year period at

a rate of 1.8mtpa. This will be followed by a further two to three year period (when mining is complete) in which

lower grade ore will be processed (Toro Gold, 2015 Pers. Comm.).

4.2 Pre-Construction Phase

An early works phase has been programmed to enable site access, preliminary works for the accommodation

village and preparation of the WSD facility before December 2015 at which time full construction and manning

up will commence. Early works (from October to December 2015) includes:

Detailed design for Main Access Road, WSD and Accommodation Camp;

Award of earthwork contract(s), or hiring of equipment if self-managed by Toro Gold;

Commencement of Main Access Road construction from the RN7 through the Wayako Valley;

Mako Gold Project


FINAL REPORT 4-20

Preparation, clearing and grubbing of the minor valley floor which forms the WSD facility;

Ordering of the demountable buildings which form part of the new accommodation camp;

Ordering owner mobile equipment; generators, pumps etc.; and

Commencement of quarry activities (including blasting) to generate aggregate for road building and

civil works.

4.3 Construction Phase

The construction activities will follow logically from the Pre-construction phase and will be carefully scheduled

to a compressed timeline targeting a first gold pour in Quarter 1 of 2017. Once site access has been established

in the Pre-construction phase, activities will progress in the following simplified sequence:

Construction of sediment retention pond downstream of the TMF (prior to the onset of the wet season);

Clearing and grubbing of areas to be developed;

Bulk earthworks, including cut and fill or cut to spoil levelling of access roads, drainage channels, Process

Plant site, ROM Pad, TMF, Accommodation Camp and Mine Pit area. Some blasting may be required for

sections of access road and occasional footings (such as the mill);

Mobilise civil contractor(s) to commence critical path concrete pours in February (civil works completed

by September 2016);

Complete installation of the WSD and river abstraction system and commission before June 2016;

Install accommodation camp facilities so that they are operational before May 2016;

Mechanical contractor to mobilise by end of July 2016, to commence tank erection at Process Plant;

Mine contractor or owner fleet to commence pre-strip by August 2016;

Power Station installation to commence by December 2016. This will be an optimal owner-operated or

independently operated diesel Power Station; and

Process Plant commissioning expected to commence in February 2017, and last for two months.

Vegetation clearance will be conducted during the dry season and confined to the minimum area required for

safe operations to reduce the potential for dust, erosion and sediment transport. Any commercially valuable

timber will be salvaged from the Project Footprint where possible.

The Company will provide daily bus transportation for Project employees to and from Kedougou town. Group

transportation will allow workers from the local area, and from Kedougou in particular, to commute from their

place of residence on a daily basis (rePlan, 2015c).

4.4 Operation Phase

The following sections describe the key Project components and processes that will take place during the

operational phase of the Mako Gold Project.

Mine Pit

The Petowal deposit will be developed as an open pit mine by conventional methods of drilling, blasting,

loading and hauling using standard industry equipment. Drilling will be by diesel-operated top hammer rigs

for waste and ore. Diesel-powered 120 tonne hydraulic excavators with 90 tonne (approximate) haul trucks

have been selected as the primary loading and hauling equipment. The pit will be mined at a maximum rate

of 24 Mt of ore per annum, producing 74 million tonnes of waste rock over the Project lifetime (Toro Gold,

2015a).

Mako Gold Project


FINAL REPORT 4-21

The local population and workers will be prevented from entering the 500m flyrock safety exclusion zone

around the pit during blasting times. All infrastructure associated with the pits will be based outside of the

exclusion zone. Prior to all blasting, the mine security team will ensure that no unauthorised people are within

the exclusion zone. Sirens, amplified verbal warnings, the posting of sentries and the closure of access roads

will also be used to deter unauthorised entry to the area.

Following blasting, the ore will be loaded and hauled out of the pit along the haul roads to the ROM ore

stockpile area for processing. The waste rock will also be loaded and hauled out of the pit to the WRD or to

facilities requiring waste rock for construction.

Ore Processing

Ore processing shall comprise the following equipment/stages:

ROM Pad;

Crushing Circuit;

Grinding and Classification Circuit;

Process Plant:

» Pre-leach thickening;

» Leach and Carbon Adsorption Circuit;

» Cyanide destruction circuit; and

» Elution and goldroom.

Water and air services.

The overall process is summarised as follows (Toro Gold, 2015b):

Primary jaw crushing and partial secondary cone crushing of ROM ore to produce a crushed product size

of 80% passing (P80) 143 mm;

A crushed ore surge bin and overflow dead stockpile with reclaim of crushed ore from the surge bin.

Single stage SAG milling in closed circuit with a pebble crusher and hydrocyclones to produce an 80%

passing 125 micron grind size;

Pre-leach thickening to increase the slurry density feeding the CIL circuit to minimise CIL tankage,

improve slurry mixing characteristics and reduce overall reagent consumption;

A CIL circuit which will leach and adsorb gold and silver values from the milled ore onto activated carbon

in six stages of leaching with carbon in all stages for gold adsorption providing a total of 24 hours leach

time;

A Zadra elution circuit treating loaded carbon, followed by electrowinning and smelting to produce

doré;

An INCO-based2 SO2 / air cyanide destruction circuit to reduce the tailings cyanide concentration to meet

the International Cyanide Management Code (ICMC) requirement of <50mg/L WAD cyanide; and

Tailings transfer to the Tailings Management Facility.

The Process Plant will have a throughput capacity of 1,800,000 tonnes per year based on a 67% felsic / 33%

basalt primary ore blend and the plant operating 8,000 hours per year (91.3% availability). Plant feed will be

maintained at above 2.7 g/t for the first five years of plant operation (Toro Gold, 2015e).

2 This refers to the sulfur dioxide (SO2) and air process developed by INCO Limited in the1980’s.

Mako Gold Project


FINAL REPORT 4-22

Tailings Management Facility

The TMF will provide secure and permanent containment of tailings discharged from the Process Plant. The

slurry discharged to the TMF will contain 48% solids by weight (Knight Piesold, 2015a).

The TMF embankment will also provide containment for all water that enters upstream areas of the Badalla

Valley. This includes both 'clean' water and 'dirty' water i.e. leachate from the WRD, sump waters from the pit

and storm water from the Process Plant. These waters will collect in the decant pond on the TMF and will be

returned to the Process Plant. The TMF has been designed, and will be managed, so that it will not discharge

to receiving waters during operations. The TMF is designed to provide water storage capacity during the wet

season.

Waste Rock Dump

A WRD is required for permanent storage of waste rock. Rock that contains no or very low levels of gold will be

removed as waste to allow access to the ore. It will be transported by haul trucks out of the Mine Pit; either to

the specially designed WRD adjacent to the pit or to facilities requiring waste rock as construction material.

Approximately 74 Mt of waste rock will be generated over the Life of Mine (Toro Gold, 2015c). All drainage and

water runoff from the WRD will be directed to the TMF. The WRD design will also incorporate features to

minimise the effect of leaching of contaminants (MEC, 2015 Pers. Comm., email correspondence 08/06/2015).

Ore Stockpile

An ore stockpile will be located in the western footprint of the WRD (see Figure 4-1). Waste rock will initially be

placed in this area and then low grade ore will be progressively stockpiled on the waste rock layer. This ore will

be processed in the final two to three years of the mine operational period. A cutoff grade of 1.3 g/t has been

selected for high and low grade ore separation and this will result in a maximum low grade stockpile size of

about 4.0 Mt at the end of mining operations (Toro Gold, 2015e). All drainage and surface water runoff from the

Ore Stockpile will be directed to the TMF.

Water Storage Dam and Abstraction System

The WSD is the main collection and storage pond for clean process water on site. The WSD will have a storage

volume of 1.24 million m3 and an embankment height of 21 m (Knight Piesold, 2015f ). The WSD is intended to

be recharged through rainfall runoff from the limited catchment and water abstracted from the Gambia River

in the wet season each year (Knight Piesold, 2015a).

The Gambia River abstraction system will comprise submersible pumps situated within a vertical concrete

tower. There will be a maximum abstraction rate of 3% from the Gambia River flow in order to protect

environmental flow, the water requirements of downstream users and aquatic biodiversity (Knight Piesold,

2015c).

Water Management

Surface water runoff within the PDA and the surrounding area will be carefully managed to ensure safe and

secure mining operations and to safeguard potentially sensitive environmental receptors downstream.

As the Mine Pit develops throughout the mine life, the pit will form a natural sump, allowing for collection of

direct precipitation and surface water runoff and relatively small volumes of groundwater. Consequently, a

method of removing the water will be required to allow mining operations to continue safely and effectively.

A volume of approximately 2,111,052 m3 will be pumped from the Mine Pit over the life of the mine. The cone

of groundwater depression resulting from the dewatering operation has been estimated to extend to a

maximum of 900 m away from the pit edge. All water from dewatering operations will be captured for Project

use – there will be no discharge to the environment.

Runoff captured from the pit, the WRD and contributing drainage areas will not be allowed to discharge directly

into the natural watercourses due to the potential presence of elevated suspended solids. All contaminated

water from mine operations will be contained by the TMF.

Mako Gold Project


FINAL REPORT 4-23

Water contained by the TMF will be returned for use in the Process Plant. The Process Plant will have a minimum

process water requirement of 36.6 tonnes per hour. However, a shortfall in process water is expected to occur

under average climatic conditions, ranging from 124,000m3/ year to 327,000m3/ year. Abstraction from the

Gambia River over a period of 6-8 months per year will be required in order to make up this shortfall.

Power Station

Power will be supplied by a diesel generator plant (the ‘Power Station’) and will comprise notionally 15 x 850

kW 415 V units. Individual generators will be housed in acoustic containers. The current Project design

envisages the Power Station supplying a base load of 9.8MW for steady state operations (Toro Gold, 2014c). The

maximum power demand3 from plant and infrastructure will be 9, 729 kW and energy consumption per year

for plant and infrastructure will be 75.7 GWhr/yr (ECG, 2015). The electrical system will be based on 11 kV

distribution and 415 V working voltage. 11 kV overhead power lines will distribute power across the site,

stepped down at point of use with pole top transformers, kiosks or conventional transformers and motor

control centres (MCCs).

4.5 Decommissioning and Rehabilitation

The overall objective of the Company’s rehabilitation programme is “to operate as a non-intrusive land user and

to create stable rehabilitated landforms that are consistent with the surrounding physical and social environment

and that do not need on-going maintenance” (AARC, 2004). Detailed information on decommissioning and

rehabilitation is provided in the Rehabilitation and Preliminary Mine Closure Plan (RPMCP), produced as Volume

E of the Mako Gold Project ESIA (Earth Systems, 2015b).

While closure management measures will be developed and refined that are specific to discrete areas of the

mine components, there are some generic management measures that will be incorporated into detailed

closure plans, as follows:

There will be no access to facilities that have health and safety risks (e.g. Mine Pit);

All equipment and vehicles will be removed from the site;

All chemicals, fuels and oils will be removed from the PDA. Where feasible chemicals will be returned to

suppliers. Left-over chemicals will be destroyed in an appropriate manner;

Buildings and structures will be demolished and the rubble will be transported to an approved disposal

area;

Buried pipelines will be cleaned, sealed and left in-situ;

Power lines and above ground pipelines will be removed to an approved disposal area;

Footings / foundations will be removed;

Stormwater management systems will be retained until they are no longer needed;

A site contaminated land survey will be conducted to identify any such areas and appropriate clean up

measures will be designed and implemented;

All potential sources of noise will be removed (subject to the completion of closure related engineering

work, e.g. mobile plant activities);

Compacted areas, including roads and building footprints will be ripped and graded to blend into

surrounding contours and to ensure drainage patterns are similar to pre-mining conditions;

Engineered erosion control measures will be established where needed;

Re-vegetation and restoration of pre-mine ecological values where possible;

3 This is defined as the maximum average load over any 30 minute period.

Mako Gold Project


FINAL REPORT 4-24

All seeding and planting will be sourced from native stock of local provenance; and

Fencing will be removed, unless retained for public and livestock safety reasons.

Rehabilitation of mining areas will be carried out progressively over the mine life, so that areas left open to

erosion are minimised and a large rehabilitation liability is avoided at closure. Rehabilitation will be conducted

in a manner which ensures community safety and benefits the local communities where possible. Closure

options and criteria will be developed in consultation with the local community.

4.6 Staff

It is expected that the staffing requirements will be as follows;

A pre-construction period of three months with a maximum of 221 staff;

A construction period of 15 months, starting with approximately 300 staff and increasing to almost 900

staff in peak periods; and

A commissioning period of two months, when staff numbers decrease to approximately 500.

During Operations, the mine will operate on a continuous basis: 350 days per year and 24 hours per day,

allowing 15 days of stoppage. A maximum permanent operations workforce totalling 361 persons is

anticipated.

Staffing requirements with relation to employment of Senegalese nationals will conform to the stipulations of

the Mining Code.

The Company’s preferential employment policy maximises the opportunity for local recruitment, training and

skill development.

4.7 Accommodation

During construction, both the existing Exploration Camp and a new Accommodation Camp will be used to

house workers. With the existing Exploration Camp capacity of 70 beds and the new Accommodation Camp of

130 beds, a total permanent capacity of 200 beds will be available. There will be a short term requirement of

about 50-80 (additional) beds during peak periods which will be supplied through temporary demountable

accommodation located adjacent to the existing Exploration Camp.

During operations, the principle accommodation facility will be the new Accommodation Camp. Of the 361

people expected to be employed during the operations phase, 130 will be accommodated in this Camp.

Priority for camp accommodation during construction and operations will be given to ‘non-local’ personnel,

occupying positions for which the skills and experience are not available within the Kedougou Region. The

majority of the remaining staff will be recruited from within the Kedougou Region and will therefore already

have accommodation within commuting distance of the Project.

Mako Gold Project


FINAL REPORT 5-25

5 PROJECT ALTERNATIVES

5.1 Approach to Identification and Assessment of Alternatives

Throughout the design and feasibility study process, a number of different alternatives for mine design,

processing and layout have been considered for the Mako Gold Project. A risk-based approach was used to

guide the evaluation of alternatives in relation to each design phase. Those Project risks and controls identified

through the assessment of alternatives have been documented in the Risk Assessment (Volume B).

Potential Project alternatives were first screened to assess whether they have the capacity to meet the technical

requirements of the Project. Options that were technically feasible were then considered in terms of the

following criteria:

Economic feasibility;

Potential environmental impact (including possible ecological impacts and effects on physical /

chemical parameters); and

Potential social costs / benefits (including likely stakeholder perception and potential impacts on land

and livelihood, and public health and safety).

Environmental and social design criteria were developed for the Project and these were applied to a range of

alternatives. Alternatives were assessed to ensure optimum design outcomes balancing social, environmental

and economic considerations.

A summary of the main Project alternatives considered are outlined in the sections below.

5.2 Mining Method

Open pit or underground ore mining methods can be used to extract ore from a mineral resource. The Petowal

deposit is proposed to be developed as an open pit mine using conventional methods of drilling, blasting,

loading and hauling using standard industry equipment. Technically, the shape and orientation of the Petowal

deposit on a mountainous ridge lends itself to open pit mining. Open pit mining is also widely considered to

be a safer and more economical extraction method. Based on the ore body geometry, rock conditions,

economics and practicalities of mining, the open pit mining method for the deposit is the only practicable

mining method available at this stage, and no alternative to this approach can be considered viable for the

Project.

5.3 Waste Rock Management

Two potential WRD location options were identified (Figure 5-1). Option 1 is located in the Badalla Valley and

adjacent to the Petowal pit, while Option 2 is further to the east. Both proposed sites are located about 1.5 km

from Tambanoumouya, are south-east of the final Mine Pit, possess the required capacity and are outside

human settlement areas.

Mako Gold Project


FINAL REPORT 5-26

Source: AMEC 2013c.

Figure 5-1 PFS Waste Rock Dump - Siting options

Option 1 was selected as the preferred WRD location for further assessment in the DFS, due to its proximity to

the Mine Pit thus minimising the haul distance for waste rock. Reduced haul distance will result in lower costs,

noise, dust and habitat fragmentation.

Alternatives were also considered for the disposal of some waste rock to the north and west of the Mine Pit.

These options were discounted due to increased risk of impact to the Niokolo-Koba National Park and priority

habitat.

5.4 Tailings Management Facility

A Tailings Management Facility (TMF) is required to provide for the secure and permanent containment of

tailings slurry discharged from the Process Plant.

Over 16 alternative sites were identified during the Project scoping and screening phase with the required

capacity for tailings storage over the life of mine. This included options in valleys draining the Petowal Hill;

Wayako Valley; east of Wayako Valley; and north of the RN7 but contained within the Mako Exploration Permit.

Many of these options were easily discounted due to the following reasons:

Mako Gold Project


FINAL REPORT 5-27

Greater distance from the Petowal deposit and/or the Process Plant leading to a larger and more

fragmented Project Footprint and higher pumping costs;

Greater impact on settlements and agricultural land in areas north of the RN7; and

Proximity to the PNNK in areas west of Petowal Hill.

Analysis during the pre-feasibility phase of the Project, identified a site within the Wayako Valley. This option

was presented in the Terms of Reference for the ESIA. However, the following impacts and risks were identified:

Relatively high levels of economic impact due to loss of agro-pastoral land and forestry resources; and

The potential requirement for periodic discharge of tailings supernatant during the operational life of

the facility.

Further technical investigations as part of the feasibility study identified the opportunity for disposal of tailings

and waste rock within the Badalla-Petowal Valley. This option is secure and stable from an engineering

perspective and has key environmental and social advantages as detailed below:

No discharge from the TMF to receiving waters during operations due to the relatively small watershed

upstream of the embankment;

Containment by the TMF embankment of all potential contaminated run-off and discharge from other

Project facilities, including WRD, ore stockpiles, Mine Pit and the Process Plant area;

Compact Project footprint significantly reducing the requirement for land and habitat loss, degradation

and fragmentation; and

Relatively minor impacts to local communities resulting from loss of land and natural resources.

Consultation with local communities indicated that this option was preferred relative to the earlier option in

the Wayako Valley.

5.5 Process Plant

Two main process routes were considered in the PFS: a Carbon In Leach (CIL) Plant, and a combined Flotation /

CIL Plant (Lycopodium, 2013a). Both process routes utilise similar crushing and milling circuits; however, the

flowsheet for the downstream circuit differs for the two routes. While the Flotation / CIL plant option reduces

water consumption over the Project lifetime, it also requires the installation of two tailings facilities and

duplication of all associated infrastructure. This would be expected to require additional footprint and

potentially have larger environmental and social impacts from land take and additional rehabilitation

requirements at closure. Further, only a small (approximately 15%) reduction of water consumption would be

expected in comparison to the CIL only option (Lycopodium, 2013a). Given the above, the CIL Plant process

route was selected as the preferred process route for the Project.

Several alternatives for cyanide detoxification / destruction where considered in the design process. Project

testwork confirmed that an INCO-based SO2 / air cyanide destruction circuit would be effective in reducing the

tailings cyanide concentration to meet the International Cyanide Management Code (ICMC) requirement of

<50mg/L WAD cyanide, and this method was therefore selected as the preferred alternative for the Project.

Various siting options for the process plant were also considered and evaluated in order to identify the

preferred option.

5.6 Ore Stockpile

Three main Ore Stockpile locations were assessed for the Project:

Option 1, draining into the Kelendourou and Badalla Valleys;

Mako Gold Project


FINAL REPORT 5-28

Option 2, draining into the Badalla and Wayako Valleys; and

Option 3, draining into the Badalla Valley within the area of the WRD (to be laid upon a bed of waste

rock).

All of the options were located at sites where there was no priority species habitat, artisanal mining or

cultivated land, although the land is suitable for grazing.

Based on the assessment of alternatives, Option 3 within the WRD in the Badalla Valley was chosen based on

proximity to the Mine Pit and Process Plant, as well as environmental and social considerations. As with the

consideration of alternatives regarding the TMF, placing the Ore Stockpile within the Badalla Valley results in a

tight footprint with most infrastructure within one catchment, and avoids impacts on the adjacent Wayako

Valley and creeks that drain back into the PNNK.

5.7 Water Supply and Management Options

5.7.1 Water Supply Alternatives

The Project requires a secure water supply to ensure continuous operation of the Process Plant and for other

mining demands.

Surface water availability in the proposed Mining Concession is characterised by marked seasonal variation,

with little to no surface water flow during the dry season. The Gambia River is the only major surface water

source in the Project area. However there is a significant variation in seasonal flows in the Gambia River at Mako

with approximately 90 % of annual flow occurring during the wet season months (June-October). Peak flow

months for the Gambia River at Mako are August, September and October, at the end of the wet season. Flows

in the Gambia River at Mako gradually decrease over the dry season from November to between little and no

flow at the end of the dry season in the months of April and May.

The Gambia River provides a secure source of surface water for the Project from July to January during a dry

year and from June to March / April in a wet year. The Project will abstract water from the Gambia during this

discharge period and pump it to a Water Storage Dam (WSD). The quantity of water pumped to the WSD will

be sufficient to ensure continuous operation of the Project during both the wet and dry season.

In order to avoid any impacts on hydrology and biodiversity, the pumping regime will only allow water

abstraction from the Gambia River during the wet season. Hydrological studies have shown that the total

annual supply of mine water proposed during a dry year represents 0.04% of the Gambia River annual flow and

0.03% of the annual Gambia River flow during the median year. The WSD would also provide some direct

retention of surface water run-off.

Various siting options for the WSD were also considered and evaluated in order to identify the preferred option.

Hydrogeological information indicated that there was insufficient groundwater in the area to support Project

requirements. Groundwater sources may, however, be sufficient for some applications e.g. drinking water at the

Accommodation Camp.

5.8 Access Roads

A decision was made in the early Scoping Phase of the Project not to use the existing Mako-Tambanoumouya

road as the main access route between RN7 and the PDA. In so doing, the Project would avoid traffic-related

impacts and safety issues to the roadside communities of Mako, Linguekoto and Tambanoumouya. The Main

Access Road was therefore realigned to depart the RN7 at a point west of Niemenike and follow part of an

existing access track south through the Wayako Valley.

Mako Gold Project


FINAL REPORT 5-29

Options to access the Project Development Area via the western foothills of the Wayako Valley were also

discounted due to the presence of groundwater springs which were subsequently identified as an important

dry season drinking water source for wildlife, including endangered species.

Positioning a road upstream of these water points would create a barrier for wildlife access, likely impact on the

water quality and the species relying on it during the dry season. As a result, the alignment of the Main Access

Road was retained within the Wayako Valley until its junction with the existing Mako – Tambanoumouya Road.

5.9 Power Station

There is no opportunity for grid connected power for the Mako Gold Project, and therefore a stand-alone Power

Station will be required. The Project Scoping Study indicated that the generator units for the Power Station

could be run off Heavy Fuel Oil (HFO), Light Fuel Oil (LFO) or diesel. Due to its density, HFO requires specialist

facilities for storage and transport compared to LFO and diesel. However, HFO is significantly cheaper than LFO

or diesel, and is utilised for power generation at other mines such as Teranga’s Sabodala mine.

As a consequence of Project power load (76 GW/a) and duration (8 year mine life), HFO was excluded as an

economically feasible option by power equipment providers due to high capital cost (Toro Gold, 2015g). Given

that the environmental and social implications of transporting and storing HFO and diesel are essentially the

same, diesel was therefore selected as the preferred fuel type for power generation for the Project.

Consideration was also given to establishment of a hybrid power supply facility comprising both diesel fired

engines and solar generation. Under this option solar energy would reduce diesel consumption over the life of

mine and reduce CO2 emissions (greenhouse gas). However, this option was discounted due to the relatively

high capital cost and extended payback period, notwithstanding the need to identify sufficient land area for

the solar field.

5.10 Workforce Accommodation Options

A new Accommodation Camp will be required to support the operation of the Project. The existing Project

Exploration Camp is located on the Mako-Tambanoumouya road and will be retained to accommodate non-

local employees during the Construction phase.

Two alternative camp sites were considered for the new Accommodation Camp, both located along the Main

Access Road for the Project and within the Wayako Valley. The preferred site was located further south and

minimised the risk of disturbance to groundwater springs that were identified as being important for local

wildlife (refer to Section 5.8). Locating the camp at the northern location would increase human presence in

the area as well as potential noise generation, light disturbance and other anthropogenic impacts.

Preferential local recruitment and daily transportation to Kedougou town have minimised the requirement for

providing Project accommodation. The Project camps will only accommodate ‘non-local’ personnel who have

skills and experience that are not available within the Kedougou Region. The majority of the remaining staff

will be recruited from within the Kedougou Region and will therefore already have accommodation within

commuting distance of the Project.

5.11 Not Proceeding with the Project

The direct consequences for Senegal of not proceeding with the Project can be summarised as follows:

The Petowal Deposit would remain undeveloped, and the Project would not contribute to gold exports

from Senegal - consequently, the Sabodala Gold Mine would remain the only large-scale gold mine

currently in operation in Senegal;

Mako Gold Project


FINAL REPORT 5-30

Investment, taxation and royalty benefits from the Mako Gold Project to the Government of Senegal

would not be received;

There would be no opportunity for employment, training or skills development associated with the

Project, with hundreds of Senegal nationals expected to be employed during construction and

operation. Any current Company employees associated with exploration activities in the Exploration

Permit area would not find ongoing employment with the Company;

Improved infrastructure associated with the Project and its benefits to local communities would not be

realised;

Local procurement and strengthening of supply chains would not be realised;

Any land, water and air residual impacts (after mitigation and management) associated with the

development of the mine will not occur;

Potential socio-economic and health impacts and risks of the Project would not occur;

Potential impacts to the terrestrial and aquatic biological environment from the Project would be

avoided, and any environmental and sustainability initiatives (e.g. biodiversity offsets and monitoring)

adopted by the Project would not occur;

The Project would not add to the cumulative impacts of other development in the region – including

both potential positive and negative impacts; and

Villages surrounding the Project Development Area and more broadly the Commune of Tomboronkoto,

would not benefit from community development financed through the Company’s environment and

social investment programme.

If the Project was not to proceed, indirect impacts associated with the Project on water supply and quality (such

as in downstream areas) or increased pressure on local agricultural land, forest and water resources due to in-

migration associated with the Project would not occur. However, indirect socioeconomic benefits would also

not be experienced at both the local and national levels, including induced economic growth and employment.

The experience of other mining projects in Senegal, such as Teranga’s nearby Sabodala Gold Mine, indicates

that these opportunities can be significant. Potential direct and indirect impacts of not proceeding with the

Project are further detailed in Chapters 9 to 11, while potential socio-economic benefits of the Project are

summarised in Chapter 2.

Mako Gold Project


FINAL REPORT 6-31

6 PHYSICAL ENVIRONMENT SETTING

The Mako Gold Project is located on hilly terrain to the north of the Gambia River. Ground elevations range

from 80 metres above sea level (masl) in the vicinity of the Gambia River to approximately 400 masl at the peak

of the Petowal hill.

The region is characterised by a “tropical savannah” climate, comprising a distinct wet season (July to Sept) and

dry season (October to June). The highest total annual rainfall recorded between 1918 and 2014 was 2160.1

mm (1954) and the lowest was 763.7 mm (2007), indicating that total annual rainfall in the Kedougou Region

varies considerably. While parts of Senegal have been subjected to drought and flood conditions in recent

decades, south-east Senegal is less prone to drought conditions. According to global hazard mapping, the

Project is considered to be located within a very low flood hazard zone and a low seismic hazard zone.

The Mako Gold Project and associated infrastructures are located within the catchment area for the Gambia

River. The Gambia River passes to the immediate south of the Project Development Area and crosses into the

Niokolo-Koba National Park further downstream. There are a number of ephemeral streams located within,

immediately downstream, or in the vicinity of the PDA that ultimately drain to the Gambia River (Figure 6-1).

These creeks have no flow during dry periods, and high flow / energy events during periods of high rainfall.

There is significant variation in seasonal flows in the Gambia River at Mako with approximately 90 % of annual

flow occurring during the wet season months (June-October). Between 1970 and 2002 the annual average flow

at Mako was 2,749,108 ML/year and the average daily flow was 7,532 ML/day.

Hydrogeology at the Petowal deposit is characterised by a relatively deep groundwater table and low

permeability fresh rocks. Average groundwater levels around the Petowal pit range from approximately 20 to

70 metres below ground level (mbgl), which reflects the considerable topographic relief. Groundwater levels

towards the valley bottom are typically much shallower, between approximately 3 and 12 mbgl.

The ESIA baseline water quality monitoring indicates generally very good water quality in the Gambia River,

with the exception of bacteriological parameters, with near neutral pH, extremely low to low conductivity, low

suspended sediment concentrations (with the exception of monitoring events during the wet season months)

and generally very low dissolved metal concentrations. The water quality was very similar for surface water

monitoring sites both up and downstream of Mako. Monitoring at tributaries draining the Petowal deposit and

Wayako Valley also indicates very good water quality with near neutral pH, extremely low to low conductivity

and generally very low dissolved metal concentrations. Groundwater quality at monitoring sites in the vicinity

of the Petowal deposit, down hydraulic gradient of the PDA and in the villages of Linguekoto and

Tambanoumouya indicates good quality with near neutral pH, moderate conductivity and generally very low

dissolved metal concentrations. Bacteriological parameters were however elevated in sites down gradient of

the PDA and in the village sites, as were nutrient levels in the village sites.

The current air quality in the vicinity of the PDA is generally good as the area is predominantly a rural

environment. No major industries are present in the vicinity of the Project. The major sources of air pollution

around the PDA include road dust, open cooking, burning, traffic and small artisanal mining operations.

Airborne particulate matter concentrations varied between sampling campaigns, with concentrations

exceeding WHO 24-hour average guidelines for PM2.5, and the 24-hour average guideline for PM10 (50 g/m3)

at Tambanoumouya and Linguekoto (although sites met the Senegalese 24-hour average guideline for PM10 in

the 2013 dry season campaign). The majority of sites met the WHO criterion during the 2014 dry season

campaign. Generally low levels of the gases SO2, O3, NO2 and CO were measured at monitoring sites during the

sampling surveys.

Existing noise emissions in the vicinity of the PDA largely originate from human activity, primarily vehicle and

motorcycle use on roads and pathways, and both domestic and wild animal / insect activity, as well as

thunderstorms. During baseline studies, international day-time standards (55 db(A)) were exceeded in dry

season 2013 in the Niokolo-Koba National Park Buffer Zone (due to presence of cicadas) and in Linguekoto in

wet season 2013, but were otherwise below guideline levels. Wet season night-time noise was characterised by

frogs and insect noise above the IFC night-time criterion (45 dB(A)).

Mako Gold Project


FINAL REPORT 6-32

Figure 6-1 Drainage lines and catchment boundaries adjacent to the Mako Gold Project

Mako Gold Project


FINAL REPORT 7-33

7 BIOLOGICAL ENVIRONMENT SETTING

The Project lies entirely outside of the Niokolo-Koba National Park (PNNK) buffer zone and is located 1 km east

of the PNNK at its closest point. The PNNK is one of the most significant protected areas in Senegal and is an

internationally recognised area for biodiversity (Figure 7-1). The Gambia River runs to the south of the Project

Development Area, and the River and tributaries are the chief freshwater habitats of the region.

Natural vegetation types identified within the PDA are primarily tree savannah, with smaller areas of woodland,

woody savannah and bowal habitat (Figure 6-3). Shrub savannah and gallery forest are found in areas near the

Project, particularly in the PNNK, but not within the PDA. The savannah types and woodland habitat are

considered to be common in nature. Bowal habitat has limited global extent despite being locally common in

parts of Senegal and gallery forest is considered to be of high conservation value to the local area due to its

importance to many priority species of fauna. The condition of the habitat types located within the PDA is

variable, with notable human disturbance particularly due to the presence of land cultivation, grazing, natural

resource collection (e.g. timber) and artisanal mining.

Figure 7-1 Niokolo-Koba National Park boundaries and location of Project

7.1 Priority Species and Habitats

Priority habitats and species have been identified by the Project through an ecological risk assessment, baseline

/ targeted studies and a Critical Habitat Assessment (CHA) (Table 7-1). The CHA (TBC, 2015) was undertaken

using criteria as per IFC Performance Standard 6 (2012) to assess whether the Project Study Area is located in

Critical Habitat, and to identify the Critical Habitat-qualifying features (priority species and habitats). The CHA

also provided focus to the assessment of impacts to priority habitats and species.

Mako Gold Project


FINAL REPORT 7-34

The CHA identified the presence of fourteen highly threatened or restricted-range

species/subspecies/subpopulations (representing eleven species). Several of the species and habitats which

qualified for Critical Habitat were identified during the baseline surveys as occurring in the Project Study Area

and/or the PNNK Study Area. The CHA also determined that the Mako Gold Project is situated in Tier 1 Critical

Habitat, as defined by the IFC Performance Standard 6. Such a designation is based on the presence and/or

quantity of significant types of biodiversity (e.g. rare species, rare habitats) in an area.

Table 7-1 Priority habitats and species

Type of Risk

Receptor

Priority Biodiversity

Features

Critical

Habitat-

qualifying

IUCN

Status

PDA Project

Study

Area

PNNK

Study

Area

Wider

PNNK

Legally

protected area

Niokolo-Koba National Park

(World Heritage Site)

+ + +

Priority

Habitats

Gallery Forest + + +

Bowal + + + +

Gambia River + + + +

Priority Flora

Lepidagathis capituliformis + EN* ? ? +

Scleria chevalieri + CR* ? ? +

Tephrosia berhautiana + EN* ? ? +

Albizia ferruginea VU +

Khaya senegalensis VU +

Vitellaria paradoxa VU

Priority Fauna

West African Chimpanzee (Pan

troglodytes spp. verus)

+ EN + + + +

Western giant eland

(Taurotragus derbianus spp.

derbianus) sub-species:

+ CR + +

African Wild Dog (Lycaon

pictus)

+ EN +

African lion (Panthera leo), West

African population - sub-

population

+ CR + +

African elephant (Loxodonta

africana)

VU + +

Hippopotamus (Hippopotamus

amphibious)

VU + + +

Priority birds

Hooded vulture (Necrosyrtes

monachus)

EN + +

White-backed vulture (Gyps

africanus)

EN + +

Rueppell's vulture (Gyps

rueppellii)

EN +

Mako Gold Project


FINAL REPORT 7-35

Type of Risk

Receptor

Priority Biodiversity

Features

Critical

Habitat-

qualifying

IUCN

Status

PDA Project

Study

Area

PNNK

Study

Area

Wider

PNNK

Egyptian vulture (Neophron

percnopterus)

EN +

Priority fish Barbus dialonensis + VU ? ? ? ?

Key: * = Draft Red List assessments carried out by Royal Botanic Gardens, Kew; + = presence; and ? = occurrence unknown,

further investigation required; CR = Critically Endangered (IUCN, 2015); EN = Endangered (IUCN, 2015); VU = Vulnerable

(IUCN, 2015); Project Study Area = MEC Exploration Permit Area, which incorporates the PDA and the proposed Mining

Concession area, and surrounding habitats; PNNK Study Area = a portion of the PNNK and buffer zone near the PDA

7.2 The Niokolo-Koba National Park

The PNNK is one of the most significant protected areas in Senegal, spanning 9,130 km2 (Figure 7-1). The PNNK

is an internationally recognised area for biodiversity, and has been designated as a natural World Heritage Site,

a UNESCO-MAB Biosphere Reserve and an Important Bird Area (IBA) because of remarkable biodiversity and a

range of ecosystems.

Human pressure on the Park has resulted in it being listed in 2007 on UNESCO’s List of World Heritage in Danger.

The PNNK was originally listed as being in danger due to imminent threats to its Outstanding Universal Values

(OUVs), including critically low mammal populations, ongoing issues with management and the potential

impacts associated with a proposed hydropower development on the Gambia River upstream of the Park. In

June 2014 (UNESCO, 2014), the World Heritage Committee decided to retain the PNNK on the List of World

Heritage in Danger due to concern over the conservation (and low numbers) of key species.

The most significant threat to the OUVs of the property is commercial poaching for the bushmeat trade

(UNESCO, 2007b; 2015). Other threats include livestock grazing, drought, illegal logging and the spread of non-

indigenous and invasive plants (UNESCO, 2007b). Other threats to habitats and species in the PNNK identified

during baseline surveys, include artisanal mining, the creation of tracks and roads (facilitating poaching) and

the collection of non-timber products (e.g. fruit).

7.3 West African Chimpanzee

The West African chimpanzee has been identified as a very high priority species for the Mako Gold Project.

Baseline and targeted surveys confirmed the presence of chimpanzee nesting habitat centred within PNNK

(north-west of Petowal) that extends into the Mining Concession and PDA. The majority of evidence (i.e. nests)

associated with this community was identified within the PNNK and less evidence was found in close proximity

to the proposed footprints of Project components. This community of chimpanzees represents the third known

chimpanzee community in the PNNK.

The exact number of chimpanzees and their range is uncertain. However, camera trapping surveys have

confirmed the presence of between 8 and 12 individuals utilising habitats in the Mining Concession, near a

water source in the Wayako Valley.

Degradation, fragmentation and loss of nesting and foraging habitats and wildlife corridors and increased

competition for food and water sources are major contributing factors in the decline of chimpanzees and

communities in Senegal.

Mako Gold Project


FINAL REPORT 7-36

Figure 7-2 Vegetation and habitat distribution in the vicinity of the Project

Mako Gold Project


FINAL REPORT 7-37

7.4 The Gambia River

The Gambia River, the principal hydrologic feature in the region, is located approximately 1.2 km to the south

of the PDA boundary and crosses into the PNNK a short distance downstream of the Project. A number of small

ephemeral streams (i.e. Badalla Creek) drain the PDA which ultimately discharge to the Gambia River. The

Gambia River is one of the largest rivers in West Africa and is significant in that it is the last major river in West

Africa that retains a natural flow regime.

The Gambia River is a priority habitat for the Project and supports a diversity of aquatic flora and fauna. The

Gambia River is recognised as an important resource for terrestrial fauna (including hippopotami) as well as

birds, especially during the dry season when other water bodies in the area have desiccated. Gallery forest

dominates the riparian zone of the Gambia River in the PNNK, however, much of this habitat has been lost or

degraded near settlements upstream of the PNNK. The Gambia River is also important to a number of villagers

who are partly dependent on fishing as a livelihood activity. The Mako Gold Project recognises the importance

of the Gambia River in terms of its biodiversity and socio-economic values and will act accordingly to avoid,

minimise and restore any adverse project-related impacts on aquatic biodiversity.

Mako Gold Project


FINAL REPORT 8-38

8 SOCIO-ECONOMIC SETTING

The Project lies in a rural area within the administrative boundary of Bandafassi Sous-Prefecture, Kedougou

Prefecture, in the Kedougou Region. The nearest major town, Kedougou, is located approximately 40 km to the

southeast of the Project. Fourteen villages and three independent hamlets with a total of almost 6,500 residents

have been identified in an approximate 10 km vicinity of the Project Development Area. There are no

settlement areas in the PDA. The settlements nearest to the PDA are Tambanoumouya and Linguekoto, while

the largest village is the village of Mako, at a distance of 7 km from the PDA. A number of the villages reported

permanent and seasonal in-migration to their villages. The main reasons for migration were to seek

employment (primarily artisanal mining) and access to agricultural land.

Local communities in the Study Area are highly dependent on crop production, livestock and artisanal mining

to maintain their livelihoods. The collection of forest resources, mainly timber but also non timber forest

products is also important. Artisanal mining has become increasingly important over the last 10 years and

most families in the community have some links to artisanal mining; it is the most significant source of cash

income. Access to the formal economy is limited. Most villages in the Study Area have low levels of business

activity, limited to micro trading shops or mobile (ambulatory) traders. Mako village, however, has a more

developed economy, with a relatively vibrant trading base focused around highway trade.

There are 14 primary schools in the Study Area, while the only secondary school is located in Mako. Literacy

rates are low (21% for men and 12% for women). There is a relatively high level of access to vocational and

trade education in Kedougou. Health care facilities in the Study Area include four health huts, a newly

constructed health post in Mako, a health post in Tomboronkoto, and the nearest hospital is found in Kedougou.

The most common health concerns are malaria, diarrhoea, skin infections, acute respiratory infections, and

asthma. HIV prevalence in Tomboronkoto Commune and Kedougou Region is higher than national rates.

Sanitation standards in Study Area villages are generally low.

Access to water and proximity to the Gambia River were among the most common cited reasons for settlement

in the Study Area. Local residents reported using the Gambia River for washing, watering of livestock and for

gardens. Surface water is not commonly used as a primary drinking water source, however, multiple villages

still use the Gambia as a secondary drinking water source (e.g. Mako, Linguekoto, Soukouta, Tambanoumouya).

Groundwater is the main source of water for domestic use and consumption. All of the Study Area villages have

at least one borehole.

The principal road in the Kedougou region is the RN7, which travels from Dakar through Tambacounda to

Kedougou. The cluster of villages collectively known as Niemenike and Mako are located directly on the RN7.

The road is in varying states of repair. From the RN7, access to the other Study Area villages is by unformed

earth tracks.

Mako Gold Project


FINAL REPORT 8-39

Plate 8-1 Artisanal mining in the vicinity of the

PDA

Plate 8-2 Fisherman on the Gambia River near Maragoukoto

(Badian)

Plate 8-3 Soukouta village

Plate 8-4 Bomboya school latrine

Plate 8-5 Hand pump in Mako

Plate 8-6 Hand pump in Badon

Mako Gold Project


FINAL REPORT 8-40

Figure 8-1 Settlement areas in the vicinity of the Mako Gold Project – showing distances to the main Project

Footprint at the mine site

Mako Gold Project


FINAL REPORT 8-41

None of the local villages have access to grid electricity. Some individual households have generators for

electricity, while solar panels have also been installed on some community infrastructure. The area is covered

by a mobile phone network and mobile phone ownership is steadily increasing.

Archaeology and cultural heritage surveys conducted during baseline studies and ongoing consultations

indicated that the area in the vicinity of the Project was regularly visited and occupied by Neolithic (c. 7500 –

3000 BC) and Historic (post 200 BC) human populations. Of all sites identified in the surveys undertaken,

twenty-five archaeological sites were initially classified as being of high importance and were characterised by

the presence, or evidence, of structures and/or spatially dense and diversified cultural material. Three of these

sites are located in the PDA. Approximately 66 cultural sites were recorded in the Study Area, including

cemeteries and diallang (culturally significant places). Two of these sites, prayer trees, are located in the PDA.

Mako Gold Project


FINAL REPORT 9-42

9 PHYSICAL IMPACTS

9.1 Hydrology, Hydrogeology and Water Quality

Detailed modelling was undertaken to assist in predicting the expected residual hydrology, hydrogeology and

water quality impacts of the Project.

Impacts to surface water hydrology during pre-construction / construction and operations will be moderate.

The hydrology of Badalla Creek and Kobokou Creeks will be significantly impacted during the rainy season,

with flow restricted to that stemming from the catchments downslope of the Project Footprint. Impacts will be

restricted to the lower reaches of Badalla and Kobokou Creeks. The morphology of the Badalla Creek will be

altered and all water flow from the upper reaches of the creek will be impounded in the TMF, while flow of

Kobokou Creek will be impounded in the WSD.

Impacts to the hydrology of the Gambia River will be negligible. Water will be abstracted from the Gambia

River during the wet season and stored in the WSD as make-up water for operation of the Process Plant. Water

abstraction from the Gambia River during the rainy season will not impact the river. The total volume of water

abstracted for the Project is less than 0.04% of the total annual Gambia River flow during a dry year and less

than 0.03% of the flow during the median flow year.

Impacts to the hydrology of Kelendourou Creek will be negligible during operations. Post-closure impacts to

surface water hydrology downstream of the Project Area are expected to be negligible.

The primary impact to surface water quality during construction will be suspended sediments generated from

land clearing / earthworks, extraction from quarries / borrow areas, and road construction / unsealed road

surfaces. The majority of sediment input will result from erosion of disturbed areas during the wet season.

Water courses most affected by suspended sediments are likely to be the Badalla and Kobokou Creek and, to

much lesser extent, the Gambia River.

A number of hazardous materials are required for construction, operations and decommissioning / closure.

There is a risk that fuel and chemical spillage may occur during transport, handling, processing, etc. resulting in

the release of a hazardous substance to soil substrate, downstream / down gradient receiving waters. The

Project has been designed to specifically address and minimise potential risks associated with hazardous

materials, particularly related to transportation.

Groundwater is the main source of water for domestic use and consumption in Project-affected villages. There

is not expected to be any impact on groundwater resources in Project-affected villages. Post-closure, the

development of the pit lake is not expected to substantially alter the hydrogeology of the aquifers of the

surrounding area.

A detailed water management and monitoring programme for the Project has been developed as outlined in

the ESMMP (Volume C), which will ensure that potential impacts of the project related to water quality,

sediment transport and hydrology are minimised. The implementation of the Rehabilitation and Conceptual Mine Closure Plan (Volume E) will ensure facilities are closed and rehabilitated in a way which restores

hydrological regimes and post-closure water quality impacts are minimised.

9.2 Other Key Environmental Aspects

Other potential impacts, risks and opportunities likely to be associated with the development of the Mako Gold

Project are:

Climate and energy – The majority of greenhouse gas emissions associated with the Project are

expected to be generated during operations, and are primarily associated with fossil fuel usage for

power generation and non-stationary mining equipment. The mitigation, and management measures

will minimise greenhouse gas emissions associated with the Project. These will include the use of energy

efficiency measures, as well as monitoring of greenhouse gas emissions.

Mako Gold Project


FINAL REPORT 9-43

Accidental events – A stand alone Risk Assessment report (Etude de Danger) has been prepared which

specifically considers the potential hazards associated with the Project and how these will be mitigated:

including a dam break consequence assessment. Whilst the probability of these events is very low,

emergency response procedures will be required to ensure that risks are minimised and appropriate

action is taken in the event of an accident or natural hazard event. As part of the environmental

management system for the Project, Emergency Preparedness and Response Plans will be developed.

Mako Gold Project


FINAL REPORT 10-44

10 BIOLOGICAL IMPACTS

10.1 Terrestrial and Aquatic Biodiversity

The Project has been designed to minimise impacts on biodiversity features, and extensive consultation with

various stakeholders regarding biodiversity issues has been conducted during the ESIA. The Project has aligned

with best practice and applied the mitigation hierarchy so that adverse potential Project-related impacts are

avoided, minimised, restored or rehabilitated. However it is recognised that even after all feasible mitigation is

put in place, residual impact will remain for some priority habitats and species. A detailed Biodiversity Action Plan (Volume C) has been developed which outlines the strategy for mitigating Project-related impacts and

offsetting residual impacts to achieve at least No Net Loss to biodiversity.

Given the successful implementation of the proposed mitigation and management measures, the residual

impacts that will require offsetting are associated with the chimpanzee, the hippopotamus, and potentially

three species of restricted-range plants (if found to be present in bowal habitat within the Project Footprint).

These residual impacts have been calculated as 1086 quality hectares for chimpanzee habitat, 5 quality

hectares for hippopotami habitat and 24 quality hectares for priority flora and bowal habitat. These residual

impacts are associated with:

Habitat loss – Some loss of habitat (and flora) for Project development cannot be avoided nor mitigated.

The loss will be partially counterbalanced by restoration and rehabilitation activities, the remaining will

be offset as per the Biodiversity Action Plan (Volume C). It is likely that some fauna species will not

return to use this habitat;

Habitat fragmentation, degradation and barriers to movement of fauna – Due to the permanent loss

of habitat, fragmentation effects will remain. Degradation will be reduced, but not eliminated, by

effective mitigation and restoration;

Habitat loss, fragmentation and degradation, and the cumulative disturbance caused by the

Project (i.e. noise, light-spill), are expected to cause permanent displacement of the chimpanzees

known to be currently nesting, foraging and moving through the PDA. This impact will commence in the

Pre-Construction / Construction Phase. Due to the length of time (approx. 8 years) that the mine will be

operating and the level of disturbance caused by its operation, following closure of the Project

chimpanzees may not return to use the habitat in the PDA as they did before. This is a Moderate residual

impact and therefore will be the focus of the offset strategy (see below);

Air and noise impacts on fauna – mitigation and management will aim to attenuate the impacts of air

and noise impacts, but it will be impossible to mitigate all impacts. There will be nuisance level impacts

for fauna species near to the PDA associated with noise and vibration from mine pit blasting. This impact

will gradually decrease as the pit develops, as the pit walls will provide some natural attenuation. With

effective blast management, overall impacts should be minor;

In-migration and increased natural resource collection, fishing and poaching – It is difficult to

quantify the residual impacts arising from Project-induced in-migration, however impacts to habitats

and species from increased natural resource collection, fishing and poaching are expected to be of Minor

to Moderate significance. The Offset Strategy will take a collaborative approach to enhance the

protection of habitats and species in offset sites. Activities proposed as part of the Offset Strategy include

working with local authorities to minimise the impacts of in-migration on natural resource exploitation

and community education and awareness; and

Residual impacts on aquatic biodiversity are expected to correspond to the quality of water released

from the Project and the efficacy of erosion and sediment control. It is difficult to quantify the residual

impacts from in-migration and increased aquatic resource use (i.e. fishing), however it is anticipated

that there will be some risk of residual impacts to aquatic fauna, particularly fish. Given the successful

implementation of the proposed mitigation and management measures, the most significant residual

Mako Gold Project


FINAL REPORT 10-45

impacts at closure for the Project will be some loss of sections of drainage channels within the Project

footprint.

The Company is committed to offsetting the Project-related residual impacts on biodiversity and is developing

an offset strategy with the aim of achieving no net loss on biodiversity and preferably net positive gains. The

offset strategy is presented in the Biodiversity Action Plan (Volume C). Stakeholder consultation and support

is integral to the design and implementation of the strategy. Mitigation measures in the Biodiversity Action Plan are tailored to reducing the impacts on priority habitats (gallery forest, bowal habitat and the Gambia

River) and species (including mammal species, vultures, restricted-range plants and a fish species), but in doing

so, also mitigate impacts on other biodiversity.

A number of candidate offsets sites have been identified and provisionally assessed for technical feasibility. The

next steps for the development of the offset strategy is to carry out a feasibility study where offset sites are

chosen with input from stakeholders, and the requirements for biodiversity gains are assessed. The Company

has also identified a number of Supporting Conservation Actions, which will be implemented and will

contribute to lowering risk or magnitude of the residual impact and will provide broad scale benefits to

biodiversity.

With the successful implementation of this offset programme and the other biodiversity management and

mitigation measures outlined in the Project management plans, the Project is not expected to result in any

significant adverse impact on biodiversity features.

Mako Gold Project


FINAL REPORT 11-46

11 SOCIAL IMPACTS

11.1 Economic Development and Employment

Economic development at national, regional and local levels is likely to be one of the most significant benefits

of the proposed Project. Revenues to be paid by the Project to the Government are based on the Mining Code

(2003), the General Tax Code (2012) and the Company’s Mining Convention with the Government. Tax income

associated with capital expenditure along with employment and material supply expenses will make a

significant contribution to the development of the Senegalese economy. Direct economic benefits to the

national Government and economy are likely to include:

Free issue of shares (10% of the Project ownership as a free carried interest);

Taxes and royalties;

Dividends;

Labour costs; and

Payments to suppliers.

The anticipated economic benefits of the Mako Gold Project at the national level will include direct economic

benefits (e.g. dividends, royalties, taxes and duties, salaries and expenditure) and indirect economic benefits

(e.g. flow on effects, training and skill development, infrastructure development). Revenues to be paid by the

Project to the Government are based on the Mining Code (2003), the General Tax Code (2012) and the Company’s

Mining Convention with the Government. The most significant benefits will be received over the construction

and operations period covering approximately 8 years.

If managed effectively, the injection of income and economic opportunity into the local community as a result

of the Project will be a major benefit for the local community. Through employment, training, procurement

and livelihood improvement programmes, the Project can be a catalyst for sustained economic growth in

Tomboronkoto Commune and the Kedougou Region more generally. The Company ’s existing social investment

programme will also continue to complement Project-related activities and contribute to achieving local

development objectives.

The Project pre-construction and construction activities are expected to last 18 months. The Project will provide

employment for approximately 700 – 900 workers during construction with a maximum permanent operations

workforce totalling between 300 - 360 persons during the operations phase. Approximately 90% of the

workforce will be national employees of which 30% are estimated to be sourced from within the Kedougou

Region during construction and 45% during operations. The Company will support skills training of local

villagers to prepare them for employment with the Project and ‘on the job’ training. The Project, and Project

employees, will also require goods and services to be procured in the local area. Local procurement will result

in increased business opportunities for local villages (particularly Mako and Niemenike and surrounding

villages). The introduction of new employment, training and business opportunities (both direct and indirect)

is likely to increase average income in the Project-affected villages and result in an improvement in living

standards.

The Company is committed to assisting local business development, actively identifying opportunities to

outsource services and giving preference to local businesses. Local infrastructure and services will be upgraded

to directly support Project development. Elements of this infrastructure and services will also benefit local

communities, in particular the upgrade of local roads, telephone networks, transportation services and access

to markets. The Project design includes the upgrade and maintenance of the Mako - Tambanoumouya road

and construction of the Main Access Road. The upgrade of local roads will facilitate transport of agricultural

inputs, accessibility to land holdings and access to markets and services, particularly for residents of Niemenike,

Tambanoumouya and Linguekoto, further promoting local economic development.

Mako Gold Project


FINAL REPORT 11-47

In addition, the Project will continue its social and environmental investment towards conservation and

biodiversity management within and adjacent to the PNNK, and community development in Tomboronkoto

Commune.

11.2 Displacement, Access and Land Use Impacts

There is not expected to be any resettlement or physical displacement of households from the Project, as no

settlement areas occur within the proposed Project Development Area.

Most of the Project impact on farmland will be on fallow farms of long duration, which are not in immediate

demand due to the reduced level of farming activity. Construction of the Main Access Road will result in the

direct loss of a small amount (<3 ha) of actively cultivated agricultural land. This will affect arable land owned

by the villagers of Tambanoumouya, Linguekoto, Niemenike and Badon.

The Main Access Road will be accessible to the public and will improve access through the Wayako Valley.

Improved access will likely have a positive impact on the viability of farming in Wayako Valley, and may

stimulate renewed interest in farming there.

The total area of agricultural land expected to be lost is approximately 46.5 hectares (Table 11-1 and Figure 11-

1). Approximately 35 ha of this land has lain fallow for more than ten years.

Table 11-1 Impact on arable and fallow land, by location

Location and Cause

of Impact

Affected

Villages

Area Affected

(ha)

Description of Affected

Area

Pre-Mitigation Impact

Evaluation

Petowal/Badalla

Valley: TMF, WRD

(small portion) and

security buffer

Tambanoumouya

28.5 Fallows of about 30 years;

sloping, stony land, suitable

for manual cultivation only.

The land is not currently in

use or in immediate demand

and alternative farming areas

are available. Overall impact:

minor

Kobokou Valley:

Water Storage Dam

and security buffer

Tambanoumouya

(one household)

7 A single fallow farm

consisting partly of sloping

land and partly of valley

bottom land.


use or in immediate demand,



minor

Kobokou/Wayako:

Proposed new

accommodation camp

Tambanoumouya

(two households)

3.4 A single fallow (for more than

10 years) farm consisting

partly of sloping land and

partly of valley bottom land,

and a fraction of an adjacent

farm.


use or in immediate demand,



minor

Dinkoncono, Main

Access Road

Niemenike

1.3 The Main Access Road will

bisect a small number of

active and/or fallow farms.

The impact on any particular

family will only be a fraction

of their land. Overall impact:

minor Badon

(one household)

< 0.5

Wayako Valley, Main

Access Road

Tambanoumouya

4.64 The Main Access Road will

bisect a moderate number

of active and/or fallow

farms. The majority of the

The impact on any particular

family will only be a fraction

of their land. Overall impact:

minor Linguekoto 0.6

Mako Gold Project


FINAL REPORT 11-48

Location and Cause

of Impact

Affected

Villages

Area Affected

(ha)

Description of Affected

Area

Pre-Mitigation Impact

Evaluation

Mako

(one household)

< 0.5 Tambanoumouya land has

been fallow for more than

10 years.

In relation to pastoralism, cattle owners in Tambanoumouya and Linguekoto will lose access to a portion of

their traditional grazing land. Seven households in Tambanoumouya are expected to be impacted by the loss

of the Petowal Hill wet-season cattle grazing area and the Kobokou grazing area. Only four households own

cattle in Linguekoto, and herders have a number of alternative grazing areas available in all seasons.

Plate 11-1 Millet adjacent to a track in Wayako Valley

Plate 11-2 Mixed cultivation surrounding an

agricultural hut in Wayako Valley

Mako Gold Project


FINAL REPORT 11-49

Figure 11-1 Agricultural land in the vicinity of the Project (MEC, 2014)

Mako Gold Project


FINAL REPORT 11-50

Project-induced in-migration may result in increased pressure on agricultural land in the vicinity of the PDA.

This may include conversion of arable land to residential land (i.e. construction of housing for migrants). Land

adjacent to the Niemenike cluster of villages, Mako and the Main Access Road is likely to be most susceptible

to in-migration impacts.

The loss of parts of the Badalla and Kobokou artisanal mining sites and the reduction in wet-season water flow

in the ephemeral streams downstream of these sites will most significantly impact the artisanal miners of

Tambanoumouya and Linguekoto. However, affected miners have low sensitivity to these impacts as there are

other available and attractive mining sites nearby, including lower Badalla, Niamanoukhou and the Gambia

River, while water availability will only be reduced (in the wet season and on a temporary basis) rather than

eliminated.

The Company has committed to a number of programmes related to agriculture and land use as part of their

Livelihood Restoration Plan (Volume D). Table 8-2 below provides a summary of the livelihood restoration

measures for each type of impact.

Table 11-2 Summary of the livelihood restoration measures, by impact type

Type of Impact Main Villages Livelihood Restoration Measure

Loss of grazing land Tambanoumouya, Linguekoto,

Niemenike, Mako

Grazing land management and enhancement in

Tambanoumouya and Linguekoto

New livestock water points outside of the Project area

Post-mine restoration of grazing resources

Loss of forest land Tambanoumouya, Linguekoto Replacement and propagation of useful trees

Post-mine restoration of forest resources

Loss of agricultural

land

Tambanoumouya, Linguekoto,

Niemenike

Facilitation and compensation for replacement of agricultural

(active and fallow) land for affected families

Land preparation for replacement of active farms for affected

families


Niemenike, Mako

Intensification of agriculture through irrigation

Loss of artisanal

mining sites


Niemenike, Mako

Intensification of agriculture through irrigation

Restrictions on access

to lands outside of PDA

Tambanoumouya, Linguekoto

Improvement and maintenance of Mako-Tambanoumouya

road

Public use of Main Access Road which will improve access to

and through Wayako Valley

Livelihood pilot programmes have already been developed and tested by the Company to enhance agricultural

productivity in Tambanoumouya and Linguekoto villages.

Given the successful implementation of the livelihood restoration and improvement measures proposed, the

residual adverse impacts of the Project livelihoods due to potential impacts on arable land, grazing areas and

crop production are considered to be negligible. The livelihood of all impacted households will be restored

and, where possible, improved. Monitoring of social indicators will also be conducted over the life of the Project

and management measures will be updated accordingly where required.

Mako Gold Project


FINAL REPORT 11-51

11.3 Cultural Heritage and Archaeology

No sites of national or international archaeological or cultural heritage significance have been identified as

being directly impacted by the Project components.

Approximately 66 cultural sites were identified in the vicinity of the PDA during multiple baseline surveys

conducted between 2012 and 2015. The Project Footprint is expected to directly impact two prayer trees within

the PDA, which are of local cultural significance for the villagers of Tambanoumouya. The Company has

committed to engage a Senegalese cultural anthropologist or sociologist to carry out the consultation process

regarding the prayer trees to be impacted and supervise any compensation.

Archaeological surveys of the Study Area identified a total of 141 archaeological sites and 820 isolated sites

(defined as more than five artefacts greater than 50 years old within a 15 m diameter). The vast majority of the

materials recovered from the sites are from the “Historic” period, particularly the latter part of the second

millennia (i.e. the last 500 years). Several examples of Neolithic (circa 7500 – 3000 BC) tools were obtained while

no Palaeolithic or Iron Age objects were encountered. Four sites considered of ‘Medium’ archaeological

importance and one site of ‘High’ archaeological importance have been identified within the Project footprint,

and are expected to be lost as a consequence of Project development. No sites containing Neolithic material

fall within the Project Footprint.

The Company has committed to conducting further archaeological investigations of sites within the Project

footprint in accordance with the expert archaeological advice. Appropriate mitigation measures for material

culture will be agreed with relevant stakeholders such as local government and the Ministry of Culture.

Additional mitigation measures are also expected to be implemented to assist in minimising the risk to other

archaeological sites including designation of ‘No Go Areas’, implementation of a Chance Find Procedure and

awareness programmes. With implementation of the proposed measures, the residual impacts of the Project

on archaeology are expected to be minor.

11.4 Other Community Impacts

As per Section 8.2, there are no settlement areas in the PDA and therefore no requirement for physical

displacement or resettlement of settlement areas, however several villages are located in the surrounding area.

The settlement nearest to the PDA is Tambanoumouya located approximately 1.3 km from the PDA at its

nearest point. The largest village in the vicinity of the Project is Mako, at a distance of 7 km from the PDA.

In addition to the impacts and benefits described in the sections above, other issues and risks for existing

villages associated with the development of the Mako Gold Project are:

Dust – During the dry season, the villages of Mako and Linguekoto could experience minor impacts from

dust during the upgrade of Mako-Tambanoumouya road, as their settlement areas are located directly

along this road. These impacts will be short term and localised. In the Operations Phase, dust may be

noticeable within approximately 5 km of the PDA during days when wind conditions promote

dispersion. Five settlements occur within 5 km of the PDA which are the villages of Tambanoumouya

and Kerekonko, and the hamlets of Dalakoy, Wassadou and Linguekoto. Negligible dust impacts are

expected for all local villages during Project decommissioning/closure as well as post-closure. Dust

suppression will be undertaken to minimise dust where Project activities are likely to have an adverse

impact on sensitive receptors, and dust monitoring will be conducted at these sensitive receptors.

Other Air Emissions – With effective implementation of the proposed management measures, impacts

on settlement areas from other air emissions (e.g. exhaust emissions from fuel combustion) are expected

to meet Senegal Government and IFC emission and ambient air quality standards.

Noise – During the Construction Phase, minor temporary noise impacts for some parts of the settlement

areas in Mako and Linguekoto may occur during the upgrade of the Mako - Tambanoumouya road.

During Operations, some noise from truck/vehicle movement along the Main Access Road may be

discernable in Tambanoumouya and other nearby villages under certain climatic conditions. This is not

expected to have any health or significant nuisance impacts.

Mako Gold Project


FINAL REPORT 11-52

Vibration / Airblast– Potential impacts on sensitive receptors from vibration can occur due to ground

or air vibrations (airblast). Project impacts on settlement areas associated with ground vibrations from

the Project are not expected to be significant. With appropriate mitigation, there should be only minor

nuisance level impacts associated with airblast from Mine Pit / quarrying blasting for two settlements

located within 3 km of the PDA (Tambanoumouya and Kerekonko), and negligible impact for settlement

areas beyond this distance. This impact will progressively decrease as the pit develops, as the pit walls

will provide some natural attenuation. Negligible vibration impacts are expected to occur for sensitive

receptors in the Decommissioning / Closure Phase, and post-closure, as no blasting is required.

In-migration – The Project will create many employment and other economic opportunities that will

lead to Project-induced in-migration, particularly during construction. Villages such as Mako and the

Niemenike cluster are expected to experience the highest levels of Project-related in-migration, with

moderate levels of in-migration also expected for other villages adjacent to the Project. This can lead to

positive benefits for economic development, however, careful management will be required to avoid

and minimise the potential adverse impacts where possible (e.g. pressures on land resources and social

services). The Company has committed to work closely with local authorities and communities to assist

in ensuring potential impacts of in-migration are minimised. This will include developing a Hygiene and

Sanitation Programme in partnership with local government in Project-affected villages, and

construction of potable water infrastructure in key villages. During closure, a net out-migration may

occur, as people leave to seek other employment opportunities.

There will also be an influx of Project employees and contractors to the Project area. This influx will be

minimised through preferential local recruitment policies and worker accommodation measures, while

impacts to villages will be reduced through measures such as the enforcement of codes of conduct for

all Project employees and contractors, and restrictions of access to villages.

Health and Safety – The presence of the Project is generally expected to improve local health facilities

and services in local villages in the area, such as improvement of water supplies and sanitation facilities

through the Project’s mitigation and investment programmes, and easier access to such services (e.g.

through road upgrade and maintenance). This is a significant potential benefit of the Project. The Project,

however, may result in health impacts such as a potential increase in infectious diseases due to Project-

induced in-migration. As above, villages such as Mako and the Niemenike cluster are expected to

experience the highest levels of Project-induced in-migration, and therefore are likely to be at highest

risk of associated health impacts. The Company will mitigate the impacts of Project-induced in-migration

on public health, in partnership with the relevant technical services and the Commune Council.

Fly rock – An exclusion zone of at least 500 m around the pit to protect people and structures from

flyrock. Flyrock will be carefully managed to ensure community safety risks are minimised, particularly

in relation to unauthorised access to exclusion zone during the blast sequence. Access restrictions to

the exclusion zone will be enforced and security personnel will be employed at key Project access points

(road infrastructure) to prohibit access via the most obvious routes.

Fisheries and aquatic resource use – Fishing and use of aquatic resources are not of significant

importance for local food security, and are generally of low importance for livelihoods and income.

Fishing is conducted by some households, particularly in the wet season. Potential impacts on aquatic

resource use from the Project will primarily be associated with risks to water quality within the Gambia

River. Minimising potential impacts on downstream water will be a priority for the Company and

detailed management and mitigation measures will be implemented to minimise these impacts (see

Chapter 9). A minor increase in pressure on aquatic resources may occur due to Project-induced in-

migration.

Terrestrial Resources – The collection of TFPs and NTFPs was considered to be of moderate importance

for local subsistence use, as well as cultural use and food security. Project development will result in the

loss of approximately 240 ha of natural habitat (e.g. grassland / bowal, woodland and savannah) as a

result of vegetation clearance. This is considered to be of minor significance due to the availability of

alternative areas for collection of terrestrial resources in the Project area. Indirect impacts will occur due

to changes in accessibility and population pressure due to in-migration. Impacts on terrestrial resource

Mako Gold Project


FINAL REPORT 11-53

use will be minimised through the implementation of the Livelihood Restoration Plan for the Project

(Volume D) as well as the Biodiversity Action Plan (Volume C). Following the implementation of

mitigation measures, residual impacts on ecosystem services associated with terrestrial resource use will

be minor for the village of Tambanoumouya and negligible for other Project-affected villages.

Visual Amenity – As all settlements are located several kilometres from the main Project infrastructure,

visual amenity impacts for key sensitive receptors will be negligible for most settlements in the

surrounding area. However, during construction and operations, the visual amenity for the villages of

Tambanoumouya and Kerekonko may be moderately impacted, with direct line-of-site to some of the

Badalla Valley vegetation clearance and Power Plant construction area. Post-closure, rehabilitation and

revegetation activities will progressively return the visual amenity of temporarily disturbed areas to pre-

Project conditions.

Mako Gold Project


FINAL REPORT 12-54

12 NIOKOLO-KOBA NATIONAL PARK

Notably there will be no direct impact of the Project on habitats within the Niokolo-Koba National Park (PNNK)

and buffer zone arising from habitat clearance as none of the Project components are located within these

areas. Given the successful implementation of the proposed mitigation and management measures, the

residual impacts for the PNNK Outstanding Universal Values (OUVs) are expected to be:

In-migration and natural resource collection, poaching and fishing– It is difficult to quantify the

residual impacts arising from Project-induced in-migration, however impacts to habitats and species

from increased natural resource collection, agro-pastoral activities, poaching and fishing in the eastern

periphery of PNNK are expected to be of Minor significance. As part of the Offset Strategy the Company

will support management activities in the PNNK including strengthening enforcement. The Offset

Strategy will also take a collaborative approach to further enhance the protection of habitats and species

in candidate offset sites including the PNNK Study Area. Activities proposed as part of the Offset Strategy

include working with local authorities to minimise the impacts of in-migration on natural resource

exploitation and community education and awareness.

Habitat loss, fragmentation and barriers to movement for PNNK ranging species – Most OUV species

of the PNNK appear to be currently restricted to the PNNK and therefore their movement patterns will

not be affected by the Project. Habitat loss and fragmentation is expected to act as a barrier to the

movement of chimpanzees outside of the PNNK and buffer zone. The degradation and fragmentation of

fauna habitats will be partially counterbalanced by restoration and rehabilitation activities as per the

RCMCP (Volume E), however habitat will not be completely restored at closure. Many species are

expected to return and use the revegetated areas within the Project Footprint post-closure including

leopards, Guinea baboons and other legally protected species. However, chimpanzees are considered

unlikely to return and use the habitat in the PDA as they did before the Project. The Company is

developing an Offset Strategy which will offset residual impacts to chimpanzees and their habitat.

Vehicle collisions – PNNK fauna are most at risk of collision on the existing RN7 which passes through

the PNNK and which will be the primary transportation route during all Project phases for supplies and

material delivery. However, only approximately three trucks per day are expected for Project-related

transportation, while total daily traffic movements are estimated to be approximately 300 on the RN7.

With the implementation of the proposed management and mitigation measures (e.g. speed limits,

restrictions on night driving, driver safety awareness training), there should be Minor impact on the OUVs

and other biodiversity values of the PNNK from vehicle collisions.

Invasive species encroachment –There should be no residual adverse impact of the Project on the

PNNK due to spreading of invasive plants. The risk of introduction of introduced species will be Minor.

Hydrology and water quality – There is expected to be no residual impacts to hydrology and water

quality within the PNNK following implementation of mitigation and management measures.

Noise and vibration – The proposed mitigation and management programme for noise and vibration

will greatly reduce the potential for noise, vibration and airblast impacts on the wildlife of the PNNK

which lead to species displacement and dispersal, but it will be impossible to mitigate all impacts. In

particular, there will still be some noise and vibration from blasting reaching the eastern periphery of the

PNNK which may cause some disturbance to priority species including African elephant, western giant

eland, African lion, chimpanzee and potential African wild dog (if present). Residual impacts are expected

to be of minor significance to OUVs.

Artificial lighting - There is a minor risk of disturbance to PNNK ranging fauna due to light spill from the

Project areas during operation. Impacts due to Project lighting could result in movement of some

nocturnal wildlife away from the part of the eastern periphery of the PNNK close to the Project further

into the Park following Project commencement, with some species also becoming adapted to the new

lighting regime. This disturbance will be temporary and will cease post-closure.

Mako Gold Project


FINAL REPORT 12-55

With the implementation of the Biodiversity Offset Strategy, and the other biodiversity management and mitigation measures proposed, the Project is not expected to result in a significant impact on the OUVs of the PNNK.

Mako Gold Project


FINAL REPORT 13-56

13 CUMULATIVE IMPACTS

The Mako Gold Project area is relatively undeveloped, with few major industrial projects in the region. As such,

and given the lack of nearby major developments / activities, the Project is not expected to significantly hinder

the development of any other existing or planned projects, and is not expected to result in any significant

environmental and social cumulative impacts. The biggest contribution from the Project is likely to be

associated with further enhancement of the socio-economic development of the region and development of

a stronger mining skills base in the Kedougou region.

The proposed Sambangalou Hydropower Dam will lead to altered hydrology in the Gambia River upstream of

the Project. Whilst this development will impact the Gambia River, its impact on the development of the Project

(and vice versa) is expected to be negligible.

The Company has incorporated environmental and social considerations into numerous aspects of the Project

design, and a detailed management programme has been developed, which will assist in minimising adverse

cumulative impacts associated with the Project. Local, regional and national level government and stakeholder

consultation will need to be undertaken throughout the life of the Project to understand and manage any

potential cumulative environmental and social risks. The proposed consultation for the Project is outlined in

the Stakeholder Engagement Plan (Volume C).

Mako Gold Project


FINAL REPORT 14-57

14 STAKEHOLDER CONSULTATION AND PUBLIC INVOLVEMENT

Throughout the ESIA process, consultation and disclosure of Project information has been undertaken with

National, Regional, Department and Sub-prefecture government officials, the local community, and a variety of

other key stakeholders. Formal consultation has included structured presentations, workshops and meetings.

Project information has been disclosed through various means including formal reports, workshops, village

assemblies and focus group discussions. Consultation for the ESIA builds upon existing community and

government relationships formed through exploration activities.

Planning for further stakeholder engagement to support construction and operations is presented in the

Stakeholder Engagement Plan (Volume C).

The overall goal of stakeholder engagement for the Mako Gold Project is to improve decision-making, build

understanding to ensure the long-term viability of the Project and to enhance potential Project benefits. The

specific objectives of the stakeholder consultation for the Mako Gold Project ESIA are to:

Establish a two-way dialogue that gives both sides the opportunity to exchange views and information,

to listen, and have their issues heard and addressed;

Put in place the participatory planning, implementation, and monitoring processes required to deliver

on social and environmental management commitments;

Disseminate understandable information in advance of consultation and decision-making, using easily

accessible methods and locations;

Ensure inclusiveness in representation of views, including women, youth, marginalized, vulnerable

and/or and minority groups;

Set up processes free of intimidation or coercion, where all participants are fully aware of their rights

according to national law and international standards;

Develop structured mechanisms for responding to people’s concerns, suggestions, and grievances; and

Demonstrate how feedback was incorporated into project or programme design, and report back to

stakeholders on a regular basis.

14.1 Stakeholder Identification and Analysis

For the Project, key stakeholder groups include Project Affected Villages (including water users, villages along

the site access route), Government of Senegal (at local, regional and national levels), and the multi-state

institutions and non-government organisations. Key stakeholder groups have been identified and are

presented in Table 13-1.

Table 14-1 Summary of key stakeholder groups

Stakeholder

Classification

Stakeholder Group Stakeholder Priorities

Communities

Project Affected Villages

Villages impacted by land acquisition, noise

and dust impacts; downstream villages; villages

along access route; host communities for

Project induced in-migration

Jobs and skill development

Local economic development

Community infrastructure and services

Livelihood restoration and improvement

Informed consultation and participation

Health, safety and security

Artisanal Mining Sites

Mako Gold Project


FINAL REPORT 14-58

Stakeholder

Classification


In-migration

Other villages in the Commune of

Tomboronkoto





Commune Council of Tomboronkoto Support for the preparation of the Commune

development plan (PDC)

Share Project benefits across the Commune





Departmental Council of Kedougou Support for the preparation of the Departmental

development plan (PDD)

Share Project benefits across the Department



Government

Ministerial Authorities Comply with relevant legislation

Alignment with relevant international

conventions and treaties

Alignment with national and regional

development plans

Responsible environment and social

management

Economic development

Administrative Authorities: Governor / Prefect /

Sub-prefect

Comply with political and administrative

process and priorities

Share Project benefits across the larger

political and administrative area


management



Informed consultation

Regional Technical Agencies Project benefits and activities conform with

regional strategies


management


Multi-state Institution

United Nations Educational, Scientific and

Cultural Organisation (UNESCO)

Protect the world heritage values of the PNNK



Promote heritage values through education

and scientific research

Organisation pour la Mise en Valeur du Fleuve

Gambie (OMVG)

Protect the environmental and social values of

the Gambia River

Mako Gold Project


FINAL REPORT 14-59

Stakeholder

Classification


Comply with license conditions for

construction and operation within the Gambia

River watershed

NGOs

International Union for the Conservation of

Nature (IUCN) and other environmental NGOs

Protect the world heritage values of the PNNK,

including threatened species and habitats



Investment in habitat enhancement

Rural Development Projects and NGOs Alignment with other development objectives

in the local area

Research

Threatened species and habitat researchers Protect threatened species and habitat

Alignment with other conservation objectives

in the local area

Institut Fondamental d'Afrique Noire (IFAN) Protect cultural heritage values

Promote heritage values through education

and awareness programmes

Other Other development projects planned for the

project region

Coordinate development activities and/or

programmes

14.2 Stakeholder Consultation Completed to Date

The Company initiated a consultation process with key stakeholders at an early stage of the Project

development. This continuous process was initiated at the beginning of the Exploration phase and will

continue throughout the life of mine. Key stakeholder engagement activities conducted for the ESIA of the

Mako Gold Project included:

Disclosure of the Terms of Reference for the Environmental and Social Impact Assessment;

Consultation with local villages in the design and implementation of preliminary environmental and

social baseline studies;

Conduct of comprehensive environmental and social baseline studies involving a range of research

institutes and scientific organisations, including: the ISE (L'Institut des Sciences de l'Environnement,

Université Cheikh Anta Diop); IFAN (Institut Fondamental d'Afrique Noire, Université Cheikh Anta Diop);

and Faculty of Science and Technology (Université Cheikh Anta Diop);

Collaboration with the Direction of National Parks and Direction of Forestry in the conduct of terrestrial

ecology surveys both within the Exploration Permit Area, and adjacent areas of the Niokolo-Koba

National Park;

Participative impact and mitigation planning with local villages, particularly relating to livelihoods, land

and water in the vicinity of the Mako Gold Project;

Development of livelihood pilot programmes in Tambanoumouya, Linguekoto, Niemenike and Mako;

and

Partnership with the Tomboronkoto Commune in the realisation of its Local Development Plan including

activities that have improved access to clean water, health services, education materials and

opportunities for income generation.

Mako Gold Project


FINAL REPORT 14-60

Stakeholders’ feedback has directly informed Project design and the management and mitigation measures

presented in the ESIA.

A summary of consultation processes completed to date is provided in Table 13-2.

Table 14-2 Summary of consultations and surveys undertaken for the Mako Gold Project to date

Consultation Stakeholder Period and Objectives

Draft ESIA Terms of Reference Project-affected Villages, Commune

Council of Tomboronkoto, government

and administrative authorities, Multi-

state institutions, Research

organisations, NGO representatives

March – July 2014

Preliminary ESIA results Project-affected Villages, Commune


and administrative authorities, multi-

state institutions, Research

organisations, NGO representatives

April – May 2015

Preliminary Project design and key

impacts

Project-affected Villages, Commune


and administrative authorities

January – February 2015

Biodiversity ‘no net loss’ strategy Commune Council of Tomboronkoto,

government and administrative

authorities, multi-state institutions,

Research organisations, NGO

representatives

November 2013

Socio-economic and household surveys

and population census

Project-affected Villages November 2012, September 2013,

August 2014

Women and youth focus group

discussions

Project-affected Villages November 2012, February and March

2015

Artisanal mining surveys Artisanal miners, village chiefs,

government authorities, NGO

representatives

November 2012 and March 2015

Participatory land-use surveys and

mapping

Project-affected Villages April and September 2013, August 2014

Archaeology and cultural heritage

survey

Project-affected Villages, research

organisations

November 2012, April 2013, May –

June 2014

Terrestrial and aquatic ecology surveys Project-affected Villages, government

authorities, research organisations

February, August-September 2013,

June- July 2014

Participatory social impact and

mitigation planning

Project-affected Villages, Commune

Council of Tomboronkoto, Chamber of

Commerce, Chamber of Trades

December 2014 – March 2015

Downstream water use surveys Project-affected Villages February – March 2015

Cumulative impact surveys Commune Council of Tomboronkoto,

government authorities

March 2015

Mako Gold Project


FINAL REPORT 14-61

Plate 14-1 Water use survey – Men’s focus group in Kerekonko

Plate 14-2 Water use survey – Women’s focus group in Wassadou

Plate 14-3 Village consultation (youth) in Bomboya

Plate 14-4 Village Consultation in Badian 1

Plate 14-5 Village consultation in Soukouta

Plate 14-6 Village consultation in Dalakoy

Mako Gold Project


FINAL REPORT 14-62

14.2.1 Summary of Consultation Outcomes

In general, consultation has found that Project Affected Villages and other stakeholders were supportive of the

Project and appreciative of their involvement in the progressive phases of Project design. The key stakeholder

priorities are listed in Table 13-1. The opinions and suggestions of stakeholders obtained through the

Stakeholder Engagement process have been, and will continue to be, considered in the design of the Project

and associated management plans. Further detail regarding the consultation outcomes are provided in the

ESIA Chapter 14 (Volume A).

14.3 Continuing Consultation for the Life of the Project

The Company has committed to continuing formal and informal consultation with stakeholders as the Project

progresses.

As part of its ongoing consultation process, the Company will continue to work with the various established

focus groups to facilitate ongoing discussion of specific Project-related issues. These groups include:

Conseil Municipale of Tomboronkoto (CM) - led by the elected commune mayor and comprised of

directly elected councillors representing the commune. All of the Project-affected communities are

located within the Commune of Tomboronkoto. Meetings will be held with the Conseil Municipale

throughout the engagement process and at key Project milestones where outputs will be reviewed and

approved;

Consultation Committee / Groupe de Contact (GdC) is chaired by the Mayor of Commune of

Tomboronkoto and comprises: two deputy Mayors and elected representatives of affected villages

(including women and youth representatives). The GdC will serve as the main multi-stakeholder forum

that will make key decisions and monitor the implementation of Project commitments;

Focus Group Discussions (FGD) will continue to be held with vulnerable groups, including women and

youth, to ensure they have a safe and open space to discuss the Project and to outline their priorities

around social impacts and social management activities; and

Five Thematic Working Groups (TWG) (land acquisition and livelihood restoration; conservation and

biodiversity management; urban infrastructure and services; local procurement; local employment) will

help facilitate discussion around specific issues as well as the planning and implementation of various

social management plans. Working groups will be comprised of directly affected people and local

experts. It will be a priority to ensure equal representation of men, women and youth, wherever possible.

These groups have proved to be effective forums of discussion and the Company will continue using these

consultation structures over the life of the Project. Consultation with these groups will be critical to the

refinement and implementation of environmental and social management plans such as the Livelihood

Restoration Plan and Biodiversity Action Plan.

14.4 Grievance Management

A Grievance Mechanism receives and addresses concerns raised by stakeholders in a transparent, constructive,

timely, confidential (if desired), culturally appropriate and accessible manner.

The Company currently maintains a simplified grievance mechanism to support Project exploration activities.

The informal resolution process involves the Mako Exploration Camp Manager, village and commune-level

leaders, and the sub-prefect where necessary.

The Company will develop a more comprehensive Grievance Mechanism, adapted from the IFC’s Guide to

Designing and Implementing Grievance Mechanisms (2008), to support Project development.

Mako Gold Project


FINAL REPORT 14-63

14.5 Reporting to Stakeholders

The Company will regularly report on the environmental and social performance of the Project to stakeholders.

Reporting will include a quarterly operations report to summarise the Company’s environmental and social

performance and significant activities, incidents and event for that period. The report will be submitted to the

relevant Senegalese authorities in Kedougou and Dakar on a quarterly basis. The Company will also prepare an

Annual Sustainability Report to summarise business and sustainability performance for each calendar year,

which will be made available to stakeholders.

Reporting practices are further detailed in the ESMMP (Volume C).

Mako Gold Project


FINAL REPORT 15-64

15 MANAGEMENT AND MONITORING

15.1 Environmental Management System

The Company is committed to establishing an Environmental Management System (EMS) for the Mako Gold

Project which is consistent with Government of Senegal legislation and aligned with international standards

(i.e. ISO14001, OHSAS 18001 etc.) This management system will provide the Company with a procedural

framework for implementing, achieving, reviewing and maintaining the Company’s environmental and

community policies and all environmental and social management targets.

A professional management and monitoring programme has been developed for the Project in keeping with

international mining standards. The programme has been documented in the detailed Environmental and Social Management and Monitoring Plan (ESMMP, Volume C). The ESMMP also includes a range of Standard

Operating Procedures that provide general environmental and social management measures to manage

Project impacts.

The Company aims to offset any residual impacts on biodiversity values, to achieve at least no net loss, as

outlined in the Biodiversity Action Plan (Volume C). With the implementation of this offset programme and

the other biodiversity management and mitigation measures outlined in the Project management plans, the

Project is not expected to result in a significant adverse impact on the biodiversity values in the long term.

A stand-alone Livelihoods Restoration Plan (Volume D) has been prepared as part of the ESIA and provides

the necessary strategic framework for the social planning of the Project and encompasses livelihood

restoration and improvement strategies. It sets out the objectives, eligibility criteria for Project Affected Persons,

entitlements, legal and institutional framework, modes of compensation, participation and consultation

procedures, and grievance redress mechanisms which will be used to compensate and restore the livelihoods

and living standards of Project Affected Persons. Other social management plans prepared as part of the ESIA

include a Local Economic Participation Plan (Volume D), and Stakeholder Engagement Plan (Volume C).

A Rehabilitation and Conceptual Closure Plan (Volume E) has been prepared which outlines the proposed

approach to rehabilitation, decommissioning and closure for the Project (refer Section 15.4).

In addition, the following specialist plans and manuals will be prepared/updated in preparation for Project

construction and operations, as appropriate to support the implementation of the environmental and social

management strategy:

Emergency Preparedness and Response Plan;

Environmental and Social Monitoring Manual;

Construction Environmental Management Plan (for construction contractors);

Transport Environmental Management Plan;

Blasting Management Plan;

Waste Management Plan (inclusive of hazardous wastes);

Waste Rock Management Plan;

TMF and WSD Operating and Monitoring Manual; and

Community Safety Plan.

To facilitate the implementation of the environmental and social management programme for the Project, the

Company has committed to establishing a site-based Environment and Community Relations Department. The

primary responsibility of these departments will be the implementation of the ESMMP and other

environmental and social management plans developed for the Project. Resources have been allocated to

ensure that these departments are established prior to construction and have sufficient capacity and resources

Mako Gold Project


FINAL REPORT 15-65

to undertake the required environmental and social management and monitoring activities. Technical

assistance from specialists will also be sought where required to fulfil the Company’s commitments.

15.2 Monitoring

The implementation of an appropriate monitoring strategy as part of the ESMMP will be important to ensure

that existing management measures are effective, and to identify the need for improved or additional

measures. The environmental monitoring programme for the Project will include five categories of monitoring:

Operation Monitoring;

Discharge (emission) monitoring;

Ambient monitoring;

Investigation monitoring; and

Post-closure monitoring.

Detailed measures for monitoring each of the potential key environmental and social impacts and benefits

associated with the Project are outlined in the ESMMP. The Company will provide support to assist the

Government of Senegal to conduct independent monitoring of Project activities through the Regional

Environmental Monitoring Committee.

15.3 Auditing and Review

Regular internal and independent external audits of the environmental management system will be

commissioned by the Company. Audits will cover the following aspects:

The appropriateness of the environment management system (as outlined in the ESMMP and other

management plans) to the current development stage and operating practices of the Project;

Performance against management measures and commitments as detailed in the ESMMP;

Development of, and performance against, continuous improvement targets;

Workforce awareness, competence and compliance with the ESMMP and associated plans and

procedures;

The performance of managers and operators in implementing and maintaining the aspects discussed in

the management plan strategies; and

Whether sufficient time, resources and expertise are available for implementation of the environment

programme as outlined within the ESMMP and other management plans.

15.4 Rehabilitation and Closure

The Project has been designed to enable it to be closed in a safe and stable manner once mining and mineral

processing has been completed. Mine closure will include the restoration of disturbed drainages, revegetation

of most affected areas and removal of infrastructure that will not be transferred to the Government. The

Company has committed to conducting rehabilitation in a manner which ensures community safety and that

benefits the local communities where possible. A Rehabilitation and Conceptual Mine Closure Plan (Volume

E) has been prepared as part of the ESIA. During the operation of the Project further consultation with

Government and community will be required to refine this Plan. As part of these consultations closure options

and criteria are expected to be developed with input from the local community.

Mako Gold Project


FINAL REPORT 16-66

16 CONCLUSIONS

The ESIA has identified the potential impacts of the Project based on available information and a professional

management and mitigation programme has been developed in accordance with Senegalese legislation and

industry best practice. The effective implementation and regular updating of the ESMMP (Volume C) and other

management plans in response to changing needs will ensure that environmental impacts attributable to the

Project are minimised and potential environmental and social benefits are maximised. Ongoing consultation

with the Government of Senegal, local communities and other stakeholders will also be important to ensure

stakeholder interests continue to be taken into account in the planning and development of the Project.

With careful implementation of the proposed management, mitigation and offset / compensation measures,

the Project should provide a net socio-economic benefit to local communities and to Senegal without

compromising the integrity of the Gambia River, Niokolo-Koba National Park or the broader environment.

Mako Gold Project - rml.com.au · Mako Gold Project ESIA Non-Technical Summary FINAL REPORT 1- 1 I...

Documents

Transcript of Mako Gold Project - rml.com.au · Mako Gold Project ESIA Non-Technical Summary FINAL REPORT 1- 1 I...