In April 2017, The Ecologist published concerns about the violation of an environmental buffer zone by the mining group Rio Tinto’s subsidiary, QIT Minerals Madagascar (QMM).
Recent studies undertaken by Rio Tinto (RT) and independently by Dr Steven Emerman, the hydrology and mining expert for The Andrew Lees Trust and an author of this article, confirm that QMM’s mine activity on the Mandena site has extended well beyond legal permissions and encroached onto the lake bed where people fish, collect reeds and other water products.
The Andrew Lees Trust reports are available in French and English.
After three months, Rio Tinto has failed to produce an official statement about the buffer violation, or answer related questions raised by The Andrew Lees Trust.
Sensitive environment
QMM is mining ilmenite, an industrial whitener, from coastal sands of southern Madagascar.
Situated alongside an estuary along the southeast coastline, the mine is operating in a sensitive environment with highly variable weather conditions, including cyclones and seasonal flooding, and a volatile water table.
The extraction of ilmenite leaves behind ponds of water and tailings enriched with radioactive substances (radionuclides). There are concerns that radionuclide-enriched water from the mine tailings will flow into the estuary by flooding or seepage.
Malagasy law requires an 80-metre buffer zone between any investment activity - such as mining - and sensitive areas such as lagoons, marshy areas and wetlands, so as not to disturb the ecological balance. This means an 80-metre area should be left between the lake edge and the mine activity.
QMM claims it was unaware of the national 80-metre buffer restriction until 2013.
Reducing the buffer
QMM therefore applied to the Malagasy Government to waiver the 80-metre restriction for their operation. Their proposed changes were presented in a Social and Environmental Management Plan (SEMP 2014-2018).
QMM proposed to reduce the legal buffer limit by 30 metres, from 80 metres to 50 metres. In reducing the buffer, QMM also proposed to build a “berm” or dam between the edge of the mining operation and the revised 50-metre buffer delimitation.
More egregious than the decimation of an additional 14.4 hectares of unique littoral forest acquired from the buffer reduction, is the fact that QMM’s mine has not respected the revised 50-metre limit and has extended onto the lake bed itself.
There are restrictions to private legal ownership within natural public areas (domaines publics naturels) in Madagascar of which reserved lands (pas géométriques), such as river beds, are included.
Malagasy law requires permissions from the local authority for extractive activities within these reserved lands. No evidence that such permissions have been sought and secured has been provided by Rio Tinto/QMM.
Mine encroachment
Comparing two visual images of the same area of the mine site in question from 2009 and 2016 clearly shows the encroachment and destruction of original forest area.
The 2009 image illustrates the very marshy nature of the lake, which shows in dark pools between the trees.
QMM’s encroachment within and beyond the revised buffer has decimated the ecosystem.
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