COMMENTS ON THE NAWAILEVU BAUXITE MINE EIA
These comments are given in response to the public feedback on the above as required by
statute, and in the interests of responsible and sustainable mining practices in Fiji. It is based
on a cursory appraisal of the EIA document at the Department of Environment on
13/05/2010
1. The Weipa project in North Queensland, the Jamaican bauxite mining industry and even
the infamous Guinea project in Africa, are key projects that this project can learn and
benefit from, particularly with regards to impacts over the long term. In this context, a
few lessons could be learnt from all these three projects, but particularly in Jamaica where
the environmental conditions are similar to those in Fiji:
a. The Jamaican operation is huge by Fiji standards, and at one time, was the 3rd largest
bauxite/alumina producer in the world. It also is the greatest cause of de-forestation
in Jamaica, causing all kinds of ecological problems that have impacted on land-use,
rehabilitation and the negative impacts on the hydrology of the areas impacted. It has
also caused dislocation of communities that have to be relocated due to the land area
requirements of bauxite mining operations.
b. Unlike the Nawailevu project, processing is done in all these countries – the key
factor in all environmental negative impacts in these countries. These negative
impacts have included: the use of large areas for tailings dam retention, that become
un-usable thereafter; huge dust problems – the so-called “red dust” that just about
covers everything on these sites; sodium precipitation in waterways and
underground water; and a caustic soda enrichment due to the use of caustic soda in
the separation process from bauxite to alumina; and high erosion and poor water
retention of soils after bauxite is mined out.
c. In Jamaica, there is even some scientific evidence that the result of deforestation and
slow re-forestation or re-vegetation, has led to much drier and hotter soils. This is
the same phenomena in Nauru where phosphate removed has revealed the limestone
bed rock that is now exposed and heated up by the sun – causing any rain clouds to
be pushed over the island, thus making it drier still.
d. Social and economic problems have persisted, particularly in Jamaica and Guinea,
where the economic benefits to the state have outweighed any community or
environmental concerns. As a result of undue political and governmental pressure,
these operations have been poorly regulated for compliance and so the local
community suffers at the expense of the national economy.
2. The project’s areal footprint is actually quite small at approximately 30ha compared to
other bauxite mines in the world. This also minimizes environmental negative impacts in
the first instance than otherwise, but since the company has applied for a far greater area
to be under license, the question to be asked is: is this only a pre-cursor to a larger mining
project to follow this first stage? If so, then the EIA has to be viewed in the context of
several years of mining operations rather than one year of operation as inferred in the
report. This enforces a much stricter and detailed characterization of both the biophysical
and biochemical environments, including a more detailed understanding of the region’s
hydrological cycle and how it impacts on the operations. The other corollary to this is
that a larger operation at a later stage could lead to onshore processing, particularly if
lower grades are found compared to the relatively high grades in the proposed 1 year
mine. This could then lead to the problems currently faced in Jamaica as alluded to
above.
3. The project dodges all the key negative impacts associated with the processing of the
bauxite into alumina on site. This is a major benefit for the project in relation to
environmental impacts, since most of the environmental problems in Jamaica’s bauxite
mining industry are mitigated against in the first instance, including: the need for tailings
dams, the use of what could have been arable land for tailings dam storage, and the
possible contamination of surface and underground water from the processing stage, that
has seen increased levels of sodium being precipitated into waterways in Jamaica, that
some have linked to the increase in hyper-tension.
4. Hydrology is a key element of this report, given its importance and linkage to erosion,
siltation and to the contamination/toxicity effects of the project on water. Hydrological
characterization though seems to be lacking to fully account for say 1 in 50 year rainfall
events, or extreme coastal flooding to then test the structures that are planned for the
operation. These standardized disaster scenarios for especially bunds, tailings dams,
drainage networks and siltation traps, are standard practice in high rainfall areas. An
example is that a 1 in 40 year rainfall event allowed the tailings dams to overflow at Mt.
Kasi, forcing the mine to close due to the ensuing environmental damage on both the
riverine and coastal/reefal environments. A properly characterized hydrological system
should then dictate:
a. The proper design of all bunds and siltation traps – indicating method and
material of construction, and dimensions;
b. Define the drainage catchment of the areas surrounding the mine site, and
therefore propose a system of drains that will link up to the siltation traps. These
drains should include diversion drains to minimize the impact of surface runoff;
and also feeder drains to feed the siltation traps, and even including finger drains
where needed;
c. Define the impact of coastal flooding in a 1 in 100 year event (or such time frame
as deemed applicable) to test the design of the two siltation traps and bunding on
the stockpile site, since this is connected to a marine environment that is used for
food and subsistence;
d. It should then determine the seasonal abstraction levels of water used by the
operation from the river systems, and also infer the dilution factors for any
discharges to these river systems for any waste discharges.
5. The characterization of the biochemical environment could also be improved upon due to
the lack of temporal data, although there has been a lot of evidence provided for the
biophysical. This is particularly important for mitigating against extreme events and the
mitigation strategies involved. This will also allow continuing monitoring of a range of
metals, TSSs and water clarity during and after the operation has seized; to properly
determine background levels. I did not identify the use of control sites given that this area
has already been damaged by pine logging and subsequent erosion, but this could be my
own oversight.
6. There seems to be a heavy reliance on the EMP, OEMP, CEMP, QMP and TMP to fully
address the issues raised in the EIA. This means a greater reliance on the company to
derive the appropriate mitigative measures for minimizing or alleviating the negative
environmental impacts of these activities. This is where regulatory control can be
properly administered, and where monitoring is crucial. Many EIAs that have been well
documented and researched, have actually failed during implementation and primarily
due to the lack of focus and commitment made to these management protocols. But again,
these can only be properly formulated if all the environmental impacts have been properly
characterized and understood prior to permitting.
7. On the socio-economic impacts, there is no discussion on regional economic impacts, that
is critical to such remote sites undergoing resource development. Rather than focus on the
primary community impacted by the operations, the report does not indicate regional
economic impacts, flows and even economic multiplier effects that are sought after in any
remote site development.
8. A compensation package should be carefully linked to the EIA, since it should highlight
how and what is to be compensated for when damage is incurred. So should the
calculation of environmental bonds to cover any rehabilitation or remedial work should
the operator abandon operations. I did not see evidence of the basis for the derivation of
the $250,000 bond suggested.
9. The SIA component of the report should have highlighted in more detail a social
cost:benefit analysis of the project to then bring all the socio-economic impacts to bear.
Without this framework, it is difficult to ascertain long term and regional impacts of the
project. This is particularly important in the area of improving community welfare as a
result of such developments, and is a key consideration inn the assessment of sustainable
development outcomes in the development of a diminishing natural resource typical in
mining. The cost:benefit analysis should also show economic flows and even infer
economic multiplier effects in ascertaining whether such development will improve the
community’s welfare or not.
10. Given the importance of landowner issues (example, current issues at Namosi prospect
that is now holding up this multi-billion dollar project if developed), there seems to be
very little focus on this area. Issues to do with land ownership, vanua structures, and the
chiefly system involved are all key aspects of ensuring landowner support over the life of
the mine, and beyond. This should also include a conflict resolution platform, and the
involvement of NLTB as trustees of native landowners.
11. Overall, I think the EIA has been well compiled and researched. I was pretty impressed
with the consultation process with stakeholders. The key now is to develop the permitting
and monitoring protocols that will ensure that these impacts are properly managed on site
as alluded to in the EIA, and that the project is actually beneficial to the community.
GN, 13/05/2010
