Comments on the EIA/CMP for the proposed Greenstone Quarry, Malolotja Nature Reserve, Swaziland

Richard C. Boycott
Senior Warden
Malolotja Nature Reserve

INTRODUCTION

At short notice I was given a copy of the above document and asked by Mr. S. Mamba, Chief Executive Officer, of the Swaziland National Trust Commission to go through it and submit comments.

In the limited time available I have endeavoured to go through the document and would like to make it clear that this report is not a comprehensive evaluation of the above document. I have tried to provide information from my particular ecological and managerial experience. Several issues are raised and these will have to be attended to.

OBSERVATIONS ON THE CONTENT OF THE DOCUMENT

In the executive summary it is stated that the mining lease holder was instructed to comply with the regulatory requirements of various acts. There is no mention of the Swaziland National Trust Commission Act of 1972 and "The Swaziland Nature and Conservation Act" does not exist.

The topography within the Malolotja Nature Reserve is one of the reserve's main attractions, and includes the quartzite rock face on the Mgwayiza Range with the greenstone deposit. In the description of the proposed project activities it is stated that the high quality of the green chert is much in demand for jewellery and dimension stone to beautify buildings. It is impossible to justify that an impressive quartzite rock face (containing green chert), located well inside a nature reserve (and one its main attractions), is to be destroyed in order to beautify buildings when the real beauty of the rock is actually in its natural situation? It is highly probable that a great deal more than the cliff face is going to be destroyed in the process.

Throughout the document indiscriminate reference is made to the quarry and the mine. Having read about the extraction methods to be used there is little doubt that the correct word is a mine. As this may have legal implications the correct terminology must be clarified. With regard to the nature reserve mining and quarrying are equally undesirable and are prohibited activities in a nature reserve. Other inaccuracies exist in the document such as reference to the "Nkomota River", that wetland areas only occur downstream of the site, that the downstream use of surface water is for domestic and agricultural purposes and that the area in close proximity to the proposed mine is "undulating savannah grassland". There are some serious omissions in the document where no mention is made of the pristine indigenous forest at the project site and that the access road is to pass through the heart of the nature reserve's wilderness area to get to the site.

It is stated in the document that "due to the topographical location the mine should have minimal visual impact from view sites in the reserve." This is totally inaccurate as the forest at the source of the Mgwayiza River and the approach to it is clearly visible from the Majolomba picnic site and Logwaja viewpoint road and from sections of the Nkomati viewpoint road, in Malolotja south. The spoil piles of the Bulembu Mine, located outside the reserve, are visible from many positions in the reserve and the Mgwayiza site is approximately at the same altitude. On the northern side of the Nkomati River hiking trails pass through the area and these would look directly upon the mine. It is suggested that the planting of belts of indigenous vegetation could be implemented as a mitigatory measure to screen the mine from view. This would be impossible as at present the vegetation at the base of the cliff face does not conceal the cliff face from view and the further back the cliff is mined the higher the scar will be. The creation of drinking sites for game at old borehole sites is not necessary as there is no shortage of water in the area.

The contention that the noise generated at the mine site will not create any major problems as the area is extremely remote from developed areas is totally unacceptable. What of the animal and bird communities in the area? The proposed site is in the heart of a nature reserve and the lack of concern for the wildlife is inconsiderate in the extreme. Noise pollution will undoubtedly have negative impacts on animal and bird populations.

The planned removal of 300 tonnes per month for 11 years hardly constitutes "a small scale operation" as described in the document. If the truth be known the compilers of the document have no real idea of the reserves of the mineral, especially as they use phrases such as "It (the deposit) forms a knoll/outcrop of unknown proportions at this moment.....", "it is hoped", and "the quarry is thus expected to last for 11 years". The actual deposit may only be a few metres thick. It is not difficult to set the scenario of the quarry retreating further and further into the mountainside in search of the desired quality of rock and in the process causing total devastation to the environment. The kind of devastation that has no place in a nature reserve.

The construction of buildings (ablution blocks and offices) and the creation of a viewing site for tourists and backpackers to view the mining activities in the Mgwayiza area of Malolotja is contradictory to the objectives of the management plan. The area is to be managed as a wilderness area and used only by hikers and backpackers.

The recommendation that "The disturbed area of approximately ten hectares is planned for use as a dam after rehabilitation and landscaping and could well become an asset to the reserve" cannot be taken seriously. A dam in the mined out quarry of the proportions described will certainly be undesirable in a nature reserve and will in fact have the opposite effect to that suggested in the document. This option is undesirable and other alternatives must be sought.

The unique hiking and backpacking wilderness of Malolotja north will be compromised by the mining project. Hiking routes in the area follow game trails and the existing low impact management track. A larger, upgraded access road will alter this permanently which represents an impact of very high significance. The upgrading of the track into the area to enable large trucks to get to the mine presents further complications. Noise pollution, scarring of the landscape, erosion and the creation of un-natural habitats are impacts that cannot be ignored. Upgrading or the building of new sections of the access road would necessitate the creation of borrowpits which are totally unacceptable inside a nature reserve irrespective of promises of rehabilitation.

Of considerable concern is the consistently low or moderate level of significance given to the environmental impacts in the construction, operational and decommissioning phases. It is quite apparent that this is a gross misrepresentation of the environmental and ecological impacts that will result from the operation. Furthermore, it is difficult to believe and to accept that during the study the impact of the project on only one element, namely geology, was identified as being irreversible. In the document text it was stated that special reference would be given to irreversible impacts. This clearly has not been done. With reference to the definitions contained within the document some of the impacts are clearly of a high or very high level of significance as several of these will extend beyond the project area. A few of the more serious examples are listed:

The upgraded access road will pass through the heart of the reserve's wilderness area.
The indigenous forest habitat extending down the Mgwayiza valley will be subjected to changes in drainage patterns.
The permanent stream flow within the indigenous forest will be threatened if the forest, or sections of it are removed or destroyed. This will directly threaten the life cycles of the rare amphibians occurring in the forest near the site and downstream from the site.
The Bald ibis breeding colony near the reserve's entrance gate will be disturbed by the road upgrading activities and will lead to the desertion of the site. Other bird populations will also be affected such as Gurney's sugarbird and the Knysna lourie.
The stockpiling of topsoil along the roads for the duration of the project and the creation of borrowpits.
The mined out quarry will be visible from many vantage points far removed from the actual site, particularly on the hiking trail network.

The conclusion of the investigation is that, in general, the overall negative impact of the mine on the environment will not be significant while the positive benefits of the operation to the nation are positive and potentially significant. Believing that the ecological assessment of the plant and animal life during the investigation was hopelessly inadequate the conclusion is misleading and is rejected. It is recommended that an independent consultant, with a more balanced approach, be called upon to carry out further work on the environmental impact assessment of the project.

BACKGROUND

It needs to be said that the mountainous terrain along the Swaziland and South African border was identified in a 1978 survey of Swaziland to be one of the most protectionworthy areas in the Kingdom. The majestic landscape and rugged topography has a particular wilderness quality not found anywhere else in Swaziland. The decision to proclaim Malolotja Nature Reserve was not made on the spur of the moment. The whole concept in the interests of the nation was carefully assessed. The process was a long and comprehensive one and the decision was taken that this part of Swaziland should be set aside for public use as a nature reserve and for the protection of Swaziland's highveld and middleveld ecosystems. It was King Sobhuza II who played the major role in the whole process. Of paramount importance, it was the King's express wish that Malolotja Nature Reserve be proclaimed and the area managed as a nature reserve.

The thought of mining in Malolotja Nature Reserve should never have been entertained without initial consultation with the management of the reserve and without understanding the background to its establishment and proclamation in the first place. In particular, the Mgwayiza Range is in the heart of the wilderness area and has been designated as such in the reserve's management plan. The area is not to be developed in anyway and no access should be permitted other than on foot. Approximately 15% of the reserve has been opened up for vehicular access by tourists, the remainder represents the finest backpacking region in southern Africa. In accordance with the objectives of the reserve no development is to take place in Malolotja north and it is to be maintained as a wilderness area where the only public access is on foot.

The ecological assessment of the plant life and the animal life in the EIA document is hopelessly inadequate. There are many rare and endangered species, endemic species and regionally important species in the area. It is wrong to consider it only important to categorise the fauna and flora as being either rare or endangered. Although there are such species in the forest and adjacent areas, the habitat does provide refuge for a high diversity of species. This is just as important, if not more important than providing habitat just for rare or endangered species. In particular, the grasslands, rock face habitats and forest areas in the Mgwayiza area are amongst the most important habitats in the reserve because of the surrounding forestry plantations where biodiversity is compromised. Afromontane forest, only found in the Highveld region of Swaziland, is a threatened habitat type in southern Africa. The indigenous forest at the site is the second largest expanse of indigenous Afromontane forest in the nature reserve. The protection of the flora in this habitat is therefore of utmost importance. Malolotja Nature Reserve is the only place in the Kingdom where these forests are adequately protected.

If access to the cliff face is granted and mining allowed, the impacts will be far reaching and will extend to locations far removed from the immediate vicinity. The forest is located between the point of entry of the track and the proposed mine site. The forest is at the source of the Mgwayiza River and permanent water is present just below the old track going through the forest, while seasonal flows are experienced above the track. Any impact on the forest will escalate downstream and could cause changes in the natural water flow. This would affect the natural flows of the Mgwayiza River and could impact adversely on some of the amphibians occurring in the forest.

PLANT AND ANIMAL LIFE

The statement in the EIA document that reserve authorities will verify that there are no known endangered or rare animal species in the study area is a gross misrepresentation. It is obvious that this aspect of the EIA received minimal attention. To illustrate the conservation importance of the Mgwayiza Forest and the surrounding grassland and rock outcrop habitats a few examples of the rare and endangered species, endemic species and regionally important species of the flora and fauna are given below.

The only population of Protea comptonii in Swaziland occurs on the Mgwayiza Range near the proposed mine. No more than twenty trees are known in the population and the easier access that will be created by the mining operation could seriously jeopardize this population.
Three species of cycad (Encephalartos) occur in Malolotja Nature Reserve, two of which are endangered. All three species occur on the Mgwayiza Range. Easier access to the area will, without question, lead to their extinction through unscrupulous collection.
The southernmost population of the large leafed Forest Fever Tree (Anthocleista grandiflora) is in Malolotja Nature Reserve. This tree is only found in a few forests in the reserve including the Mgwayiza Forest.
Approximately 25 species of plants are endemic to Swaziland and the majority of these occur in the Highveld region, some specifically in Malolotja Nature Reserve. Some species of Dicoma, Streptocarpus and Indigofera swaziensis have restricted ranges in Swaziland, or in Swaziland and the adjacent area of South Africa. Any disturbance in the area will reduce the habitat and the numbers of these regionally important species.
The invertebrate fauna of the Mgwayiza area is poorly known and much work needs to be done to determine whether there are important species of butterflies, moths and other insects in the area. If the other groups of animals (birds, reptiles and amphibians) serve as a guide then in all probability a rich and diverse invertebrate fauna can be expected in the area.
Two rare amphibians species occur in the Mgwayiza Forest, the Clicking stream frog (Strongylopus grayii) and the Natal ghost frog (Heleophryne natalensis). There are probably others in the adjacent rocky grassland habitats such as the Plaintive rain frog (Breviceps verrucosus) only known from a single Swaziland locality namely, nearby Bulembu. The Ghost frog tadpoles require permanent fast flowing mountain streams to enable them to complete their development from tadpole to frog. The Stream frog occurs exclusively in forest habitat. Both species are restricted to Malolotja Nature Reserve in the Highveld, being recorded from Swaziland for the first time by Boycott (1992).
Three species of snakes, listed as rare in the South African Red Data Book (Branch 1988), are likely to occur in the area. Two of these, Lamprophis swazicus and Lamprophis fuscus have been recorded from Malolotja Nature Reserve and the third is likely to occur in the reserve also. All three require undisturbed grassland or rocky grassland habitats. Lamprophis swazicus (also recorded from Bulembu) has a very restricted range in Swaziland and adjacent South Africa. Other rare species are likely to occur in the area as well.
The African rock python, listed as vulnerable in the South African Red Data Book (Branch 1988), occurs in Malolotja Nature Reserve and is very likely to be found in the rock outcrop and forest habitats in the area. This species is only protected in nature reserves in Swaziland and any disturbance in the area will reduce the species' habitat and numbers.
Several species of lizards are endemic to the Highveld region of Swaziland, some of which have only been recorded from Malolotja Nature Reserve. Some of these species are grassland specialists while others are rupicolous and any disturbance in the area will reduce their habitat and numbers. Examples are Scelotes mirus, Chamaesaura aenea, Lygodactylus ocellatus, Pseudocordylus melanotus, Nucras lalandii and what in all probability constitutes a new species of Dwarf chameleon (Bradypodion sp.). The Dwarf chameleon is restricted to Afromontane forests.
A high diversity of small mammals, approximately 25 species in all, has been recorded from Malolotja Nature Reserve. Several of these represent the only records of these species in Swaziland. These include the Dark-footed forest shrew (Myosorex cafer), Greater dwarf shrew (Suncus lixus), Least dwarf shrew (Suncus infinitesimus), Giant musk shrew (Crocidura flavescens), Geoffroy's horseshoe bat (Rhinolophus clivosus), Grey pygmy climbing mouse (Dendromus melanotus), Brant's climbing mouse (Dendromus mesomelas), Vlei rat (Otomys irroratus)(Monadjem 1997). It is highly likely that some of these species occur in and around the Mgwayiza Forest. Disturbance of the habitats in the area will impact negatively on these species.
In Swaziland one of the two subspecies of the Knysna lourie (Tauraco corythaix corythaix) occurs in the Afromontane forests of the northern Highveld, specifically in Malolotja Nature Reserve, where the bird is an uncommon breeding migrant (Parker 1994). It occurs in the Mgwayisa Forest. Disturbance of any part of the forest will result in the species deserting the area, at least as a breeding site.
There is a breeding colony of the rare, southern African endemic Bald ibis in the Mkomazane Gorge, near the northern entrance gate to the reserve. Noise pollution will drive these birds away as will increased access into the area other than by hikers and backpackers.
Gurney's sugarbird is extremely rare in Swaziland and is only known to occur in Malolotja Nature Reserve. One of the three known sites in the reserve where this species occurs is close to the proposed mine. Noise pollution will undoubtedly drive the species away from this site.

On ecological grounds alone it is clear that any mining activity in the area will negatively impact on many forms of plant and animal life. Rare and endangered species, endemic species and regionally important species without exception will be placed under severe threat should the mining operation proceed. Above all it must be remembered that the proposed operation is located within a proclaimed nature reserve and by definition proclaimed nature reserves are classified as highly sensitive areas.

EXISTING FUNCTIONS AND USES

Malolotja north provides protection to a wide variety of plant and animal species in a wide variety of habitats.
Malolotja north provides pristine wilderness unrivalled anywhere in southern Africa. Of the utmost importance in realising the reserve's objectives Malolotja north must be preserved and maintained as such.
The Mgwayiza Range is a critical catchment area and source of water for Swaziland. Disturbance of the area will seriously jeopardize the protection of the catchment.
Certain species of grasses are used sustainably by the local community under permit from the reserve.
Surrounding local communities obtain fresh and clean water from rivers and streams leaving the reserve, that is uncontaminated by mining activities.
In the past the King has sent traditional healers from the Royal Palace, as a royal envoy (titfunya), to Malolotja Nature Reserve for the purpose of obtaining medicinal plants from the indigenous forests in the reserve. Many of these plants are becoming increasingly threatened and the importance of protecting the forests in which they occur is critical. To destroy the Mgwayiza forest or a part thereof will result in the destruction of medicinal plants that could be used by the traditional royal healers.

CONCLUDING COMMENTS

The area identified for the mining operation falls within a proclaimed nature reserve. Such activities cannot be carried out in a nature reserve. The Mining Lease holder in recruiting the consultants for the preparation of the EIA and CMP document blatantly disregarded the express instruction of the Swaziland National Trust Commission not to enter the nature reserve. Entry into the nature reserve without permission is an offence under the National Trust Commission Act.

The mitigation methods proposed in the Comprehensive Mitigation Plan in respect of the natural vegetation and animal life are weak and unconvincing. To consider the levels of significance of the impacts as moderate and low respectively, and as reversible, is irresponsible and quite unacceptable. It is highly recommended that a more balanced approach be taken on the entire issue of the mining project in the Malolotja Nature Reserve.

In conclusion it must be said that mining projects are not sustainable while nature conservation is. The area has been set aside for public use as a nature reserve. It must be emphasised that this decision was taken after careful consideration of other alternatives and the decision was taken in the best interests of the nation. The wise use of natural resources is one of the main objectives of the Swaziland National Trust Commission. King Sobhuza II played the major role in creating the Swaziland National Trust Commission and it was the King's express wish that Malolotja Nature Reserve be proclaimed and the area managed as a nature reserve. The benefits of employment in respect of mining operations are not permanent, nor are the economic benefits of a permanent nature. Nature reserves and national parks will be there permanently for the benefit of the nation through tourism and recreation and will provide permanent job opportunities for Swazis.

REFERENCES

BRANCH, W.R. 1988. South African Red Data Book - Reptiles and Amphibians. South African National Scientific Programmes Report No. 151.

BOYCOTT, R.C. 1992. An annotated checklist of the amphibians and reptiles of Swaziland. The Conservation Trust of Swaziland.

MONADJEM, A. 1997. An annotated checklist of the mammals of Swaziland. The Conservation Trust of Swaziland.

PARKER, V. 1994. Swaziland Bird Atlas 1985-1991. Websters. Mbabane.

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Report compiled by Richard C. Boycott

5 July 1997

Suggestions or comments. This page was last updated on 28 October 2001