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Lower Zambezi National Park Mining Project is ‘Fatally Flawed’, Says Report

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The Zambezi River, flowing adjacent to the Lower Zambezi National Park.

ZAMBIA––A recent scathing report, investigating the proposed Kangaluwi Copper Mine project in the Lower Zambezi National Park, draws attention to a number of pressing issues that have not been addressed by the Australian prospecting company, Zambezi Resources Limited (ZLR), saying that the information provided by the company is in fact “fatally flawed.”

Independent mining experts who were consulted in the process of the investigation, have posed harsh questions as to whether the vague and contradictory information presented by the company, is “intentionally misleading, or demonstrates gross incompetence.”

“The documentation [Presented by Zambezi Resources] suggests a complete disregard for the Zambian legislative process,” says the report, “and questions revolve around the true purpose and scope of the project, given that copper mining appears economically unviable at the site.”

The background

The vast, unfenced Lower Zambezi National Park—straddling 120km of the Zambezi River directly opposite the Mana Pools World Heritage Site—is one of the four most visited parks in Zambia, and home to a great diversity of free-roaming wildlife, as well as local lodges and communities.

Zambezi Resources and its local subsidiary, Mwembeshi Resources, first started prospecting for copper in the Lower Zambezi in 2011, when the Zambian government granted the company a 25-year mining licence.

Shortly after receiving their licence, Zambezi Resources submitted an Environmental Impact Assessment (EIA) for a proposed opencast copper mine site in the middle of the Park.

The Zambian Environmental Management Agency (ZEMA) reviewed the document and subsequently rejected the EIA based on technical grounds. They put out the following statement to the public:

“The proposed site is not suitable for the nature of the project because it is located in the middle of a national park, and thus intends to compromise the ecological value of the park as well as the ecosystem.”

Zambezi Resources quickly appealed the rejection, and in a shocking twist, the then Minister of Lands, Natural Resources and Environmental Protection, the Honourable Harry Kalaba, overturned ZEMA’s rejection of the mine.

On 17 January 2014, despite a fully rejected EIA, full permission was given for an opencast copper mine in the Lower Zambezi National Park.

In the midst of public uproar, a group of NGO’s managed to challenge the Minister of Lands’ ruling, and now, at the time of this report, a High Court case is underway to decide whether or not the proposed copper mining Project, the Kangaluwi Mine, will go ahead inside the boundaries of the Lower Zambezi National Park.

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The proposed mining site in the middle of the Lower Zambezi National Park. Photo by Lower Zambezi National Park

The report

The proposed copper mine sets a precedent for international large-scale mining inside national parks in Zambia, says the new report, compiled by independent reviewer Dr Kellie Leigh (Phd). “Communities, stakeholders and independent experts have expressed concerns that bring into question the legitimacy of the project proposal, and whether it is in the best interests of Zambia for the project to proceed.”

The 70 page document scrutinises the information presented by the prospecting company, and discusses the decision making process around the mine and the likely benefits to Zambia, and whether sufficient capacity exists to ensure it does not negatively impact the health and wellbeing of communities, or the biodiversity values for which protected areas are set aside.

Is the project economically viable?

Among the critical issues the report highlights is the nature of the underlying copper resource, which has recently been changed from copper sulphide to copper oxide, “yet no new EIA documents have been supplied nor any announcements made to Zambian authorities or stakeholders.”

The grade of the underground copper is also questioned, saying that it is of such low quality that it is “highly unlikely that a larger mine would be economically viable.”

Findings suggest that the mine will in fact generate a loss over the first seven years of operation, amounting to a minimum of US$13 million.

The EIA also refers to a larger scope project within the mine licence area, but “little information is given about this scope and the vastly greater impacts they will have on the LZNP and the Zambezi River water catchment.”

Independent experts consulted for the report, who preferred to remain anonymous, were highly critical of the documentation provided by ZRL.

 “The technical mining aspect of the report in terms of project scope is so vague and contradictory it is not possible to discern whether this has been done intentionally to mislead or whether it is a result of incompetence on the part of the authors”.

Risks to tourism, people and the environment

The Lower Zambezi National Park is one of the four parks in Zambia that make up 96% of income from wildlife management and photo-tourism.

Through a study based on questionnaires sent out to 350 travellers and agents, the report found that “the impacts [of the mine] on the growing and sustainable tourism industry are likely to be significantly negative, and result in job losses”.

Will the mine create employment for communities? Comparably, the jobs created from copper mining are significantly less than from tourism. This is because open cast mining is dependent on heavy machinery and skilled labour in all stages of the mining process, from the use of explosives, to heavy moving equipment for hauling ore and chemical processing, which is likely to limit the number of people employed from local communities.

The report also warns that the project may well jeopardize the more than US$ 1 billion in international development aid received annually by Zambia .

When the environmental and health impacts of the mine were examined, it was found that “there is considerable risk of long term damage beyond the life of the project to the health and wellbeing of communities, wildlife and the environment.”

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Photo taken directly above the south eastern edge of the exploration site, looking down Kangaluwi Stream and showing the proximity to the valley floor and Zambezi River. The stream drains the exploration site into the valley floor through a wildlife corridor area and into the Zambezi River. Photo by K. Leigh.

Contamination of the Zambezi River and its tributaries on the escarpment, from mine runoff is of grave concern, yet independent experts noted that certain events were not considered by ZRL and have still not yet been addressed.

One US mining expert from a prominent firm stated:

“If this EIA was submitted in the USA … it would be rejected outright as insufficient, and would indicate that the proponent lacked the technical or corporate capacity to carry out such a project without significant risk to water resources, humans and wildlife.”

A failed process

The paper goes on to point out the legislative deficiencies in the process, saying that it has “highlighted critical gaps in both legislation and policy for properly evaluating and managing mining within protected areas in Zambia.”

“Despite a strong legal framework around independent review of projects by independent experts and stakeholders of ZEMA, the process becomes flawed by the ability of a single Minister to undermine the assessment process, without any requirement to share the information that formed the basis of the Minister’s decision.”

“The current mining license application process therefore lacks transparency and is open to exploitation,” says the paper.

In its conclusion, the publication strongly recommends that the project be rejected, and that further scrutiny is placed on any future mining projects in protected areas in Zambia, to ensure transparency and accountability, as well as adherence to international best practice standards.

Read the full investigation and findings from the report here.