Chapter 9 | Biological Impacts and Management Measures

Chapter 13 | Cumulative Impact Assessment

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Chapter 13 | Cumulative Impact Assessment

13 CUMULATIVE IMPACT ASSESSMENT ..................................................................... 13-1

13.1 Introduction ............................................................................................................................................................. 13-1

13.1.1 What are Cumulative Impacts? ........................................................................................................... 13-1

13.1.2 How can Cumulative Impacts Aggregate and Interact? ............................................................ 13-1

13.1.3 Cumulative Impact Assessment Methodology ............................................................................. 13-1

13.2 Other Projects and Activities in the Region .................................................................................................. 13-2

13.2.1 Mining Operations .................................................................................................................................. 13-2

13.2.2 Hydropower............................................................................................................................................... 13-7

13.2.3 Tourism Basic Infrastructure ................................................................................................................ 13-8

13.2.4 Agricultural, Farming and Fishing projects ..................................................................................... 13-9

13.2.5 Other Infrastructure Projects ............................................................................................................ 13-11

13.3 Assessment of Cumulative Impacts .............................................................................................................. 13-11

13.3.1 Gambia River .......................................................................................................................................... 13-11

13.3.2 Niokolo-Koba National Park .............................................................................................................. 13-13

13.3.3 Employment and Skills Development ........................................................................................... 13-14

13.3.4 Accommodation Availability ............................................................................................................ 13-15

13.3.5 Airshed ..................................................................................................................................................... 13-15

13.3.6 Vehicle Movements on the RN7 ...................................................................................................... 13-15

13.4 Conclusions and Management Implications ............................................................................................. 13-16

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13 CUMULATIVE IMPACT ASSESSMENT

13.1 Introduction

13.1.1 What are Cumulative Impacts?

Cumulative impacts can be defined as the successive, incremental and combined impacts of one, or more,

activities on society, the economy and the environment. Cumulative impacts result from the aggregation and

interaction of impacts on a receptor and may be the product of past, present or future activities (Franks et al.

2010).

Cumulative impacts can be both positive and negative and can vary in intensity as well as spatial and temporal

extent. Cumulative impacts may interact such that they trigger or are associated with other impacts.

Cumulative impacts can result from individually minor but collectively significant projects or activities taking

place over a period of time.

In terms of the proposed Project, cumulative impacts may occur in combination with impacts on the physical

environment, biodiversity and socio-economic conditions arising from existing projects and planned

developments. These projects and developments include other mining projects, agricultural projects, dam

infrastructure and tourism enterprises.

Cumulative impacts may also occur with regard to existing and additional pressure on the Niokolo-Koba

National Park (Park National de Niokolo-Koba or PNNK). Expected impacts from the Project on the PNNK are

described in detail in Chapter 7, and cumulative impacts discussed in the present Chapter under Section 13.2.2.

13.1.2 How can Cumulative Impacts Aggregate and Interact?

Impacts may aggregate and interact in three main ways (Franks et al. 2010):

Spatial impacts are those which occur over an area. Spatial impacts may vary in both extent and

intensity. A spatial extent impact may consist of the area over which vegetation has been cleared for

mining, while spatial intensity impacts may occur in areas where there is overlap between spatial extent

impacts from more than one source, such as an area of dust deposition where the source of the dust is

from an up-wind activity.

Temporal impacts are those that vary over time. Simple temporal impacts have a specific time of

commencement and a measured form over time; for example, the economic activity in a nearby town

tracing a similar time series to the production of a group of mines. Offset temporal impacts occur when

multiple simple temporal impacts are superimposed upon one another over time. The simplest types are

where the same simple temporal impact comes from one mine at a time and from a second mine at time

t+1.

Linked impacts involve more complex interactions such as where one impact triggers another or where

a single activity has multiple effects. Linked triggered impacts are those that occur when one impact,

either by its occurrence or by reaching a threshold level, causes another impact that would not otherwise

have occurred. The second impact is the triggered impact. An example of a triggered impact would be

when the economic activity in a town, associated with multiple operating mines, becomes sufficiently

large for a new amenity to be financially viable (e.g. a new shopping outlet).

13.1.3 Cumulative Impact Assessment Methodology

The methodology adopted for the assessment of cumulative impacts in this report comprises:

Assessment of residual impacts and risks from the proposed Project, including cumulative project

related impacts(refer to Chapters 9-12);

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Review of existing and planned developments / activities in the region that have the potential to result

in cumulative impacts with the Mako Gold Project, and the key drivers that affect them (see Section 13.2);

Identification of key potential cumulative impacts relating to these developments / activities

(Section 13.2);

Analysis of key potential cumulative impacts, including consideration of geographical and temporal

aggregations and interactions (Section 13.3); and

Stakeholder consultation and review of potential impacts (refer to Chapter 14).

Figure 13-1 shows the varying factors that combine to influence cumulative impacts arising from mining and

other sources, which have been taken into account in the above methodology.

Figure 13-1 A conceptual model of the cumulative impacts of mining (Franks et al. 2010)

13.2 Other Projects and Activities in the Region

13.2.1 Mining Operations

Major Mining Operations

A number of existing and proposed medium and large-scale mining projects are located in the Kedougou

Region, to the north-east of Mako. Existing and potential mining projects identified within approximately

100 km of the Project are outlined in Table 13-1. The most significant project in relation to cumulative impacts

is the Sabodala Gold Mine, which is the closest major operational gold mine in Senegal.

There are also a numerous other major mining projects in Mali, located at the north east of the Mako Gold

Project, including Loulo Mine at 100 km, Tabakoto mine at 120 km, Sadiola Gold Mine at 140 km; Yatela Gold

Mine at 150 km, as well as the Dandoko and Moussala Projects at 110km and at 125 km respectively.

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Table 13-1 Existing and planned mining operations in the region of the Mako Gold Project

Mining Operation Company Material Current status Distance from

Mako Gold

Project

Massawa Gold Project Randgold Gold Exploration / Feasibility ~30 km

Sabodala Gold Mine Teranga Gold (Sabodala

Gold Operations)

Gold Operational ~50 km

Makabingui Gold Project Bassari Resources Gold Feasibility & ESIA Submitted /

Proposed Development

~60 km

Boto Gold Project IAMGOLD Gold Exploration / Pre-Feasibility ~110 km

Source: Department of Mines, Kedougou.

Figure 13-2 Location of operational and exploration mining permits in the Kedougou region

Sabodala Gold Mine

Teranga Gold’s Sabodala Gold Mine is an operational gold mine located approximately 50 km north-east of the

Mako Permit Area, in the catchment of the Niokolo-Koba River which flows into the Gambia River, downstream

of the Mako Gold Project (Plates 13-1, 13-2). Mining operations at Sabodala Gold Mine started in March 2009.

The Company completed a plant expansion to double mill capacity in 2012. In early 2014, Teranga acquired its

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neighbouring property, the Oromin Joint Venture Group (“OJVG”). As the expansion and acquisition is now

complete, as a base case Teranga expects to increase average annual gold production to about 250,000 for

about 10 years, with a total reserve life of 16 years. The acquisition increased the reserve life and exploration

prospects of the Sabodala Project. There is potential to develop satellite deposits around the existing Sabodala

open pit (Teranga Gold Corporation, 2015).

Based on information from Teranga Development Strategy Report (2014), the Gold Mine is located in a mine

lease which comprises 33 square kilometres. It is the only large-scale gold mine in operation in Senegal. Its

current footprint is roughly 800 ha and includes the following major components: a Mining Area, with process

plant, mine pit, tailings storage facilities, water reservoirs, waste rock dumps and Run of Mine pad. It also

comprises an operator’s Village; this area includes housing and associated facilities for workers. The main camp

is located approximately three kilometres from the mine and was designed to house up to 860 employees. A

second camp at Bransan accommodates approximately 45 workers.

The Golouma Project located 9 km south of Sabodala open pit, is the most advanced of Teranga’s gold deposits

(Teranga Gold Technical Report, 2014).

Plate 13-1 Sabodala mine pit (Teranga, 2014) Plate 13-2 Sabodala process plant (Teranga, 2014)

Massawa Gold Project

Randgold’s Massawa gold deposit, discovered in 2004, is located approximately 30 km north-east of the Mako

Gold Project, within the Kounemba permit area. According to Randgold Annual Report 2013, Massawa deposit

is one of the largest undeveloped gold deposits in West Africa (3.36Moz, 2.57g/t) but it is also geologically and

metallurgically the most complex ore body. The company is currently updating the geological model of the

deposit. A report from January 2015 indicated that the deposit does not currently meet Randgold’s strategic

investment filters, and Randgold are continuing to explore the potential for development of the mine. Its

viability is reported to depend on finding either an effective power solution and/or additional resources (by

extending the prospection zone to other satellite deposits in the vicinity).

Makabingui Gold Project

The Makabingui Gold Project, operated by Bassari Resources Limited is located about 60 km north-east of the

Project. The project has a mineral resource of 11.9 million tonnes, which yields an average of 2.6 g/t gold for a

contained 1 million ounces of gold. Eighty percent of the resource is located within 200 m of the surface. The

ESIA for the project has been completed and lodged with Senegalese Government. The initial project mine life

is about 3 to 4 years but several options are already considered to extend the initial mine life. Bassari Resources

holds 3 contiguous exploration permits Sambarabougou, Moura and Bounsankoba, covering approximately

790 km2 within the Birmian gold belt in Senegal.

Boto Gold Project

IAMGOLD’s Boto Gold Project is located in the south-eastern corner of Senegal within the Kenieba gold belt.

The Boto Gold Project hosts an indicated resource of 22 million tonnes averaging 1.62 grams of gold per tonne

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for 1.14 million ounces and an inferred resource of 1.9 million tonnes averaging 1.35 grams of gold per tonne

for 81,000 ounces (IAMGOLD, 2015). A significant percentage of the total resources are derived from the newly

discovered Malikoundi deposit which is the largest deposit discovered to date on the property. An Initial

Environmental and Social Evaluation for the Project was conducted in June 2013, and IAMGOLD intends to

undertake further ESIA studies as part of pre-feasibility and feasibility studies to support an application for a

mining concession.

Artisanal and Small-Scale Alluvial Mining Activities

Artisanal Mining

Artisanal alluvial gold panning is a traditional livelihood activity performed along the Gambia River and a

number of its tributaries within the vicinity of the Project. Over the last ten years there has been a significant

increase in this activity, largely attributed to higher gold prices and the deployment of new technologies. These

factors have facilitated the exploitation of hard rock deposits.

Artisanal mining in the vicinity of the Project is of varying intensity. Hundreds of people work at some sites.

Artisanal mining in this area falls under the following categories:

Alluvial gold panning in the Gambia River during the dry season;

Alluvial gold panning in numerous small tributaries during the wet season; and

Sporadic artisanal hard-rock activities in areas north and south of the Gambia River, including areas of

the PNNK.

Numerous inhabitants of local villages are engaged in alluvial gold panning or hand operated sluices alongside

the Gambia River (Plate 13-3) and along several small tributaries. Since the beginning of January 2015, a “dioura”

site (multiple artisanal workings at up to 10-20 m depth) has been observed directly adjacent to the industrial

scale alluvial site mentioned above (Plate 13-4).

Small-Scale Alluvial Mining Operations

Small-scale alluvial mining has been recorded at numerous locations surrounding the Project (refer to Chapter

8 and Plates 13-5, 13-6). Small-scale mechanised alluvial mining permits have been awarded in the past to

companies within the Project vicinity (Figure 13-3). These activities usually involve the use of manual labour to

transport and wash the material in sluices, or using machines (i.e. bulldozers) to transport and deposit material

at small-scale mechanical screening infrastructure. Such activities have been observed to have localised

impacts to water quality

A mechanised alluvial mining operation site (understood to belong to the company “GIE Kambing”) is located

on the southern bank of the Gambia River between the villages of Dalakoy and Kerekonko (Plate 13-5). A recent

site visit from Earth Systems identified that mining at the site had ceased and the company was preparing to

remove their equipment. It appears there has been no treatment of the mining waste from the operation, which

it is understood may have been discharged directly into the Gambia River (Plate 13-6).

EEEMS and La Société Senegalese d’Industrie et d’Entreprise (SSIE) are two small-scale mining companies with

alluvial mining and dredging permits along the river bank between Linguekoto and Tambanoumouya. During

a site visit in May 2015, both companies were actively operating in the area. EEEMS Gold was operating a dredge

and bringing material to process on a sluice situated nearby on the river bank. SSIE was undertaking small-scale

alluvial mining by taking surface material from Niamanoukou Valley by car to a sluice situated beside the

Gambia River. Both enterprises reported they did not use any chemicals in their activities.

Basalt and laterite quarries

A number of quarries, including several laterite quarries and a basalt quarry, are located in the zone bounded

by RN7 south and west of Niemenike, and the northern limit of Mako township (Plate 13-7). The quarries are

understood to have been used during the upgrade of the RN7 by Arezki and are currently not used.

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The construction company Arezki has a laydown area just north of the Mako township (Plate 13-8). It is

understood that the company will be removing the remaining materials at the site by mid-2015.

Plate 13-3 Alluvial mining site in vicinity of Project Plate 13-4 Dioura site between Dalakoy and Kerekonko

Plate 13-5 Small-scale alluvial mining discharge to the

southern bank of the Gambia River (Source: MEC)

Plate 13-6 Small-scale alluvial mining site on southern

bank of the Gambia River

Plate 13-7 Basalt quarry Plate 13-8 Arezki laydown area

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Source: Department of Mines, Kedougou (May 2015).

Figure 13-3 Small-scale mining permits in the Project vicinity

13.2.2 Hydropower

Sambangalou hydroelectric dam project (currently at Pre-Construction Phase)

A key potential hydropower development within the Project catchment is the Sambangalou hydroelectric dam.

This project is associated with the Kaleta Hydroelectric Dam Project, located in Guinea which would link the

two dams to the electric grid of four countries (Gambia, Guinea, Guinea-Bissau and Senegal) involved in the

project.

The site of Sambangalou Dam is located in Senegal on the Gambia River and is about 60 km south of the Mako

Gold Project, with the majority of the dam lake located in Guinea (Figure 13-4). It will consist of a gravity dam

with a capacity of 128 MW and a potential for 400 GWh, with irrigation and flood control prospects.

Construction of the project will entail significant environmental and social impacts, including the following

impacts identified in the ESIA for the project (AfDB, 2014):

Loss of natural resources, including soils, vegetation, agricultural land and faunal habitat due to the

creation of a 185 km2 reservoir. These impacts clearly cannot be mitigated because of their irreversible

character;

Displacement of 186 households (1,320 persons or PAPs) with 489 traditional dwelling huts. Ten small

settlements are affected with associated lands estimated at 1,250 hectares;

Potential for health impacts due to the presence of a large volume of standing water acting as a source

of waterborne disease vectors;

Major impacts on the river regime in the operational phase. These impacts are linked to modification of

the hydraulic balance in the wet zones of the Senegalese and Gambian reaches. There will be a recession

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of the saline front during the dry season (positive and negative impact) and for a period a deteriorated

quality of water downstream of the dam (and in the reservoir); and

Crossing the river during the dry season may become more difficult.

The project could also have some positive impacts, including the following:

Improved land tenure security;

Creation of employment and income opportunities;

New agricultural opportunities; and

Improved electricity supply for rural areas

Construction of the dam was expected to start in 2014 (Engineering News, 2014); however, numerous delays

have meant that a start date is not currently known. The project will be financed by the OMVG members with

assistance from the African Development Bank, EIB, the World Bank, AFD, BIDC, BOAD, KFW and Abu Dhabi

but the financing plan is not yet finalised (EIRI, 2015).

Source: African Development Fund, 2008. Note - yellow star indicates approximate location of Mako Gold Project.

Figure 13-4 Location of the Sambangalou Hydroelectric Dam Project

13.2.3 Tourism Basic Infrastructure

There is a relatively low demand for tourism services in the vicinity of the Project. However, there are

approximately five tourist accommodation facilities in Tomboronkoto Commune, offering approximately 50

beds. Access to the PNNK is seasonal and is limited to five months of the year.

A number of tourist operations are located adjacent to the Gambia River in the vicinity of the Project. As

outlined in Chapter 6, three tourism operators were identified in the vicinity of the PDA for the Mako Gold

Project. Campamento Solidario and Keur Anneuk are located near Marougoukoto (Badian), and African Safari

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Lodge is located along the RN7 near Bafoundou. These are briefly described below. In the National Park, tourism

is very limited and makes a minimal contribution to the management of the park.

Plate 13-9 Ecocampemento Solidario Poblado of Plate 13-10 Keur Annuek

Badian (Campamentos Solidarios, 2015)

Limited tourist activities also take place downstream of the Mako Gold Project and within the Niokolo Koba

National Park in proximity to the Project.

Kedougou has more developed tourist infrastructure, including numerous hotels, restaurants and transport

services.

13.2.4 Agricultural, Farming and Fishing projects

Crop production and pastoralism are widely practised in the Kedougou region. For this reason, they are the

focus of numerous rural development programmes. As agriculture is such an important livelihood activity, there

has been an increased use of the Gambia River, flood plains and low-lying drainage areas.

The following agricultural projects have been identified in the vicinity of the Mako Gold Project:

PRODAC: Launched in 2014, the National Program of Community Agricultural Area (PRODAC) is located in 9

zones in Senegal, with one in the region of Kedougou (Plates 13-8 and 13-9). In Kedougou, PRODAC runs a land

use planning programme that aims to enhance large-scale farmlands, from 1,000 to 5,000 ha, in order to assist

in the integration of young people in the field of agriculture, and to create an incubator for future

entrepreneurs. The programme aims to create more than 300,000 employment opportunities in the country.

The operation at Itato, to the south-west of Kedougou on the Gambia River, consists of the development of

aquaculture pens, greenhouses, beehives and accommodation, and promotes aquaculture, agriculture, and

poultry activities. This programme uses the Gambia River as the main water supply source and location for

aquaculture activities.

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Plate 13-11 and Plate 13-12 Visit of water specialists to the PRODAC pilot site and Dam Track of Médina Djikoye

(PAPIL Project)

PADAER: The Support Program to Agricultural Development and Entrepreneurship was launched in 2013 and

will last 6 years. According to the Senegalese Press Agency, the programme, funded by the Senegal Government

and the Spanish Fiduciary Fund, aims to reduce rural poverty and foster economic growth in the areas of

Kedougou, Tambacounda, Kolda and Matam. The rice, maize, sorghum, and fonio sectors are targeted.

Beneficiaries are 50,000 small scale farms, and 975 producer organizations and small rural entrepreneurs. The

programme includes numerous agricultural land holdings in the Kedougou region, and the Gambia River is the

main source of water supply. Numerous villages in the vicinity of the Mako Gold Project are preparing to

participate in this programme.

PAPIL: The Support Program to Local Small Scale Irrigation started in 2006 and includes project activities in the Kedougou region. Financed by the African Development Bank, the main objective is to collect, store, and utilise

rainwater with the construction of hydro-agricultural structures. The activities carried out under the project,

according to a participatory planning approach, provided for:

Development of more than 100 small runoff control structures and facilities (micro-dams, weirs, ponds,

bottomlands, small irrigated schemes, etc.);

Rehabilitation of degraded lands;

Improving the livelihood of the target population; and

Advisory support measures and construction of a basic socio-economic infrastructure.

Agricultural activities (mainly rice cultivation) have diversified into arboriculture, beekeeping, and vegetable

gardening. The project also funded local infrastructure projects such as classrooms and dispensaries. The

project officially ended in 2013.

PROGEBE: The Regional Project of Sustainable Management of Endemic Ruminant Livestock in the West

(PROGEBE) aims to strengthen sustainably genetically characteristics of endemic livestock, increase

productivity, and commercialisation. In Senegal, the project covers an area of 5,900km2 and includes activities

in the rural communities of Bandafassi for the region of Kedougou. The project has involved the construction

of roads, milk processing plants, research centres, slaughter slabs, and training of farmers and others

stakeholders. This project ended in 2012.

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PROGEDE II: The Second Project of Sustainable and Participatory Management of Energy runs from 2011 to

2016 . Funded by the World Bank, this project aims to increase income of participating villages, and local

communities, with special attention to women, both from charcoal production and other income generating

activities such as apiculture, aviculture, cattle feeding. Areas involved in this project include Bandafassi and

Tomboronkoto (World Bank, 2014c).

13.2.5 Other Infrastructure Projects

Other infrastructure projects identified in the Project region include:

Fongolimbi Bridge: A bridge construction project situated on the Gambia River, at Fongolimbi, in the

region of Kedougou planned for 2015. There is a potential for short-term cumulative impacts from this

project affecting water quality and hydrology during the construction period. As of the date of

publication of this ESIA, construction work had not yet begun at the proposed site.

Kedougou-Salémata Road: Construction project of a 103 km road between Kedougou and Salémata

(Guinea Border) planned for 2015. Dust and vehicular air pollution are the main short-term and long-

term cumulative impacts that this project would have. At the time of publication of this ESIA, a tender

had been placed on the AGEROUTE website for the project that was due to be closed on 27 November

2015.

13.3 Assessment of Cumulative Impacts

A summary of key potential cumulative impacts associated with the Project is provided below.

13.3.1 Gambia River

Activities with Potential Cumulative Impacts

The main current or future activities upstream from the Project that could potentially alter water quality or

hydrology comprise the Sambangalou Dam project, the PRODAC agriculture / aquaculture project and semi-

industrial / small-scale artisanal mining activities. The construction of the Fongolimbi Bridge may also affect

water quality and hydrology during the Construction Phase.

One of the most significant projects that may affect water quality and hydrology of the Gambia River in the

vicinity of the Mako Gold Project if development proceeds is the Sambangalou Hydropower Dam. The

proposed dam would be located in Senegal, upstream of Kedougou and adjacent to the Senegal-Guinea

border. According to the ESIA conducted for the proposed project, the major adverse impacts of the project on

the biophysical environment of the Gambia River will be the loss of biological resources and habitats. The

construction of a dam upstream of the Project will have significant impacts on flow rates, water levels and water

quality in the Gambia River. Impacts on water quality will likely be highest during dam construction. Impacts to

flow rates and water levels will likely commence during construction and will be ongoing throughout operation

of the dam. Changes to the flow and water quality of the Gambia River may have subsequent effects on the

biological values of the River. The dam infrastructure may also significantly affect fish migration patterns along

the river. Conversely, the dam may also have a positive effect vis-à-vis the regulation of water flow of the

Gambia River, in that it would ensure that water flows during both the wet and dry seasons (water generally

stops flowing towards the middle / end of the dry season).

Potential Cumulative Impacts on Water Quality

Existing threats to the water quality of the Gambia River upstream of the Project include water abstraction for

irrigation, water pollution (e.g. from agricultural runoff, sewage and chemicals used for artisanal mining), and

potential hydropower development. No agricultural runoff is associated with the Project and the chemicals

used by the Project are not those used by artisanal miners. Consequently, sedimentation and sewage are

potential pollution sources that might have cumulative impacts.

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Sediment from the Project’s construction activities may add to that generated by the Sambangalou

Hydropower Dam activities, particularly if the construction periods overlap. This could also be exacerbated by

unregulated artisanal and semi-industrial mining activity. However, as sediment loads in the Gambia River are

known to peak during the wet season (see Section 6.5), and given the short construction period and the

management measures that will be put in place to prevent sedimentation during construction, any cumulative

impact is expected to be negligible.

No significant impacts on the water quality of the Gambia River are expected to result from the Project post-

closure.

Potential water quality impacts of the Mako Gold Project are discussed in Chapter 9. To avoid water quality

impacts downstream, the Project has been designed as a ‘zero-discharge’ operation. Supernatant water from

the TMF and other Project infrastructure will be temporarily stored in a supernatant pond and then pumped

back to the Process Plant for re-use. Surface drainage water will not be released to Badalla Creek / the Gambia

River. Monitoring of groundwater and surface water course (during the wet season as there are no permanent

water courses other than the river) will be undertaken throughout the Project lifetime and after closure. This, in

associated with risk management measures described in the Risk Assessment (see Volume B), will negate any

potential for water quality impacts originating from the Project.

Potential Cumulative Impacts on Hydrology

The development of the Mako Gold Project will add incrementally to the existing hydrological impacts to the

Gambia River from other Projects and activities. However, the hydrological impacts of the Mako Gold Project

alone are considered negligible. Potential threats to the hydrology of the Gambia River upstream of the Project

include water abstraction for irrigation / other projects as well as the Sambangalou hydropower development.

Hydropower developments such as Sambangalou will regulate the flow rates of the Gambia River and

potentially reduce the volume of water storage required for the Mako Gold Project.

Potential hydrology impacts of the Mako Gold Project are discussed in Chapter 9. A comprehensive

management and monitoring programme has been developed for the Project which will significantly reduce

the potential for the Project to impact downstream hydrology and water quality.

There will be a maximum extraction rate of 2% from the Gambia River flow in order to protect environmental

flow, the water requirements of downstream users and aquatic biodiversity). This pumping rate has been based

on the available 42 year data set for Gambia River flow. This would mean that pumping would be able to be

conducted once river flows have been established in the beginning of the wet season.

Incremental cumulative impacts from the Project on hydrology will therefore only occur during operation (e.g.

water abstraction and disruption of creek flows). In the case that the Sambangalou dam project is constructed

during the Project lifetime and results in a significantly-altered water flow regime, the relatively low water

demand of the Mako Gold Project would be expected to have a negligible impact on the overall Gambia River

flow.

No significant post-closure Project impacts on the hydrology of the Gambia River are expected.

Given the above, the minor residual impacts and risks of the Project on downstream hydrology will add

incrementally to the potential changes in hydrology due to activities such as abstraction for irrigation and

hydropower development. The effective implementation of the proposed management and monitoring

programme is expected to result in the Project not adding significantly to existing hydrological impacts and

risks to the Gambia River.

Potential Cumulative Impacts on Biodiversity

Through contributing incrementally to the existing water quality and negligible hydrological impacts to the

Gambia River, the Project may also have cumulative impacts on the aquatic ecology and aquatic resource use

of the Gambia River. Existing threats to the aquatic ecology of the river include overfishing, introduction of

exotic species, agro-pastoral pollution, urban development, artisanal and small-scale mining and hydropower

development. The impacts of the Project on aquatic ecology and resource use are not expected to be

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significant relative to the potential impacts generated by other projects (such as the Sambangalou dam and

unregulated alluvial and semi-industrial mining activities).

13.3.2 Niokolo-Koba National Park

As per Section 6.2.6, the key existing threats to the biodiversity of the PNNK include:

Altered fire regimes (natural, illegal burning or as a land management technique) which have resulted in

fires becoming more intense and widespread;

Vegetation clearance for the development of agricultural land, especially the encroachment of

agricultural land on the edges;

Poaching of animals;

Drought;

Illegal logging;

Grazing by livestock (i.e. by animals wandering in or intentional grazing), particularly on the edges near

agricultural land;

Premature drying of ponds and drought;

Artisanal mining for gold (including the use of cyanide and mercury) impacting on soil, water,

biodiversity and habitat. Note that artisanal mining is being practiced on the fringes of the PNNK; and

Accidental or intentional introduction of exotic and invasive species such as Mimosa pigra.

Potential Cumulative Impacts on Biodiversity

As outlined in Chapter 12, the key potential residual impacts of the Project on the biodiversity values of the

PNNK after mine closure are expected to be associated with:

Indirect impacts due to increased resource use – e.g. potential for increased hunting and timber/NTFP

collection.

Loss and changes in habitat within the PDA outside the PNNK, which may affect the use of these habitats

by some species associated with the Park (e.g. chimpanzees); and

Barriers to movement – the presence of the Project (outside the PNNK) will likely be a barrier to the

movement of some species associated with the Park beyond closure.

The in-migration of people into the Project area could lead to a number of cumulative impacts on biodiversity.

The key threats that could be exacerbated include the rate of vegetation clearance for the development of

agricultural land on the edges of the PNNK if significant in-migration occurs due to the Project, leading to

increased pressure on land resources. In-migration may also lead to increased forest resource use by local

villagers within the boundaries of the PNNK, increased hunting and timber/NTFP collection. Tomboronkoto

Commune and the Kedougou Region in general has experienced a considerable influx of people, primarily

related to mining – both artisanal and formalised – and related economic opportunities. The development of

the Mako Gold Project is expected to add to this in-migration. However, the Company is committed to

implementing a number of measures to minimise Project-related in-migration, as outlined in Section 11.10 (e.g.

preferential local employment, daily transport services from Kedougou town for Project employees, working

with local authorities, provision of camp for non-local employees etc.). Community awareness programmes are

also expected to be implemented to increase awareness of the local villagers regarding the need to protect the

biodiversity values of the PNNK. The effective implementation of these measures will reduce the potential

cumulative impacts of the Project related to the increased demand for (and reduced availability of ) land, natural

resources and agricultural produce by migrant population.

A key current threat to the PNNK is changes to the fire regime. Widespread and high intensity fires are common

in the dry vegetation types in the Park. Such fires have been known to change habitat and flora composition,

including changes to microclimate, soil composition and soil stability. Fires affecting the Park occur both

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naturally and due to human interventions. The use of fire by local villagers is a common practice for the clearing

of land for hunting and agriculture (i.e. cropping, cattle foraging on new shoots, logging and apiary) and as a

management tool. The Project is not expected to directly result in a significant increase in the risk of direct

ignition of fires (refer Section 9.13). While fire is a risk for any industrial project involving flammable substances

such as hydrocarbon fuels and explosives, the Project will have a number of safeguards to avoid and minimise

the risk of a fire outbreak from the site (e.g. site-specific Emergency Response Plan, staff training, fire hydrants

and hose reels). However, the Project has the potential to increasing the risk of fire in the vicinity of the PNNK

indirectly through Project-related in-migration, which, as discussed in the paragraph above, may increase

pressure on land and resources and subsequently lead to increased use of fire on the Park boundaries as part

of hunting and agricultural activities. The Company is committed to minimising Project related in-migration (as

described above) and its subsequent effects wherever possible (refer Section 11.10.3), however it is expected

that some increases in pressure on land resources will occur as a result of the Project.

The various potential impacts of the Project on the PNNK have the potential to add cumulatively to the existing

threats to the National Park. However, if effectively implemented, it is expected that these residual impacts will

be largely offset by the biodiversity offset programme for the Project (as outlined in the Biodiversity Action Plan, Volume C). If the offset programme is successful, the Project is not expected to result in a significant

cumulative impact on biodiversity values for the National Park in the long term.

13.3.3 Employment and Skills Development

Economic development

The development of the Mako Gold Project would add to the number of commercial gold mines in the region

and will be likely to:

Provide further potential for the training and employment of local workers;

Provide further scope for economic development in the region and communities through the

requirement for products and services for the Project and associated workforce; and

Add to existing transport and services to the area.

If it proceeds, the Mako Gold Project will be the second major operational gold mine in Senegal. Experience

from the Sabodala Gold Mine has shown that, if carefully managed, the potential socio-economic benefits to

local communities from such developments can be significant.

The Mako Gold Project will be likely to add to the economic development of the area which may also add

incrementally to the pressure on existing infrastructure and services. The cumulative impacts (both positive

and negative) will extend as far as Kedougou town and also along the RN7.

Tourism

A number of small tourist developments were identified in the area surrounding the Project. The development

of the Mako Gold Project is not expected to result in any significant negative impacts on tourism in the region

(refer Chapter 11). In-migration associated with the Project, and potential eco-tourism developments

associated with the biodiversity offset strategy, could increase the use of hotels and resorts in the area. The

improved access to infrastructure and services, particularly transport services and accommodation, would add

to similar socio-economic benefits for tourism associated with other major projects and developments in the

region. However, the minor visual amenity impacts of the Project will also add cumulatively to similar impacts

of other projects in the vicinity (i.e. semi-industrial mining between Dalakoy and Kerekonko).

During the Operation Phase, the Project has the potential to adversely affect tourism in the local areas. However,

direct demand for accommodation and transport services will more than offset this impact for tourist

operators.

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Agriculture and Farming Projects

Five agricultural projects were identified in the Project region. The Company has a priority programme for

livelihood restoration and improvement. This actively supports local communities by providing the following

benefits;

Improved commercial agricultural opportunities;

Agricultural intensification or extensification, as appropriate;

Improved access to technology;

Incentives to exploit areas outside the PNNK; and

Links and partnerships with other projects.

The Project will therefore continue to add cumulatively to the benefits provided to local farmers by agricultural

projects through supporting community development initiatives (refer Livelihood Restoration Plan, Volume

D). Road construction and upgrades for the Mako Gold Project may also allow easier access to agricultural areas

utilised by these projects. Additionally, increases in local incomes associated with employment and economic

opportunities from the Mako Gold Project may also allow farmers to invest in agricultural machinery (e.g.

tractors) and items such as fertilisers and pesticides.

As very little agricultural land will be affected by the Mako Gold Project, the Project is not expected to have any

significant negative effects on the agricultural and farming projects identified.

13.3.4 Accommodation Availability

The Project will significantly increase demand for accommodation in the vicinity of the Project. In the short-

term there is a potential that the existing accommodation capacity is not sufficient. Without mitigation this

could potentially lead to the creation of informal settlements and an increase in waste and pollution. However,

due to preferential local employment and other measures described in Section 13.3.2, this cumulative impact

is considered to be minor or negligible.

13.3.5 Airshed

The Project is located in a relatively pristine airshed with very few industrial projects in the region that may

affect air quality. Fires are common in the open forest covering the majority of the surrounding area (including

within the PNNK, and is one of the primary sources of airborne particulates in the area. Other major Projects in

the region such as the Sabodala Gold Mine, which uses a HFO power plant, would also contribute to the existing

levels of air pollution and greenhouse gas emissions in the broader area. However, at a regional scale the Project

emissions would not have a significant impact on the airshed when considered in isolation.

The potential air quality impacts of the Mako Gold Project have been assessed in detail in Chapter 9. The

primary air emissions from the Project will be dust from disturbed land and vehicle/equipment use, as well as

greenhouse gasses and other air emissions from fuel use. A detailed management programme to minimise

adverse air quality emissions from the Project is expected to be implemented. With diligent application of

prescribed management measures, potential air quality impacts from Project-related emission sources are

considered low and are not expected to result in any significant cumulative impacts on the airshed at a regional

scale. Air emissions from the Project will also be primarily limited to the Construction and Operation Phases of

the Project, when construction and mining activities will occur, and power will be generated by the HFO Power

Plant. Rehabilitation and revegetation activities will significantly reduce dust emissions from disturbed land

post-closure.

13.3.6 Vehicle Movements on the RN7

The National Road 7 (Route National 7 or RN7) will be used as the primary transportation route during all Project

phases for supplies and material delivery. Vehicular use of this road includes frequent transportation of various

goods and supplies for mining projects in the region as well as onward to Mali, including hazardous materials

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and hydrocarbon fuels. The key cumulative environmental and social impacts associated with transportation

on the RN7 during the Construction Phase are:

Vehicle collision risks could potentially increase due to a larger number of vehicles using the RN7;

Risks associated with the transport of hazardous materials;

Road construction, upgrade and maintenance requirements causing disruption; and

Road deterioration leading to increased risk of accidents;

There could also potentially be cumulative impacts from the Project vehicles and other vehicles using the RN7

on water quality (surface run-off containing vehicle-derived pollutants), air quality (principally dust), noise,

vibration, greenhouse gas emissions and visual amenity. During construction of the Mako Gold Project, peak

noise from passing heavy vehicles is estimated to increase by approximately 3 dB(A). These impacts are

discussed further in ESIA Chapter 9. The risks and management of transportation of hazardous materials is also

covered in Chapter 9 as well as in the Risk Assessment (ESIA Volume B).

Cumulative impacts during Project operation are also likely to include noise from haulage vehicles and

transportation of a range of hazardous materials for the Project. The factors that affect noise emissions from

traffic include the volume of traffic, the speed of traffic and the composition of traffic (number of heavy vehicles

versus light vehicles). Generally, heavier traffic volumes, higher speeds and a larger number of heavy vehicles

results in more traffic noise. Traffic vibrations may be an issue up to a maximum distance of 50 m from the road,

but would represent only a small percentage of daily vehicular traffic on the RN7, and the additional impacts

of the Project to existing vibration levels are likely to be negligible.

Villages located along the RN7 to Dakar already experience heavy traffic flows, therefore Project-related

transportation and traffic cumulative impacts are expected to be minor.

13.4 Conclusions and Management Implications

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 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 Project is also located within a well-explored and highly prospective

area for mining.

In summary, key cumulative impacts associated with the Project are expected to be related to:

Gambia River: While the Project has been carefully designed to minimise potential impacts and a

detailed water management programme has been developed to minimise Project impacts, there are

expected to be some minor residual impacts on hydrology and water quality from the Project. These

impacts will add incrementally to the existing water quality and hydrological impacts and risks

associated with other existing and planned Projects and activities within the catchment (e.g. water

abstraction for irrigation, water pollution, hydropower development etc.). Cumulative impacts on

hydrology from the Project are only expected during the Operation Phase, as the hydrology impacts of

the Project will be primarily limited to this phase. The primary cumulative impact on water quality

resulting from the Project is expected to be an increase in suspended sediments in the Gambia from

land clearance and construction activities. This impact will primarily occur during the Construction

Phase, and impacts will be minimised wherever possible through the detailed erosion and sediment

control programme proposed to be implemented for the Project. Other mitigation measures to protect

water quality;

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» Village sanitation and waste management programme;

» Development of livestock watering points away from the Gambia River; and

» Promotion of alternative livelihoods to artisanal mining and support the Government with

legalisation and formalisation of artisanal mining

Niokolo-Koba National Park: As a biodiversity offset strategy will be implemented to offset the key

residual ecological impacts associated with the Project, no significant overall cumulative impact on

biodiversity values for the PNNK is expected in the long-term. During Project construction and

operation, there is potential for the Project to add cumulatively to the existing threats to the PNNK,

particularly regarding potential increases in the use of fire, hunting and land clearance on the park

boundaries due to Project-related in-migration, and subsequent increased pressure on land and forest

resources. In-migration is expected to be actively managed and monitored for the Project, and a

detailed management programme will be implemented to minimise potential biodiversity impacts as

part of the Biodiversity Action Plan (Volume C). The Livelihood Restoration Plan (Volume C) also

includes mitigation for biodiversity impacts.

Airshed - The Project is located in a relatively pristine airshed with very few industrial projects in the

region that may affect air quality. The primary air emissions from the Project will be dust from disturbed

land and vehicle/equipment use, as well as greenhouse gasses from fuel use. Air emissions from the

Project will also be primarily limited to the Construction and Operations Phases of the Project. With

diligent application of prescribed management measures, residual air quality impacts from Project-

related emission sources are considered low and are not expected to result in any significant

cumulative impacts on the airshed at a regional scale.

Socio-economic benefits: This is expected to be the most significant cumulative impact of the Project.

The expected socio-economic benefits of the Mako Gold Project, including employment and local

economic development, are expected to be significant and will add cumulatively to those of other

major infrastructure projects in the region (e.g. Sabodala Gold Mine). Strategies have been developed

that are promote positive economic development and minimise any negative impacts of the Project

on local economic development, including the Livelihood Restoration Plan and the Local Economic Participation Plan (LEPP - Volume D). The LEPP prioritises local employment, local procurement and

local economic development. The benefits from increased accessibility resulting from road

construction and upgrades for the Project will add to similar benefits from other projects in the region.

The Project may also result in some minor cumulative impacts and benefits to tourism activities and

agricultural projects in the region, but overall the Project is not expected to significantly affect these

activities.

The Company has incorporated environmental and social considerations into numerous aspects of the Project

design, and a detailed management programme has been developed for the construction, operation and

decommissioning of the Project, to minimise the Project’s residual negative environmental and social impacts,

and maximise residual benefits associated with the Project (e.g. employment and community development).

Measures to avoid and minimise any potential cumulative impacts of the Project identified have been provided

in Chapters 9 to 11 of the current report, as well as in the various management plans prepared (refer Volume

C).

Management measures that have been developed specifically to mitigate cumulative impacts on biodiversity

include programmes within the Livelihood Restoration Plan and biodiversity offset programme (Biodiversity Action Plan (Volume C)) that will reduce dependence on the PNNK and critical habitat. The LEPP will also

maximise the cumulative socio-economic benefits of the Project.

Local, regional and national level government and stakeholder consultation will also 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 Chapter 15 and in the Stakeholder Engagement Plan (Volume C).