draft environmental scoping report malingunde...

McCourt Mining Pty Ltd (a subsidiary of Sovereign Metals Limited T: +61 8 9322 6322 | F: +61 8 9322 6558 | E: [email protected] | www.sovereignmetals.com.au

Level 9, BGC Centre, 28 The Esplanade, PERTH WA 6000 | ABN: 71 120 833 427

DRAFT ENVIRONMENTAL SCOPING REPORT

MALINGUNDE GRAPHITE PROJECT, LILONGWE DISTRICT, MALAWI

March 2018

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EXECUTIVE SUMMARY

1 Introduction Sovereign Metals Limited (Sovereign) is an Australian publicly listed company that trades on the Australian Securities Exchange (ASX) under the code ASX:SVM. Sovereign is engaged in exploration and appraisal of resource projects, with the main focus being its 100% owned Malingunde Graphite Project (the Project), which is a large high-grade saprolite-hosted flake graphite deposit on the Lilongwe plain.

McCourt Mining Pty Ltd (McCourt Mining) is a wholly owned subsidiary of Sovereign and was acquired by Sovereign in September 2012. McCourt Mining is the licence holder of the exclusive prospecting licence (EPL), EPL0372, in which the Project is located (Figure E.1).

The Project is located near the township of Malingunde, approximately 15 km southwest of Malawi's capital city of Lilongwe, and falls within the Lilongwe District of the Central Administrative Region. Access to the Project from Lilongwe is via the sealed section of the secondary road, S124, to Likuni and then the unsealed continuation of the S124 to the Kamuzu Dam turn-off. The Project area is located in close proximity to the villages of Kumalindi and Ndumila, directly north of Kamuzu Dam II. Access around the Project site is via a network of unsealed village tracks.

Sovereign is currently conducting a number of technical studies, which will culminate in a feasibility study, to determine the financial viability of developing a mine at Malingunde. An economic scoping study for the Project was completed in mid-2017. The results of this study demonstrated that the Project has the potential to be developed as a low capital and operating cost operation, with annual graphite concentrate production of approximately 44,000 tonnes (t) over an initial life-of-mine (LOM) of 17 years. Sovereign is now moving into the next phase of Project development activities, with an aim to bringing the Project into construction in 2019. One of the technical studies that is required as part of the feasibility study is an environmental and social impact assessment (ESIA).

2 Environmental and Social Impact Assessment Process Section 2(f) of the Environment Management Act (EMA), No. 19 of 2017 states that an ESIA is a legal requirement for any project that may significantly affect the environment and use of natural resources.

In 1997, the Environmental Affairs Department published the Guidelines of Environmental Impact Assessment for Malawi. The purpose of the guidelines is to integrate environmental concerns in national development, and are applicable to all types of projects in the public and private sectors for which ESIA studies may be required, as identified in the lists of prescribed projects (List A and List B) appended to the guidelines. List A identifies projects for which an ESIA is mandatory, and includes mining of minerals, expansions to mines, mining exploration activities, minerals prospecting activities, quarries, gravel pits and removal of sand or gravel from shore lines. The Project falls under this prescribed list of activities, and as such McCourt Mining has commenced an ESIA process. McCourt Mining will be the applicant for the environmental authorisation as per the requirements of the EMA.

This ESIA process for the Project will also take cognisance of other relevant Malawian legislation, policies and standards. In the absence of specific guidelines and standards under Malawi legislation, good international industry practice will be adhered to, and where relevant, international guidelines and standards applied, including the International Finance Corporation (IFC) Performance Standards on Environmental and Social Sustainability (2012), the World Bank Group Environmental, Health and Safety Guidelines (2007) and the Equator Principles (2013).

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Figure E.1: Malingunde Project Location and Prospecting Licence Area

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The ESIA process is generally undertaken in three distinct phases, namely the Project Brief, Environmental Scoping and ESIA Phases. A Project Brief was submitted to the Environmental Affairs Department of Malawi in June 2017 to initiate the ESIA process for the Project and the Department confirmed that an ESIA needs to be compiled and submitted to them for review and approval. The environmental scoping phase will be completed in May 2018 with the submission of the environmental scoping report (ESR) to the Department, after which the detailed ESIA phase will commence.

3 Environmental Scoping Report

The main aim of the environmental scoping phase is to identify potential environmental and social issues that require detailed investigation and assessment by a range of specialists in the ESIA phase, as well as develop the terms of reference (ToR) for undertaking these investigations.

The specific objectives of the scoping phase are to:

• Provide opportunity for all key Project stakeholders i.e., the relevant authorities, stakeholder groups and community members in the Project area to exchange information with the Project team and express their views and concerns regarding the Project.

• Identify key issues and concerns that require further assessment during the ESIA phase. • Determine the ToR for a variety of specialist studies to be undertaken. • Determining the extent of, and approach to, the ESIA.

The ESR provides a description of the proposed Project; information on the existing biophysical and social environment; identifies potential environmental and social issues that require detailed investigation and assessment in the ESIA; and defines the ToR for the required specialist studies.

The draft ESR will be available from 5 March to 13 April 2018 for review and comments by stakeholders. Comments and queries will be incorporated in the comments and response report, and the draft ESR amended as needed. The revised ESR will be submitted to the Environmental Affairs Department for review and approval of the ToR.

4 Project Description The Project is currently at the advanced exploration stage, with a maiden Joint Ore Reserves Committee (JORC)1 Mineral Resource Estimate (MRE) completed in April 2017. The MRE shows 28.8 million tonnes (Mt) @ 7.1% total graphitic carbon (TGC). Production will target the higher-grade core of the resource, with an initial production target over the LOM of 8.0 Mt @ 10.0% TGC. This will produce approximately 44,000 t of graphite concentrate over a 17 year mine life.

The current conceptual mine layout, with alternative locations for certain infrastructure components, is as depicted in Figure E.2.

1 The Australasian Code for Reporting of Exploration Results, Mineral Resources and Ore Reserves (‘the JORC Code’) is a professional code of practice that sets minimum standards for Public Reporting of minerals Exploration Results, Mineral Resources and Ore Reserves.

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Figure E.2: Conceptual Layout of the Malingunde Project

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Notable features of the conceptual mine layout include:

• A number of long, shallow open pits, trending in a northwest–southeast direction. • A waste rock dump (WRD) and tailings storage facility (TSF). • An ore processing plant. • Site roads providing access to the pit, processing plant and administration buildings. • Raw water storage dam, process water storage dam, site water management infrastructure and

dirty water storage dams. • Workshop to service and maintain mining fleet and equipment. • Diesel fuel storage and filling station for mine fleet and light vehicles. • Administration buildings, offices, ablution facilities and crib rooms.

A number of technical studies are being undertaken to determine the optimal layout of infrastructure. The Project area indicated in Figure E.2 is likely to reduce significantly once the optimal layout has been determined. The preferred layout will be detailed in the ESIA report.

4.1 Mining Method

Open pit mining with traditional excavator and haul trucks will be used to mine ore. Mining will be free-dig in nature and no drilling and blasting activities will be required for the operation as the material is relatively soft. Mining will be undertaken in a number of long, shallow open pits, with maximum depths of 25 m and maximum widths of approximately 200 m.

Ore will be loaded on to articulated dump trucks and hauled from the pit to the run-of-mine (ROM) pad and processing plant, while all waste rock will either be transported to the TSF site for use in embankment construction or to a nearby WRD.

The TSF for the Project has been designed to contain a volume of approximately 7.3 Mt of tailings over the LOM at a deposition rate of approximately 450,000 t per annum.

Various options for the mining sequence are being considered, taking into account TGC grade and material characteristics.

4.2 Processing

Physical separation using simple processing is anticipated with the use of an upfront scrubber to disaggregate the graphite flakes from the host material (as opposed to a jaw crusher and rod mill used in hard-rock operations) followed by standard rougher flotation, polishing grind, cleaner flotation stages and a final attritioning and cleaner flotation stage.

Chemicals used in the process are limited to a small amount of diesel (150-200 g/t of ore) and frother which aids in the rougher and cleaner flotation stages. The reagents end up with the graphite concentrate and is then evaporated when the concentrate goes through the drying stage. Hence, there are no anticipated added chemicals that would end up in the TSF or within any other parts of the site. Preliminary test work to date has indicated that the concentration of chemicals is below the IFC EHS Guidelines for Mining Effluent (2007), and in fact generally meet the World Health Organisation Guidelines for drinking water (2011).

The produced concentrate will be thickened and then filtered in a filter press. The filtered concentrate will be dried using a diesel-fired, rotary dryer. Dried product will be screened and bagged for dispatch

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and sale. Product from the operations will be transported on flatbed trucks by road to the Kanengo rail head in Lilongwe for transport to the port of Nacala in Mozambique, from where it will be exported.

Various options for the plant are being considered to allow further optimisation of the process and to ensure a high quality product for all material types.

5 Potential Impacts and Issues for Consideration

One of the main aims of the environmental scoping study is to identify issues and potential environmental and social impacts that require further investigation and assessment as part of the ESIA. The issues and potential impacts identified are based on issues and concerns received during consultation with stakeholders, as well as issues identified by various specialists based on initial desktop review, field surveys and experience on similar projects elsewhere. Refer to Section 4 of the ESR for details about baseline studies undertaken to date, as well as Section 5 for issues raised by stakeholders. These issues form the basis for further assessment and studies during the ESIA phase.

Feasible and practical management measures to reduce potential negative impacts will be proposed based on the analysis and assessment of the impacts. These management measures will form the basis of an environmental and social management plan (ESMP) that will be included in the ESIA report. It is likely that potential impacts could be successfully mitigated through appropriate measures incorporated into the design of the Project, as well as the implementation of an ESMP throughout the LOM.

The most pertinent potential impacts and issues that will be assessed in further detail are:

• Creation of employment opportunities: Construction and operation of the Project will create new employment opportunities. Some of this labour will be from local communities close to the Project site, as well as from Lilongwe. Project employment will lead to increased household income and the enhancement of local human resources through training and skills development. Further economic benefits will be generated through the procurement of local goods and services. These positive economic impacts could also lead to adverse impacts related to gender equality, and particularly the risk that women do not receive a share of the economic opportunity and have lower control of financial resources.

• Improvement in social infrastructure: Subject to agreement with national government, community development projects or funding could be created by the Project and be used to improve infrastructure and services at the local and regional level.

• Contribution to the economy: The Project will likely contribute positively to the regional economy, either by its input to an increase of exports or incentives for small and medium enterprises associated with the Project.

• Exposure and disturbance of soil: Impacts on soil may occur because of the proposed mining and mining related activities to be undertaken. Such impacts may result from the stripping and stockpiling of topsoil, polluted water run-off, spillages of hydrocarbons and/or chemicals and erosion. These impacts may further alter nutrient, chemical and physical properties of the soil, thus reducing its ability to support certain land uses post closure.

• Increased soil erosion: Heavy machinery and mining vehicles may result in the compaction of soil, leading to decreased infiltration of rain water and increased surface run-off volumes and velocities, increasing the risk of erosion. This could contribute to existing siltation impacts in surface water sources, altering water quality.

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• Lack of topsoil for rehabilitation: The potential lack of suitable topsoil for use during rehabilitation and closure may impact the successful revegetation of distributed areas, and impact on future land uses.

• Impact on vegetation and fauna: Clearing of vegetation may impact on flora and fauna, potentially resulting in displacement of fauna (mammals, birds, reptiles and amphibians) and the loss of feeding and breeding sites.

• Habitat degradation due to dust: Increased levels of dust in the area is likely, particularly during the dry season. Dust settling on plant material can reduce photosynthesis, which in turn reduces plant productivity, growth and recruitment.

• Impact on flora and fauna through accidental contact with harmful substances: Accidental spillage of harmful or toxic substances (e.g., hydrocarbons, chemicals and contaminated water) may impact on the fauna and flora, either by ingestion of the substances, uptake of chemicals by plant roots, or direct contact (through the skin, leaves or stems).

• Disturbance of fauna through noise and vibration: Vibration from heavy machinery and vehicles can affect a number of subterranean fauna, such as the collapsing of burrows, resulting in these animals leaving the area. Noise could also affect birds, mammals, reptiles, amphibians and arthropods.

• Disruption of fauna migration patterns: Local migrations of fauna in the area may be affected by mining infrastructure forming a barrier to migrating animals or reducing the chance of an animal surviving its migration due to collisions with vehicles.

• Loss of wetland habitat: A portion of the transformed dambo in the central part of the Project area may be impacted by the development of the open pits. This may result in the loss or displacement of the fauna dependent on wetland habitats for feeding, shelter and breeding purposes.

• Sedimentation of dambos: The dambos to the north of the Project area may be impacted by sediment eroded or blown off exposed soil after vegetation clearing and/or soil stockpiling, as well as erosion of the side slopes of WRDs and the TSF. Sedimentation within the wetlands could influence water flow and vegetation.

• Invasion by alien vegetation: Clearance of vegetation is likely to result in an increase in alien invasive trees and invasive shrubs, which may affect overall biodiversity.

• Impact on aquatic biodiversity: Changes in water quality as a result of surface water run-off could impact on aquatic biodiversity in the Kamuzu Dam II and river systems. Increased sedimentation of aquatic systems could potentially affect macroinvertebrate communities, decrease photosynthesis and impact fish populations.

• Decrease in surface water run-off: The construction of Project infrastructure components such as open pits, processing plants, WRDs and the TSF will require the separation of clean and dirty surface water run-off through the diversion of stormwater from these areas. Diversion of stormwater may result in changes to surface water availability in areas in close proximity to the Project.

• Deterioration in surface water quality: Wastewater and surface water run-off from the Project may contain various potential pollutants, including hydrocarbons, chemicals, acid mine drainage (AMD) and other dissolved contaminants, that could impact water quality in dambos, the Kamuzu Dam and Lilongwe River.

• Groundwater inflow into open pits: Excavation of the mining pits to 25 m deep will lead to groundwater flowing towards and into the pit area and could affect the flow of recharge water

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into the aquifers. In the event that mining pits are left as open voids upon closure, the recovery of groundwater to original levels would result in these pits filling with water.

• Impact on aquifers through pit dewatering: Dewatering of the pits is likely to result in reversed groundwater gradients and reduced discharge into streams and rivers. Dewatering may also reduce groundwater levels some distance away from the Project area, resulting in decreased availability of water for local communities who are dependent on shallow groundwater wells.

• Deterioration in groundwater quality: Contamination of groundwater could result from seepage from the mine infrastructure and waste materials, i.e., TSF and WRD. In addition, accidental spills and leaks of hydrocarbons and reagents used in processing could leach into the groundwater.

• Creation of AMD: Excavation of ore, stockpiling of ore and disposal of waste rock and tailings may lead to the generation of AMD, although this is not considered likely to be a significant issue. The generation of AMD could degrade the quality of soil and surface and groundwater sources. In addition, non-acid leaching of metals and salts may occur, resulting in neutral and/or saline runoff discharges.

• Deterioration in air quality: Mining activities are likely to result in dust generation that could impact nearby communities, particularly to the west of the Project. Vehicle movement along access roads are also likely to contribute to dust generation. Power generation through the use of diesel generators are likely to contribute to an increase in gaseous emissions and greenhouse gases.

• Increase in noise and vibration: Construction activities, the use of heavy vehicles and equipment and processing of ore could increase the level of noise at nearby communities and along the access road. Vibration from heavy vehicles travelling through local communities could impact houses and structures in close proximity to the road.

• Disturbance of cultural heritage resources: Land clearance may have irreversible impacts on the archaeological and cultural heritage sites within the Project area. Specifically, clearing of forest vegetation areas could result in the disturbance of ancestral graves.

• Impact from increase in vehicle traffic: Project activities will require the use of machinery and vehicles, which may pose a potential safety risk to other road users, particularly non-motorised vehicles and pedestrians and lead to increases in ambient noise, dust and illumination, and deteriorated road conditions and general amenity of the area.

• Change in visual landscape: Clearing of vegetation and construction of Project infrastructure is likely to change the visual character of the landscape and sense of place of the area.

• Land acquisition and resettlement: The Project may require the acquisition and development of lands that are currently used for residential and agricultural purposes. Adequate mitigation measures will be developed to minimise impacts on livelihoods and housing, food security, sanitation and health outcomes for affected residents. Land acquisition could also impact community infrastructure that exists within the Project footprint, including water resources and local roads.

• Population influx: The influx of non-locals could include those who take up Project employment, as well as those who come to the area in anticipation of economic opportunities. Influx can lead to informal settlements, increased demand for local community services, poor sanitation practices, and pressure on land and water resources. It could also impact on community well-being, with risks related to transmission of communicable disease (including sexually transmitted infections and respiratory infections), dilution of local norms and customs, and changes in way of life.

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• Rehabilitation of disturbed areas: In the event that open pits are not backfilled and left as voids, these will naturally fill with water from groundwater inflow upon closure. This will impact on land use post closure and may impact on community safety and well-being. A rehabilitation and closure plan will be developed as part of the ESIA, which will consider various options for closure.

6 Way Forward A number of Project-specific studies are required to accurately identify and assess important issues and potential impacts associated with the Project. The following studies will be undertaken as part of the ESIA phase and will focus on the Project area (Figure E.2), as well as the access route:

• Terrestrial flora and fauna. • Aquatic ecology. • Soils and land capability. • Surface water. • Groundwater. • Geochemistry (acid mine drainage). • Air quality and greenhouse gas. • Noise and vibration. • Visual impact assessment. • Social impact assessment. • Resettlement action plan. • Heritage and archaeology. • Health impact assessment. • Rehabilitation and closure plan.

For more details on the various studies refer to Section 7 of the ESR.

Stakeholder engagement will continue throughout the ESIA phase; and comments, issues and queries raised will inform the feasibility studies and be incorporated in the ESIA report. As part of the social impact assessment and data collection for the resettlement action plan, consultation will be undertaken at household level. This consultation will commence in late April 2018. The detailed ESIA phase and all specialist studies are expected to be completed by September 2018.

The main objectives of the ESIA are to identify and assess likely environmental and social impacts; propose appropriate mitigation and management measures, as well as measures to enhance Project benefits; and develop monitoring protocols. Specifically, the ESIA will:

• Define the existing social, cultural, economic and environmental conditions within the Project area.

• Review feasible Project alternatives. • Ensure social and environmental considerations and potential impacts are explicitly

addressed and incorporated into the Project design and implementation process. • Assess the potential environmental and social impacts associated with the Project. • Identify mitigation measures that are both practical and feasible to avoid or minimise the

potential impacts of the Project, and to enhance the beneficial outcomes of the Project for the communities within the area.

• Identify relevant monitoring protocols to ensure the mitigation and management measures are implemented effectively.

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A draft ESIA Report will be compiled and made available for review and comments by stakeholders during the fourth quarter of 2018. Stakeholders will be informed of the availability of all relevant document and reports throughout the ESIA process.

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Table of Contents EXECUTIVE SUMMARY .......................................................................................................................... i 1 Introduction ....................................................................................................................................... 1

1.1 Project Overview ......................................................................................................................... 1 1.2 Global Graphite Demand ............................................................................................................ 1 1.3 ESIA Approach and Objectives .................................................................................................. 4 1.4 Scoping Team ............................................................................................................................. 6 1.5 Structure of this Report ............................................................................................................... 7

2 Detailed Project Description ............................................................................................................. 8 2.1 Introduction ................................................................................................................................. 8 2.2 Resource ..................................................................................................................................... 8 2.3 Conceptual Layout and Project Components ............................................................................. 9 2.4 Mining Method .......................................................................................................................... 10 2.5 Processing ................................................................................................................................ 12 2.6 Waste Rock and TSF ................................................................................................................ 14 2.7 Transport and Logistics ............................................................................................................ 14

3 Policy, Legal and Administrative Framework ................................................................................. 15 3.1 Introduction ............................................................................................................................... 15 3.2 Republic of Malawi Policies and Frameworks .......................................................................... 15 3.3 Republic of Malawi Principal Acts and Legislation ................................................................... 18 3.4 Other Relevant Legislation, Standards and Guidelines............................................................ 25 3.5 International Agreements .......................................................................................................... 25 3.6 International Standards and Guidelines ................................................................................... 26

4 Environmental Setting..................................................................................................................... 32 4.1 Topography ............................................................................................................................... 32 4.2 Climate ...................................................................................................................................... 32 4.3 Seismicity Potential ................................................................................................................... 34 4.4 Geology ..................................................................................................................................... 37 4.5 Soils and Land Capability ......................................................................................................... 37 4.6 Flora .......................................................................................................................................... 38 4.7 Fauna ........................................................................................................................................ 44 4.8 Wetlands ................................................................................................................................... 45 4.9 Aquatic Biology ......................................................................................................................... 49 4.10 Hydrology.............................................................................................................................. 54 4.11 Hydrogeology ....................................................................................................................... 60 4.12 Social Environment............................................................................................................... 64 4.13 Archaeology and Cultural Heritage ...................................................................................... 66

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5 Stakeholder Engagement ............................................................................................................... 69 5.1 Purpose of Stakeholder Engagement ....................................................................................... 69 5.2 Objectives ................................................................................................................................. 69 5.3 Stakeholder Engagement during the Scoping Phase............................................................... 70 5.4 Issues Raised to Date ............................................................................................................... 74

6 Preliminary Identification of Key Issues .......................................................................................... 76 6.1 Soils and Land Capability ......................................................................................................... 76 6.2 Terrestrial Biodiversity .............................................................................................................. 76 6.3 Wetlands ................................................................................................................................... 77 6.4 Aquatic Ecology ........................................................................................................................ 78 6.5 Geochemistry ............................................................................................................................ 78 6.6 Hydrology .................................................................................................................................. 78 6.7 Hydrogeology ............................................................................................................................ 79 6.8 Air Quality.................................................................................................................................. 79 6.9 Noise and Vibration................................................................................................................... 79 6.10 Archaeology and Cultural Heritage ...................................................................................... 79 6.11 Visual Impact ........................................................................................................................ 80 6.12 Social Impacts ...................................................................................................................... 80 6.13 Health Impacts ...................................................................................................................... 81 6.14 Rehabilitation and Closure ................................................................................................... 81

7 Terms of Reference for ESIA Phase .............................................................................................. 83 7.1 Stakeholder Consultation .......................................................................................................... 83 7.2 Terrestrial Ecology – Flora and Vegetation .............................................................................. 83 7.3 Wetlands ................................................................................................................................... 84 7.4 Soils and Land Capability ......................................................................................................... 85 7.5 Geochemistry ............................................................................................................................ 86 7.6 Water......................................................................................................................................... 87 7.7 Air Quality.................................................................................................................................. 88 7.8 Noise and Vibration................................................................................................................... 88 7.9 Health Impact Assessment ....................................................................................................... 88 7.10 Visual Impact Assessment ................................................................................................... 89 7.11 Social Impact Assessment ................................................................................................... 89 7.12 Resettlement Action Plan ..................................................................................................... 90 7.13 Archaeology and Cultural Heritage ...................................................................................... 91

8 Summary and Conclusion .............................................................................................................. 93 9 References ..................................................................................................................................... 95

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List of Figures Figure 1.1: Malingunde Project Location and Prospecting Licence Area ................................................ 3

Figure 1.2: Approach to the ESIA Process .............................................................................................. 5

Figure 2.1: Conceptual Layout of the Malingunde Project .................................................................... 11

Figure 2.2: Conceptual Process Flow Diagram ..................................................................................... 13

Figure 4.1: Average Monthly Rainfall in the Project Area ...................................................................... 33

Figure 4.2: Average Monthly Temperatures in the Project Area ........................................................... 34

Figure 4.3: Seismicity Inducing Faults Around Lake Malawi (Amec Foster Wheeler, 2017) ................ 35

Figure 4.4: Vegetation Communities Recorded in the Project Area ...................................................... 40

Figure 4.5: Wetlands in and around the Project Area ........................................................................... 47

Figure 4.6: Location of Aquatic Biomonitoring Sites .............................................................................. 50

Figure 4.7: Regional Catchment Areas: Linthipe WRA and Lilongwe WRU ......................................... 55

Figure 4.8: Sub-catchments in the Project Area .................................................................................... 56

Figure 4.9: Surface and Groundwater Monitoring Locations ................................................................. 59

List of Tables Table 1.1: Environmental Scoping Phase Team ..................................................................................... 7

Table 2.1: Malingunde Mineral Resource Estimate (April 2017) ............................................................. 9

Table 4.1: Richter Scale, Approximate Acceleration and Mercalli Equivalent ...................................... 36

Table 4.2: Vegetation Communities Identified in the Project Area ........................................................ 38

Table 4.3: Classification of Present Ecological State Classes in Terms of General Habitat Integrity (Kemper, 1999) ............................................................................................................................... 49

Table 4.4: IHIA Results for the Wet Season (High Flow Conditions) in April 2017 ............................... 51

Table 4.5: Integrated Habitat Assessment System (IHAS) Results for the High Flow Season ............ 51

Table 4.6: Reference Conditions for Sandy and Rocky River Systems-based ASPT Scores (Tambala et al., 2016) ..................................................................................................................................... 52

Table 4.7: SASS5 Results for the Wet (High Flow) Season in April 2017 ............................................ 53

Table 4.8: Laboratory Results of Analysis of Surface Water Quality Samples ..................................... 57

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Table 4.9: Results of Laboratory Analysis of Groundwater Samples .................................................... 61

Table 5.1: Categories of Stakeholder Groups Identified during the Scoping Phase ............................. 70

Table 5.2: List of Project Announcement Meetings ............................................................................... 71

Table 5.3: List of Environmental Scoping Meetings .............................................................................. 72

List of Plates Plate 4.1: Example of a Dambo to the North of the Project Area .......................................................... 41

Plate 4.2: An Example of Mixed Riparian Vegetation ............................................................................ 42

Plate 4.3: An Example of the Forest Fragments in the Project Area ..................................................... 43

Appendices Appendix A: Flora Species Recorded

Appendix B: Fauna Species Recorded

Appendix C: List of Stakeholders Consulted

Appendix D: Background Information Document

Appendix E: Attendance Registers of Announcement Meetings (December 2017)

Appendix F: Newspaper Advertisements

Appendix G: Grievance Mechanism

Appendix H: Comments and Responses Report

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Units and Symbols m3 cubic metre

degrees

°C degrees Celsius

% per cent

ha hectare

km kilometre

km2 square kilometre

m metre

mbsl metres below surface level

µm micrometre

mm millimetre

m3 cubic metre

Mm3 million cubic metres

Mt million tonne

t tonne

t/m3 tonnes per cubic metre

Terms and Abbreviations ADC Area development committee

ASPT Average score per taxon

attritioning High intensity mechanical agitation of a slurry to clean and prepare mineral surfaces for flotation or other processes.

CBO Community-based organisation

CEDAW Convention on the Elimination of all Forms of Discrimination Against Women

CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora

dambo Seasonally waterlogged, predominantly grass covered, shallow depressions (wetlands) bordering headwater drainage lines.

DFS Definitive feasibility study

EAD Environmental Affairs Department

EIS Ecological importance and sensitivity

EMA Environment Management Act (No. 19 of 2017)

EPFI Equator Principles Financial Institution

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EPL Exclusive prospecting licence

ESIA Environmental and social impact assessment

ESMS Environmental and social management system

ESMP Environmental and social management plan

ESR Environmental scoping report

FEL Front end loaders

GIIP Good international industry practice

G.N. Government Notice

HIV/AIDS Human Immunodeficiency Virus/Acquired Immune Deficiency Syndrome

I&APs Interested and affected parties

IFC International Finance Corporation

IHAS Integrated Habitat Assessment System

IHIA Intermediate Habitat Integrity Assessment

ITCZ Inter-Tropical Convergence Zone

IUCN International Union for Conservation of Nature and Natural Resources

JORC Joint Ore Reserves Committee

LOM Life-of-mine

mamsl Metres above mean sea level

mbsl Metres below surface level

MCE Maximum credible earthquake

MDE Maximum design earthquake

MRE Mineral resource estimate

MS Malawi Standard

NEAP National Environmental Action Plan

NEP National Environmental Policy

NGO Non-government organisation

OP Operational Policy

PES Present ecological status

PFS Pre-feasibility study

PGA Peak ground acceleration

refractory Any material that has an unusually high melting point and that maintains its structural properties at very high temperatures

RoM Run-of-mine

RWG Resettlement working group

SADC Southern African Development Community

SARCOF Southern African Regional Climate Outlook Forum

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SASS5 South African Scoring System Version 5

TA Traditional authority

TDS Total dissolved solids

TGC Total graphitic carbon

ToR Terms of reference

TSF Tailings storage facility

UNESCO United Nations Educational, Scientific and Cultural Organisation

VDC Village development committee

V:H Slope gradient - described as vertical rise (V) to horizontal run (H)

WBG World Bank Group

WRA Water resource area

WRD Waste rock dump

WRU Water resource unit

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1 Introduction

1.1 Project Overview

Sovereign Metals Limited (Sovereign) is an Australian publicly listed company that trades on the Australian Securities Exchange (ASX) under the code ASX:SVM. Sovereign is engaged in exploration and appraisal of resource projects, with the main focus being its 100% owned Malingunde Graphite Project (the Project), which is a large high-grade saprolite-hosted flake graphite deposit on the Lilongwe plain.

McCourt Mining Pty Ltd (McCourt Mining) is a wholly owned subsidiary of Sovereign and was acquired by Sovereign in September 2012. McCourt Mining is the licence holder of the exclusive prospecting licence (EPL), EPL0372, in which the Project is located (Figure 1.1).

The Project is located at Malingunde, approximately 15 kilometre (km) southwest of Malawi's capital city of Lilongwe, and falls within the Lilongwe District of the Central Administrative Region (Figure 1.1). Access to the Project from Lilongwe is via the sealed section of the secondary road, S124, to Likuni and then the unsealed continuation of the S124 to the Kamuzu Dam turn-off. The Project area is located in close proximity to the villages of Kumalindi and Ndumila, directly north of Kamuzu Dam II. Access around the Project site is via a network of unsealed village tracks. The Project site is approximately 25 km from operating rail, 20 km from a major power sub-station and in close proximity to potential water sources.

Sovereign is currently conducting a number of technical studies, which will culminate in a feasibility study, to determine the financial viability of developing a mine at Malingunde. An economic scoping study for the Project was completed in mid-2017. The results of this study demonstrate that the Project has the potential to be developed as a low capital and operating cost operation, with annual graphite concentrate production of approximately 44,000 tonnes (t) over an initial life-of-mine (LOM) of 17 years. Sovereign is now moving into the next phase of Project development activities, with an aim to bringing the Project into construction in 2019. The study was based on the maiden mineral resource estimate (MRE) for the Malingunde deposit reported in April 2017, which comprises 28.8 million tonnes (Mt) @ 7.1% total graphitic carbon (TGC). The MRE includes a high-grade saprolite component of 8.9 Mt @ 9.9% (7.5% TGC cut-off) which was the focus of the study.

The production target generated by the study is approximately 8.0 Mt @ 10.0% TGC over the LOM.

Sovereign is currently still engaged in exploration, and as part of the feasibility studies, commenced a pre-feasibility study (PFS) in late 2017 which is scheduled for completion in June 2018.

If the results of the PFS are favourable, it is expected the company will be able to commence a definitive feasibility study (DFS) in the second half of 2018 which would likely be completed in the first quarter of 2019. Should the feasibility studies prove that mining is viable, and a decision is taken by Sovereign during early 2019 to proceed with the development of the mine, an application for a mining licence will be submitted to the Department of Mines.

1.2 Global Graphite Demand

Flake (or crystalline) graphite is the term for a form of carbon with a layered structure of particles which have a flat and thin morphology and graphitisation of between 95–100%.

The primary end-market for flake graphite is the refractory, foundries and crucible sector which consumed approximately 616,000 t of flake graphite production in 2016. The refractory industry is the


volume driver for flake graphite, with foundries and crucibles offering smaller markets for higher purity graphite products. The majority of flake graphite production is consumed by magnesia-carbon bricks, a mainstream, global refractory brick used in the steel industry.

The battery sector is the main emerging market for flake graphite. Spherical graphite required in many lithium-ion batteries and the need for greater capacity batteries, such as the ones required for electric vehicles, are expected to drive significant demand from this sector over the coming years.


Figure 1.1: Malingunde Project Location and Prospecting Licence Area


1.3 ESIA Approach and Objectives The Environment Management Act (EMA), No. 19 of 2017 provides the legal framework for protection and management of the environment of Malawi, as well the preparation of environmental and social impact assessment (ESIAs) for prescribed projects.

Section 2(f) of the EMA states that an ESIA is a legal requirement for any project that may significantly affect the environment and use of natural resources. The general principles also state that precautionary measures must be taken to prevent or mitigate possible deleterious environmental effects of any project, even where scientific evidence is not certain.

In 1997, the Environmental Affairs Department (EAD) published the Guidelines of Environmental Impact Assessment for Malawi. The purpose of the guidelines is to integrate environmental concerns in national development, and are applicable to all types of projects in the public and private sectors for which ESIA studies may be required, as identified in the lists of prescribed projects (List A and List B) appended to the guidelines. List A identifies projects for which an ESIA is mandatory, and includes mining of minerals, expansions to mines, mining exploration activities, minerals prospecting activities, quarries, gravel pits and removal of sand or gravel from shore lines. The Project falls under this prescribed list of activities, and as such McCourt has commenced an ESIA process. McCourt Mining will be the applicant for the applicable environmental authorisation as per the requirements of the EMA.

The ESIA process is generally undertaken in three distinct phases, namely the Project Brief, Environmental Scoping and ESIA Phases.

A Project Brief was submitted to the EAD on 12 June 2017 to initiate the ESIA process for the Project. The EAD has indicated that, based on the nature and scale of the activities, an ESIA is required to be undertaken and an ESIA Report submitted, which must be compliant with the Guidelines of Environmental Impact Assessment.

All initial surveys and consultation as part of the environmental scoping phase will be completed by April 2018. The detailed ESIA phase and all specialist studies are expected to be completed by September 2018. This phased approach and the key components are indicated in Figure 1.2.

This ESIA process for the Project will also take cognisance of other relevant Malawian legislation, policies and standards. In the absence of specific guidelines and standards under Malawi legislation, good international industry practice (GIIP) will be adhered to, and where relevant, international guidelines and standards applied, such as the International Finance Corporation (IFC) Performance Standards on Environmental and Social Sustainability (IFC, 2012) and the World Bank Group Environmental, Health and Safety Guidelines (WBG, 2007).

As McCourt Mining may require funding from international lenders, the ESIA process and documentation would also need to comply with the requirements of the Equator Principles (Equator Principles Association, 2013).


Figure 1.2: Approach to the ESIA Process

1.3.1 Scoping Phase Objectives

The main aim of the environmental scoping phase is to identify potential environmental and social issues that require detailed investigation and assessment by a range of specialists in the ESIA phase, as well as develop the terms of reference (ToR) for undertaking these investigations.

A key component of the scoping phase is the engagement of stakeholders in an attempt to provide them with Project information and identify issues and concerns of importance to them. The process is therefore highly consultative by nature.

The specific objectives of the scoping phase are to:

• Provide opportunity for all key Project stakeholders i.e., the relevant authorities, stakeholder groups and community members in the Project area to exchange information and express their views and concerns regarding the Project.

• Identify key issues and concerns that require further assessment during the ESIA phase.


• Determine the ToR for a variety of specialist studies to be undertaken. • Determining the extent of, and approach to, the ESIA.

This draft environmental scoping report (ESR) provides a description of the proposed Project; information on the existing biophysical and social environment; identifies potential environmental and social issues that require detailed investigation and assessment in the ESIA; and ToR for the required specialist studies. Comments received on this report as part of the public review period will be incorporated in the final ESR, prior to submission to the EAD.

1.3.2 ESIA Phase Objectives

The main objectives of the ESIA are to identify and assess likely environmental and social impacts; propose appropriate mitigation and management measures, as well as measures to enhance Project benefits; and develop monitoring protocols. Specifically, the ESIA will:

• Define the existing social, cultural, economic and environmental conditions within the Project area.

• Review feasible Project alternatives. • Ensure social and environmental considerations and potential impacts are explicitly

addressed and incorporated into the Project design and implementation process. • Assess the potential environmental and social impacts associated with the Project. • Identify mitigation measures that are both practical and feasible to avoid or minimise the

potential impacts of the Project, and to enhance the beneficial outcomes of the Project for the communities within the area.

• Identify relevant monitoring protocols to ensure the mitigation and management measures are implemented effectively.

1.4 Scoping Team Sovereign has appointed a team of local and international environmental specialists to conduct the ESIA process and oversee the various specialist inputs. Dhamana Consulting (an environmental consulting firm based in Australia) will coordinate the compilation of the various environmental reports and ESIA process, and will be assisted by C12 Consultants (a Malawian environmental consulting firm) and AECOM (South Africa).

Several specialists were appointed to conduct surveys during the scoping phase, with the aim of gaining an understanding of the environmental and social characteristics of the area in which the Project is located. Data collection and surveys were undertaken relating to flora, terrestrial fauna, aquatic biology, wetlands, surface and groundwater quality, air quality, archaeology and cultural heritage, and socio-economic aspects. Additional surveys and assessments will be carried out during the ESIA phase to obtain a thorough understanding of the environmental setting and enable the specialists to undertake an assessment of the potential environmental impacts associated with the Project.

The team involved in the environmental scoping phase is detailed in Table 1.1.


Table 1.1: Environmental Scoping Phase Team

Name Company Area of Specialisation

Nanette Hattingh Dhamana Consulting ESIA Manager

Akeel Hajat C12 Consultants ESIA Report Review and Advisor

Chaitali Mukherjee C12 Consultants ESIA Report Review

Karien Lötter AECOM Social Impact Assessment and Resettlement Action Plan

Anelle Lötter AECOM Stakeholder Consultation

David Mussa C12 Consultants Stakeholder Consultation

Arthur Kambombe C12 Consultants Stakeholder Consultation

Adrian Hudson Hudson Ecology Terrestrial Biodiversity

Sandra Carminati GCS Pty Ltd Aquatic Biology

Dr. Matthew Ojelede Digby Wells Environmental Air Quality and Greenhouse Gas

Erick Dorfling GCS Pty Ltd Surface and Groundwater Quality

Daniel Fundisi GCS Pty Ltd Hydrology

Chrissy Chiumia Malawi Department of Antiquities Archaeology

Oris Chapinga Malijani Malawi Department of Antiquities Cultural Heritage

Wouter Fourie PGS Heritage Archaeology and Cultural Heritage

Marko Hutten PGS Heritage Archaeology

Paul Klimczak SLR Consulting Hydrology and Surface Water

Mihai Muresan SLR Consulting Hydrogeology and Groundwater

1.5 Structure of this Report

This report is presented in eight sections containing the following information:

• Section 1: Introduction, overview of the Project and objectives of the environmental scoping study.

• Section 2: Provides a brief description of the resource, Project layout and infrastructure components, mining method and ore processing method.

• Section 3: Provides a summary of the governing policies and legislation. • Section 4: Provides a description of prevailing environmental and social conditions based on

existing data available, and the initial desktop reviews and surveys by various specialists. • Section 5: Presents an overview of stakeholder engagement process and activities

undertaken to date, as well as a summary of key issues and concerns raised by stakeholders. • Section 6: Details issues identified during environmental scoping phase which will require

further investigation and assessment as part of the ESIA. • Section 7: Presents the proposed ToR for the various specialist studies. • Section 8: Provides a summary of the findings of this ESR.


2 Detailed Project Description

2.1 Introduction

In 2015, McCourt’s in-country geological team made a new and significant graphite discovery at Malingunde using hand auger drilling techniques in an area of no outcrop.

The Project is currently at the advanced exploration stage, with a maiden Joint Ore Reserves Committee (JORC)2 MRE completed on 18 April 2017.

An initial Scoping Study (preliminary economic assessment) was completed in June 2017. The Scoping Study considered a scenario that was based on mining approximately 475,000 t of ore to produce about 44,000 t of graphite concentrate per annum. Feasibility studies to evaluate the technical and economic feasibility of a commercial mining operation at Malingunde have commenced, however a decision to proceed with mine development has not yet been made and is not expected to be made until 2019, subject to a number of factors.

Sovereign is targeting a very simple mining and processing operation, selling reasonable volumes of very high-quality graphite concentrates into existing markets. Sovereign is not actively considering the construction and operation of highly technically challenging and expensive downstream processing operations, such as a spherical graphite plant.

2.2 Resource

CSA Global Pty Ltd was engaged by Sovereign to prepare a MRE for the Malingunde flake graphite deposit. The MRE is reported in accordance with the 2012 Edition of the JORC Code and is tabulated in Table 2.1.

The JORC 2012 compliant MRE shows 28.8 million tonnes (Mt) @ 7.1% total graphitic carbon (TGC). Production will target the higher-grade core of the resource, with an initial production target over the LOM of 8.0 Mt @ 10.0% TGC. This will produce approximately 44,000 t of graphite concentrate over a 17 year mine life.

2 The Australasian Code for Reporting of Exploration Results, Mineral Resources and Ore Reserves (‘the JORC Code’) is a professional code of practice that sets minimum standards for Public Reporting of Minerals Exploration Results, Mineral Resources and Ore Reserves.


Table 2.1: Malingunde Mineral Resource Estimate (April 2017)

Malingunde Mineral Resource Estimate (4.0% Cut-off Grade)

Indicated Inferred Total

Tonnes (Mt)

Grade (% TGC) Tonnes (Mt) Grade

(% TGC) Tonnes (Mt) Grade (% TGC)

Saprolite 23.0 7.1 5.7 7.3 28.8 7.1

Saprock 12.8 7.0 4.2 7.1 17.0 7.0

Fresh Rock - - 19.3 7.0 19.3 7.0

Total 35.9 7.0 29.2 7.1 65.1 7.1

Malingunde Mineral Resource Estimate

(7.5% Cut-off Grade)

Indicated Inferred Total

Tonnes (Mt)

Grade (% TGC) Tonnes (Mt) Grade

(% TGC) Tonnes (Mt) Grade (% TGC)

Saprolite 7.1 9.6 1.8 10.8 8.9 9.9

Saprock 3.8 9.4 1.2 10.0 5.0 9.5

Fresh Rock - - 5.7 9.6 5.7 9.6

Total 10.9 9.5 8.6 9.9 19.5 9.7

2.3 Conceptual Layout and Project Components

The current conceptual mine layout, with alternative locations for certain infrastructure components, is as depicted in Figure 2.1. Notable features of the conceptual mine layout include:

• A number of long, shallow open pits, trending in a northwest–southeast direction. • A waste rock dump (WRD) and tailings storage facility (TSF). • An ore processing plant using simple processing is anticipated with the use of an upfront

scrubber to disaggregate the graphite flakes from the host material (as opposed to a jaw crusher and rod mill used in hard-rock operations) followed by standard rougher flotation, polishing grind, cleaner flotation stages and a final attritioning and cleaner flotation stage.

• Site roads providing access to the pit, processing plant and administration buildings. • Raw water storage dam, process water storage dam, site water management infrastructure and

dirty water storage dams. • Workshop to service and maintain mining fleet and equipment. • Diesel fuel storage and filling stations for mine fleet and light vehicles. • Administration buildings, offices, ablution facilities and crib rooms.

Some of the graphite mineralisation and hence some of the proposed open pits lie within the watershed of the Kamuzu Dam II. The Project area is approximately 1-2% of the watershed of the Kamuzu Dam II. However, the northwest part of the deposit lies outside of the watershed for the Kamuzu Dam II (refer Section 4.10 and Figure 4.8). The option of locating the TSF, processing plant, workshops and other infrastructure to the northern extent of the Project area outside of the Kamuzu Dam II watershed to minimise potential contamination issues, however unlikely these issues may be,


is being evaluated.

A number of technical studies are being undertaken to determine the optimal layout of infrastructure. The Project area indicated in Figure 2.1 is likely to reduce significantly once the optimal layout has been determined. The preferred layout will be detailed in the ESIA report.

2.4 Mining Method

Open pit mining with traditional excavator and haul trucks will be used to mine ore. Mining will be free-dig in nature and no drilling and blasting activities will be required for the operation as the material is relatively soft. Mining will be undertaken in a number of long, shallow open pits, with maximum depths of 25 m and maximum widths of approximately 200 m. The base of these open pits will be above the level of the Kamuzu Dam. The Project overall has a very low strip ratio of 0.5:1 (waste:ore).

Loading will be undertaken by a combination of front end loaders (FEL) and excavators. Ore will be loaded on to articulated dump trucks with a payload capacity of 40 t and hauled from the pit to the run-of-mine (ROM) pad and processing plant. This type of equipment is common among mining contractors in Africa and suits the required production capacities planned for the Project.

Various options for the mining sequence are being considered, taking into account TGC grade and material characteristics.


Figure 2.1: Conceptual Layout of the Malingunde Project


2.5 Processing

A physical separation process will be used to produce the graphite concentrates. The process involves upgrading the saprolite ore from ~10% TGC to a grade of ~97% TGC. Processing of ore will include the following:

• Washing and disaggregating the soft saprolite with a scrubber. • Rougher flotation. • Polishing grind. • Cleaner flotation. • Attrittioning. • Drying. • Bagging.

The process is depicted in the conceptual flow diagram in Figure 2.2.

The mined ore will be fed by FEL to a run-of-mine (RoM) feed bin. Ore will be withdrawn from the bin at a controlled feed rate by means of a belt feeder equipped with a weightometer. A transfer conveyor will convey the ore to a rotary scrubber. The scrubber is fitted with a 3 millimetre (mm) aperture trommel screen. Oversize material is conveyed to a dump for removal by FEL and truck.

Scrubber undersize is pumped to the rougher flotation section. This will consist of a conditioning tank and 5 x 10 m3 trough flotation cells. Trough cells have been chosen for ease of operation and to allow the use of froth paddles as initial flotation rates can be high. Diesel collector and Glycol F-549 frother will be added. Rougher tailings will be pumped to the tailings thickener.

Chemicals used in the process are limited to a small amount (150-200 g/t of ore) of diesel and frother which aids in the rougher and cleaner flotation stages. The reagents end up with the graphite concentrate and is then evaporated when the concentrate goes through the drying stage. Hence, there are no anticipated added chemicals that would end up in the TSF or within any other parts of the site. Preliminary test work to date has indicated that the concentration of chemicals are below the IFC EHS Guidelines for Mining Effluent (2007), and in fact generally meet the World Health Organisation Guidelines for drinking water (2011).

Rougher concentrate, expected to be approximately 20% of the feed mass, will be scrubbed in a stirred mill. The concentrate will then undergo cleaner flotation. This section will consist of a conditioning tank and 4 x 3 m3 trough flotation cells. Cleaner tailings will be pumped to the tailings thickener.

Cleaner concentrate will be screened to split the process into a fines and coarse circuit. The screening will target a cut size of 150 micrometre (µm) (100 mesh).

The -150 µm (-100 mesh) fraction will be at a low density, approximately 9% solids. It will be thickened for attritioning, although it is not expected that the optimum of 70% solids will be attainable. The +150 µm (+100 mesh) fraction will have been de-watered by the screen and additional water will be added to the attritioner feed to obtain the optimum density.


Figure 2.2: Conceptual Process Flow Diagram

Each of the streams, +150 µm (+100 mesh) and -150 µm (-100 mesh), will be treated individually in similar attritioning and flotation sections. A section will consist of a single attritioning unit followed by 6 x 0.5 m3 trough flotation cells. The cells will be configured as three re-cleaning stages, in which the concentrate from each group of two cells will be re-treated in the following two. Tailings will be recycled to previous stages of cleaning.

The final concentrate from the +150 µm (+100 mesh) and -150 µm (-100 mesh) streams will be combined, thickened, and filtered in a filter press. The filtered concentrate will be dried using a diesel-fired, rotary dryer. Dried product will be screened and bagged for dispatch and sale.

Water from the tailings thickener will be recycled. Thickener underflow will be pumped to a tailings storage facility.

The following plant services have been allowed for in the conceptual process design:

• Reagent make-up and dosing systems for diesel, Glycol F-549 frother and flocculant. • Air compressors to instrument air standard. • Water storage and distribution for potable, process, spray and pump gland service systems. • Plant mobile equipment including a forklift, telescopic boom handler and light delivery vehicles

(LDVs).

Current modelling indicates the operation will also require a net additional water of approximately 0.25 Mm3 (250 ML) per annum for processing and other requirements. It is the intention to source some of this water requirement from the Kamuzu Dam II, but this will be subject to negotiation and agreement with the Lilongwe Water Board. The storage of Kamuzu Dam I and II is 24.3 Mm3, and the


requirement of the Project represents less than 1% of the total storage capacity.

2.6 Waste Rock and TSF

Waste rock generated from the open pit mining activities will be used for the construction of the starter embankment of the TSF, as well as successive raises to the embankment to achieve LOM deposition capacity.

All waste rock will either be transported to the TSF site for use in embankment construction or to a nearby WRD. An opportunity exists for waste dumping in previously exhausted pits and this will be investigated further as part of the PFS.

The TSF for the project has been designed to contain a volume of approximately 7.3 Mt of tailings of the LOM at a deposition rate of approximately 450,000 t per annum. The characteristics of the tailings produced have not been confirmed, and therefore a conservative approach to the achieved deposited density has been adopted assuming a final settled density of 1.15 t/m3, thus resulting in a total required deposition volume of some 6.35 Mm3 for a LOM of 17 years.

Based on information from test work to date on the potential quality of the tailings and supernatant water from process requirements, a compacted clay liner has been assumed for the TSF and will be investigated as part of the PFS. It has been noted that the majority of material to be placed in the TSF, is clay-rich, ranging from approximately 20-40% clay by volume.

The embankment walls will be constructed with upstream and downstream slopes of 1V:2H to an elevation of 1,151 metres above mean sea level (mamsl). Beyond the 1,151 mamsl elevation and to the final elevation of 1,158 mamsl, slopes on the embankment will be constructed to slopes of 1V:2.5H.

2.7 Transport and Logistics

Product from the operations will be bagged and transported on flatbed trucks by road to the Kanengo rail head in Lilongwe – a distance of approximately 26 km – to be packed into standard shipping containers and railed directly into vessel stacks at the port of Nacala in Mozambique.

It is proposed that product will be transported from the Project site along the existing S124, which runs through the villages of Kumalindi and Likuni. Just west of Lilongwe, vehicles will turn in a northerly direction and follow the existing Lilongwe Western Bypass Road. The route follows the existing road to the intersection of the S122, and vehicles will then turn in an easterly direction onto the S122 and travel along this road to Kanengo.


3 Policy, Legal and Administrative Framework

3.1 Introduction The activities associated with planning, pre-construction preparations, construction, operation and decommissioning of the Project are governed by a range of Malawian Acts and regulations, with the aim of protecting the environment and communities in close proximity to the Project.

Given the location of the Project activities, the Project will need to comply with legislation relevant to the management of land, water, forestry, mining, health, biodiversity, air quality and social issues.

Sovereign and McCourt Mining is committed to undertake all Project activities in full compliance with Malawian legislation, as well as any obligations under international conventions and treaties which Malawi has entered into.

This section provides a summary of the relevant policies, legal and administrative frameworks that govern the environmental and social issues pertaining to the planning and implementation of the Project.

3.2 Republic of Malawi Policies and Frameworks

3.2.1 The Constitution of the Republic of Malawi, 1994

The Constitution of the Republic of Malawi, 1994 and as amended, along with national laws and regulations forms the basis of legislative requirements for development of large scale projects such as the Malingunde Graphite Project.

The Constitution contains principles of national policy in section 13, including that of sustainable development of environmental resources. The section sets out a broad framework for sustainable environmental management at various levels in Malawi. Section 13 provides that the State shall actively promote the welfare and development of the people of Malawi by progressively adopting and implementing policies and legislation aimed at managing the environment responsibly in order to, under section 13(d):

a) Prevent the degradation of the environment;

b) Provide a healthy living and working environment for the people of Malawi;

c) Accord full recognition to the rights of future generations by means of environmental protection and the sustainable development of natural resources; and

d) Conserve and enhance the biological diversity of Malawi.

The Constitution provides a framework for the integration of environmental considerations into development programs. The implication of this provision is that development programs and projects are undertaken in an environmentally responsible and sustainable manner.

In line with the principles set out in section 12 of the Constitution, public participation and consultation is encouraged. This principle is based on the presumption that, while organised society delegates its affairs to public institutions, the public retain the right to have an input in decision making and enforcement processes, and to expect, as a minimum, transparency in government decision making.

Further, the Constitution in section 146 establishes local government authorities to represent the people over whom they have authority, and to be responsible for their welfare, and gives them the


responsibility of, among other things, promoting infrastructural and economic development, through the formulation and execution of local government plans. Consultation at local government level will be required as part of the ESIA.

3.2.2 National Environmental Policy

The National Environmental Policy (NEP), 1996 (amended in 2004) provides a broad policy framework for environmental planning in development programmes and projects, including undertaking environmental impact assessments for prescribed projects. The overall goal of the NEP is the promotion of sustainable social and economic development through the sound management of the environment and natural resources in Malawi. The policy seeks to meet the following goals:

• Ensure environmental security to support the health and well-being for all people in Malawi, now and in the future.

• Promote sustainable utilisation and management of the country’s natural resources and encourage, where appropriate, long-term self-sufficiency in food, fuel wood and other energy requirements.

• Facilitate the restoration, maintenance and enhancement of the ecosystems and ecological processes essential for the functioning of the biosphere and prudent use of renewable resources.

• Integrate sustainable environment and natural resources management into decentralised governance systems.

• Promote participation by local communities, non-government organisations (NGOs) and the private sector in environment and natural resources management.

• Promote the use and application of local knowledge and norms that facilitate sustainable environment and natural resources management.

The policy promotes the rights of every person to a clean environment, and a duty to maintain and enhance the environment.

The policy recognises the need for ESIAs to ensure that development options or projects are environmentally sound and sustainable, and that the environmental consequences are identified early and taken into account in project design and implementation. ESIAs will consider not only biophysical impacts but also impacts related to social, health, economic, political and cultural aspects, as well as HIV/AIDS impact.

The NEP contains specific sectoral policies relating to sustainable water use, forestry, fisheries, wildlife and mining. It specifically states that stringent ESIAs will be required for all mining projects to ensure sustainable environment and natural resources management. The polluter pays and the precautionary principles must also be incorporated in the design, implementation and monitoring of mining projects.

3.2.3 National Land Policy, 2002

The National Land Policy of 2002 provides an institutional framework for democratising land management and outlines procedures for protecting land tenure rights, land-based investments and management of development at all levels.

The objectives of the policy include promotion of tenure reforms that guarantee security and instil confidence and fairness in land transactions e.g. compensation, promotion of a decentralised and transparent land administration and enhancement of conservation and community management of


land resources.

Section 9 of the policy deals with the protection of the environment and land resources and recognises the need for ESIA of large land development projects. This requirement is to integrate adequate environmental management plans and also to protect biodiversity and water resources.

3.2.4 National Water Policy, 2005

The overall goal of the National Water Policy is to ensure sustainable management and utilisation of water resources, in order to provide water of acceptable quality and of sufficient quantities. It further aims to ensure availability of efficient and effective water and sanitation services that satisfy the basic requirements of every Malawian and for the enhancement of the country’s natural ecosystems. The policy is based on the premise that all people shall have access to potable water and adequate sanitation services to reduce incidences of water related diseases.

Malawi’s policy on water resources management requires that:

• Water should be managed and used efficiently and effectively in order to promote its conservation and future availability in sufficient quantity and acceptable quality.

• All programs related to water should be implemented in a manner that mitigates environmental degradation and at the same time promotes the enjoyment of the asset by all.

The policy further addresses objectives for improving the efficiency and effectiveness of management of the quality of water resources.

3.2.5 National Forest Policy of Malawi, 2016

The policy promotes the conservation, establishment, protection and management of trees and forests for the sustainable development of Malawi.

Some of the key objectives of the policy are to:

• Provide an enabling framework for promoting the participation of local communities, the civil society and the private sector in forest conservation and management.

• Promote the growing of trees by all sections of the communities in order to achieve sustainable self-sufficiency of wood and forest derived products and services.

• Promote sustainable management of forests for the protection of the environment, conservation of biodiversity and climate change management.

3.2.6 National Environmental Action Plan (NEAP), 2004

The NEAP was prepared in 1994 in response to Agenda 21 that required signatories to the 1992 Rio Declaration to prepare an action plan for integrating environmental issues into socio-economic development programs. The NEAP was updated in 2004. The objectives of the NEAP are to:

• Document and analyse all major environmental issues and measures in order to alleviate them.

• Promote sustainable use of natural resources in Malawi. • Develop an environmental protection and management plan.


Key issues relevant to this project include:

• Soil erosion. • Water resources degradation. • Threat to natural resources. • Threat to biodiversity.

The policy recognises the integration of social issues with environmental issues, so requiring an integrated environmental and social assessment.

3.2.7 Gender Policy, 2008

The Gender Policy, 2008 identifies gender equality as a basic human right, and is also recognised in the Malawi Growth and Development Strategy as important for sustainable, social and economic development. Inequities are to be addressed over time as part of Malawi’s development.

Practical issues such as food security are identified in the Policy as supporting women’s fundamental welfare. Any disruption to the use of land for small scale agriculture, or disruption of normal employment can lead to food security issues. Food security minimises stress on households, and therefore protects women from the possibility of stress escalating to domestic violence situations. The project will need to develop interim food security plans as part of the social strategy ahead of construction activities or resettlement plans.

In addition to this important policy work, and in line with gender equality as one of 8 United Nations Millennium Development Goals, legislation has now been passed in Malawi.

3.2.8 National HIV/AIDS Policy, 2003

The goal of this policy is to prevent human immunodeficiency virus (HIV) infections, to reduce vulnerability to HIV, to improve the provision of treatment, care and support for people living with HIV and acquired immune deficiency syndrome (AIDS) and to mitigate the socio-economic impact of HIV/AIDS on individuals, families, communities and the nation. The objectives are to:

• Prevent HIV infections. • Improve delivery of prevention, treatment, care and support services. • Mitigate the impact of HIV/AIDS on individuals, the family and communities. • Reduce individual and societal vulnerability to HIV/AIDS through the creation of an enabling

environment. • Strengthen the multi-sectoral and multi-disciplinary institutional framework for coordination

and implementation of HIV/AIDS programmes in the country.

Importantly, this Policy recognises the impact of HIV/AIDS on vulnerable people, including women, and the marginalisation and discrimination of people living with HIV/AIDS.

3.3 Republic of Malawi Principal Acts and Legislation

The implementation of the ESIA process in Malawi is based on the principles in the 1992 Rio Declaration on Environment and Development and the legislative requirements of the EMA. By signing the Rio Declaration on Environment and Development, Malawi has committed, among other things, to Principle 17 concerning ESIA:


‘Environmental impact assessment, as a national instrument, shall be undertaken for proposed activities that are likely to have a significant adverse impact on the

environment and are subject to a decision of a competent national authority’.

The EMA is the principal Act which outlines the requirements for project developers to undertake an ESIA. Accordingly, the Project activities are subject to approval under the terms of the Act, and as such, the ESIA will be undertaken in accordance with this regulatory framework, as well as the ESIA Guidelines published by the EAD.

3.3.1 Environment Management Act (EMA), 2017

The EMA of 2017 repeals the previous Act of 1996 and any subsidiary legislation. It forms the basic legal framework for protection and management of the environment of Malawi, as well the conservation and sustainable utilisation of natural resources.

The general principles detailed in Part II of the Act specifically state that every person shall take all appropriate measures to protect the environment, conserve natural resources, and promote the sustainable utilisation of natural resources. Section 2(f) states that an ESIA is a legal requirement for any project that may significantly affect the environment and use of natural resources. The general principles also state that precautionary measures must be taken to prevent or mitigate possible deleterious environmental effects of any project, even where scientific evidence is not certain. The Malingunde Project falls under the prescribed list of activities as published in the ESIA Guidelines of 1997, and as such McCourt will be required to prepare an ESIA.

Section 5 of the Act allows for the effective public participation in environmental management and the right of every person to access environmental information and to participate in environmental decision-making processes (either directly or through a representative body).

The Act establishes the Malawi Environment Protection Authority as the principal agency for the protection and management of the environment. Section 9(f) stipulates that the Authority will be responsible for the review and approval of ESIAs, strategic environmental assessments and other relevant assessment in accordance with the EMA. At the time of compiling this ESR, the Authority had not yet been established and will therefore be submitted to the EAD.

The Act specifically states that no person shall excavate, drill, tunnel or disturb a wetland in a manner that has an adverse effect on the wetland without written approval from the Authority.

Part IX of the EMA makes provision for pollution control of both air and water pollution. With regard to water pollution, the EMA prohibits discharging of any pollutants into the environment. It further makes it a duty of every person to prevent the discharge of any pollutant into the environment other than in accordance with the Act and to comply with such general or specific directions of the Authority for preventing, minimising or cleaning up, removing or disposing of any pollutant discharged into the environment. Although the provision requires that any discharge of pollutants be in accordance with the EMA, the EMA has not made specific provision for that discharge.

3.3.1.1 Guidelines for Environmental Impact Assessment (1997)

In line with section 24 of the EMA of 1996, the Government of Republic of Malawi produced a set of Guidelines for Environmental Impact Assessment in Malawi in 1997. The purpose of the guidelines is to integrate environmental concerns in national development, and are applicable to all types of projects in the public and private sectors for which ESIA studies may be required, as identified in the


lists of prescribed projects (List A and List B) appended to the guidelines. List A identifies projects for which an ESIA is mandatory, which includes mining of minerals, expansions to mines, mining exploration activities, minerals prospecting activities, quarries, gravel pits and removal of sand or gravel from shore lines. This excludes those activities which have received a project specific exemption signed by the Director for Environmental Affairs and co-signed by the Director of Mines.

The Guidelines outline the process for conducting ESIAs and facilitate compliance to the ESIA process by developers.

3.3.2 Land Act, 2016

The Land Act of 2016 comprehensively deals with tenure of public and private land, and vests all land in the Republic in perpetuity.

The Act prescribes procedures of appropriate acquisition of land by the Minister for public purposes. The procedures include the steps to be undertaken for government to acquire land starting from issuance of formal notices to persons with existing land interests to payment of compensations and formal land ownership transfer.

The Act places restrictions on the sale of private land to persons who are not Malawian citizens and provides for conditions under which such transactions may take place.

The Act prescribes the "rules of good husbandry”, which stipulates that due regard be given to the maintenance of the land (whether arable, woodland or pasture) free from harmful weeds, clean and in a good state of cultivation and fertility and in good condition. Furthermore, good husbandry must include the maintenance and clearing of drains, earthworks and access roads; as well as proper repair of fences, hedges and field boundaries.

Two categories of land are recognised in Malawi in terms of the Act, namely private and public land. Private land includes freehold, leasehold and customary estate, while public land includes Government land and unallocated customary land.

Customary land is all land within the boundaries of a Traditional Land Management Area other than Government or reserved land, and land designated as customary land under the Land Act. A Traditional Land Management Area (an area demarcated and registered as falling within the jurisdiction of a Traditional Authority) can be divided into:

• Communal land occupied and used on a communal basis. • Land occupied by individual or family under customary law. • Land available for communal or individual occupation through allocation by a land committee.

3.3.3 Lands Acquisition Act, 1970

The Lands Acquisition Act, 1970 bestows upon the Minister the power to acquire land, either compulsory or by agreement, if he is of the opinion that it is in the interests of Malawi to do so. Compensation for land acquisition will be by agreement or as determined under the Act.

The Act describes the process of notification of persons who own land or have an interest in it, as well as the assessment of fair compensation for the acquisition of land.


3.3.4 Customary Land Act, 2016

The Act repeals the Customary Land (Development) Act, (Act 5 of 1967 and Act 26 of 1988) and provides for the management and administration of customary land in Malawi. In terms of the Act, customary land is defined as land within the boundaries of a Traditional Land Management Area other than Government or reserved land; land designated as such under the Land Act, 2016 or any other written law or administrative procedure in force; or land which the boundaries have been agreed upon by a land committee claiming jurisdiction over that land.

The Act bestows the responsibility for management of all customary land in Traditional Land Management Areas onto Land Committees at a group village headman level.

Furthermore the Act makes provision for the transfer of customary land; declaration of customary land as hazardous where it poses a danger to life or lead to environmental degradation; procedures for granting and management of customary estates. Customary land (not communal) may be made the subject of a grant of a customary estate by a land committee through the formal process as described in the Customary Land Act.

3.3.5 Water Resources Act, 2013

The Water Resources Act provides for the control, conservation, apportionment and use of water resources of Malawi. The Act vests ownership of all public water in the President while the control of all public water is vested in the Minister responsible for water affairs.

The objectives of the Act are to:

• Promote the rational use and management of water resources through appropriate standards and techniques for the investigation, use, control, protection, management and administration of water resources; as well as the regulation of all public and private activities which may influence the quality, quantity, distribution, use or management of water resources.

• Allow for the orderly development and use of water resources for all purposes. • Control pollution and to promote the safe storage, treatment, discharge and disposal of waste

and effluents which may pollute water or otherwise harm the environment and human health.

The Act classifies the bed and banks of watercourses and lakes and the adjacent land as public land and no person shall cultivate or carry out any activity within these areas, except as determined by the relevant Authority.

The Act prohibits any person to divert, dam, store, abstract or use public water for any other purpose except in accordance with the provisions of the Act. Section 39 of the Act prohibits any person to abstract, impound and use of water from a water resource without the required licences. In addition, a licence is required for the drainage of any swamp or other land. The application for such a licence to abstract and use water must be accompanied by an environmental impact analysis of the proposed abstraction of water upon the environment and existing water users and water resources.

It is an offence for any person to allow effluent to come into contact with any water or cause pollution of a water resource. Persons who own, control, occupy or use land must take measures to prevent pollution from occurring from activities and processes. All effluent discharges must be undertaken in compliance with prescribe standards of effluent quality, as well as an approved discharge permit.

Part X of the Act deals with the impoundment of water, the management of dams with a safety risk


and flood management. The Act prohibits the diversion or impoundment of watercourses except in accordance with the provisions of the Act.

3.3.6 Waterworks Act, 1995

The Waterworks Act, 1995 provides for the establishment of Water Resources Boards and water-areas and gives the said Water Boards various powers and duties in connection with water supplies and waterborne sewerage sanitation in their respective water areas.

The Act empowers the Board to supply water if requested for purposes other than domestic purposes, or where no water mains owned by the Board lies within 100 m of any boundary of premises for which a supply of water has been requested. Supply of water may be undertaken by the Board on such terms and conditions as it may decide, having regard to the costs which would be incurred making such supply of water available.

The Act also empowers Water Boards to make by-laws for the regulation of the use and the prevention of pollution and the prevention of pollution of gathering grounds, waterworks and water therein.

3.3.7 National Parks and Wildlife Act, 2004 and National Parks and Wildlife (Amendment) Act, 2017

The purposes of the National Parks and Wildlife Act, 2004 are to conserve selected examples of wildlife communities, and to protect rare, endangered and endemic species of wild plants and animals. In addition, it aims to conserve wildlife throughout Malawi so that the abundance and diversity of their species are maintained at optimum levels commensurate with other forms of land use, in order to support sustainable utilisation of wildlife for the benefit of the people of Malawi.

Section 25 of the National Parks and Wildlife Act, 2004 stipulates the criteria which requires to be included in ESIA reports relating to the impact on wildlife. This shall include:

• A statement of existing or anticipated impacts. • An account of the species, communities and habitats affected and the extent to which they

may be threatened. • A statement of whether rare, endangered or endemic species may be affected. • A description of mitigation measures.

The Amendment Act broadens the scope of environmental impact assessments to include social aspects.

3.3.8 National Parks and Wildlife (Protected Species) (Declaration) Order, 1994

The Protected Species (Declaration) Order of 1994 stipulates the species of wild plants and animals that are declared to be protected species for the purposes of the National Parks and Wildlife Act. The schedule lists all plants and animals in a national park or wildlife reserve, as well as specific species of plants, mammals, reptiles and birds.

3.3.9 Forestry Act, 1997

The Forestry Act, 1997 regulates the management, research, education, industries and participation in forestry activities. It further provides for the protection and rehabilitation of fragile areas. The Act seeks to protect trees and other resources in forest reserves, conserve and enhance biodiversity,


protect and facilitate management of trees on customary land, promote community involvement in the conservation of trees, promote sustainable utilisation of timber and other forest produce and protect fragile areas such as river banks and water catchments.

The Act deals with the management of indigenous forests on customary and private land; forest reserves and protected forest areas; woodlots and plantation forestry and also crosscutting issues including law enforcement and fire management.

Diverse use of forest areas is encouraged under the provisions of the Act, so as to empower local communities’ active management of their forest areas.

Forestry Rules set out protected species of trees, and outline permissions required before felling of any protected forest areas may be carried out.

Rehabilitation measures are to be conducted in a manner consistent with the provisions for coordinating forestry development and implementing the Forestry Programme of Action in the Southern African Development Community (SADC) region, as in section 5 of the Forestry Act.

3.3.10 Fisheries Conservation and Management Act, 1997

The Fisheries Conservation and Management Act provides for the conservation and management of fish stocks and fisheries of Malawi. The Act regulates the monitoring, control and surveillance of fishing operations and allows for the issue of permit and licences for fishing, aquaculture and related operations.

The Act encourages the participation of local communities in the conservation and management of fisheries in Malawi.

Section 19 of the Act stipulates that a permit is required for fishing in waters for scientific research or experimental purposes and the collection of specimens. An application for such a permit must be made to the Director of Fisheries in the prescribed form. Furthermore, no person shall use any explosive, device capable of producing an electric current, poison or other noxious substance for the purpose of killing, stunning, disabling or catching fish or in any way such fish more easily caught. The permit stipulate in Section 19 may however exempt persons from some of the provisions of the Act.

The Act stipulates that no person shall disturb, injure, poison, kill or detrimentally affect any fish, fish spawning ground, including any aquatic plant life or food for fish in any river, stream lake or other part of the fishing waters by casting, discharging, introducing or allowing to fall, flow or percolate into such waters any sawdust or sawmill refuse, oil, chlorinated hydrocarbon, biocide, pesticide, toxic or any other substance, heavy metal or other material or rubbish which could lie on the bed of such waters.

3.3.11 Fisheries Conservation and Management Regulations, 2000

The Fisheries Conservation and Management Regulations details the restriction on net mesh, mouth sizes, headline lengths, depths and fishing times in specific areas.

3.3.12 Plant Protection Act, 1969

The Plant Protection Act, 1969 provides for the prevention of introduction and the eradication of pests and diseases destructive to plants and related matters.

In terms of the Act, an owner of land or premises has the duty to take measures prescribed or


required by the Act, and reasonable additional measures necessary for the eradication, reduction or prevention of the spread of a pest or disease.

It is also an offence to introduce a pest on to land or premises in Malawi.

The Regulations promulgated under the Act prohibits the import and export of plants from Malawi without having applied for and obtained a phytosanitary certificate first.

3.3.13 Monuments and Relics Act, 1990

This Monuments and Relics Act makes provision for the conservation, preservation and study of cultural heritage; the acquisition by Government of rights and trusteeship over monuments and relics and for the preservation thereof by agreement with the owners. The Act further contains provisions on the procedure to be followed in relation to the exportation and importation of monuments, relics and collections of cultural heritage.

Before any land altering development activity is undertaken, a Cultural Heritage Impact Assessment is required by the laws of Malawi. The Monument and Relics Act of 1990 provides statutory protection against the threat of development on declared monuments, historical buildings and archaeological, paleontological, geological, anthropological, ethnological and other heritage sites to enable their preservation for posterity and socio-economic development.

Section 29 of the Monuments and Relics Act states that:

1. A person in charge of any survey, excavation, exploration, construction or new development shall, at the earliest stages of planning for such activities, give notice to the Minister to enable, where necessary, rescue archaeology to be carried out (…)

2. (…) the cost of such work shall … be borne by the person in charge of any survey, excavation, exploration, construction or other development.

The Malawi Cultural Policy (2014) and the Antiquities Policy (2012) also provide statutory and legal mandate of ensuring that Cultural Heritage Impact Assessment is conducted before embarking on large scale land altering development projects.

3.3.14 Gender Equality Act, 2013

The Gender Equality Act reflects Malawi’s commitment to gender equality, and makes provisions for the Malawi Human Rights Commission to:

• Monitor and evaluate the state organs, state agencies and public bodies including the private sector to promote gender equality and make recommendations that the Commission deems necessary.

• Carry out investigations and conduct searches in relation to any gender issues on receipt of complaint or on its own accord.

• Make recommendations to the Minister on any gender issues. • Provide information to any party in a gender dispute on rights, remedies or obligations. • Perform functions on implementation of the Gender Equality Act.

3.3.15 The Employment Act, 2000

The Employment Act regulates employment matters i.e. minimum wage, fair labour practices, non-discrimination and prohibition (in some cases) of employment of children. When employing people for


the implementation of the project activities, the developer should ensure that provisions of this Act are complied with.

The Employment Act further makes provision for anti-discrimination in section 5, and equal pay, as per section 6 of the Act.

3.3.16 Labour Relations Act, 1997

Rights to reach collective agreements are protected under the Labour Relations Act (1997), and orderly and expeditious dispute settlement is supported. This Act serves to promote sound labour relations through the protection and promotion of freedom of association, the encouragement of effective collective bargaining and the promotion of orderly and expeditious dispute settlement, conducive to social justice and economic development.

3.4 Other Relevant Legislation, Standards and Guidelines The following legislation, guidelines and standards will also be considered during the ESIA process:

• Occupational Health and Welfare Act, 1997. • MS 539 Industrial effluents – Tolerance limits for discharge into inland surface waters. • MS 59 Solid waste – Handling, transportation and disposal – Code of practice. • Water Abstraction Regulations (G.N. 230/1969). • Water (Water Pollution Control) Regulations (G.N. 31/1978). • MS 733 Borehole and shallow well water quality – Specification. • MS 214 Drinking water – Specification. • MS 682-1 Water quality – Sampling Part 1: Guidance on the design of sampling programmes

and sampling techniques. • MS 682-3 Water quality – Sampling Part 3: Guidance on the preservation and handling of

water samples. • MS 682-4 Water quality – Sampling Part 4: Guidance on sampling from lakes, natural and

man made. • MS 682-6 Water quality – Sampling Part 6: Guidance on sampling of rivers and streams. • MS 173 Acoustics Noise pollution – Tolerance limits. • MS 532 Borehole construction – Code of practice.

3.5 International Agreements

Malawi is party to a number of international conventions, treaties and protocols, which are relevant to the Project. These agreements serve as the principal framework for international co-operation and collaboration between members of the international community in their efforts to protect the local, regional and global environment. Malawi is bound to the provisions of an international agreement/law only if it signs and submits instruments of ratification in respect of a particular agreement.

The Government of Malawi is a signatory to a number of bilateral and international agreements and conventions, as listed below:

• The Rio Declaration on Environment and Development (1992). • The United Nations Framework Convention on Climate Change (1992). • The Montreal Protocol on Substances that Deplete the Ozone Layer (1987). • The United Nations Convention to Combat Desertification (1994). • The Convention on Biological Diversity (1992).


• The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) (1973).

• The African Convention on the Conservation of Nature and Natural Resources (revised) (2003).

• The SADC Revised Protocol on Shared Watercourses (2000). • The SADC Protocol on Fisheries (2001). • The SADC Protocol on Forestry (2003). • The International Plant Protection Convention (1951). • The Ramsar Convention on Wetlands of International Importance (1971). • The Convention Concerning the Protection of World Cultural and Natural Heritage (1972). • The Convention on the Conservation of Migratory Species of Wild Animals (1979). • The International Treaty on Plant and Genetic Resources for Food and Agriculture (2001). • The SADC Protocol on Gender and Development (1997). • The United Nations Convention on the Elimination of all Forms of Discrimination Against

Women (CEDAW) (1979). • The Vienna Declaration and Programme of Action of the World Conference on Human Rights

(1993). • The International Covenant on Economic, Social and Cultural Rights (1966).

3.6 International Standards and Guidelines

The ESIA for the Project will also adhere to generally accepted international good practice and standards, particularly those prescribed by the IFC Performance Standards on Environmental and Social Sustainability (IFC, 2012) and the Equator Principles. In the absence of specific guidelines and standards under Malawian legislation, and where relevant, international guidelines and standards will be applied.

The IFC is a member of the World Bank Group, providing finance and development advice for private sector ventures and projects in developing countries. Their Performance Standards provide benchmarks for identifying and managing environmental and social risks. The ESIA will take cognisance of the eight IFC Performance Standards and associated Guidance Notes on Environmental and Social Sustainability (IFC, 2012), which together define the optimal environmental, social and health standards to be upheld throughout the life of a project. Also relevant are World Bank Guidelines and Handbooks for specific issues such as cumulative impact assessment and resettlement. Specifically, they provide guidance to:

• Identify environmental and social impacts, risks and opportunities of projects, with effective community engagement and consultation.

• Identify and minimise impacts on workers, affected communities and the environment, and prioritise active management of impacts.

• Identify specific objectives, such as avoidance of damage of areas of cultural significance. A demonstration of an awareness of these standards is expected as part of an environmental and social due diligence process to be undertaken by the financing institution.

3.6.1 IFC Performance Standards

The IFC Performance Standards comprise of a collection of eight quality standards which the project developer is required to meet throughout the life of the investment. These performance standards include the following:


IFC-PS 1: Assessment and Management of Environmental and Social Risks and Impacts

This standard underscores the importance of managing environmental and social performance throughout the life of a project through an effective environmental and social management system (ESMS). Its objectives are to:

• Identify and evaluate environmental and social risks and impacts of the project. • Adopt a mitigation hierarchy to anticipate, and avoid or manage risks and impacts to workers

and communities. • Promote improved environmental and social performance of clients through the effective use

of management systems. • Ensure that grievances from communities and external communications from other

stakeholders are responded to and managed appropriately. • To promote and provide means for adequate engagement with communities throughout the

project cycle on issues that could potentially affect them and to ensure that relevant environmental and social information is disclosed and disseminated.

IFC-PS 2: Labour and Working Conditions

This standard recognises that the pursuit of economic growth through employment creation and income generation should be accompanied by protection of the fundamental rights of workers. Its objectives are:

• To promote the fair treatment, non-discrimination and equal opportunity of workers. • To establish, maintain and improve the worker-management relationship. • To promote compliance with national employment and labour laws. • To protect workers, including vulnerable categories of workers such as children, migrant

workers, workers engaged by third parties, and workers in the project proponent's supply chain.

• To promote safe and healthy working conditions, and the health of workers. • To avoid the use of forced labour.

IFC-PS 3: Pollution Prevention and Abatement

This standard recognises that increased economic activity and urbanisation often generate increased levels of pollution to air, water, and land, and consume finite resources in a manner that may threaten people and the environment at the local, regional, and global levels. Its objectives are:

• To avoid or minimise adverse impacts on human health and the environment by avoiding or minimising pollution from project activities.

• To promote more sustainable use of resources, including energy and water. • To reduce project-related greenhouse gas emissions.

IFC-PS 4: Community Health, Safety and Security

This standard recognises that project activities, equipment, and infrastructure can increase community exposure to risks and impacts. In addition, communities that are already subjected to impacts from climate change may also experience an acceleration and/or intensification of impacts due to project activities. Its objectives are:


• To anticipate and avoid adverse impacts on the health and safety of the community during the project life from both routine and non-routine circumstances.

• To ensure that the safeguarding of personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimises risks to the communities.

IFC-PS 5: Land Acquisition and Involuntary Resettlement

This standard takes into account that project-related land acquisition and restrictions on land use can have adverse impacts on communities and persons that use this land. Land acquisition may result from involuntary resettlement, that is, physical displacement (relocation or loss of shelter) or economic displacement (loss of assets or access to assets that leads to loss of income sources or other means of livelihood) as a result of project-related land acquisition. The objectives of the standard are:

• To avoid, and when avoidance is not possible, minimise displacement by exploring alternative project designs.

• To avoid forced eviction. • To anticipate and avoid, or where avoidance is not possible, minimise adverse social and

economic impacts from land acquisition or restrictions on land use by (i) providing compensation for loss of assets at replacement cost and (ii) ensuring that resettlement activities are implemented with appropriate disclosure of information, consultation, and the informed participation of those affected.

• To improve, or restore, the livelihoods and standards of living of displaced persons. • To improve living conditions among physically displaced persons through the provision of

adequate housing with security of tenure at resettlement sites.

IFC-PS 6: Biodiversity Conservation and Sustainable Natural Resource Management

The standard follows the principle that protecting and conserving biodiversity, maintaining ecosystem services, and sustainably managing living natural resources are fundamental to sustainable development. Its objectives are:

• To protect and conserve biodiversity. • To maintain the benefits from ecosystem services. • To promote the sustainable management of living natural resources through the adoption of

practices that integrate conservation needs and development priorities.

IFC-PS 7: Indigenous Peoples

This standard recognises that Indigenous Peoples, as social groups with identities that are distinct from mainstream groups in national societies, are often among the most marginalised and vulnerable segments of the population.

IFC-PS 8: Cultural Heritage

This standard takes into account the importance of cultural heritage for current and future generations, consistent with the Convention Concerning the Protection of the World Cultural and Natural Heritage. Its objectives are:


• To protect cultural heritage from the adverse impacts of project activities and support its preservation.

• To promote the equitable sharing of benefits from the use of cultural heritage.

3.6.2 The World Bank Group Policies

The WBG provides guidance on ESIA requirements through their Environmental, Health, and Safety Guidelines, which includes sectoral guidelines. It addresses environmental monitoring and management issues, and identifies typical mitigation measures. The World Bank ESIA process is implemented through a set of operational policies and procedures whose primary objective is to ensure that Bank operations do not cause adverse impacts and they “do no harm”.

Specific safeguard policies address natural habitats, pest management, cultural property, involuntary resettlement, indigenous peoples, and safety of dams, projects on international waterways and projects in disputed areas. The World Bank's environmental and social safeguard policies are a cornerstone of its support to sustainable poverty reduction. The objective of these policies is to prevent and mitigate undue harm to people and their environment in the development process. These policies ensure that environmental and social issues are evaluated in decision making, help reduce and manage the risks associated with a project or program, and provide a mechanism for consultation and disclosure of information. They also ensure that potentially adverse environmental and social consequences are identified, minimised, and mitigated. Key World Bank policies that will be considered during the ESIA process include:

• OP 4.01 Environmental Assessment (1999, revised 2013). • OP 4.04 Natural Habitats (2001, revised 2013). • OP 4.09 Pest Management (1998). • OP 4.11 Physical Cultural Resources (2006, revised 2013). • OP 4.12 Involuntary Resettlement (2001, revised 2013). • OP 4.36 Forests (2002, revised 2013). • OP 4.37 Safety of Dams (2001, revised 2013).

3.6.3 The Equator Principles

The Equator Principles are a set of voluntary guidelines which a number of financial institutions have adopted with the intention of creating an industry standard for assessing and managing environmental and social issues in the project finance sector. The Equator Principles are based on the policies and guidelines of the IFC, which is the private sector development arm of the World Bank. The ESIA for the Project identified the requirements listed below as key to the Project and it is the intention that the Project will comply with these principles.

Principle 1: Review and Categorisation

Principle 1 provides that when a project is proposed for financing, the relevant Equator Principles Financial Institution (EPFI) shall, as part of its internal social and environmental review and due diligence, categorise such projects based on the magnitude of their potential impacts and risks in accordance with the environmental and social screening criteria of the IFC.

Proposed projects may be categorised as one of the following:

• Category A: Projects with potential significant adverse social or environmental impacts, those that are diverse, irreversible or unprecedented.


• Category B: Projects with potential limited adverse social or environmental impacts that are few in number, generally site specific, largely irreversible and readily addressed through mitigation measures.

• Category C: Projects with minimal or no social or environmental impacts.

In consideration of the above Equator Principle categories, the Project is classified as a Category A project.

Principle 2: Environmental and Social Assessment

Category A projects shall conduct an environmental and social assessment to address, as appropriate and to the EPFI’s satisfaction, the relevant social and environmental impacts and risks of the proposed project. The assessment should also propose mitigation and management measures relevant and appropriate to the nature and scale of the proposed project.

Principle 3: Applicable Environmental and Social Standards

Principle 3 requires that the assessment address compliance with local laws, regulations and permits that pertain to environmental and social issues.

Principle 4: Environmental and Social Management System and Equator Principles Action Plan

Under Principle 4, an environmental and social management plan (ESMP) will be prepared to address issues raised during the ESIA process and incorporate actions required to comply with the applicable standards. Where the applicable standards are not met to the EPFI’s satisfaction, EPFI will agree an Equator Principles Action Plan. The Action Plan is intended to outline gaps and commitments to meet EPFI requirements in line with the applicable standards.

Principle 5: Stakeholder Engagement

Pursuant to Principle 5, effective stakeholder engagement with interested and affected parties must be undertaken in a structured and culturally appropriate manner. For projects with potentially significant adverse impacts on affected communities, the proponent must conduct an informed consultation and participation process. The consultation process must be tailored to the risks and impacts of the project; the project’s phase of development; the language spoken by stakeholders. This process should be free from external manipulation, interference, coercion and intimidation.

Principle 6: Grievance Mechanism

For all Category A projects, a grievance mechanism must be established as part of the ESMS, designed to receive and facilitate resolution of concerns and grievances about the Project’s environmental and social performance.

The grievance mechanism will seek to resolve concerns promptly, using an understandable and transparent consultative process that is culturally appropriate, readily accessible, at no cost, and without retribution to the party that originated the issue or concern. The mechanism should not impede access to judicial or administrative remedies.


Principle 7: Independent Review

An independent environmental and social consultant, not directly associated with the client, will carry out an independent review of the assessment documentation, including the ESMP, the ESMS, and the stakeholder engagement process documentation to assist the EPFI's due diligence, and assess Equator Principles compliance.

The independent environmental and social consultant will also propose or comment on a suitable Equator Principles Action Plan capable of bringing the project into compliance with the Equator Principles, or indicate when compliance is not possible.

Principle 8: Covenants

This principle requires the project proponent to include in all financing and related contractual documents, commitments to abide by all of the Principles, all host country laws and regulations and all plans and management systems developed in accordance with the Principles.

Principle 9: Independent Monitoring and Reporting

This requires the proponent where appropriate to retain an independent environmental and/or to verify its monitoring information, which would be shared with the financing institutions.

Principle 10: Reporting and Transparency

Each EPFI adopting the Equator Principles commits to report publicly at least annually about its Equator Principles implementation process and experience, taking into account appropriate confidential considerations.


4 Environmental Setting The Project surroundings is sparsely vegetated as a consequence of rampant deforestation of the indigenous woodland. Natural vegetation regrowth is minimal due to pressure on wood resources which forms the main fuel supply for most households. The main areas of vegetation occur within the dambo (wetland) areas and a number of preserved pockets of forested areas that also include village cemeteries.

A number of semi-permanent and ephemeral water courses occur within the project footprint. The project area lies mostly within the immediate watershed of the Kamuzu Dam II, with the southwestern part of the deposit terminating at the water’s edge, near the spillway.

Existing environmental and social information was collected, collated and summarised in this section, and provides a description of the baseline environmental conditions that will inform the various specialist surveys. In areas where information is deficient, further data will be collected as part of the specialist studies.

4.1 Topography

Regionally the Project is situated within the Central Region Plateau (also known as the Lilongwe Plain) a large continuous tableland, 900 – 1,400 mamsl located on the western side of The Great Rift Valley. The gradient of the land varies between 1:50 to 1:90 across the Project site.

Although the area is characteristically flat or undulating plains, localised rounded hills (also known as dwalas or inselbergs) of more resistant gneisses rise up above the plain level (Hudson Ecology, 2017a).

A slightly elevated catchment divide is located at approximately the centre of the Project area with a general eastwest orientation. A number of small valley areas (dambos) drain the Project area, flowing into the Lilongwe River. These dambos drain in a southeasterly direction to the south of the catchment divide, while two larger dambo systems drain in a northeasterly direction to the north of the catchment divide.

4.2 Climate

The Project is located in the central area of Malawi that has a typical sub-tropical climate, which is relatively dry and strongly seasonal. The climate is characterised by two distinct seasons, with a warm wet season from November to April during which 95% of the annual precipitation takes place, and a cool dry winter season between May and August with mean temperatures varying between 17 and 27 degrees Celsius (C). A hot, dry season lasts from September to October with average temperatures varying between 25C and 37C.

Meteorological data was obtained from the Food and Agricultural Organisation (FAO's) CLIMWAT 2.0 database3 for the Lilongwe International Airport (20 km northnortheast of the Project area) and Chitedze (18 km southwest), and an average of these two stations was used to estimate monthly averages at the Project site (SLR, 2017).

In addition to the CLIMWAT data, hourly weather data for Kamuzu Dam Weather Station for the 3 The FAO CLIMWAT database comprises a dataset of measured climatic parameters taken from over 5 000 weather stations around the world with the records for each weather station comprising at least 15 years, in most cases covers the period 1971 – 2000, and data has been cross checked between stations to ensure for a consistent database suitable for determining regional and temporal variations in average weather conditions.


period between 1985 and 2017 was sourced from Meteo Blue (https://www.meteoblue.com; Meteo Blue, 2017). The Kamuzu Dam weather station is located approximately 3 km southwest of the Project.

4.2.1 Rainfall

Rainfall in Malawi is strongly influenced by the main rain bearing systems including the Inter-Tropical Convergence Zone (ITCZ), Congo air mass, Easterly Waves and Tropical Cyclones.

The Department of Climate Change and Meteorological Services (2018) indicated in their forecast for 2017/2018 that the season will be characterised by neither El Niño nor La Niña neutral conditions, as a result of El Niño Southern Oscillation (ENSO) conditions that have developed over the Eastern Central Equatorial Pacific.

These current neutral conditions are analogous to the neutral conditions that were experienced in the 1990/1991, 1993/1994, 2001/2002 and 2012/2013 seasons. During these past neutral years, Malawi experienced late onset of the rains and normal to below normal total rainfall amounts over most areas. However above normal amounts were experienced over highlands and lakeshore areas (Department of Climate Change and Meteorological Services, 2018).

Extreme conditions include the drought that occurred in the 1991/92 season and floods of the 1988/89 season (Department of Climate Change and Meteorological Services, 2017).

The annual average rainfall in the Project area varies between 800 mm and 1,000 mm. In line with weather forecasts, the area experienced normal to above normal rainfall amounts during October 2016 to March 2017. The Southern African Regional Climate Outlook Forum (SARCOF) indicated that normal total rainfall amounts are expected during the period October 2017 to March 2018 (Department of Climate Change and Meteorological Services, 2018).

The average monthly rainfall in the Project area is illustrated in Figure 4.1. The average total annual rainfall measured at the Kamuzu Dam weather station is approximately 950 mm.

Figure 4.1: Average Monthly Rainfall in the Project Area

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Rainfall FAO CLIMWAT Rainfall Kamuzu Dam

https://www.meteoblue.com/


4.2.2 Temperature

The average temperatures during the cool dry winter season (May to August) vary between 8C (minimum) and 26C (maximum), while average temperatures during the hot dry season (September to October) vary between 12C and 30C. Figure 4.2 illustrates the average monthly minimum and maximum temperatures.

Figure 4.2: Average Monthly Temperatures in the Project Area

4.2.3 Wind Speed and Direction

Data from the Kamuzu Dam weather station was used to determine the dominant wind direction and speed. The prevailing wind direction is northeast to southeast and the average wind speed over a year is 8.5 km/hour.

4.3 Seismicity Potential

Malawi is situated in the southern branch of the active East Africa Rift System (Yang and Chen, 2010 as cited in Amec Foster Wheeler, 2017). In the Malawi Rift, several major geological faults (e.g., Livingstone and Bilila-Mtakataka faults) can be identified using seismic stratigraphic analysis.

Geological, geodetic, and geomorphological studies in Malawi indicate the possibility for experiencing infrequent, large earthquakes originated from the well-matured fault systems along Lake Malawi (Amec Foster Wheeler, 2017). Figure 4.3 shows locations of seven faults in the Malawi Rift region: Livingstone, Usisya, Mbamba, Bandawe, Metangula, Mwanjage, and Bilila-Mtakataka faults.

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Figure 4.3: Seismicity Inducing Faults Around Lake Malawi (Yang and Chen, 2010 as cited in Amec Foster Wheeler, 2017)

The seismic hazard for the Project area was evaluated by SLR (2017) as part of TSF Options Study. To evaluate the seismic hazard the following methodology was adopted:

• Identify all earthquake sources capable of producing damaging ground motions (± 500 km radius from the TSF).

• Characterise the distribution of source-to-site distances associated with potential earthquakes.

• Assess the distribution of ground motion intensity, which is a function of earthquake magnitude and distance.

A review of the United States Geological Survey (USGS) Earthquakes Hazards database was undertaken to identify historical earthquakes centred around the Project area. A total of 189 events have occurred within a radius of ±500 km between 1900 and December 2017. The magnitudes of all of these vary between 0 and 6.7 on the Richter Scale (SLR, 2017).

The majority (125) of the earthquakes have a magnitude between 4 and 4.9 (Richter scale). Two earthquakes with a magnitude greater than 6.0 on the Richter scale were recorded within the ±500 km radius. There were 24 earthquakes with a magnitude between 5.0 and 5.9 and 34 earthquakes with a magnitude between 3.0 and 3.9 within the ±500 km radius of the Project Area.


The largest magnitude earthquake, with a magnitude of 6.7, was recorded on 1 May 1919 and occurred approximately 303 km northeast of the Project site.

The closest earthquake occurred on 28 February 1990 approximately 50 km from the Project area at a depth of 33 km. This earthquake registered a magnitude of 5.1 on the Richter Scale.

Table 4.1 represents a comparison between the Richter Scale, approximate ground acceleration and Mercalli Equivalent, as well as providing a general description of the observations that are likely for the respective events. Comparison of the earthquakes which have occurred within the 500 km radius to Table 4.1 shows that the earthquakes fall into category I to IX.

Table 4.1: Richter Scale, Approximate Acceleration and Mercalli Equivalent

Richter Scale

Approximate Acceleration

(cm/s2) Approximate Mercalli Equivalent

<3.5 I Felt only by a few persons at rest, especially on upper floors of buildings.

3.5 2.5 II Felt quite noticeably by persons indoors, especially on upper floors of buildings. Many people do not recognise it as an earthquake. Standing motor cars may rock slightly. Vibrations similar to the passing of truck. Duration estimated.

4.2 2.5 III

4.5 10 IV

Felt indoors by many, outdoors by few during the day. At night, some awakened. Dishes, windows, doors disturbed; walls make cracking sound. Sensation like heavy truck striking building. Standing motorcars rocked noticeably.

4.8 25 V Felt by nearly everyone; many awakened. Some dishes, windows broken. Unstable objects overturned. Pendulum clocks may stop.

5.4 50 VI Felt by all, many frightened. Some heavy furniture moved; a few instances of fallen plaster. Damage slight.

6.1 100 VII Damage negligible in buildings of good design and construction; slight to moderate in well-built ordinary structures; considerable damage in poorly built or badly designed structures; some chimneys broken.

6.5 250 VIII

Damage slight in specially designed structures; considerable damage in ordinary substantial buildings with partial collapse. Damage great in poorly built structures. Fall of chimneys, factory stacks, columns, monuments, walls. Heavy furniture overturned.

6.9 250 IX Damage considerable in specially designed structures; well-designed frame structures thrown out of plumb. Damage great in substantial buildings, with partial collapse. Buildings shifted off foundations.

7.3 500 X Some well-built wooden structures destroyed; most masonry and frame structures destroyed with foundations. Rails bent.

8.1 750 XI Few, if any (masonry) structures remain standing. Bridges destroyed. Rails bent greatly.

>8.2 980 XII Damage total. Lines of sight and level are distorted. Objects thrown into the air.

Source: The Geography Site, 2013 as cited in SLR, 2017

4.3.1 Maximum Credible Earthquake

The maximum design earthquake (MDE) for critical structures (i.e., the TSF) is the maximum level of ground motion for which a structure is designed. The associated performance requirement is that the structure performs without catastrophic failure, although severe damage or economic loss may be tolerated. For critical structures, the MDE is the same as the maximum credible earthquake (MCE) (SLR, 2017).


The MCE is the largest conceivable earthquake that appears possible along a recognised fault or within a geographically defined tectonic province, under the presently known or presumed tectonic framework. For the purposes of the Project, the MCE is defined as the peak ground accelerations (PGA) having a return period of 10,000 years, or equivalently, 0.5% probability of exceedance in 50 years. The selected time period of 10,000 years is standard for critical structures for areas with low to moderate seismicity.

It is standard practice to assume that the maximum credible magnitude is 0.5 units larger (on the Richter Scale) than the maximum observed event (Durrheim et al, 2016 as cited in SLR, 2017). The largest earthquake that has occurred within a ±500 km radius had a magnitude of 6.7. The MCE is therefore assumed to have a magnitude of 7.2 on the Richter scale. For conservative purposes, the approximate PGA value for the MCE is approximately 4.8 m/s2 (0.48 g).

4.4 Geology

The Malingunde area is located on the Lilongwe Plain, which is underlain by a Neo-Proterozoic to Cambrian semi-pelitic paragneisses of the Mchinji Group (Thatcher & Walter, 1968 as cited in Amec Foster Wheeler, 2017). Lithologies include kyanite, biotite, garnet, pyrrhotite and graphite bearing gneisses and schists. This area has a largely preserved, deep tertiary tropical weathering profile containing significant thicknesses of saprolite, which is the soft, clay-rich material hosting the graphite mineralisation.

A typical profile from surface is soil (“SOIL”, 01 m), ferruginous pedolith (“FERP”, 14 m), mottled zone (“MOTT”, 47 m), pallid saprolite (“PSAP”, 79 m), saprolite (“SAPL”, 925m), saprock (“SAPR”, 2535 m) and fresh rock (“FRESH” >35 m). For the purposes of the MRE, all units from saprolite and above were grouped under the classification “saprolite”. This was based on the assumption that saprolite material is free-dig, and that all weathering zones have similar metallurgical characteristics.

Flake graphite mineralisation occurs within graphitic gneissic units that are interlayered and separated locally by barren felsic, biotite kyanite gneisses and schists. Mineralisation is broadly conformable with the host paragneiss sequence, striking northwest and dipping at 25-50° to the northeast. Mineralisation has been modelled as three separate zones with a total strike length of 4.5 km, horizontal widths of between 50230 m and to a maximum vertical depth of 50 m. Two discrete, higher grade graphite zones (>8-10% TGC) occur within the far northern and southern limits of the delineated mineralised extents.

4.5 Soils and Land Capability

According to the geological map (1:100,000), red-brown sandy clay soils (Qr) dominate the study area. Their colour depends on the degree of cultivation and the percentage of humus present. These soils are probably derived largely from the micaceous rocks and, to a lesser extent, from pyritic and hornblendic rocks, including metagabbros. A surface float of quartz, kyanite and, less commonly, tourmaline is typically developed over these soils which broadly may be correlated with the ferruginous soils of Brown and Young’s (1965) classification (Hudson Ecology, 2017a).

In the Lilongwe River, the 2.5 km stretch in the upstream limit of the study area is occupied by dambo soil (Thatcher and Walter, 1968 as cited in Hudson Ecology, 2017a). This area of impeded drainage is occupied by hydromorphic soils; dark grey, black and mottled soils mainly composed of clay minerals. The thin humus of the A-horizon supports only shallow rooted plants, like grasses. The low permeability of clays combined with the poor site drainage produce a waterlogged soil liable to seasonal flooding.


4.6 Flora

A terrestrial biodiversity survey of the Project area and immediate surrounds was undertaken in April 2017. The results of this survey are summarised in Section 4.6 (Flora) and Section 4.7 (Fauna).

The Project area falls within the Southern Miombo woodlands ecoregion a discontinuous ecoregion which is located on the Central African Plateau at elevations between 1,000 and 1,500 m. Numerous grassy wetlands are interspersed along drainage lines in dambos (Barnes, 1998 as cited in Hudson Ecology, 2017a). Highly weathered, acidic, and nutrient-poor soils, mainly alfisols and some oxisols in wetter locations, predominate and are more than 3 m deep in places. Shallow stony soils are common along the escarpment and around inselbergs. Soils are generally well-drained. To the west, the ecoregion ranges marginally onto aeolian Kalahari sands.

Floristically, the Southern Miombo woodlands ecoregion forms part of a belt of miombo woodland that extends from Angola, in the west, to Tanzania, in the east. This miombo band is synonymous with the Zambezian Phytochorion, the largest of White’s (1983) Regional Centres of Endemism within Africa (Hudson Ecology, 2017a). Miombo plant communities are dominated by trees belonging to the family Caesalpiniaceae and characterised by Brachystegia and Julbernardia species.

4.6.1 Vegetation Communities

Vegetation in Malawi is extensively miombo woodland, deciduous forests, and thickets, evergreen and semi-evergreen forests and montane grassland. Malawi has about 5,500 to 6,000 flowering plants, and 250 species of bryophytes, 200 of which are mosses. Out of the documented more than 6,000 plant species, 253 are considered threatened, vulnerable, rare or endangered (Hudson Ecology, 2017a).

Flora assessments were conducted during the latter part of the wet season in April 2017, based on physiognomy, moisture regime, rockiness, slope and soil properties, four main communities were recognised, namely:

• Dambo grassland vegetation. • Mixed riparian vegetation. • Forest vegetation. • Cultivated lands.

These vegetation communities are shown in Figure 4.4.

Table 4.2 indicates the relative size of each of the vegetation communities to in the study area.

Table 4.2: Vegetation Communities Identif ied in the Project Area

Vegetation Community Area in ha % of Total Study Area

Dambo grassland vegetation community 23 6%

Mixed riparian vegetation community 9 3%

Forest woodland vegetation community 10 3%

Cultivated lands 333 89%

Total Study Area 375 100%


Ninety-one terrestrial (91) plant species were recorded in the Project area representing 29 families. Tree species and shrub species accounted for 16 species (18%) and 16 species (18%) of the total number of species, respectively, while forbs accounted for 22 species (24%) of the total number of species recorded. Grass species accounted for 34% of the total number of species recorded with 31 species. With only 6 species (7%) of the total number of species recorded, cyperoid plants made up the smallest percentage of the species. A detailed list of flora species identified is attached in Appendix A.

Of the species likely to occur in the Project area, one species is currently listed as Least concern, two species are listed as near threatened, two species are listed as Vulnerable while one species is listed as critically endangered under the International Union for Conservation of Nature and Natural Resources (IUCN) Red List of Threatened Species (Red List). Only one species of conservation importance was recorded, namely Burkea africana (ash tree or wild syringa), which was recorded in the riparian forest and the forest fragments. This species is classified as protected under Malawi legislation.


Figure 4.4: Vegetation Communities Recorded in the Project Area


4.6.2 Dambo Grassland Vegetation Community

Dambos are seasonally waterlogged, predominantly grass covered, shallow depressions bordering headwater drainage lines (Plate 4.1). These are generally found in higher rainfall flat plateau areas and have river-like branching forms. Dambo grasslands are located to the north and northwest of the local study area (Figure 4.4). One dambo is located within the Project area and runs in a northsouth direction towards the Kamuzu Dam. This dambo has however been extensively transformed by agricultural activities and only a very small area, adjacent to the Kamuzu Dam II, can be classified as a functional wetland. Generally, dambos in the area are characterised by a gently sloping channelled or unchannelled valley with large grassy floodplains. Due to the fact that the dambo within the study area is so extensively transformed that it can be characterised as cultivated lands, and no longer as a functional dambo, dambos to the north and northwest were investigated in order to obtain an indication of species likely to occur in this vegetation community.

Plate 4.1: Example of a Dambo to the North of the Project Area

Species dominance is not uniform and occurs in mosaics of local dominance of different species. In the outer, drier parts of the dambo the grass community is dominated by Hyparrhenia filipendula, Setaria incrassata, Sporobolus pyramidalis, Loudetia simplex, Pogonarthria squarrosa, Hyperthelia dissoluta, Cynodon dactylon, Eragrostis chapelieri, Setaria pumila, Stereochlaena cameronii and Eragrostis superba. This area of the dambo is often interspersed by weeds and woody species such as Kigellia africana, Piliostigma thonningi, Senna siamea, Solanum delagoense, Bidens biternata, B. pilosa, Tagetes minuta, Conyza albida, Sesbania microphylla and Oldenlandia corymbosa. Closer to the channel of the dambo, vegetation changes so that the grass species are dominated by species such as Hemarthria altissima, Paspalum urvillei, Arundinella nepalensis, Aristida junciformis, and sedges such as Cyperus esculentus, Cyperus tenax, Kylinga erecta, Pycreus aethiops, Typha latifolius and Typha domingensis. Forb species closer to the channel include Ranunculus multifidus, Verbena bonariensis, Senecio strictifolius, Helichrysum species, Kniphofia linearifolia and Polygonum senegalense, while the channel itself may host aquatic macrophytes such as Azolla nilotica, Pistia stratiotes, Utricularia cf. intermedia, Persicaria lapathifolia, Nymphaea nouchali and Nymphaea lotus.


Although the dambos have intrinsic conservation importance, the degraded (and in some cases transformed) nature of the wetlands in the study area do reduce the conservation importance of these areas.

4.6.3 Mixed Riparian Woodland

Mixed riparian (or riverine) woodland vegetation (Figure 4.4) occurs along the banks of more permanent water bodies such as perennial rivers and dams. This vegetation community is comprised of a mixture of fine- and broadleaved tree species as well as a well-developed shrub layer and poorly developed grass and forb layers. This vegetation community demonstrates a far lesser degree of degradation than other vegetation communities in the region and the main form of disturbance occurs in the form of invasive species propagation in the vegetation community. This vegetation community comprises of a range of tree species including Vachellia polyacantha, Vachellia sieberiana, Albizia antunesiana, Burkea africana, Combretum molle, Ekebergia benguelensis, Faurea speciose, Piliostigma thonningi, Antidesma venosum, Afzelia quanzensis and Trichilia emetic. Common shrub species in this vegetation community include Eriosema ellipticum, Eriosema engleranum, Euclea crispa, Gnidia kraussiana, Indigofera arrecta, Lippia javanica, Lopholaena coriifolia, Maytenus senegalensis, Rhynchosia resinosa, Flueggea virosa and Diospiros heterophylla. Due to the increased canopy cover the grass and forb layers are poorly defined and grasses found in this vegetation community include Aristida junciformis and Eragrostis spp.

Plate 4.2: An Example of Mixed Riparian Vegetation

4.6.4 Forest Vegetation Community

Forest vegetation communities are found mostly surrounding ancestral graveyards (manda), which represent forest islands (Figure 4.4) of relatively unspoiled vegetation, with smaller patches in cultivated dambo grassland. The unspoiled nature is due to their sacred value and communities’ beliefs (Mauambeta, et al., 2010 as cited in Hudson Ecology, 2017). This habitat has a good representation of older and larger trees, typically with dense canopy cover, and includes indigenous trees such as Rauvolfia caffra, Julbemardia globiflora, Kigellia africana, Parinari curatellifolia, Ochna


puhra, Pericopsis angolensis, Toonia ciliata, Vangueriopsis lanciflora, Piliostigma thonningii and Cussonia arborea. Due to the disturbance by livestock and the high density of the crown cover (60%) the shrub, grass and forb layers are poorly defined, with the shrub layer being particularly poorly defined. Shrub species recorded in this vegetation community include Euclea crispa, Gnidia kraussiana, Helichrysum kraussii, Indigofera arrecta, Lantana camara and Leptactina benguelensis. The grass layer is sparse and characterised by Eragrostis spp., Heteropogon contortus, Hyperthelia dissoluta, Melinis repens, Pogonarthria squarrosa and Sporobolus pyramidalis, while the forb layer is dominated by exotic species such as Achyranthes aspera and Bidens pilosa, in high densities, as well as species such as Polygonum senegalense, Ranunculus multifidus, Senecio strictifolius, Sesbania microphylla and Solanum spp. Forest woodlands in the Project area are restricted to isolated stands of vegetation with minimal connection, with more expansive regional forests found within forest reserves in the region.

Plate 4.3: An Example of the Forest Fragments in the Project Area

4.6.5 Cultivated Lands

Cultivated land within the local study area consists of cultivated dambo and cropland, and covers approximately 89% of the local study area. Cultivated lands in the dambo areas are used to grow crops such as vegetables (especially a number of variety of squashes, Cucurbita sp.), tomatoes (Solanum lycopersicum), Irish potatoes (Solanum tuberosum), maize (Zea mays) and sugarcane (Saccharum officinarum). During the dry season, some of these areas are irrigated from shallow groundwater wells or the river. The remainder of the cultivated land area is cultivated for the purposes of maize and groundnuts (Arachis villosulicarpa). These areas are often devoid of trees or very sparsely populated by scattered trees. Tree species found in this vegetation community include exotic species of economic importance, for wood such as Eucalyptus saligna and Gmelina arborea, and fruit, such as Mangifera indica (mango) and Psidium guajava (guava). Indigenous trees that occur in this vegetation community include Kigellia africana, Piliostigma thonningi, Senna siamea and Dichrostachys cinerea. The shrub layer in this vegetation is virtually non-existent although coppicing


trees do occur in areas, while forb species in these areas are dominated by weed species such as Bidens biternata, Bidens pilosa, Oldenlandia herbacea, Sesbania microphylla, Solanum delagoense, Tagetes minuta and Verbena bonariensis. Due to the fact that these areas are heavily grazed when not cultivated, the grass layer is relatively sparse and dominated by unpalatable and sub-climax species such as Aristida junciformis, Cynodon dactylon, Eragrostis spp. Heteropogon contortus and Hyparrhenia filipendula.

4.7 Fauna

4.7.1 Herpetofauna

There are 140 species of reptiles recorded in Malawi, represented in 22 families. Species diversity for the Project area was relatively low, with only 12 species being recorded during the April 2017 surveys (Hudson Ecology, 2017a). These species include Agama mossambic, Dasypeltis scabra, Philothamnus semivariegatus, Crocodylus niloticus, Lygodactylus capensis, Duberria lutrix, Amblyodipsas polylepis, Lycophidion capense, Trachylepis margaritifera, Trachylepis varia, Causus rhombeatus and Bitis arietans. None of the species recorded are restricted in number or distribution, nor are any of the species regarded as protected species by Malawi Legislation or listed on the IUCN Red List.

There are a number of probable explanations for the low species diversity, and these can be split into explanations for temporary reduction in species richness and permanent reduction in species richness. These explanations are summarised as follows:

Temporary reduction in species richness:

• Weather – with colder winters and more moderate days, reptile species richness declines due to lower levels of activity in exothermic species such as reptiles.

• Higher rainfall – during times of higher rainfall reptile prey species (small mammals, birds, insects and other species) are often more dispersed thus dispersing the reptile predators often making recording of these species more difficult due to reduced density in highly favourable areas.

Permanent reduction in species richness:

• Habitat destruction – much of this area has been denuded of natural habitat thus greatly reducing the number of species, and abundance of individuals of the species, historically occurring in the area.

• Persecution – reptiles, particularly snakes, are one of the most severely persecuted taxa in the world and are usually killed due to fear or superstition.

• Food – many reptile species, particularly terrapins and tortoises, are utilised as a food source and in areas with high population density, such as the study area, these species and the abundances of individuals are greatly reduced.

4.7.2 Amphibia

There are 91 species of anurans (frogs and toads) recorded in Malawi. Only five species of anurans were recorded during the April 2017 field surveys, including Breviceps mossambicus, Amietophrynus gutturalis, Amietophrynus garmani, Hyperolius pusillus and Kassina senegalensis (Hudson Ecology, 2017a). None of the species recorded are classified as being restricted in abundance or distribution,


although Malawi does host a number of endemic species, and none of the species recorded are listed under the IUCN Red List.

4.7.3 Avifauna

About 646 species from 78 families, comprising 456 residents, 94 intra-African migrants of regular occurrence (most of which probably breed in Malawi), 77 regular and 12 vagrant Palaearctic species have been documented in Malawi (Hudson Ecology, 2017a). Over a third of all bird species in Malawi are considered to be uncommon or rare and of at least limited conservation concern. Ninety-four birds in Malawi are restricted range species, found in only one or a few biomes, but there are no true national endemic bird species. Only fifty-six (56) species of avifauna were recorded during the April 2017 field surveys. None of the species recorded during the 2017 survey are restricted in range or abundance, and none of the species recorded are currently listed on the IUCN Red List. Species recorded during the field survey are included in Appendix B.

4.7.4 Mammalia

About 195 species of mammal species from 37 families have been recorded in Malawi. Only twenty-eight (28) species of mammalia were recorded during the April 2017 field surveys, and are listed in Appendix B. None of these species are classified as species of conservation importance. The number recorded is far lower than the expected number of species for this area. The reduction in number of species recorded in the area, during the April 2017 study can be attributed to a number of factors namely:

• Destruction of habitat. • Introduction of domestic animals which outcompete and predate indigenous species. • Overutilisation of mammal species as a food source. • Reduction of prey species (particular prey species for larger mammalian predators, which

would compete with humans in rural Africa).

4.8 Wetlands

4.8.1 Wetland Delineation

Wetland delineation was conducted as part of the biodiversity survey undertaken in April 2017. The delineation was undertaken according to the Guidelines for Delineating the Boundaries of a Wetland set out by the South African Department of Water Affairs (DWA, 2008) in the absence of Malawi guidelines on this aspect. Due to the transitional nature of wetland boundaries, these are often not apparent and the delineations should therefore be regarded as a human construct. The delineations are based on scientifically defensible criteria and are aimed at providing a tool to facilitate the decision making process regarding the assessment of the significance of impacts that may be associated with the proposed development (Hudson Ecology, 2017b).

The wetlands were delineated by considering the following wetland indicators:

• Terrain unit indicators help identify those parts of the landscape where wetlands are most likely to occur. Wetlands occupy characteristic positions in the landscape and can occur on the following terrain units: crest, midslope, footslope, and valley bottoms.

• Soil wetness indicator identifies the morphological signatures developed in the soil profile as a result of prolonged and frequent saturation.

• The vegetation indicator identifies hydrophytic vegetation associated with frequently saturated soils.


Based on the conceptual mining footprint and an assessment of the watersheds in the area, three wetlands (dambos) were delineated as part of the study; one falls within the Project area (Dambo 1) and two (Kankoma dambo and Kovuma dambo) occur to the north of the Project area (Figure 4.5).

The Kankoma and Kovuma dambos flow in a west-east direction. As with the vast majority of the dambos in the area, these two dambos have been impacted to a significant degree through anthropogenic impacts such as impoundments, cropping, grazing and overutilisation of natural resources. These dambos have, however, not been completely transformed as is the case with other dambos in the area.

Dambo 1 occurs in the southern part of the Project area draining southwards into the Kazumu Dam II. This dambo has been completely transformed and performs very little, or no, functionality usually associated with wetlands. Transformation has occurred through the natural vegetation being removed throughout the wetland in order to be replaced by agriculture; mainly in the form of maize (Zea mays) and groundnuts (Arachis villosulicarpa). Almost all aspects of this dambo have been severely impacted or transformed through anthropogenic impacts such as cropping, impoundments, grazing and overutilisation of natural resources, and this dambo can be characterised as transformed.

4.8.2 General Floristic Attributes A total of 109 species of plants, associated with wetland and riparian systems, were recorded in the study area during the April 2017 surveys (Hudson Ecology, 2017b).

Generally the most common species across all three of the wetlands surveyed are Cyperus esculentus, Cyperus tenax, Kylinga erecta, Typha domingensis, Aristida junciformis, Andropogon eucomus, Arundinella nepalensis, Cynodon dactylon, Echinochloa pyramidalis, Heteropogon contortus , Hyparrhenia filipendula, Hyparrhenia nyassae, Hyperthelia dissoluta, Melinis repens, Pogonarthria squarrosa, Sporobolus pyramidalis, Bidens biternata, Bidens pilosa, Conyza albida, Euphorbia tirucalli, Oldenlandia corymbosa, Oldenlandia herbacea, Senecio strictifolius, Solanum delagoense, Tagetes minuta, Verbena bonariensis, Dichrostachys cinerea, Gmelina arborea, Senna alata and Piliostigma thonningii.

Six monitoring sites were established in the Project area (Figure 4.5); three were located across the Lilongwe River (upstream and downstream of the Kamuzu Dam), with another three in each of the three identified dambos. Species diversity varies considerably across the six monitoring sites with the Kankoma dambo and the riparian monitoring site upstream of the Kamuzu Dam showing the highest species diversity with 58 and 70 species respectively, while the sites with the lowest species diversity being Kovuma dambo and Dambo 1 located in the Project site, with 45 and 37 species respectively.


Figure 4.5: Wetlands in and around the Project Area


4.8.3 Wetland Conditions

4.8.3.1 Kankoma Dambo

Similar to the other wetlands (dambos) within the study area, Kankoma dambo has been severely impacted. This wetland has been canalised to a lesser extent than the other wetlands in the area, furthermore the wetland has been impounded to allow for vehicle and pedestrian traffic. Although many of the graminoid and cyperoid species expected still occur in the area, some woody species such as Senna alata have encroached upon the canal. Although a large number of indigenous species are still present on site, a large number of exotic species have invaded the wetland areas. These likely originate from surrounding agricultural areas and seed dispersal through means of vehicles. Exotic species present on this site include Bidens biternata, Bidens pilosa, Helichrysum sp, Sesbania microphylla, Solanum delagoense, Tagetes minuta and Verbena bonariensis. Cyperoid species include Cyperus digitatus, Cyperus esculentus, Cyperus tenax, Kylinga erecta and Pycreus aethiops. While Typha latifolius and Typha domingensis are also present in areas where water persists. The majority of wetlands in the area are severely degraded and grass species occurring in these wetlands include Andropogon gayanus, Aristida junciformis, Arundinella nepalensis, Brachiaria deflexa, Cynodon dactylon, Eragrostis capensis, Eragrostis chapelieri, Hyparrhenia filipendula, Melinis repens, Pogonarthria squarrosa, Setaria pumila, Sporobolus pyramidalis, Sporobolus subtilis and Themeda triandra. This wetland is severely overgrazed and canalisation and erosion both occur frequently in this wetland.

4.8.3.2 Kovuma Dambo

Similar to the other wetlands, Kovuma dambo has been severely impacted. This wetland has been considerably canalised causing the desiccation of the outer to edges of the wetland causing the encroachment of terrestrial grass species, such as Themeda triandra and woody species. Although many of the graminoid and cyperoid species expected still occur in the area, the number of these species has been greatly reduced from the number of expected species in the area. There is encroachment of some woody species, such as Senna alata, in the channel, and the dambo is also being impacted on by the cultivation of water intensive species such as Eucalyptus spp in the adjacent areas. Many exotic species such as Bidens pilosa, Blumea alata, Conyza albida, Eucalyptus saligna, Psidium guajava, Sesbania microphylla, Solanum delagoense, Tagetes minuta, Verbena bonariensis and Lantana camara are present at this site. Cyperoid species include Cyperus digitatus, Cyperus esculentus and Cyperus tenax. While Typha domingensis is present and in certain areas dominates where water persists. The majority of wetlands in the area are severely degraded and grass species occurring in these wetlands include Andropogon gayanus, Aristida junciformis, Brachiaria deflexa, Cynodon dactylon, Eragrostis capensis, Eragrostis chapelieri, Melinis repens, Pogonarthria squarrosa, Sporobolus pyramidalis and Themeda triandra is present in areas where the dambo has been desiccated through the canalisation of the valley.

4.8.3.3 Dambo 1

Dambo 1 can only be described as completely transformed from an ecological point of view. This means that very little, if any, of the ecological function of the wetland still remains. This area is also colonised by exotic species in many areas, the infestation by exotic species ranges from mild to severe in various areas of the dambo. Small areas (<1 ha) of natural vegetation occur very sparsely within this dambo, tree species recorded in this dambo area include mainly Senna alata, with the odd Kigellia africana and Piliostigma thonningii, individuals being recorded on the edge of cultivated lands. The grass and sedge layers of this dambo have been virtually eradicated and are limited to regrowth in fallow lands where species such as Aristida junciformis, Arundinella nepalensis, Cynodon dactylon,


Hyparrhenia filipendula, Pogonarthria squarrosa and Sporobolus pyramidalis are emergent. Forb species are dominated by alien invasive species such Bidens biternata, Bidens pilosa, Solanum delagoense, Tagetes minuta, Agave sp. Opuntia sp. and Verbena bonariensis.

4.9 Aquatic Biology

As part of the environmental scoping study, six aquatic biomonitoring4 sites (MML1, MML2, MML3, MMDR, MMD1 KAN and MMD2 KO) were established on the Lilongwe River, a drainage channel and two dambos (GCS, 2017). One site, Site MML1, was assessed upstream of the Project area on the Lilongwe River. Two sites, Sites MMD1 KAN (located at the Kankoma dambo) and MMD2 KO (located at the Kovuma dambo), were assessed upstream of the Project area on the opposite side of the watershed. Two sites, namely, Sites MML2 and MML3, are located downstream of the project area on the Lilongwe River, while Site MMDR is located within the Project area. Six toxicity sample points were also selected to coincide with these biomonitoring sites. Diatoms and toxicity levels (on four trophic levels) were analysed on these water samples. The positions of these biomonitoring and toxicity sampling points are presented in Figure 4.6.

4.9.1 Habitat Integrity

The general habitat integrity of each site was assessed using the Intermediate Habitat Integrity Assessment (IHIA) as adapted by Kemper (1999) for application in rapid intermediate habitat assessments. Results obtained from this index were used to aid in the interpretation of the biotic integrity results. The method assesses the present ecological state (PES) of both the instream and riparian zone habitat integrity in terms of impacts such as water abstraction, flow and channel modifications, inundation and water quality. Scores are allocated according to the extent of the impact related to each factor and total scores for instream and riparian zone integrity are summed up and averaged to provide an overall percentage for the PES of the general habitat integrity. The method classifies the PES into one of six classes, ranging from unmodified/natural (Class A), to critically modified (Class F) (Table 4.3).

Table 4.3: Classif ication of Present Ecological State Classes in Terms of General Habitat Integrity (Kemper, 1999)

Class Description Score (% of total)

A Unmodified, natural. 90-100

B Largely natural, with few modifications. 80-89

C Moderately modified. 60-79

D Largely modified. 40-59

E Extensively modified. 20-39

F Critically modified. <20

4 Aquatic biomonitoring (or biological monitoring) is a tool in determining the condition of aquatic ecosystems by considering the functional and/or structural aspects of biological communities.


Figure 4.6: Location of Aquatic Biomonitoring Sites


The general habitat integrity at Sites MML1 and MML2 was regarded as being moderately modified (Class C); largely natural with few modifications (Class B) at Site MML3; critically modified at Site MMDR (Class F); unmodified and natural at Site MMD1 KAN (Class A); and largely modified (Class D) at Site MMD2 KO. These classifications are based on the assessment as per Table 4.4. Refer to Figure 4.6 for the location of these sites.

Table 4.4: IHIA Results for the Wet Season (High Flow Conditions) in April 2017

IHIA Scores MML1 MML2 MML3 MMDR MMD1 KAN

MMD2 KO

Instream Score (%) 79.0 79.00 81.3 18.5 96.8 51.2

Riparian Score (%) 80.7 80.1 79.6 5.07 97.6 34.1

Overall Score 79.9 79.6 80.5 11.8 97.2 42.7

Class C C B F A D

Sites MML1, MML2 and MML3 exhibited limited impacts on water quality; moderate impacts on flow at Site MML1; moderate impacts resulting from inundation at all three sites; and the presence of exotic macrophytes at Sites MML2 and MML3.

Moderate impacts resulting from flow modifications at Site MMDR were evident, with extensive impacts as a result of water abstraction, bed and channel modifications, water quality modifications and exotic macrophyte encroachment.

At Site MMD1 KAN, limited instream impact has occurred as a result of water quality modifications. Moderate impacts resulting from water abstraction, bed and channel modifications, water quality modifications, inundation, and exotic macrophyte encroachment have occurred at Site MMD2 KO.

Extensive riparian zone impacts have occurred at Site MML1 as a result of inundation. A moderate impact is evident as a result of inundation at Site MML2, and moderate impacts have resulted from indigenous vegetation removal and exotic vegetation encroachment at Site MML3. Site MMDR has been largely impacted on by indigenous vegetation removal, exotic vegetation encroachment, bank erosion, water abstraction, channel modifications and water quality modifications. Site MMD1 KAN has experienced limited impact with regards to water quality modifications and Site MMD2 KO has been largely impacted on by indigenous vegetation removal, exotic vegetation encroachment and flow modifications.

4.9.2 Habitat Suitability

The integrity of the instream and riparian habitat has a direct influence on the structure of the aquatic community. The Integrated Habitat Assessment System (IHAS) (version 2) was used to determine the suitability of the habitat, specifically for the requirements of the macro-invertebrate community (McMillan, 1998 as cited in GCS, 2017). The contribution of different biotopes (Table 4.5) was calculated to determine the final IHAS score, which reflects the overall habitat integrity of the site. The results of the IHAS assessment conducted at the biomonitoring sites during the wet (high flow) season survey in April 2017 are presented in Table 4.5.


Table 4.5: Integrated Habitat Assessment System (IHAS) Results for the High Flow Season

IHAS Biotopes Assessed MML1 MML2 MML3 MMDR MMD1 KAN

MMD2 KO

Stones in Current (SIC) 0 18 14 0 0 0

Vegetation (VEG) 13 9 11 0 10 11

Gravel, Sand and Mud (GSM) 7 8 15 2 10 9

Physical Stream Condition 27 19 29 28 21 21

Total Habitat Score 7 35 14 14 42 10

Total IHAS 47 54 69 30 41 41

Site MML3 on the Lilongwe River obtained the highest IHAS score with regards to habitat suitability required for the colonisation of the macro-invertebrate community (Table 4.5). The habitat integrity at Sites MML1, MML2 and MMDR was found to be inadequate to support a diverse macro-invertebrate community. This is likely to be attributed to the flood conditions observed at Sites MML1 and MML2, and due to channel modification and diversion at Site MMDR. Flood conditions were observed at Site MML3. However, as the site was downstream of a road bridge, the flow was intercepted by the bridge pillar occurring instream which created more suitable habitat for the community.

The habitat integrity at Sites MMD1 KAN and MMD2 KO was also found to be inadequate to support a diverse macro-invertebrate community. As these two systems do not contain flowing water and lacked the presence of stones in current, results from the application of the IHAS at these points are not necessarily a true reflection of the state of the habitat. Application of the IHIA is therefore likely to give a more accurate indication of the general habitat integrity at these two sites.

4.9.3 Aquatic Macro-Invertebrate Integrity

Aquatic macro-invertebrate assemblages are widely used as biological indicators to assess the health of aquatic environments. Aquatic macro-invertebrates were sampled using the qualitative South African Scoring System Version 5 (SASS5) sampling method. In the absence of a Malawi-specific approach for the assessment of macro-invertebrate integrity, this index was used to determine the condition of each site. The survey undertaken in April 2017 considered the SASS5 Score and the number of macro-invertebrate taxa per site to determine the average score per taxon (ASPT Score). The methodology applied by Tambala et al. (2016) (as cited in GCS, 2017) was then used as a guideline to determine the PES class for each biomonitoring site as detailed in Table 4.6.

Table 4.6: Reference Conditions for Sandy and Rocky River Systems-based ASPT Scores (Tambala et al., 2016)

Class Description ASPT (Sandy) ASPT (Rocky)

A Unmodified, natural. >6.9 >7.9

B Largely natural, with few modifications. 5.8 - 6.9 6.8 - 7.9

C Moderately modified. 4.9 - 5.8 6.1 - 6.8

D Largely modified. 4.3 - 4.9 5.1 - 6.1

E/F Seriously to critically modified. <4.3 <5.1


The results from applying the SASS5 assessment framework to the six biomonitoring sites are indicated in Table 4.7.

Table 4.7: SASS5 Results for the Wet (High Flow) Season in April 2017

Aspect MML1 MML2 MML3 MMDR MMD1 KAN

MMD2 KO

SASS5 Score 49 44 74 15 71 54

Number of Taxa 12 9 11 3 15 12

ASPT Score 4.1 4.9 6.7 5.0 4.7 4.5

PES Class E/F E/F C E/F D D

With regards to the SASS5 assessment, the macro-invertebrate integrity at Site MML3 was regarded as being in moderately modified (Class C) condition, which is the highest class obtained for all sites. Site MML3 obtained the highest SASS5 and ASPT score of 74 and 6.7, respectively, indicating a high macro-invertebrate diversity and sensitivity (Table 4.7). This is mainly attributed to the slower, more diverse flow and habitat compared to the upstream Site MML2 as a result of the presence of the instream road bridge pillar as mentioned previously.

Site MMDR, which is considered to have a macro-invertebrate community integrity that is currently in a severely to critically modified (Class E/F) state, achieved the lowest SASS5 score indicating that the diversity of the community was found to be poor at this site. The ASPT score was found to be higher at this point compared to Sites MML1 and MML2, which were both also found to be in a severely to critically modified (Class E/F) condition. However, as only three taxa were present at Site MMDR, this score is not likely to be a true reflection of the ecological sensitivity of the site in terms of water quality. In addition, as the Lilongwe River was in flood during the time of assessment, the interpretation of the SASS5 results for Sites MML1, MML2 and MML3 in terms of water quality is limited. An assessment during the normal high flow regime, when the river is not in flood, is therefore required for a more accurate interpretation of the state of the macro-invertebrate community structure at these sites.

The integrity of the macro-invertebrate community at both Sites MMD1 KAN and MMD2 KO were found to be in a largely modified (Class D) state. This is likely a result of the limited habitat diversity due to the lack of flowing water and the absence of the stones habitat. The elevated pH level at Site MMD1 KAN and the slightly elevated EC level measured at Site MMD2 KO are also likely to contribute to this PES class. Site MMD1 KAN obtained a higher SASS5 and ASPT score in relation to Site MMD2 KO which is likely a result of better habitat availability and water quality at Site MMD1 KAN. A good diversity of macro-invertebrates was observed at Site MMD1 KAN, and the sensitivity of the macro-invertebrate community was slightly higher at Site MMD1 KAN in relation to the community present at Site MMD2 KO. The lower sensitivity at Site MMD2 KO was likely a result of the slightly elevated EC level measured at this point. This may be mainly attributed to runoff from the villages and the agricultural fields in the surrounding areas. Spatial variation on the Lilongwe River indicates a 33.7% increase in the SASS5 score between Sites MML1 and MML3, which is indicative of increased macro-invertebrate diversity at Site MML3. This is likely a result of better habitat availability at Site MML3. The ASPT score also increased in a downstream direction by 38.8% between Sites MML1 and MML3, which is also likely a result of better habitat availability at Site MML3.


4.10 Hydrology

4.10.1 Catchment Areas

Malawi's drainage system is divided into 17 Water Resources Areas (WRAs), which are subdivided into 78 Water Resources Units (WRUs).

The Project area is situated within the designated Linthipe Water Resources Area (WRA 4) with a catchment area totalling 8 885 km2. The Linthipe WRA comprises a number of river basins WRUs. The Project is located in the Lilongwe WRU (4D) with a sub-catchment area totalling 1 615 km2 (Figure 4.7).

Sub-catchments in the Project area are indicated in Figure 4.8.

4.10.2 Rivers, Streams and Dams

The Lilongwe River boarders the southern and eastern sides of the Project site. The Lilongwe River flows eastwards into the Kamuzu Dam and from the dam towards the northeast to the City of Lilongwe (refer Figure 1.1 and Figure 4.9). The Lilongwe River is the main supply of water to the City of Lilongwe.

The Kamuzu Dam is located directly to the south of the Project on the Lilongwe river and is divided into Kamuzu Dam I and Kamuzu Dam II. The 18 m high Kamuzu Dam I has a storage capacity of approximately 5.2 Mm3. The 24 m high Kamuzu Dam II has a storage capacity of approximately 19 Mm3.

The two dams have a combined catchment area of approximately 1,870 km2 and act as water balancing reservoirs for the Lilongwe River. The Project area covers less than 2 per cent of this area.


Figure 4.7: Regional Catchment Areas: Linthipe WRA and Lilongwe WRU


Figure 4.8: Sub-catchments in the Project Area


4.10.3 Surface Water Quality

Surface water quality sampling was undertaken during April 2017 and December 2017 to establish a baseline profile of the surface water quality in the Project area. Samples were taken from five locations (MM ST1, KZ1, KZ2, KZ4 and KZ5), with two sites upstream of the Project area, one within and two sites downstream of the Project area. These monitoring locations are indicated in Figure 4.9.

Samples were analysed by an accredited laboratory, WaterLab, in South Africa. The results of the analysis are detailed in Table 4.8 and compared to the Malawi Drinking Water Standard.

Surface water localities MM-ST1, KZ1 and KZ2 indicated elevated conductivity and manganese concentrations exceeding the Malawi Drinking Water Standard. Elevated aluminium concentrations were detected at KZ2, while elevated iron concentrations were present at all sampling sites. Antimony concentrations were elevated at all sites during the December 2017 sampling period, but not during April 2017. The remaining concentrations were all low.

Monitoring of these sites will continue to be undertaken on a quarterly basis throughout 2018 to obtain representative baseline water quality data.

Table 4.8: Laboratory Results of Analysis of Surface Water Quality Samples

Parameters Units Malawi Drinking

Water Standard

Date MM-ST1 KZ1 KZ2 KZ4 KZ5

pH in water at 25ºC 5-9.5 Apr 17 6.9 7.7 7.4 7.6 7.8 Dec 17 5.3 8 7.5 7.8 8

Conductivity in mS/m @ 25ºC

mS/m 5-10 Apr 17 28 5.8 15 7.9 7.8 Dec 17 39.8 8.8 8 7.6 8.2

TDS (0.7µm) @ 105ºC mg/l 70-150 Apr 17 150 45 60 <20 <20 Dec 17 316 70 58 56 66

Calcium mg/l 80-150 Apr 17 23 4.6 5.3 4.5 6.8 Dec 17 34.6 6.7 5.8 5.6 6.1

Potassium mg/l 25-50 Apr 17 2.7 1.6 3.5 2.6 1.8 Dec 17 4.5 1.5 1.6 1.5 1.6

Magnesium mg/l 30-70 Apr 17 10 1.2 1.4 1.3 2.1 Dec 17 13.6 1.9 1.7 1.8 2

Sodium mg/l 100-200 Apr 17 13 5.7 5.7 6.5 5.8 Dec 17 14.9 7 6.1 6.1 6.1

Phosphorus mg/l

Apr 17 0.04 <0.03 0.3 0.04 <0.03 Dec 17 0.19 0.096 <0.010 0.182 <0.010

Sulphur mg/l

Apr 17 38 0.55 9.1 2.7 1.6 Dec 17 - - - - -

Silicon mg/l

Apr 17 13 9.8 9.5 8.6 8.5 Dec 17 23.8 6.8 7.1 6.8 7.4

Silver mg/l

Apr 17 <0.008 <0.008 <0.008 <0.008 <0.008 Dec 17 <0.01 <0.010 <0.010 <0.010 <0.010

Aluminium mg/l 0.15-0.3 Apr 17 0.004 0.016 0.086 0.07 0.019 Dec 17 0.193 <0.001 0.385 <0.1 0.143

Arsenic mg/l 0.01-0.5 Apr 17 0.001 0.001 0.003 0.001 <0.0005 Dec 17 <0.01 <0.010 <0.010 <0.010 <0.010

Boron mg/l

Apr 17 <0.002 <0.002 0.005 0.002 0.002 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Barium mg/l

Apr 17 0.036 0.015 0.36 0.018 0.017 Dec 17 0.076 0.023 0.022 0.02 0.025

Beryllium mg/l

Apr 17 <0.005 <0.005 <0.005 <0.005 <0.005 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Bismuth mg/l

Apr 17 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005


Parameters Units Malawi Drinking

Water Standard

Date MM-ST1 KZ1 KZ2 KZ4 KZ5

Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010 Cadmium mg/l 0.003-0.005 Apr 17 <0.0001 <0.0001 <0.0001 <0.0001 <0.0001

Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010 Cobalt mg/l 0.25-0.5 Apr 17 0.014 <0.0004 0.002 <0.0004 <0.0004

Dec 17 0.080 <0.010 <0.010 <0.010 <0.010 Chromium mg/l 0.05-0.1 Apr 17 0.008 0.004 0.009 0.004 0.004

Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010 Copper mg/l 0.5-1 Apr 17 0.001 0.001 0.001 0.001 0.001

Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010 Iron mg/l 0.01-0.2 Apr 17 0.06 0.12 2.8 0.61 0.058

Dec 17 29.98 0.56 0.47 0.12 0.303 Lithium mg/l

Apr 17 <0.002 <0.002 <0.002 <0.002 <0.002 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Manganese mg/l 0.05-0.1 Apr 17 0.63 0.004 0.49 0.067 <0.002 Dec 17 2.45 0.234 0.078 0.034 0.087

Molybdenum mg/l

Apr 17 <0.001 <0.001 0.002 <0.001 <0.001 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Nickel mg/l 0.05-0.15 Apr 17 0.013 <0.001 0.001 0.001 <0.001 Dec 17 0.025 <0.010 <0.010 <0.010 <0.010

Lead mg/l 0.01-0.05 Apr 17 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Antimony mg/l 0.005-0.01 Apr 17 <0.01 <0.01 <0.01 <0.01 <0.01 Dec 17 0.047 0.075 0.051 0.05 0.042

Selenium mg/l 0.01-0.02 Apr 17 <0.002 <0.002 <0.002 0.002 <0.002 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Tin mg/l

Apr 17 <0.002 <0.002 <0.002 <0.002 <0.002 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Strontium mg/l

Apr 17 0.15 0.032 0.038 0.035 0.045 Dec 17 0.21 0.047 0.039 0.038 0.036

Thorium mg/l

Apr 17 <0.003 <0.003 <0.003 <0.003 <0.003 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Titanium mg/l

Apr 17 0.001 0.002 0.006 0.004 0.001 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Thallium mg/l

Apr 17 <0.003 <0.003 <0.003 <0.003 <0.003 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Uranium mg/l

Apr 17 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Vanadium mg/l 0.1-0.2 Apr 17 0.003 0.003 0.003 0.003 0.002 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Tungsten mg/l

Apr 17 <0.006 <0.006 <0.006 <0.006 <0.006 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Zinc mg/l 3-5 Apr 17 <0.05 <0.05 <0.05 <0.05 <0.05 Dec 17 0.457 0.01 <0.010 0.021 0.027

Zirconium mg/l

Apr 17 <0.007 <0.007 <0.007 <0.007 <0.007 Dec 17 <0.010 <0.010 <0.010 <0.010 <0.010

Chloride mg/l 100-200 Apr 17 1.3 1.6 1.8 2.8 1.7 Dec 17 7 2 2 2 2

Fluoride mg/l 0.7-1.0 Apr 17 0.28 <0.05 <0.05 0.12 0.25 Dec 17 <0.2 0.2 0.2 0.2 0.2

Nitrite mg/l 6-10 Apr 17 <0.5 <0.5 <0.5 <0.5 <0.5 Dec 17 - - - - -

Nitrate mg/l 6-10 Apr 17 0.2 0.2 <0.1 <0.1 0.5 Dec 17 - - - - -

Sulphate mg/l 200-400 Apr 17 76 0.21 <0.05 0.22 1.9 Dec 17 164 2 2 3 4

Mercury µg/l

Apr 17 <0.001 <0.001 <0.001 <0.001 <0.001 Dec 17 <0.001 <0.010 <0.010 <0.010 <0.010

Note: Highlighted Values Exceed the Malawi Drinking Water Standard Upper Limit


Figure 4.9: Surface and Groundwater Monitoring Locations


4.11 Hydrogeology

4.11.1 Groundwater Levels

Groundwater users within, and in close proximity to, the Project area were identified and the coordinates, elevations, water levels, use and equipment of the boreholes identified were recorded. These groundwater sampling locations were selected in an attempt to determine the existing groundwater levels and quality within the Project area, as well as upstream and downstream from the Project site.

Static groundwater levels could not be measured at MAL PS BH, MM-CW3, MM-CW4, MM-CW5, MM-CW7, MM-CW2 and MM-CW1 where these localities are fitted with hand water pumps and measuring the static groundwater level is not possible as the borehole is sealed off.

The average static groundwater level is 6.7 metres below surface level (mbsl).

4.11.2 Groundwater Quality

Groundwater quality sampling was undertaken during April 2017 and December 2017 from existing community water boreholes, hand dug wells and exploration boreholes at the locations indicated in Figure 4.9. Samples were analysed by an accredited laboratory, WaterLab, in South Africa. The results of the analysis are detailed in Table 4.9 and compared to the Malawi Drinking Water Standard.

Groundwater at all sampling sites indicated elevated conductivity levels above the Malawi Drinking Water Standard, with the majority of these sites indicating elevated concentrations of total dissolved solids (TDS) above the standard. Elevated aluminium concentrations were detected at MM-CW1, MM-CW5 and MM-CW6, while elevated iron concentrations were present at five of the eleven sampling sites. Manganese concentrations exceeded the Malawi Drinking Water Standard at MAL PS BH, DD03, MM-CW1, MM-CW2 and MM-CW5. Antimony concentrations were elevated at the majority of the sampling sites during the December 2017 sampling period, but not during April 2017. The remaining concentrations were all low.

Monitoring of these sites will continue to be undertaken on a quarterly basis throughout 2018 to obtain representative baseline water quality data.


Table 4.9: Results of Laboratory Analysis of Groundwater Samples

Parameters Units Malawi

Standard- Drinking

Water

Date MGA C80

MAL P5 BH DD-02 DD-03 MM-

CW1 MM-CW2

MM-CW3

MM-CW4

MM-CW5

MM-CW6

MM-CW7

pH in water at 25ºC 5-9.5 Apr 17 7.6 7.6 8.4 8.3 7.2 8.2 8.4 8.1 8.1 8.5 8.4 Dec 17 - 6.2 7.2 7.4 6.7 6.9 7.5 6.7 7.2 7.5 7.5

Conductivity in mS/m @ 25ºC mS/m 5-10

Apr 17 13 24 36 29 27 36 51 30 15 40 65 Dec 17 - 25.1 37.6 28.3 16.3 40.1 40.7 30.6 15 42.6 32.1

TDS (0.7µm) @ 105ºC mg/l 70-150 Apr 17 120 240 250 260 180 210 410 190 110 220 210 Dec 17 - 224 274 240 140 338 306 236 100 316 244

Calcium mg/l 80-150 Apr 17 7.9 12 36 25 23 42 62 25 9.1 44 34 Dec 17 - 10.6 33.8 27.4 8.7 43.7 38.8 23.3 8 58.6 29.9

Potassium mg/l 25-50 Apr 17 1.8 6.5 5.1 9.6 2.6 4.4 4.7 4.1 5.8 2.4 3.7 Dec 17 - 5.5 3 4.2 4.5 3.7 3 3.4 4.4 3.8 3

Magnesium mg/l 30-70 Apr 17 4 13 16 10 10 12 20 13 6.1 20 14 Dec 17 - 12.7 17.6 10.8 7 11.8 18.6 13.3 7.6 26.3 13.8

Sodium mg/l 100-200 Apr 17 12 12 16 15 13 15 21 14 8.7 13 12 Dec 17 - 10.55 14.33 13.03 6.77 13.01 16.13 11.76 5.75 16.51 10

Phosphorus mg/l Apr 17 <0.03 <0.03 <0.03 0.04 <0.03 <0.03 <0.03 <0.03 0.04 0.05 <0.03 Dec 17 - - - - - - - - - - -

Sulphur mg/l Apr 17 16 31 13 17 39 34 37 21 5.8 4.2 6.5 Dec 17 - - - - - - - - - - -

Silicon mg/l Apr 17 20 25 24 26 13 31 31 24 12 33 31 Dec 17 - 27.08 25.92 30.51 22.24 33.78 33.43 27.27 13.73 51.73 35.1

Silver mg/l Apr 17 <0.008 <0.008 <0.008 <0.008 <0.008 <0.008 <0.008 <0.008 <0.008 <0.008 <0.008 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Aluminium mg/l 0.15-0.3 Apr 17 0.085 0.027 <0.003 0.039 0.006 <0.003 <0.003 <0.003 0.22 <0.003 <0.003 Dec 17 - <0.01 <0.01 <0.01 0.56 <0.01 <0.01 <0.01 0.83 1.96 <0.01

Arsenic mg/l 0.01-0.5 Apr 17 <0.0005 <0.0005 <0.0005 0.001 0.001 0.001 <0.0005 <0.0005 <0.0005 0.002 0.001 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Boron mg/l Apr 17 0.004 0.002 0.002 0.003 <0.002 0.002 0.003 <0.002 <0.002 <0.002 0.003 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Barium mg/l Apr 17 0.068 0.02 0.11 0.11 0.046 0.021 0.052 0.042 0.11 0.11 0.057 Dec 17 - 0.025 0.089 0.088 0.215 0.027 0.063 0.051 0.154 0.228 0.069

Beryllium mg/l Apr 17 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Bismuth mg/l Apr 17 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01



Standard- Drinking

Water Date MGA

C80 MAL P5

BH DD-02 DD-03 MM-CW1

MM-CW2

MM-CW3

MM-CW4

MM-CW5

MM-CW6

MM-CW7

Cadmium mg/l 0.003-0.005

Apr 17 <0.0001 <0.0001 <0.0001 <0.0001 <0.0001 <0.0001 <0.0001 <0.0001 <0.0001 <0.0001 <0.0001 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Cobalt mg/l 0.25-0.5 Apr 17 <0.0004 0.003 <0.0004 0.005 0.01 0.002 0.001 <0.0004 <0.0004 <0.0004 <0.0004 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Chromium mg/l 0.05-0.1 Apr 17 0.007 0.012 0.023 0.015 0.006 0.016 0.024 0.015 0.01 0.027 0.021 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Copper mg/l 0.5-1 Apr 17 <0.0009 0.006 0.001 0.002 0.001 <0.0009 0.001 0.002 <0.0009 <0.0009 0.002 Dec 17 - 0.011 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Iron mg/l 0.01-0.2 Apr 17 0.08 <0.05 0.085 0.13 0.075 0.1 0.15 0.055 0.12 0.11 0.08 Dec 17 - 0.12 0.04 4.21 6.6 1.87 0.15 0.6 3.42 1.25 0.05

Lithium mg/l Apr 17 <0.002 0.013 <0.002 <0.002 <0.002 0.007 0.003 <0.002 <0.002 <0.002 0.002 Dec 17 - 0.011 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Manganese mg/l 0.05-0.1 Apr 17 <0.002 0.16 <0.002 0.002 0.59 0.23 0.081 <0.002 <0.002 <0.002 <0.002 Dec 17 - 0.14 0.04 0.78 0.78 0.25 <0.025 <0.025 0.46 0.4 <0.025

Molybdenum mg/l Apr 17 <0.001 <0.001 0.001 0.002 <0.001 <0.001 0.001 <0.001 <0.001 0.001 <0.001 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Nickel mg/l 0.05-0.15 Apr 17 0.001 0.021 0.003 0.01 0.011 0.004 0.005 0.004 0.001 0.001 0.001 Dec 17 - 0.014 <0.01 0.019 <0.01 <0.01 <0.01 0.055 <0.01 <0.01 <0.01

Lead mg/l 0.01-0.05 Apr 17 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Antimony mg/l 0.005-0.01 Apr 17 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Dec 17 - 0.056 0.030 0.015 0.015 0.031 0.066 0.036 0.033 0.022 0.03

Selenium mg/l 0.01-0.02 Apr 17 0.003 0.002 0.003 <0.002 <0.002 <0.002 0.002 0.004 <0.002 <0.002 <0.002 Dec 17 - <0.01 <0.01 <0.01 <0.01 0.002 0.004 <0.01 <0.01 <0.01 <0.01

Tin mg/l Apr 17 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Strontium mg/l Apr 17 0.089 0.025 0.12 0.097 0.15 0.11 0.15 0.1 0.09 0.18 0.092 Dec 17 - 0.021 0.102 0.063 0.081 0.103 0.133 0.086 0.074 0.162 0.072

Thorium mg/l Apr 17 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Titanium mg/l Apr 17 0.007 0.003 0.003 0.005 0.001 0.003 0.003 0.002 0.011 0.004 0.003 Dec 17 - <0.01 0.021 0.017 <0.01 0.025 0.032 0.013 0.025 0.051 0.016

Thallium mg/l Apr 17 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Uranium mg/l Apr 17 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01



Standard- Drinking

Water Date MGA

C80 MAL P5

BH DD-02 DD-03 MM-CW1

MM-CW2

MM-CW3

MM-CW4

MM-CW5

MM-CW6

MM-CW7

Vanadium mg/l 0.1-0.2 Apr 17 0.003 0.002 0.004 0.003 0.004 0.004 0.006 0.002 0.003 0.017 0.023 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.013

Tungsten mg/l Apr 17 <0.006 <0.006 <0.006 <0.006 <0.006 <0.006 <0.006 <0.006 <0.006 <0.006 <0.006 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Zinc mg/l 3-5 Apr 17 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.09 <0.05 <0.05 <0.05 Dec 17 - 0.026 0.044 0.028 0.027 <0.01 0.065 0.014 0.017 0.118 0.024

Zirconium mg/l Apr 17 <0.007 <0.007 <0.007 <0.007 <0.007 <0.007 <0.007 <0.007 <0.007 <0.007 <0.007 Dec 17 - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Chloride mg/l 100-200 Apr 17 1.1 0.72 1.9 1.5 1.2 1.1 1 2.1 2.5 3 1.7 Dec 17 - <2 7 <2 <2 <2 <2 2 2 4 2

Fluoride mg/l 0.7-1.0 Apr 17 <0.05 0.48 0.1 0.05 0.28 0.19 0.48 0.22 0.37 0.99 0.38 Dec 17 - 0.3 0.2 <0.2 <0.2 0.3 0.2 0.2 0.2 0.6 0.2

Nitrite mg/l 6-10 Apr 17 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 Dec 17 - - - - - - - - - - -

Nitrate mg/l 6-10 Apr 17 2.9 0.8 16 0.9 0.1 <0.1 2.7 12 0.6 3.7 7.1 Dec 17 - - - - - - - - - - -

Sulphate mg/l 200-400 Apr 17 19 61 22 28 75 66 75 37 9.3 6.5 11 Dec 17 - 91 39 41 35 108 55 66 10 13 20

Mercury µg/l 1-2 Apr 17 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 Dec 17 - <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

Note: Highlighted Values Exceed the Malawi Drinking Water Standard Upper Limit


4.12 Social Environment

4.12.1 Administrative Structures

The Project is located within the Lilongwe District of the Central Administrative Region. Within this District there are 18 Traditional Authorities (TA). The Project site is within TA Masumbankhunda. The access road S124 is located within TA Malili and Lilongwe City. The area earmarked for further detailed social surveys surrounding the Project area also extend into the TA Masula. Within each TA, Area Development Committees (ADC) and Village Development Committees (VDC) provide representation for residents at the area (collection of villages) and village level. Each village has a Village Head or chief.

The TA boundaries have been revised since 2008, when the last national census was undertaken; accordingly, TA level data for the newly defined TAs (which include TA Masumbankhunda) will only be available after the 2018 census has been completed. Data for TA Chiseka has been included in some of the data reported in this section of the report, as the Project area of influence delineated for consideration of socio-economic aspects covers part of this TA, based on the 2008 delineation.

4.12.2 Demographic Profile

The population of Lilongwe District is approximately 2 million, as per the 2008 census, of which approximately one-third live in the city of Lilongwe.

Census data for TA Masumbankhunda and TA Masula are not available as they were enumerated as part of TA Chiseka during the 2008 census. However, they have been estimated as being 62,900 for TA Masumbankhunda and 107,000 for TA Masula in 1998 (Lilongwe District Council, Social Economic Profile, 2017 as cited in AECOM, 2018).

The population of villages within and adjacent to the Project site has not yet been established but will be identified as part of the ESIA process. Traditional structures with thatched roofs and mud walls are common in Lilongwe District.

4.12.3 Ethnic Groups and Religion

Nationally, the dominant groups are the Chewa, Lomwe and Yao peoples. Rural parts of the Central Region are mostly Chewa. Around 15% of the population is Ngoni – a group that traces its history to South Africa (Madise, 2015 as cited in AECOM, 2018).

TA Chiseka (representing the Project area of influence) is predominantly dominated by Chewa, which accounts for 90% of the population. Tumbuka, Yao and Ngoni are also represented. Inter-marriages are frequent between members of different tribes (AECOM, 2018).

As per the 2008 Census, Christianity is the main religion in Malawi, although there is a significant Muslim population. The broader Lilongwe District is mostly Christian, accounting for 83% of the population.

There are four main languages spoken in the Lilongwe District, with Chichewa as the most common, followed by Yao, Tumbuka and Nyanja. Over 94% of the people of Lilongwe speak Chichewa, while English is the official language (AECOM, 2018)


4.12.4 Settlements and Land Use

Lilongwe District has 62% of people living in traditional structures, 17% in permanent houses and the remaining 21% in semi-permanent houses. Traditional housing units are characterised by thatched roofs and mud walls, and may be vulnerable to disasters such as fires and floods. Permanent housing units commonly have iron sheet, tiles, concrete or asbestos roofs, with walls of burnt bricks, concrete or stones, and concrete and paved floors (AECOM, 2017).

The major land use in the area is subsistence cropping and livestock. The main cultivated food crops are seasonal maze, cassava and sweet potato. Cultivated landholdings are small and fragmented and operate under a freehold land tenure system. The villages of Kubale, Ndumila and Kumalindi are the villages in close proximity to the Project area.

4.12.5 Land Tenure

Formal land ownership (owning a land title or deed) is uncommon in Malawi, and only 5 % of men and 2% of women have a formal title for their land. Additionally, rural households are more likely to own agricultural land (83%) than urban households (37%). In the Lilongwe District 35% of women own land alone while 15.5% own land jointly with their husband (NSO, 2017 as cited in AECOM, 2018).

Based on preliminary information provided by government it is understood that land is the Project area of influence is held under freehold title, which is a form of private ownership. This will be reviewed and confirmed as part of the work undertaken for the development of the resettlement action plan (RAP) (AECOM, 2018).

There are several estates identified as being located at or near the Project area. These are owned by either individuals or companies and may be leased to others for their use.

4.12.6 Employment

Economic activity in rural Lilongwe District and the area around the Project site is predominantly subsistence farming, based on small-scale cultivated land and rearing of livestock. Some subsistence fishing occurs in Kamuzu Dam. Formal employment in the private sector (excluding family businesses) and government is minimal.

Employment data available from the 2014 Welfare Monitoring Survey (NSO, 2014 as cited in AECOM, 2018) state that national labour force participation was 83% in 2014 – 2015 (84% for males, 82% for females). In Lilongwe Rural the figure was 86% (89% for males, 84% for females). At 78%, youth labour force participation in Lilongwe Rural was greater than the national average of 70%.

Land near the Kamuzu Dam is suitable for agriculture year-round due to the abundance of water. Crops, livestock products, charcoal and wood products are usually purchased by vendors at the production site or in villages. Some producers sell products directly in markets, usually in Malingunde, Sinyala, or Likuni, but also in Chinsapo and Lilongwe.

According to the 2008 census, there are almost 29,000 farming households in TA Malingunde and 23,600 in Chiseka (which includes TAs Masumbankunda and Masula) with an average land holding size of 0.8 ha and 0.6 ha respectively (compared to an average of 0.7 ha at district level) (AECOM, 2018).


4.12.7 Education

Within Masumbankhunda TA there are 32 primary schools and 3 secondary schools. A small portion of children enrol in secondary school. Teacherpupil ratios are approximately 1:100 for primary schools and 1:15 for secondary schools in Masumbankhunda TA. Nationally, the literacy rate for people over 15 years old is 72% (81% for males, 64% for females), and the median number of years of completed schooling is 5.6 for women and 6.6 for men. Literacy in Lilongwe Rural is lower than the national average at 63% (74% for males, 53% for females).

4.12.8 Health

For the nation as a whole, life expectancy at birth has risen to 62 years in 2015 from an average of 46 years in the 1990s. However, it remains below the global average of around 71 years in 2015. The main causes of death are HIV/AIDS, lower respiratory infections, diarrhoeal diseases, and malaria. Food security is an issue within the area around the Project site, with more than one-quarter of households reporting being without food during the ‘hunger months’ from January to March.

4.12.9 Vulnerable Populations

The vulnerable groups that exist within communities that could be impacted by the Project include:

• Households who are reliant on subsistence agriculture and are vulnerable to drought or crop failure as well as any Project impacts on access to land. This group includes a substantial proportion of the population at and around the Project site.

• Women who have limited financial independence, and who may be impacted by changes in household incomes created by Project opportunities. Women may have lower access to Project opportunities and could be adversely impacted by financial benefits that are principally controlled by men.

• Children who are in or could be drawn into child labour. Child labour is an issue within Malawi and any increase in economic activity and / or pressures on families could result in more children being used for labour.

4.12.10 Services, Facilities and Infrastructure

The Project area includes local access roads and may include tube wells or boreholes that are used to supply drinking water to local residents, schools and communal areas or buildings. The presence and location of these will be subject to confirmation from mapping to be conducted during the ESIA process.

There is a health centre at Malingunde, which serves a population of approximately 40,000 people. The region is experiencing substantial shortages in human resourcing for health care, including doctors and nurses.

4.13 Archaeology and Cultural Heritage

Limited archaeological and heritage research has been done in the Project area to date. However, there is potential to find evidence of human habitation because of the long history of human settlement in the area.

4.13.1 Msinja Sacred Cultural Landscape and Shrines

The most notable cultural feature in the Malingunde area is the living and vibrant Msinja cultural landscape with deep roots in the traditions of the local people who live within and around it. The


Msinja cultural landscape and the associated traditional religious shrine is dated to as early as the 13th century when the Chewa arrived in this part of Africa (Nthara, 1973 as cited in PGS Heritage, 2018). Msinja was a religious city which functioned as a centre of national worship for the Chewa people. It was the site of the great Rain Shrine of the Chewa tribe where sacrifices were offered for rain-making and thanks-giving during heavy harvest (Rangeley, 1952 as cited in PGS Heritage 2018). The original sacred site was located on top of Dzalanyama, in Kaphirintiya hill. On the site, there is a sacred forest in which there is a rock with imprints on it, and it is believed by the Chewa to be the footprints of the first man and woman (McFareen, 1986 as cited in PGS Heritage, 2018).

The stretch of land from the hills of Kaphirintiya to the lowland on the Malawian side (eastern side of the hill) is referred to as Msinja because it is alleged that when the first Chewa people arrived in the area they heard the sound of pounding of mortars, kusinja, but they could not see any people. The proto-Chewa Shrine at Kaphirintiya was managed by a woman priestess with the title of ‘Makewana’, the mother of all people (Nthara, 1973). The priestess was of the Banda clan and was not allowed to be married since she was considered to be the wife of ‘Chisumphi’ (the priestess of God head). The role of Makewana was to mediate between Chisumphi and the Chewa nation, directing prayers to their deity (Chisumphi) (Van Breugel, 2001 as cited in PGS Heritage, 2018). Makewana also acted as a secular authority in all matters, apart from religious aspects, before the arrival of the Phiri Clan who invaded them and took over the secular authority of the land (Rangeley, 1952). However, she was assisted by a male priest called ‘Kamundi Mbewe’ who was also her protector and 'Tsang’oma', the drum beater, who used to call people to the shrine and a number of young girls called ‘Matsano’ who have not reached puberty stage. All people who were involved in the affairs of the shrine used to wear black cloths.

Carlos Wiese, a German official in the Portuguese service described the shrine at Msinja as the “Mecca of the Maravi”. This was because all the Chewa chiefs from Zambezi in Mozambique, Lwangwa in Zambia, to Kasunga in Malawi, Lake Malawi and beyond, made their annual pilgrimages to Msinja to pray for rains and posterity in their homes. Msinja was a very popular and busy city. In 1830, Gamito, a Portuguese traveller, noticed some commercial activity taking place at Msinja. It is also reported that David Livingstone visited Msinja in 1867 (PGS Heritage, 2018).

Msinja city was well designed. At the centre was the temple where sacrifices were offered. The sacred temple was served by various functionaries. Five officials, who included Makewana, formed the nucleus of Msinja city, (Schoffeleers, 1999 as cited in PGS Heritage, 2018). They lived at the centre of the city very close to the temple. Other functionaries lived in 11 villages that surrounded the city. These villages were similar to what we now call locations or residential areas (Rangeley, 1952 as cited in PGS Heritage, 2018).

4.13.2 The Nyau Sacred Cult and Dambwes

Since the original and predominant population living in this proposed mining project area is the Chewa, they are commonly referred to as Nyau societies. The Nyau is a secret and sacred cult, involving the ritual dance practiced among the Chewa people in Malawi. These people keep their dancing costumes in sacred places called dambwes (forest patches which also act as meeting places of the Nyau secret societies. This tradition has been included on the United Nations Educational, Scientific and Cultural Organization (UNESCO) Representative List as a masterpiece of intangible cultural heritage under the 2003 Intangible Cultural Heritage Convention, and thus it has a global significance. There is the likelihood of finding these dambwes in this Project area.


4.13.3 Graves

Several ancestral grave sites, as well as cemeteries are scattered throughout the Project area and will require further detailed assessment during the ESIA. This will include the localisations of ancestral graves and royal graves of traditional leaders which have cultural and historical significance to the local communities.


5 Stakeholder Engagement

5.1 Purpose of Stakeholder Engagement

The objectives of engaging stakeholders during the ESIA process include the following:

• Creating an understanding of the Project: an open, inclusive and transparent process of culturally appropriate engagement and communication will be undertaken to ensure that stakeholders are well informed about the Project. Information will be disclosed as early and as comprehensively as possible.

• Involving stakeholders in the assessment: stakeholders will be included in the scoping of issues, the identification of impacts, the generation of mitigation and management measures, and the review of the ESIA report. They also play an important role in providing local knowledge and information as baseline data that will inform the impact assessment.

• Building relationships: through supporting open dialogue, engagement helps establish and maintain a productive relationship between the ESIA team and stakeholders; and eventually between stakeholders and the operating mining company.

• Engaging vulnerable groups: an open and inclusive approach to consultation increases the opportunity of stakeholders to provide comment on the Project and to voice their concerns. Some stakeholders, however, need special attention during the consultation process due to their vulnerability. Special measures will be considered to ensure that the perspectives of vulnerable stakeholders are heard and considered.

• Ensuring compliance: The process is designed to ensure compliance with both local regulatory requirements and the IFC performance standards. One of the key outcomes of engagement should be free, prior and informed consultation of stakeholders, where this can be understood to be:

o free: engagement free of external manipulation or coercion and intimidation; o prior: engagement undertaken in a timely way, for example the timely disclosure of

information before a development is undertaken and or participation is sought regarding the identification of issues of concern; and

o informed: engagement enabled by relevant, understandable and accessible information.

5.2 Objectives

Engagement during the scoping phase of the ESIA aims to integrate stakeholder issues within the ESIA process from an early stage. It enables stakeholders to raise issues of concern and suggest ways to enhance benefits to the community from the Project. It also provides stakeholders with an opportunity to evaluate alternatives and to contribute relevant local knowledge to the process.

Stakeholder consultation undertaken during the scoping phase had the following objectives:

• Introduce the Project and the ESIA process to stakeholders and obtain clarification with regard to the most suitable community engagement approach.

• Notify other stakeholders of the Project and ESIA process. • Identify stakeholder issues of concern. • Formally initiate the engagement process and introduce the engagement team.


• Provide stakeholders with an opportunity to ask questions and give input on the proposed ESIA process and Project.

• Table and elicit comment on the findings from the draft ESR.

5.3 Stakeholder Engagement during the Scoping Phase

5.3.1 Identification of Stakeholders

Stakeholders who may potentially be affected by or have an interest in the Project were identified and a database developed. Details of individual stakeholders are compiled in a stakeholder register which will be periodically updated throughout the ESIA engagement process. Such information is kept on a database for ease of use but details are not shared with any third party.

As part of stakeholder identification and analysis process, it is important to identify individuals and groups who may find it more difficult to participate and those who may be differentially or disproportionately affected by the Project because of their marginalised or vulnerable status. It is also important to understand how each stakeholder may be affected – or perceives he/she may be affected – so that engagement can be tailored to inform them and address their views and concerns in an appropriate manner.

Table 5.1 details the various stakeholder groups that were identified following the announcement of the Project in December 2017, which was the first step in the environmental scoping phase. These stakeholder groups will be expanded on throughout the ESIA according to the individuals and groups who were consulted and/or registered as stakeholders, also referred to as Interested and Affected Parties (I&APs).

A detailed list of stakeholders consulted to date is included as Appendix C.

Table 5.1: Categories of Stakeholder Groups Identif ied during the Scoping Phase

Stakeholder Category Stakeholder Groups Interest in the Project

Government National regulatory bodies, including, among others: Ministry of Natural Resources, Energy and Mining; Environmental Affairs Department (EAD); Department of Mines; Ministry of Land, Housing and Urban Development; Department of Lands and Valuation; Department of Antiquities

National government is of primary importance in terms of establishing policy, granting permits or other approvals for the Project, and monitoring and enforcing compliance with Malawian law throughout all stages of the Project life-cycle.

District regulatory bodies and key parastatal authorities: Lilongwe District Council; Lilongwe Water Board

One district authority and several parastatal organisations (e.g. Lilongwe District Council and Lilongwe Water Board) are impacted by the Project and will be informed of progress and plans in their areas, to consider the Project activities in their policy-making, regulatory and other duties and activities.

Traditional authorities (TAs)

Chiefs and village heads Local community leaders, acting as representatives of their local community. Meetings with TAs will follow local customs and will be held prior to any wider


Stakeholder Category Stakeholder Groups Interest in the Project

communication in local communities to respect the prevailing political and social structures.

Communities Project affected communities including registered and customary land owners, residents and occupiers of land, people who use and access land resources

Households and communities that may be directly or indirectly affected by the Project and its activities.

Vulnerable groups Women and children headed households, elderly, disabled, youth, ethnic minorities, etc.

Vulnerable groups may be affected by the Project by virtue of their physical disability, social or economic standing, limited education, and/or lack of access to land.

Civil society and NGOs

Associations, groups, community-based organisations (CBOs), cultural groups and NGOs

Organisations with direct interest in the Project, and its social and environmental aspects and that are able to influence the project directly or through public opinion. Such organisations may also have useful data and insight, and may be able to become partners to the Project in areas of common interest.

Commerce and industry (including the media)

Local businesses and entrepreneurs affected by potential social and/or environmental impacts, and potential suppliers and contractors

Individuals or organisations with direct economic interest in the Project. This may be through gaining contracts with the Project or due to economic impacts caused by the Project.

Bilateral and multilateral organisations

Development agencies and financial institutions

A range of different international organisations may have an interest in the Project.

5.3.2 Background Information Document

A background information document (BID), including a registration and comment form, was compiled in English and translated into Chichewa. The BID contained information on the Project, ESIA process, stakeholder consultation and ESIA team, and invited stakeholders to complete the registration form and submit comments as part of the process. It also provided contact details where additional information could be obtained.

A copy of the BID was made available at all stakeholder meetings and distributed to I&APs on the database who were unable to attend these meetings.

Additional copies of the BID were also made available at the DC offices and provided to the TAs to distribute among community members.

Copies of the BID in English and Chichewa are attached in Appendix D.

5.3.3 Project Announcement

The Project and ESIA process was announced through a series of stakeholder meetings from 4-7 December 2017, as detailed in Table 5.2. These meetings involved stakeholders at national, district and local level.


Table 5.2: List of Project Announcement Meetings

Meeting Venue Date

Environmental Affairs Department; Department of Mines

EAD Monday, 4 December 2017 – 10:00

Various Ministries and Government Departments; Member of Parliament for Malingunde; Friends of Malingunde

Cross Roads Hotel Monday, 4 December 2017 – 14:00

Lilongwe District Council District Council Offices Tuesday, 5 December 2017 – 10:00 Lilongwe Water Board Lilongwe Water Board Wednesday, 6 December 2017 – 10:00 Non-government Organisations; Community Services Organisations (CSOs); CBOs

Cross Roads Hotel Wednesday, 6 December 2017 – 14:00

Traditional Authorities; District Council representatives

District Council Thursday, 7 December 2017 – 10:00

The purpose of these meetings was to provide stakeholders with information about the Project, introduce the ESIA team and proponent, provide information about the ESIA process, and give I&APs and opportunity to raise questions and issues. A presentation was given at these meetings, which was based on the information contained in the BID, and a copy was made available to stakeholders on request.

The attendance register of each meeting is attached as Appendix E.

5.3.4 Environmental Scoping Meetings

A series of meetings will be held between 7 and 9 March 2018 to present and discuss the contents of the draft ESR. The scheduled meetings are detailed in Table 5.3 and invitations to attend these meetings were sent to the relevant stakeholders.

Table 5.3: List of Environmental Scoping Meetings

Meeting Date / Venue

Ministries / Departments / Parastatals • Ministry of Mines and Energy • Ministry of Lands, Housing and Urban

Development • Ministry of Agriculture, Irrigation and Water

Development • Ministry of Transport and Public Works • Ministry of Local Government and Rural

Development

• Environmental Affairs Department • Department of Mines • Department of Antiquities • Department of Roads • Department of Lands and Valuation • Department of Irrigation and Water Development

• Malawi Roads Authority

Wednesday, 7 March 2018 – 10:00 Cross Roads Hotel


Meeting Date / Venue

• Lilongwe Water Board • National Water Resource Authority (NWRA) • Malawi Energy Regulatory Authority (MERA)

• Chamber of Mines and Energy • Member of Parliament

Lilongwe District Council

TA Masumbankhunda - in the Project Area • Development Committees (village and area – VDC

and ADC) • Chiefs

Wednesday, 7 March 2018 – 14:00 District Council Offices

TA Chigwirizano - Along Access Road • Development Committee (village and area – VDC

and ADC) • Chiefs

Thursday, 8 March 2018 – 10:00 District Council Offices

NGOs / CBOs / CSOs Thursday, 8 March 2018 – 14:00 Cross Roads Hotel

Community meetings in the Project Area Friday, 9 March 2018 – 09:00

Information meeting with the media Friday, 9 March 2018 – 14:00 Cross Roads Hotel

The aims of these meetings are to:

• Present a summary of the contents of the draft ESR. • Identify key issues and concerns that require further assessment during the ESIA phase. • Present the terms of reference (ToR) for the specialist studies to be undertaken. • Discuss the extent of, and approach to, the detailed ESIA phase.

Comments received will be incorporated into the revised comments and response report, and the ESR will be amended where deemed necessary

5.3.5 Review of Draft Environmental Scoping Report

This draft ESR was made available to the public for review and comments on 5 March 2018. An electronic copy is available on Sovereign's website http://sovereignmetals.com.au/building-malingunde/. Hard copies of the report can be viewed at:

• Offices of C12 Consultants – Office Number 7, Skyband Complex, off Paul Kagame Rd, Lilongwe.

• Offices of the Environmental Affairs Department. • Lilongwe District Council Offices. • Masumbankhunda Traditional Authority.

A copy of the report on CD can also be obtained from McCourt Mining's offices in Lilongwe.

The availability of the draft ESR was advertised in the Nation and Daily Times newspapers on x February 2018. Copies of the advertisements are attached in Appendix F.

http://sovereignmetals.com.au/building-malingunde/

http://sovereignmetals.com.au/building-malingunde/


Stakeholders may submit comments and queries relating to this report and the Project until 13 April 2018. Comments received will be incorporated into the revised comments and response report, and the ESR will be amended where deemed necessary. A revised version will be submitted to the EAD in early May 2018 for review and approval.

5.3.6 Grievance Mechanism

Stakeholder engagement is a two-way process. Therefore, it is important to ensure that there is a grievance mechanism to allow stakeholders affected by or interested in the Project to present their input (e.g. opinions, requests, suggestions, feedback and grievances) for consideration and, if required, seek redress.

A grievance mechanism has been developed (Appendix G) and will be communicated to stakeholders during the scoping engagement meetings, as well as the draft ESIA engagement meetings. A dedicated representative (e.g. community liaison officer) will be appointed for the Project, who will be responsible for grievance management. Grievances will be passed through the representative in the first instance, who will be responsible for passing the grievance on to the appropriate person according to the Project grievance mechanism.

The grievance mechanism will be updated throughout the life of the Project and continue to be implemented during the construction and implementation phases of the Project.

5.4 Issues Raised to Date

A variety of views, issues and concerns have been raised by stakeholders to date. The specific issues raised by stakeholders are detailed in the comments and response report in Appendix H.

The most pertinent issues raised and comments received thus far are as follows:

• Mining as an industry is a relatively new concept for Malawi and resistance can be expected, especially in terms of resettlement and compensation.

• Resettlement and compensation should be conducted according to international standards (timely information, consultation with those who may be impacted, and proper compensation is required).

• In terms of relocation, it is important to ensure that those who have to potentially be moved understand where they will be relocated to and ensure that they are satisfied with the new location.

• The exact project boundaries and communities that need to be relocated needs to be identified and communicated.

• Consultation with stakeholders at all levels and throughout all phases of the ESIA process is critical.

• A transparent ESIA process during which stakeholders can access information in a timely manner, provide their comments, and consideration is given to comments, is required.

• The ESIA team should work closely with civil society organisations, NGOs, and affected households.

• Impact on ground and surface water sources, particularly the Kamuzu Dam need to be identified and assessed.

• Impact on roads and communities along the access road should be considered. • Impact on soils and land capability need to be identified and assessed. • Impact on cultural heritage and graves need to be considered carefully. • Impacts, including cumulative impacts of the process should be assessed and associated

mitigation measures should be developed (e.g. water, roads, soils, social, etc.).


• Rehabilitation and closure of the mine is a priority; all alternatives should be assessed and information about the proposed plans should be discussed.

• Information should be provided on planned social development programmes associated with the project, including corporate social responsibility programmes and a community development agreement.

• Information on the boundaries of the Project and which stakeholders will be impacted is required.


6 Preliminary Identification of Key Issues One of the main aims of the environmental scoping study is to identify issues and potential environmental and social impacts that require further investigation and assessment as part of the ESIA. The issues and potential impacts identified are based on issues and concerns received during consultation with stakeholders, as well as issues identified by various specialists based on initial desktop reviews, field surveys and experience on similar projects elsewhere. These issues form the basis of further assessment and studies during the ESIA phase.

Feasible and practical management measures to reduce potential negative impacts will be proposed based on the analysis and assessment of the impacts. These management measures will form the basis of an ESMP that will be included in the ESIA report. It is likely that potential impacts could be successfully mitigated through appropriate measures incorporated into the design of the Project, as well as the implementation of an ESMP throughout the LOM.


Impacts on soil may occur because of the proposed mining and related activities. Such impacts may result from the stripping and stockpiling of topsoil, polluted water run-off, spillages of hydrocarbons and/or chemicals and erosion. Such impacts may further alter nutrient, chemical and physical properties of the soil, thus impacting on its ability to support certain land uses post closure.

The use of heavy machinery during the construction process is likely to result in the compaction of soil, leading to decreased infiltration of rain water and increased surface run-off volumes and velocities, increasing the risk of erosion.

Project activities will lead to the exposure and disturbance of soil, which may be prone to erosion by water and wind. The amount and intensity of rainfall, soil type and structure and the slope of the terrain will influence the rate of erosion. This could contribute to existing siltation impacts in the Kamuzu Dam, altering water quality through increased turbidity and substrate composition of the receiving aquatic environments.

The potential lack of suitable topsoil for use during rehabilitation and closure may impact the successful revegetation of distributed areas, and impact on future land uses.

6.2 Terrestrial Biodiversity

6.2.1 Clearing of Vegetation

The clearing of vegetation is likely to be the greatest impact on the vegetation communities affected by the Project, and all types of vegetation communities on site are likely to be affected by this impact to some extent. Vegetation clearing may result in displacement of fauna (mammals, birds, reptiles and amphibians) and the loss of foraging and breeding sites, as well as movement corridors.

6.2.2 Habitat Degradation due to Dust

Dust is likely to be caused by excavation of the pits, hauling ore or waste along unsealed roads, stockpiling ore at the processing plant and dumping waste at the WRD and TSF. Increased levels of dust in the area is likely, particularly in the dry season. Dust settling on plant material can reduce the amount of light reaching the chlorophyll in the leaves, thereby reducing photosynthesis, which in turn reduces plant productivity, growth and recruitment.


6.2.3 Accidental Contamination by Toxic Substances

The accidental spillage of harmful or toxic substances, including hydrocarbons, chemicals and contaminated water, may impact on the fauna and flora of the area in a number of ways. Direct pathways include ingestion of the substances by fauna species resulting in toxicity in that individual, uptake of chemicals by the roots of plants which may lead to toxicity in the plants, and the chemicals entering the plant or animal's system due to contact (through the skin, leaves or stems). Indirect pathways include the ingestion of contaminated plants or animals by other herbivorous or predatory species.

6.2.4 Disturbance of Fauna

Vibration from heavy machinery and vehicles can affect a number of subterranean fauna taxa, such as burrowing mammals, reptiles and arthropods. Vibration affects these animals by causing the collapsing of burrows, and result in these animals leaving the area.

Noise could also affect a wide range of taxa including avifauna, mammals, reptiles, amphibians and arthropods.

Local migrations of fauna in the area may be affected by hauls roads, excavation of pits and waste facilities, due to these areas forming a barrier to migrating animals or reducing the chance of an animal surviving its migration due to collisions with vehicles on the haul roads.

6.3 Wetlands

6.3.1 Loss of habitat

A portion of the transformed dambo in the central part of the Project area may be impacted by the development of the open pits. Loss of the wetland habitat may also result in permanent loss or displacement of the biota, including invertebrates, birds, amphibians and mammals (e.g. water mongoose and possibly otter) dependent on wetland habitats for feeding, shelter and breeding purposes.

6.3.2 Sedimentation of Dambos

The dambos to the north of the Project area may be impacted by sediment eroded or blown off exposed soil after vegetation clearing and/or soil stockpiling. Marginal habitats could be modified by excessive growth of reeds in the deposited sediment as well as increased invasion by alien vegetation.

Erosion of the sides slopes of soil stockpiles, the WRD and the TSF, and movement of this eroded sediment into the valley bottoms may lead to increased sedimentation within the wetlands, which in turn could influence water flow and vegetation.

6.3.3 Invasion by alien vegetation

Clearance of existing vegetation is likely to result in an increase in alien invasive trees, such as Sesbania, and invasive shrubs, such as bugweed and Lantana. Invasive alien trees, have the most severe impacts on aquatic ecosystems as they out-compete indigenous trees, thus affecting overall biodiversity. Dense stands of invasive trees tend to shade out understorey plants such as sedges, reeds and grasses, thus exacerbating erosion of exposed soil and reducing the availability of habitats for riparian species.


6.4 Aquatic Ecology

Potential changes in water quality as a result of surface water run-off includes increased levels of suspended solids, siltation, dissolved solids, trace metals, and changes in dissolved oxygen concentrations and pH values. Changes in water quality could impact on aquatic biodiversity in the Kamuzu Dam and river systems.

Increased sedimentation of aquatic systems could potentially affect macroinvertebrate communities, decrease photosynthesis and impact fish populations.

An increase in metal concentrations in surface water systems due to mining activity may increase the risk of metal accumulation in aquatic biota, although this is considered to be unlikely. This in turn could have implications for public health if fish are consumed by local communities who are dependent on the rivers and dam as a source of subsistence fishing.

6.5 Geochemistry

Excavation of ore, stockpiling of ore and disposal of waste rock and tailings may lead to the generation of acid mine drainage (AMD), which could degrade the quality of surface and groundwater sources. AMD is generated when sulphide containing rock and soils are exposed to air and water and seeps into the environment. Preliminary investigations indicate that sulphides on site have already been oxidised to sulphates. Therefore, little or no acid generating potential is expected in the saprolite zone.

In addition, the potential for leaching of metals and salts under neutral or saline conditions need to be investigated and confirmed.

Although deemed unlikely to occur, the potential for AMD and will be confirmed through detailed studies undertaken as part of the feasibility studies for the Project.

6.6 Hydrology

The construction of Project infrastructure components such as open pits, processing plants, WRDs and the TSF will require the separation of clean and dirty surface water run-off through the diversion of stormwater from these areas. Diversion of stormwater may result in changes to surface water availability in areas in close proximity to the Project.

Decreased infiltration of rain water and increased surface run-off volumes and velocities are likely to result due to compaction of soil, increasing the risk of erosion from areas devoid of vegetation. This may result in an increase in siltation of the Kamuzu Dam and Lilongwe River downstream of the Project area.

In the event that mining pits are left as open voids upon closure, the recovery of groundwater to original levels would result in these pits filling with water.

Wastewater and surface water run-off from the Project may contain various pollutants, including hydrocarbons, chemicals, AMD and other dissolved contaminants, that could impact water quality in dambos, the Kamuzu Dam and Lilongwe River.


6.7 Hydrogeology

Excavation of the open pit will be to a depth of approximately 25 m, which is likely to be below the current groundwater level, leading to groundwater flowing towards and into the pit area. Dewatering of the pits will be required to ensure safe working conditions and that the pit does not fill with water. Potential impacts include reversed groundwater gradients and reduced discharge into streams and rivers.

Dewatering of the pits may reduce groundwater levels some distance away from the Project area, resulting in decreased availability of water for local communities who are dependent on shallow groundwater wells for domestic use, agricultural activities and stock water.

Contamination of the groundwater could result from seepage from the mine infrastructure and waste materials, i.e., TSF and WRD. In addition, accidental spills and leaks of hydrocarbons and reagents used in processing could leach into the groundwater.

6.8 Air Quality

The activities carried out over the life of the Project are likely to result in dust generation that could impact nearby communities. Dust generation is expected from vegetation clearance, land disturbance, soil stockpiling, haulage of materials, handling of ore and waste rock material and other related activities. Vehicle movement along access roads are also key activities that will contribute to dust generation.

Mining activities are likely to result in an increased emission of exhausts gases, by vehicles and the use of generators, which may have an impact on air quality.

Activities associated with the construction and operation of the Project, particularly increased vehicle and equipment use and the use of diesel generators, are likely to result in an increase in greenhouse gas emissions.

6.9 Noise and Vibration

Construction activities, the increase in the number of heavy vehicles and equipment for mining operations, processing of ore and day-to-day activities could increase the level of noise at nearby communities and along the access road. An increase in noise levels could have an impact on the perceived nuisance levels from the mining operations at sensitive receptors.

Vibration from heavy vehicles travelling along the access road through local communities could impact houses and structures in close proximity to the road.


The Project may have irreversible impacts on the archaeological and cultural heritage sites that could be identified within the Project area. The land transformation activities during land clearing for construction, mining operations and development of access roads, may result in disturbance and destruction of potential archaeological and paleontological sites, graveyards, and the shrines and sacred sites. Specifically, clearing of forest vegetation areas could result in the disturbance of ancestral graves. The severity of the impact will depend on the proximity of the heritage sites to the Project operational areas.


6.11 Visual Impact

Clearing of vegetation is likely to change the visual character of the landscape and sense of place of the area.

The construction of infrastructure components with large physical dimension (i.e., processing plant, WRD and TSF) in areas that have been cleared of existing vegetation is likely to result in these components being visible over some distance, and in many instances several kilometres.

The visibility of, and increased exposure to heavy vehicles on access roads, especially where villages and houses are located close to these roads may also result in visual impact to these communities.

6.12 Social Impacts

6.12.1 Land Acquisition and Resettlement

The Project may require the acquisition and development of lands that are currently used for residential and agricultural purposes. Without adequate mitigation this could have a significant impact on livelihoods and lead to worse housing, food security, sanitation and health outcomes for affected residents. Such impacts could be long-lasting, and by putting increased pressure on other land and resources could contribute to local conflict related to land ownership and use. In the context of recent drought and food shortages there may be high vulnerability to such impacts.

Land acquisition could also impact community infrastructure that exists within the Project footprint, including water resources and local roads. The RAP is a key mitigation measure for the management of these impacts related to land acquisition.

6.12.2 Creation of Employment Opportunities

Construction and operation of the Project will create new employment opportunities. Some of this labour will be from local communities close to the Project site, as well as from Lilongwe. Project employment will lead to increased household income and the enhancement of local human resources through training and skills development. Further economic benefits will be generated through the procurement of local goods and services, and the creation of indirect employment by suppliers and induced employment as a result of increased incomes being spent locally.

These positive economic impacts could also lead to adverse impacts related to gender equality, and particularly the risk that women do not receive a share of the economic opportunity and have lower control of financial resources. Economic opportunities can also raise expectations, and there could be a risk of these not being met if they are not managed and local hiring and procurement practices are not applied.

6.12.3 Population Influx

The local employment created by the Project could attract people from outside the local area to the communities in direct proximity to the Project site, including Malingunde. The influx of non-locals could include those who take up Project employment, as well as those who come to the area in anticipation of economic opportunities. Influx can lead to informal settlements, increased demand for local community services, poor sanitation practices, and pressure on land and water resources. It could also impact on community well-being, with risks related to transmission of communicable disease (including sexually transmitted infections and respiratory infections), dilution of local norms and customs, and changes in way of life.


The proximity of the Project site to large population centres (Likuni, Lilongwe) may mean that there is lower risk of long-term movement of people to the area close to the Project site; however, the extent of influx risk must be assessed, managed and monitored accordingly. An Influx Management Plan could serve as a key mitigation measure to management impacts associated with influx.

6.12.4 Increase in Traffic

The Project will increase the level of traffic on existing roads during construction and operations. This traffic will include large vehicles, including those hauling equipment and large loads, in areas with pedestrians and road-side businesses and residences. This increase in traffic could create a safety risk to other vehicles and pedestrians along the road-side, as well as impacts to local residents from increased noise and dust.

Road improvement works conducted by the Project will help to reduce these risks, though these works could also create adverse impacts by altering accessibility to road-side businesses and residences during and after the works.

6.12.5 Disturbance and physical impacts to adjacent communities

The Project will create noise and dust which could be experienced at adjacent residences and communities. This could lead to disturbance, and at an extreme, health impacts. Earthworks and water discharges could also create water pooling that increases mosquito presence and spread of vector diseases including malaria.

6.12.6 Improvement in Social Infrastructure

Subject to agreement with national government, community development projects or funding could be created by the Project and be used to improve infrastructure and services at the local and regional level. The specific scope of such projects or levels of funding may not be known for assessment in the ESIA; however, the potential impacts that could be generated will be assessed based on options or scenarios.

6.13 Health Impacts

Mining activities are likely to result in an increase in fugitive dust and exhausts gases, which may impact on human health.

An influx of people in the area could pose risks in terms of community health and safety by increasing the prevalence of communicable diseases.

Stakeholders have indicated that standing water in open voids post closure may increase the risk of mosquito-borne diseases such as malaria.

6.14 Rehabilitation and Closure

The successful closure of the Project at the end of the LOM will be dependent on the acceptability of the proposed end land, extent to which infrastructure components can be rehabilitated and potential future access to mineral resources.

In the event that open pits are not backfilled and left as voids, these will naturally fill with water from groundwater inflow upon closure. This will impact on land use post closure and may impact on community safety and well-being.


Filling of open pits with waste material will be dependent on the availability and competency of waste material. In addition, backfilling of pits could impact on the potential to mine other mineral resources located below the base of the pit.

A rehabilitation and closure plan will be developed as part of the ESIA, which will consider various options for closure.


7 Terms of Reference for ESIA Phase The environmental scoping phase has identified a number of environmental and social issues and impacts (see Section 6) and concerns from stakeholders (Section 5.4 and Appendix H). These potential issues and impacts will require further detailed investigations during the ESIA phase, which will commence following submission of the ESR to the EAD for review.

To adequately describe and assess the potential environmental and social impacts associated with the project, a number of specialist studies are required to be undertaken as part of the ESIA. These studies will focus on the Project area (Figure 2.1) as well as the access route to the site. An outline of the anticipated studies is provided below.

7.1 Stakeholder Consultation

During the impact assessment phase, the primary aim of stakeholder engagement will be to engage I&APs with regard to the results of the specialist studies, the impacts identified and the proposed management measures. Several of the specialist studies to be undertaken are highly consultative in nature (particularly the social impact assessment) and comments and issues raised as part of these studies will be captured in the comments and response report.

The draft ESIA report will be placed at the same venues where the draft scoping report was placed for a 30-day review period and is scheduled for August/September 2018. Stakeholders will be notified by email / advertisements / notifications / posters of the availability of the draft ESIA report for public comment and further stakeholder engagement meetings. A non-technical summary will be compiled, translated and distributed to stakeholders with a comment sheet.

Consultation meetings will be held with the same categories of stakeholders consulted during the scoping phase.

All comments, issues of concern and suggestion received from stakeholders will be included in the comments and response report and amendments to the ESIA report made as required.

The draft ESIA report will be revised based on issues raised during the comment period. The revised document will be submitted to the regulatory authorities to inform the environmental authorisation decision.

Stakeholders will be notified of the decision of the authorities by email / advertisement.

7.2 Terrestrial Ecology – Flora and Vegetation

To determine the impact on the terrestrial ecological environment, it is necessary to supplement the existing information of the area in the ESIA phase for the Project as follows:

• Conduct field surveys of terrestrial fauna and flora during both the wet and dry season at a level that will comply with impact assessments according to IFC Performance Standard 6.

• Map and delineate vegetation types. • Undertake a detailed survey of environmentally sensitive areas to verify and expand upon

existing data, particularly the island of natural vegetation and the natural riparian forest. It is also important to determine the role of these vegetation communities as refuges for fauna species.


• Survey the area for general floristic and faunal diversity (common species, Red List flora and fauna species, alien and invasive plant species) as well as associations between fauna and vegetation communities.

• Undertake small mammal trapping to identify and confirm smaller and cryptic small mammal species present in the area, and to determine the presence or absence of listed mammal species with a high probability of occurrence.

• Undertake point and transect counts for avifauna species in all vegetation communities in order to identify avian assemblages associated with different vegetation communities, and to determine the presence or absence of listed avifauna species with a high probability of occurrence.

• Construct large pitfall traps to identify reptile species occurring in the study area with more precision and to determine the presence or absence of listed reptile species with a high probability of occurrence.

• Assess the potential presence of Red List flora and fauna species, which were identified during the initial survey to have a high probability of occurrence in the Project area.

• Provide detailed descriptions of ecological habitat types, plant communities and faunal assemblages.

• Compile an ecological impact evaluation.

7.3 Wetlands

In order to determine the impact of the proposed development on the biological environment, it is necessary to supplement the existing information regarding wetlands of the area in the ESIA phase for the Project as follows:

• Conduct a detailed field survey in the wet season of environmentally sensitive areas to verify and expand upon the results of the scoping assessment, particularly dambos that may be impacted by the Project.

• Survey representative areas in order to obtain a clear understanding of the nature of sensitivity of the dambos.

• Survey the area for general floristic and faunal diversity (common species, Red List flora and fauna species, alien and invasive plant species) as well as associations between fauna and wetland areas communities.

• Assess the potential presence of Red List flora and fauna species, determined during the scoping phase to have a high probability of occurrence in the Project area.

• Provide detailed descriptions of wetlands and faunal assemblages. • Using the final Project layout and additional information, compile an ecological impact

evaluation.

7.3.1 Aquatic Ecology

The assessment of aquatic resources is deemed necessary to determine any impacts (positive or negative) on the resource and to highlight any significant trends in the water quality. Data obtained from the aquatic ecology survey will be utilised as a reference to compare results from future monitoring undertaken during project development and operation to. This will allow for the quantification of impacts on the surface water system from the proposed project infrastructure and activities.


The aquatic ecology study will include the following:

• Determine the present ecological state of the surface water resources in the vicinity of the Project area. This will include:

o In situ testing of the biota-specific water quality variables including pH, electrical conductivity (EC), dissolved oxygen (DO) and temperature will be carried out to provide an indication of the presence of any stressors in the system. The results will be compared against relevant water quality guidelines and used to aid in the interpretation of the biomonitoring results. Any significant trends in the water quality will also be highlighted.

o General habitat integrity will be assessed using the Intermediate Habitat Integrity Assessment (IHIA) method adapted by Kemper (1999) for application in rapid intermediate habitat assessments.

o Habitat suitability with particular reference to the macro-invertebrate community will be assessed using the Integrated Habitat Assessment System (IHAS Version 2). This index will be used to aid in the interpretation of the SASS5 results.

o The diversity and sensitivity of the macro-invertebrate community will be assessed using the SASS5 index. All assessments will be performed by a River Eco-status Monitoring Programme (REMP) accredited practitioner. The SASS5 results will be evaluated according to the interpretation guidelines set out in Tambala et al. (2016) in order to retain consistency for comparative purposes.

o Diatoms will be sampled and the integrity of the diatom community at these points will be analysed using the Specific Pollution Sensitivity Index (SPSI) which will in turn reflect the quality of the water within these ecosystems.

o Whole Effluent Toxicity (WET) screening tests will be conducted by an accredited laboratory on the water sampled during the survey. The tests will determine the relative toxicity of possible chemicals present in the water samples on selected aquatic organisms.

• Define areas of aquatic ecological sensitivity. • Determine the reference conditions pertaining to fish and molluscs by compiling reference

lists of those species occurring within the Kamuzu Dam and the Lilongwe River within the vicinity of the project area.

• Determine the integrity of the fish communities occurring within these systems. • Determine the baseline levels of metals occurring within fish. • Identify potential impacts (positive and/or negative) the proposed development may have on

the surface water resources and recommend suitable mitigation measures. • Provide recommendations for future monitoring programs. • Use the data obtained to provide ecological input into the ESIA.


The soil study will focus on the identification of the dominant soil forms, the distribution of soil forms, the existing land capability and current land use within the proposed area. The assessment of the impact on soils and land capability will include:

• Conducting a study of the soils present on the Project site through a field survey. A hand soil auger will be used to determine the soil type and depth. The soil will be augered to the first restricting layer or 1.5 m depth. Survey pits dug as part of the geotechnical assessment will also be surveyed to determine soil types and depths.


• The soil forms (types of soil) will be classified according to the Food and Agriculture Organisation (FAO) of the United Nations (World reference base for soil resources) (FAO, 2015).

• Representative soil samples will be taken for fertility and texture analysis in a laboratory from the topsoil (0-0.3 m) and subsoil (0.3-0.6 m) of the dominant soil forms.

• Samples will be analysed for soil acidity, fertility and texture (sand, silt and clay) • Total heavy metal concentrations will be analysed using aqua regia method. • Soils samples will be analysed for acid base accounting (ABA) to determine the potential for

acid generation. This will also be used to identify the risk to the environment by defining areas of potential acid sulphate soils. In the event that acid sulphate soils are identified, management measures to reduce the potential risks to the environment due to the disturbance of acid sulphate soils during construction and operation will be developed.

• Soil samples will be sent to a certified laboratory to determine the gross alpha and beta radioactivity concentration. The gross alpha radioactivity concentration in soils is defined as the total radioactivity of all alpha emitters; while the gross beta radioactivity in soils is due to the natural isotopes 40K, 210Pb and 228Ra. Soil samples will be collected to determine the alpha and beta activity concentration using the alpha and beta counters.

• Determine the land capability and land use by assessing a combination of soil, terrain and climatic features. Land capability will be defined according to the potential for the land to support cultivation.

• Determine the erosion potential of a particular soil based on soil texture, permeability, organic matter content and soil structure.

• Assess the availability of soils for effective rehabilitation. • Identify potential impacts (positive and/or negative) on soils and land capability, and

recommend suitable mitigation measures. • Provide recommendations for future monitoring programs.

7.5 Geochemistry

A detailed geochemical assessment of the waste rock and tailings will be undertaken to determine the potential for the Project to produce AMD and non-acid leachate. This includes:

• Geochemical laboratory testing will be undertaken of waste rock and tailings that are representative of the overall ore body, as well as the metallurgical process to be adopted. This will comprise ABA to determine the acid forming characteristics, together with multi-element analysis. The multi-element analysis is used to identify any element enrichments in the samples.

• Determine the proportion of potentially acid forming (PAF) and non-acid forming (NAF) material in the waste as part of the ABA.

• Undertake limited distilled water extract testing of waste rock samples to allow preliminary assessment of leaching potential.

• Conceptualise flow and dominant geochemical processes. • Determine the risk of seepage and likely volumes and quality of seepage. • Determine the contaminant loads which are likely to report to groundwater. • Develop suitable management measures for the WRD and TSF to limit the potential for

production of AMD and non-acid leachate.


7.6 Water

7.6.1 Surface Water

A specialist surface water study will be undertaken with the aim of predicting potential impacts on surface water resources such as rivers, streams and dams, in particular the Kamuzu Dam and the Lilongwe River. This study will include the following:

• Review all available information and develop a description of the baseline hydrology of the site and surroundings based on climatic data, storm rainfall intensities, topography, density of vegetation, hydrological soil types and catchment characteristics.

• Identify sensitive surface water receptors. • Undertake quarterly surface water sampling from streams, rivers and dams with the Project

area. • Interpret laboratory analysis of surface water samples. • Develop a site wide water and salt balance. • Identify potential impacts (positive and/or negative) the Project may have on surface water

resources. • Develop a stormwater / surface water management plan. • Provide recommendations for future monitoring programs. • Information from the hydrogeological model will be used to make recommendations for

rehabilitation and closure of the area.

7.6.2 Groundwater

A specialist groundwater study will be undertaken as part of the ESIA to determine the potential impact on groundwater sources. As part of the study the following will be undertaken:

• Identification and description of groundwater features. • Determine the type and characteristics of the aquifer, including transmissivity, hydraulic

conductivity, storativity and specific storage • Undertake quarterly groundwater sampling from community boreholes, hand dug wells and

groundwater monitoring boreholes. • Determine the flow direction of the groundwater across the site. • Develop a hydrogeological model. • Interpret water quality data and determine potential impacts. • Determine the dewatering requirements for the operation of the open pits and potential

drawdown of surrounding aquifers. • Undertake an assessment of the impact of drawdown on groundwater users. • Determine the potential impact on groundwater quality from seepage from the TSF and

WRDs. • The potential for AMD will be assessed as part of the geochemistry study, and the results will

be used to develop a numerical model for the mass transport simulations in the hydrogeological model that will be developed. The purpose of the model to simulate groundwater flow and contaminant transport during, and post mining.

• Identify potential impacts (positive and/or negative) the Project may have on the groundwater resources.

• Develop site-specific management measures. • Provide recommendations for future monitoring programs. • Information from the hydrogeological model will be used to make recommendations for

rehabilitation and closure of the area.


7.7 Air Quality

A specialist air quality assessment will be undertaken as part of the ESIA, which will include ambient air quality monitoring, air quality assessment and modelling, as well as a greenhouse gas assessment. The study will include the following activities:

• Installation of dust monitoring units. • Collect monthly dust samples to determine baseline conditions. • Undertake continuous monitoring of gases and particulate matter using a real-time AQ-mesh

monitor. • Undertake passive sampling of man-made anthropogenic VOCs (BTEX – benzene, toluene,

ethylbenzene and xylene (monthly) using Radiello® passive diffusive samplers. • Assessment of site meteorology using modelled data. • Develop an ex ante estimated GHG emissions footprint and reporting framework at Project

level. • Identify potential impacts on air quality and develop site-specific management measures. • Provide recommendations for future monitoring programs.

7.8 Noise and Vibration

A noise and vibration survey and subsequent impact assessment will be undertaken in the vicinity of all noise sensitive areas at the Project boundaries, as well as along proposed haul routes and access roads. As part of the study the following activities will be undertaken:

• Undertake initial baseline noise measurement surveys to determine existing noise levels at the proposed site boundaries and sensitive receptors.

• Undertake noise and vibration surveys on site to determine baseline conditions. • Predict the future noise regime based on the mining method and transportation outside the

proposed boundaries of the site. • Undertake noise and vibration modelling. • Develop mitigation methods, should these be necessary or appropriate.

7.9 Health Impact Assessment

A quantitative human health risk and impact assessment will be conducted as part of the ESIA to determine the significance of the potential impacts to human health from the Project. The assessment will focus on potential health impacts relating to chemical contamination of environmental media, such as the atmosphere, groundwater and surface water. Health risks will be assessed as far as complete source-pathway-receptor linkages can be demonstrated. The study will consist of four interrelated steps as follows:

• Undertake situation assessment and hazard identification, with the purpose of identifying all contaminants suspected to pose hazards to human health.

• Review chemical and physical analysis data of raw materials as well as mining and processing waste materials will be required to characterise the potential hazards and evaluate potential risks.

• Undertake a review of relevant toxicological and epidemiological information to describe how humans can be expected to respond to different doses or concentrations of the contaminants identified at the proposed Project.


• Evaluate whether a complete human exposure pathway exists at or near the proposed Project under reasonably anticipated operational and land-use conditions through a source-pathway-receptor analysis.

• Quantify potential health risks identified through the source-pathway receptor analysis using hazard quotients or cancer risk statements as appropriate.

• Interpret the health risk assessment results in terms of impact assessment criteria.

7.10 Visual Impact Assessment

A visual impact assessment will be undertaken which considers potential impacts associated with temporary activities and infrastructure associated with construction, long-term activities and infrastructure associated with operations, and short-term activities and infrastructure associated with decommissioning of the mine. The assessment approach is focussed on the landscape and the way people perceive the landscape as a visual amenity. The study therefore involves a large geospatial component with activities related to the sourcing, capturing and analyses of geospatial features. The following activities will be undertaken as part of the specialist study:

• Determine the visual baseline of the study area by investigating the context and character of the landscape and how it is perceived by society, including landscape context, visual exposure and identification of sensitive visual receptor areas.

• Identify areas of high viewer incidence to quantify the perceived perception of the observers in these identified areas.

• Develop buffer radii around to model the effect of reduced impact over distance and to identify the point where the impact becomes negligible to observers.

• Determine the visual absorption capacity of the surrounding landscape in terms of the height and density of the natural vegetation cover and the presence of existing man-made structures.

• Assess the impact on sensitive receptors. • Develop mitigation measures.

7.11 Social Impact Assessment

A social impact assessment will be undertaken as part of the overall ESIA process. This process is highly consultative in nature and will require coordination with the stakeholder engagement process. The following activities will be undertaken as part of the study:

• Define the Projects area of interest. • Compile socio-economic baseline profile of the area of interest. • Conduct stakeholder interviews with the purpose of gaining insight into the local Project

context and gather further primary and secondary data. • Undertake site visit over a two-week period with the following aims:

o Meeting with key informants at national and local level. o Locating directly and indirectly affected communities and estimating the number of

households. o Assessing the extent of the area of interest. o Conducting inclusive focus groups to gain insight into key socio-economic variables,

such as community patterns, demographic make-up, key livelihood activities and their distribution, quality and quantity of public infrastructure and social service provision (education, healthcare, sanitation)

o Identification of vulnerable groups.


o Assessment of governance and leadership structures, dynamics and capacity. o Identifying potential population influx hotspots and access routes

• Undertake impact analysis and evaluation. • Develop social indicators to measure social changes over the area of interest over the life of

the Project.

7.12 Resettlement Action Plan

A resettlement action plan (RAP) that is compliant with Equator Principles and IFC Performance Standards, as well as procedures outlined in the IFC’s Handbook for Preparing a RAP, will be undertaken to promote the continuation of displaced households’ standards of living and livelihood strategies post-resettlement. Specifically, the RAP will:

• Systematically define the process of resettlement and associated activities undertaken during planning to ensure displacement is dealt with in a socially and culturally sensitive manner.

• Identify all physical and productive assets in the Project footprint and register all potentially displaced households and communities.

• Identify and assess displacement-related impacts, and recommend measures to mitigate these impacts.

• Ensure the active participation of governmental stakeholders and potentially displaced stakeholders during the land acquisition and resettlement planning and implementation processes.

• Ensure appropriate endorsement from potentially displaced stakeholders through the planning process.

The RAP will be completed by undertaking the following activities:

• Definition of the resettlement-affected area through the delineation of a temporary and permanent Project exclusion zone.

• Identification and categorisation of stakeholders involved in the resettlement process. • Establishment of a resettlement working group (RWG), the primary consultative forum during

the resettlement planning process. The RWG will serve as a channel of communication between Sovereign, displaced communities and government role players, and will advise on orderly and equitable resettlement and compensation activities. The composition of the RWG will ensure that displaced parties are adequately represented and fairly heard.

• Development of a dispute resolution and grievance redress mechanism. • Undertake census and socio-economic survey of all households in the exclusion zone, or who

have assets such as agricultural fields in the exclusion zone. • Compile an asset inventory by means of an asset survey of individually and communal assets

that would be affected through resettlement. • Undertake a quantitative and qualitative assessment of asset, land use and infrastructure

data, as well as the baseline profile to determine expected impacts of resettlement. • Develop a compensation framework which will form the basis of compensation agreements

with displaced households. • Develop an entitlement matrix identifying all categories and affected people, types of losses

and types of compensation and assistance. • Undertake livelihood restoration planning. • Identification and acquisition of sites to which displaced persons can be relocated to. • Develop a resettlement specific monitoring and evaluation framework to assess the

performance, effectiveness and impacts of RAP activities.



A detailed archaeological and cultural heritage impact assessment will be undertaken, which comply with IFC and UNESCO standards. The main aim would be to compile a detailed inventory of the heritage resources within the Project area based on field investigations. The scope of work will include the following:

A detailed site survey will be undertaken using transect walk methodologies of 5-6 experienced archaeological surveyors spaced 15-20 m apart surveying the ground to be affected by the Project. The survey will also cover a buffer zone of 50 m each side of the proposed Project area.

Stakeholders in the area will be consulted to source their views, including traditional leaders, local village elders, land owners and other stakeholders who could provide insight. The stakeholder engagement will mainly aim at determining the significance that the local people and other stakeholders attach to the cultural heritage sites in the proposed Project area.

In order to assess site significance and define the mitigation measures of the sites located within and/or in proximity of the Project area, heritage sites will be classified according to their importance and the required appropriate intervention. The following categories will apply (each category will imply specific mitigation measures to be taken):

• Low Priority Site: No further treatment. • Medium Priority Site: Mapping of the site and controlled sampling required. Further

monitoring during construction to ascertain final priority/importance. • High Priority Site: Further treatment warranted. This can include, but not limited to:

o No-go or relocate development activity position. o Extensive data collection and mapping of the site. o Preserve site.

The prioritisation of a site is not a definite measure of its scientific importance but rather a temporary classification regarding potential and further treatment requirements. In this regard, some high priority sites may well be re-evaluated as non-important after further study. The criteria used to define the value of a site are multiple and complex. However, regarding the area’s archaeological sites the aim is to understand both the history of the region and the way of life of past populations. In this context, the criteria used to evaluate the sites are as follows:

• Age of the finds. • Density and/or variety of the finds. • Context of the finds. • Social significance of the finds. • Precursory archaeological knowledge of the area. • Describe the existing environment associated with the proposed development in terms of its

heritage, archaeology, and palaeontology as well as the sensitivity of the surrounding areas to any change.

Subsurface probing in high, medium, and low potential areas will be undertaken to identify archaeological sites. In order to maximise the number of potentially significant sites identified, the intensity of surface and subsurface investigations would be proportional to the probability of site occurrence. Investigations will be most intensive in high potential areas and least intensive in low potential areas.


Mitigation measures will be developed to avoid the areas of significance or reduce the impacts on heritage resources.


8 Summary and Conclusion Sovereign is currently still engaged in exploration, and as part of the feasibility studies, commenced a PFS in late 2017 which is scheduled for completion in June 2018.

If the results of the PFS are favourable, it is expected the company will be able to commence a DFS in the second half of 2018 which would likely be completed in the first quarter of 2019. Should the feasibility studies prove that mining is viable, and a decision is taken by Sovereign during early 2019 to proceed with the development of the mine, an application for a mining licence will be submitted to the Department of Mines.

One of the main aims of the environmental scoping study is to identify issues and potential environmental and social impacts that require further investigation and assessment as part of the ESIA. The issues and potential impacts identified are based on issues and concerns received during consultation with stakeholders, as well as issues identified by various specialists based on initial desktop reviews, field surveys and experience on similar projects elsewhere. These issues form the basis for further assessment and studies during the ESIA phase.

The most pertinent potential impacts and issues that will be assessed in further detail are:

• Exposure and disturbance of soil. • Increased soil erosion. • Lack of topsoil for rehabilitation. • Clearing of vegetation. • Habitat degradation due to dust. • Impact on flora and fauna through accidental contamination by toxic substances. • Disturbance of fauna through noise and vibration. • Disruption of fauna migration patterns. • Loss of wetland habitat. • Sedimentation of dambos. • Invasion by alien vegetation. • Impact on aquatic biodiversity. • Decrease in surface water run-off. • Deterioration in surface water quality. • Groundwater inflow into open pits. • Impact on groundwater levels through pit dewatering. • Deterioration in groundwater quality. • Creation of acid mine drainage. • Deterioration in air quality. • Increase in noise and vibration. • Disturbance of cultural heritage resources. • Impact from increase in vehicle traffic. • Change in visual landscape. • Land acquisition and resettlement. • Creation of employment opportunities. • Population influx. • Increase in traffic. • Improvement in social infrastructure. • Contribution to the economy. • Rehabilitation of disturbed areas.


A number of Project-specific studies are required to accurately identify and assess important issues and potential impacts associated with the Project. The following studies will be undertaken as part of the ESIA phase:

• Terrestrial flora and fauna. • Aquatic ecology. • Soils and land capability. • Surface water. • Groundwater. • Geochemistry (acid mine drainage). • Air quality and greenhouse gas. • Noise and vibration. • Visual impact assessment. • Social impact assessment. • Resettlement action plan. • Heritage and archaeology. • Health impact assessment.

Stakeholder engagement will continue throughout the ESIA phase; and comments, issues and queries raised will inform the feasibility studies and be incorporated in the ESIA report. The detailed ESIA phase and all specialist studies are expected to be completed by September 2018.

A draft ESIA Report will be compiled and made available for review and comments by stakeholders during the fourth quarter of 2018. Stakeholders will be informed of the availability of all relevant document and reports throughout the ESIA process.


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Report Prepared for Sovereign Metals Limited, Perth, Western Australia.

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Department of Climate Change and Meteorological Services. 2018. Prospects for the 2017/2018 Rainfall Season in Malawi. A WWW publication accessed on 29 January 2018 at https://www.metmalawi.com/forecasts/seasonal.php

Department of Water Affairs and Forestry (DWA). 2008. Updated Manual for the Identification and Delineation of Wetlands and Riparian Areas, prepared by M. Rountree, A. L. Batchelor, J. MacKenzie and D. Hoare. Stream Flow Reduction Activities, Department of Water Affairs and Forestry, Pretoria, South Africa.

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Hudson Ecology. 2017a. Terrestrial Ecology Study for the Proposed Sovereign Metals Malingunde Flake Graphite Project Near Lilongwe, Malawi. Report Prepared for Sovereign Metals Limited, Perth, Western Australia.

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Kemper, N. 1999. Intermediate Habitat Integrity Assessment for Use in the Rapid and Intermediate Habitat Assessments. Version 1. Department of Water Affairs and Forestry, Pretoria, South Africa.

McFareen, W. 1986. History in the Land of Flames: The Maravi States of Pre-colonial Malawi. Berkeley: University of California.

Meteo Blue. 2017. A WWW publication accessed on 12 October 2017 at https://www.meteoblue.com/en/weather/forecast/archive

Nthara, S.J. 1973. The history of the Chewa: with 5 maps. Stuttgart: Steiner.

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