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Mako Gold Project
Environmental and Social Impact Assessment
FINAL
Chapter 9 | Biological Impacts and Management Measures
Chapter 12 | Niokolo-Koba National Park Impacts and Management
Measures
Mako Gold Project
Environmental and Social Impact Assessment
FINAL
Chapter 12 | Niokolo-Koba National Park Impacts and Management Measures
12 NIOKOLO-KOBA NATIONAL PARK IMPACTS AND MANAGEMENT
MEASURES .................................................................................................... 12-1
12.1 PNNK and Priority Species and Habitats ....................................................................................... 12-2
12.1.1 Existing Threats in and around PNNK .............................................................................. 12-4
12.1.2 Current Status of Priority Large Mammal Populations in PNNK ............................. 12-5
12.2 Potential Impacts Associated with Mako Gold Project ............................................................ 12-6
12.3 Avoidance, Mitigation and Management .................................................................................. 12-12
12.3.1 Avoidance ............................................................................................................................... 12-12
12.3.2 Minimisation .......................................................................................................................... 12-12
12.3.3 Rehabilitation / Decommissioning / Closure ............................................................. 12-14
12.4 Residual Impact Assessment and Offsets .................................................................................. 12-14
12.4.1 Residual Impact Assessment ........................................................................................... 12-14
12.4.2 Offset Strategy ...................................................................................................................... 12-18
12.5 Monitoring and Evaluation ............................................................................................................. 12-19
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12 NIOKOLO-KOBA NATIONAL PARK IMPACTS AND MANAGEMENT MEASURES
The purpose of this chapter is to assess Project-related impacts on the Outstanding Universal Values1 (OUVs) of
the Niokolo-Koba National Park (Parc National du Niokolo Koba - PNNK) for which the PNNK is listed as a World
Heritage Site (UNESCO, 2012). This chapter also includes a residual impact assessment and a summary of the
Company’s offset strategy that has been designed to offset residual impacts to ensure ‘no net loss’ of
biodiversity.
The Project lies entirely outside of the PNNK and buffer zone; and is located close to the PNNK, 1 km east of the
PNNK at its closest point (Figure 12-1). The PNNK is one of the largest protected areas in West Africa, spanning
9,130 km2. The PNNK is an internationally recognised area for biodiversity, and has been designated as a natural
World Heritage Site, a UNESCO-MAB Biosphere Reserve and an Important Bird Area (IBA) because of remarkable
biodiversity and a range of ecosystems. The Project is not expected to have any direct impacts to the OUVs of
the PNNK arising from habitat clearance for Project development.
There are important linkages between this chapter and other impact chapters in this ESIA Report. The Project
will not be operating in the PNNK or its buffer zone. An assessment of impacts on priority species and habitats
associated with the Project Development Area (PDA) and Project Study Area is presented in Chapter 10:
Biodiversity Impacts. An assessment of the potential impacts of the Project on physical, biological and social
aspects is presented in Chapters 9, 10, and 11.
Detailed plans related to the management of potential biological impacts, and implementation of biodiversity
offsets, are provided in the following components of this ESIA Report:
Biodiversity Action Plan (BAP), which includes the Company’s biodiversity offset strategy (Volume C);
Technical appendices to this ESIA (Volume A);
Environmental and Social Management and Monitoring Plan (ESMMP, Volume C);
Rehabilitation and Conceptual Mine Closure Plan (RCMCP, Volume E); and
Select chapters of the ESIA (which will be specifically referred to).
1 OUV has been defined as “…natural significance which is so exceptional as to transcend national boundaries and to be of common
importance for present and future generations of all humanity.” (IUCN, 2013)
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Figure 12-1 Project location in relation to the Niokolo-Koba National Park and Senegal's borders
12.1 PNNK and Priority Species and Habitats
Niokolo-Koba National Park (PNNK) was inscribed on the UNESCO World Heritage list in 1981 due to its
Outstanding Universal Values (OUVs) in accordance with Criterion (x)2. The PNNK is listed because it “contains
all the unique ecosystems of the Sudanese bioclimatic zone such as major waterways (the Gambia, Sereko, Niokolo,
Koulountou), gallery forests, herbaceous savanna floodplains, ponds, dry forests - dense or with clearings - rocky
slopes and hills and barren bowés. The property has a remarkable diversity of wildlife, unique in the sub-region. It
counts more than 70 species of mammals, 329 species of birds, 36 species of reptiles, 20 species of amphibians and a
large number of invertebrates”(UNESCO, 2012). “Lions, reputedly the largest in Africa, are a special attraction, as well
as the Derby Eland, the largest antelope in existence. Other important species are also present, such as the elephant,
leopard, African wild dog and chimpanzee “(UNESCO, 2015).
The remote and inaccessible areas of the PNNK are known to be inhabited by many species, including the last
wild population of African elephants (Loxodonta africana) in Senegal. Other threatened species known to
inhabit the PNNK are West African chimpanzees (Pan troglodytes spp verus; hereafter referred to as chimpanzee),
leopards (Panthera pardus), African lions (Panthera leo), African wild dogs (Lycaon pictus), hippopotamus
(Hippopotamus amphibius), West African red colobus (Procolobus badius), western giant elands (Taurotragus
derbianus spp derbianus), hooded vultures (Necrosyrtes monachus) and white-backed vultures (Gyps africanus).
The PNNK is intersected by several major waterways and their tributaries; the Gambia, Niokolo and Koulountou
Rivers are distinctive features of the landscape and also create seasonal grass floodplains. The waterways
provide habitat for the three African crocodile species (Crocodylus sp.), tortoises, as well as numerous species
of fish and invertebrates and other wildlife (e.g. otters). The PNNK also supports many bird species including
2 Contains “the most important and significant natural habitats for in-situ conservation of biological diversity, including those containing threatened species of outstanding universal value from the point of view of science or conservation” (WHC 2013)
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biome restricted species and migratory species which are dependent on freshwater ecosystems as stop-over
points in their annual migratory routes.
Terrestrial and aquatic baseline studies (see Chapter 7) and a Critical Habitat Assessment (TBC, 2015) using
criteria as per IFC PS6 (IFC, 2012) were used to more clearly define the OUVs of the PNNK that are relevant to
the Project. The biodiversity features identified as a priority species and habitats for the ESIA are presented in
Table 12-1. Not all of these species and habitats were identified within the PNNK Study Area nor the Project
Study Area (see Chapter 7: Biodiversity Settings for a definition of the study areas applicable to the Project).
This impact assessment considers impacts to priority fauna that inhabit the PNNK and buffer zone and priority
fauna that are known to range outside these areas into the PDA and Project Study Area (e.g. PNNK ranging
species such as chimpanzees and hippopotami). This chapter also considers impacts to priority habitats and
flora located in the PNNK and buffer zone. Impacts to priority habitat and flora outside of this area (e.g. bowal
habitat in the PDA) do not constitute an impact to the OUVs of the PNNK.
Table 12-1 Priority habitats and species
Type of Risk
Receptor
Priority Biodiversity
Features
Critical
Habitat-
qualifying
IUCN
Status
PDA Project
Study
Area
PNNK
Study
Area
Wider
PNNK
Natural
Habitats (and
fauna
habitats)
Gallery Forest + + +
Bowal + + + +
Gambia River + + + +
Flora
Lepidagathis capituliformis + EN ? ? +
Scleria chevalieri + CR ? ? +
Tephrosia berhautiana + EN ? ? +
Albizia ferruginea VU +
Afzelia africana VU +
Khaya senegalensis VU +
Vitellaria paradoxa VU +
Large
Mammals
West African Chimpanzee (Pan
troglodytes spp. verus)
+ EN + + + +
Western giant eland
(Taurotragus derbianus spp.
derbianus) sub-species:
+ CR + +
African Wild Dog (Lycaon
pictus)
+ EN +
African lion (Panthera leo), West
African population - sub-
population
+ CR + +
African elephant (Loxodonta
africana)
VU + +
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Type of Risk
Receptor
Priority Biodiversity
Features
Critical
Habitat-
qualifying
IUCN
Status
PDA Project
Study
Area
PNNK
Study
Area
Wider
PNNK
Hippopotamus (Hippopotamus
amphibious)
VU + + +
West African red colobus
(Procobolobus badius spp
temminckii)
+ EN +
Birds Hooded vulture (Necrosyrtes
monachus)
EN + +
White-backed vulture (Gyps
africanus)
EN + +
Rueppell's vulture (Gyps
rueppellii)
EN +
Egyptian vulture (Neophron
percnopterus)
EN +
Reptiles Cynisca senegalensis + Data
Deficient
+
Dwarf crocodile (Osteolaemus
tetraspis)
VU +
Fish Barbus dialonensis + VU ? ? ? ?
Invertebrate Elattoneura pluotae + CR +
Key: * = Draft Red List assessments carried out by Royal Botanic Gardens, Kew; + = presence; and ? = occurrence unknown, further
investigation required; CR = Critically Endangered (IUCN, 2015); EN = Endangered (IUCN, 2015); VU = Vulnerable (IUCN, 2015)
12.1.1 Existing Threats in and around PNNK
Habitat quality and species diversity in the PDA, Project Study Area and surrounding environs have been
impacted by anthropogenic disturbance including conversion of natural habitats to agro-pastoral systems,
uncontrolled burning, illegal and unregulated hunting and unsustainable collection of natural resources
(timber and non-timber products). These are described in detail in Chapter 7: Biodiversity Settings. These
threats are also known to occur inside the PNNK and buffer zone.
Human pressure on the Park has resulted in it being placed on UNESCO’s List of World Heritage in Danger in
2007. The PNNK was originally listed as being in danger due to imminent threats to its Outstanding Universal
Values (OUVs), including critically low mammal populations, ongoing issues with management and the
potential impacts associated with a proposed hydropower development on the Gambia River upstream of the
Park. The PNNK has remained on UNESCO’s List of World Heritage in Danger since 2007.
The most significant threat to the OUV of the property is commercial poaching for the bushmeat trade
(UNESCO, 2007b; 2015). Poaching appears to have reduced since 2007 due to the permanent presence of
rangers in the PNNK and this appears to be having a positive impact on wildlife in the Park. However, the loss
of fauna reportedly increases with distance from the fixed guard posts (IUCN, 2015).
Threats in the PNNK also include livestock grazing, drought, illegal logging and the spread of non-indigenous
and invasive plants (UNESCO, 2007b). Other threats to habitats and species in the PNNK, identified during
baseline surveys, include artisanal mining, the creation of tracks and roads (facilitating poaching) and the
collection of non-timber products (e.g. fruit) (See Chapter 7: Biodiversity Settings).
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The IUCN has also listed the PNNK as being of “critical conservation outlook”, highlighting that it requires urgent
(additional), large-scale conservation measures, or the Park may lose the values for which it was awarded World
Heritage listing (Osipova et al., 2014).
12.1.2 Current Status of Priority Large Mammal Populations in PNNK
At a meeting in June 2014 (UNESCO, 2014), the World Heritage Committee decided to retain the PNNK on the
List of World Heritage in Danger due to concern over the conservation (and low numbers) of key species. The
World Heritage Committee reiterated “its serious concern as regards the state of conservation of the key species in
the park, notably the elephant and chimpanzee” (UNESCO, 2014). In 2015 the PNNK was retained on the List of
World Heritage in Danger. Corrective measures include updating the ecological monitoring programme of key
species for the Outstanding Universal Values of the property (lion, Derby eland, elephant, chimpanzee and wild
dog) and integrating this information into the management plan (UNESCO, 2015).
Dupuy and Verschuren (1977) state that the elephant population in the PNNK comprised approximately 350
individuals, based on an aerial census carried out since 1968. It was suggested by Dupuy and Verschuren (1977)
that without poaching, elephant numbers could have exceeded 1,500 and other species’ populations would
have similarly increased. However, by 1975 elephant numbers had already started to decline. In a 2006 aerial
survey of the south of the PNNK, six elephants were sighted and Renaud et al., (2006) estimated that the
population comprised of 10 elephants at the time of survey. This group of 10 is only 3% of the 350 individuals,
and although the entire Park was not surveyed during 2006, this is nonetheless a dramatic decline. According
to the Rapport de la Mission UICN au Parc National du Niokolo-Koba (Tiomoko and Van Merm, 2015), the exact
number of elephants currently present in the PNNK is uncertain however, only one elephant is regularly
observed.
Lion numbers also appear to have declined, although exact population numbers are not clear. From 1996 to
2001 estimates of lion populations were between 20 and 150 (Bauer, 2003; Bauer and Van Der Merwe, 2004).
Current lion population estimates in the PNNK are 16 with a maximum of 54 and that dramatic and catastrophic
declines in prey populations are the major causing factor (Henschel et al., 2014). One of the main causes of lion
prey population declines is poaching.
The West African Wild Dog (subpopulation) is Critically Endangered (IUCN, 2014; TBC, 2015). The population in
the PNNK is thought to be the only potentially viable population in the region, and was one of the key values
for the designation of the UNESCO World Heritage Site (TBC, 2015). The population in the PNNK appears to be
recovering and small packs comprising approximately twenty individuals are regularly observed by rangers
and researchers (Tiomoko and Van Merm, 2015).
Populations of some prey species (antelope) of African lions and African wild dogs also appear to be increasing
in numbers (Tiomoko and Van Merm, 2015).
The western giant eland (the West African subspecies of Giant Eland) is listed as Critically Endangered (East,
1999; IUCN 2014). Less than 200 animals are estimated to remain in Senegal, with the majority in the PNNK
(Nezerková & Hájek 2000; Koláčková et al., 2011; IUCN 2014). The PNNK population was also one of the key
values for the designation of the PNNK as a UNESCO World Heritage Site.
The estimated number of wild chimpanzees in Senegal ranges between 200 and 400 individuals (this estimate
does not include individuals identified during the Project baseline study), with most individuals inhabiting
unprotected areas (Kormos et al., 2003). The PNNK is regarded as an extremely important area for chimpanzee
conservation (Pruetz et al., 2002; Kormos et al., 2003), and holds 46% of the species’ national range. The exact
number of chimpanzee individuals in the PNNK is uncertain. It is clear that there are two known communities
(Pruetz et al. 2012), one at Mount Assirik and a second at Anten and the Mako group may be a third. There is
potential for there to be additional communities as large areas of the PNNK have not been surveyed.
There is some indication of population stability in the Mount Assirik community within the PNNK. This
community was studied in the 1970’s (see McGrew et al., 1981) and surveyed again in 2000 by the Miami Assirik
Pan Project. Pruetz et al., (2012) revisited the community in 2012 and found that the population had increased
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since 2000, however the authors admit that caution should be made when interpreting the results as they did
not cover as much area as the 2000 study.
Despite the distance of the Mount Assirik community from the national border or the National Route 7
(>20 km), there is recent evidence of poachers, including shells, footprints and shotgun fire. It is believed that
these poachers were targeting large mammals, particularly antelope but not chimpanzees. However, the
chimpanzees’ behaviour is likely to have been altered from the presence of the poachers, and this activity may
cause them stress. There was a dramatic increase in the detection of poaching evidence in the 2012 study
compared to the 2000 survey. Wildlife densities in the PNNK remain low (Tiomoko and Van Merm, 2015).
Overall, poaching is likely to be a major determining factor in the decline of large mammals in the PNNK in the
future without widespread and multi-agency intervention (Henschel et al., 2014).
12.2 Potential Impacts Associated with Mako Gold Project
The following sections consider the potential Project-related risks for the OUVs in the PNNK Study Area (for a
definition of this area, see Chapter 7: Biodiversity Settings), as well as priority fauna that are known to range
outside this area into the PDA and Project Study Area (PNNK ranging species) in the absence of appropriate
management and mitigation. Management and mitigation measures are outlined in Section 12.3 and residual
impacts are assessed in Section 12.4.
The Project lies entirely outside of the PNNK and buffer zone, hence there will be no direct habitat loss within
the PNNK or its buffer zone, as none of the Project components or roads are located within these areas. In the
absence of appropriate management and mitigation, the most significant potential risks to the OUVs as a result
of the Project are likely to be associated with:
Project-induced in-migration to villages near the PDA, leading to increased risk of indirect habitat loss
and degradation from timber and non-timber collection, habitat clearance for agro-pastoral activities
and artisanal mining in the PNNK Study Area;
Project-induced in-migration and increased poaching in the PNNK Study Area;
Species displacement (of species from the PDA into the PNNK) and increased inter-intra-specific
competition/conflict from habitat loss;
Habitat loss, fragmentation and barriers to movement for some PNNK ranging species associated with
Project development;
Accidental injury and mortality of PNNK ranging species from vehicle collision or poisoning (from
contaminated water within the TMF during operation;
Introduced and invasive species entering the PNNK as a consequence of Project induced in-migration;
Artificial lighting; and
Noise and vibration (e.g. from blasting).
Other less likely/significant potential risks that may alter species assemblage and distribution will be changes
to air quality and downstream water quality/hydrology.
Potential risks to the OUVs of the PNNK associated with each of these aspects in the absence of mitigation are
discussed in the following sections.
In-migration
Project-induced in-migration to villages near the PDA is expected to lead to increased pressure on natural
resources due to increased natural resource exploitation (i.e. increased collection of timber and non-timber
products, poaching and fishing). This risk is most likely to occur during the Pre-construction / Construction and
Operation Phases of the Project with out-migration occurring during the Decommissioning / Closure Phase.
The predicted extent of Project induced in-migration is presented in Chapter 11. Villages such as Mako and the
Niemenike cluster have had relatively high rates of recent migration and population growth (4% per annum
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from 2004 to 2014) which is already putting some strain on local infrastructure and natural resources. Based on
experience of other projects in the region, the population of the villages of Mako and Niemenike could easily
double over the Project life. However, the expected impacts of in-migration on habitat and species are difficult
to quantify.
In-migration and natural resource exploitation of timber and non-timber products will firstly occur around
towns and villages, but may extend to resource-rich areas, such as the buffer zone and the eastern limit of the
PNNK. If unregulated, this may impact upon the habitat and flora in the broader area, including the eastern
extent of the PNNK Study Area, leading to localised habitat degradation. If increased pressure on natural
resources does occur, forests (i.e. gallery forest and woodland) and savannah habitats (i.e. woody savannah, tree
savannah and shrub savannah) are expected to be targeted for timber and fruits. Illegal logging is an ongoing
threat to habitats and species in the PNNK (UNESCO, 2007; 2014; 2015) and many species are targeted for their
commercial value including Vitellaria paradoxa and Khaya senegalensis (IUCN, 2015). Saba senegalensis fruits
are also known to be targeted by local villagers.
The impacts of livestock grazing on the OUV’s of the PNNK are a current concern to the World Heritage
Committee (UNESCO, 2007 & 2015). Impacts arising from increased agro-pastoral activities in the PNNK are
likely to be of Minor significance as migrants and Project affected villages in general are predicted to trend
towards a cash economy which would lead to a movement away from subsistence farming.
In-migration may lead to an increase in artisanal mining outside and inside the PNNK if unregulated. If this does
occur, artisanal mining will be restricted to the PNNK Study Area where there is known gold mineralisation.
Potential impacts arising from artisanal mining include loss of habitat, disturbance caused by mining-related
noise and potential contamination of water sources if chemicals are used to process the gold. The majority of
the sites in the PNNK Study Area are relatively small, however, two moderately sized artisanal sites were
recorded during baseline surveys. Hence there is the potential for some of the smaller sites to expand.
There is a risk that Project-induced in-migration during construction and operation would lead to increases in
poaching and fishing in the PNNK which is likely to be more pronounced in the PNNK Study Area. At closure, a
net out-migration from the area is expected to occur, reducing potential risks. The nature and extent of
poaching arising from Project-related in-migration is difficult to predict. However, any increase in poaching
would exacerbate the current threat to the fauna population in the PNNK. In-migration also increases the risk
that chimpanzees, traditionally excluded from hunting and the bush meat trade by the majority of Senegalese
people because of cultural taboos against eating them, may be hunted by migrants that lack the same cultural
taboos (Carter et al., 2003; Pruetz, 2013). In response to an increase in pressure on natural resources, hunters
may begin targeting fauna not previously included in their repertoire, such as chimpanzees (Pruetz, 2013).
During baseline surveys of the Gambia River, few adult fish were captured and catches were dominated by
juvenile and immature fish. Aquatic ecology specialists stated that this is an indication of over exploitation of
fish stocks, as adult fish are more sought after by fishermen. Increases in fishing activities and the continued
use of illegal fishing equipment in the Gambia River will add to these existing pressures on fish stocks.
If unregulated, natural resource collection, poaching and fishing is likely to lead to the improvement of existing
tracks and the creation of new access routes in the PNNK, particularly in the PNNK Study Area, resulting in
localised habitat loss and fragmentation and an increased presence of human activity.
Species Displacement and Dispersal
Habitat clearance within the PDA during construction will cause fauna (Guinea baboons, leopards,
chimpanzees and other legally protected species) to disperse into the surrounding area, most likely into the
PNNK. This may increase inter- and intra-specific competition for resources, including space, water and food in
the PNNK. The level of impact on the OUVs of the PNNK in the area where species disperse will be dependent
on the availability of resources to support these additional individuals and the current territories of these
dispersing species. The territories of leopards and Guinea baboon that utilise habitats in and around the PDA
may overlap with the PNNK, hence territorial conflicts are unlikely to occur as competition for resources will be
low.
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It is possible that the PNNK holds sufficient resources to support the in-migration of fauna from the PDA and
as such will not impact fauna currently inhabiting the PNNK. Alternatively, there may be insufficient resources
(i.e. late dry season water sources) and this increased dispersal will put pressure on the OUVs. It is very difficult
to predict the outcome of the displacement and dispersal, and wildlife monitoring in the PNNK Study Area
would be required to understand the changes resulting from the Project.
The loss of habitat in the PDA is expected to cause permanent displacement of the chimpanzees from this area.
Territorial conflict resulting from displacement of chimpanzees is unlikely as it is considered that the
chimpanzee habitat in the PDA / Wayako Valley connects with that in the PNNK and buffer zone. Chimpanzees
are likely to disperse into similar habitat types within the PNNK, its buffer zone and north of the PDA, where
there is suitable habitat, food and water sources. Chimpanzees are also expected to continue to use the spring
in the Wayako Valley, which is an important dry season water source.
Habitat Loss and Fragmentation / Barriers to Movement outside the PNNK
Evidence of African elephant, African lion and western giant eland (PNNK OUVs) were found in the PNNK Study
Area but not in the PDA and Project Study Area. It is likely that the presence of the settlements, National Route
7, vehicle traffic, human activity near the Gambia River, steep topography, sub-optimal habitat quality and
exploration activities in the vicinity of the proposed Project already form a barrier to movement of these
species. It is expected that the development of the Project will not change this, and as such there will be a
Negligible impact on these species.
Habitat degradation, loss and fragmentation arising from Project development are expected to create barriers
to the movement of chimpanzees (a PNNK-ranging species) in the PDA and surrounds. Chimpanzees are
selective in their habitat use and often use drainage channels and the associated gallery forest for movement
at Mako and other sites (Pruetz and Bertolani, 2009). The removal of wildlife corridors (e.g. drainage channels),
clearance of 244 ha of land (natural and modified habitat (IFC, 2012) / Critical habitat (TBC, 2015)) for Project
components and infrastructure with significant levels of disturbance, intensification and expansion of
cultivated areas and the creation of roads will create barriers to movement for chimpanzees. The Project is
predicted to restrict chimpanzee movements outside of the PNNK in areas around the PDA including, along
the Wayako Valley (north to south) and to the hills located east of the Wayako Valley. The construction of the
main access road is expected to restrict chimpanzees from accessing habitats and resources in the eastern
extent of the Wayako Velley where chimpanzees and their nests have previously been observed during the
baseline study (see Chapter 7). Chimpanzees may also potentially have to find new routes to access water
sources in the western extent of the Wayako Valley during the dry season due to habitat fragmentation in the
PDA. It is unknown how much the chimpanzees currently use and rely on habitats in these areas.
Female migration and genetic exchange between the Mako chimpanzee community and chimpanzees south
of the Gambia River may be potentially impacted by habitat fragmentation / barriers to movement. In this
instance, female migration is only likely to occur during the dry season when the Gambia River is low enough
to be crossed by chimpanzees and potential crossing points are likely to be restricted to areas away from
settlements. Further research is required to confirm the nature and extent of exchange between these
communities and the impact of the Project. Female migration and genetic exchange between the Mako
chimpanzees and communities within the PNNK are unlikely to be affected. Any impacts from habitat
fragmentation and barriers to movement are expected to be of significance to chimpanzees prior to mitigation.
Some birds, including some biome restricted birds, may perceive the activities around the PDA as a barrier to
movement, however long-ranging birds are unlikely to find ground activities as barriers to movement.
A small area of hippopotami riparian habitat will be removed for the construction of a Project road and pipeline
and a smaller area of aquatic habitat may be degraded by suspended sediments at the confluent of Badalla
Creek and the Gambia River (< 7 ha in total). This is not expected to restrict hippopotami (a PNNK ranging
species) movement within their habitat range and the expected impact to hippopotami is Negligible.
Residual impacts to hippopotami habitat will arise from habitat loss for the construction of a Project road and
pipeline (resulting in the loss of riparian habitat, tree savannah and fallow land) and degradation of aquatic
habitat (e.g. arising from suspended sediments at the confluent of Badalla Creek and the Gambia River). It was
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assumed that all hippopotami habitat is of very high habitat quality. GIS analysis was used to calculate the total
area of impacted habitat and the quality hectares was calculated.
The Project has also been specifically designed to have a compact footprint, reducing the loss and
fragmentation of habitats (refer Chapter 5).
Vehicle Collision
Increased Project-related vehicle and plant activity during all Project phases will increase the risk of accidental
mortality and injury to mammals and birds from collisions with vehicles and machinery. The areas where PNNK
fauna is most at risk of collision is the existing National Road 7 (which passes through the PNNK). Some species
that are known to range outside of the PNNK (i.e. chimpanzees) will also be at risk of vehicle activity in the PDA
and along the Main Access Road in the Wayako Valley where the majority of vehicle movement will occur (see
Chapter 10). Project traffic will be temporary and will cease post-closure.
Fauna that are known to cross the RN7 in the PNNK include African wild dogs and lions. Collisions are most
likely to occur with nocturnal species (i.e. leopards), which are less likely to be seen by drivers and may be
startled by vehicle headlights, and predators feeding on carrion on or beside roads (i.e. vultures) (Forman and
Alexander, 1998). Many species of fauna that inhabit the PNNK are either nocturnal or carrion feeders.
The National Road 7 (RN7) will be used as the primary transportation route during all Project phases for supplies
and material delivery. During operation, it is expected that approximately three trucks per day will transport
materials to the Project. The average number of daily traffic movements recorded on the RN7 during the traffic
survey (Volume A, Appendix D) was 220 (all vehicle types), however since the opening of a customs checkpoint
on the eastern Senegal border (Kidira) daily movements are estimated to be approximately 300. Therefore
Project-related transportation will not significantly add to this traffic load and the risk of Project related vehicle
collisions will be low.
The company is already implementing a variety of measures to minimise the likelihood of any wildlife collisions
associated with vehicle use for Project exploration activities, for example driver safety awareness training,
speed limits and restricting driving at night or in low-light conditions (e.g. dusk). Expected impacts to PNNK
OUVs from vehicle collision are predicted to be of minor significance, prior to mitigation.
Hydrology and Water Quality
Any reduction in the availability of suitable drinking water sources during the dry season would be likely to
have an adverse impact on the Mako chimpanzee community, resulting in increased competition for water
resources and potentially affecting the health of chimpanzees. Therefore, the Project has been designed to
avoid direct impacts (i.e. clearance) to the springs in the Wayako Valley, which are known to be an important
dry season water sources for chimpanzees and other fauna. Furthermore, these springs are not expected to be
impacted by downstream water quality and hydrology impacts generated from suspended sediments and
reduced flow rates.
The main Project impact to surface water is expected to arise from suspended sediments notably that
generated from construction activities (e.g. land clearing, road construction). It is anticipated that suspended
sediments will mainly impact ephemeral creeks in the Project Study Area and outside of the PNNK. However,
an increase in suspended sediments in the Kelendourou Creek could also impact downstream aquatic habitats
in the PNNK buffer zone. It is however unlikely for suspended sediments to reach the PNNK. Impacts on
downstream habitats and fauna in the PNNK buffer zone arising from suspended sediments are expected to
be minor prior to mitigation.
Three small Kelendourou Creek tributaries will be affected by small catchment area losses to the Mine Pit during
operation (and post-closure). There is predicted to be a Negligible change in the natural flow which will not
affect downstream habitats and species in the PNNK and buffer zone (see chapter 9: Physical Impacts).
The Project is not expected to have significant adverse impacts on the flow rates, water quality or the aquatic
biodiversity of the Gambia River (see Chapter 9: Physical impacts). The Mako Gold Project will abstract water
each year from the Gambia River during the rainy season months for storage in the Water Storage Dam (and
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FINAL 12-10
utilisation as process water, dust suppression, and as a camp supply). During a relatively dry year, total flow in
the Gambia is approximately 1,760,000 ML and approximately 2,888,000 ML during the median year. The total
annual supply of mine water proposed during a dry year represents 0.04% of the Gambia River annual flow and
0.03% of the annual Gambia River flow during the median year.
There will be a maximum abstraction rate of 3% from the Gambia River flow, and no abstraction when the
instantaneous river discharge is less than 5 m3/s, in order to protect environmental flow, the water requirements
of downstream users and aquatic biodiversity. This would mean that pumping would be able to be conducted
once river flows have been established in the beginning of the wet season. Impacts to aquatic habitats and
species downstream of the PDA in the PNNK are expected to be of Negligible significance.
Project-related artificial water sources (i.e. TMF surface water, water storage dam) can be attractive to some
wildlife, particularly during the dry season when water is scarce. During operation, there will be a risk of adverse
health impacts (i.e. poisoning) and mortality to wildlife arising from the ingestion of contaminated water
contained within Project facilities. In particular, the TMF surface water may have elevated concentrations of
cyanide, salinity, metals and nutrients (breakdown products of cyanide); see ESIA Report Chapter 9: Physical
impacts. During operation, water will be fully contained within the TMF and there will be no surface discharge
from site. Cyanide destruction, via the INCO (SO2 + air) process, will also be implemented to ensure weak acid
dissociable (WAD) cyanide concentrations are below 50 mg/L in the TMF in accordance with the International
Cyanide Code.
Most wildlife will avoid the TMF due to the disturbance levels in the PDA (i.e. noise, artificial lighting, human
activity) and the fact that the site will be difficult to access. Chimpanzees are unlikely to drink contaminated
water from the TMF or other facilities as they are selective of the quality of water they drink (Galat et al., 2008).
Of the species from within the PNNK, birds (including PNNK biome-restricted birds and vultures) are most at
risk from coming into contact with polluted water sources. Carrion feeders such as vultures may also be at risk
from the consumption of carcasses of birds or other animals that have been poisoned by drinking
contaminated water. The Company is committed to minimising and monitoring the interaction between
wildlife and the TMF, which is expected to largely mitigate this risk.
There is a risk of surface and ground water contamination through accidental spills or seepages of diesel fuel,
hazardous compounds (i.e. cyanide, solvents, metalliferous drainage) and non-hazardous waste during
operation which would be detrimental to the health of large mammals and birds if ingested. This will be
controlled through risk management and emergency response strategies outlined in the Project Risk
Assessment.
Invasive Species Encroachment
The invasive species Mimosa pigra is present along the banks of the Gambia River, tributaries and ponds inside
and outside of the PNNK. This species is an aggressive competitor that is capable of progressively dominating
areas of natural habitat and its spread is being actively controlled and monitored in the PNNK (UNESCO, 2015).
The risk that Project vehicles and personnel may transfer M. pigra seeds from affected areas along the Gambia
River into the PNNK is considered low as the Project and transport corridors are located outside of the PNNK.
Noise, Vibration and Airblast
The primary noise impacts of the Project are expected to occur during operation, where blasting, mining and
processing activities will affect the local ambient acoustic environment. Based on conservative noise modelling
for the Project, relevant international (WB/IFC EHS Guidelines – Noise Management 2007) and national
standard (Senegal Noise Pollution Standards Article R84 of Decree 2001-282) criteria for noise will be exceeded
within the immediate vicinity of the mine and processing plant.
The primary impacts of blasting will be excess noise, airblast, and ground vibration. Under normal operating
conditions, blasting will not occur more than once a day and will typically occur in the late afternoon. Noise
levels are not expected to exceed IFC night-time criteria in villages and sensitive receptor areas. However, noise
is expected to have impacts on wildlife in the vicinity of the mine including the PNNK buffer zone.
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Ground vibrations from mine blasting are predicted to exceed adopted human comfort level criterion (0.56
mm/s) within 500 m of the blast site (see Chapter 9). Vibrations generated from process equipment and
periodic blasting are not expected to impact the PNNK.
Generally large mammals and birds are wary of unfamiliar and/or loud noise and vibration, particularly if it is
associated with anthropogenic disturbance, and are likely to respond with a flight reaction. Mammals and birds
can also experience stress, reduced biological fitness and decreased breeding success (Francis and Barber,
2013). Chronic stress can make species more susceptible to diseases, pathogens and parasites (Dhabhar, 2002,
Sapolsky et al., 2000). Some species may be able to habituate to consistent noise and vibration levels, however
it is unlikely that fauna will habituate to blasting. It is likely that most fauna will disperse away from the source
and thus avoid the ongoing effects.
Airblasts from mine blasting are predicted to be below human discomfort levels level in the eastern periphery
of the PNNK. Airblasts at this level can startle wildlife (Bowles, 1995) and it is likely that wild animals would be
more sensitive to airblasts than humans, and likely to move away. Airblast may be perceptible in Chimpanzee
nesting habitat in the PNNK (4.3 km north-west from Mine Pit; see ESIA Report Chapter 7: Figure 7-5) and as
such may cause disturbance and displacement to chimpanzees and other species in this area.
Most noise, vibration and airblast impacts are likely to be attenuated over the life of the mine, particularly as
the mine pit deepens. Thus, any effect on wildlife from noise and vibration from the Project will reduce over the
course of the mine life. Noise and vibration impacts from the Project will also cease completely post-closure.
Artificial Lighting
It is anticipated that the Project will be in operation on a 24 hour basis, with the main components illuminated
for safety. Skyglow occurring above Project components from poorly shielded lighting, scattered by low clouds
or ambient dust can potentially increase apparent lighting impact by as much as 40%. Direct views to night
lighting associated with the Project would be visible to nearby villages and potentially to vehicles travelling on
National Route 7 (as predicted by GIS viewshed analyses) resulting in disturbance to wildlife in the vicinity of
the PDA. Artificial lighting in the PDA will be visible from within the PNNK and may potentially cause
disturbance to wildlife in the eastern periphery of the PNNK and buffer zone (see Chapter 9) if unmitigated.
Light-spill is known to cause disturbance to crepuscular (fauna that are active primarily during dawn and dusk)
and nocturnal species (i.e. some large mammals, bats and birds) and can cause a range of behavioural changes
and affect the circadian rhythms and cycles of activity of nocturnal, crepuscular and diurnal species, disruption
of seasonal acclimatisation, disrupts predator-prey relationships, increase prey intake and alter reproduction
behaviour (Gaston et al., 2013; Longcore and Rich, 2004). Many species use lightscapes (e.g. moonlight) as cues
for movement around their environment and altering these lightscapes by light pollution may disrupt these
movements by disorienting the animal (Gaston et al., 2013). This can potentially result in physiological stress
and thereby reducing biological fitness. It is unlikely that crepuscular and nocturnal species (i.e. lions, African
wild dogs, African elephants, hippopotami) in the eastern periphery of the PNNK would remain near light-spill.
Impacts to mammals and birds in the eastern periphery of the PNNK from artificial lighting are expected to be
of Moderate significance prior to mitigation.
Air Quality
Fugitive dust emissions (e.g. PM10 and PM2.5) and combustion emissions air pollutants (i.e. CO, SO2, NOx,
particulate matter and VOCs) will be generated during the Pre-Construction / Construction Phase (see chapter
9) which will be short term, localised and staged over a moderately short period of time (approximately 20
months). Localised air quality impacts are expected to occur within approximately 1 km of the construction
areas and 200 m of unsealed roads (depending on weather conditions) and are not expected to impact priority
fauna and their habitats in the PNNK. Concentrations of particulates within 1 km of Project sources are
predicted to exceed international health criteria, if unmitigated. Dust deposition drop-out may also impact
chimpanzee habitats in the PDA, in areas near the source site and adjacent to the Main Access Road in the dry
season.
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The primary Project air emission that may affect fauna during the Operation Phase is dust. Based on
conservative modelling for dust emissions generated by Project activities, international (WHO Air Quality
Guidelines 2005) criteria for air quality may be exceeded in the PDA close to the sources. In the absence of
mitigation, impacts to fauna from emissions are expected to be of Moderate significance. There is also the
potential for minor dust impacts on receptors to occur within approximately 5 km of the PDA during the dry
season. These impacts will primarily relate to fugitive dust emissions from drilling and blasting within the Mine
Pit, as well as excavating, earthmoving and processing (crushers) etc. Combustion emissions from diesel vehicle
exhausts, machinery and generators as well as the operation of the Diesel Power Plant may also contribute to
Minor impacts. It is unlikely that ecologically significant levels of dust or emissions from the Project will reach
the PNNK.
12.3 Avoidance, Mitigation and Management
To ensure that Project impacts do not contribute to the decline of Outstanding Universal Values (OUVs) in the
PNNK, the Company is employing the mitigation hierarchy to avoid, mitigate, manage, restore and offset
impacts on biodiversity for its activities outside of the PNNK. An Environmental and Social Management and Monitoring Plan (ESMMP; Volume C) and a Biodiversity Action Plan (BAP; Volume C) have been prepared
providing detailed plans and procedures for the protection and management of biodiversity for the Project. A
summary of the specific measures to avoid, minimise and manage any potential risk to the OUVs of the PNNK
are outlined below for each stage of the Project.
12.3.1 Avoidance
The Project lies entirely outside of the PNNK and its buffer zone. The Project Study Area is located close to the
PNNK, 1 km east of the PNNK at its closest point. No Project-related habitat clearance will be undertaken in the
PNNK or the buffer zone.
The Project Footprint has been reduced in size since first inception, and has thus avoided impacts on a much
greater area of chimpanzee and other species’ habitat. This has avoided impacting some drainage channels
that are used by chimpanzees for commuting and foraging. Furthermore, the main access road has been re-
routed to the south to avoid impacting an important dry season water source for chimpanzees, leopards,
Guinea baboons and other fauna, located west of the Wayako Valley outside of the PNNK. These springs are not
expected to be impacted by downstream water quality and hydrology impacts generated from suspended
sediments and reduced flow rates. Chimpanzees and other fauna are expected to continue to use these springs
and habitats throughout the lifespan of the Project.
Pre-clearance checks will be undertaken to avoid impacting baobab trees that are important food and nesting
resource for chimpanzees where possible.
Primary sources of potentially mine contaminated water (e.g. waste management facilities, Process Plant, TMF,
hazardous chemicals and fuel storage areas) have been sited within a single catchment away from major
drainage lines with primary and secondary containment facilities in place to prevent potential discharge into
the receiving environment. The TMF has been designed to avoid discharge to receiving waters during Project
operation and employs cyanide destruction, via the INCO (SO2 + air) process (see Chapter 9).
High noise emission equipment and infrastructure are located as far as practicable from potential sensitive
receptors.
12.3.2 Minimisation
An ESMMP (Volume C) and BAP (Volume C) have been prepared providing detailed plans and procedures for
the protection and management of biodiversity for the Project. A summary of the measures to avoid, mitigate
and manage high-risk potential impacts on priority habitats and species in the PNNK and buffer zone is
outlined below:
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Pre-Construction / Construction
Control measures will be implemented to minimise adverse impacts on habitats in the PNNK and buffer zone.
The company will consult with local authorities to minimise the impacts of Project-induced in-migration on
natural resource exploitation (including the collection of timber, non-timber products and hunting). The
Company will also collaborate with PNNK area managers to ensure indirect impacts to the PNNK are adequately
mitigated. Livelihood restoration mitigation measures will also be implemented to incentivise land use change
in the PNNK where this is likely to avert habitat loss and degradation of the OUVs of the PNNK. If successful,
these incentives should reduce pressure on the PNNK and minimise habitat destruction and degradation.
Access to the PNNK and buffer zone by Project staff and contractors is restricted and subject to the prior
approval of the DPN (Direction of National Parks). Project staff and contractors are banned from entering the
PNNK and buffer zone to collect timber and non-timber products, hunt and fish. Project staff and contractors
are banned from hunting, buying or trading wildlife to minimise impacts to fauna populations. Environmental
education and awareness programmes will be conducted for Project staff and contractors (e.g. through staff
inductions). This will emphasise the importance of the PNNK and prohibitions / penalties of natural resource
use in the PNNK.
The displacement of PNNK ranging species from the PDA will be minimised by ensuring a ‘minimal-impact
footprint’ for the Project in which habitat clearance will be restricted to only the land required for the
construction of Project components and the associated infrastructure.
Project staff and contractors will be banned from initiating close contact with chimpanzees and other wildlife,
as humans can act as a vector for the transmission of diseases to chimpanzees. Adherence to hygiene principles
and proper waste management will also reduce the risk of disease transmission to chimpanzees.
The invasive species prevention protocol will minimise the risk of transferring invasive species (i.e. Mimosa
pigra) from infected areas along the Gambia River. This will include wash-down procedures of Project vehicles
moving from the Gambia River and other know affected areas. Project vehicles, staff and contractors will be
banned from entering the PNNK and buffer zone without permission.
Disturbance to fauna from increased noise and vibration will be minimised by restricting the use of particular
machinery and vehicles at dusk, dawn and during the night. Natural sound barriers (i.e. trees and earth mounds)
will be retained, where possible, to attenuate noise and vibration. Staff and contractors will adhere to SOP05:
Noise and Vibration Management throughout the lifespan of the Project
Disturbance to fauna from noise, vibration and airblast from blasting in quarries near the RN7 will be minimised
by continual improvement of mine blast-associated noise and airblast management measures during the
Operation Phase and through adherence to SOP08: Blasting Management.
Impacts to fauna caused by disturbance from artificial lighting will be minimised through the use of capped
and directional lighting. Artificial lighting will be directed away from sensitive areas including the PNNK buffer
zone.
Sediment control dams will be used to minimise the impacts from suspended sediments on downstream
aquatic habitats in the PNNK. Vegetation on steep slopes and riparian corridors will be preserved where
possible to minimise erosion. Surface water management infrastructure (e.g. cut-off / diversion drains, velocity
dissipation devices, culverts) will be installed in appropriate locations to minimise and control surface water
flow over disturbed areas.
Adverse impact to habitats and flora arising from fugitive dust and diesel combustion will be minimised
through adherence to SOP04: Emission and Dust Control. This includes using water to reduce dust levels in areas
of biodiversity sensitivity (i.e. near the PNNK buffer zone), particularly during the dry season, stabilising
landforms and implementing erosion prevention measures.
Operation
In addition to the proposed management and mitigation measures for Pre-Construction / Construction Phase
above, the following measures will be adopted:
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Blasting in the Petowal mine pit will adhere to SOP08: Blasting Management and will only be undertaken during
daylight hours typically in late afternoon (when levels will not exceed IFC night-time criteria) to minimise
disturbance to fauna, particularly chimpanzees. It is anticipated that the on-going excavation of the pit will
provide additional noise shielding from blasting throughout the Project operation as the elevation of the
western pit wall will be maintained above the eastern extent of the pit. Continual improvement of mine blast-
associated noise and airblast management measures during the Operation Phase will also minimise impacts to
fauna.
Fencing will be installed around the site perimeter of the TMF to restrict fauna, including some PNNK ranging
species, from accessing these areas and ingesting TMF surface water. If necessary, a variety of bird scaring
techniques will be tested to assess their effectiveness in deterring birds from the TMF. Any incidents involving
wildlife, including PNNK ranging species, will be reported and monitored and mitigation measures will be
reviewed and adapted where appropriate.
The TMF is designed to contain a 1 in 100 year 72 hour storm event and a 1 in 100 year 12 month wet rainfall
sequence, with an additional 1 m contingency freeboard (Knight Piesold, 2015d). Strict control of freeboard
within the TMF will avoid and minimise requirements for downstream release. Cyanide destruction shall be
employed, via the INCO (SO2 + air). Shallow and deep groundwater monitoring bores will be installed
downgradient of the TMF to detect seepage water quality and quantity (see Chapter 9).
12.3.3 Rehabilitation / Decommissioning / Closure
During Decommissioning / Closure mitigation measures will be implemented as per the Rehabilitation and Conceptual Mine Closure Plan (Volume E). Rehabilitation and closure will aim to re-establish an ecosystem
that functions in a similar manner (or better) than that which existed before mining related disturbance.
Revegetation efforts will utilise native species of local provenance to establish self-sustaining tree savannah,
wooded savannah, or shrub savannah vegetative communities where feasible. This will be favourable for
chimpanzees and other fauna. Species selection will include flora known to provide nesting or forage value for
chimpanzees and riparian corridors will be planted to provide cover for migration to the extent that is feasible.
Rare, threatened and indigenous species including restricted-range species, in addition to protected
vegetation and species of cultural significance will be incorporated into planting programmes. Weed-free seed
sources will be procured to the extent that is possible. This will minimise the extent of habitat fragmentation
and allow PNNK ranging species to return to use habitats in the PDA following closure.
12.4 Residual Impact Assessment and Offsets
12.4.1 Residual Impact Assessment
Notably, there will be no direct impact of the Project on habitats within the PNNK and buffer zone from habitat
clearance, as none of the Project components are located within these areas. Given the successful
implementation of the proposed mitigation and management measures, the residual impacts for the PNNK
Outstanding Universal Values (OUVs) are summarised in Table 12-2 and discussed below in more detail:
In-migration and natural resource collection and agro-pastoral activities – It is difficult to quantify
the residual impacts arising from Project-induced in-migration, however, impacts to habitats and species
from increased natural resource collection and agro-pastoral activities in the PNNK are expected to be
of Minor significance. The Company will collaborate with PNNK area managers to ensure indirect residual
impacts to the PNNK are adequately mitigated through offsetting. Activities proposed as part of the
offset strategy (see below) will incentivise land use change to reduce pressure on natural resources in
the PNNK Study Area.
In-migration, poaching and fishing – The nature and extent of poaching arising from Project-related
in-migration are difficult to predict. There is a risk of impact to species from poaching and fishing,
however these are expected to be of Minor significance. The Company will collaborate with PNNK area
managers to ensure indirect residual impacts to the PNNK are adequately mitigated through offsetting.
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Residual impacts to priority species and their habitats from in-migration will be addressed in the offset
strategy which is expected to include a combination of restoration and averted loss offsets including
strengthening enforcement in the PNNK, community awareness and education. The offset strategy will
also take a collaborative approach to enhance the biodiversity value of degraded habitats through
habitat restoration and enhancement.
Species displacement and dispersal – Most of the threatened species present within the PNNK appear
to mostly stay within PNNK boundaries and therefore their habitat use will not be affected by the Project.
However, habitat loss, fragmentation and degradation, and the cumulative disturbance caused by the
Project (i.e. noise, vibration etc.) within the PDA are expected to cause displacement of chimpanzees (a
species that is known to range inside and out of the PNNK). Due to the length of time that the mine will
be operating and the level of disturbance caused by its operation, chimpanzees are considered unlikely
to return and use the habitat in the PDA as they did before the Project. Residual impacts to chimpanzees
from habitat loss, fragmentation and degradation are expected to be of Moderate significance.
Habitat loss, fragmentation and barriers to movement for PNNK ranging species – Most threatened
species in the PNNK appear to be present within the PNNK boundaries and therefore their movement
patterns will not be affected by the Project. Habitat loss and fragmentation is expected to act as a barrier
to the movement of chimpanzees. The degradation and fragmentation of fauna habitats will be partially
counterbalanced by restoration and rehabilitation activities as per the RCMCP (Volume E), however
habitat will not be completely restored at closure. Rehabilitation of the TMF at decommissioning,
including treatment of the TMF supernatant pond at decommissioning, is expected to reduce the
residual impacts, however, some areas will not be rehabilitated to the same value as before Project
development (e.g. pit and TMF). Monitoring of surface and groundwater post-closure will be
implemented to determine whether additional measures are required to avoid post-closure impacts to
water quality. Many species are expected to return and use the revegetated areas within the Project
Footprint post-closure including leopards, Guinea baboons and other legally protected species.
However, chimpanzees are considered unlikely to return and use the habitat in the PDA as they did
before the Project. Residual impacts to chimpanzees are expected to be of Moderate significance.
Vehicle collisions – With the implementation of the proposed management and mitigation measures,
there should be Minor impact on the OUVs and other biodiversity values of the PNNK from vehicle
collisions with animals.
Invasive species encroachment –There should be no residual adverse impact of the Project on the
PNNK due to spreading of M. pigra. The risk of introduction of other introduced species will be Negligible.
Hydrology and water quality – There is expected to be no residual impacts to aquatic and terrestrial
biodiversity following implementation of mitigation and management measures.
Noise and vibration – The proposed mitigation and management program for noise and vibration will
greatly reduce the potential for noise, vibration and airblast impacts on the wildlife of the PNNK, but it
will be impossible to mitigate all impacts. In particular, there will still be some noise and vibration from
blasting reaching the eastern periphery of the PNNK which may cause some disturbance to priority
species including African elephant, western giant eland, African lion, chimpanzee and potential African
wild dog (if present). Residual impacts are expected to be of Minor significance to OUVs.
Artificial lighting - There is expected to be a Minor residual impact to PNNK ranging fauna due to light
spill from the Project areas during operation.
Table 12-2 Summary of key expected pre-mitigation impacts, mitigation measures and residual impacts to PNNK
OUV’s for each Project phase
Receptor / Value:
OUVs
Expected Pre-
Mitigation Impact
Significance
Key Management & Mitigation
Measures
Key Expected Residual
Impacts and Overall Impact
Significance
Pre-Construction / Construction
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Receptor / Value:
OUVs
Expected Pre-
Mitigation Impact
Significance
Key Management & Mitigation
Measures
Key Expected Residual
Impacts and Overall Impact
Significance
Priority terrestrial habitat MINOR
Livelihood restoration mitigation measures
Project staff and contractors banned from accessing PNNK
Project staff banned from collecting timber and non-timber products.
Adherence to the invasive species prevention protocol
NEGLIGIBLE
No terrestrial habitat
clearance from the PNNK
or buffer zone
Possibly some risk of
increased natural resource
collection in eastern
periphery of PNNK
Priority aquatic habitat MINOR
Suspended sediment and erosion controls
Adherence to SOP07: Hazardous Materials Management and SOP02: Water Quality and Pollution Management
NEGLIGIBLE
No aquatic habitat
clearance in the PNNK
Possibly some risk of
impacts from increased
artisanal mining
Priority threatened
terrestrial fauna
MODERATE
Project staff and contractors banned from hunting, buying or trading wildlife and entering PNNK and buffer zone
Prohibited driving at night outside of the PDA, unless permission has been sought or in the event of an emergency.
Adherence to SOP07: Hazardous Materials Management and SOP02: Water Quality and Pollution Management
Driver training and adherence to the Highway Code
Avoidance of using artificial lighting
Capped / directional lighting
Adherence to SOP05: Noise and Vibration Management
Avoid using noisy machinery and vehicles at dusk, dawn and at night
Retention of natural sound barriers (trees / mounds)
MODERATE
Possibly some risk of increased poaching in the in eastern periphery of PNNK
loss of chimpanzee habitat outside of the PNNK (Note: these chimpanzees range inside and out of the PNNK)
Increased risk of poaching
Priority threatened
aquatic fauna
MINOR
Suspended sediment and erosion controls
Adherence to SOP07: Hazardous Materials Management and SOP02: Water Quality and Pollution Management
NEGLIGIBLE
Possibly some risk of increased fishing in the Gambia River
Operation
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Receptor / Value:
OUVs
Expected Pre-
Mitigation Impact
Significance
Key Management & Mitigation
Measures
Key Expected Residual
Impacts and Overall Impact
Significance
Priority terrestrial habitat MINOR
As per Construction Phase, plus:
Habitat Restoration
NEGLIGIBLE
Possibly some risk of increased natural resource collection in eastern periphery of PNNK
Priority aquatic habitat MINOR
As per Construction Phase, plus:
Abstraction of Gambia River during wet season
Habitat Restoration
NEGLIGIBLE
Priority threatened
terrestrial fauna
MINOR
As per Construction Phase, plus:
Adherence to SOP08: Blasting Management
Blasting in afternoons only.
Fencing and monitoring the TMF
MODERATE
Most chimpanzee habitat loss, degradation and fragmentation impacts outside the PNNK will remain in Operation
Risk of disturbance to fauna (i.e. chimpanzee) from blasting
Risk of disturbance from blasting
Priority threatened
aquatic fauna MINOR
As per Construction Phase, plus:
Abstraction from the Gambia will occur during high flow months
NEGLIGIBLE
Decommissioning / Closure
Priority terrestrial habitat MINOR
As per Construction Phase
NO IMPACT
Priority aquatic habitat MINOR
As per Construction Phase NO IMPACT
Priority threatened
terrestrial fauna MINOR
As per Construction Phase, plus:
Restoration activities in the
PDA conducted in
accordance with the
Rehabilitation and
Conceptual Mine Closure
Plan
Routine checks for
compliance
NEGLIGIBLE
Habitat restoration in the PDA will reduce overall residual impacts to chimpanzee habitat Post-Closure
Some areas of permanent habitat loss will remain (e.g. pit and TMF)
Priority threatened
aquatic fauna
MINOR
As per Construction Phase, plus:
Restoration activities in the
PDA conducted in
accordance with
Rehabilitation and
Conceptual Mine Closure
Plan
Routine checks for
compliance
NEGLIGIBLE
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12.4.2 Offset Strategy
The Company is developing an offset strategy with the aim of achieving no net loss on biodiversity, and
preferably a net gain. This strategy is summarised in the Biodiversity Action Plan (Volume C). The Project has
aligned with best practice and employed the mitigation hierarchy to avoid, minimise and restore adverse
impacts to biodiversity. The Company is also committed to developing and implementing a comprehensive
biodiversity offsets programme that adequately compensates for residual impacts (e.g. from indirect habitat
degradation from in-migration).
The Company is developing an offset strategy for the residual impacts to chimpanzee habitat. The offset
strategy will make a significant contribution to the conservation of the remaining habitat for the Mako
chimpanzee community, including areas of this habitat both in and outside the PNNK. Chimpanzees use
multiple habitat types and their range overlaps the ranges of other priority species. This approach will therefore
also benefit other priority species of fauna that share the habitat range of the Mako chimpanzee community in
the PNNK. This may include African lion, Western giant eland, African elephant, African wild dog (if present) and
other fauna.
A number of candidate offsets sites have been identified and provisionally assessed for technical feasibility i.e.
being potentially able to achieve the gains required to offset the residual impacts (losses). The five candidate
offset sites include areas inside and outside of the PNNK, and suggested offset actions will include a range of
activities such as restoration of degraded habitats, enhancement of species migration corridors, law
enforcement against poaching and illegal mining within the PNNK, and community programmes to incentivise
land use change. Indicators will be identified to demonstrate and monitor quantifiable biodiversity gains
achieved through offsetting. Where possible, offsetting will align with regional, national and international
strategies and management plans for biodiversity conservation including government lead approaches to
conservation.
At this point, losses from direct impacts have been quantified. However indirect impacts are more complex, and
are more difficult to quantify. Therefore, indirect impacts to PNNK have not yet been quantified. Stakeholder
input, along with additional baseline information is needed for these calculations. The Company is committed
to calculating indirect impacts in the next steps of the offset strategy, so that appropriate offsets are developed,
and no net loss is achieved (see BAP).
Supporting conservation actions to be conducted alongside the biodiversity offset program will include:
Support conservation actions in the PNNK in partnership with the DPN;
Supporting landscape scale ecological research;
Data and information sharing regarding the species and habitat ecology in the PNNK, buffer zone and
surrounding landscape;
Contribution to the development of biodiversity management plans through sharing data, technical
knowledge, skills and partnership alliance;
Investment in a number of community programmes which will also achieve biodiversity gains; and
A seed collection and propagation programme will be established with the aim of contribution to the
global conservation of rare and threatened flora.
The Company is developing the governance structure for the offset programme and will collaborate with
technical partners (probably a multi-stakeholder agency) to monitor compliance, assess performance against
the management plan and evaluate biodiversity gains achieved through offsetting.
The Company has committed to conducting a transparent stakeholder consultation and engagement process
with regards to biodiversity management and the development of the offset strategy. In particular, biodiversity
experts with knowledge of World Heritage and protected areas from the Biodiversity Group of Independent
Experts have been consulted throughout this process. The opinions and suggestions of stakeholders obtained
through the stakeholder engagement process have been, and will continue to be, considered in the design of
Mako Gold Project
Environmental and Social Impact Assessment
FINAL 12-19
the Project, biodiversity management and offsetting. Ongoing consultation activities are outlined in the BAP
and Stakeholder Engagement Plan (refer Volume C).
12.5 Monitoring and Evaluation
Monitoring and Evaluation Programme
The Mako Gold Project will implement a monitoring and evaluation programme to assess the effectiveness of
mitigation measures and to inform the requirement for adaptive management. The success of the offset
program will also be validated through a programme of monitoring conservation gains. A detailed description
is presented in the BAP and the ESMMP. A few of the key approaches that will be undertaken inside the PNNK
and buffer zone are listed as follows:
Remote sensing: A structured camera trapping monitoring programme will be developed, which will entail
the establishment of key monitoring sites and a schedule for the rotation of camera traps inside the PNNK,
buffer zone and around the PDA. Camera trapping will primarily be used to monitor any changes in priority
species habitat and resource use, particularly chimpanzees. However the camera trapping programme will also
capture information on other species of fauna including African lion, elephant, western giant eland and
important prey species for carnivores and omnivores. The camera trapping will further the existing knowledge
regarding species’ ecology, population dynamics and numbers of individuals. Monitoring may also provide
information on human activity within the PNNK and buffer zone.
Target chimpanzee survey: Walkover chimpanzee surveys will be undertaken every two years during the wet
and dry seasons. Repeat census will target sensitive areas and sites of main habitat usage in the PNNK and
buffer zone. Surveyors will search for direct evidence of chimpanzees (i.e. sightings and calls) and indirect
evidence of chimpanzee activity (arboreal nests, faeces, prints, feeding remains) either side of predetermined
transect routes.
Targeted hippopotami survey: Surveys will be undertaken twice a year during the wet and dry seasons.
Sample points will include the PNNK and buffer zone.
Water quality: An aquatic monitoring programme will be established to measure any changes to the baseline
parameters and overall health of the Gambia, including continuation of water quality monitoring at sampling
sites; monitoring appropriate site specific bio-indicators (i.e. freshwater macro-invertebrate diversity and
abundance); and an assessment of fish diversity and abundance including continued search for Barbus
dialonensis.
Threat related measures will also be used for monitoring offsetting (e.g. land use changes, enforcement,
enhancement and revegetation etc.). Stakeholder consultation and ground-truthing will be required to confirm
the suitability of these indicators.
The Company will commission an independent review of the offset programme to evaluate offsetting. A panel
of independent experts established by the Company, and comprising Senegalese specialists in aquatic and
terrestrial ecology, will review and monitor performance of the Company’s Biodiversity Action Plan.