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A brief Paper on Environmental Impact Assessment reports of three Companies

…a focus on SOCFIN, Sierra Leone Agriculture, and ADDAX Bioenergy

 By Michael Freeman – For Action for Large-scale Land Acquisition Transparency (ALLAT) Network

 Background/context:

The narrative in this paper is tacitly presented in a briefing fashion. Due to the three tier crises of food, fuel, and finance, globally a new wave of natural resource exploitation emerged targeting largely Africa and some Asian countries.  Land, which is the context of this exploitation, is attracting a new drove of investors across Africa.

The scale of these investments runs into millions of hectares and their impact on local livelihoods and the environment are likely to lead to major social and economic transformation in rural areas across African countries.  The start of this transformation is already witnessing social conflicts between land owners/users and investors and the has the potential to increase with time as the scale of the problem increases.

While donors, development banks and African governments are promoting industrial scale agriculture, principally for development and poverty reduction, they contradict their rationale for industrial scale agriculture by also promoting small scale farming sector as the most significant contribution to poverty reduction.  In the midst of the contradiction, African governments lean more to arguments supporting industrial scale agriculture for gains in employment and infrastructural development thus keen to attract foreign investment into the sector.

Why this briefing paper?

v  To critically examine the environmental, social, and health impact assessment of ADDAX, SOCFIN AND Sierra Leone Agriculture (SLA) and determine their short comings.

v  To contribute to the public debate on the impact/ramifications of industrial scale agriculture on the environment.

v  To proffer recommendations for possible incorporation into policy

v  To support existing advocacy to influence policy 

What does an ESHIA seek to do: Process and Function

EIA is simply define as a systematic process to identify, predict and evaluate the environmental effects of proposed actions and projects. It is applied prior to major decisions and commitments being made. Social, cultural and health effects are considered as an integral part of the EIA (EIA Training Resource Manual, UNEP 2002).

 

The EIA process should be:

_ purposive – meeting its aims and objectives

_ focused – concentrating on the effects that matter

_ adaptive – responding to issues and realities

_ participative – fully involving the public

_ transparent – clear and easily understood

_rigorous – employing ‘best practicable’ methodology

_ credible – carried out with objectivity and professionalism

_ efficient – imposing least cost burden on proponents

Source:

 

Furthermore, ESHIA should:

_ be applied to all proposals with significant impacts

_ be applied early in the project cycle

_ address relevant environmental, social and health impacts

_ identify and take account of public views

_ result in a statement of impacts and mitigation measures

_ facilitate informed decision making and condition setting

 

Environmental, Social and Health Impact Assessment process

 

Figure 1: The diagram showing pictorial/flow chart form of a general framework of EIA process

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Source: Environmental Impact Assessment Training Resource Manual, UNEP 2002.

 

Generally the EIA process comprises the following steps:

_ screening – to decide if and at what level EIA should be applied

_ scoping – to identify the important issues and prepare terms of reference

_ impact analysis – to predict the effects of a proposal and evaluate their significance

_ mitigation – to establish measures to prevent, reduce or compensate for impacts

_ reporting – to prepare the information necessary for decision-making

_ review – to check the quality of the EIA report

_ decision-making – to approve or reject) the proposal and set conditions

_ follow up – to monitor, manage and audit impacts of project implementation

_ public involvement – to inform and consult with stakeholders

(Environmental Impact Assessment Training Resource Manual, UNEP 2002)

 

World Bank process

The schematic diagram of the World Bank model while could be seen as more complex compared to the UNEP, has the following steps:

_ Screening and Scoping

_ Impact Identification

_ Impact Prediction

_ Mitigation and Enhancement

_ Reporting

_ Environmental Management Plan (EMP)

_ Environmental Audit/Evaluation

 

FAO Process

The schematic diagram of the FAO model is presented in a more simplistic fashion. It entails however the following steps and is well presented in the diagram.

_ Initial environmental review (IER)

_ Environmental screening

_ Environmental scoping

_ Environmental analysis of assessment

_ Environmental measures

_Appraisal and Approval

_ Reporting

_ Environmental management plan

 

Figure 3: Overview of EIA process

Source: Environmental Impact Assessment: Guidelines for FAO field projects

 

The Environment Protection Agency, Sierra Leone (EPASL)

The EPASL is the leading agency responsible for the protection of the country’s environment. In part 3 of its statute are spelt its functions in which it is stated: Subject to this Act, the Agency shall perform the following functions:–

(1) advise the Minister on the formulation of policies on all aspects of the environment and in particular make recommendation for the protection of the environment;

(2) co-ordinate the activities of bodies concerned with the technical or practical aspects of the environment and serve as a channel of communication between such bodies and the Minister;

(3) co-ordinate the activities of such bodies as it considers appropriate for the purposes of controlling the generation, treatment, storage, transportation and disposal of industrial waste;

(4) secure, in collaboration with such persons as it may determine the control and prevention of discharge of waste into the environment and the protection and improvement of the quality of the environment;

(5) collaborate and coordinate with such foreign and international bodies as the Agency considers necessary for the purposes of this Act;

(6) issue environmental permits and pollution abatement notices for controlling the volume, types, constituents and effects of waste discharges, emissions, deposits or other source of pollutants and of substances which are hazardous or potentially dangerous to the quality of the environment or any segment of the environment;

(7) issue notices in the form of directives, procedures or warnings to such bodies as it

may determine for the purpose of controlling the volume, intensity and quality of noise in

the environment;

(8) prescribe standards and guidelines relating to ambient air, water and soil quality, the pollution of air, water, land and other forms of environmental pollution including the discharge of wastes and the control of toxic substances;

(9) ensure compliance with any laid down environmental impact assessment procedures in the planning and execution of development projects, including compliance in respect of existing projects;

(10) act in liaison and co-operation with government agencies, local councils and other bodies and institutions to control pollution and generally protect the environment;

(11) conduct investigations into environmental issues and advise the Minister thereon;

(12) promote studies, research, surveys and analyses for the improvement and protection of the environment and the maintenance of a sound ecological system;

(13) initiate and pursue formal and non-formal educational programmes for the creation of public awareness of the environment and its importance to the economic and social life of Sierra Leone;

(14) promote effective planning in the management of the environment;

(15) develop a comprehensive database on the environment;

(16) impose and collect environmental protection levies in accordance with this Act or regulations made under this Act;

(17) coordinate and monitor the implementation of national environmental policies;

(18) coordinate with Government Ministries, local councils and other agencies on matters

relating to environmental protection and management;

(19) collect and make available to the public or interested persons or bodies, through publications and other appropriate means and in cooperation with public or private organizations, environmental data and information;

(20) promote the establishment of national environmental standards;

(21) act as the focal point on all issues concerning the environment; and

(22) perform any other function conferred on it under this Act.

 

13. Except otherwise provided in this Act, the Agency in the performance of its functions under this Act or any other enactment shall not be subject to the direction or control of any person or authority.

 

While the Agency is situated in the Ministry of Lands, Country Planning and the Environment, the statute confers unto it in section 13 complete independence. This means that it should perform its functions with total autonomy.

 

The statute in part 4 refers to Environmental impact Assessments and subjects anyone who intends to undertake certain categories of projects (as set out in the first schedule of the statute) to apply to the Agency for an EIA licence. The first schedule sets out projects that would require EIA licence.

 

 

First Schedule, section 24:

(a) substantial changes in renewable resource use (e.g. conversion of land to agricultural production, forestry or to pasture land, rural development, timber production);

(b) substantial changes in farming and fisheries practices (e.g. introduction of new crops, large scale mechanisation or use of chemicals in agriculture);

(c) exploitation of hydraulic resources (e.g. dams, drainage and irrigation projects, water basin development, water supply);

(d) infrastructure (e.g. roads, bridges, airports, harbours, transmission lines, pipelines, railways);

(e) industrial activities (e.g. metallurgical plants, wood processing plants, chemical plants, power plants, cement plants, refinery and petro-chemical plants, agro-industries).

(f) extractive industries (e.g. mining, quarrying, extraction of sand, gravel, salt, peat, oil and gas);

(g) waste management and disposal (e.g. sewerage systems and treatment plants, landfills, treatment plants for household and hazardous waste);

(h) housing construction and development schemes;

(i) establishment of places of entertainment, motor repair garages and welding shops;

(j) importation of second hand vehicles.

 

In addition to the first schedule are also other schedules. For example schedule two of section 25 sets out the factors determining the need for an EIA for a project. In addition, schedule three of section 26 sets out the contents of an EIA.

 

Schedule 2, Section 25

The full text of schedule 2, section 25 is not stated here. However to determining whether a project requires an environmental impact assessment should include among others–

(a) the environmental impact on the community;

(b) the location of the project;

(c) whether the project transforms the locality;

(d) whether the project has or is likely to have substantial impact on the ecosystem of the locality;

(e) whether the project results in the diminution of the aesthetic, recreational, scientific, historical, cultural or other environmental quality of the locality;

(f) whether the project will endanger any species of flora or fauna or the habitat of the flora or fauna; etc.

 

Schedule 3, Section 26

The body of any EIA shall contain a true statement and description of–

(a) the location of the project and its surroundings;

(b) the principle, concept and purpose of the project;

(c) the direct or indirect effects that the project is likely to have on the environment;

(d) the social, economic and cultural effect that the project is likely to have on people and society;

(e) the communities, interested parties and Government ministries consulted;

(f) any actions or measures which may avoid, prevent, change, mitigate or remedy the likely effect on people and society;

(g) any alternatives to the proposed project;

(h) natural resources in the locality to be used in the project;

(i) the plans for decommissioning of the project;

(j) such other information as may be necessary for a proper review of the potential environmental impact of the project.

 

Other schedules like schedules 4, 5 and 6 set out respectively: controlled substances, application forms, and permit to import or export controlled substances. For the purpose of this assignment the first three schedules will serve as points of reference for the three ESHIA reports even though other schedules especially schedule 5 will be cross referenced when the need arises.

 

Analyses and Findings

  1. 1.         Environmental Social and Health Impact Assessment for the Establishment of Oil Palm and Rubber Estates in the Malen Region, Southern Sierra Leone.

 

For the purpose of this analysis the report shall be referred to as “the Socfin Report.” The project for which the ESHIA report was done is oil palm and rubber plantations. The initial nucleus size of the project according to the ESHIA report is 12,000ha and is located in the Malen region. The arable land area under lease in Malen represents approximately 40% of the chiefdom land mass.

 

The Socfin report is inadequate in a number of ways:

  1. The report failed to present a true statement and description of the location of the project and its surroundings. While the report covered levels of description of the project location in plain descriptive language, it failed to enumerate or map names, types of species and there abundance in the project location. By doing this the base line natural biodiversity would have been captured giving a proper understanding of the biodiversity situation in the project location. Indeed an attempt was made to list in table 10, page 124 animal diversity in the project location against a general trend in the country, this again fell short of informing on population samples in a given space/transect. But while fauna was attempted, the vegetation or flora diversity, a sedentary population, much easier to study were not identified and categorised. Apart from the type of vegetation present in the Malen region it was necessary to closely note flora diversity as the major main inhabitants of the region. It would have been prudent to highlight species range, abundance and diversity in each of the categories presented in the vegetation map on page 120.

 

Apart from enumerating the natural biodiversity of the region, there was need to enumerate the crop or agronomic diversity of the region as a baseline study. This gives a complete picture of what is at stake when the land area in question is brought under monoculture cultivation. It would also be in record of the kinds of species; animals, plants and crops that featured in this location if proper restoration of the land is to be done in future (at decommissioning stage). Failing to present these in the ESHIA study presents a great loss for the future both in terms of ecological services and sustainable land management.

  1. There are 3 major rivers, in the project area viz, Malen, Wange and Sewa. There are also many streams and lakes in the same region, (page 165). Water is a critical natural resources to be used and already in use in the operations of the company. Water is extracted for various uses in the operations of the company. Nursery operations require tremendous amount of water to be extracted from the available water sources. Crop in the field is very likely going to need water especially at the early years of its development. The Socfin report failed to inform readers on the quantum of water to be extracted for the nursery, the plantation and at different stages of the estate’s development as well as in the extraction of palm oil during operations of the oil mill.  From which sources would water be extracted? Is there going to be any irrigation facility to be developed and what would be the extent of the irrigation? Finally, form the survey map of Socfin’s leased area it is observed that quite a substantial length of a particular river serves as boundary to the leased land. The consequences of such annexation are not mentioned in the report.

The report concentrated on the mere description of the hydrologic system and avoided engaging with the intricate issues of water extraction from water sources, its impact on the water sources, particularly on transient flows between groundwater and surface water as well as impact on surface and ground water. Surface water flow assessment and groundwater discharge are bound to be prerequisite where water extraction from water sources is meant for industrial type operations such as watering seedlings in nursery meant for plantation and water use in oil mill. With the correct understanding of the hydrology in the region it is possible to have a clear picture of the extent of the impact on communities living up and down streams of rivers or on other surface water sources.  Communities depend on water for various purposes, domestic and others. Any impact on water quantity and quality will surely affect community health and sanitation.

  1. Critical to water safety or condition is pollution from noxious substances. The report dwelt on the use of chemical fertilizers and their likely pollution effects both of the soil and water regimes. The report mentioned the very likely use of herbicides, insecticides and pesticides. However, the report was very silent on the commercial and scientific names of these chemicals in spite of the fact that these can be provided by the company with an enormous experience in oil palm production on the continent and in Asia. The need for the names is important because they should be checked against EPA’s list of chemicals that are either banned or requires certain permission to import, see EPA Act 4th schedule.
  2. Worthy of mentioning is the need for a comprehensive list of all villages and hamlets within the leased area and their demographic data. This would indicate the scale of impact on a population living within the lease envelope and will reduce future conflict in a situation involving any resettlement.

 

 

 

 

 

 

 

 

 

 

 

Table 1: Showing matrix of the Extent to Which the Three EIAs Conform to the EPASL Law

 

 

Item

 

Environmental Impact  Report Title

 

Responsible Company

Conforms to

EPA SL Schedule 1

Conforms to

EPA SL Schedule 2

Conforms to

EPA SL Schedule 3

 

Comment

1 Environmental Social and Health Impact Assessment for the Establishment of Oil Palm and Rubber Estates in the Malen Region, Southern Sierra Leone. Socfin Agricultural Company, SL Ltd.  

 

 

 

Conforms

 

 

 

 

Conforms

 

 

Partly

Schedule 2 of the EPASL statute is silent about categorizing projects as seen in the FAO’s overview of the EIA process. Here projects are categorized as A, B, C.
2 Environment and Social Impact Assessment of an Oil Palm Development Project in Port Loko District, Sierra Leone. Sierra Leone Agriculture  

 

 

 

 

 

 

Conforms

 

 

 

 

 

 

 

Conforms

 

Partly

Apart from the recently developed environmental and social regulations for the minerals sector by MMR and EPASL, no such regulation exists for other sectors including industrial farming or large scale agriculture.
3 Sugarcane and Ethanol Project In Sierra Leone Addax Bioenergy, Addax & Oryx Group (AOG)  

 

Conforms

 

 

Conforms

Partly

No environmental regulation exists for the production of biofuels.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 2:  Matrix showing the extent to which the ESHIAs conforms or fail in aspects of Schedule 3 and 4 of the EPASL Act

Item  

Environmental Impact  Report Title

Responsible Company EPA SL Schedule 3 (Failed) EPASL Schedule 4 (Failed)                                                                     Comment
      a b c f h   Chemicals  
1 Environmental Social and Health Impact Assessment for the Establishment of Oil Palm and Rubber Estates in the Malen Region, Southern Sierra Leone. SAC x x x x x   x One Chemical likely to be used or already being used by Socfin is TRICLOPYR 480 EC, a herbicide against dicotyledonous plants. The equivalent acid of Triclopyr is Butoxyethyl ester
2 Environment and Social Impact Assessment of an Oil Palm Development Project in Port Loko District, Sierra Leone. SLA x x x x x   x  
3 Sugarcane and Ethanol Project In Sierra Leone ADDAX x x x x x   x  

Note: EPA Act, Third Schedule points a, b, c, f, h is referred to in the sixth column of this table.

 

  1. 2.         Environmental and Social Impact Assessment of an Oil Palm Project in Port Loko District, Sierra Leone.

For the purpose of this analysis the report shall be referred to as “the SLA report.”The report was prepared by CEMMATS Group Ltd on behalf of Sierra Leone Agriculture (SLA). The project for this report is Oil Palm Plantation. The project is situated in the Bureh, Kasseh, and Maconteh (BKM) amalgamated Chiefdom of Port Loko district, Northern Sierra Leone. The project area covers a total of 41,584.4ha (SLA report, 36), and will affect 32 villages in the BKM.

  1. The project area description to present a baseline of the industrial farm project was to some extent described even though the description had biases towards geology and soils of the concession area. The concession area is characteristic of low fertility generally; see pg 110-111 and table 3.15 indicating that fertilizers are very likely to be used to improve soil fertility as stated in the discussion, pg 111. Furthermore, the soil suitability evaluation accounts that all the management units are suitable for some form of crop production and these include: rice (upland and low land), groundnuts, maize, cassava, sweet potato, citrus, oil palm and vegetables.

 

The report attempted to list the flora and fauna species within the concession area, however, the manner in which care was taken to describe the soil of the region should have been applied to the flora species. Vegetation description was by and large attributed to those of farm bush in fallow and some attempts at inventorying of flora species were done, even though mapping of the species was ignored. The report presents a dramatic departure from the SOCFIN report as it attempted to identify the agro-vegetation/species of the concession.

 

  1. There is a map of the concession area (pg 85) included in the ESHIA report. It is observed that the concession area is largely adjacent to the Little Scarcies River; in fact it takes the meandering turns of a substantial length of the river. This portrays a picture of trying to capture the river to as larger extent as possible.
  2. Data on annual water budget is over 30 years old and may be unreliable giving climate change and variations as crucial factors in modern day environmental crisis. Such outdated data may therefore influence outcomes of discussions relating to hydrological conditions in the concession area, particularly that which deals with water discharge, flow rate, drainage and even evapotranspiration rate 

The report also share the same characteristics as the Socfin ESHIA by ignoring the critical issue of water extraction from the Little Scarcies during the operation of the company at every aspect of its phases of operation, including developing and operating the nursery, developing the estate/plantation and the oil mill. Even though the report considered water intake as a significant issue for oil palm production, it did not dwell on the impact of such intake. Water extraction from water sources that is also shared by communities is likely to affect communities with their water needs and this will be profound in the dry periods and should the investor drain out streams and wetlands. Water wells in communities are likely to experience falls in water table when dramatic shifts in hydrological regimes occur.

 

  1. While the SLA ESHIA report acknowledges contamination of surface and ground water it mentions only in general terms the contaminants such as pesticides, fertilizers, other agrochemicals. It is important that specific chemicals intended to be used; their commercial and chemical names are included in the study. This will assist EPASL to understand at the preliminary stages the chemicals to be used in the operations of the investor and make appropriate recommendations.

 

  1. Like the data on water budget, other climatic data presented in table 3.2, page 89 are also over 30 years old and may present reliability challenges given the climate change context of today.

 

  1. Sugarcane and Ethanol Project In Sierra Leone:

The ESHIA report of ADDAX Bioenergy, also referred to as “the ADDAX Report” compared to the other two ESHIA reports, the ADDAX Environmental, Social and Health Impact Assessment (ESHIA) is a lot more detailed. A number of specialist studies were carried out including:

  • Scoping study,
  • Land use Impact Assessment,
  • Biodiversity and Ecological Impact Assessment,
  • Hydrology and Surface Water Assessment,
  • Social Impact Assessment, and
  • Resettlement Policy Framework

All of these individual specialist reports generated the Framework Environmental and Social Management Plan.

The ADDAX project will be developed in an area covering about 15,500 hectares, including: A total planted area of 12,500ha, consisting of an annual harvested area at full development of 10,500ha and with 2,000ha lying fallow every year for a rest period. The ESHIA report is about the growing of sugar cane to produce ethanol in an expected 200-day season for the crop. The factory will produce 90,000 m3 of ethanol annually and will have its operating period extended into the cane off-season by using cassava tuber as an alternative feed stock supply. This cassava tuber will be purchased from out-growers in and out of the region. The sugar cane plantation/estate will be irrigated during the dry season and will be harvested mechanically (ESHIA Volume 2).

  1. Description of the biodiversity and the ecological environment of the study area was categorized into riparian and swamp forest, village/terrestrial forest, wetlands/bolilands, Lophira woodlands, palm plantations, elephant-grass grasslands and cultivated lands however, careful mapping of flora and fauna in range and diversity was lacking in the baseline of the report.

The report states that the loss of natural vegetation associated with loss of biodiversity will occur, yet no rigorous description of the species that comprise the natural vegetation was presented.

  1. Concession map and land use is obtained in volume 2 of the ESHIA report of ADDAX Bioenergy. Like the other two industrial scale agriculture for none food crops, the concession map is to a great proportion proximate to river sources (Rokel and Mabole), implying that the estate will heavily be reliant on water from these sources. The report did recognize this and is stated in the hydrological study (vol. 2 hydrology and surface water assessment), however the report fails to embark on the critical issue of water consumption. 
  1. The ESHIA report of ADDAX states that water will need to be extracted from the Rokel River the same river upon which the Bumbuna Hydro -electricity facility depends. But while the Bunbuna Hydro-electric facility is at the upper limits, the ADDAX project is at the lower limits. Water extraction for the ADDAX operation is contextualized in the hydrological study against flow rate of the Rokel River. While flow rate is important it is insufficient to inform on the volume of water discharged. In similar vein the report indicated the water extraction requirement of ADDAX but failed to put real volume value to be consumed in the year.

The report failed to inform readers the basis of ADDAX water extraction requirement. It is known that water requirement of sugar cane is about 205cm or annually about 196 cm (Khaled Bali, Juan Guerrero, Rick Snyder, and David Grantz).  The approximate number of crops in the estate based on an experienced company like ADDAX would determine the likely volume requirement of the crop in the field and in addition to this factors such as evapotranspiration and surface evaporation can give a guide as to the volume of water required in the field. Considering other operations on the estate such as construction, and ethanol production will be added water uptake from the river bringing a total water requirement of the estate.

 

It is stated that no impact will be subjected to the Rokel River given the flow rates and the demand rates but this can be only ascertained when such detail analysis are carried. Demand downstream is bound to affect supply in the upstream hence supply that would be required for the hydro-electricity, yet the hydrological study failed to consider the analysis of impact in the upper catchment/dam area especially now that other factors such as climate change/variation are now at play more than ever before.

Swamps and boli lands will be affected by the operations of the company, especially when leveling of the land mass is required for adequate ease of operation, such as mechanization, and watering of the estate noting that erosion should be minimized. This leveling would mean that swamps and boli lands will be drained as they are filled with earth or soil. This drainage is bound to have levels of impact on ground water sources. Communities within the range of such drainage will have their ground water sources affected. Water table of wells dug manually will be reduced or may even dry out.

  1. Water and soil contamination from the use of inorganic/chemical fertilizers, herbicides, pesticides and fungicides is acknowledged in the report. Contamination will take two major forms, erosion and leaching. Since according to the report gravity fed water system will be used there is bound to be erosion during this process, this will be acute in the rainy season when there will be surplus water on the estate. The residual chemicals will be drained into water bodies and concomitantly lead to water poisoning that will be used for downstream communities. Leaching, the next way of water contamination will affect ground water as the chemicals gradually percolate the soil and enter ground water sources. Water poisoning by leaching becomes acute when it is cumulative that is occurs for prolong periods such as those of the lease time of company.

 

Some herbicides mentioned for use in the report are Glyphosate (roundup), Acetochlor (harness), Gesparim (Atrazine), 2,4D ester, hexazinone (velpar), Diuron (DCMU), Metribuzin (Sencor), Dicamba, Trifluxysulfron (Envoke), Pendimethalin (Prowl 3 3EC). The mention of these names while an improvement, however, mentioning the active chemical ingredient would have been helpful if only to compare with EPASL list of cautious chemicals. No mention of names of pesticides and fungicides in the discussion either.

Lime, Nitrogen, Phosphorus and Potassium are the main inorganic fertilizers that will be used in the growing of the cane crop. The area under cultivation would require large quantities of these chemicals. For e.g. 180kg/ha of Nitrogen at the ratoon stage would require a total of 1.8million kg of Nitrogen over 10,000ha of land. The continuous use of such large quantities of chemicals over prolonged periods of time is bound to destroy the soil structure and impacting the future use of the soil when the lease period would have expired. In addition to the standard fertilizers, trace elements to induce crop efficiency, resistance and other physiological performance of the crop will be used. These trace elements are sources of heavy metals whose concentration over time (cumulative) can be very lethal. No mention of names of trace elements was reported in the ESHIA, even when the use is implied in the report.

 

Synthesis

The ESHIA reports of the three investments are lacking in crucial detailed information which would have a telling effect when consideration will be paid to rejuvenation of the land to its original status at project closure phase. The need for a well documented true picture in the baseline survey/study of a given concession is essential because it will serve as the only evidence in documented form of the concession area in archive. The EPA Act states:  An EIA shall contain a true statement and description of– (a)the location of the project and its surroundings…. A true picture should therefore present detail species (flora and fauna) mapping and abundance in the area. This information is required not only for the purpose of re-colonising the concession area at time of project closure but also to understand the real value of the ecological services in terms of cost-benefit analysis. What value could be ascribed to the biological diversity present within the concession before it is replaced with monoculture species? Such value can be estimated with a proper understanding of the ecological services the eco-system provides, which by extension depend on the available species, their range and abundance.  Therefore if the true picture is not presented as it is with the three ESHIA reports such benefits to be lost will not be compared to the alternative plantation. The next need for a true picture would be to inform on what clearing will cause to the livelihood situation and hence the social conditions of the communities. Farmlands are usually lost and on such land there is usually an agro-ecology presenting the variety of crops grown on farmlands and other plantation crops.  Crop and crop land lost to the large scale plantations also portrays the level of poverty, food insecurity and socio-cultural issues that will pervade communities. But the agro-ecological mapping will assist to determine which crops were viable in specific areas of the concession when once the land is returned to the owners after the lease.

 

Water is a key element in agriculture and water becomes even the lead resources for industrial scale agriculture. This assertion is evident in the location of the plantations/estates of the three companies whose ESHIA reports are assessed by this report. The maps of the three concession areas being developed by Sierra Leone Agriculture, ADDAX and Socfin portray that the concession areas are very close to the nearby rivers. All of the maps show that the contours of the rivers are followed to a great extent giving extensive access to the water resources of the rivers. It is no gainsay to therefore state that industrial scale agriculture and processing would require industrial scale water extraction from those water bodies to which they are proximately located.

Water extraction analysis within the hydrological study should be a paramount component of ESHIA reports. Such analysis should include an estimation of the quantum of water to be used by the entire operation of the company, the impact such extraction would likely have on the water resources of the region, especially on communities up and down stream that depend on the resources. Other impacts on ground water regimes of the region must be investigated and how that translates on ground water usage of the region.

A proper hydrological study should take into account the seasonality of the country which is marked with two extreme cases of heavy rains and acute dry spell. Large volume of water would be required in certain places for tender plants in the field if post field planting losses is to be minimized. Such uptake of water by the industrial estate would also be competing with community water demands at a time when water levels are at their lowest points.

 

In relation with water issue is the aspect of contamination by agro-chemicals whether chemical fertilizers, trace elements, pesticides, herbicides, and fungicides etc. Prolong use of these chemicals and the volume applied over vast areas will surely percolate into ground water, or drain into surface water through erosion. Either or both ways will have profound impact on community health and sanitation which is a major issue in Sierra Leone.

Conclusion

Environmental, Social and Health Impact Assessments are at the heart of mega-projects such as these industrial plantations. Industrial scale land clearing has immense environmental ramifications and so deserves total care in undertaking the ESHIA investigation as well as scrutinising the report. It is observed that critical environmental issues were overlooked in all of the reports.

Recommendations

  1. ESHIA reports must be seriously interrogated to identify gaps that may pose future problems
  2. Ensure that proper ESHIAs are done by avoiding generalizations and applying specifics in cases such as chemicals, water use, and biodiversity.

3.  Ensure that the Environmental Protection Agency (EPA) scrupulously assesses EIAs to meet the standards set in the Environmental Protection Act 15 ensure that the EPA establishes guidelines (as is already the case for the extractive industry) to assist companies to improve on their environmental standards.

4.  As far as possible, do not allow traditional or any other authorities to coerce or intimidate local communities on behalf of the company

5.   Respect the principle of free, prior and informed consent during negotiations

6.   Ensure that proper EIAs are conducted in line with the Environmental Protection Act and

FAO guidelines, and they include specific information on chemical and water use, impact on community access to water and water quality, and biodiversity.

References

  1. Environmental Protection Agency,  Supplement to the Sierra Leone Gazette Vol. CXXXIX, No. 44

dated 11th September, 2008

  1. Environmental and Social Impact Assessment of an Oil Palm Project in Port Loko District, Sierra Leone.
  2. Sugarcane and Ethanol Project In Sierra Leone: – The ESHIA report of ADDAX Bioenergy, also referred to as “the ADDAX Report.”
  3. Henry D. Foth, Fundamentals of Soil Science 7th edition, John Wiley & Sons
  4. R. J. Harlley, The Agricultural Notebook 17th edition, Butterworths.
  5. UNEP, Environmental Impact Assessment: Training Resource Manual, 2nd edition.
  6. FAO, Environmental Impact Assessment: Guidelines for FAO Field Projects
  7. Australia Environmental Protection Agency, Environmental Impact Assessment

 

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