Preparing the ESIA and Mine Design

Early Phases of the ESIA

Terms of reference for the assessment were approved by the Ministry in charge of Environment in 2011 based on extensive consultations locally, with national authorities in Conakry, and with key international parties like UNESCO and the International Union for the Conservation of Nature (IUCN). Intensive studies to characterise the baseline conditions were conducted between 2011 and 2013.

Recent and On-Going Work on the ESIA and Mine Design

From 2014 to 2019, the Project’s studies were largely on hold. SMFG used this period to collect data addressing key topics mainly related to biodiversity, including the World Heritage Site’s outstanding universal value. Engineering work focused on innovative design improvements to further reduce environmental and social impacts. By late 2019, at the time of the transfer of ownership to High Power Exploration, several datasets had become outdated, and local social and land-use conditions had changed. The new owners were keen to complete baseline studies. From late 2019 through March 2020, multiple field studies were undertaken to update and complete all relevant datasets, whose analysis and writing-up followed later in 2020 and into 2021. In parallel, technical studies related to designing the mine and all associated operations continued throughout 2020 and are still underway in 2021.

ESIA-Mine Design Interface

SMFG’s staff responsible for mine engineering and design and those responsible for the ESIA work side-by-side in the same offices and with a single design philosophy to ensure that all design decisions are made in consideration of potential impacts. Together, they select optimal ways to avoid or otherwise minimise negative impacts, and identify and maximise positive impacts. When a final design for the Project is selected, the impacts will be summarised in the ESIA report, and management plans will be prepared to manage predicted, residual impacts.

Mine Closure

Mine Closure

A progressive closure plan will be developed so that when an area is no longer needed, it will be stabilised and rehabilitated at the time, without waiting.

A final closure plan will be an integral part of the initial project design to ensure that mine closure is addressed from the very beginning, when construction starts. When the Project is completed, rehabilitation of the entire area will be completed according to the final closure plan. SMFG has committed to IFC’s Performance Standards, and benchmarks against ICMM’s Mining Principles in the development and execution of the progressive and final closure plans.

The Mitigation Hierarchy

SMFG rigorously implements the ‘mitigation hierarchy’ of first avoiding impacts, then minimising them, and then restoring areas post-disturbance.

SMFG is and will continue ensuring that its activities do not have material, lasting, negative impact on the outstanding universal value (OUV) of the Mount Nimba WHS, and do not put its integrity at risk. Through the ESIA process, SMFG emphases avoiding and minimising impacts above all, in accordance with the IUCN’s World Heritage Advice Note on Environmental Assessment.  SMFG will seek to minimise the need for offsets, and recognises that OUV is unique and cannot be offset.

Standards for the ESIA

First and foremost, SMFG adheres rigorously to Guinean legal requirements.

In addition, SMFG has committed to IFC’s Performance Standards. The company benchmarks against international good practice arising from the status of the adjacent World Heritage Site and Nimba Mountains Biosphere Reserve, too, namely the International Council on Mining and Metal’s Position Statement on Mining and Protected Areas, and IUCN’s World Heritage Advice Notes on Environmental Assessment and on Mining and Oil/Gas Projects. These provide advice on what is appropriate or not, and on specific elements of the process of environmental impact assessment when pursuing an industrial project near a world heritage site.

SMFG’s Commitments

SMFG’s Commitments

SMFG seeks to achieve net gain in the biodiversity values for the critical habitat identified in the Project’s area of influence, in accordance with IFC’s Performance Standard 6. The primary focus of net gain will be on the core areas of the Nimba Mountains Biosphere Reserve, and above all the Mount Nimba World Heritage Site, where the company will invest significantly in protection and restoration.

SMFG recognises that the project must stand on its environmental merits. While the Project’s investments in equitable, sustainable local development will be significant, social benefits cannot justify environmental losses.

Who Is Conducting the ESIA?

The list of contributors to the ESIA’s studies includes Golder Associates, Insuco Guinée SARL, NewFields Consulting, Hatch Associates, the Berlin Museum of Natural History, Bat Conservation International, the Royal Museum of Central Africa, the Missouri Botanical Gardens, the Free University of Brussels, the National Museum of Natural History – Paris, the Institut de Recherches Agronomiques de Guinée (IRAG), the Institut de Recherches Ecologiques de Bossou (IREB), the Centre International de Recherche Agricole pour le Développement (CIRAD), the Hungarian Natural Heritage Trust, Afrique Nature, the University of Kent, the Copenhagen Zoo, Nangui Abrogoua University, the LAMTO Research Station, OKAPI Consulting, the Wild Chimpanzee Foundation, many other institutions and still further individual specialists associated with universities and research institutes.