Intended for
Compagnie des Bauxites de Guinée (CBG) and potential lenders
Date
20th November 2015
Project Number
UK14-21611
CBG BAUXITE MINE
EXPANSION PROJECT,
GUINEA
ENVIRONMENTAL AND
SOCIAL DUE DILIGENCE
– TECHNICAL REPORT
CBG BAUXITE MINE EXPANSION PROJECT, GUINEA
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE –
TECHNICAL REPORT
Project No.
Issue No.
Date
Made by
Checked by
Approved by
UK14-21611
1
20th November 2015
C Halliwell, R Bisset, P Burston, K Nash, L Vining, R
Andrews, V Votrin
Chris Halliwell
Richard Andrews
Made by:
C Halliwell, R Bisset, P Burston, K Nash, L Vining ,
R Andrews, Val Votrin
Checked/Approved by:
Chris Halliwell
/
Richard Andrews
This report has been prepared by Ramboll Environ with all reasonable skill, care and
diligence, and taking account of the Services and the Terms agreed between Ramboll
Environ and the Client. This report is confidential to the Client, and Ramboll Environ
accepts no responsibility whatsoever to third parties to whom this report, or any part
thereof, is made known, unless formally agreed by Ramboll Environ beforehand. Any
such party relies upon the report at their own risk.
Ramboll Environ disclaims any responsibility to the Client and others in respect of any
matters outside the agreed scope of the Services.
Version Control Log
Revision
Date
Made by
Checked by
Approved by
Description
Issue 1
20/11/2015
CH,RB,PB,
CH
RJA
Technical Environmental and Social
KN, LV, RJA
Ramboll Environ
Box House
Box
Wiltshire
SN13 8AA
United Kingdom
T +44 122 574 8420
www.ramboll-environ.com
Due Diligence Report
Environmental and Social Due Diligence – Technical Report
CBG Bauxite Mine Expansion Project, Guinea
CONTENTS
EXECUTIVE SUMMARY
1.
INTRODUCTION
2.
SCOPE AND STRUCTURE OF THE REPORT
2.1
Scope
2.2
Project Standards
2.3
Structure of the Report
2.4
Limitations
3.
PROJECT DESCRIPTION
3.1
Current Mine Activities
3.2
Project Description – the Financed Project
4.
SIGNIFICANCE ASSESSMENT
4.1
Review Findings
4.2
Categorisation of Risk
5.
LEGISLATIVE FRAMEWORK AND OTHER PROJECT
STANDARDS
5.1
National Legislation
5.2
International Standards
5.3
Lenders’ Standards
6.
PERFORMANCE STANDARD 1: ASSESSMENT AND
MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS
AND IMPACTS
6.1
Management Systems
6.2
Environmental and Social Impact Assessment
6.3
Management plans
7.
PERFORMANCE STANDARD 2: LABOR AND WORKING
CONDITIONS
7.1
Applicability of PS2
7.2
Analysis of HR documentation against PS 2 requirements and
identification of gaps
7.3
Conclusions and recommendations to close gaps
8.
PERFORMANCE STANDARD 3: RESOURCE EFFICIENCY
AND POLLUTION PREVENTION
8.1
Air quality
8.2
Noise and Vibration
8.3
Water and Sediments
8.4
Geology, soil and seismicity
8.5
Waste management
8.6
Ships’ wastes, ballast water and sediments management
8.7
Hazardous materials management
8.8
Landscape and Visual Impacts
8.9
Greenhouse gas emissions
9.
PERFORMANCE STANDARD 4: COMMUNITY HEALTH,
SAFETY, AND SECURITY
9.1
Human rights
10.
PERFORMANCE STANDARD 5: LAND ACQUISITION AND
INVOLUNTARY RESETTLEMENT
10.1
Resettlement and Livelihoods Restoration Policy Framework
10.2
Compensation-related grievances
10.3
Livelihood Restoration
10.4
Unplanned in-migration (influx)
I
1
3
3
3
4
4
5
5
6
11
11
11
13
13
13
15
16
16
17
28
35
35
35
38
41
41
51
54
60
61
63
64
67
67
74
76
79
79
80
80
81
Environmental and Social Due Diligence – Technical Report
CBG Bauxite Mine Expansion Project, Guinea
11.
11.1
11.2
11.3
11.4
12.
13.
13.1
13.2
13.3
13.4
13.5
13.6
13.7
13.8
13.9
13.10
PERFORMANCE STANDARD 6: BIODIVERSITY
CONSERVATION AND SUSTAINABLE MANAGEMENT OF
LIVING NATURAL RESOURCES
Introduction
ESIA
Critical Habitat Assessment
Biodiversity Action Framework
PERFORMANCE STANDARD 7: INDIGENOUS PEOPLES
PERFORMANCE STANDARD 8: CULTURAL HERITAGE
Legislative context and international standards
Categories of cultural heritage
Baseline Coverage of the mine expansion, rail network and
port developments
Cultural heritage impact assessment
Chance Finds
Communication / stakeholder engagement
Mitigation measures
Access
Project use of Cultural Heritage
Summary
85
85
85
98
100
110
111
112
112
113
114
114
115
115
116
117
117
Environmental and Social Due Diligence – Technical Report
i
CBG Bauxite Mine Expansion Project, Guinea
EXECUTIVE SUMMARY
Ramboll Environ UK Limited (hereafter Ramboll Environ) was commissioned to fulfil the role of
Lenders’ Independent Environmental and Social Consultant (IESC) by Compagnie des Bauxites de
Guinée (‘CBG’ or the ‘Company’), the International Finance Corporation (IFC) and other potential
lenders which are considering financial support for a CBG bauxite mine Expansion Project in
Guinea.
CBG has been operating since 1973 and has its facilities located in Kamsar and Sangarédi in the
northwest of Guinea. CBG currently mines, transports by rail, processes and ships approximately
13.5 million tonnes of bauxite ore per annum. The Expansion Project will increase the capacity of
the current mine in a phased manner to 27.5Mtpa by 2022. In addition to the mine expansion,
the Project will also include improvements to town infrastructure, rail operations and port
facilities.
It should be noted that the scope of the Expansion Project as originally envisaged by CBG has
changed. Originally CBG envisaged Phase 1 as an increase to 18.5 Mtpa and later 22.5 Mtpa
followed by a Phase 2 which envisaged a further expansion to 27.5 Mtpa. The scope covered by
the proposed financing is for a tonnage of 18.5 Mtpa. Some of the documentation provided for
review (such as the Environmental & Social Impact Assessment referenced below) considers the
eventual 27.5 Mtpa production level. The ESIA includes numerous mitigation measures that have
been developed based on the full expansion project tonnage; the full Expansion Project is
inclusive of the 18.5Mtpa phase. Consequently the mitigation measures expressed in the ESIA
are equally applicable to the 18.5Mtpa.
Should any additional increases in production be proposed for the CBG concession beyond the
18.5 Mtpa financed CBG is committed to follow an appropriate environmental and social
assessment process (e.g. preparation of an ESIA addendum) consistent with the IFC Performance
Standards including cumulative impact assessment.
For the purposes of this report the full expansion project to a production level of 27.5 Mpta is
referred to as the ‘Expansion Project’. The initial phase of the Expansion Project, up to
18.5Mpta, is referred to as the ‘Financed Project’ or ‘Project’.
This report provides our findings following an Environmental and Social Due Diligence Review of
the Financed Project for which was assessed against applicable Project Standards, primarily the
IFC Performance Standards (2012), identifying environmental and social risks associated with the
Financed Project.
The report presents our findings of a review of the Environmental and Social Impact Assessment
(ESIA) and associated documents related to the Project. More specifically, the report is based on
information gained following:

a detailed review of the ESIA;

review of supporting and supplementary information to the ESIA;

face-to-face technical workshops in Paris with CBG HSE personnel and lenders; and

a site visit.
Given the ongoing nature of CBG’s mining operations, in addition to impacts anticipated during
the expansion, the findings presented in this report also include observations that relate to CBG’s
current operations.
Throughout the due diligence process, CBG has cooperated fully and responded to
Ramboll Environ requests in relation to the due diligence effort. During the due diligence
process, following presentation of our initial findings, CBG has addressed many comments and
Environmental and Social Due Diligence – Technical Report
ii
CBG Bauxite Mine Expansion Project, Guinea
observations either through the further development of Environmental and Social Management
Plan (ESMP) prepared for the Expansion Project, or via the issue and disclosure of a
Supplementary Information Package (SIP) to the previously disclosed ESIA. Consequently there
are many instances where initial concerns expressed about the adequacy of the ESIA have been
addressed during the due diligence process, either by the development of new documentation or
firm commitments to future actions in order to address concerns.
In order to reflect this process over time, this report typically describes the adequacy of the ESIA
and then the measures already undertaken/to be undertaken to address any deficiencies in the
ESIA. The level of environmental and/or social risk following implementation of the measures is
also provided within summary tables at the end of each technical chapter.
Key findings, in order of IFC Performance Standard, are presented below.
PS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND
IMPACTS
Management Systems - The Company has been mining bauxite ore since 1973 and operates a
Hygiene (Health), Safety, Environment and Communities Management System (HSEC MS) with
associated plans, procedures and resources. The management of Expansion Project activities will
be integrated within the existing HSEC MS. The ESIA includes an Environmental and Social
Management Plan (ESMP) that has been produced specifically for the Expansion Project and will
also be integrated into to the HSEC-MS.
The HSEC MS is guided by the Mining Code of Guinea and international good practice, notably IFC
Performance Standards and associated guidelines. The structure and content of the HSEC MS is
detailed in CBG’s HSEC Management Plan using a ‘Plan Do Check Act’ approach to continuous
improvement. The Plan includes system elements typically expected of an integrated HSE-MS.
The HSEC MS has been developed in accordance with the requirements of OHSAS 18001:2007
Occupational Health and Safety Management Systems and ISO 14001:2004 Environmental
Management Systems, although CBG has not sought or received formal certification.
ESIA – the ESIA was produced in December 2014 by the French Canadian consultancy firm, EEM
Sustainable Management, based in Quebec. It was written to meet international standards and
for the most part correctly identifies the issues relevant to the Project. There are, however,
some concerns regarding the adequacy of assessment. For example, the assessment of
cumulative impacts is brief and offers little in terms of assessment and mitigation measures.
There are also some aspects of the Expansion Project that were reportedly undefined pending
detailed design and were consequently excluded from the ESIA, including dredging works and the
routing of future mine access roads.
Chapter 10 of the ESIA, entitled Environmental and Social Management Plan (ESMP), includes a
tabular consolidation of the mitigation measures identified throughout the ESIA. The mitigation
measures are written in a clear manner, although in some cases lack specificity i.e. refer to the
need to develop further plans.
Following the receipt of Ramboll Environ’s initial review of the ESIA many of the concerns raised
have since been addressed by additional assessment effort and/or commitments to future work
as presented in the SIP. Further commentary on the ESIA and the subsequent SIP is provided by
topic in the Performance Standard sub-headings below.
Stakeholder Engagement – the ESIA describes how stakeholder engagement has been an ongoing process up to December 2014 (the date the draft ESIA was finalised). Consultations
occurred in three phases: scoping (with preparation of Scoping Report); baseline study
preparation; and during the assessment of impacts. Following ESIA finalisation, the agency
Environmental and Social Due Diligence – Technical Report
iii
CBG Bauxite Mine Expansion Project, Guinea
responsible for approving the ESIA, the Bureau Guinéen d’Études et d’Évaluation
Environnementale (BGÉÉE) conducts a series of feedback meetings on the ESIA and ESMP with
selected communities in/near the mine area, the factory/port area and along the railway.
The disclosed ESIA also makes reference to a Stakeholder Engagement Plan (SEP), which was
reviewed prior to the Paris workshop, together with a ‘Procedure for a Stakeholder Engagement
Management Plan’ (considered to be functionally equivalent to a SEP) and ‘Procedure for
Stakeholder Identification, Analysis and Mapping’, both of which focus on the post-ESIA phase.
Following receipt of Ramboll Environ comments on these two SEPs, CBG amended both and the
revised versions are included in the Supplementary Information Pack. In addition, CBG has
produced two supporting documents for the implementation of the ‘Procedure for a Stakeholder
Management Plan’ and ‘Procedure for Stakeholder Identification, Analysis and Mapping’. These
supporting documents are essentially tools to assist stakeholder identification, mapping and
recording of the status of interactions between CBG and the stakeholders.
Grievance Mechanism - the ESIA presents evidence indicating that local stakeholders consider
that the current mechanism(s) for dealing with grievances is (are) not working effectively. The
ESIA refers to a Complaints Registry and states that the Grievance Mechanism will be announced
and explained to the communities. During the Ramboll Environ review of the ESIA and
accompanying documentation, CBG provided a draft of a Grievance Mechanism, based on the
Grievance Mechanism presented in the ‘ESIA’ SEP. Following Ramboll Environ comments
presented during the Paris workshop, CBG prepared a revised and improved Grievance
Mechanism that is in line with good practice and focuses only on community stakeholders and
excludes employees and those individuals/households affected by land take. These two separate
groups will have their own specific Grievance Mechanisms.
PS 2: LABOR AND WORKING CONDITIONS
Labour and working conditions are addressed in a number of sections of the ESIA, including a
chapter dedicated to human rights. Following the Paris workshop, CBG provided a suite of
policies and procedures which also cover many of the topics that are required by PS 2. Certain
rectifiable and relatively minor gaps were identified which CBG should close out in the near future
including: design, dissemination and implementation of an employee Grievance Mechanism;
inclusion of migrant workers and their working terms and conditions in the policies/procedures;
and a commitment to prepare a Retrenchment Plan should collective dismissal of employees
prove to be unavoidable. With reference to construction workers’ camps, there is no mention of a
commitment to adhere to the guidance/advice presented in IFC/EBRD Guidance for Workers’
Accommodation: Processes and Standards. Such a commitment is necessary.
PS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION
The ESIA assesses a range of Project-related pollution and energy efficiency issues. Key
observations by topic are identified below.
Air Quality – the ESIA concludes that the affected airshed at both Kamsar and Sangarédi is
already degraded, with baseline ambient air quality already exceeding international levels in
some instances. The due diligence process has identified that currently there are insufficient
baseline data to adequately characterise baseline conditions or to validate the air dispersion
modelling used to predict future concentrations. CBG is committed to carrying out additional
baseline monitoring and to update the air dispersion modelling when complete. Whilst it is
considered by Ramboll Environ the future predictions of pollutant emissions and resulting
ambient concentrations represent a worst case, the provision of additional baseline data would
provide greater assurance that the predicted future concentrations are correct.
Environmental and Social Due Diligence – Technical Report
iv
CBG Bauxite Mine Expansion Project, Guinea
The assessment concludes that gaseous emissions will increase with the Expansion Project (and
the Financed Project) at both Kamsar and Sangarédi due to the increased combustion processes
and from blasting operations at Sangarédi. Particulate concentrations are also predicted to
increase at Sangarédi due to the increased activity, but would decrease to a certain extent at
Kamsar due to improved dust control measures associated with the process facility upgrades
associated with the Financed Project. The assessment predicts that there would be exceedences
of the WHO limits for both gaseous and particulate pollutants. Overall, the ESIA concludes that
the expansion plans would result in a high adverse impact on air quality (based on 27.5Mtpa).
A number of additional mitigation measures have been included within both the ESIA and the
ESMP, but greater consistency is needed between the two documents to ensure that all relevant
measures are included within the ESMP, in particular the suggested set back distances to protect
villages during mining and blasting operations. The ESIA has not determined the potential
impact of these additional mitigation measures on overall air quality, therefore it is unclear
whether these will be sufficient to bring ambient air quality back in line with the applicable air
quality standards.
Noise and Vibration – the ESIA concludes that the Project will increase the current noise levels,
with IFC day and night time noise limits exceeded in some locations. Mitigation measures are
specified for affected receptors where the increase from baseline levels is greater than 5 dB(A)
(rather than 3dB(A)). Noise monitoring is highlighted in the ESIA in order to verify the efficacy of
the proposed mitigation measures. The need for additional underwater noise assessment is
acknowledged by CBG and will be undertaken in the near future.
Water and Sediments - review of the ESIA identified a number of areas of uncertainty relating
to water management and absence of baseline data. As a consequence, CBG has established a
Water Management Framework which commits CBG to adhering to PS 3 and effectively managing
water resources during each phase of Project development, including the issue (by January 2016)
and implementation of a Water Management Plan (WMP) in accordance with the Rio Tinto HSE
Standard E101 (Standard E10). The WMP will add to the scopes of the current Surface Water and
Sediment Monitoring Program and Well Network and Monitoring Program presented in the SIP,
and will become part of the evolving ESMP.
As part of the WMP, CBG has committed to preparing water balances for the Kamsar area and
Sangarédi mining area, including development of a groundwater model to enhance understanding
of the hydrogeological / hydraulic regime and to proactively assess potential impacts on local
communities and sensitive habitats and species. CBG will also establish a broader and technically
focused monitoring network for surface water, sediments and groundwater, which will be adapted
based upon the information obtained and as the mining activities progress. The WMP will also
include a Water Management Strategy and a monitoring register (including KPIs and action
thresholds which, if breached, will trigger corrective actions), clear definition of responsibilities
and training needs for staff, as well as establishment of a specific CBG team for water
management.
The Project is reliant on the implementation of the WMP to meet PS3 requirements. This includes
filling gaps in baseline data, completing impact assessments through modelling and monitoring,
and review of mitigation measures, if/where necessary. A thorough and well implemented WMP
should enable the key water-related risks associated with the Project to be addressed. Given the
evolving nature of the Project, with mining progressing gradually across the various plateaux, it
is recommended that the scope of the WMP, which CBG has committed to review on an annual
basis, be reviewed and agreed with Lenders prior to its initial finalisation, and during subsequent
annual reviews.
Environmental and Social Due Diligence – Technical Report
v
CBG Bauxite Mine Expansion Project, Guinea
Reinstatement of disturbed areas
CBG has a rehabilitation programme that involves smoothing the slopes left by mining followed
by reforestation of those areas exploited. CBG aims to rehabilitate one hectare for each new
hectare mined, however, there is reportedly a considerable backlog from the mining that took
place in previous years, resulting in prolonged exposure of unvegetated areas with potential
impacts to water quality, biodiversity and visual amenity. Measures to accelerate reinstatement
have been provided by CBG.
Waste Management – based on an initial review of the ESIA it was found that although
management of waste is discussed, there was no dedicated waste management section. The
ESIA discusses hazardous and non-hazardous waste management, although the level of detail
afforded to this topic is insufficient to give the reader a full appreciation of waste management
issues and management practices.
For example, the volumes of waste likely to be generated
during the Project and the technical suitability of disposal options are unclear.
Following Ramboll Environ’s initial feedback on the management of waste, CBG has made
available further documentation concerning its current waste management practices. The new
documentation highlights a number of good practices that CBG is either currently undertaking or
has committed to undertake in the future. Nevertheless there are concerns regarding the
suitability of certain non-engineered and temporary waste disposal sites and the level of
environmental monitoring around waste facilities undertaken in the past that need to be
addressed.
PS 4: COMMUNITY HEALTH, SAFETY, AND SECURITY
The ESIA draws attention to a number of health and safety concerns raised by affected
communities, including:

a belief amongst community members that CBG is responsible for health effects such as
respiratory diseases that they link to the air emissions arising from CBG’s operations;

water contamination (used oil, fuel) and impacts to consumed fish; and

railway crossing is a concern, notably the lack of safe crossing areas.
Although it is unclear whether these concerns are justified, there is nevertheless a concern
amongst communities that the Project poses a health and safety risk and the ESIA does include
mitigation measures to reduce the risks posed to communities. There is, however, no systematic
approach which focuses on the activities that will be part of the proposed mine expansion
(construction and operational phases) and the alterations in health and safety risk profiles posed
by these activities. Of note, the ESIA remains silent on a number of individual topics/issues with
specific water-born, vector-borne and communicable diseases not addressed.
Issues relating to provision of security services, and their relation to communities, are not
adequately addressed in the ESIA. Recommendations to address these short coming are
presented in this report.
PS 5: LAND ACQUISITION AND INVOLUNTARY RESETTLEMENT
The ESIA recognises that some villages, or parts of villages, may have to be physically relocated.
In addition, it is recognised that many villages will experience a loss of land with likely livelihood
implications. The ESIA makes a clear reference to the need for a Resettlement Action Plan (RAP)
as required by PS 5.
Currently, the long term mine development plan has not been finalised and there is
understandably some uncertainty over the villages and land to be affected, and thus the extent
of physical and economic displacement. A Resettlement Action Plan (currently a working draft) is
however being prepared for the villages of Fassaly Foutabhe and Hamdallaye (covering both
Environmental and Social Due Diligence – Technical Report
vi
CBG Bauxite Mine Expansion Project, Guinea
types of displacement). Arising from the experience of preparing this RAP, CBG has prepared a
Resettlement and Livelihoods Restoration Policy Framework (RLRPF) which establishes the
principles and procedures to be used to prepare future RAPs and Livelihood Restoration Plans
(LRPs). CBG has also undertaken to close out all existing grievances relating to compensation
payments made in the period 2010-2015 and has initiated a process, based on periodic social
surveys, to track and evaluate the extent to which livelihoods of people/households affected by
land take have improved, declined or stayed the same in the future.
PS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING
NATURAL RESOURCES
The Project area contains large areas of natural and critical habitats. Critical habitats have been
determined based on the presence of a large number of threatened and endemic species, globally
significant populations of migratory species, as well as threatened ecosystems. Two Ramsar sites
and two Key Biodiversity Areas are located in the vicinity of the Project area. The Project area
also provides significant ecosystem services to local affected communities including food
(agricultural, fisheries and bush meat), raw material (timber and firewood) and fresh water.
Therefore, the requirements of PS6 are highly relevant to the Project.
The ESIA was informed by a wide range of ecology surveys including freshwater and marine fish,
amphibians, reptiles, birds and mammals. An assessment was also made for important
ecosystem services of bushmeat and fuelwood. The ESIA identified a wide range of impact types
to biodiversity, including habitat loss, fragmentation, reduction in air quality, noise and vibration,
water pollution, light pollution, human disturbance, collisions, induced access (including increased
exploitation of timber and bushmeat) and invasive species. A detailed review of the ESIA and
associated documents identified a number of significant gaps within the baseline information and
impact assessment (especially in relation to quantification of indirect impacts). In particular,
impacts arising from cumulative impacts, impacts from haul roads (including fragmentation),
induced access, blasting noise disturbance and impacts to hydrological regimes that support
critical habitats were not characterised. In addition, the ESIA’s assessment of critical and natural
habitat did not comply with IFC PS6.
In response to initial feedback on the ESIA, CBG has instigated a number of important actions to
address the identified gaps. Firstly, CBG commissioned The Biodiversity Consultancy to produce a
new Critical Habitat Assessment that meets IFC PS6 and identifies the priority biodiversity
features of the Project Area. CBG has also commissioned additional studies, including surveys for
amphibians, reptiles, vultures, benthic fauna and three sets of studies for chimpanzee. However,
there remains some inconsistency between recommendations for additional surveys in the ESIA,
the CHA and those currently commissioned. Therefore, it is recommended that a systematic
review of survey requirements is provided as part of the Project’s future Biodiversity Action Plan
(BAP). CBG has produced a Biodiversity Action Framework (BAF) which sets out the structure
and content of the BAP. The BAP will be the primary mechanism to implement mitigation in
relation to biodiversity. The BAF explains that the BAP will fill gaps in baseline information, refine
impact assessments and review the existing mitigation measures and detail a long-term
monitoring programme. If a robust BAP is developed and implemented thoroughly, it has the
potential to address the key risks to the Project in relation to biodiversity. The BAP will include a
feasibility study for biodiversity offsets, on which the Project is reliant on to meet PS6
requirements for no net loss of natural habitats and a net gain in critical habitats. There are
however inherent significant delivery risks associated with biodiversity offsets. For example they
will likely require third party involvement or affect land outside the control of CBG. Until the
feasibility study is completed there remains an unquantified risk that PS6 requirements in relation
to natural and critical habitat may be difficult to achieve.
Environmental and Social Due Diligence – Technical Report
vii
CBG Bauxite Mine Expansion Project, Guinea
PS 7: INDIGENOUS PEOPLES
The ESIA does not consider Indigenous People. CBG reports that there are no indigenous
peoples, within the meaning of PS 7, living and /or occupying territory temporarily in the areas of
the Project operations. Ramboll Environ has found no evidence to contradict CBG’s view.
PS 8: CULTURAL HERITAGE
While CBG’s current management of cultural heritage does not align fully with the letter of the
Performance Standard, it is evident from the documentation and associated discussions between
CBG and Ramboll Environ that the understanding and commitment exists within CBG to remedy
deficiencies in due course and in accordance with the recommendations of this report. In
particular, there is a key undertaking on the part of CBG to develop and publish a Cultural
Heritage Management Plan, including Chance Finds Procedure, prior to further exploration and
development activity. Development of the skills and capacity to both prepare the CHMP and to
ensure its implementation across the on-going operations will have to be carefully monitored.
The ESIA report captures in large part the landscape of cultural heritage practices and resources
in the concession areas. The ESIA recommends that the baseline studies conducted to date
should be considered as a first step in the evaluation of local cultural practices linked with the
sites, a recommendation with which Ramboll Environ concurs. The important next step is to
ensure that these are fully developed and implemented as part of the Cultural Heritage
Management Plan for the Project.
The ESIA study also highlights the high archaeological potential of the mine concession area, as
well as noting that prior to work on the railway and port, site-specific surveys should be carried
out. As a result, the overall assessment of impact presented in the ESIA is potentially high. Even
after mitigation, residual impacts on archaeological heritage in the mine concession area remains
high. It becomes more important therefore to ensure the timely development and consistent
application of a robust Chance Finds Procedure applicable to all stages of site planning and
operation. The mitigation measures proposed appear realistic from a technical and financial
perspective, and have been accepted in full by the CBG as part of its commitment to developing
and implementing a Cultural Heritage Management Plan as set out in the ESMP.
Following consultations between Ramboll Environ and CBG, it is accepted that considerations of
access to cultural sites have been and are being taken into account by CBG during mine planning
and operations, most notably through the existing and planned stakeholder engagement and
resettlement planning procedures and practices. It is also accepted that the CHMP will include a
mechanism to keep procedures up to date as operations progress (management of change).
Summary
In summary there are a number of areas of environmental and social management that currently
fall short of IFC Performance Standards and good international practice. However, measures have
been identified either within the ESMP or this report that will address the shortfalls. Provided
these measures are fully implemented in a timely manner, Ramboll Environ does not recognise
any fatal flaws with respect to environmental and social issues.
In the majority of cases, CBG is aware of these measures and fully committed to their
implementation as part of its ongoing management of HSEC matters. Many of the actions
identified have already commenced.
Environmental and Social Due Diligence – Technical Report
1
CBG Bauxite Mine Expansion Project, Guinea
1.
INTRODUCTION
Ramboll Environ UK Limited (hereafter Ramboll Environ) was commissioned in May 2015 to fulfil
the role of Lenders’ Independent Environmental and Social Consultant on behalf of Compagnie
Bauxites de Guinée (‘CBG’ or the ‘Company’), the International Finance Corporation (IFC) and
other potential lenders. Together, the potential lenders are considering financial support for a
CBG mine expansion project in Guinea.
CBG is a mining company jointly owned by the Government of Guinea and Halco Mining (a Joint
Venture between Alcoa, Rio-Tinto Alcan and Dadco). The Company has been operating since
1973 and has its primary facilities located in Kamsar and Sangarédi in the northwest of Guinea.
CBG currently mines, transports by rail, processes and ships approximately 13.5 million tonnes
per annum (“Mtpa”) of bauxite ore at 3% free moisture.
The Expansion Project will increase the capacity of the current mine in a phased manner,
increasing by 9Mtpa (to 22.5Mtpa) by 2017 (Phase 1) and then by a further 5Mtpa (to 27.5Mtpa)
by 2022 (Phase 2). In addition to the mine expansion, the Project will also include improvements
to town infrastructure, rail operations and port facilities.
It should be noted that the scope of the Expansion Project as originally envisaged by CBG has
changed. Originally CBG envisaged Phase 1 as an increase to 18.5 Mtpa and later 22.5
Mtpa followed by a Phase 2 which envisaged a further expansion to 27.5 Mtpa. The scope
covered by the proposed financing is for a tonnage of 18.5 Mtpa. Some of the documentation
provided for review (such as the Environmental & Social Impact Assessment referenced below)
considers the eventual 27.5 Mtpa production level. The ESIA includes numerous mitigation
measures that have been developed based on the full expansion project tonnage; the full
Expansion Project is inclusive of the 18.5Mtpa phase. Consequently the mitigation measures
expressed in the ESIA are equally applicable to the 18.5Mtpa.
Should any additional increases in production be proposed for the CBG concession beyond the
18.5 Mtpa financed CBG is committed to follow an appropriate environmental and social
assessment process (e.g. preparation of an ESIA addendum) consistent with the IFC Performance
Standards including cumulative impact assessment.
For the purposes of this report the full expansion project to a production level of 27.5 Mpta is
referred to as the ‘Expansion Project’. The initial phase of the Expansion Project, up to
18.5Mpta, is referred to as the ‘Financed Project’ or ‘Project’.
This report presents the findings of a review of the ESIA and associated documentation relating
to the Expansion Project. More specifically, the report is based on information gained following:

a detailed review of the ESIA (English language translated version);

review of supporting and supplementary information to the ESIA;

face-to-face technical workshops in Paris, France with CBG HSE personnel and lenders; and

a site visit.
This report provides clarity on those areas where the Project is not meeting the IFC Performance
Standard (PS) (and other applicable standards, as defined in Section 2.2) and presents these in
terms of the significance of risk to the Project’s health and safety (H&S), environmental or social
performance (see Section 4.2).
In some instances, the report also highlights the progress made by the Company during the due
diligence process. For example, the Company has responded rapidly to a number of areas of
concern that were initially highlighted during the Ramboll Environ review and which were
subsequently discussed during the Paris workshops and other meetings held prior to finalisation
Environmental and Social Due Diligence – Technical Report
2
CBG Bauxite Mine Expansion Project, Guinea
of this report. Actions taken to address concerns identified in the due diligence process include
additional baseline monitoring and assessment of impacts. In addressing these concerns, the
Company has produced/or revised a number of monitoring and management plans and produced
a Supplementary Information Pack (SIP) to the disclosed ESIA.
Where relevant, findings from the initial stages of the Ramboll Environ review or actions agreed
during the workshops may be referenced, in part to provide context, but also to demonstrate the
good progress made by the Company.
This Report identifies areas where the Health, Safety, Environmental and Social (HSE and S)
performance does not meet with the Project applicable standards and/or where the Project poses
significant HSE and S risks. The significance of each issue identified is provided, taking into
account the magnitude of the potential risk/adverse effect.
Environmental and Social Due Diligence – Technical Report
3
CBG Bauxite Mine Expansion Project, Guinea
2.
SCOPE AND STRUCTURE OF THE REPORT
2.1
Scope
This Technical Environmental and Social Due Diligence Report details the Project’s ability to
satisfy the applicable Project Standards (listed in Section 2.2) and, in doing so, presents the
environmental and social risks associate with the Project. It has been prepared on behalf of CBG
(the Sponsor), IFC and other current potential lenders and may be made available to other
potential lenders (collectively the ‘Lenders’) to the Project. It addresses the various components
of the Project (as defined in Section 3, Project Description herein) as summarised below:

Mine operations centred around the town of Sangarédi – increase in mobile equipment,
manpower, maintenance facilities and additional rail track and train loading facilities;

Rail operations – increased rolling stock, maintenance facilities, new sidings, shunting yards;

Kamsar processing plant and port– new train unloading stations, new crushers, conveyor
belts, stockpiling areas, new dryers, upgrade of existing conveying transportation and ship
loader and increased port fleet;

Project infrastructure – additional power generation, steam and compressed air generation,
increased potable water production and supply, new fuel, oil and diesel facilities; and

Kamsar and Sangarédi township infrastructure (housing, roads, utilities).
The report takes account of additional work that has either been undertaken, is in progress, or
which the Company has made clear commitments to undertake in the future since the issue of
the ESIA. In particular, the report makes reference to actions agreed in the Paris workshops held
in August 2015 in which preliminary findings of Ramboll Environ’s review were discussed. During
these workshop meetings, a number of actions were identified that will be necessary to complete
for the Project to meet the 2012 IFC Performance Standards. Actions identified during the
meetings were categorised as Priority 1, 2 or 3 actions, with priority being assigned on the basis
of the timeframes with which they should be undertaken. Priority 1 actions are required for
Lenders’ disclosure and therefore represent the most urgent actions. Priority 2 and 3 actions are
no less important, but should be developed as part of an on-going update of the Company’s
ESMS, and are therefore not required for disclosure and so are less time critical.
2.2
Project Standards
In accordance with Ramboll Environ’s Terms of Reference, the Project was assessed against the
following standards and guidelines:

IFC Performance Standards (2012) and EHS Guidelines, including

PS1 Assessment & Management of Environmental & Social Risks & Impacts

PS2 Labour and Working Conditions

PS3 Resource Efficiency and Pollution Prevention

PS4 Community Health, Safety, and Security

PS5 Land Acquisition and Involuntary Resettlement

PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources.

PS7 Indigenous Peoples

PS8 Cultural Heritage

International Labour Organization (ILO) conventions; and

Applicable laws and regulations of Guinea.
Environmental and Social Due Diligence – Technical Report
4
CBG Bauxite Mine Expansion Project, Guinea
2.3
Structure of the Report
Section 3 below provides a summarised description of the proposed Project facilities (within the
context of the broader Expansion Project), activities and timelines. Section 4 outlines the
Guinean legislative framework and other applicable Project Standards. Thereafter, this report is
structured around the eight 2012 Performance Standards listed above. The key issues identified
during the ESDD process are summarised in ‘significance tables’ for each Performance Standard.
2.4
Limitations
Detailed design of the Project is currently ongoing. Whereas this is positive in that it allows for
design changes that can accommodate the findings of the ESIA, it should also be recognised that
there may be additional design changes with environmental and social implications that are not
addressed in the current ESIA or SIP.
Environmental and Social Due Diligence – Technical Report
5
CBG Bauxite Mine Expansion Project, Guinea
3.
PROJECT DESCRIPTION
This Section is intended to provide a high-level summary of the Project, based on the description
in the ESIA and associated documentation, with emphasis on those elements of the Project that
could give rise to environmental and/or social impacts. A short outline of the current operations
is also provided for context.
3.1
Current Mine Activities
CBG has carried out mining operations in its Sangarédi concession area in North West Guinea
since 1973. Currently, it is extracting 13.5 Mtpa of bauxite ore which is transported by rail to the
port of Kamsar where it is loaded on to ships for export. In addition to the mine, CBG operates
the rail network as well as basic processing facilities and the port at Kamsar (Figure 1).
Figure 1: Project Location
The current operations include:

Mining

Removal of vegetation and overburden

Drilling and blasting of bauxite ore

Transportation by road to a rail loading area where it is temporarily held in linear
stockpiles


Rail transportation


Reinstatement of disturbed land
Loading on to rail wagons and transportation of ore 135 km by rail to Kamsar
Processing and shipping
Environmental and Social Due Diligence – Technical Report
6
CBG Bauxite Mine Expansion Project, Guinea
3.2

Unloading at Kamsar shunting yard1

Crushing

Drying

Storage

Transfer of crushed ore to quayside by conveyor

Ship loading (Panama sized vessels).
Project Description – the Financed Project
The CBG Expansion Project includes an increase in the extraction rates, bauxite ore
transportation and processing. A phased expansion is planned as follows:

Phase 1: increasing production from the current 13.5 Mtpa to 22.5 Mtpa by the end of 2017
(with an intermediary 18Mtpa phase which represents the phase to be financed); and

Phase 2: a further expansion to 27.5 Mtpa planned for 2022.
The Project will necessitate the construction and modification of the Company’s infrastructure,
equipment and operations. These activities will take place at three distinct Project sites: the
mine concession area; the port at Kamsar; and the rail network connecting the mine to the port.
Further description of each is provided below.
The map below shows the location of current mining activities and the proposed expansion areas.
3.2.1 Mine
The Project will necessitate:

The acquisition of addition plant and equipment (loaders, trucks, bulldozers and water tanks)
and additional manpower to operate the equipment. New workshop facilities will be required
to service the additional mobile machinery.

The construction of the new rail yard, extension of the sidings and storage area in Parawi (for
Phase 1) and associated facilities (road, bridges, railway) already planned by CBG in order to
operate to the north of the N23 national road will be brought forward. An overpass, linking to
the new bauxite storage area will be constructed to cross the national road.

An increase in the rate of clearance of vegetation and overburden2 in existing areas within the
CBG concession area. The total area for which mining has already been approved (the
Expansion Project will not add to this area) is 3,200 ha, over which habitat (including farmed
areas) will be lost/degraded.

Extraction of bauxite ore typically using drilling and blasting techniques.

The loading of ore on to trucks and transportation to the main storage heap located near the
railway.

Improvements to the town infrastructure at Sangarédi (and Kamsar) for additional new
workforce.

Construction of temporary construction camps within the industrialised and mining zones of
Kamsar and Sangarédi, respectively.
1 The current unloading station has been in use for 40 years. It requires considerable maintenance and the rail wagon unloading
process will be replaced by a safer system as part of the Project.
2 Usually, the quantity of overburden to remove to reach the mineralized zone is very low, as the bauxite ore is generally close to the
ground surface. This overburden is stored and used as cover for the restored land during the rehabilitation phase.
Environmental and Social Due Diligence – Technical Report
7
CBG Bauxite Mine Expansion Project, Guinea
Figure 2: Current and Future Mine Area
3.2.2 Rail
Bauxite ore is transported from the mining site to the Kamsar plant via a railway granted to CBG
by the Guinean government.
Five trains per day, each comprising two locomotives and 120 loaded bauxite ore wagons leave
the Sangarédi mine for Kamsar. Each wagon contains around 82 tonnes3 of bauxite ore.
To manage the additional bauxite ore associated with the expansion, for the full Expansion
Project trains will ultimately comprise three locomotives moving 130 wagons (rather than the 120
wagons/train). Additional locomotives will enable CBG to increase the daily transportation to
nine trains per day (compared to the current five to seven a day) reaching Kamsar (7 days a
week).
3 Long term mine plan refers to 85 tonnes per wagon
Environmental and Social Due Diligence – Technical Report
8
CBG Bauxite Mine Expansion Project, Guinea
To achieve 27.7Mtpa, new sidings will be built between the mining site and Kamsar at KP 14 and
KP118 to enable trains to pass each other. At KP 118, a 2.5 km siding will be built on the north
side of the current railway. At the KP14, the main railway line will be converted into a siding
between the KP 13.4 and 15.5, and the new section of rail added. These additional sidings will
not be required for the 18.5 Mtpa extraction rate.
The existing Tanéné (KP 72.7) and Boké (KP 54.7) sidings will be extended. The Boké siding will
not require major works, but the Tanéné sidings will be extended by 600m.
3.2.3 Kamsar Processing Facilities and Port
The following modifications will be necessary at the Kamsar facilities to accommodate the
increased production levels.
Shunting Yard – Train Unloading Station
The Expansion Project requires a new rail wagon unloader, capable of unloading 27.5Mtpa, to
replace the existing unloading facilities (wagon dumper) and therefore some modifications to the
railway line in the Kamsar shunting yard within CBG’s current allocated industrial zone. A new
crushing facility will be located at the unloading area.
The unloading area will be fully enclosed to reduce the associated noise and dust emissions. A
dust control system, inclusive of ventilation systems, curtains and fogging nozzles is planned in
the unloading area to reduce fugitive dust emissions.
The building of the entire unloading area and of an unloading line is planned for the intermediate
phase of 18.5 Mtpa. A second unloading line is planned during the first extension phase to 22.5
Mtpa.
Crushers
The current hammer mills will be replaced by a two-step crushing system with a 27.5 Mtpa
capacity. The first crusher will reduce the ore size to 300 millimetres and the second crusher will
reduce it to 100 millimetres. A new conveyor will transport the ore from the first crusher to a
separate building housing the second crusher. From the second crusher, a new conveyor, will
then transport the ore to the transfer station.
The ore will then be transported by a further conveyor to the new transfer tower.
No changes will be made to the current stacking and ore reclaiming systems.
Drying Process
The bauxite ore is dried to achieve a moisture content of 6.7% prior to shipping. Two new drying
ovens will be necessary for the processing of the additional ore. The new ovens will be installed
with scrubbers and a new storage shed for the dried bauxite. This new storage shed will be built
immediately behind the current storage shed.
Waste from the scrubbers (mainly comprising bauxite slurry) is currently discharged into a
sedimentation pond. The waste is then removed, dried and recycled into the process as raw
material.
Based on the actual production, the future total waste generated by scrubbers when extract rates
are 27.5 Mtpa is estimated to be 68,000 tonnes per year. A technical study by CBG has
demonstrated that the current waste drying capacity will be sufficient to dry the future annual
production of slurry.
The dry ore storage capacity will be increased to 150,000 tonnes.
Environmental and Social Due Diligence – Technical Report
9
CBG Bauxite Mine Expansion Project, Guinea
Conveyors
New conveyors will be installed for the Expansion Project and other existing conveyors will be
modified to improve the rate of ore transportation between existing and new facilities. The new
conveyors will have an enclosed design.
Power Generation
The energy needs associated with the additional equipment will increase the energy demand to
28.35 MW. To meet this increased demand, four additional electrical generators will be required
in Kamsar. Two are planned for the 18.5Mtpa phase and will be integrated into the current
power station.
An additional power generator will also be required in Sangarédi and will be installed into the new
power station at Sangarédi. Similar to the existing power generators, they will use diesel fuel
and heavy fuel oil (HFO). CBG currently possess three 10,000 m3 HFO tanks that will be
supplemented with an additional 10,000 m3 HFO tank for the 27.5 Mtpa phase. This HFO will be
used to generate electricity which will serve the dryer and steam boiler.
Other Facilities
Other facilities to support the Expansion Project include:

a new 3,000 m3 diesel storage tank with secondary containment;

two additional compressors for the new rotary dryers; and

an additional boiler installed for the 18.5 Mtpa phase.
Port Upgrades
Quay Extension - the current 275 metre long quay will be extended by a further 301 metres to
enable the mooring and continuous loading of two Kamsarmax4 vessels. This quay will be
extendable and therefore able to accommodate larger Cape size5 vessels if needed in the future.
The extended quay will comprise a concrete deck supported on foundation piles.
Dredging - dredging operations are required to enlarge the turning basin and the berthing basins
.Only one turning basin is required for the 18.5 Mtpa phase and the total amount of dredged
material for the 18.5 Mtpa phase is 300,000m3.
A second basin is planned for the 22.5 Mtpa phase which will also serve the 27.5Mtpa phase. .
The volume of material to be dredged for both turning circles has been calculated to be
419,000m3.
Ship Loader – initially the existing ship loader will be used to operate on both jetties. For the
22.5Mtpa phase a second ship loader will be installed in order to load two Kamsarmax vessels
simultaneously. The simultaneous loading of two vessels will also be sufficient for loading during
27.5Mtpa phase. Improved conveyor efficiency is planned to move the volumes of bauxite
necessary to achieve 27.5Mtpa.
The quay will be designed such that a further extension of the two jetties would be possible to
enable the simultaneous loading of two Cape Size vessels, although there are no plans for such
an extension (nor for the associated channel dredging to allow passage of Cape Size vessels) as
part of the Financed Project nor the full Expansion Project.
There will be an increased number of support vessels, for example, a pilot boat and tug.
4 Kamsarmax refers to vessels with a DWT of 70,000 and a ballast draft of 7 metres
5 Cape size vessels have a DWT of 150,000 and a ballast draft of 9 metres
Environmental and Social Due Diligence – Technical Report
10
CBG Bauxite Mine Expansion Project, Guinea
Shipping activities, other than those activities within the confines of the port and port waters, are
excluded from the Expansion Project and hence this report.
Workers’ Accommodation
Temporary workers construction camps and permanent accommodation are planned at the mine
and the port locations. A temporary workers construction camp will be located into the
N’dangara mine (approximately 8km west of Sangarédi) to accommodate 60 workers during the
18.5Mtpa phase. CBG also plans to build 113 permanent accommodation units in Sangarédi town
for the 22.5Mtpa phase. Another temporary workers construction camp for 600 workers will be
built in the Kamsar industrial area of the Project. The CBG will also build accommodation for 275
workers in Kamsar (22.5Mtpa phase).
Associated Facilities
The ESIA does not identify any associated facilities based on the IFC definition of associated
facilities, which are ‘facilities that are not funded as part of the project and that would not have
been constructed or expanded if the project did not exist and without which the project would not
be viable.’ The facilities described above are understood to be Project facilities; Ramboll Environ
has not identified associated facilities that have been omitted from the ESIA.
Environmental and Social Due Diligence – Technical Report
11
CBG Bauxite Mine Expansion Project, Guinea
4.
SIGNIFICANCE ASSESSMENT
4.1
Review Findings
A summary of the review findings is presented in a summary significance table at the end of each
section. For each item, we present:
4.2

the topic/aspect;

a description of the issue or deficiency;

identification of the standard(s) against which the deficiency has been identified;

Ramboll Environ’s recommendation to resolve/manage the deficiency; and

the significance on a 3-point scale (see below for criteria).
Categorisation of Risk
A ranking system has been used to indicate the relative significance of the deficiencies/omissions
identified by the due diligence review. As well as highlighting the most important areas requiring
attention, it can also be used to aid the tracking and rectification of specific items requiring
improvement.
Identified omissions/deficiencies have been placed into one of the following three categories:
Low:
Minor inconsistencies, errors, omissions and data gaps that diminish the accuracy
of the assessment but do not significantly influence the compliance of the
documentation/project performance with relevant standards, or can be readily
addressed.
Deficiencies pose minor risk of environmental/social harm.
Moderate:
No, or insufficient, information available at the time of reporting leading to a
potentially significant non-compliance with relevant standards or known minor
compliance that would pose a significant HSE or S risk. However, the
deficiency(ies) are recognised by the Company and measures have been outlined
to address the deficiencies in the future.
Moderate issues will require on-going monitoring to confirm proposed measures are
fully defined and implemented in a timely manner.
High:
Same as above except where:
the Company has not identified/committed to measures that would be necessary to
address the deficiency;
opportunities to address the deficiencies have been missed and therefore cannot be
remedied; or
there is a heavy reliance on third parties in order for measures to be successfully
implemented.
‘High’ issues present a significant risk of environmental and/or social harm.
The ranking provided in the tables indicates the level of risk based on current status of
environmental and social management. However it is recognised that CBG has made significant
progress in identifying additional measures to reduce the risks identified early in the due
diligence process. Consequently, for the purposes of this report, the level of risk following the
implementation of actions recommended by the IESC, is indicated in parenthesis as the ‘residual
risk’ within the summary tables presented at the end of each chapter.
Environmental and Social Due Diligence – Technical Report
12
CBG Bauxite Mine Expansion Project, Guinea
For example, a ‘High’ significance may be expected to fall to 'Moderate’ or ‘Low’ following
implementation of mitigation measures/additional effort. A lessening of the risk ranking is only
made where there are firm commitments to future actions that are provided in sufficient detail
for the IESC to opine and that are considered both adequate and actionable. It also is based on
the understanding that the Company will have the resource and expertise to implement the
measures in full.
In some cases the risks might be negligible; in such cases the residual significance is assigned a
‘Negligible’ significance. An example is provided below.
Table 1: Example of the summary table format
ID
Aspect
Issue
Description
Phase
Standard
IESC
Recommendations
000
Storm
water runoff –
monitoring
Company X
does not
monitor the
quality of
surface water
run-off from
facilities with
potential for
undetected
long term
contamination
of a nearby
watercourse.
Operations
IFC EHS
Guidelines
Company X shall
commit to
undertake weekly
sampling from Q2,
2016 at the site’s
storm water
discharge point.
Significance
High
(falling to
Low if
Company
commits to
recommended
monitoring
programme)
Environmental and Social Due Diligence – Technical Report
13
CBG Bauxite Mine Expansion Project, Guinea
5.
LEGISLATIVE FRAMEWORK AND OTHER PROJECT
STANDARDS
This section provides an overview of the standards adopted by the Project and used in the
assessment and management of environmental and social impacts, with reference to both
national legislation, international legislation and Lenders’ standards.
5.1
National Legislation
According to the ESIA, two particularly pertinent legal codes exist in the Republic of Guinea
concerning the protection of the environment:

the Environmental Code (the Environmental Enhancement and Protection Code); and

the Mining Code, 2011 (amended by 2013 Bill).
In September 2011, the Government of Guinea introduced a new Mining Code (replacing the
preceding Mining Code, 1995). Existing CBG operations are not immediately affected by the new
Code with regard to most social and environmental aspects.
Article 142 of the new Mining Code (similarly to the former Mining Code) requires that all
operations be authorised on the basis of an Environmental and Social Impact Assessment that
complies with the Environmental Code.
Many decrees and orders define the regulatory framework of ESIAs in Guinea; including Order Nº
990/MRNE/SGG/90 which defines the procedures and methodology to be adopted while
conducting an ESIA.
5.1.1 Status of Permits for Expansion Project
The draft ESIA of the Expansion Project was finalised in December 2014. CBG submitted the
ESIA to the relevant Guinean authorities in February 2015 and received a Certificate de
Conformite Environmentale (Environmental Conformity Certificate) in June 2015 with a validity of
1 year. The ESIA was disclosed on the CBG web site in September 2015.
During the site visit in August 2015, undertaken by the Guinean consultancy firm Bureau
d’Etudes Laforêt (BEL) under contract to Ramboll Environ, CBG confirmed that all environmental
legislative and regulatory authorisations and permits are up to date and valid, and conform with
the necessary regulatory requirements. It is our understanding that there is no legal action
against CBG relating to failures in environmental, social, health and safety performance.
5.2
International Standards
The ESIA provides a list of international conventions ratified by Guinea with direct relevance to
the Project.
Air Quality and Climate Change

Framework Convention on Climate Change of the United Nations (1992) and Kyoto Protocol
(1997);

Vienna Convention on the Protection of the Ozone Layer (1985); and

Montreal Protocol on Substances that Deplete the Ozone Layer (1987).
Biodiversity

Convention on the Conservation of Migratory Species of Wild Animals (1979);

Convention on Biological Diversity (1992);

African Convention on the Conservation of Nature and Natural Resources (1968);
Environmental and Social Due Diligence – Technical Report
14
CBG Bauxite Mine Expansion Project, Guinea

Convention concerning the Protection of World Cultural and Natural Heritage (1979); and

Ramsar Convention on Wetlands (1993).
Marine and Maritime

United Nations Convention on the Law of the Sea (1994); and

Agreement for cooperation in the protection and Development of the Marine and Coastal
Environment of the West and Central African Region (1984).
Labour and Working Conditions

Convention on Freedom of Association and Protection of the Right to Organise, 1948 (No.87)
(ratified in 1959);

Convention on the Right to Organise and Collective Bargaining Convention, 1949 (No.98)
(ratified in 1959);

Convention on Discrimination (Employment and Occupation) (No. 111) (ratified in 1960);

Convention on the Worst Forms of Child Labour, 1999 (No. 182) (ratified in 2003); and

Convention on the Minimum Age for Admission to Employment, 1973 (No. 138) (ratified in
2003).
Other

Basel Convention on transboundary movements of hazardous wastes (1995, adhesion without
ratification);

Convention on Action Against Desertification (1992); and

Extractive Industries Transparency Initiative (candidate status restored in 2011).
The list of applicable conventions provided in the ESIA does not include a number of conventions
that would typically be expected to apply to a Project of this nature. It would appear that in
some cases these omissions were simply an oversight in the list and have been considered by the
Project during the development of the ESIA and/or associated management plans. A nonexhaustive list of conventions omitted from the ESIA list that might apply include:

UNESCO Convention for the Safeguarding of Intangible Cultural Heritage, 2003;

MARPOL 73/78 (applicable annexes);

ILO 29 on forced Labor, 1930

ILO 105 on the Abolition of Force Labor, 1957 and

ILO 100 on Equal Remuneration, 1951.
Despite their omission in the ESIA list, the requirements of ILO 105 an ILO 29 are both captured
in the Company’s Code of Ethics and Business Conduct. ILO 100 is addressed via CBG’s
Collective Bargaining Agreement (Article 58).
Others not included in the list are:

Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter
(London Convention), 1972; and

International Convention for the Control and Management of Ships' Ballast Water and
Sediments, 2004
These two conventions have not been ratified by Guinea. Furthermore, the Ballast Water
Convention has not been ratified by the necessary number of countries for it to come into force.
Nevertheless CBG recognises the Ballast Water Convention and MARPOL; further details
regarding CBG’s consideration of these conventions is described later within this report.
Environmental and Social Due Diligence – Technical Report
15
CBG Bauxite Mine Expansion Project, Guinea
5.3
Lenders’ Standards
The ESIA states that it was developed in accordance with the national requirements and Good
International Industry Practice (GIIP), with specific reference to IFC Performance Standards,
2012, IFC EHS Guidelines and Equator Principles III.
These have been supplemented by other international standards as follows:

EHS Guidelines for Mining, 2007; and

2006 IPCC Guidelines for National Greenhouse Gas Inventories.
The ESIA clearly defines the standards used and the rationale behind the use of specific
standards. Further details concerning Applicable Project Standards are provided in subsequent
chapters of this report.
Other guidance considered applicable to the Project include inter alia:

EHS Guidelines for Railways;

EHS Guidelines for Ports; and

Workers’ accommodation: processes and standards - a guidance note by IFC and the EBRD.
These standards and guidelines are not explicitly referenced in the ESIA, however, much of the
aspects and guidance in these documents has been incorporated into the Project design. Where
this is not the case, the deficiencies are highlighted and relevant guidance within these standards
and guidance documents is cited in the following sections of this report.
Environmental and Social Due Diligence – Technical Report
16
CBG Bauxite Mine Expansion Project, Guinea
6.
PERFORMANCE STANDARD 1: ASSESSMENT AND
MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS
AND IMPACTS
6.1
Management Systems
The Company has been mining bauxite ore since 1973 and has an established Hygiene (Health),
Safety, Environment and Communities Management System (HSEC MS) in place with associated
plans, procedures and resources. The management of Expansion Project activities will be
integrated within the existing HSEC MS.
The ESIA includes an Environmental and Social Management Plan (ESMP). Further commentary
about specific aspects of the HSEC MS and the ESMP are provided throughout this report. An
overview of the system is provided below.
Overview
The existing HSEC MS is guided by the Mining Code of Guinea and international good practice,
notably IFC Performance Standards and associated guidelines. The structure and content of the
HSEC MS is detailed in CBG’s HSEC Management Plan (CBG_HSEC_PRO_1010) based on the ‘Plan
Do Check Act’ approach to continuous improvement. The Plan includes the following system
elements:

Quality, Safety and Environment Policy (QSE) Policy (including Community)

Risk Management (including hazard identification process/tools and identification of risk
within change management process)

Legal Requirements and Other Commitments

Goals and Targets and Programs

Resources, Roles, Responsibilities and Authority

Training, Competency & Awareness

Behaviour and Observation

Communication, Consultation and Participation

System Documentation & Records Management

Contractor Selection and Management, including a contractor pre-qualification and approval
process that includes consideration of CBG’s HSEC requirements)

Accident/Incident Reporting and Investigation

Operation controls (a suite of safety, Health and Hygiene, environmental and community
related procedures)

Emergency Preparedness and Response

Monitoring and Measurement

Nonconformity, Corrective and Preventive Action

Internal and External Audits

Management review
The HSEC MS has been developed in accordance with the requirements of OHSAS 18001:2007
Occupational Health and Safety Management Systems and ISO 14001:2004 Environmental
Management Systems, although the MS has not received formal certification.
The Community, Quality, Safety and Environment Policy is supported by its Senior Management.
Under the ‘Community’ component of the policy, CBG has set itself several key objectives,
including the implementation of a negotiated involuntary resettlement programme that will be
Environmental and Social Due Diligence – Technical Report
17
CBG Bauxite Mine Expansion Project, Guinea
beneficial for affected villages, in accordance with IFC Performance Standard 5 on involuntary
resettlement and the principles of sustainable development. Other social impact aspects also sit
beneath the Community banner.
Implementation of the Expansion Project ESMP will be the responsibility of the ‘HSEC Manager –
Expansion Project’. The HSE Manager – Expansion Project is also the primary contact with the
construction contractors and therefore essential to the implementation of the ESMP. The position
was held by an experienced HSEC Manager who resigned shortly before this report was finalised.
The post of HSEC Manager – Expansion Project is a key position that must be filled as a priority.
It is understood that the Director of HSEC is currently undertaking the duties of the HSEC
Manager – Expansion Project. He will also be responsible for the implementation of the ESMP
across CBG’s entire operations in the future, supported by three new recruits responsible for the
management of environment and biodiversity, monitoring and construction related HSE
management.
It is understood that candidates have been identified and the Company is actively recruiting to fill
the new posts. It is further understood that CBG has recently recruited a Manager to head its
Community Relations Department.
6.2
Environmental and Social Impact Assessment
An Environmental and Social Impact Assessment (ESIA) has been prepared for the full Expansion
Project (27.5Mtpa). The ESIA has been prepared to satisfy the requirements of national and
international legislation and Good International Industry Practice (GIIP), including the Lenders’
standards as described in Chapter 4. The ESIA was disclosed in May 2015 and has been
approved by the Guinean Government.
The ESIA was produced by the French Canadian consultancy firm, EEM Sustainable Management,
which has its headquarters based in Quebec. The ESIA was completed in one year with the
support of local in-country consultancies including Insuco Guinea, SENES and Sylvatrop. The
ESIA was originally prepared in French but was subsequently translated to English.
The ESIA has the following structure:
Chapter 0 – Executive summary;
Chapter 1 - Background to the environmental and social impact assessment for the Expansion
Project;
Chapter 2 - Study of the physical environment;
Chapter 3 - Biological baseline;
Chapter 4 - Study impacts on the biological environment;
Chapter 5 - Social baseline;
Chapter 6 - Stakeholder consultation;
Chapter 7 - Social impact assessment;
Chapter 8 - Report of potential impacts on human rights;
Chapter 9 - Cumulative effects assessment;
Chapter 10 - Health risk assessment report;
Chapter 106 - Environmental and social management plan: and
6 The French version was released with two Chapter 10s. The numbering error was rectified in the English translation.
Environmental and Social Due Diligence – Technical Report
18
CBG Bauxite Mine Expansion Project, Guinea
Annexes.
The structure and content of the ESIA is consistent with other ESIAs for projects of similar size
and significance. Further commentary concerning the adequacy of the ESIA is provided later in
this and subsequent sections. The scope of the ESIA was based on a mining plan initially
submitted for the period up to 2027 (Figure 1-2). Extension of the mining areas—and therefore
extension of the railroad, or construction of a road capable of handling land trains—was studied
as part of the 2014–2042 Long-Term Mining Plan (June 2014), but was not included in this ESIA,
since operations will not be moved to the North Cogon area until 2027. An additional study will
be needed for that extension.
Chapter 1 of the ESIA includes a project description, the legislative framework, an analysis of
alternatives and the Terms of Reference for the study.
6.2.1 Project Description
The ESIA contains a description of the Expansion Project and provides a good appreciation of the
Project details. Although there is no specific definition of area of influence (as defined within the
IFC Performance Standards) the Project area of influence, inclusive of the port, processing
facilities railway and mining facilities is adequately captured within the Project description and
subsequent impact assessment chapters. The ESIA was only finalised (December 2014) based on
the FEL 2 design7 and the Project description provides a reasonable summary of the current
Project design (as of September 2015), thus providing an acceptable basis for the impact
assessment.
There are, however, a number of observations with respect to the accuracy of the ESIA project
description:

there is very little information regarding the additional infrastructure works planned for
Sangarédi and Kamsar;

the ESIA does not reflect the current waste management operations or plans for the use of
new incinerators;
The ESIA also acknowledges a number of uncertainties that result from the long-term
development of the dispersed bauxite plateaux (known locally as “bowals”), including a lack of
information pertaining to route alignments for future mine access roads and assessment of
dredging impacts.
Changes to the Project design resulting from further refinement during the FEL 3 (detailed
design) stage which result in material environmental and/or social impact should be subject to a
management of change process and further considered during future Lenders’ monitoring visits.
6.2.2 Analysis of Alternatives
An Analysis of Alternatives is presented in the ESIA. Examples of alternatives considered are
provided below:

The mining plan has been revised to optimise mining operations and the duration of mining
activity and reduce impacts on land take and populations. For example, in the “Bowal8 22”
area, the mining operations will last 4 years instead of 9 years as initially planned.
7 Work to prepare the mine Expansion Project is divided into 4 Front-End Loading (FEL) phases: FEL 0 to FEL 3. FEL 2 is essentially the
pre-feasibility phase and FEL 3 is the feasibility phase. The ESIA Report is a FEL 2 deliverable.
8 The term ‘bowal’ refers to an area of weathered lateritic plateau
Environmental and Social Due Diligence – Technical Report
19
CBG Bauxite Mine Expansion Project, Guinea

The use of surface extraction equipment (instead of explosives) has been considered and
remains under evaluation as part of the on-going FEL 3 study, noting that discussions with
Company representatives would suggest non-explosive extraction is feasible in many cases.

Several options for crossing the national road (which will be required in 2017 when
operations will move to the north-east of the road) have also been considered. A bridge will
be built and mining trucks will pass under the bridge.

Several options for the port operations were considered, including the size of vessels required
to meet the expanded export capacity. Following a consideration of alternatives CBG took the
decision not to use larger Cape Size vessels, thereby avoiding the need to dredge the existing
approach channel and significantly reducing the amount of dredging required.

The location of railway sidings, primarily associated with the 27.5Mtpa phase, has been
altered to increase the separation distance between a village and the Project’s railway
activities following the identification of nearby settlements.

Areas outside of the Expansion Project’s industrial zones were initially selected as sites for
construction camps. Following consultations and further consideration of social impacts, both
camps will be located within the Kamsar and Sangarédi industrial zones.
The Analysis of Alternatives appears to have taken environmental and social aspects into
consideration.
6.2.3 Legislative Framework
See Section 4 of this report.
6.2.4 Impact Assessment Methodology
A consistent methodological approach has been used for each of the physical, biological and
social impact assessments. Positive, negative, direct and indirect impacts have been considered
using information gathered from baseline studies and stakeholder meetings.
The ESIA states that impacts have been assessed for two phases of the Project: construction and
operations; and for three areas: 1) Kamsar plant and port; 2) the railway connecting the mine to
the plant; and 3) the bauxite mine concession area. Whereas there is no reference to
decommissioning, certain elements of mine closure/reinstatement are addressed through mine
rehabilitation plans (Section 6.3.2, Mine Rehabilitation and Closure Plan).
The impacts are assessed based on the following criteria:

Value (~sensitivity) [1/3];

Degree of disturbance [1/3];

Geographical extent [1/6]; and

Duration [1/6].
Each criterion is then assessed to determine whether the impact is ‘Low’, ‘Medium’ or ‘High’ using
a matrix that is largely qualitative.
Residual impacts are assessed according to the same methodology and take into consideration
another criterion: the likelihood of occurrence. This criterion has been used to prioritise the
actions for inclusion in the Environmental and Social Management Plan (ESMP).
6.2.5 Mitigation Measures (General)
The ESIA identifies numerous mitigation measures and concludes that the Project’s impacts are
acceptable provided the mitigation measures identified in the ESIA are implemented in full.
Environmental and Social Due Diligence – Technical Report
20
CBG Bauxite Mine Expansion Project, Guinea
The Company is committed to the implementation of the measures specified in the ESMP,
Chapter 10 of the ESIA, and any amendments to the ESMP made as a result of the Lenders’ due
diligence process. Amendments will be disclosed as part of the SIP.
6.2.6 Cumulative Impacts
The ESIA includes a chapter dedicated to the assessment of cumulative impacts that, according
to the ESIA, uses the guidelines of the Canadian Environmental Agency (Canadian Environmental
Assessment Agency Practitioners Guide to Cumulative Effects Assessment, 1999). The chapter
also states that the standards of the IFC Good Practice Note – Cumulative Impact Assessment
and Management: Guidance for the private sector in Emerging Markets, 2012) are also met.
The IFC Guidance note introduces a six stage approach to the assessment of cumulative impacts
as follows:

Step 1: Scoping Phase I – Valued Environmental Components (VEC), Spatial and Temporal
Boundaries;

Step 2: Scoping Phase II – Other Activities and Environmental Drivers;

Step 3: Establish Information on Baseline Status of VECs;

Step 4: Assess Cumulative Impacts on VECs;

Step 5: Assess Significance of Predicted Cumulative Impacts; and

Step 6: Management of Cumulative Impacts – Design and Implementation.
The guidance provides a systematic framework for the assessment of cumulative impacts. The
Cumulative Impacts Assessment (CIA) provided within the ESIA is generally brief and only
partially includes the steps listed above, or omits them entirely, e.g. no assessment of
significance and very little in terms of the management of cumulative impacts as required by
Steps 5 and 6, respectively.
The CIA does, however, briefly outline proposed and/or anticipated future developments in north
west Guinea that consist primarily of further bauxite mining operations that are proposed or
currently active in concession areas surrounding the Expansion Project. Similarly, further
railways, refineries and ports are described. The level of detail provided in the ESIA is limited,
reportedly because information concerning these projects was considered to be limited or out of
date at the time the ESIA was prepared.
Current and possible future projects with the potential to result in cumulative impacts are listed
in the table below.
Environmental and Social Due Diligence – Technical Report
21
CBG Bauxite Mine Expansion Project, Guinea
Table 2: Other projects in the vicinity with potential to cause cumulative impacts
Project with Potential for
Cumulative Impact
1. Guinea Alumina Corporation
(GAC)
Comments
Bauxite mine to the west and immediately adjacent to the
CBG Expansion Project.
Potential shared use of CBG railway
New port adjacent to CBG port
Status: ongoing
2. La Compagnie des Bauxites
de Dian-Dian - Rusal-
Bauxite Mine northwest and immediately adjacent to the
CBG Expansion Project
COBAD
3. Project Nord Cogon /
Gaoual – (CBG)
4. Projects Boffa-SantouHouda
The expansion of CBG operations north of the Cogon River is
scheduled for 2030
Several bauxite concessions are listed in the prefectures of
Boffa, Boke and Télimélé.
5. Project Fria - Rusal
Bauxite mining to the south east of the Expansion Project
concession area.
6. Project Kabata - Alcoa / Rio
The Kabata project which includes the construction of an
alumina refinery for CBG’s bauxite with an initial capacity of
1.5 Mtpa. Through successive expansions, the project could
reach a maximum capacity of 4.5 Mtpa.
Tinto Alcan (RTA)
The project would be located near Kamsar and would be
connected to the current rail line at the PK14. The
construction of a port adjacent to the plant is also planned.
7. Raffineria d’alumine de
Boké - Henan International
Mining Company
8. Barrage hydroélectrique sur
le fleuve Cogon
Includes plans to construct and operate a bauxite mine with
a production capacity of 10 Mtpa and an alumina plant with
a capacity of 1.2 Mtpa.
Infrastructure such as a port, power plant and a railway
would be constructed.
This is a project to build a hydroelectric dam on the Cogon
river between the prefecture of Boké and Gaoual, funded by
the mining company Semafo and IFC. Date of start-up
unknown.
The Figure below is taken from the CIA chapter of the ESIA to illustrate the extent and proximity
of ongoing and proposed projects in the region relative to CBG facilities.
Environmental and Social Due Diligence – Technical Report
22
CBG Bauxite Mine Expansion Project, Guinea
Figure 2. Extent and Proximity of Ongoing and Proposed Projects in the Region
Potential cumulative impacts are described qualitatively for each of the three Expansion Project
components: mine, rail and port. No methodological attempt is made to assess the significance,
although the descriptive narrative outlines numerous significant cumulative impacts, with which
we would concur, relating to: land take, economic and physical displacement, biodiversity, air
quality, social dynamics and demography, population flux and cultural heritage amongst others.
The CIA chapter concludes with a recommendation that the Government of Guinea should work
with mining companies to undertake a strategic study of the impacts associated with the bauxite
mining industry. As reported in the Interim Report, the Company’s role in communicating this
recommendation to the Government, or its role in managing cumulative impacts is unclear from
the ESIA.
The potential for cumulative impacts has been discussed on several occasions and is
acknowledged by the IESC, Lenders and the Company. CBG has therefore made the following
firm commitment in the revised ESMP ‘CBG is considering cumulative impacts within its area of
influence in accordance with PS1 and will cooperate with any national institution or any other
company which would launch work in the CBG area of influence in order to implement common
mitigation measures.’
The assessment of cumulative impacts typically requires a collaborative approach and the sharing
of information by those parties with the potential to cause cumulative impacts. In the case of the
rail network, where CBG is the operator, CBG has an obligation under a Rail Concession
Agreement to undertake environmental and social studies in relation to any expansion and/or
increased use of the rail network. To date, the IESC understands that no request has been made
to use the rail network, however, should such a request be made in the future, CBG will be well
placed to assess the cumulative impacts associated with any additional rail network user(s).
Environmental and Social Due Diligence – Technical Report
23
CBG Bauxite Mine Expansion Project, Guinea
IFC is also looking at options to providing fund in support of a regional cumulative impacts
assessment. Whereas the funding has not been secured, on the basis of the CBG commitment
above, it is understood that such an initiative would be supported by CBG.
6.2.7 Stakeholder engagement
In its Interim Report, Ramboll Environ reported that the Stakeholder Engagement Plan (SEP),
referred to in chapter 6 of the ESIA Report, entitled ‘Consultations des Parties Prenantes’
(Stakeholder Consultations) was not available. Subsequent to the submission of the Interim
Report the SEP was made available to Ramboll Environ as was another document, entitled,
‘Procedure for Stakeholder Engagement Management Plan (CBG_HSEC_PRO_5020 Version 1,
01/07/2015). Subsequently, after the Paris workshop, this latter SEP was amended, approved
and issued as Procedure for Stakeholder Engagement Management Plan - CBG_HSEC_PRO_5040
Version 1, 18/09/2015. Although referred to once, in the text, as a ‘Community Relations Plan’
this SEP does apply to a wide range of local stakeholders and sets our broad principles for
stakeholder engagement to be used in the implementation of CBG project and operations in the
post-ESIA phase.
Therefore, there are two SEP documents: one of which relates to the ESIA process, the ‘ESIA’
SEP, and one which focuses on the project implementation phase, the ‘post-ESIA’ SEP. Following
a review of these two SEPs prior to the Paris workshop CBG was requested to:

Update the ‘ESIA’ SEP by including a clear statement that this SEP was approved by CBG
prior to ESIA stakeholder activities being initiated; and

Amending the ‘post-ESIA’ SEP so that it includes a systematic account of stakeholder
identification accompanied by stakeholder mapping. Also, more details were requested on the
schedule for consultation events, frequency of their occurrence, the disclosure of materials
and mechanisms for managing consultations.
Comments are provided below on both the ‘ESIA’ and ‘post-ESIA’ SEPs.
‘ESIA’ Stakeholder Engagement Plan
Structure and Content
This SEP was approved by CBG in the autumn of 2013, early in the ESIA process. It is stated that
a number of its recommendations have been acted upon by CBG since the approval date. Given
that it is approved, the text should have been updated in a way that is consistent with the
‘approved’ status of the SEP. For example, in section 7.3.1 there is reference to, “…. a preliminary
list of stakeholders potentially targeted for consultations on project-related issues is provided
below…”. Also, in Section 9 there is the following statement, concerning the proposed actions in
the consultation calendar (table 9-1), “The table below proposes a calendar for the implementation
of the stakeholder engagement plan, which is primarily dependent on when the SEP is finalized and
approved by CBG internally.” Similarly, the table caption is “Provisional timetable for launching the
SEP”. These statements give the impression that it is still a working draft.
In section 7.3, of the SEP, specific reference is made to the stakeholder engagement
requirements stipulated in paragraphs 25-36 of PS 1 and it is stated that the engagement
strategy is designed to meet IFC requirements. A summary is provided of the key IFC
requirements in which developing a Social Management Plan is presented as the final item.
Preparation of such a Social management Plan is not an IFC requirement in any of the PSs (an
additional comment on this Plan will be provided below). Despite the reference to key PS 1
requirements there is no mention of the guidance on the structure/content of SEPs as provided in
the companion Guidance Note 1 (Annex B). It is not a requirement to prepare a SEP with the
structure/content as indicated in the Guidance Note, but it is prudent to take note of this
guidance and it is surprising to see no reference to it in the SEP and to see that the structure of
the SEP does not approximate to the suggested Table of Contents in IFC’s Guidance Note.
Environmental and Social Due Diligence – Technical Report
24
CBG Bauxite Mine Expansion Project, Guinea
The SEP does include sections that contain information/material that complies with both PS 1 and
the ‘Annex B’ guidance on SEP structure/contents. However, the focus, emphasis and level of
detail provided, in many instances, is not consistent with the ‘spirit’ of IFC requirements and,
also, good international industry practice for SEP content/implementation. In addition, the scope
of the SEP is much wider than is really necessary. It has elements that appear to relate more to
formulation of a CBG internal/external communications policy/plan rather than to a SEP for an
ESIA process. In this context, it is noted that the post-ESIA SEP is cross-referenced in this SEP
(Procedure for Stakeholder Engagement Management Plan - CBG_HSEC_PRO_5020 Version 1,
01/07/2015, subsequently amended, approved and issued as CBG_HSEC_PRO_5040 Version 1,
18/09/2015).
ESIA-related stakeholder engagement actions
The key elements of stakeholder engagement that ‘may’ be implemented are contained in the
following statement from PS 1, “Stakeholder engagement is an ongoing process that may
involve, in varying degrees, the following elements: stakeholder analysis and planning, disclosure
and dissemination of information, consultation and participation, grievance mechanism, and
ongoing reporting to Affected Communities”. However, the nature, frequency, and level of effort
may vary commensurate with a project’s risks and adverse impacts, and its phase of
development.
The evidence from ESIA Chapter 6 shows that stakeholder engagement has been an ongoing
process up to December, 2014 (date of ESIA Report). Consultations occurred at three phases:
scoping (with preparation of Scoping Report), baseline study preparation and, then, during the
assessment of impacts. Post ESIA finalisation, the agency responsible for approving the ESIA,
the Bureau Guinéen d’Études et d’Évaluation Environnementale (BGÉÉE) conducted a series of
feedback meetings on the ESIA and ESMP to selected communities in/near the mine area, the
factory/port area and along the railway.
In addition, two of the PS 1 ‘elements’ are in place: disclosure and dissemination of information,
and consultation and participation. Review of the SEP confirms that it is not possible to evaluate
the extent of stakeholder analysis and planning as the rationale behind the SEP scope in terms of
stakeholder identification and engagement planning is not clearly presented (see comments
below). The SEP does include a grievance mechanism. Only partial information is presented on
the topic of type and scale of ongoing reporting to Affected Communities.
PS 1 gives emphasis to identifying Affected Communities and ‘other’ stakeholders. However,
there are only generic references in Chapter 6 to Affected Communities (for example, villages
located close to the railway). There are no lists naming Affected Communities for each of the
concession area, the railway and the port facility. Further, PS 1 requires that care is taken when
identifying ‘Affected Community’ stakeholders, “where applicable, the Stakeholder Engagement
Plan will include differentiated measures to allow the effective participation of those identified as
disadvantaged or vulnerable. When the stakeholder engagement process depends substantially
on community representatives, the client will make every reasonable effort to verify that such
persons do in fact represent the views of Affected Communities and that they can be relied upon
to faithfully communicate the results of consultations to their constituents” The caveat ‘where
applicable’ is believed to apply to the CBG Expansion Project because of the scale (both in terms
of locations and magnitude) of the type of activities needed to achieve the proposed increase in
output per annum.
Chapter 6 does show that a range of Affected Community stakeholders were identified (for
example, youth and women’s groups). However, there is no mention of disadvantaged or
vulnerable groups being consulted. There is mention of a number of public meetings in
communities, but no information to demonstrate the rationale behind the selection of the
Environmental and Social Due Diligence – Technical Report
25
CBG Bauxite Mine Expansion Project, Guinea
locations for the meetings and the type of invitees or attendees in terms of ensuring that these
stakeholders were representative of their communities.
For projects with potentially significant adverse impacts on Affected Communities, an Informed
Consultation and Participation (ICP) process must be conducted. An ICP process involves an indepth exchange of views and information, leading to the client incorporating into its decisionmaking process the views of the Affected Communities on matters that affect them directly, such
as the proposed mitigation measures and the sharing of development benefits and opportunities.
A number of communities, such as Hamdallaye, are identified as being expected to experience
potentially significant adverse impacts (physical displacement) – others may experience
potentially significant adverse impacts, but not involving either physical or economic
displacement. However, there is no mention of an ICP process being undertaken for any
community (however, in the list of Abbreviations and Acronyms, ICP is included as CPÉ:
Consultation et participation éclairées) and it is mentioned in in the SEP. For communities such
as Hamdallaye the ICP process would be subsumed in work to be done to prepare a Resettlement
Action Plan. Indeed, the Resettlement and Livelihoods Restoration Policy Framework, prepared
as a precursor to the first and subsequent RAPs (first RAP is for villages of Fassaly Foutabhe and
Hamdallaye) includes ICP as part of RAP/LRP preparation.
The main concerns relating to the SEP refer to the lack of specific detail on the following topics:

Stakeholder identity and relative priority (types of stakeholders are mentioned in the text and
in Annexe 1 a long list of specific stakeholders is provided – these were stakeholders
consulted during the scoping stage). Affected communities are mentioned by name, but there
is no list of these communities by concession area, rail network of port/facility area in the
main SEP text. Also, there is virtually no reference to vulnerable groups apart from a brief
mention of women and young people;

The range of disclosure and consultation activities to be implemented according to ESIA
stages (such as scoping - apart from the provision of the long list of individual stakeholders
in Annexe 1), during ESIA work, and ESIA Report completion). There are no tables showing
integration of disclosure and consultation with ESIA stages;

Disclosure materials and methods; and

Consultation methods to be used for the different stakeholder types (there is reference to
focus groups, but no presentation of the different types of consultation methods considered
appropriate by stakeholder type).
Although there is mention/consideration of all of these topics there is no underlying
rationale/logic or methodological approach presented which presents clearly and systematically:

The identity of stakeholders (and priority) and allocation to two key groups (Affected
Community and Non-affected Community stakeholders);

When stakeholders will be consulted in terms of ESIA process;

How they will be consulted (methods such as face-to-face meetings; public meetings); and

Type of information disclosure that will occur (especially, materials to be disclosed, language,
timing, and mechanism of disclosure).
The topic of disclosure is mentioned, but apart from a few references to certain methods such as
use of radio there is no statements about materials (such as brochures/leaflets and posters) to
be prepared (also, language/s to be used) and dissemination mechanisms. The SEP gives no
clear indication that all stakeholders will receive material on the proposed Project /ESIA in a
location/format that they can access/understand easily and in a timeframe that will give them
time to consider the contents. This is a key issue in terms of PS 1 and it is not presented
adequately in the SEP.
Environmental and Social Due Diligence – Technical Report
26
CBG Bauxite Mine Expansion Project, Guinea
An ESIA-focused SEP is essentially a tool which sets out an integrated action plan for undertaking
ESIA-related consultations. One key test of the adequacy of such a SEP is to consider the extent
to which a person/team, with no prior involvement in SEP preparation, could read the SEP and
then implement it in a cost-effective way. The lack of background rationale and detail, in the SEP,
would preclude such a ‘new’ team from undertaking this activity without considerable assistance
from the existing ESIA team.
It is stated that a Social Management Plan will be prepared. No such Plan exists in the ESIA or
associated documents reviewed to date. Chapter 10 of the ESIA report contains an Environmental
and Social Management Plan. Reference to a ‘standalone’ Social Management Plan is
unnecessary.
Post-ESIA Stakeholder Engagement Plan
The focus of this SEP (Procedure for Stakeholder Engagement Management Plan CBG_HSEC_PRO_5040 Version 1, 18/09/2015) is on managing current and future CBG
operations and projects and on local-level stakeholders. Two comments can be made on this
document. First, the word ‘Procedure’’ is not appropriate and should be removed from the title.
Secondly, although it requires annual monitoring for evaluation purposes there is no time-scale
provided for review, amendment and, as necessary, re-issue. Also, within this context, there is
no requirement for regular reporting of the results from the monitoring/evaluation. Reference is
made, in this SEP, to the following supporting HSEC documents:

CBG_HSEC_PRO_5030 Procedure for Stakeholder Identification, Analysis and Mapping
(Version 1; Issued 18/09/2015);

CBG_HSEC_PRO_5060 Grievance Mechanism Procedure (Version 1; Issued 01/09/2015); and

CBG_HSEC_ENR_5041 Procès-verbaux des reunions (template for recording the minutes of
meetings).
In response to requests made at the Paris workshop (see above), following a review of an earlier
version of this SEP, more details are provided in the current version on the range of
stakeholders, the schedule for engagement activities and mechanisms for implementing the
activities. It is supported by a companion ‘Procedure for Stakeholder Identification and Analysis
and Mapping’ which in turn is supported by:

CBG_HSEC_ENR_ 5031 Stakeholder identification and Analysis Register; and

CBG_HSEC_ENR_ 5032_Stakeholder Mapping Tool.
This ‘Procedure’ (and the register and mapping tool) will be used to support SEP implementation
and periodic updating of the SEP. SEP performance will be monitored/evaluated using a set of
indicators to be developed by the HSEC Director. These documents are all very recent and there
is no experience yet of their use. The stakeholder list in CBG_HSEC_ENR_ 5031 Stakeholder
identification and Analysis Register is comprehensive and includes the main ‘Affected Community‘
stakeholders. However, three comments can be made. First, the list of community-based
economic groups includes ‘animal husbandry’ which is an ambiguous term as it can cover two
distinct ethnic groups with different livelihood strategies with respect to livestock. Sedentary
farmers can be involved in animal husbandry as can groups with a pastoralist way of life (usually
ethnically and culturally distinct from sedentary farming groups). The former stay in one location
while the others move with their animals and occupy territory only temporarily (often
seasonally). It would be better for animal husbandry to be subsumed under ‘farmers’ to produce
the following stakeholder group - farmers (crop and animal husbandry) and to add an additional
group to the list – livestock/cattle herders. This will help ensure that herders who may be using
bowals, likely to be affected by mine expansion, are consulted along with other ‘Affected
Community‘ stakeholders. Secondly, the CBG_HSEC_ENR_ 5032_Stakeholder Mapping Tool
Environmental and Social Due Diligence – Technical Report
27
CBG Bauxite Mine Expansion Project, Guinea
refers to ‘indigenous peoples’. To avoid confusion this item should be removed as it has be
established that there are no indigenous peoples, as defined by PS 7, which inhabit or occupy
temporarily the mine expansion Area of Influence. Finally, it will be important, going forward,
that there is continuing consistency in terms of stakeholder identity and characteristics between
these related, but separate documents. Careful co-ordination and rigorous QA/QC will be needed
in updating work.
This SEP does not include a Grievance Mechanism as it is presented in a support document to the
SEP - as indicated above (see also Section 6.2.8 below).
6.2.8 Grievance mechanism
The ESIA presents evidence that local stakeholders consider that the current mechanism(s) for
dealing with grievances is (are) not working effectively. Also, in Section 3.4.2 of Chapter 10, the
ESIA Report refers to a Complaints Registry and states that a Grievance Mechanism will be
announced and explained to the communities. This suggests that there is no current Grievance
Mechanism in place, but rather that one will be produced for the Expansion Project. This is
further supported by other sections in the ESIA that refer to the lack of a formal system for
complaints management and by the fact that the ‘ESIA’ SEP includes a Grievance Mechanism.
Based on the description of a proposed Grievance Mechanism presented in the ‘ESIA’ SEP, CBG
has prepared, but not yet approved, a Grievance Mechanism (CBG_HSEC_PRO_5060 Grievance
Mechanism Procedure, Version 1, Issued 01/09/2015). This Grievance Mechanism is stated to be
compliant with PS 1 and PS 5 and its scope includes communities (including individuals),
contractors and sub-contractors, companies and other stakeholders either living or
working/operating within CBG’s zone of influence. The key responsibility for managing the
Grievance Mechanism will rest with the Coordinator for Resettlement, Compensation and
Grievance Management.
The Grievance Mechanism includes most of the key principles and characteristics that accord with
PS 1 and good international practice. The objectives of the Grievance Mechanism are clearly
stated and comply with PS 1 requirements as stated in paragraph 35 of PS 1; except for
statements to the effect that that the Grievance Mechanisms will involve no costs to a
complainant and that there will be no retribution directed at any complainant.
Some details are not developed fully as might be expected in the Procedure. For example, few
details are provided on the range of ways in which a grievance can be submitted. It seems that
contact (mostly verbal) with community liaison personnel is the method most likely to be initiated
and, therefore, used. There is no mention of other options such as boxes that could be located in
selected communities in easily accessible sites or submission of grievances by email/text (may be
an option for some stakeholders). Also, the method by which communities and other
stakeholders will be informed about the Grievance Mechanism, and how it will operate, is not
presented.
During the Paris workshop, CBG was requested to provide a status account relating to number of
‘open’ community grievances and progress being made to close them. Subsequently, CBG has
reported (SIP Appendix 8.7 Grievance Management Memorandum) that, since April 2014, the
newly-formed department of Community Relations (Relation Communautaire) has been involved
in ESIA- and RAP-related consultations and, as a result, a number of unresolved community
complaints (31) came to light. All these complaints were registered, subsequently, and
processed in order to resolve them. At the time of reporting, 24 of the 31 complaints (77%)
have been processed and closed. Work is continuing to close the remaining complaints in the
near future.
Environmental and Social Due Diligence – Technical Report
28
CBG Bauxite Mine Expansion Project, Guinea
6.3
Management plans
Chapter 10 of the ESIA is referred to as the Environmental and Social Management Plan (ESMP)
for the Expansion Project that has been integrated with the ESIA in accordance with the
requirements set forth in national legislation, including the General Guide for Conducting
Environmental and Social Impact Studies in the Republic of Guinea, 2013. The chapter includes:

a summary of the Project’s Health, Safety Environment and Community (HSEC) standards
and systems;

an explanation of the ESMP’s integration with the broader HSEC Management System (HSECMS), including the development of detailed environmental and social plans, programmes and
procedures; and

a list of mitigation measures identified in the ESIA.
The ESMP makes reference to the management of Health and Safety (H&S), approach to H&S
risk analysis and over 50 policies and existing procedures that contribute to the Health, Safety,
Environment and Communities Management System (HSEC-MS), skills and training and the audit
process. Many of these have been provided for review during the due diligence process.
The ESMP is considered to be a live document that will require periodic update as actions are
completed or new actions become necessary. Consistent with its ‘live status’ the ESMP disclosed
as part of the ESIA has since been revised and disclosed (October 2015) as part of the
Supplementary Information Package.
Whereas the ESIA provides a reasonable overview of the HSEC-MS it should be noted that
specific mitigation measures are merely listed and have not yet been fully incorporated in
Expansion Project Management Plans and/or existing operations phase management plans.
Furthermore they are often generic or lack specificity in certain cases.
The disclosed ESIA also makes reference to a number of other plans, including:

a mine rehabilitation plan (Sangarédi);

a harvest management plan for bushmeat;

a management plan for the harvest of firewood;

a forest protection plan (Sangarédi);

a plan to protect vegetation bowals;

the Cogon corridor protection plan; and

a plan to protect the estuary of the Rio Nuñez.
Following finalisation of the Interim Report Ramboll Environ was made aware that these plans
would be amalgamated within a Biodiversity Action Plan (BAP), itself preceded by a BAP
Framework (BAF). Accordingly reference to these plans is not included in the revised ESMP
disclosed within the SIP. Further commentary on the adequacy of a BAP framework is provided in
Chapter 11, Performance Standard 6.
6.3.1 Information gaps
The ESIA reports that a number of necessary studies could not be considered during the
preparation of the ESIA because engineering decisions were pending, for example, dredging
works and the routing of future mining roads.
6.3.2 Mine Reclamation and Closure Plan
In accordance with IFC EHS Guidelines for Mining, mine sponsors should prepare a Mine
Reclamation and Closure Plan (MRCP) in draft form prior to the start of production, clearly
Environmental and Social Due Diligence – Technical Report
29
CBG Bauxite Mine Expansion Project, Guinea
identifying allocated and sustainable funding sources to implement the plan and outlining the
Company’s intentions to continue environmental and social monitoring post closure. The Long
Term Mine Plan, dated June 2014, highlights that there is not a plan for the existing mine. The
need to develop such a plan is clearly identified in the ESIA9.
The need for further consideration of mine closure, particularly the need to establish a funding
mechanism, was discussed during the Paris workshops, where is became apparent that the
Company did have plans for rehabilitation of disturbed areas, including the most recent
‘Conceptual Mine Reclamation and Closure Plan’ (dated September 2015).
The plan recognises that rehabilitation budgets have been insufficient in the past, thereby
resulting in a backlog of land in need of rehabilitation. It also recognises the additional budget
necessary to address the backlog with the aim of clearing the backlog by 2030. The plan further
outlines a progressive approach to mine closure in line with the phased opening of new mining
areas. The plan has as one of its objectives the rehabilitation planning on a system of running
closures, rehabilitation and monitoring. The plan outlines actions associate with temporary
closure (where an area may be reworked at a later date) and final closure. It further describes
activities during operational and post-operational phases, including social programmes and water
management and is costed through to 2027. The social planning includes brief consideration of
loss of employment and support to be provided by CBG to find alternatives or retrain. However,
this is not fully considered and it is expected that measures to further refine closure management
measures will be included in an evolving ESMP. It is further noted that the Conceptual Mine
Reclamation and Closure Plan is limited to the mining areas around Sangarédi i.e. it does not
address final closure of CBG’s operations outside of the Sangarédi area, thereby excluding
closure in other Project areas, for example, the demolition of port and plant facilities at Kamsar.
CBG has confirmed its commitment to undertake a development of a Mine Reclamation and
Closure Plan that aligns with the requirements of the IFC EHS Guidelines for Mining. The plan will
be based on the current conceptual plan and is scheduled for finalization in December 2015.
The revised plan will also provide details of financial provisions to be set aside for mine closure.
The financial mechanism used to ensure financial sustainable funding will be based on the
guidance document ‘Guide to Accounting for Asset Retirement Obligations - An Analysis of FASB
Statement No. 14, KPMG 2003. Details of CBG’s funding mechanisms, the anticipated closure
costs and the current funding levels are provide in the Independent Engineer’s report.
The ESMP presented in the SIP commits to undertake closure in accordance with the Rio Tinto
Standard (March 2013), although this applies only to mining areas at the exclusion of rail and
Plant/port areas.
6.3.3 Contingency planning
CBG approach to emergency response is outlined in its Emergency response procedure Procedure for Plan d Mesures d’Urgence (PMU) issued 01/07/2015 CBG-HSEC –PRO-1120. The
status of the document is unclear and would appear to have been recently prepared and be
unapproved.
The procedure is intended to cover all significant emergency situations including fires, explosions,
spills of hazardous materials, release of toxic gases.
The plan defines linkages with other organisations to be contacted/involved in an emergency
response including communication with the public; roles and responsibilities within CBG and
makes reference to the following specific plans within the procedure:
9 Ramboll Environ was initially provided with a Mine Closure Plan dated June 2011 immediately prior to finalisation of this Interim
Report. .
Environmental and Social Due Diligence – Technical Report
30
CBG Bauxite Mine Expansion Project, Guinea

Train derailment carrying dangerous goods;

Liquid hydrocarbon leak at the plant site;

Leak offshore hydrocarbon liquid;

Fire involving hydrocarbons;

Fire a garage, stores, maintenance shop, warehouse involving hazardous materials.
The plans refer to response actions and also specific high-level requirements for training and
periodic exercise drills. However the plans generally lack specificity and cannot be considered to
be operational emergency response plans. For example, there is little reference to environmental
sensitives requiring prioritisation e.g. mangrove areas, a tiered approach and external resources
to support in large incidents, equipment types/inventories or deployment methods, although
photographic evidence presented to Ramboll Environ does confirm that CBG has an equipment
stockpile inclusive of floating booms for oil containment in port waters.
Environmental and Social Due Diligence – Technical Report
31
CBG Bauxite Mine Expansion Project, Guinea
Table 3: Summary of Findings, PS1
ID
Aspect
001
Cumulative
Impact
Assessment
Issue Description
The ESIA (as disclosed following submission
Phase
Standard
All
PS1
IESC Recommendations
The commitment satisfies PS1, however
to national regulators) does not fully follow
it is recognised that the Company will
recognised guidelines for the assessment of
need to maintain a proactive approach to
cumulative impacts and consequently does
understanding and management of
not identify specific mitigation measures.
cumulative impacts, and engage with
However the Company has since committed
other parties on a regular basis.
in a Supplementary Information Package to
further consideration of cumulative in
accordance with PS1 and cooperation with
Further plans should be developed in
other bodies to implement common
collaboration with external parties and
mitigation measures.
the implementation of such plans
monitored.
002
‘ESIA’ SEP
contents,
scope and
focus
The ‘ESIA’ SEP does not present an adequate
All
PS1
approved by the Guinean competent
or details as to inter alia stakeholder
authority (BGÉÉE) there is no benefit to
identified (Affected Community and Non-
be gained by amending the ‘ESIA’ SEP to
Affected Community stakeholders); schedule
take account of these comments. This
of engagement activities linked to the key
view is reinforced by the existence of the
ESIA process stages; methods for engaging
‘post-ESIA’ SEP and its companion
with stakeholders by stakeholder type;
support documents.
mechanisms. These are all key factors to be
clearly presented in a SEP. As this ‘ESIA’ SEP
lacks this information it is considered that it
would not be possible for others, not involved
in SEP preparation, to implement it
effectively.
High
(possibly
falling to Low
or moderate
although there
is an inherent
uncertainty
because CBG
will be reliant
on
collaboration
with 3rd
parties to
manage
cumulative
impacts)
Since the ESIA Report has been
rationale (as a basis for its scope/contents)
materials for dissemination and dissemination
Significance
Low
Environmental and Social Due Diligence – Technical Report
32
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
003
‘Procedure
for a
Stakeholder
Engagement
Management
Plan’: title
and ‘review’
period
The current title is inappropriate. It is not a
‘Procedure’. Also, although
monitoring/evaluation will occur annually,
there is no date given for a review and
possible amendment/re-issue, as necessary
of this Plan.
Preexpansi
on and
ongoing
PS1
The title should be changed to
‘Stakeholder Engagement Plan’. It
should also include a date by which it
will be reviewed and, as necessary,
amended and re-issued on the basis of
the monitoring/evaluation results.
Stakeholder
engagement
reporting
Although there is a monitoring/evaluation
requirement there is no reporting
requirement.
Preexpansi
on and
ongoing
Stakeholder
identification
for postESIA
Herders of livestock (cattle herders following
a pastoral livelihood strategy to varying
degrees) are not identified separately from
other groups practising animal husbandry.
There is a risk they may be omitted from
consultations if not explicitly identified as a
distinct stakeholder.
Preexpansi
on and
ongoing
In the CBG_HSEC_ENR_ 5032_Stakeholder
Mapping Tool there is a reference to
Preexpansi
on
PS1
A requirement should be inserted in
section 2.7 Evaluation du PEPP (SEP
evaluation) stating that an annual report
will be prepared, for each the first 4
years of SEP implementation, and
submitted to the Lenders by an agreed
date for each of the four years.
Thereafter, the reporting period will be
reviewed and may be amended by
mutual agreement between CBG and the
Lenders.
Significance
Moderate
(Negligible
once all
changes have
been made)
The stakeholder list in CBG_HSEC_ENR_
5031 Stakeholder identification and
Analysis Register should be amended so
that the term ‘animal husbandry’ is
subsumed under the economic group
‘farmers’ to produce the following
stakeholder group – ‘farmers (crop and
animal husbandry)’ and an additional
economic group should be added to the
list – ‘livestock/cattle herders’.
Moderate
(Negligible
once all
economic
groups have
been
captured)
The reference to ‘indigenous peoples’
should be removed/replaced from the
Low
(negligible)
Environmental and Social Due Diligence – Technical Report
33
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
‘indigenous peoples’. It has be established
that there are no indigenous peoples, within
the meaning of PS 7, that inhabit or occupy
temporarily the mine expansion Area of
Influence.
There is risk of inconsistent stakeholder
identity and characteristics because as
separate but linked documents are being
used/updated.
004
005
Community
Grievances
Grievance
Mechanism
The process of closing outstanding
community grievances from the period 2010
-2015 is not yet complete.
Although compliant with many PS 1
requirements in relation to the scope/content
of a Grievance Mechanism there are the
following deficiencies:

No statements that raising a grievance
will involve no costs to a complainant and
that there will be no retribution directed
at any complainant;

Few details are provided on the range of
ways in which a grievance can be
submitted. It seems that contact (mostly
verbal) with community liaison personnel
IESC Recommendations
Significance
CBG_HSEC_ENR_ 5032_Stakeholder
Mapping Tool.
Preexpansi
on and
ongoing
PostESIA
PostESIA
CBG should ensure careful co-ordination
in the updating of these documents and
apply rigorous QA/QC checks on
proposed updates before approval.
Lenders
PS1
During the first (of the expected) IESC
monitoring visits there should be an
examination of grievance records to
confirm the status of the open
grievances and interview a sample of the
complainants to determine whether the
resolutions are to the satisfaction of the
complainants.
CBG to amend the Grievance Mechanism
by adding add statements that will
remove these deficiencies.
Low
(negligible)
Moderate
(negligible
once
grievances are
closed)
Low
(negligible
once the
amendments
are made and
the Grievance
Mechanism is
disclosed and
operating)
Environmental and Social Due Diligence – Technical Report
34
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
CBG currently has a conceptual Mine
Reclamation and Closure Plan (dated
September 2015). The plans outlines
temporary and final rehabilitation of
disturbed areas around the Sangarédi mining
activities and provides funding information.
However, it does not consider final closure of
operations and decommissioning of plant and
port facilities at Kamsar. It also provides
insufficient detail in some areas, notably
social programmes.
Ops
IFC EHS
guidelines mining
CBG to upgrade and elaborate the
current conceptual closure plan to align
with the Rio Tinto Standard (March
2013) and IFC EHS Guidelines for
Mining.
The Company has a procedure in place to
manage emergency situations, including oil
spills to sea. However it is unclear what level
of resources are in place and what level of
spill will be managed by CBG.
Ops
Significance
is the method most likely to be initiated
and, therefore, used. There is no mention
of other options such as boxes that could
be located in selected communities in
easily accessible sites or submission of
grievances by email/text.

The method by which communities and
other stakeholders will be informed about
the Grievance Mechanism, and how it will
operate, is not presented.
006
007
Mine closure
and postclosure
Emergency
response
The plans provided for review are generally
brief and cannot be considered to be
operational plans.
IFC EHS
Guidelines
- ports
A series of detailed operational
emergency response plans should be
developed. Response personal should be
well trained and participate in periodic
emergency response exercises/
scenarios.
Moderate
(Negligible
following
revision of
closure plan)
Moderate
(Low when
operational
plans are
developed)
Environmental and Social Due Diligence – Technical Report
35
CBG Bauxite Mine Expansion Project, Guinea
7.
PERFORMANCE STANDARD 2: LABOR AND WORKING
CONDITIONS
7.1
Applicability of PS2
The applicability of PS 2 should be, “…..established during the environmental and social risks and
impacts identification process” (IFC PS 2). There is no statement in the ESIA confirming its
applicability to the proposed Expansion Project. In fact there is no mention, in the ESIA, of this
PS, and its implications, beyond it appearing in lists of all IFC PSs. However, a number of PS2
topics are in fact considered in the ESIA Report - in two separate locations:

Chapter 8 - Report of potential impacts on human rights; and

Chapter 10 - Environmental and Social Management Plan.
Given the social context of the Project, the labour market, need for contractors and the
associated workforce accommodation camp, it is reasonable to consider that IFC PS 2 is
applicable to the Project.
A detailed presentation of impacts and mitigating measures that pertain to human rights is
provided in ESIA Chapter 8. In the context of the proposed Project there is considerable overlap
between the two ‘domains’ of labour and working conditions and human rights. For example, in
Chapter 8 there is an assessment of an impact on the right of workers to form
associations/unions and to strike. Application of PS 2 also, would guarantee this right.
A small number of mitigation measures are identified in the ESMP (Chapter 10) that relate
directly to Labour and Working Conditions. They are presented, however, as mitigating measures
for impacts on ‘the local economy and household livelihood strategies’. Finally, both chapters of
the ESIA contain consideration of issues relating to labour and working conditions for subcontractors and the supply chain.
As all PSs (with the exception of PS7) apply to the Project and, since CBG is long-established
mining operator that wishes to expand its existing operations, it is expected that it will continue
to implement its existing Human Resources (HR) and HR-related policies, procedures and other
documentation (referred to collectively as ‘HR documentation’ below) during the expansion of its
operations. Therefore, a consideration of this HR documentation provides a way to determine key
gaps between it and PS 2 requirements. It is noted that some of the individual items of the HR
documentation date from before 2000 while others are relatively recent.
This section focuses, accordingly, on key topics:
7.2

Analysis of HR documentation against PS 2 requirements and identification of gaps;

Conclusions and recommendations to close gaps.
Analysis of HR documentation against PS 2 requirements and identification of gaps
During the Paris workshop there was a discussion on ‘Labor and Working Conditions’ where CBG
confirmed the existence of a set of HR documents relating to labour and working conditions.
Subsequently, copies of these HR documents were provided and they were reviewed to identify
those that covered/included PS 2 topics. After this analysis, specific HR documents were selected
and they are presented below, with a brief commentary where relevant, identifying the
coverage/inclusion of specific PS 2 elements. They are presented under the following headings:

General/employees;

Health and safety;

Contractors; and
Environmental and Social Due Diligence – Technical Report
36
CBG Bauxite Mine Expansion Project, Guinea

Workers’ camps.
7.2.1 General/employees

Code of Ethics and Business Conduct (Code d’Ethique et de Conduite des Affaires), 2010: This
is similar to a typical ‘Code of Conduct’, but embraces both the Company and workers as
being almost a single entity. The Code covers issues relating to equal opportunities for
workers and it forbids child and forced labour and dealing with suppliers who do use such
labour. There was no evidence of child or forced labour observed during Ramboll Environ’s
site visit indicating the code is effective;

Internal Rules (Reglement interieur), 2009. This is similar in many ways to a Staff Handbook
and covers most of the standard range of topics that would be expected in such a document;

Expansion Project Local Content Policy (implemented since 2010). This Policy emphasizes
recruitment and includes statements about CBG being an equal opportunity employer (taking
no account of ethnicity, religion, age, gender, or marital status) with an approach, “….to
recruitment [that] is supported by a clear methodology that embraces transparency, equity,
and fairness for all candidates”. The issue of equal remuneration is covered by the Collective
Agreement (Convention Collective), 1995 -see below;

Accommodation Policy (Politique de Logement), 2014. This policy deals with allocation of
housing for permanent staff, but not with temporary construction workforce camps; and

Policy for Rationalization of Costs of Workers (Politique de Rationalisation des Couts de Main
d’Ouevre), 1996. This is a policy covering retrenchment issues, but focuses mainly on types
of workers and compensation mechanisms;

Collective Agreement (Convention Collective), 1995. This is similar in scope to a ‘Collective
Bargaining Agreement’ as it covers relations between CBG and workers’ organizations
(syndicats) and includes principles that will be applied to employer (CBG) - employee
relationships. Article 58 of the Agreement state that, “…..wages shall be equal for all workers
recruited in the Republic of Guinea, regardless of their origin, their nationality, their gender,
their age and their status….” Exceptions will be made for expatriate employees in recognition
of the ‘constraints’ that apply to their recruitment; and

Example of a Contract of Employment (unlimited duration), N°152/CDI/70/2013/CBG,
undated. This covers the following key aspects that would be expected in such a contract and
it is in accordance with the laws of Guinea: remuneration/bonus, rights and obligations of
worker and company, annual holidays, medical/social insurance, etc. plus other specific
aspects such as accommodation, transport and allocation of food rations. Dispute resolution is
covered, but only in relation to the role of an external agency, the Regional Labour
Inspectorate.
No Grievance Mechanism for workers was provided. A document entitled’ Traitement des Plaintes’
(Complaints Procedure) was produced, but it is only a small table or section of a larger table,
which contains a summary of a complaint/grievance, the responsible person for managing it and
the action taken. It is not considered to be a Grievance Mechanism for workers.
Investigations made during the site visit (24-28 August, 2015) confirm that no formal employee
Grievance Mechanism exists. It was reported that (translation into English),
“CBG sometimes records complaints which emanate from its staff. These complaints are mostly
oral, covering such matters as remuneration, policies and procedures, or housing conditions.
There is not a specific database of complaints; but a register was opened for this purpose from
the year 2015.
Environmental and Social Due Diligence – Technical Report
37
CBG Bauxite Mine Expansion Project, Guinea
The complaints are recorded and action follows immediately, particularly discussions involving
explanation and awareness-raising and if necessary, an action plan is implemented with
immediate effect. This approach is identical for both the localities of Kamsar and Sangarédi”.
Subsequently, CBG clarified the situation by stating that employee grievances are managed
under 3 processes:

The trade-union agreement which provides for formal processes of communication with CBG
management;

‘Whistle-blowing’ procedure under the control of the Ethics Committee. A leaflet entitled
‘Depliant Ethique’ is provided to each employee and contractor; and

Appointed “working relation advisors” for each CBG division.
The ‘whistle-blowing’ procedure is not focused, directly, at managing employee grievances
although certain criteria and provisions could be interpreted in this manner. Despite these 3
processes, there is no single, specific and formal employee grievance mechanism in place.
7.2.2 Health and safety
In terms of health and safety of workers of contractors/suppliers a variety of document have
been provided showing evidence of care for workers’ health and safety, including

Cardinal Rules; and

Personal Safety Plan.
7.2.3 Contractors
The following document has been supplied:

Contractor Management (HS-1001), 2014. In this Procedure it is stated that,
“All temporary employees, trainees, consultants, etc. are governed by the same safety
management system as the regular employees of CBG. They are entitled to the training
required for the tasks they perform, to personal protective equipment and to adequate
supervision. They also have the same obligations as CBG employees.
All individual suppliers are subject to the same safety measures as CBG employees
(workplace inspections, monthly safety meetings, weekly meetings, tool box meetings, task
analysis and risk assessment, etc.)”
With respect to employee health and safety, it is noted that, for the year 2015 to end September,
CBG has reported the following data regarding direct employee and contractor injuries: Total
Recordable Injuries = 14 and Total Injuries = 43. There were no fatalities. CBG records key
details of every recordable incident on an Incident Register and prepares monthly Incident
Reports. The IESC recommends incidents records are compared against industry benchmarks.
7.2.4 Workers’ camps
During the construction phase, CBG will build two construction camps for workers: one in the
N’Dangara mine area to accommodate 60 workers, and another in the industrial area of Kamsar
for 600 workers. Most construction workers will be housed by CBG during the construction phase.
For the operational phase, CBG has plans to build 388 new dwellings reserved exclusively for
future mine expansion-related employees and their families, including 133 houses in the town of
Sangarédi and 275 in Kamsar, by 2017. CBG will continue to apply its social policy of providing
housing for its workers’ families.
With respect to construction workers’ camps, there is no mention of the design principles and
criteria to be applied to ensure that good international practice is being followed in terms of camp
layout and facilities, nor is there a consideration of the camp management policies and
Environmental and Social Due Diligence – Technical Report
38
CBG Bauxite Mine Expansion Project, Guinea
procedures to be applied. In this context, it would be expected that there would be reference to
using the guidance/advice contained within the following document: the IFC/EBRD (2009)
Guidance Note entitled ‘Workers’ Accommodation: Processes and Standards’.
7.3
Conclusions and recommendations to close gaps
Although many PS 2 elements are covered by the HR documentation there are some gaps. To
ensure that CBG is aligned more fully with PS 2 it should update and amend the Code of Ethics
and Business Conduct (Code d’Ethique et de Conduite des Affaires) to include:

Confirmation that its scope of application for worker-related issues covers direct, contracted
and supply chain workers;

Migrant workers (to ensure that they are engaged on substantially equivalent terms and
conditions to non-migrant workers carrying out similar work);

Status/role of the Grievance Mechanism; and

Commitment to the preparation of a Retrenchment Plan if collective dismissals of workers
cannot be avoided (as per the IFC Good Practice Note: Managing Retrenchment).
Also, CBG must prepare a Grievance Mechanism to be introduced/disseminated and implemented
throughout the Company and its contractors.
Assistance with all the above tasks can be found in SAI/IFC (2010) Measure & Improve Your
Labor Standards Performance: Performance Standard 2 Handbook for Labor and Working
Conditions.
With respect to workers’ camps, CBG should apply the IFC/EBRD (2009) Guidance Note entitled
‘Workers’ Accommodation: Processes and Standards’ to inform the design, construction and
management of all construction workers’ camps and prepare an overarching camp management
plan for both proposed camps or individual plans if there are sufficient differences between the
two camps.
Environmental and Social Due Diligence – Technical Report
39
CBG Bauxite Mine Expansion Project, Guinea
Table 4: Summary of Findings, PS2
ID
Aspect
Issue Description
Phase
Standard
008
Applicability of PS
2 to the ESIA
The applicability of PS 2 to the ESIA is
not stated. There is consideration of
some labour and working conditions
and issues in different ESIA Report
chapters, but no integrated and
consistent analysis aligned with the
topics/issues of PS 2 is presented in the
ESIA Report.
All
PS2
Subsequent to the Paris workshop,
copies of key Human Relations policies
and procedures (HR documentation)
were provided and subsequent review
showed that most key PS 2 issues are
covered/included. Some gaps were
identified and these need to be closed
by incorporation into HR documentation
going forward.
IESC Recommendations
Applicability of PS 2 needs to be clearly
stated.
Significance
Low
CBG should update and amend the
Code of Ethics and Business Conduct
(Code d’Ethique et de Conduite des
Affaires) to include:

Confirmation that its scope of
application for worker-related
issues covers direct, contracted and
supply chain workers;

Migrant workers (to ensure that
they are engaged on substantially
equivalent terms and conditions to
non-migrant workers carrying out
similar work);

Status/role of the Grievance
Mechanism; and

Commitment to prepare a
Retrenchment Plan if collective
dismissals of workers cannot be
avoided (as per the IFC Good
Practice Note: Managing
Retrenchment):
Moderate
(Negligible once
changes are made
and revised
policies/procedures
implemented)
Environmental and Social Due Diligence – Technical Report
40
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
009
Workers’
Grievance
Mechanism
It was confirmed during the site visit
that no specific employee Grievance
Mechanism (GM) exists.
Construction
workforce camps
There is no reference to guidance
document - IFC/EBRD (2009) Guidance
Note entitled ‘Workers’
Accommodation: Processes and
Standards’.
010
Phase
Standard
IESC Recommendations
CBG must prepare a Workers’
Grievance Mechanism in line with IFC
guidance to be disseminated and
implemented throughout the Company
and its contractors.
All
PS2
CBG should apply the guidance
contained in IFC/EBRD (2009)
Guidance Note entitled ‘Workers’
Accommodation: Processes and
Standards’ and include key design and
construction requirements into
contract/s to be issued to contractors
responsible for design and
construction.
CBG should prepare an overarching
camp management plan based on
guidance contained in IFC/EBRD (2009)
Guidance Note entitled ‘Workers’
Accommodation: Processes and
Standards’ (or individual plans if there
are sufficient differences between the
two camps).
Significance
Moderate
(Negligible
following
introduction of a
employees’
Grievance
Mechanism)
Moderate
(Negligible if
design/construction
of camps and a
camp management
plan incorporates
the IFC/EBRD
guidance)
Environmental and Social Due Diligence – Technical Report
41
CBG Bauxite Mine Expansion Project, Guinea
8.
PERFORMANCE STANDARD 3: RESOURCE EFFICIENCY
AND POLLUTION PREVENTION
This chapter considers to the assessment of key environmental impacts assessed in the ESIA and
the Company’s commitments to the prevention of pollution and resource efficiency. It addresses
the following key areas as they relate to the CBG’s operations and the Expansion Project:
8.1

air quality;

noise and vibration;

water and sediments;

geology, soils and seismicity;

waste management;

hazardous materials management;

landscape and visual impacts; and

greenhouse gas emissions.
Air quality
8.1.1 Project standards
The assessment has used the WHO ambient air quality guidelines in the absence of national
standards which are consistent with the IFC guidelines. The assessment states that “the WHO
guidelines recognize the need for a staged approach to achieving the recommended guidelines
(below which health impacts would not be expected) and consequently allow for interim targets”.
The Project ESIA uses interim target levels for some pollutants, including PM10, PM2.5 and SO2,
instead of the guideline concentrations.
The assessment considers that the most lenient Interim Target 1 is applicable for the assessment
as the air quality environment in Kamsar and Sangarédi is already burdened by current bauxite
mining and processing activities and other activities undertaken by the local population. It is
agreed that the monitoring data suggests that the existing air quality is burdened by local
sources of PM10, and therefore for PM10 the use of the Interim Target 1 is appropriate. However,
the monitoring results for SO2 suggest that existing concentrations are low and therefore it is
considered that the Guideline concentration would be a more appropriate standard for the
assessment.
8.1.2 Baseline data
The assessment relies on a combination of monitoring and modelling data to establish baseline
pollutant concentrations.
Monitoring data was used for the assessment was very limited. Particulate concentrations were
determined based on samples collected over 24-hour sampling periods whilst gaseous pollutants
were determined through monthly sampling periods. There was no monitoring of dust
deposition. The ESIA Authors have indicated that the collection of monitoring data was limited
due to security concerns as well as accessibility issues to the more remote sites. Later in the
season field staff could no longer carry out sampling due to the Ebola virus.
In Kamsar monitoring was carried out for particulates at four locations for a maximum of 12
days. Gaseous pollutants were monitored for 4 months at one location.
At Sangarédi particulate monitoring was carried out at 4 locations for a maximum of 6 days and
gaseous pollutants at 2 locations for 2 months. The monitoring was carried out in the dry season
Environmental and Social Due Diligence – Technical Report
42
CBG Bauxite Mine Expansion Project, Guinea
between February and May. Particulate concentrations can vary significantly from day to day
depending on the weather and local and regional activity. Good practice normally suggests that
baseline concentrations for all pollutants including dust should be carried out for a minimum of 3
months.
Although the location of the monitoring sites is shown on a plan, there is no textual description of
the monitoring sites to determine whether they are potentially influenced by other sources such
as local roads or to what extent they may be being influenced by current mining activity.
Additional information has subsequently been provided in the SIP in relation to the monitoring
sites by the ESIA Authors.
Because of the lack of baseline monitoring data, the baseline assessment was augmented with
baseline modelling using the Calpuff model.
For Kamsar, it is understood that the baseline modelling included the existing operations carried
out by CBG, but no other existing sources of pollutants such as local traffic, other industrial
sources or domestic heating were modelled. Some comparison of the monitored to modelled
concentrations has been carried out to validate the modelling, whilst this shows good agreement
for short term particulate concentrations at the two monitoring sites used in 2014, the agreement
is poor with the data collected in the 2011 survey, with the modelled concentrations much lower
than the monitored concentrations. As such it is considered that there may be other significant
sources of background pollutants which have not been included in the baseline.
The ESIA Authors acknowledged that additional sources of local pollutants are also likely to be
contributing to the baseline total in Kamsar, but these have not been included within the
modelling as distinct sources as there was insufficient baseline monitoring data available to
determine likely background contributions. The ESIA Authors indicated that when estimating the
likely emissions arising from the facility a number of conservative assumptions were made and
therefore the predicted resulting ground level concentrations are likely to be a worst case and as
such would represent both emissions from the facility and from local background sources. This
was verified through a comparison between the modelled and monitored data collected for the
ESIA which showed a good agreement, although agreement with data recorded in 2011 was less
good.
At Sangarédi, a similar approach was taken in that no consideration of background
concentrations was provided in the modelling. Again the ESIA Authors consider that given the
worst case assumptions included within the calculation of the emissions, the predicted
concentrations when carried out close to a village receptor would include both the contribution
from the mine and the local background.
A comparison of the monitored and modelled data for PM10 at Sangarédi is provided in Table 5,
demonstrating the disparity between the data.
Table 5:
Comparison of monitored to modelled PM10 Concentrations µg/m3
Monitored Existing Concentrations
Modelled Baseline
Concentrations
No of Sample Days
Average Daily
Concentration
Annual Average
Concentration
AQ-10 Kourawel
5
124.5
1.0
AQ-11 Hamdallay
6
95.7
8.1
AQ-12 Petoun BW
6
111.0
2.9
AQ-13 Paravi
5
80.7
0.8
Environmental and Social Due Diligence – Technical Report
43
CBG Bauxite Mine Expansion Project, Guinea
It is understood that additional baseline air quality data is to be collected and an air quality
monitoring strategy has been submitted providing details of the permanent automatic monitoring
station to be installed in Kamsar and the additional short term monitoring that is proposed at
additional locations in both Kamsar and Sangarédi. The ESIA Authors recommend the purchase of
additional monitoring equipment to supplement that already owned by CBG.
The mitigation plan
included in the ESMP indicates that the results of this monitoring would be used to further
validate the modelling carried out for the ESIA. It is recommended that the monitoring at
Sangarédi is carried out close to the existing operations. On the assumption that this monitoring
is carried out as indicated, and the modelling updated accordingly this would provide greater
assurance of the predicted future concentrations.
As part of the air quality monitoring survey local meteorological data will also be collected in both
Kamsar and Sangarédi. It is recommended that this data is used to validate the Weather
Research Forecast Non-hydrostatic Mesoscale Model meteorological data which was used in the
Calpuff model to predict future air quality concentrations. This would provide further assurance
of the predicted concentrations.
8.1.3 Assessment methodology
Emissions have been calculated using the US EPA AP42 database of emission factors and these
have been modelled using the Calpuff air dispersion model. These methods are considered
appropriate for assessing impacts from mining operations.
For both locations, and each of the expansion phases (18.5, 22.5 and 27.5Mtpa) concentrations
have been predicted over a receptor grid and at discrete receptors. At Kamsar, only two discrete
receptors have been modelled, the two locations where baseline measurements were obtained.
At Sangarédi concentrations were predicted at a large number of individual villages.
Detailed information on the location of the mine roads was identified as a potential limitation to
the study. Given that haul roads are identified as a significant source of particulates this could
have a significant impact on the assessment.
The waste management information provided within the SIP indicates that CBG may operate a
number of small scale waste incinerators close to Kamsar. It is understood that these units will
operate to French emission standards, as such the potential for significant emissions to air is
considered low.
The predicted ground level concentrations from the blasting operations within the disclosed ESIA
were uncharacteristically high and significantly above the guideline values at a number of
receptor locations. There was only limited data within the ESIA regarding the assumptions and
modelling methodology for this scenario. As a result of these concerns the ESIA Authors have
revisited and revised the assessment of impacts arising from blasting. This has indicated that a
set back distance of 370 m should be imposed between the villages and nearest working area to
ensure compliance with the one hour NO2 target criteria.
Within the ESIA there is limited consideration given to the likely impacts from air quality on
ecological receptors either through gaseous emissions or through the potential to impact
eutrophication or acidification and this is presented in Chapter 4 rather than in the air quality
section. Additionally, within the ESIA the impact from dust deposition was only quantified for
water features, whereas there is the potential that dust deposition could also impact vegetation.
Consideration of dust deposition on ecological receptors has more recently been presented within
the SIP (see also Chapter 11, PS6) and indicates that at Kamsar dust deposition is likely to
reduce as a result of the CBG proposed improved dust mitigation measures associated with the
Expansion Project. At Sangarédi the effects would increase as the production rate increases and
are predicted to result in an adverse effect on 11.3 hectares of ground (excluding bare ground
Environmental and Social Due Diligence – Technical Report
44
CBG Bauxite Mine Expansion Project, Guinea
and built up area) for the 22.5 Mtpa scenario, increasing to 84.3 hectares for the 27.5 Mtpa
scenario, although it should be noted that these figures include the area to be cleared for mining.
A further commitment to assess potential impacts on ecology as a result of dust deposition and
air quality is provided within the BAF, indicating this issue will be included within the BAP and
would include suitable mitigation measures.
No methodology was presented for determining the significance of impacts within the ESIA air
quality chapter although this is presented elsewhere in the ESIA – there is simply a commentary
on whether the air quality target criteria are met or exceeded and whether the proposals increase
or decrease emissions. The significance of the predicted increases or decreases is not quantified
within the air quality chapter, although again this is presented elsewhere in the ESIA, although
there is no cross referencing to refer the reader to this section. As a result from the air quality
chapter it is difficult to determine the significance of the predicted effects.
8.1.4 Summary of impacts
Kamsar
Particulate concentrations are predicted to decrease in Kamsar due to the introduction of better
control measures as part of the Expansion Project. However gaseous emissions are predicted to
increase substantially over time with an increase in concentrations of over 100% compared to the
existing situation for the final operating scenario (27.5Mtpa). This is due to the increase in the
use of heavy fuel oil and diesel for power generation. There are some predicted exceedences of
the Interim Target 1 concentrations at the two receptor locations for both PM10 and PM2.5 for the
future scenarios, although these exceedances are lower than the existing situation. As detailed in
Section 8.1.1 it is considered that the Interim Target 1 criteria are appropriate for the
assessment. Similarly there are exceedances of the gaseous objectives but the number of
exceedences increase as a result of the expansion plans. The ESIA concludes that the Expansion
Project would have a medium positive impact on particulate concentrations but a high adverse
impact on SO2 and NO2 concentrations.
Sangarédi
The Expansion Project will result in a substantial increase in both particulate and gaseous
concentrations at villages close to the mining activities. Where baseline concentrations were very
low, the proposed mining operations are predicted to increase concentrations by several orders of
magnitude. There are some exceedances of the annual PM10 Guideline criteria and some
exceedance of the most lenient Interim Target criteria (18.5Mtpa phase). In relation to PM2.5
there is some exceedance of the Guideline criteria, particularly for the 22.5 and 27.5Mtpa phases,
but no exceedance of the Interim Target 1 criteria. There is no exceedance of the annual NO2
Guideline criteria. The assessment has identified that the exceedences of the PM10 and PM2.5
annual criteria is largely as a result of emissions from unpaved haul roads.
The blasting
operations have the potential to result in exceedance of the short term one hour NO2 Guideline if
the recommended set back distances are not adhered to.
The assessment concludes that the expansion plans would have a high adverse impact on
particulate and gaseous pollutants as a result of emissions arising in the mining area.
Rail Siding
A generic model setup was used to assess impacts from the two rail sidings. A discussion of the
results is provided although the modelling results are not set out in either the ESIA chapter or
appendices or the subsequent SIP. At PK14 the operation of the rail siding may result of
exceedance of the 1 hour NO2 objective within a distance of 625 m of the siding. This distance
may be less at the siding PK 118 where there are likely to be cumulative impacts from both
Environmental and Social Due Diligence – Technical Report
45
CBG Bauxite Mine Expansion Project, Guinea
mining and locomotive activities. The assessment concludes that the expansion plans would
have a medium adverse impact on both particulate and gaseous emissions at the railway sidings.
8.1.5 Mitigation measures – Air Quality Chapter
The modelling assessment has been carried out assuming a number of inbuilt mitigation
measures will be achieved, for example ‘water spraying of haul roads will ensure 80% dust
control’. No information is provided on how this will be achieved i.e. what measures will be in
place to ensure the target is met/triggers that will activate dust suppression measures. The
mitigation suggests some additional measures that could be considered to further reduce
emissions but these are not presented as firm commitments. Given that unpaved haul routes are
identified as a one of the major sources of PM10 and PM2.5 it is considered that a firm commitment
to additional mitigation of impacts from these sources when they arise close to villages should be
provided. As such it is considered that this section is minimal and non-committal given the
extent of the proposed expansion.
The modelling has been used to determine a number of setback distances for the villages which
should be implemented to mitigate short term air quality impacts and to ensure compliance with
the relevant WHO Guideline or Interim Targets, however these do not appear to have been
brought forward into the mitigation section of the air quality chapter or the ESMP. Additionally
many of the measures included in the air quality chapter are included as targets or aspirations
rather than defined commitments.
8.1.6 Mitigation measures – ESMP
The ESMP (SIP version) contains a number of commitments and measures which are inconsistent
with the air quality assessment. For example, the ESMP states “during the detailed engineering
and construction phases, engineering controls for atmospheric emissions as identified in the
deliverables from the feasibility study will be developed and implemented in order to meet the
first intermediate targets or IFC guidelines” and “the new electrical generators will meet IFC
criteria and will be built and operated so as not to increase gas and particle emissions to levels
exceeding the first intermediate targets of IFC guidelines”. The air quality assessment clearly
demonstrates this will not to be the case.
Additionally, the ESMP states that “CBG will lower contract specifications by 20% regarding
bunker C sulphur content”. The IESC has been informed that recent deliveries of fuel have had a
sulphur content of 1.4%, compared to 3% previously. CBG plans to formalise contracts to recieve fuel with 1.4% sulphur content going forward. The ESMP states that “if moderate or severe impacts are anticipated or occur during construction
or operation CBG will study the application of additional control measures”. However there is no
definition of what is a moderate or severe impact and therefore there is uncertainty as to when
the suggested additional control measures may be implemented. The suggested additional
control measures include the following:

increasing the use of water-spray dust control;

increasing maintenance and cleaning around dust-producing areas;

enclosing emissions sources; and

use of a fuel with lower sulphur content.
Such measures and remedial actions should be implemented through a dust or air quality
management plan, which would set trigger levels to identify moderate or severe event, identify
the actions that should be undertaken should an event occur and what actions should be taken to
prevent a reoccurrence.
Environmental and Social Due Diligence – Technical Report
46
CBG Bauxite Mine Expansion Project, Guinea
The ESMP includes a setback distance of 100 m for exploration and operational structures and a
target distance of 1 km for mine roads from villages. These are inconsistent with the distances
proposed within the air quality chapter of the ESIA.
8.1.7 Post mitigation impacts
There is no consideration of post mitigation impacts – generic mitigation has been taken into
account within the prediction of emissions, but there is no consideration of the likely effects
which would arise if the suggested set back distances were implemented or if the sulphur content
of the bunker fuel was reduced. As a result the residual impacts remain unchanged from that
predicted by the impact assessment. In addition, a number of further mitigation options are
suggested within the ESMP which are to be assessed as part of the feasibility study, for example
the use of higher capacity road trains, the use of conveyors to transport bauxite in sensitive area.
It is recommended that further assessment is provided to assess the effectiveness of these
additional mitigation measures and whether the reduction in emissions or distances proposed
would be sufficient to ensure air quality standards will be met. This could be combined with the
additional assessment to be carried out once additional baseline monitoring data has been
collected.
8.1.8 Monitoring
There is reference in the ESIA to an ambient air quality monitoring plan at both Kamsar and
Sangarédi. At Kamsar it is understood that CBG is in the process of constructing a suitable
building to house the ambient air quality monitoring equipment and this station should be up and
running in the near future. The ESIA indicates that data collected by this station would be used
to confirm existing conditions. Whilst this monitoring would give a good indication of
concentrations at this location, if monitoring is carried out at only one location it will be difficult
to determine what is arising from the existing CBG operation and what is from background
sources. It is therefore advised that the monitoring is augmented with a number of short term
studies carried out a various locations within the Kamsar region. Information on the proposed
monitoring programme has been provided within the SIP and indicates that background
monitoring would be carried out at Kamsar airport.
There is no consideration of emissions monitoring from the plant contained in the processing
facility. IFC guidance suggests that annual stack emissions testing is carried out for small
combustion plant. Consideration should also be given to the use of continuous particulate, or
opacity monitoring on the dryer stacks.
At Sangarédi CBG propose to use mobile air quality samplers to monitor ambient air quality
concentrations both prior and during mining operations. This is considered an appropriate
methodology to verify the modelling assessment and to ensure the adequacy of mitigation
measures. The monitoring can also be used to enhance the dust management procedures, in the
event there are recurrent problems.
Environmental and Social Due Diligence – Technical Report
47
CBG Bauxite Mine Expansion Project, Guinea
Table 6: Summary of Findings, PS3 (air)
ID
Aspect
Issue Description
Phase
Standard
LESC Recommendations
011
Air Quality – Air
Quality Standards
The air quality assessment considered that
the existing airshed at both Kamsar and
Sangarédi was already burdened through
the existing CBG operations and other
local sources of pollutants and therefore
the assessment has used the most lenient
WHO guideline values for particulates and
SO2. Whilst this is considered appropriate
for particulates further justification is
required for SO2.
All
WHO
CBG has committed to carrying out
further monitoring of baseline air
quality in the vicinity of both Kamsar
and Sangarédi to characterise the
existing air quality and to provide
robust justification for the choice of air
quality standards.
Air Quality _
Baseline
Characterisation
Within the current ESIA there is
insufficient data on existing background
concentrations of pollutants. As a result
the ESIA Authors have relied on air
dispersion modelling to characterise the
existing situation. However there is
inconsistencies between the monitored and
modelled baseline and it is considered that
there is insufficient monitoring data to
verify the baseline modelling.
All
Air Quality –
Assessment
Methodology
The predicted existing and future scenarios
presented in the disclosed ESIA do not
include the background pollutant sources,
such as traffic, domestic fuel burning and
natural concentrations of pollutants. The
modelling has only assessed the
contribution from CBG’s activities. As a
result there is the potential that all the
predicted concentrations are under
predicted and the number of exceedances
may be much greater. Additional
information has been provided within the
SIP regarding the modelling methodology
Operation
012
013
WHO
WHO
CBG is committed to carrying out
additional monitoring of existing air
quality. It is recommended that the
results of this monitoring is used to
verify the baseline modelling and to
source apportion the existing pollutant
concentrations between that arising
from the existing CBG operations and
that from other sources.
It is recommended that the modelling
is revisited once the additional baseline
monitoring has been carried to provide
further assurance of the accuracy of
the predicted impacts.
Significance
Moderate
(potentially
reducing to
negligible
once additional
data is
supplied)
Moderate
(potentially
reducing to
negligible
once additional
data is
supplied)
Moderate
(potentially
reducing to
low/negligible
once additional
air quality
assessment is
revisited)
Environmental and Social Due Diligence – Technical Report
48
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
LESC Recommendations
Within the Air Quality chapter of the ESIA
no consideration has been given of impacts
on ecological receptors, through direct
gaseous emissions, acidification or
eutrophication or from dust deposition.
Consideration of potential impacts from
dust deposition on ecological receptors has
subsequently been included within the
BAP, but no additional information has
been provided on acidification or
eutrophication as a result of emissions of
NOx and SOx.
All
PS6
It is recommended that an assessment
of potential impacts from gaseous
emissions of pollutants is carried out
for sensitive ecological receptors.
Predicted concentrations, as presented in
the disclosed ESIA, resulting from blasting
are extremely high. Limited information is
provided in the assessment on what
assumptions were made to model these
emissions.
Operation
Significance
with regard to background concentrations.
The conservative nature of the emissions
projections is such that the ESIA Authors
consider that the predicted concentrations
would include both the contribution from
the CBG operations and the background
sources.
014
015
Air Quality –
Assessment
Methodology
Air Quality –
Assessment of
Blasting Impacts
This area of the assessment has now been
revised by the ESIA Authors and a new
assessment provided in the SIP which has
reduced the recommended set back
distance necessary to ensure the one hour
NO2 Guideline is not exceeded at nearby
villages. However, this set back distance
has not been captured within the ESMP.
It is further understood that this work
will be captured within the scope of the
BAP – see also 049.
WHO
The ESMP should be revised to include
the predicted set-back distance for
blasting operations to ensure
compliance with the one hour NO2
Guideline.
Low
(potentially
reducing to
negligible
once additional
data is
supplied)
Moderate
(potentially
reducing to low
or negligible
on the
assumption that
appropriate set
back distances
are captured in
ESMP)
Environmental and Social Due Diligence – Technical Report
49
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
LESC Recommendations
016
Air Quality Mitigation
There are inconsistencies between the
mitigation suggested within the air quality
assessment and that included within the
ESMP. Furthermore measures are
presented as targets and aspirations rather
than firm commitments. The effect of
these mitigation measures have not been
assessed when predicting the residual
effects.
Operation
IFC
The air quality assessment and the
ESMP should be reviewed to provide
one clear set of mitigation measures to
adequately control emissions of air
pollutants.
Air Quality
Mitigation - dust
There is currently no over-arching air
quality and dust management plan
included within the ESMP.
All
017
PS1
The ESMP should include the provision
of a number of air quality and dust
management plans for both the
construction and operational phases.
Separate plans would need to be
produced for Kamsar and Sangarédi.
The plans would include details of the
following:

Air quality monitoring;

Routine mitigation measures to
prevent/reduce emissions (for
example operating procedures to
ensure correct operation of bag
filters at Kamsar, frequency of
damping down haul routes at
Sangarédi, separation distances to
be adhered to);

Action to be taken in the event of a
high pollution episode or
complaints being received; and
Significance
Moderate
(potentially
reducing to low
or negligible
on the
assumption that
consistent and
appropriate
mitigation
measures are
captured in
ESMP)
Moderate
(potentially
reducing to
negligible on
the assumption
that suitable
plans are
produced)
Environmental and Social Due Diligence – Technical Report
50
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
LESC Recommendations

Significance
Procedure to review and update the
plans as required.
018
019
Air Quality
Mitigation –
ecological
receptors
Mitigation proposals have not been put
forward to protect sensitive ecological
receptors for effects relating to dust
deposition or other air pollutants.
All
Air Quality
Predicted Effects
The assessment concludes that the
Expansion Project would result in a high
adverse impact on particulate and gaseous
air pollutants as a result of the mining
operations at Sangarédi.
Operation
At Kamsar the expansion of the port and
plant operations would result in medium
positive effect on particulate emissions but
a high adverse effect on gaseous
pollutants.
The operation of the rail siding would
result in a medium adverse effect on air
pollutants.
PS3, PS6
WHO
The ESMP should include appropriate
measures to adequately mitigate the
effects of dust deposition at
ecologically sensitive receptors.
Consideration should be given to
additional mitigation measures
including the implementation of
setback distances and the use of
cleaner fuels. The efficacy of these
measures should be assessed to
determine whether exceedance of the
air quality standards would still arise.
Moderate
(potentially
reducing to
negligible on
the assumption
that suitable
mitigation
measures are
put in place and
detailed within
the ESMP)
High
(potentially
reducing to
moderate/low
on the
assumption that
suitable
mitigation
measures are
effectively
implemented)
Environmental and Social Due Diligence – Technical Report
51
CBG Bauxite Mine Expansion Project, Guinea
8.2
Noise and Vibration
8.2.1 Project standards
As Guinea has no community noise or vibration criteria, the ESIA adopts the threshold limits and
recommendations from IFC guidance (General and Mining EHS Guidelines, IFC, 2007) were used
for noise and the Australian and New-Zealand Environmental Council for vibration (ANZEC,
1990).
8.2.2 Baseline data
The noise background data were collected by CBG under the technical guidance of EEM in
September 2014. A total of 20 locations were monitored for 48 hours: 5 near the Kamsar plant
and 15 at the Sangarédi mining area. The existing background noise along the railway was
modelled.
The noise levels at the sensitive receptors (four) near the existing Kamsar site were found to be
already exceeding the IFC thresholds for day time (two) and night time (four) in part due to the
current plant operations.
The noise levels used for the assessment are daily average levels rather than a representative
level for a quiet period. The latter is better suited as a measure of the baseline noise climate
when assessing the potential for adverse impacts.
8.2.3 Assessment methodology
Noise modelling (using Cadna-A) was performed for the Kamsar site, the Sangarédi mine and the
railway.
The magnitude of the noise impact was mainly compared to the noise level increase due the
proposed expansion and compared to the IFC guideline (3 dB(A) increase) as follows: < 3dB(A)
(no or negligible magnitude), 3-5 dB(A) (low magnitude), 5-10 dB(A) (moderate magnitude), >
10 dB(A) (high magnitude). Ramboll Environ would question the ‘low magnitude’ categorisation
for a 3–5 dB(A) increase, because such an increase exceeds the IFC limit and yet does not trigger
consideration of mitigation measures.
The ESIA places emphasis on the IFC noise limit of 3dB(A) increase above background. The
wording of the IFC guidelines for plant noise impacts is “Noise impacts should… result in a
maximum increase in background levels of 3 dB at the nearest receptor location off-site.”
The impact assessment compares current and future noise levels, by adding the “non-plant
background” noise level (i.e. the underlying noise level, excluding current plant noise) to the
specific noise from the plant in both existing and proposed scenarios. The existing plant causes
an increase in background level of up to +9 dB. For the Financed Project, the future plant is
predicted to cause an increase in background level of up to +10 dB. However, the assessment
presents a ‘change in impact’ of up to +1 dB, which is not significant. In reality the combined
impact from CBG current and expansion related operations is an increase in the non-plant
background level of up to +10 dB, which is significant.
8.2.4 Summary of impacts
Kamsar
The predictive modelling indicates that all four of the nearest sensitive receptors would
experience a noise level (max 55 dB(A)) that exceed the IFC night time limit of 45 dB(A)
following the proposed increase to 18.5Mtpa, although these levels are not significantly higher
Environmental and Social Due Diligence – Technical Report
52
CBG Bauxite Mine Expansion Project, Guinea
than those currently experienced, with a predicted incremental increase of 1dB(A) for the Project
(and up to 3dB(A) for the full Expansion Project).
Whereas it is acknowledged that background noise levels are already elevated, this is in part due
to current CBG activities and as such it is Ramboll Environ’s opinion that mitigation measures
should be considered for any incremental increase, where noise levels are predicted to exceed
the IFC night and day time limits in residential areas of 45dB(A) and 55dB(A) respectively.
The construction of the new quay at Kamsar also has the potential to generate significant
airborne and underwater noise impacts with the potential to affect human receptors and fauna in
the marine environment (see below).
Sangarédi
At the Sangarédi mine, prior to mitigation and depending on the number of simultaneous working
areas, 40 to 50% of the 102 villages are predicted in the ESIA to experience noise levels above
the IFC daytime limit and 60 to 85% above the night time limit as well as a noise increase of
over 3 dB(A). When considering a moderate noise impact magnitude (5 to 10 dB(A) increase),
these figures drop to 30 to 45 % of the villages impacted during day and night times.
In the absence of Project data, only standard impact curve for blasting vibrations and airblast
overpressure were estimated for the mine using internationally recognized reference values and
equations. The impact was ranked as high.
Railway
The predicted noise level increases along the railway were all below the IFC thresholds (3 dB(A)
increase). The impact magnitude was ranked negligible and the overall significance as moderate.
Workers’ accommodation
Performance Standard 2: Labor and Working Conditions requires the Company to consider
adequate protection from noise at the workers’ accommodation (where provided). It is
understood that current accommodation facilities are located in Sangaredi and therefore sufficient
distance from the active mining areas to be unaffected by noise.
Underwater noise
The ESIA recognise that noise impacts will result from the underwater noise produced by
construction activities and further highlights that construction of the quay extension will occur in
an area of critical habitat (a conclusion supported by an independently prepared Critical habitat
Assessment – see Chapter 11), however the ESIA does not adequately assess the impacts from
underwater noise sources. This is considered by Ramboll Environ to be a significant omission
given the level and duration of noise anticipated from the piling activity required for the quay.
Underwater noise level limits are proposed by reference to a research paper from 2007 and
potential mitigation measures are identified.
During the Paris workshop meetings, the need for a detailed study on underwater noise was
discussed and recommended to CBG because of significant impacts to marine species that can
occur.
CBG has committed to studying the effects of the Project on underwater noise levels in the Port
of Kamsar within the context of its Biodiversity Action Plan (Chapter 11). These additional
studies, scheduled for October and November 2015, will be include as part of the BAP scope and
include the assessment of noise from quay construction and dredging operations.
Environmental and Social Due Diligence – Technical Report
53
CBG Bauxite Mine Expansion Project, Guinea
Biodiversity
Mitigation measures are proposed to reduce the noise impact upon the biodiversity. These
include extraction of bauxite in areas that are furthest away from sensitive habitats thereby
allowing a progressive increase in noise and a noise reduction because ore extraction will take
place below grade. CBG has also committed to undertake more specific noise impact
assessments for key species such as chimpanzees. The impact of noise on biodiversity is
discussed in more detail in Chapter 11, Biodiversity (PS6).
Blasting
The mining operation will involve the use of explosives and blasting which will result in air
overpressure. Assessment and management of blasting noise has been undertaken by the
definition of setback distances based on a detonation charge amount at which the noise level
limit would be met. Generally, such an approach is reasonable, however, there remains a certain
level of prediction uncertainty associated with the sole use of distance and charge size to
determine noise propagation because noise from blasting is also dependent on factors other than
distance, such as maximum instantaneous charge, direction of blast, burial depth of explosives,
wind speed and direction, atmospheric pressure and the height of clouds. Therefore, reliance on
detonation charge alone cannot be used to ensure that the quoted levels will be met. The
uncertainties associated with the use of standard (non-site specific) blast propagation curves is
recognised in the ESIA which makes the recommendation that blast monitoring be conducted
such that site specific propagation equations can be developed for use in blast design for the
Extension Project.
The impacts to biodiversity from blasting are further discussed in Chapter 11.
8.2.5 Mitigation measures
No mitigation measures have been considered for the impact at Kamsar and along the railway.
At Sangarédi, amongst other mitigation measures, those mining areas generating a noise
increase in excess of 5dB(A) at the nearby villages will not be mined unless site specific noise
reduction measures are implemented, including minimum set back distances and the use of the
surface mining technique, if feasible.
Regarding vibration, the standard impact curves will be used to select the appropriate explosive
charge depending on the distance to the receptors.
Noise reduction is also proposed in the form of vegetation shields. It is recognised in the ESIA
that the screening effects by such vegetation is minimal, although it does have the potential to
mask (conceal) the Project’s noise by increasing the general background noise level. In
Ramboll Environ’s opinion vegetation cannot be considered an effective mitigation measure
because:
-
It only provides masking under high wind speeds;
-
It cannot be easily introduced as a new feature;
8.2.6 Monitoring
A noise monitoring programme similar to the baseline monitoring will be implemented at Kamsar
and Sangarédi for each expansion phase and used to validate the predicted data. A noise and
vibration monitoring programme is also recommended in the ESIA for blasting activities to
confirm the standard impact curves although no further detail is provided.
Environmental and Social Due Diligence – Technical Report
54
CBG Bauxite Mine Expansion Project, Guinea
8.3
Water and Sediments
8.3.1 Project standards
CBG has developed a Water Management Framework, dated 5th October 2015, which commits
CBG to effectively managing water resources during every phase of the Project development, and
is consistent with IFC Performance Standard 3 (PS3). As part of this approach, CBG will develop a
Water Management Plan (WMP) in line with the Rio Tinto HSE Standard E101 (Standard E10)
which will describe the operating philosophy and water management strategy for the CBG
operations. The WMP will be current for four years from January 2016 and will be reviewed and,
if necessary, amended on an annual basis under a management of change system dependent
upon the findings of the various planned studies and monitoring. The WMP will include review and
amendment of Appendix 6.2 (Surface Water and Sediment Monitoring Program) and Appendix
6.4 (Well Network and Monitoring Program) of the Supplementary Information Package (SIP).
Once complete, the WMP will become part of the evolving ESMP. The WMP should include
assessment and monitoring of water levels in surface water and groundwater as a consequence
of the increased abstractions expected as a consequence of the Expansion Project at Batafong
(for the supply of Kamsar) and on the Cogon River (for supply to the mine).
Under the WMP, CBG will prepare water balances for the Kamsar area and Sangarédi mining
area. CBG will also develop a groundwater model to validate the long-term effect on groundwater
for environmentally sensitive areas and local communities. The results will be used to identify
local communities’ water usage and sensitive habitats and species at risk as a consequence of the
mining operations and to ensure sufficient monitoring in these areas is undertaken, filling key
gaps which may be identified in the initial monitoring network. The data obtained will be used to
develop a CBG Water Management Strategy which will establish the Company’s approach to
water management, conservation and protection.
The Water Management Plan will also be guided by existing Guinean regulations relating to the
protection of water (Code de l’environnement (Ordonnance N° 045/PRG/87) of 1987 and the
Code de l’eau (Loi n° L/94/ 005/CTRN) of 1994, IFC Performance Standards (including PS3) and
General and Mining EHS Guidelines (2007), and the Mining Code of Guinea (particularly Chapter
VII).
For review of water quality data provided by CBG, the above regulations, standards and
guidelines have been adopted, as wells as other international reference values and guidelines
such as the criteria for water quality and sediment published by the World Health Organization
(WHO), the US Environmental Protection Agency (US EPA), Canada and / or member states of
the European Union (EU) given that Guinea has only general water management guidelines and
no water quality criteria.
CBG has established set chemical suites for laboratory analysis of potable water samples from
water treatment plants which source water from two surface water abstraction points (Batafong
and Cogon Sangarédi) and a groundwater well abstraction (Songolon). Samples are also obtained
from four other groundwater wells directly which do not undergo treatment. Samples of potable
water are also obtained for analysis at key points from the subsequent distribution network. The
samples are obtained twice per month but the analytical suite is relatively limited and could be
improved upon with reference to IFC guidance and WHO potable water guidelines.
CBG also obtains samples of wastewater effluent discharged from the treatment stations at
Kamsar and Sangarédi. The analysis suite for these discharges is limit, and should include
additional analytes to better characterise potential impacts to the receiving water bodies.
Additional parameters would include metals, petroleum hydrocarbons, nitrate, ammonium,
phosphate, sulphate, chloride, etc.
Environmental and Social Due Diligence – Technical Report
55
CBG Bauxite Mine Expansion Project, Guinea
8.3.2 Baseline data
Additional water and sediment baseline data were collected in April and June 2014 from 10
surface water and sediment sampling stations around the Kamsar port, as well as from 12
surface water and sediment sampling points and 2 local wells (the latter not tested for
hydrocarbons and explosive residues) at the Sangarédi mine.
The aluminium concentrations in surface water and sediment were found to increase downstream
of the Kamsar port and the arsenic and chromium concentrations in all sediment samples were
found above international reference values. Also based on the previous baseline data (AECOM,
2011), wastewaters (four samples) from the Kamsar site were found in concentrations exceeding
international discharge values.
In the Sangarédi area, several surface water and sediment sample concentrations exceeded the
international reference values for metals including aluminium but without a clear association with
the mining activities. Groundwater quality results showed some minor anomalies in iron,
coliforms, sodium, chlorine and aluminium at the Kamsar site as well as in iron and manganese
at the Sangarédi site.
For Sangarédi, no conceptual site model has yet been provided which gives an interpretation of
the hydrology and hydrogeology and the interaction between the various water bodies, and with
regards to this model, and no rationale for the surface water and groundwater monitoring
sampling plans has been provided to justify the sampling locations, targeted water body,
laboratory analytical suite is provided. It is understood that these will be included in the WMP to
be prepared and issued by January 2016.
It is understood that the mine areas of the bauxite plateaux are designed such that the base of
the mined pits are above the level of the water table and so that all storm water run-off is
collected within the mine pit in settlement / infiltration basins, i.e. no run-off being directed offsite and with no off-site discharge of the run-off water collected in the settlement / infiltration
basins. Similarly, it is understood that the bauxite plateaux are underlain by clayey sediments,
with natural springs occurring on the valley sides at the contact horizon between the bauxite and
the clayey sediments. Water from these springs is assumed to flow down-slope and into the
rivers in the valley bottoms. Given the proximity of these springs to mining operations, they may
be susceptible to impacts. The water monitoring plan for the concession to be developed in the
WMP should therefore include identification of and monitoring of such springs, particularly where
they may occur in close proximity to mining areas or the waste disposal facility at Sangarédi.
The valley bottoms are reported to be underlain by alluvial deposits which form shallow aquifers.
These aquifers are understood to provide baseflow input to the rivers and are also exploited by
village wells for supply of water for human consumption and use. It is understood that a deeper
aquifer exists in fractured bedrock beneath the valley bottom alluvial aquifers, but whether the
two aquifers are in hydraulic contact is not known. It is unclear whether the bedrock aquifer is
exploited for use. Information on which specific aquifers the groundwater monitoring programme
will target will be included in the WMP to be developed (an initial network of some 40
groundwater investigation wells is planned to be installed by CBG in Q4 2015 as a preliminary
phase of evaluation of the groundwater resource). CBG will need to demonstrate a clear rationale
for the selection of monitoring well locations and the geology in which they are screened, and
justify whether or not there is value in including deep wells in the bedrock aquifer. It is
understood that some of the initial 40 wells mentioned above are being installed at selected
locations in the perched aquifer at the base of the bauxite plateaux deposits and in the river
bottom alluvial deposits. An outline methodology developed by Arcadis has been reviewed by
Ramboll Environ which suggest that nested wells are to be installed in the bauxite plateaux
deposits (perched aquifer) and also in the groundwater body in the underlying clayey deposits.
Environmental and Social Due Diligence – Technical Report
56
CBG Bauxite Mine Expansion Project, Guinea
Given the challenges in achieving adequate seals between discrete groundwater bodies, nested
wells should be avoided, and separate wells in separate boreholes installed instead.
8.3.3 Assessment methodology
The ESIA reports that groundwater is used for drinking and agricultural purposes locally and that
the mining activities to date are reportedly not impacting the aquifers. The only source of
potential impacts on surface water and sediment at the Kamsar and Sangarédi sites, however,
that was evaluated in the ESIA was that of deposition of air emissions (dust, SO2 and NO2), which
was modelled and presented in the air quality section of the ESIA. The impacts resulting from
storm water run-off across disturbed ground and stockpiled bauxite ore were not included, nor
were impacts to spring water quality emerging from the plateaux areas around the Sangarédi
mining zone evaluated. There is currently a lack of hydrological and hydrogeological data which
limits the ability of the ESIA to quantify of the likely location and significance of potential
impacts. The assessment of impacts on groundwater by the ESIA was only performed in a
qualitative manner for the Kamsar site, with no assessment conducted for the Sangarédi site and
general concession area due to the insufficient baseline and monitoring data available.
Subsequent to the issue of the ESIA, CBG has commissioned the above mentioned installation of
some 40 groundwater wells as part of an initial phase of assessment of the groundwater resource
and quality, with the intent that these wells may subsequently form part of an evolving
groundwater and surface water monitoring network.
The impacts of sanitary wastewater from all the sites and workers’ camps are not presented in
the document, nor potential impacts on groundwater quality from on-site waste storage facilities
(an un-engineered landfill in the case of the Sangarédi site) and a temporary waste storage at
the Kamsar facility.
8.3.4 Impact assessment
At the Kamsar site, the ESIA concluded there would not be an adverse impact on surface water
and sediment due to the mitigation measures planned for air quality which should enable a
reduction of air emissions, although contributions from non-atmospheric sources were not
considered as stated previously.
At the Sangarédi site, dust and metals depositions were predicted to increase by 60% and,
therefore, a moderate impact on the surface water quality is expected, especially with respect to
aluminium concentrations in the smaller waterbodies, such as tributaries to the River Cogon
where hydrological data was available. Limited and localised impacts are expected on the
sediment quality.
The impacts resulting from groundwater and surface water abstractions from the Kamsar and the
Sangarédi sites in relation to the Expansion Project were not judged to be significant in the ESIA.
The impact on the groundwater resource were determine by the ESIA to be mainly due the
dewatering during the construction of the crusher at the Kamsar site and were considered to be
‘low’. According to the ESIA, groundwater and surface water resource impacts could not be
properly evaluated at the Sangarédi site because of limited baseline/monitoring data. Their
associated impact ranking (positive high for groundwater flow and quantity and negative high for
groundwater quality) is unsubstantiated.
8.3.5 Dredging
The dredging activities at the Kamsar port (418,000 m³), required as part of the Expansion
Project, were not studied in detail in the absence of a detailed dredging plan for the Rio Nunez
estuary but were instead assessed based on a comparison with the routine maintenance dredging
(100,000 m³) currently performed every 2 or 3 years as part of CBG’s current operations. Their
Environmental and Social Due Diligence – Technical Report
57
CBG Bauxite Mine Expansion Project, Guinea
associated impact on surface water and sediment quality were ranked moderate and high
respectively in the ESIA.
The ESIA makes the following recommendations:

avoid the use of suction dredgers. If there is no alternative, a turtle deflector or other means
must be used

reduce underwater noise to a minimum whilst dredging (without reference to specific
measures)

undertake a study to determine the [benthic fauna] of the sediment deposition zone

a recommendation that, if possible, dredging be avoided from August to January to minimise
impacts to blackchin guitarfish.
CBG recognises the need to develop a Dredge Management Plan, both to meet with industry good
practice and also to address the mitigation measures listed above from the ESIA.
Following finalisation of the Interim Report, CBG has provided Ramboll Environ with a draft
Dredge Management Plan, July 2015. The plan appears to only address dredging for the 18.5
MPTA phase and therefore outlines measures for the dredging and deposition of 300,000 m3 of
sediment from the turning circles and berthing area. The plan states that ‘Working techniques
and methods will be specified and detailed when the [dredging] contract is awarded’.
Consequently the plan is generally brief and missing several key elements as follows:

the plan refers to a site selected at the mouth of the Rio Nunez estuary in deeper water that
does not represent an important fishing area and is outside of the area considered by CBG10
to be representative of critical habitat. The area selected has been used previously during
maintenance dredging.

The plan acknowledges the recommendation in the ESIA for additional studies of benthic
fauna (assumed to be at the deposition zone) and physico-chemical characterisation of
sediments (assumed to be in the dredge area) prior to dredging operations. It makes
reference to reference to OSPAR Guidelines for the Management of Dredged Material.

The plan includes the mitigation measures detailed in the ESIA, inclusive those listed above.
Whereas the ESIA recognises the potential impacts associated with dredging and disposal of
dredge spoil, there is limited detail and a reliance on a future Dredge Management Plan. The
current draft dredge management plan is brief and points to further specification once a dredge
contractor has been appointed. During discussions with CBG it was understood that the
contractor has been requested to incorporate the mitigation measures specified in the ESIA
within its proposal. It is further understood that additional benthic survey and sediment analysis
work has been commissioned.
At the time of writing there remain a number of uncertainties relating to the sensitivity of the
dredge spoil disposal site and the nature of sediments to be dredged. The suitability of the
proposed disposal site should be demonstrated. In the absence of this critical information and the
precise mitigation measures to be employed by the dredging contractor, the dredge management
plan lacks the necessary detail.
The IESC also notes that whereas the Expansion Project does not require any deepening of the
approach channel, dredging of the channel in the longer term has not been ruled out.
10 The Critical Habitat Assessment includes the Rio Nunez as potential Critical Habitat on the basis that wide ranging species can be
found in the area.
Environmental and Social Due Diligence – Technical Report
58
CBG Bauxite Mine Expansion Project, Guinea
8.3.6 Mitigation measures
The mitigation measures specified in the ESMP include: development of a water management
plan; upgrade of the surface water and groundwater monitoring programmes; compliance with
the IFC wastewater discharge limit at the two wastewater treatment plant effluent discharge
points; the application of a 50m buffer between its operations and any water bodies to prevent
soil erosion by storm water; and the rehabilitation of the mined areas as soon as possible after
extraction of the bauxite ore using previously stockpiled top soil; development of a plan to
manage mine road crossings of surface water courses; and development of an additional study to
identify the sediment settlement zone associated with dredging, including sediment sampling and
analysis.
CBG obtains samples of river water for laboratory analysis. The analytical suite is limited and
could be improved to better evaluate potential impacts to river quality.
8.3.7 Monitoring
The monitoring programme is briefly discussed in the ESIA for wastewater, surface water and
sediment. In the ESMP and Water Management Framework, CBG undertakes to update and
improve its water and sediment monitoring programme to better evaluate the potential impacts
of its activities on the environment. This includes: an expanded surface water and sediment
quality programme; determination of surface water discharge at key locations in the Sangarédi
area; determination of groundwater depth and quality using wells at Kamsar, near the landfill
areas and around the Sangarédi mining areas; study of sediment at the proposed dredging and
sediment disposal sites to help assess potential impacts to surface water quality; adding a
groundwater monitoring plan; putting in place a monitoring programme to measure the flow
rates / volumes of the principal water channels; adding further sampling points to the current
surface water monitoring plan; and adding laboratory measurement of pH to the analysis suite
for surface water samples.
CBG will also continue with its current programme of monitoring wastewater discharges from its
two treatment stations, one at Kamsar and the other at Sangarédi, including addition of UV
treatment step for the Sangarédi station (mentioned in the text of the ESMP but not captured in
the summary table of Attenuation Measures (Section 4.2 of the ESMP).
8.3.8 Summary
Review of the ESIA raises a number of uncertainties that remain open pending preparation and
issue of CBG’s WMP, however, CBG has made clear, high-level commitments in its Water
Management Framework to address these uncertainties and to adhere to the requirements of
PS3. The open items include:

the adequacy of baseline data collected for the purposes of the ESIA, particularly as
groundwater impacts in the Sangarédi area have not been adequately addressed;

the impacts resulting from Project dredging activities and measures in place to minimise
water quality impacts;

clarification of the proposed mitigation measures, particularly where there is limited
specificity.
CBG has committed either in the ESMP or within the WMP (to be prepared) to the following
items:

Roles and responsibilities and resources for carrying out and supervising the tasks in the
WMP, including competence and training requirements.
Environmental and Social Due Diligence – Technical Report
59
CBG Bauxite Mine Expansion Project, Guinea

a model of the main groundwater bodies/aquifers, the locations of springs and surface water
bodies (run-off, springs/streams emanating from the plateaux and feeding the valley floor
rivers, lakes) and their interaction, and to identify the nature of surface water / groundwater
interactions and the degree to which the main rivers are groundwater fed.

quantitative water balances and solute balances.

identification of the locations of sensitive areas most at risk of being adversely impacted by
mining activities, including local well abstractions, communities, habitats and species.

the establishment of gauging stations to measure river water flows.

justification for selection of monitoring points (including the periodicity of monitoring and the
associated analytical suites) relative to the conceptual model and water balance, and a
description of how the monitoring plan and monitoring points will evolve with time as mining
progresses across the concession area, including establishment of baseline (pre-mining) data.
The monitoring programme will consider both water quality issues and water resources
(reduced spring flow, increased / decreased water levels and resource availability, etc.).

Review of the WMP on an annual basis, including gap analysis to identify gaps in the
monitoring network relative to the evolving mining operations and increasing knowledge from
monitoring results and studies, and associated amendment of the monitoring plan to fill key
gaps, and to monitor at a sufficient frequency and for appropriate parameters.

Provide an explanation of how water will be managed and resources and quality protected, in
particular:

Storm water and run-off management, including control of erosion and potential for
sedimentation of surface water resources.

Surface water protection – especially spring flow protection and from sediment loading
and dust fall-out (from mining operations and river crossings especially).

Identification of risk of impacts to existing users of water (e.g. resource impacts, water
level decline, quality degradation of village abstractions, etc.).

Demonstration that a sufficient monitoring plan has been developed and enacted – and
that associated mitigation processes have been developed which can be enacted in the
event a deterioration is observed.

Establishment of key performance indicators relative to which monitoring results will be
assessed and clear guidance on when / how exceedances will trigger subsequent action to
assess / address a given issue.

Include reference to Spill Prevention Control and Countermeasure Plans (SPCCs) (to control
water impacts from hydrocarbon sources including oil and grease traps, containment
structures, etc.) and other plans relevant to protection of water resources which have been
developed or a commitment to develop them, e.g. the Waste Management Plan (to prevent
negative impacts to water resources from waste containment structures, including domestic
waste storage, hazardous waste storage, etc.

Outlines for design of road ditches, culverts, diversions and sediment control structures
(sedimentation impoundments) based on a 25 year/ 24 hour return event for temporary
structures and a 100 year/24 hour return precipitation event for permanent structures.

Detailed plans associated with stream/river crossings to prevent impact to the water resource
and to prevent sedimentation, etc.
The Water Management Plan should also include other IFC specific requirements, including:

Consultation with key stakeholders (e.g. government, civil society, and potentially affected
communities) to understand conflicting water use demands and the dependency of
Environmental and Social Due Diligence – Technical Report
60
CBG Bauxite Mine Expansion Project, Guinea
communities on water resources and/or conservation requirements that may exist in the area
(with reference to the SEP and RAPs).

Detailed plans required to protect important springs and riparian areas supporting protection
of biodiversity (with reference to the BAP).
In closing, given the above, the Project is clearly reliant on the implementation of the WMP to
meet IFC PS3 requirements. However, in Ramboll Environ’s opinion, a thorough and well
implemented WMP should enable the key water-related risks associated with the Project to be
addressed. Given the evolving nature of the Project, with mining progressing gradually across the
various plateaux, it is recommended that the scope of the WMP, which CBG has committed to
review on an annual basis, be reviewed and agreed with Lenders prior to its initial finalisation in
January 2016, and during subsequent annual reviews. The Company has committed to the
provision of roles, responsibilities and resources for carrying out and supervising the tasks in the
WMP, including competence and training requirements. Given the importance of the WMP and its
successful implementation, those individuals with responsibility for implementation of the plan
need to have the appropriate capabilities. Currently the Company is being assisted by external
consultants; there is therefore a need to need to develop technical capability within the CBG
management team. It is understood that the new recruits described in Section 6.1 will be
required to have a background in water management.
8.4
Geology, soil and seismicity
8.4.1 Project standards
The Guinean legislation does not provide soil quality criterion. As such, the international
guidelines (IFC and Quebec) were used as reference.
8.4.2 Baseline data
This section of the disclosed ESIA is solely based on the ESIA for the previous production
increase (AECOM, 2011) and no additional baseline data were collected. The geological baseline
does not include hydrogeological information. The seismicity baseline data mentioned a moderate
risk.
The soil baseline information identifies visual signs of hydrocarbon contamination at six locations
at the Kamsar site and at two locations at the Sangarédi site during the now dated geotechnical
study (Golder, 2011).
On average, two spillages per year of hazardous materials have been recorded at the Kamsar site
since 1993. Most of the contaminated soil has been removed and is stored at a so called
“redemption” site located at the edge of the industrial zone where a bioremediation unit has
relatively recently been installed. Laboratory analysis of soil samples (AECOM, 2011) has
detected hydrocarbon in excavated contaminated soil near the tank farm and at the “redemption
site”, as well as elevated aluminium concentrations, especially in the drying bed area where
bauxite sludge is stored directly on bare soil without an impermeable barrier.
Leaching tests have identified potential for migration of dissolved phase aluminium in
groundwater.
Three soil samples obtained at the Sangarédi site (AECOM 2011 and BCG/EEM 2014) identified
contamination from hydrocarbons at the fuel loading/unloading site.
During the August Paris meeting it was confirmed that the refuelling area has secondary
containment (concrete / impermeable). The ESMP also includes the following commitment that
‘all hazardous materials (including oil and fuel) used in construction activities will be stored in
Environmental and Social Due Diligence – Technical Report
61
CBG Bauxite Mine Expansion Project, Guinea
tanks or in areas with effective retention systems (such as retention basins) to prevent
environmentally harmful spills.’
8.4.3 Assessment methodology
The assessment approach was mainly qualitative and concluded that the soil resource and soil
quality are of high and moderate value, respectively.
The assessment scope included consideration of soil removal and erosion at the mine and railway
sites, dust and gaseous deposition of contaminants near the construction and operation sites,
and the accidental spillage of hazardous materials.
The impact of aluminium on vegetation is studied in the biological impact assessment chapter of
the ESIA (see comments relating to biodiversity impacts in Chapter 11 of this report).
8.4.4 Impact assessment, mitigation and monitoring
The soil removal and erosion impact on 3,200 ha was qualitatively ranked in the ESIA as high
and moderate respectively, although its localised and short-term characterisation is questionable,
especially in the absence of a robust supporting argument. The ESIA concluded that the general
recommendations and good practices proposed as mitigation measures are expected to reduce
the residual impacts to moderate and low respectively.
The dust and gas deposition was ranked as moderate in relation to the high aluminium content.
Although the mitigation measures described in the air quality section of the ESIA are proposed
(to reduce deposition of dust), the residual impact is stated to remain moderate.
The impact related to accidental release was not ranked, presumably because of the uncertainty
surrounding such unplanned events, although various mitigation measures are presented.
Further measures to protect soil quality are presented in various sections of the ESIA and HSEC
plans and procedures. These include a Remediation Plan (including storage of top soil for reuse
and reinstatement of mined areas); plans for the safe handling and use of hazardous materials;
spill response plans (including measures to recover spills to soils); the Waste Management
Procedure (treatment of contaminated soils in a bioremediation facility) etc. The adequacy of
each of these plans/procedures is elsewhere in this report.
8.5
Waste management
The ESIA addresses waste management within the landscape, geology, soil and seismicity section
of the ESIA rather than within a stand-alone section.
8.5.1 Project standards
The IFC EHS guidelines for mining activities are mentioned but it is not clear if and how they
have been used and no reference to Guinean waste regulations is provided in the ESIA or the
Waste Management Procedure (ref. CBG_HSEC_PRO_4010).
8.5.2 Current practices
The current waste management situation is briefly described in the soil baseline section of the
ESIA and may be summarising as follows:

non-hazardous waste (Kamsar): collected separately and disposed of in a licensed landfill
equipped with a geomembrane. Waste is periodically covered to deter scavenging at the site.

hazardous waste (Kamsar): used batteries are emptied of their acid at a ‘garage’; medical
wastes are incinerated on site and the ashes disposed of at the above-mentioned landfill; and
used oil is burnt/used as fuel in the drying oven; and
Environmental and Social Due Diligence – Technical Report
62
CBG Bauxite Mine Expansion Project, Guinea

wastes from Sangarédi are disposed in a landfill located 1 km east of the city.
The ESIA also makes brief reference to the collection and transport to landfill of community
wastes deposited beside the railway, although it is unclear what agreements are in place or
whether this is an informal arrangement. It also highlights waste collection carried out by CBG in
Sangarédi as the only waste service in Sangarédi.
Following review of the ESIA, waste management practices were discussed during the workshops
in Paris. The current practices indicate that the position described in the ESIA is out of date;
consequently CBG’s Waste Management Procedure has been appended to the SIP in order to
present current waste management practices. Waste management practices at the time of
writing this report are as follows:
For non-hazardous wastes generated in Kamsar, CBG operates a landfill site in Bendougou,
approximately 15km east of Kamsar. Waste is collected from site operations and residents of the
CBG village (reportedly 30,000 workers and their families). The landfill facility is lined with a
geomembrane and wastes are periodically covered with soil to reduce odours and discourage
scavenging animals, although there is no leachate control at the site. Groundwater is reportedly
3m below the site and is saline. The landfill is secured by a perimeter fence and security guard.
The landfill has been operated continuously by CBG since mining operations commenced.
However, CBG stopped using the facility approximately one year ago following protests11 from
residents of Bendougou village in which the road serving the landfill was blocked.
CBG has temporarily stopped using the landfill at Bendougou and at the same time stopped
maintaining the road to the landfill, although it does expect to restart use of the landfill in the
near future following resolution of the Bendougou community grievance.
During the period that CBG has been prevented from accessing the Bendougou landfill, the
Company has been stockpiling non-hazardous wastes on land located at Torabora adjacent to the
Kamsar facilities within the CBG industrial zone. A number of improvements have been made to
the temporary disposal site, including erection of fencing to secure the site and traffic
management. The use of the site has reportedly been authorised by relevant authorities, but
nevertheless the land is considered by Ramboll Environ to be unsuitable for waste disposal
because it lacks any engineering controls such as an impermeable layer, drainage/leachate
control or monitoring.
At Sangarédi, non-hazardous wastes are deposited in an old unlined mine pit. The pit has been
used for many years, although the suitability of the pit cannot be confirmed. The practice clearly
falls short of good industry practice.
Hazardous wastes facilities in general are poor in West Africa and reportedly do not exist in
Guinea. CBG’s current practice is to either bio-remediate contaminated soils (see below), reuse
(tyres), incinerate (combustible medical wastes) or store hazardous wastes such as used
batteries until an appropriate solution can be found. Hazardous wastes from Sangarédi are
typically transported to Kamsar for storage, reuse etc. Waste oils are transported to Kamsar and
used as fuel in the bauxite drying ovens. Asbestos is removed by accredited providers and
encased in concrete sarcophagus (photographic evidence provided).
CBG has recently established a site for bioremediation of oil contaminated soils. The site has
been specifically chosen and lined with clay to prevent contamination of groundwater.
11 Protest related to the provision of water and electricity. This issue is discussed further in Chapter – unresolved grievance
resolution.
Environmental and Social Due Diligence – Technical Report
63
CBG Bauxite Mine Expansion Project, Guinea
8.5.3 Impact assessment and mitigations measures
Within the ESIA, the impact from wastes is briefly mentioned in relation to potential impacts to
soil. The magnitude of impact was judged to be low because most of the wastes are disposed of
in landfills. Given that the landfills are not designed in accordance with good practice and the
paucity of monitoring data there is little to support this this categorisation.
Mitigation measures are however proposed in the ESIA such as the maximisation of waste
recycling, the possible export of metal waste, the disposal to landfill of all other non-hazardous
wastes, the shipment by train of all hazardous waste from Sangarédi to Kamsar for disposal, and
the management of excavated and contaminated soil.
Following an initial review of the ESIA it was concluded that there is insufficient consideration of
waste management in the ESIA. Further effort was required to establish what management
practices are in place for the collection, segregation and disposal/treatment of wastes, and
whether these will be sufficient for the Expansion Project. Ramboll Environ requested and was
provided with the Company’s Waste Management Plan and also visited the CBG waste
management facilities described above.
Following further discussions with the Company, Ramboll Environ has been informed that
groundwater sampling from a single monitoring well 1km from the Bendougou landfill has not
resulted in detection of contamination from the site. CBG plans to extend groundwater
monitoring at the Bendougou site and also commence monitoring at the other wastes disposal
locations of Sangarédi, Torabora and Kamsar and the bio-remediation site, although specific
detail on parameters and frequency of monitoring is not specified in the waste management
procedure.
The waste management procedure includes useful information concerning the segregation of
wastes, record keeping, adoption of waste hierarchy and general objectives for waste
management and includes details regarding the acquisition of three modern mobile incinerators,
at a cost of US$600,000 for incineration of medical wastes amongst others.
The Company is making good progress in improving its waste management practices through the
introduction of waste segregation and recycling, the afore mentioned bioremediation site (unused
to date) and the procurement of mobile waste incinerators and new compactor trucks. However
the Company should also give further consideration to the potential risks from leachate and, as a
first measure, monitor surface and groundwater quality in proximity to the landfill sites to
confirm their suitability for ongoing use. It is understood from the Waste Management Procedure
that measures to address this issue are planned via an extended the groundwater monitoring
programme.
8.6
Ships’ wastes, ballast water and sediments management
The ESIA does not make reference to the management of ballast water and sediment and in
general provides little detail concerning the management of ships’ wastes. Similarly the Waste
Management Procedure (CBG_HSEC_PRO_4010) does not address ships’ wastes.
This observations contradicts discussion during the site visit where we understand that CBG has
begun a programme to manage ships’ waste, including ballast waters. Similarly, during the
August Paris workshop CBG confirmed verbally that ballast water control is included within
shipping contracts.
In support of this statement, Ramboll Environ has received a copy of a Ballast Water Reporting
Form for the Port of Kamsar which requires ships to provide detail of ballast water exchanges
performed before reaching the port. At this stage Ramboll Environ has not been able to review
completed forms requested by CBG nor confirm the requirements of the Ballast water Convention
Environmental and Social Due Diligence – Technical Report
64
CBG Bauxite Mine Expansion Project, Guinea
are being met due to time constraints. The efficacy of the procedure should be verified during
ongoing monitoring of the Project.
Ramboll Environ has also been informed that ships are required to maintain a garbage
management plan(s)/records in accordance with MARPOL 73/78 Annex V MEPC 201(62). A
sample waste certificate has been provided and stamped by the Ministry of Environment. The
Ship’s waste is identified for disposal at the Bendougou landfill.
8.7
Hazardous materials management
There is no specific section regarding hazardous materials management in the ESIA report.
Hazardous materials are covered within the groundwater section where groundwater
contamination due to accidental hydrocarbon spills or release of explosive residues is briefly
mentioned, and the soil section, with some accidental hydrocarbon release aspects covered.
8.7.1 Project standards
The groundwater section briefly mentions the IFC EHS Guidelines for Mining, and there is a
general reference to Article 142 of the Mining Code of Guinea in the ESMP which states that
‘appropriate techniques and methods must be used to protect the environment and the safety of
the workers and Local Community in accordance with the Environmental Code or international
best practices in this area’. It is not clear though how the IFC guidance was used in developing
mitigation measures for hazardous materials management.
8.7.2 Current practices
The history of accidental hydrocarbon spills at the Kamsar site since 1993 is described in section
8.4.2 above.
The main hazardous materials mentioned throughout the ESIA report include oil, petroleum
products, explosives and calcium chloride used as a chemical dust suppressant. The types and
quantities of these and other hazardous materials to be used by the Project (including mining
chemicals, cooling agents for air conditioning units, etc.) are not specified.
The ESMP states that CBG has developed and implemented over 50 HSE policies and procedures
divided into 14 sections, including Section 700 Hazardous Materials Management. The current
CBG’s Procedure for Hazardous Substances and Dangerous Goods (ref. CBG_HSEC_PRO_2110
dd. 1 July 2015), a material request form along with the risk score (ref. CBG_HSEC_ENR_2111),
a hazardous substances register (ref. CBG_HSEC_ENR_2112) and an MSDS form
(CBG_HSEC_ENR_2113) were available for review. The procedure is applicable to all CBG
activities in Guinea and provides general guidance on how to order, approve, register, store, label
and dispose of any hazardous materials used on site. Audit, record keeping, training and
information requirements are also outlined. However, the procedure:

Does not clearly define applicable standards and ‘recognised HSEC standards’ on which CBG’s
current hazmat practices are based


Does not define ‘European Standards’ on which signage procedures should be based
Does not determine internationally accepted methodologies such as HAZOP, HAZID, etc. to be
used for hazard assessment

Does not include any procedures for transportation of hazardous materials compliant with
those described in the IFC EHS General Guidelines (section 3.5)
During the Paris workshop (11-13 August 2015) CBG confirmed that explosives are handled by a
contractor. No operating procedures/plans were provided to Ramboll Environ concerning the
management and storage of explosives to confirm that those are used and managed in line with
the IFC EHS Guidelines for Mining.
Environmental and Social Due Diligence – Technical Report
65
CBG Bauxite Mine Expansion Project, Guinea
A hazardous substances register (in French) includes 226 chemicals used by different CBG sites
and specifies type (solid, liquid or gaseous), use (wastewater treatment, refrigerant, surface
coating, etc.), quantity stored, annual volume consumed, type of packaging, and users within the
Company.
According to documentation provided during the due diligence process, It is noted that one of the
refrigerant gases used at the Kamsar and Sangarédi sites is Freon R-12, or
dichlorodifluoromethane, also known as CFC-12, which is classified as ozone depleting substance
(ODS) and scheduled for phase-out under the Montreal Protocol (which Guinea has acceded to on
25th June 1992). This Annex A substance is a chlorofluorocarbon (CFC) which was banned for
production and consumption in 1996 (with an extension for Article 5 (developing) countries,
including Guinea until 2010) and can currently be used only as fire retardant in submarines and
aircraft. In line with IFC PS3, the Company should avoid consumption of the Annex A and Annex
B compounds and in particular CFC-12, although the IFC guidance does note that continued use
of CFCs in refrigeration equipment is permitted using a good practice to minimise refrigerant
leakages. CBG’s HSEC Manager has however informed the IESC that CFCs have been phased out
and are no longer used on site.
The Company is also using R-22, or chlorodifluoromethane and R-141b, or dichlorofluoroethane
as refrigerants at the Kamsar and Sangarédi sites. These substances are
hydrochlorofluorocarbons (HCFC) with less ozone depletion potential which are planned to be
finally phased out in 2040. However, many Article 5 countries are already using proven zero
ozone depletion potential alternatives preferred to HCFCs.
In addition, R-404A, a hydrofluorocarbon (HFC) is used. This fluorinated greenhouse gas (F-gas)
with a global warming potential of 3922 has just been hit by the new EU F Gas Regulations (in
force from 1st January 2015) requiring refrigerants with a GWP over 2500 to be finally phased out
in 2020. In the US, R-404A along with other common refrigerants with high GWP could be
banned from 2016 under new proposals from the US Environment Protection Agency.
We also note that the Company is using a number of insecticides at its sites in Kamsar and
Sangarédi, although all these substances are listed to be ‘not in stock’ in the hazardous
substances. Those include:

Malathion

Rampant Radical

Dethrine

Foxine

Larvifox

Sarfac

Sarlothrine

K-Othrine
The IFC PS3 clearly states that clients will not purchase, store, use, manufacture, or trade in
products that fall in WHO Recommended Classification of Pesticides by Hazard Class Ia
(extremely hazardous) or Ib (highly hazardous). The same applies to Class II (moderately
hazardous) pesticides, unless there are appropriate controls in place for manufacture,
procurement, or distribution and/or use of these chemicals. The following pesticides used by the
Company fall in either WHO Hazard Class Ia or II:

Sarfac (contains cyfluthrin, a WHO Hazard Class Ia substance)

Dethrine (contains deltamethrin, a WHO Hazard Class II substance)

K-Othrine (contains deltamethrin)

Sarlothrine (contains lambdacyhalothrin, a WHO Hazard Class II substance)
Environmental and Social Due Diligence – Technical Report
66
CBG Bauxite Mine Expansion Project, Guinea
Foxine containing highly toxic aluminium phosphide is also used as an insecticide. Aluminium
phosphide is a gaseous fumigant not classified under the WHO Recommended Classification of
Pesticides by Hazard and the WHO guidance indicates it should be subject to exposure limits set
out by the national legislation. No information was available to Ramboll Environ by the time of
writing this report whether Guinean exposure limits for aluminium phosphide had been set.
8.7.3 Impact assessment and mitigations measures
The soil contamination from hydrocarbon spills is generally considered as an environmental risk,
with the magnitude of impact assessed to be medium in relation to the site-specific nature of the
impact and its short duration.
The mitigation measures specified in the ESMP include: storage of all hazardous materials
(including oil and fuel) used in construction activities in tanks or in areas with effective retention
systems (such as retention basins); machinery inspections to avoid leaks and spills; development
of a locomotive inspection programme; availability of spill control kits in locations where
hazardous substances (including petroleum products) are handled; maintenance of machinery
and equipment in CBG shops or in the field, using safe methods for recovering used machine oil;
and storage of materials and equipment within guarded perimeters to prevent vandalism and
theft, which could result in soil contamination.
It is noted that some mitigation measures are formulated rather broadly, e.g. ‘precautionary
measures will be applied during the transport, handling and installation of equipment containing
oil’. There is also a statement that the Project will comply with CBG’s hazardous materials
management procedure, which we assume is the Procedure for Hazardous Substances and
Dangerous Goods referenced above.
To ensure alignment with the IFC PS and as part of the ESMP, the Company should develop a
Hazardous Materials Management Plan (HMMP), as set out in the relevant sections of the IFC EHS
General Guidelines (section 1.5 with the regard to the general hazardous materials management
approaches and section 3.5 with regard to the transport of hazardous materials) as well as in
section 1.2 of the IFC EHS Guidelines for Mining with regard to the use of explosives.
The HMMP should also address specific hazardous materials issues onsite, including:

Asbestos in building materials – include results of asbestos survey, asbestos related hazard
assessment and appropriate management actions, including ACM disposal techniques and
end-of-life sites

Ozone depleting substances – include evaluation of viable alternatives to R-12, R-22 and R404A currently being used as refrigerants and timeframes for the discontinuation of use of
those ODS

Chemical pesticides – include results of a compliance review of the pesticides in use onsite
against the Rotterdam Convention and the Stockholm Convention and the timeframes for the
discontinuation of use of pesticides identified as WHO Hazard Class Ia and II and of any other
substances (if identified) listed in the relevant annexes to the above conventions. The HMMP
should demonstrate robust results of the selection of the pesticides that are low in human
toxicity, are known to be effective against the target species, and have minimal effects on
non-target species and the environment. The pesticides to be used by the Project should be
handled, stored, applied, and disposed of in accordance with the Food and Agriculture
Organization’s International Code of Conduct on the Distribution and Use of Pesticides or
other relevant GIIP.
Environmental and Social Due Diligence – Technical Report
67
CBG Bauxite Mine Expansion Project, Guinea
8.8
Landscape and Visual Impacts
The Landscape Assessment section of the ESIA (Section 2.5) does not adequately address
landscape and visual impacts. This is reflected in the incorrect methodology set out on Page 118
of the ESIA which does not provide a transparent or coherent basis for the assessment.
Specifically, the methodology incorrectly conflates landscape and visual considerations, provides
no information on the extent of the study area adopted for the assessment or how the sensitivity
of landscape and/or visual receptors has been ascribed, and does not explain how the level of
residual impacts has been determined.
The baseline description in provided Section 2.5.2 is exceedingly brief for such a large
development area and does not adequately describe the landscape and visual resource of the
area, or the receptors therein. It also contains a number of erroneous statements regarding the
basis of landscape analysis and the sensitivity of receptors. Consequently, it is considered to
provide an insufficient basis for either the identification of potential landscape and visual impacts.
The Landscape Assessment provides no details of the sources of potential landscape and visual
impact (physical, spatial or temporal) or how this might affect the landscape and visual resource.
The assessment also contains no details of mitigation measures, presumably due to the paucity
of the landscape and visual baseline appraisal and the absence of an examination of the potential
sources of impacts.
8.9
Greenhouse gas emissions
Resource efficiency issues have been addressed by CBG in a Greenhouse Gas (GHG) emissions
assessment section as part of the air quality chapter of the physical impact assessment.
The GHG emissions assessment for the Project is based on the methodology and values
recommended into the 2006 IPCC Guidelines for National Greenhouse Gas Inventories. Current
CBG GHG emissions represent 3% of national GHG emissions in Guinea. The assessment in the
ESIA estimates that the final expansion phase (27.5Mtpa) will constitute 3.6% of national GHG
emissions.
This increase in GHG emissions is not directly proportional to the production increase, as a more
efficient production process is planned to be used in the Expansion Project. Therefore, CBG has
estimated that during the final phase, CO2 emissions will represent 0.018 tCO2e/tonne of bauxite
shipped compared with 0.020 tCO2e/tonne of bauxite shipped in 2012.
Several measures to reduce GHG emissions are detailed in the ESIA including: appropriate
maintenance of trucks, vehicles and locomotives; optimisation of the locomotives to wagons ratio
during transportation of ore; a new on-board rail signalling system featuring an automated speed
controller (22.5 Mtpa) to reduce fuel consumption; consideration of GHG emissions performance
criteria for the purchase of new equipment; and the rapid rehabilitation of cleared areas once
extraction is over.
In line with IFC performance requirements, CBG has committed to annual reporting of GHG
emissions during the operations phase and a number of energy efficiency measures to reduce
GHG emissions.
Environmental and Social Due Diligence – Technical Report
68
CBG Bauxite Mine Expansion Project, Guinea
Table 7: Summary of Findings (PS3 excluding air)
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
020
Noise –
airborne
(excluding noise
impacts on
ecological
receptors which
are addressed
in Chapter 11)
The noise assessment presented in the
ESIA raises a number of concerns:
Construction
and
operations
GIIP
The impacts of noise on human
receptors (residential areas and
workers’ accommodation as
appropriate), and mitigation
measures to reduce noise impacts
where necessary, should be
further assessed within a
Supplementary Information
Package (SIP).

Impact significance categorisations
considers a 3-5dB(A) to be low
magnitude; consequently within the
ESIA it often does not warrant
IFC general
EHS
guidelines
(for noise)
mitigation.

Incremental noise levels from the
The ESMP commits to noise
mitigation measures when the
noise levels produced by
operations increase the baseline
ambient sound level by more
than 3 dB(A) or exceed the IFC
guidelines. However this is
limited to mine operations and
should be extended to include rail
and port/plant locations.
expansion are provided in the
context of existing elevated noise
levels. However in certain
circumstances the elevated
background noise level exceedance
results from CBG’s ongoing
activities and incremental increases
without mitigation cannot be
justified. In these circumstances
Moderate
(falling to low if
recommendations
accepted)
The ESMP also commits to a
noise monitoring plan. This
should include blast monitoring in
order to develop site specific
propagation equations to refine
blast design.
mitigation measures should be
considered to avoid ‘noise creep’.

Significance
There are uncertainties associated
with the use of standard (non-site
specific) blast propagation curves
to manage noise levels.

Airborne noise impacts from quay
construction are not assessed.
021
Noise underwater
The ESIA does not assess the impacts
to marine fauna associated with
underwater noise generated by
vessels, dredging activities and
Construction
and
operations
GIIP and
IFC general
EHS
Noise impacts to marine fauna
(fish, marine mammals and
reptiles) should be assessed and
mitigation measures specified.
Moderate
(falling to low if
recommendations
accepted)
Environmental and Social Due Diligence – Technical Report
69
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
construction of the new quay (e.g.
piling impacts).
022
Dredging
The significance of impacts associated
with dredging activity has not been
adequately assessed in the ESIA, in
part, due to a lack of baseline data.
Mitigation measures have been
recommended but lack specificity.
Construction
and
operations
(maintenanc
e dredging)
Standard
IESC Recommendations
guidelines
(for noise)
Within the Supplementary
Information Package there is a
commitment to undertake a
detailed underwater noise
assessment as a part of the
Biodiversity Action Plan.
IFC EHS
guidelines for
Ports,
Harbors and
Terminals
Additional baseline data is
required to determine the
sensitivity of affected habitats
and potential impacts. This
information should then be used
to inform the development of a
detail Dredge Management Plan,
inclusive of detailed mitigation
measures, addressing capital and
maintenance dredging.
The current preliminary management
plan for dredging lacks specificity. A
detailed Dredge Management Plan is
required, that is consistent with
industry good practice and that
provides greater detail regarding
mitigation measures to be
implemented (e.g. noise reduction).
023
Surface water
and
groundwater
baseline and
monitoring
Limited surface water hydrological
baseline data (quality and flows)
relative to the mine development
footprint. Absence of groundwater
quality baseline, including
understanding of aquifer and flow
regimes and interaction with surface
waters. Absence of justified rationale
establishing necessary monitoring
locations, targeted aquifers, analysis
suites, periodicity of sampling,
evolution of the monitoring network
over time as mining progresses across
the concession area. A programme of
At the time of writing it is
understood that additional
baseline data collection is
underway.
Construction
and
operations
IFC
guidelines
Additional baseline data are
required throughout current and
proposed mining areas to
establish an adequate
understanding of the hydraulic
regime, establish a conceptual
model of surface watergroundwater interaction, and
water quality, availability and
flows.
At the time of writing, a detailed
plan showing proposed sampling
locations, their justification and
laboratory analysis suite is in
preparation.
Significance
Moderate
(reducing to Low
following collection
of additional
baseline data and
preparation of a
detailed Dredge
Management Plan)
Moderate
(Low)
Environmental and Social Due Diligence – Technical Report
70
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
well installation is to be implemented
by CBG in the last quarter of 2015.
IESC Recommendations
Significance
The baseline data should be used
to inform the Water Management
Plan and to establish a
subsequent (and preliminary)
monitoring network /
programme.
The use of nested wells in the
groundwater well monitoring
network should be avoided.
024
Water
Management
Plan
Development and implementation of a
Water Management Plan (WMP).
Construction,
operations
and closure
IFC EHS
Guidelines for
Mining
At present, no Water
Management Plan has been
developed, though CBG has
developed a Water Management
Framework that commits to the
development of a WMP in
accordance with PS 3
requirements. A substantial effort
will be needed to develop the
plan, including well installation,
data collection, preparation of a
water balance and groundwater
model, establishment and
implementation of a monitoring
plan, KPIs and action triggers, as
well as related plans (e.g.
stakeholder engagement plans
with other water users, etc.).
Development of the WMP may
require further iterative well
installation and sampling of
surface water / groundwater and
surface water gauging.
The influence on water levels at
and in the area of the existing
pumping site on the Tinguilinta
Moderate
(Low following
development of a
robust WMP)
Environmental and Social Due Diligence – Technical Report
71
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
Significance
River near Boké (Batafong) due
to the planned increased
groundwater abstraction for
Kamsar will also need to be
assessed and monitored to
provide assurance that the
increased abstraction volume
does not cause dewatering /
drying up of surface water
courses or adversely impact
groundwater supply wells.
Similarly, for water use at the
mine, it is planned to increase
abstraction from the pumping
station on the Cogon River
downstream from the dam,
notably for dust control
measures. The predicted increase
in water use is 496 m3/day, an
increase of 12.4% over the
current 4,000 m3/day. As with
the Batafong abstraction, the
influence on water levels of the
increase will need to be assessed
and monitored to provide
assurance that the increased
abstraction volume does not
cause dewatering / drying up of
surface water courses or
adversely impact groundwater
supply wells.
025
Surface Water Mine Road
Crossings
Preparation of procedures for
management of mine road crossings to
prevent sedimentation and
deterioration of surface water quality.
Construction
and
operations
IFC EHS
Guidelines for
Mining
See comments relating to Water
Management Plan above.
NA
Environmental and Social Due Diligence – Technical Report
72
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
026
Wastewater
Effluent
Discharge
Commitment to install UV treatment at
the Sangarédi plant.
Operations
IFC
guidelines
and Guinean
regulations
The intent to install UV treatment
is stated in the text of the ESIA
but not carried through to the
ESMP.
027
Potable Water
Details on planned improvements for
monitoring of effluent discharges,
including expansion of parameters
analysed to better assess impacts to
receiving water bodies.
Extension of current laboratory
analytical suite for monitoring of
potable water to include wider group of
parameters in line with WHO guidance
Extension of monitoring suite as
several common key effluent
parameters are not included
which are important to assess
impacts on surface water.
Operations
WHO potable
water quality
guidelines
CBG currently implements a good
programme of sampling to assure
potable water quality, though the
laboratory analysis suite is
limited.
Significance
Moderate
(Low once the UV
treatment is
operational)
Moderate
(Negligible)
CBG to expand the suite of
parameters to align with WHO
guidelines.
028
029
Mine restoration
Landscape and
Visual impact
There is a current notable backlog in
revegetation of mined out area with
the potential to result in soil erosion,
increased storm water run-off,
sedimentation of watercourses and
ongoing visual impacts.
Operations
and closure
The landscape and visual impact
assessment (LVIA) methodology used
in the ESIA lacks rigour and fails to
provide any mitigation measures.
Operations
IFC EHS
Guidelines for
Mining
CBG to implement procedures,
consistent with measures outlined
in the IFC Guidelines for Mining,
that adhere to a more prompt
revegetation programme to
promote return of wildlife and
manage storm water run-off.
GIIP
CBG should give further
consideration to mitigation and
monitoring of LVIA and specify
identified actions in the ESMP and
associated plans. In particular
timely reinstatement of disturbed
areas, vegetative screening and
Moderate
(Low once the back
log has been cleared
and there is prompt
reinstatement of
newly opened areas)
Low
Environmental and Social Due Diligence – Technical Report
73
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
Significance
considerate siting of facilities can
be employed to reduce landscape
and visual impacts.
030
Waste
management
Current waste management practices
fall short of good international practice.
Waste facilities in some instances are
not engineered and are likely to be
unsuitable to receive wastes. .
Construction
and
operations
IFC EHS
guidelines –
waste
management
Additional monitoring is required
to confirm the current waste
management facilities are not
resulting in environmental
damage, particularly
contamination of surface and/or
groundwaters.
CBG should expedite reuse of the
lined landfill at Bendougou and
cease use of the temporary
Torabora site.
031
Hazardous
Materials
A number of restricted substances
subject to international bans or phaseouts are used onsite.
The Hazardous Materials Management
Plan has some information gaps, for
example, procedures or the
transportation of hazardous materials.
Construction
and
operations
IFC EHS
guidelines –
hazardous
materials
management,
transport of
hazardous
materials
A revised Hazardous Materials
Management Plan that is
consistent with IFC guidelines
should be developed.
Moderate
(Low if the
suitability of disposal
sites can be
confirmed following
results of further
monitoring)
Low
Environmental and Social Due Diligence – Technical Report
74
CBG Bauxite Mine Expansion Project, Guinea
9.
PERFORMANCE STANDARD 4: COMMUNITY HEALTH,
SAFETY, AND SECURITY
The applicability of PS 4 to the proposed Expansion Project is established by the fact that
community health, safety and certain ‘security’ issues are addressed in three separate chapters
of the ESIA:

Chapter 10, Health risk assessment addressing the emissions from CBG for local communities
and workers;

Chapter 7, Social Impact Assessment; and

Chapter 8, Report on the potential impacts on human rights.
Chapter 10 focuses on health risks (with emphasis on those related to emissions generated by
CBG: specifically, changes in noise levels, air quality, and water quality) to both communities and
workers (occupational health and safety). Similarly, Chapter 8 focuses on both communities and
workers while Chapter 7 focuses only on communities.
The discussion of health and safety risk to communities and workers in Chapter 10 is high-level
and focuses on comparing the results of ambient monitoring of noise, air quality and water
quality in the vicinity of Kamsar (factory/port) and Sangarédi (mine concession area) with
standards/guidelines of organisations such as the World Health Organisation and the US
Environmental Protection Agency and then drawing inferences as to likely current health risks
and possible changes in health risks. There is no systematic approach which focuses on the
activities that will be part of the proposed mine expansion (construction and operational phases)
and the alterations in health and safety risk profiles posed by these activities. It is noticeable that
this chapter does not contain an assessment of impact significance based on the standard
method/approach used in most of the other impact chapters. It is acknowledged elsewhere in the
ESIA (Chapter 7) that the impacts of the Expansion Project on human health is not based “on a
real study of epidemiological risks" suggesting the ESIA authors had concerns over the adequacy
of the Health Impact Risk Assessment (HIRA).
In Chapter 10, there is inadequate consideration of the following topics (all required by PS 4):

Differential health risks arising from routine/non-routine operations (there is mention of
accidental oil releases, but not in this chapter);

Vulnerable groups; apart from a mention that adverse changes in air quality can affect,
particularly, the elderly and the very young;

Health and safety risks as a result of interference with provisioning and regulating ecosystem
services (for example, those health and safety risks arising from possible increase in flooding
risk caused by Project-induced alterations to topography or hydrological regimes);

Water-borne, water-based, water-related, and vector-borne diseases, and communicable
diseases that could result from Project activities, taking into consideration differential
exposure to, and higher sensitivity of, vulnerable groups. The only water/vector borne
disease considered is malaria. There is no mention of other vector-borne diseases such as
onchocerciais, schistosomiasis, and lassa fever that exist in West Africa. The only sexuallytransmitted disease mentioned is HIV/AIDS. It is stated that tuberculosis exists in the area of
CBG operations, but it is not considered further. There is no discussion of Ebola if only in
terms of potential CBG options/actions to manage the issue in the future, although Ramboll
Environ has been provided with CBG’s procedures for managing the Ebola risk;

In the context of these diseases, there is no consideration given to vulnerable groups apart
from the general statement that populations associated with mining operations tend to have a
Environmental and Social Due Diligence – Technical Report
75
CBG Bauxite Mine Expansion Project, Guinea
higher than average incidence and exposure to HIV/AIDS and hence are, by definition,
vulnerable to a potential increase in exposure to the virus.

Hazardous material management and safety. There is no discussion of this topic in Chapters 7
and 10 (the HIRA) or the ESMP. As described in the review against PS 3 (see above), there is
no specific section dealing with hazardous materials management in the ESIA report with only
accidental oil releases being discussed together with waste disposal routes for hazardous
wastes.

Emergency Preparedness and Response Measures. There is no discussion of these emergency
measures to protect community health in Chapters 7 and 10 or the ESMP.
PS 4 also requires consideration of issues relating to the provision of security personnel (whether
provided by a company, its contractors or the state). Since 1992, CBG has implemented a
security system of two strands (i) a subcontracted security company providing security guards
and (ii) two police (gendarmerie) units (each with 6 subunits) based at Kamsar and Sangarédi,
overseen by a military advisor attached to CBG management. These units work alongside the
security division of CBG and in collaboration with the security provider. The main mission of the
security guards/police units is to protect workers and their families, to ensure the free movement
of workers from their residence to their place of work, and ensure the security of all CBG
installations. This system which has been in place since 1992, and the incidences of theft of fuel,
electrical cabling and other incidents has reportedly decreased significantly.
PS 4 require a series of measures to be undertaken to ensure that interactions between security
provision and local communities are managed to avoid or minimise adverse effects on
communities. This issue is not discussed in any of the impact chapters nor are any mitigating
measures (in line with actions required by PS 4) presented in the ESMP. The ESMP includes a
section on Community Security, but the measures identified apply to community health and
safety issues related, primarily, to prevention of accidents involving community members
(primarily Project-related road traffic accidents), and do not include measures relating to
interaction between communities and security personnel (such as vetting of security providers,
and formulation of clear rules of engagement).
Chapter 7 focuses on communities and, primarily, on non-pollution threats to community health
status (such as traffic accidents) and on public access to health facilities and services. Attention
is paid, also, to transmissible diseases (with a brief discussion of a wider range of water- borne
disease than is provided in Chapter 10). A relatively comprehensive list of mitigation measures is
provided in the ESMP. However, this chapter exhibits the same weaknesses as Chapter 10 with
respect to the compliance with PS 4 requirements (see discussion of Chapter 10 above).
Ramboll Environ makes two further observations in the context of all the chapters dealing with
community health and safety issues:

There are no references to any of the easily-available guidance documents which set out the
procedures/approach/method for conducting a health impact assessment in an ESIA context;
and

The mitigation measures in the ESMP are generally comprehensive (except perhaps for
sanitation aspects). However, many of them will require significant investments (financial,
technical, human) and the capacity of CBG to implement them needs to be demonstrated,
particularly as some of the measures will require the support and participation of national
institutions.
The ESIA also draws attention to a number of community health and safety concerns raised by
communities, including:
Environmental and Social Due Diligence – Technical Report
76
CBG Bauxite Mine Expansion Project, Guinea

a belief amongst community members that CBG is responsible for health effects such as
respiratory diseases that they link to the air emissions arising from CBG’s operations;

water contamination (used oil, fuel) and impacts to consumed fish; and

railway crossing is a concern, notably the lack of safe crossing areas.
A memorandum (Appendix 7.3 of the ESIA) has been addressed to the CBG by several
representatives of the towns in the Sangarédi area, requesting that CBG respect the laws
regarding health and environment and takes into consideration public health issues while
conducting its Expansion Project. CBG has confirmed that, although no formal, written response
was provided to the representatives, several meetings and discussions were held on the issues
raised.
CBG recognizes that traffic-related risks are amongst the most important for the mine expansion.
It already has the following key Procedure in place: CBG_HSEC_PRO_2011_Procedure for Traffic
Management (issued 01/07/2015). This sets out actions to be taken in relation to issues/actions
such as:

Traffic Routes;

Traffic Controls and Site Entrances;

Delivery Curfew;

Hazardous Storage Areas;

Driving and Transport Rules;

Temporary Road Closures;

Training and Authorisation; and

Driving Related Incidents.
This Procedure is backed up by two supporting procedures:

CBG_HSEC_PRO_2012_Procedure for Driver Training and Accreditation; and

CBG_HSEC_PRO_2010_Procedure for Vehicle Journey Management (both issued on
01/07/2105).
In addition to these existing controls, the ESMP commits to wide range of additional measures
(some new and others building upon those already in existence) designed to improve community
health safety ranging from analyses of community risks to specific measures such as motorised
barriers at railway crossings and illumination of sections of track.
To summarise, community health and safety issues are discussed in the ESIA Report, but in a
general manner. Many of the individual topics/issues which need to be addressed to ensure the
requirements of PS 4 are satisfied are not included in sufficient detail. In addition, issues relating
to provision of security services, and its relevance in relation to communities, are not addressed
in the ESIA Report. The key risk of traffic-related community health and safety is recognized and
is controlled through existing procedures. These are strengthened through additional measures in
the ESMP.
9.1
Human rights
The ESIA includes a human rights chapter (Chapter 8) that covers the relevant international
human rights standards and establishes the applicable legal framework in which the Project
operates by documenting the links between the relevant international human rights standards
and the national legal provisions. While 22 pages are dedicated to the discussion of the legal and
conceptual human rights framework, only three paragraphs are used to discuss the actual
implementation of this framework in Guinea. This is imbalanced as the short text suggests that
Environmental and Social Due Diligence – Technical Report
77
CBG Bauxite Mine Expansion Project, Guinea
the protection of human rights as outlined in the national legal framework allows room for
improvement. In a satisfactory human rights impact assessment (HRIA) one would expect that
the key challenges of the enjoyment of human rights by the population and in the Project area in
particular would be discussed in detail to establish a comprehensive framework in which the
Expansion Project will operate. Furthermore, as this is an expansion of an existing operation, the
chapter would benefit from a summary of the human rights performance of the existing mining
operations.
The current Chapter makes it difficult to obtain a good understanding of what are the most
common human rights challenges i.e. the implementation and protection of human rights in a
non-project environment. Consequently, the chapter on potential human rights impacts of the
Expansion Project is theoretical and generic. While the outlined impacts are correct, the section
remains superficial and consequently does not provide a good understanding of what challenges
CBG will face during the extension of the existing mine.
As there are very limited details on the existing human rights practices and challenges in Guinea,
on the track record of CBG to date and on the potential impacts within this framework, the
mitigation measures are mostly limited a to generic mitigation measures such as “elaborate a
company policy” and “implement this policy”, i.e. they lack specificity.
Due in part to the generic nature of the mitigation measures specified in the ESIA, the Monitoring
and Evaluation Plan is similarly generic. For example, the HRIA suggests that the indicator for the
implementation of the right to form associations and use of collective bargaining is “restriction of
the rights of unions by the authorities”. Here the Company might argue, with some justification,
that it has limited control over the authorities’ actions and one might further argue that this is a
rather generic indicator. In a satisfactory HRIA more measurable indicators would be required.
However, despite the weaknesses identified in the ESIA chapter, IESC recognizes that Project
adherence to all relevant IFC Performance Standards ensures that many of the key human rights
issues are adequately addressed. The recommendations made in this ESDD report, when
implemented with those already identified by CBG, will ensure the requisite adherence; in
particular, but not limited to, recommendations on labour and working conditions, land
acquisition and involuntary resettlement, and community, health, safety and security.
Environmental and Social Due Diligence – Technical Report
78
CBG Bauxite Mine Expansion Project, Guinea
Table 8: Summary of Findings, PS4
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
032
Compliance with
PS 4
The dispersed locations of information and
analysis has led to the lack of focus and
coherence in the consideration of
community, health, safety and security
issues in the ESIA Report.
All
Lenders
CBG must ensure that, during
preparation of all ESMP ‘plans’ dealing
with community health and safety
issues, it identifies and assesses all key
community health and safety issues and
then includes measures to manage
them (the approach to identifying and
assessing the issues should be based on
a) all Project Expansion actions, in all
phases, that might result is in
community health and safety impacts
and b) be based on advice in an existing
‘good practice’ guide to Health Impact
Assessment such as IFC (2009)
Introduction to Health Impact
Assessment.
In essence, the sum of the individual
sections dealing with this PS topic does not
constitute a systematic and comprehensive
account of the topics included in PS 4.
No consideration of hazardous material
management and safety within the context
of community health and safety.
CBG must prepare a security
management plan to ensure that CBG
(and its security providers) implement
all the key principles/actions/
recommendations contained in the
ICMM document (undated) Voluntary
Principles on Security and Human
Rights: Implementation Guidance Tools
Issues of hazardous materials
management with respect to community
health and safety (including transport)
to be integrated with recommendations
on this topic presented in Chapter 8
above.
Significance
High
(decreasing to
Low if
recommendations
are
implemented)
Environmental and Social Due Diligence – Technical Report
79
CBG Bauxite Mine Expansion Project, Guinea
10. PERFORMANCE STANDARD 5: LAND ACQUISITION AND
INVOLUNTARY RESETTLEMENT
The ESIA states that CBG wishes to comply with international standards, including IFC’s PS 5 on
Land Acquisition and Involuntary Resettlement and the requirement for a Resettlement Action
Plan (RAP) and/or a Livelihood Restoration Plan (LRP), ensuring that no person will be worse off.
In early 2011, CBG commissioned the consultancy, AECOM, to carry out a gap analysis
identifying the differences between its procedures for "eviction" and those presented in the
(then) current PS 5 version (2006). The gap analysis report was provided to CBG in March 2011.
Also, in 2011, CBG commissioned AECOM to prepare a RAP for the village of Kolaboui in the
railway zone because, as stated, “…..a first siding is being built as this impact assessment report
is being written” (Chapter 7). The ESIA also refers to historical dissatisfaction among affected
communities with the compensation provided by CBG in respect of land acquisition/occupancy.
In the ESIA (Chapter 7, Social Impact Study) it is recognised that some villages, or parts of
villages, may have to be physically relocated. Subsequently, it is estimated that approximately
10 villages will experience a loss of land with likely physical and economic displacement
implications. It is anticipated that 4 RAPs (covering the estimated 10 villages) will be prepared
by 2022, with one RAP to be implemented in 2016.. All these villages are in the mine concession
area, but there are also potentially affected communities, in terms of livelihood implications, at
the factory/port site (fisheries) and also near to the railway network infrastructure.
The ESIA meets international requirements/benchmarks in its analysis of potential land
acquisition and involuntary resettlement impacts. The information provided in the ESIA meets a
key PS 5 requirement by demonstrating how CBG has taken action in its analysis of alternatives
to avoid and/or minimise land take and its likely impacts. For example, the use of alternative
design and/or siting options where land take and resulting economic and/or physical
displacement was either (a) the key factor, or (b) a contributing factor to the decision to
amend/reject an option (see Section 6.2.2 of this report, Analysis of Alternatives). Also, to the
extent feasible, given the uncertainties regarding proposed new mine sites, the scale and location
of physical and economic displacement are identified.
Subsequent to submission of the ESIA to BGÉÉE, CBG released a Terms of Reference for the
preparation of a RAP for the two villages of Fassaly Foutabhe and Hamdallaye. During the Paris
workshop, CBG confirmed that this RAP existed as a working draft (the RAP deals with both
physical and economic displacement issues). At the time of preparation of this report, this RAP
had not been finalized so was not available for review (it is expected to be completed in
December 2015). CBG further confirmed that this RAP would provide the basis for preparation of
a Resettlement and Livelihoods Restoration Policy Framework (RLRPF) that would establish a
common set of principles and procedures to be followed for future RAPs/LRPs.
10.1 Resettlement and Livelihoods Restoration Policy Framework
Using the experience of preparing this RAP, and taking PS 5 requirements and Guinean laws into
account, CBG has prepared the RLRPF for disclosure. The RLRPF covers all the key issues and
topics that are necessary to meet PS 5 requirements. It confirms a commitment to prepare a RAP
or LRP, as required (RAP for physical displacement, or physical displacement and economic
displacement, and an LRP for economic displacement only).
In the discussion of the role of socio-economic surveys (RLRPF Section 6, Socioeconomic
Surveys) in the RAP/LRP process there is a clear focus on identifying and obtaining information
on vulnerable people and this includes female-headed households. Later, Section 12 Monitoring
and Evaluation presents an indicative and non-exhaustive list of indicators whose status will be
Environmental and Social Due Diligence – Technical Report
80
CBG Bauxite Mine Expansion Project, Guinea
tracked, periodically, over time. The socio-economic survey undertaken in the context of RAP/LRP
implementation provides the essential baseline data which enables data, showing the future
states of the indicators, to be evaluated by comparison of the ‘before’ and after’ datasets. This
evaluation will show whether livelihoods have improved or not. While realizing that this list of
indicators in the RLRPF is only indicative, it is important that it reflects the increasing trend in
good international practice to focus on sex/gender issues and stresses that it is important that
sex-disaggregated data needs to be obtained early in the RAP/LRP process. The following
examples could be added to the indicative list in the RLRPF:

Number of women with title/shared title or customary ‘ownership’ right to land;

Socio-economic status of female-headed households;

% enrolment of female children under 16 years of age in school; and

Distance walked by women and female children, under 16 years of age, every day to obtain
water.
The RLRFP makes no mention of the need for periodic checking of links to the BAP Framework
and its recommended activities (see section below on PS 6). The BAP Framework recommends
maintaining links to those involved in RAP/LRP management because of the adverse impacts that
displacement can cause to biodiversity interests. Conversely, those involved in managing
RAPs/LRPs need to be aware of the implications of BAP-related actions such as establishing
offsets involving creation of protected areas, buffer zones or any other form of restricted access,
which may be implemented to enhance biodiversity interests, to determine whether such actions
would trigger application of PS 5.
10.2 Compensation-related grievances
During the Paris workshop, CBG was requested to review the situation regarding closure of
compensation-related grievances that were registered in the period 2010 -2015 and to assess the
extent to which livelihoods had been restored in terms of showing an improvement or, at as a
minimum, remaining the same in the post-compensation period. Also, CBG was requested to
consider and present the ways in which it intended to manage potential influx in the context of
RAP/LRP preparation/implementation.
CBG has addressed an External Memorandum (18/09/2015) to IFC and other lenders which
provides data on all actions taken, and results to date, relating to compensation grievances. To
date, 186 complaints related to two types of compensation have been identified for the period
covering the past 5 years (166 of these relates to compensation paid to individuals and the rest
relate to community-based compensation payments). One hundred (100) of these grievances
relate to land acquisition and 86 relate to compensation for damage to crops and other property
caused by CBG activities. A register has been established to assist processing and closure of
these grievances. To date, 7 of the 86 crop/property damage compensation grievances remain
open and work is progressing to evaluate them as part of the work leading to expected closure.
The fate of the remaining 100 grievances is not clear.
10.3 Livelihood Restoration
CBG has designed a socio-economic survey to determine extent of livelihood restoration for
compensated households. A sample of 20% of such households (33 from 166 compensated
individuals who are also complainants) has been selected and they will be surveyed every year
using a set of pre-determined indicators. The results will be used to demonstrate the changing
socio-economic/livelihood status of the households, for example, whether they are experiencing
improvement in their livelihood status, a decline, or ‘no change’. To date, the survey work has
begun, but is not yet complete. Fifteen (15) interviews have occurred and the results show that
Environmental and Social Due Diligence – Technical Report
81
CBG Bauxite Mine Expansion Project, Guinea
14 respondents indicate an improvement in their livelihood status and 1 respondent indicating ‘no
change’.
CBG is to be commended for beginning this work so promptly, but the representativeness of this
sample is questionable. First, restricting the ‘population’ to be sampled to those who have
complained may be acceptable if there is a justification in terms of the objectives of the survey.
Also, a 20% sample (33) out of a population of 166 equates to a confidence interval (error
margin) of 15.This means that if 60% of the respondents state that their livelihood has improved
in response to a specific question then it is possible to be sure that if the same question had been
asked of all 166 respondents between 45% (60-15) and 75% (60+15) would have given the
same answer. This is quite a large margin of error. Finally, there is no mention of the procedure
used to choose the 33 respondents. CBG is advised to provide a justification for basing the
sample only on 166 complainants (excluding other affected parties that have not raised a
complaint) and a rationale for the selection of the 33 respondents. In addition, CBG should reconsider the sample size and decide whether it provides results that are credible in terms of
meeting the objectives of the survey. If not, then it might wish to increase the sample size.
Finally, the allocation of responsibility for this work appear to lie with the Community Relations
department although this is not stated explicitly; responsible parties should be clearly stated.
10.4 Unplanned in-migration (influx)
Section 10.6 Influx Management, of the RLRPF presents details on the ways/mechanisms by
which unplanned in-migration into villages/areas, that are subject to RAP/LRP preparation and
implementation, will be managed. These are helpful and will assist management of unplanned inmigration. CBG should seek additional guidance in the IFC publication: Projects and People: A
Handbook for Addressing Project-Induced In-Migration to strengthen its approach for future
RAPs/LRPs.
(http://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/ifc+sustai
nability/learning+and+adapting/knowledge+products/publications/publications_handbook_inmigr
ation__wci__1319576839994).
Environmental and Social Due Diligence – Technical Report
82
CBG Bauxite Mine Expansion Project, Guinea
Table 9: Summary of Compliance Findings, PS5
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
033
Provision of new
land for
resettlement –
liaison/coordination
with biodiversity
experts
The RLRPF has no requirement to ensure
that staff responsible for managing land
acquisition and resettlement initiate and
maintain close liaison with their
counterparts involved in Biodiversity
Action Plan implementation. Clear
guidance is needed to ensure that any
resettlement implications arising from the
implementation, of the Biodiversity Action
Plan, are known as early as possible.
Post-ESIA
PS5
Include a clear statement in the
RLRPF that close and regular liaison
must be initiated and maintained by
senior managers responsible for
resettlement with their counterparts
responsible for Biodiversity Action Plan
implementation.
Significance
Moderate
(decreasing to
Negligible, if
the
recommendation
is implemented)
The draft Biodiversity Action Plan contains
a statement about need to consult
resettlement managers with respect to the
implications of resettlement actions for
biodiversity interests.
034
Restoration of
livelihoods – equal
treatment for
women
Insufficient guidance is provided in the
RLRPF with respect to gender issues in
terms of the procedure for evaluation of
the effectiveness of RAP/LRP measures to
improve livelihoods or at minimum restore
them to pre-displacement levels.
Post-ESIA
PS5
Add gender-specific indicators to the
indicative list of socioeconomic
indicators to be tracked to evaluate
the effectiveness of RAP/LRP
measures to improve livelihoods or at
minimum restore them to preRAP/LRP implementation levels.
Examples include:

Number of women with
title/shared title or customary
‘ownership’ right to land;

Socio-economic status of femaleheaded households;

% enrolment of female children
under 16 years of age in school;
and
Moderate
(decreasing to
Negligible, if
the
recommendation
is implemented)
Environmental and Social Due Diligence – Technical Report
83
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations

Significance
Distance walked by women and
female children, under 16 years of
age, every day to obtain water.
Ensure that the initial baseline
socioeconomic survey (essential to a
‘before and after’ comparison is
designed to collects data to enable the
baseline status of the gender-specific
indicators to be established.
035
Closure of
outstanding
grievances
CBG has been working effectively to close
out outstanding crop/property
Pre
expansion
PS5
Continue this activity as a priority and
complete close-out of the remaining
compensation-related grievances.
grievances as quickly as possible.
However, to date, 7 of the 86 complaints
are open and work is progressing to
evaluate them as part of the work leading
IESC to review progress towards
to expected closure.
close-out beginning with the first IESC
monitoring visit and continuing until
The fate of 100 grievances, relating to
the IESC confirms, in one of its
land acquisition compensation, from
regular monitoring reports, that the
the total of 186 registered compensation-
Moderate
(decreasing to
Negligible, if
the
recommendation
is implemented)
issue is closed. During this work the
related grievances is not clear.
IESC will interview a sample of those
who have submitted grievances to
determine whether the grievances
were resolved to their satisfaction.
036
Adequacy of
livelihood
restoration mechanism
CBG has initiated work to determine that
past compensation payments are not
associated with a reduction in livelihood
status for the recipients. This work is
based on a socio-economic survey of a
sample (20%) from compensation
Post-ESIA
PS5
Obtain professional advice from social
specialists as to the credibility of the
approach being used against the
objectives to be achieved by the
survey. If changes are recommended
to CBG then these are to be acted
upon immediately.
Moderate
(decreasing to
Negligible, if
the
recommendation
is implemented
Environmental and Social Due Diligence – Technical Report
84
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
recipients (the survey will be repeated to
track livelihood status into the future).
There are three main issues associated
with the approach being used. Essentially
no justifications are provided for:

Selection of the 166 compensation
recipients (only this who have
complained to CBG about
compensation previously;

Decision to use a sample of 20% of the
recipients;

Selection of the actual sample
family/households to be surveyed to
meet the 20% sample target (33
respondents).
Phase
Standard
IESC Recommendations
A special edition of the Memorandum
will be issued providing the results of
the professional advice with a
timetable for survey implementation.
Significance
Environmental and Social Due Diligence – Technical Report
85
CBG Bauxite Mine Expansion Project, Guinea
11. PERFORMANCE STANDARD 6: BIODIVERSITY
CONSERVATION AND SUSTAINABLE MANAGEMENT OF
LIVING NATURAL RESOURCES
11.1 Introduction
The Project Area has been assessed by the ESIA as containing critical habitats which have been
determined based on the presence of a large number of threatened and endemic species, globally
significant populations of migratory species, as well as threatened ecosystems. The Project Area
provides significant ecosystem services to local affected communities including food (agricultural,
fisheries and bush meat), raw materials (timber and firewood) and fresh water. Therefore, the
requirements of IFC PS6 are highly relevant to the Project.
Following a brief review of the ESIA, Ramboll Environ’s Interim Report identified a number of
inadequacies in relation to its biodiversity assessment. Additional issues of concern were also
discussed during the workshop held in Paris during August 2015. To address some of the concerns, a
Critical Habitat Assessment (CHA) was commissioned by CBG and completed by The Biodiversity
Consultancy Limited (TBC). In addition, CBG commissioned the Wild Chimpanzee Foundation (WCF)
to provide a complementary primate study. Some additional supplementary information relating to
biodiversity was included in the Supplementary Information Package (SIP) provided by EEM. EEM
have also produced a Biodiversity Action Framework (BAF), which sets out how the Project will
develop its Biodiversity Action Plan (BAP). Additional field surveys have been commissioned by CBG,
including primates, benthic fauna, amphibians, reptiles and vultures. These surveys are ongoing and
the results are not currently available to inform the DD report, although they will inform the
development of the BAP.
This section includes a review of the ESIA, the CHA, WCF report, SIP and the BAF. As with the other
sections of this report, the chapter describes some of the shortcomings associated with the disclosed
ESIA and the efforts and measures (preparation of CHA, WCF report, SIP and BAF) put in place by
CBG during the due diligence periods to remedy such short comings. The summary tables also
present ‘residual’ risks following implementation of actions in the ESMP/recommendations made in
this report.
11.2 ESIA
11.2.1 Relevant standards and guidelines
The ESIA chapters relating to biodiversity (Chapters 3 and 4) quotes IFC PS6 (2012) and EPIII
(2013) as the relevant standards for the assessment. IFC’s Mining guidelines (2007) are not
specifically referred to in the Biodiversity section, although the majority of the core recommendations
of the 2007 guidelines are picked up in the more recent IFC PS6 (2012). Other relevant best practice
guidelines (e.g. Independent report on biodiversity offsets ICMM IUCN (2012)) have not been
included as Project standards and guidelines, but are mentioned in the SIP.
A list of national legislative instruments relevant to the study are referred to in Chapter 4 of the ESIA
(as well as Annex 4.1 of the ESIA). Le code de protection de la faune sauvage et réglementation de
la chasse (Loi L/99/038/AN) translated as ‘The protection of wildlife code and hunting regulations’, is
highlighted as being of particular relevance to the assessment as it provides legal protection to plant
and animal species, including species found within the Project Area. However, the ESIA does not
provide a comprehensive list of protected species found within the Project Area, or an assessment of
whether the relevant national legislation can be met. Therefore, it is not possible to evaluate whether
the Project can comply with applicable national law as required by IFC PS6. However, the ESMP
(Appendix 8.9 of the SIP), states: “Given the importance that the Republic of Guinea gives to
Environmental and Social Due Diligence – Technical Report
86
CBG Bauxite Mine Expansion Project, Guinea
biodiversity, demonstrated in its laws, its action plans and the international conventions it has
ratified, CBG reiterates its adherence to the principles and recommendations of these texts and
makes the commitment to remind them to its employees and subcontractors.” This statement is
repeated in the BAF and therefore it appears that there is a good appreciation within CBG of this
issue.
Chapter 4 of the ESIA also refers to La monographie nationale sur la biodiversité de la Guinée (1997)
(The National Monograph on Biodiversity of Guinea), which is Guinea’s response to the Convention
on Biological Diversity (CBD), as well as other national plans such as Plan d’action national pour
l’Environnement (PNAE) (the National Action plan for the Environment). Where species recorded
within the Project Area are listed as In Peril by La monographie nationale sur la biodiversité de la
Guinée, this has been highlighted within the baseline section. A list of international conventions
relevant to biodiversity to which Guinea is party to is provided in Chapter 4 of the ESIA. A description
of these has been expanded further within the SIP.
11.2.2 Assessment methodology
The assessment methodology used in the ESIA is briefly set out in Section 1 of the ESIA. Chapter 4
of the ESIA describes how this has been applied to the assessment in relation to biodiversity.
Chapter 4 of the ESIA identified three main groups of biological Valued Environmental Components
(VEC): i) species, ii) habitats and iii) biological resources. The valuation of species was principally
based on the International Union for Conservation of Nature and Natural Resources (IUCN) Redlist of
Threatened Species. High value species are those classified as either IUCN Endangered, or Critically
Endangered (or those species likely to be revised into these categories in the near future). Medium
value receptors are those that are either IUCN Vulnerable or Near-threatened. This is a relatively
simplistic approach for valuation that does not take into account other factors such as population
sizes, rarity, ecosystem position, fragility etc. However, given the number of species included in the
assessment it provides a pragmatic approach. To be in better accordance with IFC PS6, endemic and
range restricted species, as well as internationally/nationally important populations of migratory
species could have been included in the identification of VECs. The TBC CHA however does include an
assessment of all threatened, endemic and migratory species recorded within the ESIA and has
identified additional species that are be considered high value. This more comprehensive list of VEC
species will be included within the BAP.
Within the ESIA, habitats have been valued according to IFC PS6 classification of critical (high value)
and natural (medium value) habitats. Modified habitats are not valued. This is because the majority
of potentially modified habitats have been assessed to represent natural habitats as a precautionary
measure. The only remaining modified habitats comprise human habitation, mines and industrial
zones, which are not valued in the biodiversity assessment.
Biological resources (ecosystem services) of sea fish, firewood and bush meat have been valued by
the ESIA (medium, low and low respectively), however no quantifiable criteria have been provided on
how these assessments have been arrived at. The Ecosystem Services Review (ESR) contained in the
SIP, identifies additional ecosystem services that are not valued within the ESIA.
11.2.3 Critical Habitat Assessment (ESIA)
An initial assessment of critical habitat is provided within Chapter 4 of the ESIA. The three critical
habitats identified by the ESIA were: the estuary of the Rio Nuñez, gallery forests (Sangarédi) and
the Cogon River Corridor. The ESIA states that the assessment has taken into consideration the five
main IFC PS6 criteria for determining critical habitat. During the August Paris workshop, EEM
confirmed that other criteria listed in IFC PS6 (e.g. landscape and ecological processes required for
Environmental and Social Due Diligence – Technical Report
87
CBG Bauxite Mine Expansion Project, Guinea
maintaining critical habitat) were not included in the assessment. Whilst critical habitat has been
identified within the ESIA, the methodology for determination of critical habitat does not conform to
IFC PS6 and its associated guidelines (i.e. Guidance Note 6 Biodiversity Conservation and
Sustainable Management of Living Natural Resources). For criteria 1-3 (i.e. threatened,
endemic/range-restricted species, migratory / congregatory species), the assessment has not been
applied to each species individually. The assessment has not used a landscape-scale approach to
include “discrete management units” which ideally should be completed on a species-by-species
basis. The ESIA has also not determined if the Project site is located in a Tier 1 or Tier 2 critical
habitat with respect to criteria 1-3. Therefore, within the ESIA it is unclear which specific biodiversity
values underpin critical habitat and their level of importance. This significantly undermines the
remaining impact assessment and design of mitigation measures to meet IFC PS6 requirements. A
number of potential triggers for critical habitat were not included in the ESIA’s assessment. For
example, the presence of two IUCN Endangered and range-restricted fish species Epiplatys njalaensis
and Archiaphyosemion jeanpoli have not been assessed for critical habitat in relation to the Project
Area’s watercourses. The Critically Endangered and endemic species of reptile (Hemidactylus
kundaensis) was not included in the critical habitat assessment. The three endangered species of
wide ranging vultures were not included in the assessment of critical habitat. Also Annex 3.6
suggests that the Project Area meets criteria for Important Bird Areas (IBA) due to the presence of
threatened and biome-restricted bird species. Although not formally recognised by Birdlife
international as an IBA, and therefore not explicitly meeting the definition of an Internationally
Recognised Area as defined by IFC PS6, it suggests that the Project Area may trigger critical habitat
due to the bird populations present. Finally, due to inadequacies in the baseline surveys, additional
triggers for critical habitats may be present, but as yet not identified.
Many of these shortcomings were discussed at length during the Paris workshop. In response, CBG
commissioned TBC to complete a new CHA, which is reviewed in more detail in section 11.3 below.
The TBC CHA goes a very long way to addressing the inadequacies of the ESIA assessment of critical
habitat described above.
11.2.4 Baseline conditions
Internationally Recognised Areas
Internationally Recognised Areas (IRAs) have been partially addressed by the ESIA in accordance
with IFC PS6 and are valued as high importance.
The ESIA identified Rio Kapachez Ramsar site located to the south of Kamsar as the only IRA of
relevance to the Project. IRAs are first addressed in Chapter 4 (impact assessment), rather than
detailed as part of the biological baseline section (Chapter 3). By not including IRA’s in the design,
implementation and presentation of baseline surveys, the ESIA does not provide a comprehensive
assessment of the current status of the IRAs, demonstrate how important the Project Area is for
maintaining the integrity of the IRAs or their qualifying features, or make a detailed assessment of
potential impacts. Whilst it is unlikely that significant direct impacts to the Rio Kapachez Ramsar site
will occur (with the possible exception of disposal of dredged material nearby), this is not made clear
in the ESIA. It is also possible that some of the populations of species that underpin the Ramsar
site’s status also depend upon the Nunez estuary (e.g. Sterna albifrons,) as supporting habitat.
The ESIA did not to identify the presence of Boulléré Key Biodiversity Area (KBA) which is located
within the Project Area at Sangarédi. Boulléré KBA has been designated due to potently significant
populations of globally threatened species sooty/white-naped mangabey Cercocebus atys (IUCN VU),
chimpanzee Pan troglodytes (IUCN EN), and West African red colobus Procolobus badius (IUCN EN).
All three species were recorded at Sangarédi according to the ESIA. Insufficient surveys were
Environmental and Social Due Diligence – Technical Report
88
CBG Bauxite Mine Expansion Project, Guinea
completed within the Boulléré KBA to verify its importance and assess the Project’s potential impacts.
This is now one of the foci of additional surveys recently commissioned by CBG.
Habitats and Species
A wide range of field surveys were commissioned to inform the ESIA, including vegetation, marine
and freshwater fish, amphibians, reptiles, birds and mammals. Most of the survey methodologies
employed rapid assessment techniques that maximises the information gathered from a limited level
of survey effort. To this end, the surveys were completed effectively by an experienced and
competent field team. The surveys have produced a large amount of data that enables the main
ecological sensitivities to be identified at a broad level. However, they do not represent systematic
survey methodologies designed to provide comprehensive results. Therefore, there are significant
gaps in the biodiversity baseline information provided by the ESIA. This in turn has implications on
the ability of the ESIA to identify critical habitat, accurately assess impacts and design appropriate
mitigation to meet requirements of IFC PS6.
For the surveys that have been completed, there are limitations in the methodologies employed that
affect their robustness. One common limitation to all the surveys completed is their limited annual
and seasonal coverage. Baseline studies were completed within a single period between the end of
October and the beginning of December 2013. This period is at the end of the rainy season and at
the start of the dry season. The ESIA states that the single survey period was selected due to costeffectiveness and that it enables the surveys to capture some of the species apparent in either
season. However, many of the species specific surveys were completed within a short period within
the whole survey campaign (e.g. birds at Kamsar were surveyed between 11th and 16th November
2013). In several places in the ESIA and its annexes, it is acknowledged that the results were
incomplete due to the short survey campaign. For example, the ESIA refers to seasonal limitations
due to lack of flowering parts on plants, burning of vegetation and the migratory behaviour of
animals. Therefore, the surveys should be considered to represent a single survey sample and are
unlikely to provide a comprehensive or accurate record of changes due to seasonality or inter-annual
variation.
Within the ESIA, secondary data were obtained from a number of recent published studies from the
region (e.g. Inventaire de la flore des plateaux miniers de Sangarédi, Bidikoum, Silidara et
N’Dangara BERCA-Baara, 2003). Additional sources have been used to fill some gaps in the field
survey results, however it is not apparent that a thorough, systematic and comprehensive literature
search has been completed. For many of the species groups, secondary data sources have not been
used to assess the potential for additional notable species to occur in the study area. In order to
address this issue, a more systematic use of secondary data was included within the TBC CHA and
has identified the potential presence of additional high priority species.
Presentation of some of the key results is not clear within the ESIA, with implications for assessing
the impacts to VECs and critical habitat. For example it is not clear where the two endangered and
range restricted freshwater fish species (Epiplatys njalaensis and Archiaphyosemion jeanpoli) were
recorded and how these relate to the Project’s activities. It is not clear where the threatened species
of reptile were found and what habitats they are found in. This has to some extent been clarified
through the provision of additional mapping included in the SIP. However, there are some apparent
contradictions between the ESIA and information included in the TBC CHA, which mean that the
status of key reptile species is still uncertain in the Project’s documentation.
The following limitations in the ESIA’s baseline surveys have been identified by Ramboll Environ
following a review of the Annexes to Chapter 3 of the ESIA (Note, some of these identified limitations
have already been discussed with CBG and are subject to additional surveys in October and
November 2015):
Environmental and Social Due Diligence – Technical Report
89
CBG Bauxite Mine Expansion Project, Guinea
Limitations of botanical survey:

Completed at sub-optimal time of year.

Some areas at Sangarédi have been under-recorded (e.g. Medina Dian, Diandian area).

Gallery Forest at Siding PK 118 not fully surveyed due to time of year. Although degraded, the
ESIA acknowledged that species of conservation importance may be present.

Kamsar survey based on just 3 plots, located remote from the Port. No surveys completed in
areas adjacent to Port (i.e. areas most likely to be impacted). Based on Ramboll Environ’s site
visit, it appears that there is mangrove vegetation immediately adjacent to the Port which has
not been surveyed.

The Kew report acknowledges that comprehensive species lists for the vegetation types cannot
be produced as a result of one survey in one season.

Currently only 3-5% of plant species in Guinea have been formally assessed for their IUCN
conservation status. However, it is understood that Kew have provided professional opinion on
the status of the plants recorded and additional assessment has been provided by the Missouri
Botanical Garden, included in the TBC CHA.
Limitations of marine fisheries survey

Surveys are based on local fisheries rather than comprising a biological survey, therefore limited
to commercially valuable species.


Survey effort too low to provide comprehensive assessment of species present.
Very limited understanding of ecology of fish species present and their use of the estuary for
important life-cycle stages (e.g. spawning and nursery areas, or their seasonal timing). Annex
3.3 of the ESIA notes the presence of juveniles of Rhinobatos cemiculus (IUCN EN) and
Rhinoptera marginata (IUCN NT) within the estuary, which suggests that it is used as a nursery
areas.

Very limited use of secondary data to fill data gaps. The presence of other threatened fish species
can be predicted based on secondary data.

Annex 3.3 of the ESIA notes that IUCN Critically Endangered Largetooth Sawfish Pristis pristis
recorded at Kamsar in 1990, but this is not referenced in the main body of the ESIA.
Limitations of freshwater fish surveys

Some of the tributary catchments not surveyed. Given the apparent small distributions of the
threatened and endemic species present in the Study Area, this need to be addressed.

Survey effort does not allow accurate distributions and population assessment of threatened and
endemic species of fish present in the study area.

Very limited understanding of the ecology of threatened and endemic species of fish.

Very limited use of secondary data to fill data gaps.

The ESIA lacks a description of the physical characteristics of freshwater habitats such as running
water and rivers. There is no description of the physical habitats inhabited by priority fish
species.
Limitations of large mammal surveys

At Sangarédi, the survey was largely confined to the western half of the Project Area, with few
samples in the eastern portion.

Annex 3.5 of the ESIA states that camera trapping effort was less than a 1000 trap days and
therefore only a species list could be provided and no further analysis could be completed.
Environmental and Social Due Diligence – Technical Report
90
CBG Bauxite Mine Expansion Project, Guinea

The surveys do not appear to have adequately covered Boulléré KBA, which is designated due to
three species of primates.

Does not conform to best practice survey for great apes.

Annex 3.2 of the ESIA recommends that a dolphin survey is completed during the dry season.
The existing survey was completed during the wet season, at which time, according to local
fishermen, dolphin use of the estuary is at its lowest.
Following the Paris workshop, CBG commissioned WCF to complete a complementary study of
primates in the CBG concession. This report was based on fieldwork completed by WCF in 2010-2012
and 2014-2015. The surveys only covered the western part of CBG’s concession, but enable an initial
estimation of chimpanzee populations. It is understood that CBG has commissioned the WCF to
initiate a systematic survey of the entire concession, which should provide a robust baseline for
chimpanzee. According to the BAF, additional surveys are also due to be completed by Sylvatrop in
October and November 2015 that will investigate chimpanzee nest locations close to mining areas
and use of plateau habitats on or near the proposed mining areas.
Limitation of bird surveys

Very limited survey period (i.e. 16th – 22nd November at Sangarédi and 11-16 November 2013 at
Kamsar), which does not accurately capture either intra or inter-seasonal variation.

Sampling areas at Kamsar insufficient to identify important areas for congregatory / migratory
birds (e.g. feeding sites or high-tide roost sites), especially in areas close to the Port at highest
risk of disturbance.

No assessment of population densities or size at Sangarédi.

No assessment of potential migratory populations of bird species at Sangarédi.

Some parts of the Project Area at Sangarédi poorly covered.

Access in many areas at Sangarédi difficult due to tall grassland. Annex 3.6 of the ESIA
recommends additional surveys in January and February when access is easier.
Limitation of reptile surveys

Large portions of Sangarédi region not surveyed during short survey period. Only a single survey
location is located within the Priority areas.

ESIA states that the surveys at Kamsar has only produced very partial results and longer work in
the area would certainly have resulted in more species, particularly among the snakes.

The status of marine turtle nesting is unclear in the ESIA. According to the specialist that
completed the survey, it is possible for turtles to be nesting in the area.

ESIA does not confirm if other notable reptile species might expect to occur based on previous
published studies.

Habitat and distribution of Critically Endangered Hemidactylus albivertebralis and Cassine River
worm lizard Cynisca oligopholis (IUCN Endangered) is not confirmed within the ESIA.
According to the BAF, additional reptile surveys at Sangarédi will be completed in October and
November 2015.
Limitation of amphibian surveys

Areas of Sangarédi region not surveyed.

Not completed during the wet season.

ESIA does not confirm if other notable amphibian species might expect to occur based on
previous published studies.
Environmental and Social Due Diligence – Technical Report
91
CBG Bauxite Mine Expansion Project, Guinea

Habitat and distribution of Critically Endangered Hemidactylus albivertebralis and Cassine River
worm lizard Cynisca oligopholis (IUCN Endangered) is not confirmed within the ESIA.
According to the BAF, additional amphibian surveys at Sangarédi will be completed in October and
November 2015.
The ESIA makes recommendations for the following additional studies:

bats;

marine benthic fauna;

additional botanical surveys to be completed in September and October;

studies of endangered species of vulture; and

studies of the Kunda half-toed lizard Hemidactylus kundaensis.
The TBC CHA also makes recommendations for additional survey work (see section 11.3 below). The
BAF details additional survey work currently planned (see section 11.4, below).
Ecosystem services
Chapter 3 of the ESIA includes the results of rapid baseline surveys for bush meat, fire wood and
fisheries. Whilst these are likely to represent important ecosystem services (ES) in the Project Area,
the ESIA does not provide a systematic review to identify priority ecosystem services as required by
IFC PS6. As a result important ecosystem services, such as grazing for livestock have not been
addressed.
During the August Paris workshop it was agreed that an ES Review (ESR) would be completed and
included in the SIP. The ESR included in the SIP considers an exhaustive list of ES and identifies both
type 1 and type 2 ES of relevance to the Project. The ESR also assesses whether the ES are
adequately addressed in the ESIA. A number of ES are assessed by the ESR as being poorly
addressed or not addressed by the ESIA. The Project’s ESMP includes the following measures for ES:
“The Project will promote community use of biodiversity and other ecosystem services by: 60.1.
prohibiting hunting and harvesting of natural products outside the work area by its employees and
contractors; 60.2. offering wood from land clearing to nearby residents, at no charge.” It does not
appear that the Project’s proposed mitigation measures have been reviewed to address potential
impacts to ES based on the findings of the ESR. Additional, stakeholder engagement and detailed
impact assessment may be required to identify appropriate mitigation measures to meet IFC PS6
requirements.
The BAF states that Project’s control framework will include stakeholder and partnership roles
including establishing a biodiversity and ecosystem services working group. It is not currently clear
whether it will be the role of this working group to address the additional ES identified by the ESR.
Invasive species
The botanical surveys completed to inform the ESIA included assessment for the presence of invasive
species. The ESIA mentions the presence of at least two invasive plant species. Chromalaena
odorata, an invasive plant from the Neotropical region, was observed at several locations in the
study area. In addition, cashew Anacardium occidentale has been planted by CBG to re-vegetate
areas within the present mining operations. This species is non-native and poses an invasive risk. It
is currently unclear whether cashew will continue to be used in future rehabilitation works due to a
perceived economic benefit for local communities. The potential for impacts from the introduction of
marine invasive species has not been assessed in the ESIA. However, during the August Paris
workshop CBG confirmed verbally that ballast water control is included within shipping contracts (see
also Section 8.6).
Environmental and Social Due Diligence – Technical Report
92
CBG Bauxite Mine Expansion Project, Guinea
The ESMP includes consideration of invasive species in line 58: “CBG will set up an annual program
for controlling nuisance and invasive species such as Chromalaena.” It is suggested that this
programme is further considered during future Lenders’ monitoring visits.
Impact assessment
The ESIA identifies a range of impact types, including habitat loss, fragmentation, reduction in air
quality, noise and vibration, water pollution, light pollution, human disturbance, collisions, induced
access (including increased exploitation of timber and bushmeat) and invasive species. The impacts
types considered in Chapter 4 are reasonably comprehensive. However significant gaps in the ESIA’s
detailed assessment of impacts in relation to biodiversity have been identified by Ramboll Environ
and are discussed in the following sections. Some of these gaps have also been identified within the
TBC CHA (Table 11 within the CHA).
Cumulative Impacts
With large areas of Guinea, including the majority of the Boké prefecture subject to mining
concessions, there is likely to be significant cumulative impacts to biodiversity, including natural and
critical habitats. The ESIA includes a dedicated chapter for the assessment of cumulative impacts
that implies that there will be impacts to biodiversity (see Section 6.2.6 above for a more detailed
review of this chapter). This issue is highlighted in the TBC CHA as likely to present the greatest risk
to biodiversity and greatest challenge to address. Within the SIP there is a statement that confirms
that CBG is considering cumulative impacts within its area of influence in accordance with PS1 and
will cooperate with any national institution or any other company that would launch work in the CBG
area of influence in order to implement common mitigation measures. This statement has also been
included in Appendix 10.2 of the BAF, and therefore it is expected that this issue will be addressed
further within the BAP. It is also understood that the IFC is also looking at options to providing fund
in support of a regional cumulative impacts assessment. Whereas the funding has not been secured,
on the basis of the CBG commitment above, it is understood that such an initiative would be
supported by CBG.
Impacts to Habitats and Species
Chapter 4 of the ESIA provides some quantification in relation to habitat loss (e.g. comparison of
hectares lost as a percentage of resource). There is some cross-referencing to relevant results in
other chapters (e.g. air quality, noise) to provide quantification of indirect impacts. However, there
are significant limitations in the ESIA’s assessment of indirect impacts. There is no meaningful
quantification to provide the evidence to support the assessment of impacts to species. The lack of
quantification means that it is not easy to assess whether the levels of mitigation suggested are
sufficient to provide ‘no net loss’ of biodiversity. Additional quantification of impacts will be provided
by the BAP. Some of the priority issues that require additional studies are discussed in the following
sections. Some of the priority issues that require addressing are discussed in the following sections.
Dredging
Due to the lack of baseline surveys for benthic fauna, the ESIA does not assess potential impacts
from dredging. It also does not assess impacts from disposal of dredged material (e.g. smothering of
benthic communities, contaminated sediments and the relationship of disposal site with critical
habitats and Internationally Recognised Areas). This data gap has been recognised by CBG and is
being addressed through the completion of sediment and benthic surveys in both of the dredge area
and the disposal site (as detailed in Appendix 8.3 of the SIP). According to the BAF, the assessment
of impacts to natural and critical habitats within the Nunez Estuary, including from dredging, will be
addressed through the BAP.
Environmental and Social Due Diligence – Technical Report
93
CBG Bauxite Mine Expansion Project, Guinea
Indirect Impacts Mediated through Local Community Uses of Resources
The Project will cause indirect impacts to biodiversity due to its impacts to local communities. This
will take a variety of forms. The ESIA discusses potential impacts on biodiversity due to increased
access from haul roads. This is likely to increase pressure from bush meat hunting and wood fuel
gathering. The ESIA addresses this issue through a commitment to management plans for access in
relation to bushmeat and wood fuel gathering. The TBC CHA identifies that additional work is
required to quantify the impacts from hunting, bushmeat and wildlife trade. In addition, the TBC CHA
identifies that indirect impacts from induced access and in-migration are not currently considered in
the ESIA. This could affect both Sangarédi and Kamsar. The mining operations will also exclude local
communities from areas of agricultural land. This, along with increased population from in-migration,
will increase pressure on the remaining agricultural areas which could potentially lead to agricultural
intensification and possibly conversion of natural and critical habitats into farmland. This issue is
highlighted as a significant source of impact in Annex 3.5 of the ESIA, but not picked up in chapter 4
or addressed by proposed mitigation measures.
The BAF suggests that some of these issues will be addressed through the Project’s biodiversity
control framework, including a Harvesting Management Plan, Fisheries Management Plan and
Induced Access Plan. However, it is not currently clear whether these will be based on additional
quantitative assessment and cover impacts from displacement.
Marine Noise Impacts
The ESIA does not provide any noise modelling within the marine environment in relation to potential
impacts to fish and cetaceans (both construction and operation). Therefore, it is not currently
possible to provide an accurate assessment of potential impacts on a number of threatened species
of fish, turtles and cetaceans, many of which are triggers for critical habitat. The ESMP states that
the Project will reduce underwater noise to a minimum during dredging or quay construction (line
54.2 of the ESMP). However, there is no indication how this will be achieved, how it will be monitored
and if control thresholds will be imposed.
In recognition of this deficiency, according to the BAF, underwater noise will be addressed through
the BAP. Noise modelling is due to be completed in October and November 2015. The Ambient Air
Quality and Noise Monitoring Plan included in Appendix I of the SIP provides a brief overview of a
marine noise assessment that is due to be commissioned by CBG. The BAF states that protection
measures may be modified or expanded as result of the underwater noise study.
Air Quality
The air quality chapter of the ESIA does not discuss impacts to ecology receptors. Therefore, it is
hard to see the evidence to support the conclusion in Chapter 4 of the ESIA that impacts to ecology
will be minimal. A quantitative assessment of impacts to specific habitat types from deposition in the
vicinity of the Project was not included in the ESIA.
Additional information on the potential impacts from dust deposition to vegetation are provided in
the SIP. This provides a much more quantitative assessment of likely impacts. However, it should be
noted that not all of the mining areas have been modelled and therefore the total areas of impact for
the entire Project Area at Sangarédi are still to be quantified. Nevertheless, based on the information
provided, it is clear that there are likely to be some loss of natural habitats, and possibly critical
habitats caused as a result of changes in air quality. This will need to be included in the BAP and
appropriate mitigation and /or offsets provided in compensation. Whilst the additional modelling has
addressed impacts from dust deposition impacts on vegetation, it does not assess potential impacts
to watercourses and it does not assess potential impacts of nitrogen deposition. The BAF states that
the BAP will include review of the impacts from potential changes to air quality.
Environmental and Social Due Diligence – Technical Report
94
CBG Bauxite Mine Expansion Project, Guinea
Water Quality
The ESIA provides a limited assessment of the potential impact on ecological receptors from changes
in water quality.
The water quality guidelines for aluminium used in the ESIA assessment is 87 μg/L (from the U.S.
EPA). This value is based on toxicity tests with the striped bass in water with pH 6.5–6.6 and
hardness <10 mg/L. The ESIA’s water quality assessment states that there is potential for this value
to be approached or exceeded in the expansion scenarios, particularly the 22.5 Mtpa scenario.
However, no indication is given on the origin of the elevated levels or where these exceedances will
occur in relation to important fish populations. Given the threatened status of the fish species
present in the Project Area a more detailed eco-toxicological assessment would be appropriate.
Section 2.6.4 of the SIP includes a small additional piece of information in relation to a published
study on aluminium toxicity on fish, which highlights the toxicity of aluminium to fish within the
range of pH and dissolved oxygen concentrations found within the Project Area.
The SIP includes Appendix 8.2 Surface water and sediment sampling program produced by Arcadis.
The locations of the suggested sampling locations have partly taken into account the location of
sensitive biological receptors. However, it is not comprehensive. According to EEM, not all of the
known locations of fish species that trigger Critical Habitat were supplied to Arcadis to consider.
Therefore, it is unlikely that the number and locations of the sample locations suggested will provide
sufficient detail, firstly to provide a more accurate impact assessment on sensitive biological
receptors, and secondly provide sufficient monitoring of long term effects.
It is recommended that the water quality sampling and monitoring programme (committed to by
CBG in its water management Framework) is reviewed to take into account all of the known locations
of freshwater fish species that trigger critical habitat as part of the Project’s BAP. In addition, more
sampling locations adjacent to active mining operations to check for exceedances during operation
may be appropriate. This should be included in an active management strategy whereby any
exceedances can be investigated and corrective actions taken to protect sensitive watersheds. The
protection of freshwater fish is detailed in the BAF for inclusion in the BAP, and it is understood that
this will include an evaluation of the water quality survey programme.
Impacts Caused by Haul Roads
The ESIA does not assess potential impacts from haul roads on biodiversity adequately. The
construction and operation of haul roads to the numerous mining blocks are likely to cause a range
of significant adverse impacts to habitats and species including habitat loss, increased run-off of
sediments, habitat fragmentation, dust and disturbance. A plan showing the potential routes of haul
roads has been included in Appendix II of the SIP. This highlights the likely extent of impacts to both
habitats and species, including critical habitat. This issue is highlighted by the TBC CHA as potentially
significant and it recommends that the road plan should consider impacts to sensitive habitats and
take avoidance measures to reduce potential impacts where possible.
The ESMP states that the Project will optimize the mine road network in relation to biodiversity for
the Long-Term Mining Plan in the detailed engineering phase (line 63.4 of the ESMP). The BAF also
states that the BAP will consider the restoration of mined areas and inform decisions regarding fate
of mining haul roads. However, the feasibility of closing roads once in place has not been currently
assessed. It is not clear that the likely residual fragmentation effects on critical habitat will be
quantified for inclusion of the Project’s offset strategy.
Environmental and Social Due Diligence – Technical Report
95
CBG Bauxite Mine Expansion Project, Guinea
Noise Disturbance
It does not appear that the assessment methodology for noise impacts contained within the ESIA is
suitable to assess impacts to ecology at Sangarédi as it only calculates exceedances at village sites,
rather than produce contour plots that could then be overlain to calculate the areas of habitat that
would be affected by noise. Looking at the number of villages that will suffer exceedances, along with
the contour plots showing set-back requirements it appears that noise impacts will travel significant
distances from the mine sites.
The areas affected by blasting has not been modelled in either the ESIA or the SIP. Instead these
documents describe an approach based a maximum charge size for a given distance from any given
human habitation. This does not address potential impacts to ecology (e.g. chimpanzees). The ESIA
does not give any indication at what sort of distances from the mine might be affected and provides
no information on the likely blasting programme that may be required at any particular site (e.g.
number, frequency and duration of blasts). The SIP has provided a little more information on
blasting, indicating that there will be a single blast per day (during the August Paris workshop CBG
indicated that there are likely to be between 1-2 blasts per day). However, the SIP also states that
the number or size of blasts will not increase over the existing levels. However, it is not explained
how production levels can increase, whilst the level of blasting remain the same.
The SIP provides the following example scenario based on the requirement to keep noise levels in
villages to below 115 dBmax: “if a blast is to occur at 3 km from a village, the maximum allowable
charge mass per delay would be 50 kg (driven by the airblast requirements). In order to meet this
limit, the 10 tonnes of explosive material should be distributed among 200 equal charges, each
separated temporally by a delay (10,000 kg / 50 kg = 200 charges).” Based on this, it appears that
115 dBmax at 3 km distance is the minimum expected noise levels and away from villages, higher
noise levels will occur at greater distances (due to increased charge sizes). In reality, the noise
received at any given point is affected significantly by wind speed, wind direction, low clouds
(reflection of air waves), atmospheric pressure, and air temperature. Also the burial of the charges
can have more effect than the splitting into smaller maximum instantaneous charges. Therefore, the
proposed method of calculating charge mass to achieve certain noise limits is not a practical
possibility. This is relevant to both human and biodiversity receptors.
Based on published studies of effects of noise impacts to wildlife, disturbance can be predicted at
levels exceeding 65 dBmax. Therefore, blasting is likely to pose a high risk to mammal populations,
including chimpanzee. This risk has not been quantified or addressed in the ESIA. The BAF states
that the BAP will include measures to reduce or eliminate blasting impacts. However, based on the
information currently available, the feasibility to eliminate disturbance impacts from blasting to
biodiversity remains unclear, although it is understood that CBG is exploring the options for nonblasting ore extraction techniques. The use of non-blasting techniques (surface mining) should be
considering as a mitigation measure to reduce noise impacts to sensitive ecological receptors as well
as human receptors.
Hydrology
Impacts on ecology from changes in hydrology at Sangarédi has not been assessed by the ESIA. An
assessment of impacts on ecology is excluded from the ESIA due to the hydrology chapter concluding
a positive impact. However, there is currently a lack of hydrological and hydrogeological data which
limits the ability of the ESIA to quantify of the likely location and significance of potential impacts.
The assessment of impacts on groundwater by the ESIA was only performed in a qualitative manner
for the Kamsar site, with no assessment conducted for the Sangarédi site and general concession
area due to the insufficient baseline and monitoring data available (see Section 8.3 for a detailed
review of the hydrology section of the ESIA).
Environmental and Social Due Diligence – Technical Report
96
CBG Bauxite Mine Expansion Project, Guinea
Impacts on the river Cogon or other watercourses from abstraction is not assessed. The ESIA
mentions the possibility of a 13 km pipeline, however based on discussions from the August Paris
workshop, it is understood that water for dust suppression will continue to be taken from CBG’s
reservoir and distributed using tankers and that a pipeline will not be required.
Impacts on the river Cogon or other watercourses from abstraction is not assessed. The ESIA
mentions the possibility of a 13 km pipeline but does not assess potential impacts from its
construction. Based on discussions from the August Paris workshop, it is understood that water for
dust suppression will continue to be taken from CBG’s reservoir and distributed using tankers and
that a pipeline will not be required.
The TBC CHA highlights the potential of changes in hydrology to impact critical habitat, including
threatened and endemic species of fish, amphibians and reptiles. It is understood that the Company
is initiating a much expanded physical sampling program to include groundwater and will produce a
water balance study as part of a wider Water Management Plan (WMP). The Project is clearly reliant
on a thorough and well implemented WMP to meet IFC PS6 requirements. However, this issue is also
detailed in the BAF for inclusion in the BAP, which should enable the key water-related biodiversity
risks associated with the Project to be addressed.
11.2.5 Mitigation
Mitigation Hierarchy
A range of mitigation measures are proposed in Chapter 4 of the ESIA. There is no explicit mention
of the mitigation hierarchy and how this may have been included in the Project design. With
exception of an example of a reduced dredging area, there is little indication that any concrete
avoidance measures in relation to biodiversity sensitivities were taken. It is understood that the use
of surface miners instead of blasting to reach deposits located near villages, roads or other structures
is being considered by the Project. However, there is no indication:

that surface miners were considered in areas of biodiversity sensitivity to reduce impacts:

whether avoidance of exploitation of specific deposits was considered; and

whether increased set back distances were considered to reduce impacts to critical habitat.
It is understood that avoidance measures will be further assessed within the Project BAP. Appendix
10.2 of the BAF details that avoidance measures will be taken in relation to direct loss of gallery
forest, woodland, wooded grassland and bowal grassland if required. It also suggests potential
avoidance of key habitats for chimpanzee.
ESMP
Chapter 4 of the ESIA sets out proposed mitigation measures including those to be employed during
vegetation clearance and measures to avoid water, air and light pollution.
Within Chapter 4 of the
ESIA, many of the mitigation measures do not represent firm commitments as they use phases such
as ‘consider the use of’ and ‘where possible’. The wording for many of the measures included within
the ESMP has been tightened, however a small number of items remain non-committal. The
robustness of the measures are weakened by the absence of control limits in relation to mitigation
measures, or the lack of measures required to achieve acceptable levels. For example, Chapter 4
quotes injurious noise thresholds for cetaceans. In the ESMP, the commitment merely states that
‘underwater noise will be reduced to a minimum during dredging or quay construction’. There is no
information on what noise levels are acceptable and how this will be achieved or monitored.
Whilst many of the mitigation measures included in Chapter 4 and the ESMP have value, there is a
lack of measures of sufficient robustness to provide a significant reduction of impacts. For example,
the noise chapter discusses set-backs for blasting near to villages, but none are proposed for
Environmental and Social Due Diligence – Technical Report
97
CBG Bauxite Mine Expansion Project, Guinea
significant ecological receptors (e.g. chimpanzee nest areas). As many of the gallery forest areas are
very narrow, several areas of this habitat are entirely contained within the likely impact zone from
operations.
The effectiveness of the proposed mitigation measures in most instances will depend how each one
will be implemented at each mining area. For example, the location of lighting, soil management,
clearance measures. Therefore it is recommended that site-specific construction management plans
(CMP) are produced for each new mining area that incorporate the mitigation commitments in
relation to biodiversity (among other environmental and social aspects). The CMPs should be
produced with expert input from suitably qualified ecological experts.
Whilst the main mitigation implementation mechanism for biodiversity will be the BAP, it is likely that
the ESMP will need to be reviewed following the production of the BAP to ensure that the two
documents are consistent. Given the live status of the ESMP this should be possible.
Reinstatement
The CBG 25 Year Long Term Mining Plan states that ‘CBG has a rehabilitation programme that
involves smoothing the slopes left by mining followed by reforestation of those areas exploited. The
objective is to maintain one hectare rehabilitated for each new hectare mined. There remains
however, a considerable backlog from mining in previous years, particularly for the Sangarédi deposit
that is still being mined.
A total of 1,215 ha await rehabilitation over past mining areas, in addition to some 320 ha devoted
to infrastructure.
It is understood that a programme of restoration has been developed to restore the backlog along
with new areas of mining during the lifetime of the Project, finishing in 2027. The restoration is due
to be completed prior to the initiation of exploitation of the North Cogon concession; annual
reinstatement targets to address the backlog will be determined on an annual basis. Whilst mined
areas are awaiting restoration, there is the risk of impacts to biodiversity because of increased
runoff, erosion, sediment deposit in surface water bodies, thereby emphasising the importance that
current reinstatement backlogs are addressed.
It is understood that approximately 50 % of the restored areas will be planted to create “natural
habitats” and 50 % restored to agricultural land including cashew plantations and grazing. It is not
clear whether the natural habitats created will be equivalent to the natural habitats lost. The
reinstatement of mining areas is a complex issue that needs to balance the needs of local
communities as well as biodiversity. The ownership and long-term management of the restored areas
is currently unclear. However, there is an overarching commitment to cause no net loss of natural
habitats in the BAF and Appendix 10.2 of the BAF refers to offsets in relation to bowal and woodland
habitats. The BAF section on Habitat Action Plans (HAPs) includes restoration guidance. The
restoration guidance should be compiled in accordance with IFC’s EHS Guidelines for Mining.
Following restoration, there is the potential a net loss of natural habitats and any residual impacts
would need to be included within the offset strategy. This may include the principle of “like-for-like,
or better” whereby habitats of higher diversity may be favoured over habitats of lower diversity.
Compensation
Due to the nature of the Project and the large areas of natural and critical habitat likely to be
affected, in order to meet IFC PS6 requirements of no net loss (and a net gain for critical habitat),
the ESIA relies heavily on the recommendation for a series of management plans. The ESIA provides
recommendations that management plans are produced to covers the following areas:

mine rehabilitation;
Environmental and Social Due Diligence – Technical Report
98
CBG Bauxite Mine Expansion Project, Guinea

management plans for road access in relation to hunting and firewood;

habitat protection plans (forest and bowals);

protection of the Cogon Corridor; and

protection of the Rio Nuñez estuary.
It is understood that CBG do not own any land within the concession (only the right to mine bauxite).
Therefore without additional feasibility studies, it is not possible to confirm that the proposed
protection of the Nunez estuary, gallery forests or Cogon corridor are deliverable. The residual
impact assessment contained with the ESIA has assumed that the proposed management plans for
these areas are implemented successfully. Given the complexity and number of the critical and
natural habitat features affected, combined for the need of third party involvement, this is potentially
overly optimistic. Therefore, the ESIA’s residual impact assessment of a Medium Positive impact for
many of the habitats and species appears to be unfounded and it is important that the residual
impacts are reassessed as committed to in the BAF.
11.2.6 Monitoring
The mitigation measures described within Chapter 4 of the ESIA and the ESMP do not include a clear
monitoring and control plan for either the construction or operational phase, with limited reference to
monitoring of certain key species. However, this has been largely addressed by the BAF (see Section
11.4 below).
11.3 Critical Habitat Assessment
As already highlighted, following the Paris workshop, CBG commissioned TBC to complete a new
CHA. The TBC CHA is considered by Ramboll Environ to have been completed in accordance with IFC
PS6 and largely addresses the shortcomings of the ESIA’s assessment of critical habitat described in
Section 11.2. Due to the different methodologies employed, the conclusions of the TBC CHA differ to
that of the ESIA. It is understood that the TBC CHA will take primacy going forward (e.g. to inform
the Project BAP).
The TBC CHA concludes that that the Project is situated in critical habitat due to the presence of 16
highly threatened and/or restricted-range terrestrial species / subspecies, including:

West African chimpanzee Pan troglodytes verus, west African red colobus Procolobus badius
temminckii and the Critically Endangered reptiles Cynisca cf oligopholis and Hemidactylus
kundaensis.

Five species qualify for Tier 1 critical habitat and a further 11 species/subspecies for Tier 2 critical
habitat.

Eight marine species and the presence of highly threatened mangrove ecosystems qualify the
Nunez estuary as Tier 2 critical habitat.
A number of Internationally Recognised Areas were also assessed to represent critical habitat:

Rio Kapachez Ramsar site and Important Bird Area (IBA);

Iles Tristao Ramsar site and IBA

Boulléré KBA; and

Kamsar KBA (located approximately 8 km upstream of Kamsar Port and has been designated due
to significant populations of chimpanzee and globally threatened species purple marsh crab
Afrithelphusa monodosa (IUCN EN);
The assessment completed by TBC is based on the existing available data. The CHA states that
further critical habitat-qualifying biodiversity may be present in the area of assessment. The global
Environmental and Social Due Diligence – Technical Report
99
CBG Bauxite Mine Expansion Project, Guinea
ranges of 12 Critically Endangered and Endangered species (1 crocodile and 11 marine fish) overlap
the area of assessment and would qualify as critical habitat if confirmed to be present. The CHA also
notes that the Île Alcatraz et Île du Naufrage candidate marine IBA would qualify as critical habitat if
its status is confirmed.
One area where the TBC CHA differs from the ESIA is in relation to gallery forest. Gallery forest is not
considered by the TBC CHA to be critical habitat under criterion 4, although the TBC CHA suggests
that a finer-grained habitat classification and assessment of loss rates could change this evaluation.
However, it is understood that as a precautionary measure, CBG will treat all gallery forest as critical
habitat and included in the Project’s BAP as such.
The CHA makes a different conclusion of which habitats represent critical habitat to that contained in
the ESIA, with a number of additional habitats that should be considered high priority, but only
where they support species that trigger critical habitat. This includes all freshwater aquatic habitats,
along with some areas of woodland, wooded grassland, bowal and non-bowal grassland. The CHA
also confirms six types of natural habitat: gallery forest; wooded grassland and woodland; bowal
grassland; non-bowal grassland; beaches, sand banks and mud flats; and freshwater aquatic
habitats.
Although unlikely to significantly affect the conclusions of the CHA, there are a small number of
points which Ramboll Environ would welcome some additional clarification:
1. The TBC CHA’s introduction mentions additional criteria for critical habitat to be applied on a
case-by-case basis (e.g. such as areas required for the reintroduction of threatened species).
However, it is not clear how these criteria have been included in the CHA.
2. The TBC CHA does not include an assessment of biome-restricted bird species, which are
highlighted by the ESIA to be of significance.
3. The baseline surveys for migratory birds at Kamsar were based on a single survey. A number
of species were recorded in numbers approaching 1% thresholds (ringed plover, whitefronted plover and gull-billed tern) and therefore Ramboll Environ recommends that these
should be in the list of additional potential critical habitat triggers.
The CHA states that due to inadequate baseline data there is a significant risk that many potentially
threatened plant and amphibian species may be present that have not been included in the
assessment. In response, the BAF states that additional amphibian surveys are scheduled for
October and November 2015 (Appendix 10.1 of the BAF). The BAF suggests that additional plant
surveys will be delayed until before vegetation clearance. Ramboll Environ recommends that the
plant surveys are brought forward to address the gap identified by the TBC CHA.
The CHA also states that due to data resolution and time constraints, it was not possible to map the
location of critical habitat in detail and that this should be a priority task for mitigation planning. The
BAF states that additional fieldwork will be completed to provide a better understanding of the
location of different habitat types and priority species. However, it does not include a specific
commitment to map the location of critical habitat features in proximity of the mining areas and
ensure that areas supporting critical habitat qualifying features are clearly marked on Project maps
and design diagrams, as recommend in the CHA. The production of clear constraints maps showing
location of critical habitats is recommended by Ramboll Environ as an output from the BAP.
The CHA included a gap analysis in the current biodiversity baseline contained within the ESIA and
provided the following assessment of priority for additional studies:

Status of Endangered primates – High Priority

Presence and status of Endangered purple marsh crab – High Priority
Environmental and Social Due Diligence – Technical Report
100
CBG Bauxite Mine Expansion Project, Guinea

Presence of critical habitat qualifying plant species – High Priority

Status of Critically Endangered and endemic lizard species – High Priority

Presence of Endangered amphibian species – High Priority

Status of critical habitat qualifying marine species - Medium Priority

Presence and status of marine turtle nesting sites - Medium Priority

Status of mangroves - Medium Priority

Status of benthic flora and fauna within the estuary - Medium Priority (already commissioned)

Presence of Endangered vulture colonies - Medium Priority

Presence and status of bats in mangroves and other habitats - Medium Priority

Status of and impacts on CH-qualifying and potentially qualifying groupers and elasmobranchs
(sharks and rays) - Medium Priority
CBG has commissioned additional fieldwork that is currently being implemented. This is discussed
further in the following section in relation to the BAF.
11.4 Biodiversity Action Framework
During the August Paris workshop it was agreed that the BAF would be produced that would take into
account the findings of the TBC CHA.
The BAF describes the scope of the BAP that will be the main implementation mechanism for
mitigation in relation to biodiversity. The BAF states that the BAP will manage additional baseline
studies, refine impact assessments, review the existing mitigation commitments, include an offset
strategy and detail a long-term monitoring strategy. According to the BAF, the BAP will also include
its own stakeholder engagement programme to address biodiversity and ecosystem services. This
provides a logical process to address the gaps in the ESIA discussed in previous sections. The BAF
states that CBG is committed to meet IFC PS 6, and in particular causing no net loss to natural
habitats, a net gain in critical habitats and the requirements in relation to internationally recognized
areas. Overall, Ramboll Environ considers that if the BAP is developed and implemented as set out in
the BAF, it has the potential to manage the Projects risks in relation to biodiversity and meet the
requirements of IFC PS6. The following three sections provide some comments on the detail of the
BAF. However, it is not clear how the Project’s biodiversity control framework, which includes
numerous other plans, as set out in the BAF, will be structured and managed. It is recommended
that this is clarified and set out clearly in the BAP.
As indicated above, provided the BAP is developed and implemented thoroughly, it has the potential
to address many of the Project risks highlighted in previous sections of this report. However, there
are also outstanding issues that have not been included in the BAF. Therefore, it is recommended
that the scope of the BAP should be reviewed and agreed with Lenders prior to its development.
11.4.1
Management System
Section 7 of the BAF describes how the BAP will interface with other key management plans (e.g.
ESMP, SEP, RAP) and attempts to describe the Project’s biodiversity control framework. However, it
is not obvious from this section how the BAP will fit within the Company’s overall environmental
management system. It is recommended that this is set out more clearly in the final BAP. It will also
likely require minor amendments to other management plans to ensure that they also set out their
interface with the BAP. The BAF states that CBG will name a biodiversity specialist to coordinate and
oversee the biodiversity-related tasks. The appointment of an internal dedicated Project biodiversity
manager is considered by Ramboll Environ as a very positive action.
Environmental and Social Due Diligence – Technical Report
101
CBG Bauxite Mine Expansion Project, Guinea
11.4.1 Additional Baseline Studies
The previous sections of this ESDD report discusses limitations of the baseline surveys included
within the ESIA. Many of these limitations are recognised by the ESIA, which makes
recommendations for additional fieldwork (see section 11.2). The TBC CHA also makes a gap analysis
of the ESIA baseline information and provides additional recommendations for surveys (see Section
11.3). According to the BAF, some additional field work has already been commissioned to be
completed in October and November 2015. This includes:

a marine benthic survey of the area to be dredged (as well as the disposal site) (details are
included in Appendix 8.3 of the SIP);

primate surveys;

reptiles, including Kunda half-toed lizard;

Pinto's puddle frog;

purple marsh crab; and

endangered vultures.
These additional surveys aim to fill many, but not all of the identified gaps in the baseline
information provided by the ESIA as discussed above. However, the need for all of the surveys
recommended in the ESIA and TBC CHA is debatable (e.g. bat surveys). Therefore, it is
recommended that the BAP provides a clear and systematic assessment of the remaining survey
requirements of the Project. The initial results of additional surveys currently underway may inform
this assessment. It is recommended that the design and implementation of any additional surveys
are closely related to the design of mitigation measures for critical and natural habitats, as well as
long-term monitoring requirements to inform an adaptive management programmes. As part of the
BAP’s assessment of survey requirements, it is suggested that the following are considered:

CBG have currently committed to additional plant surveys to be delayed until before vegetation
clearance, which may be 20 or more years away. This is likely to limit the ability of the Company
to address any priority species that may be found. Therefore it is suggested that these surveys
are brought forward.

There are potential significant conservation benefits from additional studies to be completed
within the Nunez estuary, especially if these could be co-ordinated with other projects in the area
as part of efforts to address cumulative impacts. This might include additional studies on marine
fish, cetaceans and wintering birds. In relation to wintering birds, additional studies may confirm
qualification of Nunez estuary in meeting IBA criteria.

Freshwater fish surveys to cover tributaries previously not surveyed and targeted surveys to
improve understanding of distribution and populations of threatened and endemic / range
restricted fish species present at Sangarédi. Confirmation of species identification through genetic
analysis may be useful.
11.4.2 Biodiversity Offsets
The BAF includes a commitment to develop a biodiversity offset strategy to include both on-site and
off-site offsets. The BAF sets out important principles, in accordance with international guidelines, to
which the Project’s offset strategy will meet. Biodiversity offsets have inherent delivery risks. For
example, they are likely to require third party involvement and affect land outside the control of
CBG. However, biodiversity offsets also provide potential opportunities to deliver large gains for
biodiversity. In particular the BAF mentions the potential external offsets involving the development
of a protected area in the Bafing region of Guinea (WCF 2015) where an estimated 4,000
chimpanzees currently live. The development of a suit of metrics to measure losses and gains will be
Environmental and Social Due Diligence – Technical Report
102
CBG Bauxite Mine Expansion Project, Guinea
important to demonstrate that net gains in critical habitat are achieved. According to the BAF, an
offset feasibility study will be included in the BAP. This should provide a better understanding on the
delivery risks associated with biodiversity offsets, although it is recognised that it is likely to be many
years before the success of any offset programme can be demonstrated.
It is recommend that the BAP will also need to consider natural habitats as part of the biodiversity
offset strategy if the requirement for no net loss is to be met.
11.4.3 Internationally Recognised Areas
The BAF includes consideration of IRA’s within appendix 10.2. This identifies the potential for
Boulléré KBA to be enhanced and protected in collaboration with GAC, which would be in accordance
with requirements of IFC PS6 in relation to IRA’s. It is recommended that Rio Kapachez Ramsar site
is also included within consideration of the BAP. Although impacts to the Ramsar site may not result
from the Project, due to its proximity to the Nunez estuary it potentially provides opportunities for
additional conservation programmes that should not be discounted at least until the biodiversity
offset feasibility study is completed.
11.4.4 Monitoring
Section 9 of the BAF details an expanded monitoring programme over and above that provided by
the ESIA and ESMP (although the detailed monitoring programme is still being assessed for inclusion
in the final BAP). This will include monitoring of additional key species. The BAF includes important
commitments that the monitoring plans will include control mechanisms, threshold values and a
mechanism to adapt the approach based on results. Although implied, the BAF does not specify that
the monitoring will be designed to demonstrate no net loss of natural habitats and a net gain in
critical habitats (including the underlying species that trigger critical habitat).
Environmental and Social Due Diligence – Technical Report
103
CBG Bauxite Mine Expansion Project, Guinea
Table 10: Summary of Findings, PS6
ID
Aspect
Issue Description
Phase
Standard2
IESC Recommendations
037
Relevant
Standard,
Guidance and
Legislation
The ESIA does not provide a comprehensive list
of nationally protected species found within the
Project Area, or an assessment of whether the
relevant national legislation can be met.
Therefore, it is not possible to evaluate whether
the Project can comply with applicable national
laws as required by IFC PS6, although it
appears that CBG appreciate this issue.
All
PS6
CBG to compile a list of protected
species found within the Project
Area and evaluate whether the
Project can comply with the relevant
national legislation. Incorporate any
additional mitigation measures
required to meet national legislation
into the ESMP or BAP.
Assessment
Methodology
The Valued Environmental Components (VECs)
identified and assessed in the ESIA have been
updated by the Project’s CHA and ESR.
Therefore, it is important that future
assessment (e.g. Project BAP, CIA etc.),
focusses on the updated list of VEC’s. To this
end, the BAF has incorporated the additional
species identified by the CHA.
All
Ecosystem
Services (ES)
The ESR identifies ES that are not assessed in
the ESIA. The ESMP does not appear to have
been updated to cover additional ES. The BAF
states that the Project control framework will
include a biodiversity and ecosystem services
working group. However, it is not clear whether
this group will address the additional ES
identified in the ESR.
All
Internationally Recognised Areas (IRAs) have
been partially identified in accordance with IFC
PS6 and are valued as high importance.
However, the ESIA does not discuss how the
Project Area may contribute towards
maintaining the integrity of nearby IRAs or their
qualifying features and potential impacts to
All
038
039
040
Internationally
Recognised
Areas (IRAs)
PS6
PS6
PS6
Ensure that future assessment (e.g.
Project BAP, CIA etc.), focusses on
the updated list of VEC’s.
Include all priority ES, as identified
by ESR in the TOR for the
biodiversity and ecosystem services
working group. This group should
assess the impacts on ES and
develop any additional mitigation
measures that might be required to
be included within the Project’s
ESMP or other relevant plans.
Ensure that BAP fully considers IRAs
and demonstrably satisfies the
requirement of PS6 in relation to
IRAs. This should include:
Assess importance of Project Area in
maintaining integrity of IRAs.
Significance
Moderate
(It would be
possible to
implement
recommendation
through the BAP.
Falling to Low if
recommendation
implemented)
Low
(falling to
Negligible if
recommendation
implemented)
Moderate
(falling to Low if
recommendation
implemented)
Moderate
(Falling to Low if
recommendation
implemented)
Environmental and Social Due Diligence – Technical Report
104
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard2
IRAs have not been assessed. This has already
been incorporated into the BAF to be
implemented as part of the BAP.
IESC Recommendations
Significance
Update impact assessment for all
relevant IRAs
Develop measures to enhance and
protect IRAs
Include IRAs in consideration of
offsets and CIA.
041
Critical Habitat
Assessment
(CHA)
The updated TBC Critical Habitat Assessment is
considered to have been completed in
accordance with IFC PS6. There are small
number of points that would benefit
clarification. The CHA may need to be refined as
additional fieldwork results become available.
All
PS6
Ensure that areas supporting critical
habitat qualifying features are
clearly marked on Project maps and
design diagrams, as recommend in
the CHA.
The BAF does not include a commitment to map
the location of critical habitat features within
the mining areas and ensure that areas
supporting critical habitat qualifying features
are clearly marked on Project maps and design
diagrams, as recommend in the CHA.
042
Baseline
Conditions
There are discrepancies between additional
survey requirements identified by the ESIA, the
CHA and those that are currently being
undertaken to fill identified gaps.
Refine CHA once additional fieldwork
results are available. This can be
completed as part of the Project
BAP.
All
PS6
It is recommended that the BAP
includes a systematic review of
additional survey requirements.
Additional studies should be
designed and implemented in
relation to mitigation measures for
critical and natural habitats and
form the basis of long-term
monitoring.
TORs for additional studies should
be provided for review by the
Lender’s IESC.
Moderate
(Once additional
fieldwork results
are available and
incorporated into
an updated CHA,
as well as Project
mapping this
would fall to Low)
High
(Falling to Low
once the survey
requirements
have been
systematically
assessed, existing
surveys are
completed and
their results
assessed)
Environmental and Social Due Diligence – Technical Report
105
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard2
IESC Recommendations
043
Invasive
Species
The adequacy of control mechanisms for
invasive species will need to be reviewed as
part of the Lender’s monitoring programme.
All
PS6
CBG to provide details on invasive
species control mechanisms for
review once they are available. The
restoration plans are to be reviewed
as part of the Project BAP. This
should include consideration of
invasive species risk.
Impact
Assessment:
Cumulative
Impacts
CBG has committed to consider cumulative
impacts in line with PS1. This will be considered
as part of the Project BAP. However, at the
current time there is little information to assess
how this will be achieved.
All
Impact
Assessment:
Quantification
of impacts to
habitats and
species
Insufficient quantification of impacts to natural
and critical habitats (including priority species)
in the ESIA. According to the BAF, this will be
addressed by the Project BAP.
All
Impact
Assessment:
Dredging
Impacts from dredging have not been assessed
by the ESIA. According to the BAF, this will be
addressed by the Project BAP.
044
045
046
All
PS6
PS6
PS6
CIA to be included in the Project BAP
and taken into consideration in
mitigation measures and offsets.
Project BAP needs to refine impact
assessments to habitats and
species, including from indirect
impacts. This should include
appropriate metrics by which to
measure no net loss. It is
recommended that the scope and
methodologies employed in the
additional impact assessments are
agreed in advance with the Lender’s
IESC.
Review results from benthic surveys
and assess potential impacts as part
Significance
Moderate
(Falling to Low, if
control
mechanisms are
demonstrated to
be adequate)
High
(possibly falling to
Moderate or Low
although there is
an inherent
uncertainty
because CBG will
be reliant on
collaboration with
3rd parties to
manage
cumulative
impacts)
Moderate
(Falling to Low, if
recommendation
implemented)
Moderate
Environmental and Social Due Diligence – Technical Report
106
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard2
IESC Recommendations
of BAP. Develop appropriate
mitigation measures.
047
048
049
050
Impact
Assessment:
Indirect
Impacts
Mediated
through Local
Community
Uses of
Resources
The BAF suggests that some of these issues will
be addressed through the Project’s biodiversity
control framework, including a Harvesting
Management Plan, Fisheries Management Plan
and Induced Access Plan. However, it is not
currently clear whether these will be based on
additional quantitative assessment and cover
impacts from displacement.
All
Impact
Assessment:
Marine noise
Impacts from marine noise has not been
assessed.
All
Impact
Assessment:
Air Quality
Additional air quality monitoring and modelling
needed to quantify impacts and inform
mitigation. According to the BAF, this will be
addressed by the Project BAP.
All
Impact
Assessment:
Haul Roads
The ESMP states that the Project will optimize
the mine road network in relation to
biodiversity for the Long-Term Mining Plan in
the detailed engineering phase. The BAF also
states that the BAP will consider the restoration
of mined areas and inform decisions regarding
fate of mining haul roads. However, it not clear
that it will be feasible to remove haul roads
once in place or whether the likely residual
fragmentation effects on critical habitat will be
All
PS6
PS6
PS6
PS6
Complete quantitative review of
impacts from bushmeat hunting,
fuelwood collection, induced access
and agricultural displacement as
part of the Project BAP. Residual
impacts will need to be included in
offset strategy.
Complete marine noise modelling
and develop appropriate mitigation
and control measures to be included
in ESMP / BAP. This should include
consideration of vibration piling and
marine mammal observers.
Complete additional monitoring and
modelling to quantify impacts to
natural and critical habitats from
changes in air quality to inform
appropriate mitigation and offsets.
Complete quantitative impact
assessment of fragmentation effects
of haul roads and include in offset
strategy. Complete feasibility study
of road decommissioning.
Significance
(Falling to Low if
recommendation
implemented)
High
(Due to complexity
of these issues, as
well as questions
over feasibility of
mitigation, this
issue is likely to
remain of
Moderate
significance)
Moderate
(Falling to Low if
recommendation
implemented and
appropriate
controls identified)
Moderate
(Falling to Low if
recommendation
implemented)
High
(Due to complexity
of this issue, as
well as questions
over feasibility of
mitigation, this
issue is likely to
remain of
Environmental and Social Due Diligence – Technical Report
107
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard2
IESC Recommendations
assessed for inclusion of the Project’s offset
strategy.
051
052
053
054
Impact
Assessment:
Water Quality
Significance
Moderate
significance)
Additional water quality monitoring and ecotoxicological studies needed to quantify impacts
to fish and inform mitigation. According to the
BAF, this will be addressed by the Project BAP.
All
Impact
Assessment:
Blasting
Lack of impact assessment of blasting noise on
biodiversity. Lack of feasible control mechanism
to mitigate impacts. According to the BAF, this
will be addressed by the Project BAP.
All
Impact
Assessment:
Hydrology
Lack of baseline data and modelling to assess
potential impacts to hydrology supporting
critical habitats. At the current time it is not
possible to assess feasibility to protect water
resources.
All
Mitigation
measures:
Mitigation
hierarchy
There is no explicit mention of the mitigation
hierarchy within the ESIA. Avoidance measures
are included in the BAF, to be implemented
through the BAP.
All
PS6
PS6
PS6
PS6
Water quality monitoring
programme needs to be reviewed in
light of priority species. Robust
control and management strategy
required to protect watercourses to
be developed as part of BAP.
Avoidance measures should be
considered for key catchments.
Additional studies are required to
assess potential impacts to
biodiversity and particularly
chimpanzees from blasting noise.
Robust avoidance and mitigation
measures need to be developed as
part of BAP.
Complete hydrological monitoring
and modelling to inform impact
assessment and Water Management
Plan. Measures to address issue
needs to be co-ordinated with BAP
to ensure water supplies to local
communities as well as biodiversity
are protected.
Assess feasibility of specific
avoidance mitigation measures to
avoid impacts to critical habitats
(e.g. setbacks from areas of gallery
forests) as part of BAP.
Demonstrate that the mitigation
hierarchy has been applied through
the BAP.
Moderate
(Falling to Low if
recommendation
implemented)
High
(Risk will need to
be reassessed
following the
completion of the
BAP)
Moderate
(Low following
development of a
robust WMP)
Moderate
(Falling to Low if
mitigation
hierarchy
implemented
robustly within
BAP)
Environmental and Social Due Diligence – Technical Report
108
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard2
IESC Recommendations
055
Mitigation
measures:
ESMP
Mitigation measures within the ESMP will need
to be reviewed and updated following updates
to the ecological baseline, critical habitat
assessment and review of impacts as part of
the BAP.
All
PS6
Mitigation measures within the ESMP
will need to be reviewed and
updated following updates to the
ecological baseline, critical habitat
assessment and review of impacts
as part of BAP.
Efficacy of many of the ESMP measures will
depend on site-specific implementation (e.g.
lighting control).
056
057
058
Produce site-specific construction
management plans that incorporate
the mitigation commitments with
expert ecology input.
Mitigation
Measures:
Reinstatement
Plans
Reinstatement plans only provide 50%
”natural” habitats. The restoration of mined
areas needs to balance biodiversity aims and
the needs of local communities. There is a
potential net loss of natural habitats following
restoration that will need to be included in the
offset strategy.
All
Biodiversity
Action Plan
BAP):
Management
Systems
Ramboll Environ considers that if the BAP is
developed and implemented as set out in the
BAF, it has the potential to manage the
Project’s risks in relation to biodiversity and
meet the requirements of IFC PS6. However, it
is not clear how the BAP will fit within the
Company’s overall environmental management
system.
All
BAP:
Biodiversity
Offsets
Biodiversity offsets have inherent delivery risks
partly because they require third party
involvement or and affect land outside the
control of CBG (although biodiversity offsets
also provide potential opportunities to deliver
large gains for biodiversity). The feasibility of
offsets will not be known until the completion of
PS6
PS6
Review reinstatement plans to
balance value to biodiversity and
local communities. Include residual
losses of natural habitats in offset
strategy using principle of “like for
like or better”.
The BAP should include a clear
structure to show how it fits within
CBG’s overall environment and
social management system.
The feasibility study should explore
options for biodiversity offsets in line
with international good practice.
This will need to include measures
for both natural and critical habitat.
Significance
Moderate
(Falling to Low if
recommendation
implemented)
Moderate
(Falling to Low
once the BAP has
been developed
(note that inherent
risk associated
with biodiversity
offsets is high).
Moderate
(Falling to
negligible once
BAP developed and
integrated in the
Company
Management
Systems)
High
(The risks
associated with
biodiversity offsets
can be reassessed
once the feasibility
study has been
Environmental and Social Due Diligence – Technical Report
109
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard2
IESC Recommendations
the feasibility study being completed as part of
the ESIA.
059
Monitoring
The ESIA does not provide a clear monitoring
and control plan for either the construction or
operational phase. According to the BAF, this is
to be developed as part of BAP.
Significance
completed as part
of the BAP)
All
PS6
A detailed monitoring framework
should be developed that is aligned
with the aims of the BAP, to provide
long-term monitoring to inform the
adaptive management of key
biodiversity features and
demonstrate no net loss of natural
habitats and a net gain in critical
habitats (including the underlying
species that trigger critical habitat).
Moderate
(Falling to
Low/negligible if
recommendation
implemented)
Environmental and Social Due Diligence – Technical Report
110
CBG Bauxite Mine Expansion Project, Guinea
12. PERFORMANCE STANDARD 7: INDIGENOUS PEOPLES
The applicability of PS 7 should be “…..established during the environmental and social risks and
impacts identification process” (PS 7). The ESIA Report does not contain an analysis to determine
whether this PS would be applicable throughout the ESIA process. Such an analysis should be
carried out very early in the ESIA process i.e. during the scoping phase or as part of social
baseline preparation and would involve actions such as:

Checking official documents;

Consultation with social experts familiar with the ethnic group characteristics and distribution
in the country; and

Consultation with key local-level leaders.
The result would be an ESIA decision (setting no precedent for other future situations) confirming
the presence or absence of indigenous peoples in the Project Area of Influence.
During the Paris workshop, it was confirmed by an IFC Social Specialist, with knowledge of both
Guinea and the mine expansion Area of Influence, that no indigenous people inhabit or occupy
such territory temporarily. Ramboll Environ has found no evidence to contradict CBG’s view
during its due diligence review.
Environmental and Social Due Diligence – Technical Report
111
CBG Bauxite Mine Expansion Project, Guinea
13. PERFORMANCE STANDARD 8: CULTURAL HERITAGE
The applicability of PS 8 to the Project is confirmed in the ESIA by the inclusion of cultural
heritage in both the social baseline and social impact chapters and the mitigating measures
contained in the social impact chapter and in the ESMP.
The fundamental requirement of this performance standard is the identification and mitigation of
project impacts on cultural heritage, as defined in IFC Performance Standard 8, including:
“tangible forms of cultural heritage, such as tangible moveable or immovable objects, property,
sites, structures, or groups of structures, having archaeological (prehistoric), paleontological,
historical, cultural, artistic, and religious values; unique natural features or tangible objects that
embody cultural values, such as sacred groves, rocks, lakes, and waterfalls; and certain
instances of intangible forms of culture that are proposed to be used for commercial purposes,
such as cultural knowledge”.
With regard to cultural heritage protection objectives, IFC Performance Standard 8 states:
“The client is responsible for siting and designing a project to avoid significant adverse impacts to
cultural heritage. Where a project may affect cultural heritage, the client will consult with
Affected Communities within the host country who use, or have used within living memory, the
cultural heritage for long-standing cultural purposes. The client should not remove, significantly
alter, or damage critical cultural heritage. In exceptional circumstances when impacts on critical
cultural heritage are unavoidable, the client will use a process of Informed Consultation and
Participation (ICP) of the Affected Communities as described in Performance Standard 1 and
which uses a good faith negotiation process that results in a documented outcome. The client will
retain external experts to assist in the assessment and protection of critical cultural heritage.”
The Standard therefore covers requirements regarding:

protection of cultural heritage in project design and execution;

procedures for chance finds;

consultation;

removal of cultural heritage;

critical cultural heritage; and

the project’s use of cultural heritage.
PS8 also requires that “….if there is a chance of impacts to cultural heritage, the client will retain
competent professionals to assist in the identification and protection of cultural heritage”. The
composition of the ‘cultural heritage’ team included competent professionals and was in line with
this PS 8 requirement.
This section identifies those areas of concern where gaps and/or deficiencies are present based
on a review of the ESIA, review of all available documentation of relevance to Cultural Heritage
considerations together with targeted enquiries carried out during the site visit 25-30 August
2015.
While there are some deficiencies with the letter of the Performance Standard, we believe that
CBG’s understanding and commitment exists to remedy these in due course and in accordance
with the recommendations set out in Table 11. In particular, there is a key requirement to
develop and publish the Cultural Heritage Management Plan (CHMP), including a Chance Finds
Procedure, prior to any further exploration and development activity.
Environmental and Social Due Diligence – Technical Report
112
CBG Bauxite Mine Expansion Project, Guinea
Recommendation
Ensure that CBG acquires the necessary capacity to develop an appropriate CHMP including
Chance Finds Procedure prior to development of the mine expansion activities.
13.1 Legislative context and international standards
The ESIA clearly defines the standards used and the rationale behind the use of specific
standards. The following are considered by the ESIA:
Guinean legislation refers to the handling of tangible heritage in its Mining Code, in Article 111,
which stipulates that “No prospecting, exploration, or exploitation of Mine or Quarry Substances
can begin on a surface within a radius of one hundred (100) meters: around properties
surrounded by walls or similar enclosures, villages, settlements, wells, religious buildings,
cemeteries and sites considered sacred, without the consent of the owner (...)”.
In general terms, it is apparent that the broad provisions of the following have also been
followed:

UNESCO Convention for the Safeguarding of Intangible Cultural Heritage, 2003

ICMM Sustainable Development Framework:
Principle 3. Uphold fundamental human rights and respect cultures, customs and values in
dealings with employees and others who are affected by our activities

Ensure that all relevant employees, including security personnel, are provided with
appropriate cultural and human rights training and guidance

Respect the culture and heritage of local communities, including indigenous peoples
Principle 4: Implement risk management strategies based on valid data and sound science.

Consult with interested and affected parties in the identification, assessment and
management of all significant social, health, safety, environmental and economic impacts
associated with our activities.
OECD Guidelines for Multinational Enterprises

Carry out risk-based due diligence to identify, prevent and mitigate actual and potential
adverse impacts

Avoid causing or contributing to adverse impacts on matters covered by the Guidelines,
through their own activities, and address such impacts when they occur

Seek to prevent or mitigate an adverse impact where they have not contributed to that
impact, when the impact is nevertheless directly linked to their operations, products or
services by a business relationship.
These have been supplemented by other international standards as follows:

EHS Guidelines for Mining, 2007

EHS Guidelines for Railways and

EHS Guidelines for Ports
Recommendation:
Ensure that the development and implementation of the CHMP explicitly addresses all relevant
national and international standards and integrates best practice guidance.
13.2 Categories of cultural heritage
PS 8 makes a very clear distinction between tangible and intangible cultural heritage. It also
distinguishes critical cultural heritage from other types of cultural heritage. The ESIA does not
Environmental and Social Due Diligence – Technical Report
113
CBG Bauxite Mine Expansion Project, Guinea
consistently abide by the PS 8 categorisation. In fact, the term ‘critical cultural heritage’ does not
appear and no cultural heritage items are classed as being critical cultural heritage (this may be
because there are none, but this has to be stated clearly with justification not just inferred from
the ESIA).
The discussion of cultural heritage items and likely impacts focuses almost exclusively on tangible
cultural heritage, namely ‘sacred sites’ including genie (spirit) areas and burial places, and
archaeological sites. It does not systematically consider all categories of tangible cultural
heritage: there is cursory mention of the remains of old villages in very poor condition and hence
considered to be of low importance in the study area (mine concession). There is little
consideration of intangible cultural heritage beyond a mention of the values and practices
associated with the use of sacred sites.
Finally, there is no discussion or confirmation of whether there are mine expansion activities that
may occur within the buffer zone and/or boundaries of a legally protected area established for
cultural heritage purposes.
However, since the ESIA report proposes that the baseline studies conducted to date should be
considered as a first step in the evaluation of local cultural practices linked with the sites, the
important next step is to ensure that these are fully developed and implemented as part of the
Cultural Heritage Management Plan.
Recommendation:
The baseline studies capture the key cultural heritage assets and values present in the
concession area. As part of ongoing studies in the CHMP, similar studies to be carried out at the
railway sidings and Kamsar port development site will enable sufficient characterisation of any
cultural heritage assets present and appropriate management measures to be implemented.
While it is understood that there are no cultural heritage protected areas within the mine
expansion zone, additional confirmation is required to the effect that no mine expansion activities
will occur within the buffer zone or boundaries of any legally protected areas established for
cultural heritage purposes.
13.3 Baseline Coverage of the mine expansion, rail network and port developments
A key generic requirement of PS 8 is that, “…..the client will identify and protect cultural heritage
by ensuring that internationally recognized practices for the protection, field-based study, and
documentation of cultural heritage are implemented”. Also, “The client is responsible for siting
and designing a project to avoid significant adverse impacts to cultural heritage”. For both of
these aims to be achieved there must be a sound baseline knowledge of the location, type and
features of each known item of critical cultural heritage and non-critical cultural heritage.
Baseline studies of cultural heritage were only undertaken for the mine concession area since it is
considered that the additional land take for development of the rail network and the factory/port
areas is not likely to have a significant cultural heritage impact. The baseline survey used simple
surface prospection methods to identify numerous new sites and finds of archaeological
significance. As such, the survey provides a good indication of the archaeological potential of the
area. No survey was carried out on the railway although recommendations are made for local
community consultation.
Despite the lack of baseline information for the rail network and factory/port areas, an ‘indicative’
impact assessment has been provided for impacts in the areas likely to be affected by the mine
expansion. As a result, potential future impacts on cultural heritage assets in these areas have
not yet been assessed, nor are there any management measures proposed.
Environmental and Social Due Diligence – Technical Report
114
CBG Bauxite Mine Expansion Project, Guinea
Whereas further studies for the rail network and factory/port zones are recommended in the
ESIA, all Project development zones should have been treated in a similar way and included
together in the ESIA. At present, in the early stages of FEL-3, it may be that design and siting
options are being considered for the non-surveyed areas. This poses a risk of additional costs
should an option need to be amended due to a future survey identifying an item of critical
cultural heritage.
Recommendation:
Develop and implement a CHMP to include baseline assessment and impact management in all
Project areas not surveyed to date. This Plan should interface with the Stakeholder Engagement
Plan to ensure effective local community consultation.
13.4 Cultural heritage impact assessment
Community surveys around the identified cultural heritage sites and within a 500m zone from the
future deposits to be mined were used to evaluate the importance of these sites to the local
communities. The degrees of importance attributed are necessarily qualitative – the report
suggests that investigation at a finer level of detail could lead to reassessment of the level of
importance.
Community consultation appears to have been used effectively to understand the decisions made
by the communities to agree to have their sites lost or, on the contrary, their desire to preserve
them or even possibly resume their practices on the site or a replacement site with equivalent
characteristics. The ESIA provides clear evidence that the views of the local community have
been fully taken into account in the assignment of sites to the categories of whether or not, and
to what extent, any particular site can be moved or destroyed. Emphasis is placed on community
consultation and recommendations are made in the report to ensure that the process of
negotiation and consultation implemented to date are continued into the Project operations.
Despite the absence of detail regarding intangible cultural heritage, the acknowledgement and
use of customary practices and procedures throughout the survey is positive. It was emphasised
during subsequent discussion with CBG that this approach is already an inherent part of the way
cultural heritage assets and issues are being addressed. It remains to formalise these procedures
in the CHMP to ensure consistency and replicability of this approach.
Recommendation:
Provide a road map in the CHMP to guide cultural heritage asset identification and assessment
drawing on and formalising the approach already taken.
13.5 Chance Finds
A key PS 8 requirement states that, “….in areas where cultural heritage is expected to be found,
either during construction or operations…… the client will develop provisions for managing chance
finds through a chance find procedure which will be applied in the event that cultural heritage is
subsequently discovered”. The mitigation measures presented in the social impacts chapter of
the ESIA and the ESMP do not include an explicit commitment to implement a Chance Finds
Procedure. It is stated only that any archaeological find will be reported to the responsible
government authority and will not be moved without its consent. The commitment in the ESMP to
develop and implement a CHMP should of necessity include the required Chance Finds Procedure.
As reported by the ESIA study, the overall assessment of impacts presented in the ESIA is high.
Even after mitigation, residual impacts on archaeological heritage in the mine concession area
remains high. Therefore it becomes important to ensure the development and consistent
application of a robust Chance Finds Procedure applicable on an ongoing basis during all stages of
site planning and operation.
Environmental and Social Due Diligence – Technical Report
115
CBG Bauxite Mine Expansion Project, Guinea
Recommendation:
Chance finds’ or ‘unforeseen discoveries’ procedures should be developed and implemented
across existing and future operations. They should include:
1. Stop work in the vicinity of the find at once (very often work can be continued at another part
of the Project, so avoiding costly delays).
2. Notify the accountable operations manager or relevant CBG authority. The find should be
treated as a cultural heritage incident and reported.
3. Notify police if human remains have been found: various legal requirements are likely to be
triggered.
4. Notify cultural heritage authorities, if required, in the case of any archaeological or
palaeontological find.
5. Use heritage experts and relevant community members to assess the significance of the find,
and report it to the authorities if required by law.
6. Decide on the right way to manage the find in consultation with the relevant community
groups and stakeholders. Resume work if permitted and agreed.
13.6 Communication / stakeholder engagement
Another key requirement is to consult with local communities and governmental agencies to
obtain information on the type, characteristics and significance of sites from both a technical and
community perspective. Material presented in the ESIA confirms that such consultations have
occurred and therefore it is fully in line with PS 8. However, this only applies to the mine
concession area as no sites have been recorded for the other two main Project areas.
Stakeholder consultation is recognised as of prior importance in the identification of the presence
and significance of cultural heritage and in the exploration and design of mitigation measures.
This includes decisions made to ensure continued access to sites of cultural heritage value as
identified by the communities themselves. To this effect it is noted that there are no identified
grievances relating to cultural heritage sites. That said, the mechanism for integration of local
communities views in the decision-making process and the elaboration of cultural heritage
management plans (even on an ad hoc basis) should be made more explicit.
Recommendation:
Develop and formalise the existing consultation procedures to ensure continuation of Informed
Consultation and Participation of local communities in decisions affecting cultural and
archaeological heritage.
13.7 Mitigation measures
PS 8, like other PSs, contains a range of requirements about actions to be taken in specific
circumstances during Project construction and operation. It is usual for these requirements to be
incorporated into mitigating measures. The number of mitigating measures contained in the
section on cultural heritage impacts in the social impacts chapter is large, while the number that
have been included in the ESMP by comparison is small with some being very specific in focus
while others are more general.
The report identifies a total of 136 sacred sites in the mine concession area alone (including a
500 m buffer). Of these, 44 are classified as ‘unmovable’ and the remaining 92 as ‘movable after
negotiation’. The status of these negotiations remains unclear – of primary importance is the
formalisation of the mechanism of informed consultation and participation to be implemented as
part of the ongoing negotiations. This should be incorporated into both the Stakeholder
Engagement Plan and the Cultural Heritage Management Plan (with consistency across the two).
Environmental and Social Due Diligence – Technical Report
116
CBG Bauxite Mine Expansion Project, Guinea
Recommendation:
The mitigation measures discussed in the ESIA are expected to be taken forwards into the CHMP,
to which CBG is committed to via its ESMP. These mitigation measures are:

ensure that the community consultation process is consistent and transparent;

organize a further examination of the two Stone Age sites (open air and in a cave);

if the sites are not directly affected and practices are not disturbed, the sites’ existence and
location should still be recorded so that operations or workers will not accidently disturb the
sites;

if the sites and practices will be disturbed, a number of procedures must be followed. All
sacred sites mentioned by people are important simply because they were mentioned and
therefore require special treatment. Nothing must be destroyed before completing the proper
procedure which can include one or more of the following steps, depending on the particular
case:

Negotiate displacement, destruction or replacement with the people concerned and
especially with the people responsible for the sites (they are identified in the site
descriptions);

Consult ‘genie’ specialists to determine what sacrifices to make;

Identify a replacement site where the ‘genies’ who ask to be rehoused by humans can be
placed or where dead ‘genies’ can be buried;

In the railroad and port zones where heritage studies were not conducted, check for the
potential existence of sacred sites in the areas that will be affected by the Project. The same
treatment recommendations apply.
13.8 Access
Access considerations required under PS 8 have not been explicitly addressed in the ESIA or
ESMP, for example, “Where the client’s project site contains cultural heritage or prevents access
to previously accessible cultural heritage sites being used by, or that have been used by, Affected
Communities within living memory for long-standing cultural purposes, the client will, based on
consultations ……, allow continued access to the cultural site or will provide an alternative access
route, subject to overriding health, safety, and security considerations”.
However, it is clear in the ESIA that effective consultation with local communities and their
representatives has taken take place and will occur prior to any interference with or alteration to
site access. The ESIA outlines the cultural practices associated with sacred sites and with land
ownership and access in general terms. Discussions with CBG representatives has confirmed that
respect for local cultural practices is already fully integrated into community consultations. Of
importance to the expansion plan moving forwards is the recommendation to understand and
respect the beliefs specific to the symbolic logic of the local communities, together with their
settlement history and seniority on the land. Emphasis is placed on the values attached to the
management of rituals, sacred sites and agreements.
Following detailed consultations with CBG it is accepted that considerations of access to cultural
sites have been and are being taken into account during mine planning and operations, most
notably through the existing and planned stakeholder engagement and resettlement planning.
Recommendation:
Of importance to the Project moving forward is the ESIA recommendation to understand and
respect the beliefs specific to the symbolic logic of the local communities, together with their
settlement history and seniority on the land.
Environmental and Social Due Diligence – Technical Report
117
CBG Bauxite Mine Expansion Project, Guinea
Decision-making procedures governing access to sites of cultural heritage importance should be
made consistent and communicated clearly to all relevant personnel.
The CHMP should take the ESIA recommendations fully into account.
13.9 Project use of Cultural Heritage
This aspect is not addressed by the ESIA. However, no Project use of cultural heritage is either
planned or expected. Nevertheless, the CHMP should include provisions to address the potential
use and commercialisation of cultural heritage assets in line with the requirements of PS8.
Recommendation:
The CHMP should include provisions and measures to ensure that all relevant employees,
including security personnel, are provided with appropriate cultural heritage training and
guidance.
Cultural Heritage Management Planning
There is sufficient evidence to suggest that Cultural Heritage has been appropriately taken into
account in Project design through identification of sensitive sites and the planning of measures to
ensure their integrity. However there remains a need for further assurance that the protection
and management of cultural heritage is to be taken into account in Project execution.
To this end, a CHMP must be developed and implemented in line with the recommendations in
the ESIA and summarised in this report. This should provide the guidance for involvement of
Project planning and engineering personnel, appropriate local and national government agencies
and knowledgeable people / experts in the management of cultural heritage assets and values
across the Project sites and during all phases including site rehabilitation and closure.
The CHMP should include a mechanism to keep procedures up to date as operations progress
(management of change). It should make explicit the criteria used to assess the importance of
the cultural heritage assets (in particular the use of the local manager of the site). In addition,
there is a commitment by CBG, through the ESMP, to put in place measures for monitoring and
follow up of site protection and management conditions, through agreement with the local
community and engagement with the national museum.
Recommendation:
Ensure that CBG acquires the necessary capacity to develop and implement the CHMP prior to
development of the mine expansion activities. This could include liaison with local national and
international expert counterparts to develop the CHMP, taking into account the recommendations
of the ESIA.
13.10 Summary
In summary, while there is good baseline information for the Sangarédi region, this does not
extend to the rail network and factory/port zones. As part of the CHMP, similar cultural heritage
baseline studies are to be carried out at the railway sidings and Kamsar port development site
which, together with the establishment and implementation of a Chance Finds Procedure, will
enable sufficient characterisation of any cultural heritage assets present and appropriate
management measures to be implemented.
It is recognised that the local communities have engaged with the process of identification and
assessment of sites of cultural heritage importance, have been given the opportunity to express
their knowledge of all cultural sites, and that these are being taken into consideration during the
operation planning. However, the mechanisms by which this has occurred are not consistently
transparent for all sites. This is expected to be remedied in full through the development of the
Environmental and Social Due Diligence – Technical Report
118
CBG Bauxite Mine Expansion Project, Guinea
CHMP to align with the SEP and RAP (as well as general land management and rehabilitation
plans). In particular, Cultural heritage baselines will be carried out in the affected areas as a
component of RAP development and implementation for these zones prior to any works being
conducted that could affect cultural heritage assets.
The establishment of a coherent Chance Finds Procedure as part of the CHMP is considered
sufficient to address the issue of incomplete baseline coverage.
Further effort must focus on the preparation of workable management plans which integrate the
key elements of the CHMP, together with the mechanisms to ensure their implementation. This
should include ensuring that appropriate specialist input is engaged to develop the Plan and to
train all relevant employees, including security personnel, and contractors in its application. In
particular, given that mitigation measures must often be implemented by contractors,
mechanisms to ensure contractors are aware, capable and contractually bound to implement the
mitigation measures must be developed and their efficacy monitored as part of the CHMP.
Environmental and Social Due Diligence – Technical Report
119
CBG Bauxite Mine Expansion Project, Guinea
Table 11: Summary of Findings, PS8
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
059
Document
structure and
Project standards
The ESIA report focusses on locally-relevant
aspects of tangible and intangible cultural
heritage at the mine concession. More explicit
attention to international standards and
guidelines specific to Railway and Port
development is advised.
All
National
and
Lender
(PS8)
Ensure that the development and
implementation of the CHMP addresses all
relevant national and international
standards and integrates best practice
guidance.
Categories of
Cultural Heritage
The ESIA does not clearly address all required
aspects of cultural heritage, although the
baseline studies do capture the key cultural
heritage assets and values present in the
concession area.
All
061
Cultural Heritage
baseline data
There is no identification of cultural heritage
assets potentially affected by planned impacts
during extension of railway sidings at the
various locations along the railway route or at
the Port/Kamsar site.
All
062
Cultural Heritage
impact assessment
Potential future impacts on cultural heritage
assets along the railway route extension and in
the Port/Kamsar site cannot be assessed
because of the lack of baseline survey in these
areas.
060
The need to prepare a plan for the
management of cultural heritage is
included in the ESIA and ESMP.
PS8
As part of ongoing studies in the CHMP,
similar studies to be carried out at the
railway sidings and Kamsar port
development site will enable sufficient
characterisation of any cultural heritage
assets present and appropriate
management measures to be
implemented.
PS8
Develop and implement a CHMP to include
baseline assessment and management in
all Project areas not surveyed to date.
PS8
Develop and implement a CHMP to include
baseline assessment and management in
all Project areas not surveyed to date.
This should include measures to engage
with local communities, drawing on the
community consultation approach taken
during existing activities including the
ESIA surveys and integrated into the
proposed Stakeholder Engagement Plan
for all activities.
Significance
Moderate
(falling to
Low once
CHMP in
place)
Moderate
(falling to
Low once
CHMP in
place)
Moderate
(falling to
Low once
CHMP in
place)
Moderate
(falling to
Low once
CHMP in
place)
Environmental and Social Due Diligence – Technical Report
120
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
IESC Recommendations
063
Cultural Heritage
mitigation
measures
There is no established formal mechanism for
consistent implementation of recommended
and agreed mitigation measures.
All
PS8
Take all mitigation measures discussed in
the ESIA forwards into the CHMP and
ensure transparency in mechanisms for
their agreement and implementation.
064
Cultural Heritage
Access
Need to formalise existing mechanisms to
ensure that the existing successful approach
allowing access to cultural heritage sites is
applied consistently.
All
PS8
Include in the CHMP the recommendation
to understand and respect the beliefs
specific to the symbolic logic of the local
communities, together with their
settlement history and seniority on the
land.
Ensure that ongoing development of the CHMP
conforms to national requirements and is
consistent with or improves on approaches
taken by similar projects elsewhere in Guinea.
All
065
Cultural Heritage
Management
Planning
PS8
Liaise with local national and international
expert counterparts to develop the CHMP,
taking into account the recommendations
of the ESIA.
Develop and implement a CHMP in line
with the recommendations of this report,
to include Chance Finds Procedures and
applicable across all sites and phases of
the Project.
066
067
Cultural Heritage
Management
Policy Statement
Ensure that CBG acquires the necessary
All
PS8
Hire specialists to develop an appropriate
capacity to develop an appropriate CHMP
CHMP. Ensure training of all relevant CBG
including Chance Finds Procedure prior to
and contractor personnel in application of
development of the mine expansion activities.
the CHMP.
Need to develop and communicate a clear
concise policy position on cultural and
archaeological heritage management.
All
PS8
Liaise with local national and international
expert counterparts to develop the CHMP,
taking into account the recommendations
of the ESIA.
Significance
Moderate
(falling to
Low once
CHMP in
place)
Low
Moderate
(falling to
Low once
CHMP in
place)
Moderate
(falling to
Low once
CHMP in
place)
Moderate
(falling to
Low once
CHMP in
place)
Environmental and Social Due Diligence – Technical Report
121
CBG Bauxite Mine Expansion Project, Guinea
ID
Aspect
Issue Description
Phase
Standard
068
Chance Finds
Procedure
There is no Chance Finds Procedure in place.
All
PS8
IESC Recommendations
Significance
Chance finds’ or ‘unforeseen discoveries’
procedures should be developed and
implemented across existing and future
operations. They should include all items
detailed in this Report and be applicable
to employees and subcontractors alike.
This should include ensuring that all
relevant employees, including security
personnel, are provided with appropriate
cultural heritage training and guidance.
Given that mitigation measures must
often be implemented by contractors,
mechanisms to ensure contractors are
aware, capable and contractually bound to
implement the mitigation measures must
be developed as part of the CHMP.
The need for a chance finds procedure is
recognise in the ESMP.
Moderate
(falling to
Low once
CHMP in
place)
Environmental and Social Due Diligence – Technical Report
CBG Bauxite Mine Expansion Project, Guinea
122