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African Minerals LTD

ESIA - Tonkolili Project Phase II (Mine,


Rail & Port)

Technical Bid (un-priced bid)

Revised November 2012

erm.com

Delivering sustainable solutions in a more competitive world


African Minerals LTD

ESIA - Tonkolili Project Phase II (Mine, Rail


& Port)

Technical Bid (un-priced bid)

Proposal Number: 0160710-IAP-016

Revised November 2012

Prepared by: Environmental Resources Management


(ERM)

or and on behalf of
Environmental Resources Management

Approved by: Mike Everett

Signed:

Position: Partner

Date: 01.11.12

This proposal has been prepared by Environmental Resources Management


the trading name of Environmental Resources Management Limited, with all
reasonable skill, care and diligence within the terms of the Contract with the
client, incorporating our General Terms and Conditions of Business and
taking account of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any


matters outside the scope of the above.

This proposal is confidential to the client and we accept no responsibility of


whatsoever nature to third parties to whom this report, or any part thereof, is
made known. Any such party relies on the report at their own risk.
CONTENTS

1 INTRODUCTION .......................................................................................................... 1
1.1 UNDERSTANDING OF THE PROJECT .......................................................................... 2
1.2 STUDIES TO DATE ...................................................................................................... 6
1.3 UNDERSTANDING OF THE SCOPE OF WORK............................................................. 6
2 REGULATORY FRAMEWORK & INTERNATIONAL GOOD PRACTICE ..... 9
2.1 LOCAL REGULATIONS ............................................................................................... 9
2.2 ENVIRONMENTAL GUIDELINES FOR MINING OPERATIONS IN SIERRA LEONE ....... 9
2.3 INTERNATIONAL POLICIES, GUIDELINES AND STANDARDS .................................. 13
3 ERM PROFILE AND SELECTED PROJECT EXPERIENCE ................................ 17
3.1 INTRODUCTION ....................................................................................................... 17
3.2 ENVIRONMENTAL RESOURCES MANAGEMENT ..................................................... 17
3.3 DALAN DEVELOPMENT CONSULTANTS DDC .................................................... 20
4 ESIA APPROACH & METHOD ............................................................................... 23
4.1 OBJECTIVES.............................................................................................................. 24
4.2 PHASE 1 APPLICATION AND SCOPING................................................................. 25
4.3 PHASE 2 SPECIALIST BASELINE STUDIES .............................................................. 31
4.4 PHASE 3 IMPACT ASSESSMENT AND REPORTING ................................................ 74
4.5 PHASE 4 MANAGEMENT PLANS .......................................................................... 78
5 PUBLIC PARTICIPATION PROCESS ..................................................................... 83
5.1 PUBLIC PARTICIPATION AND CONSULTATION PROCESS ....................................... 83
6 PROJECT SCHEDULE ................................................................................................ 90
7 PROJECT TEAM STRUCTURE AND PROJECT MANAGEMENT .................. 91
7.1 TEAM STRUCTURE ................................................................................................... 91
7.2 PROJECT MANAGEMENT....................................................................................... 108

ANNEXES

ANNEX A ERM MINING EXPERIENCE


ANNEX B - CVS
1 INTRODUCTION

Environmental Resources Management (ERM) is pleased to provide this


Technical Bid for undertaking Environmental and Social Impact Assessments
(ESIAs) on behalf of African Minerals Limited (AML) to support the Phase 2
expansion of the Tonkolili Iron Ore Mine in Sierra Leone which includes:

Tagrin Port marine and landside;


Railway, infrastructure; and
Tonkolili Mining, water resources and Tailings Storage Facility (TSF).

We believe that the combination of our proposed team, ERMs expertise and
experience in undertaking similar ESIAs for the mining industry places us in a
good position to complete the ESIAs in an efficient and professional manner,
to the Sustainability Performance Standards of the International Finance
Corporate (IFC).

The remainder of this Bid is structured as follows:

Section 1 provides a summary of ERMs understanding of the project and


scope of work;

Section 2 provides an overview of Sierra Leonean regulations and


international policies, guidelines and standards to which this project will
need to comply;

Section 3 highlights ERMs experience of conducting ESIAs for similar


projects;

Section 4 outlines ERMs overall approach to the ESIA;

Section 5 provides our proposed approach to the Public Participation


Process;

Section 6 provides a draft project schedule to be discussed and agreed with


AML; and

Section 7 describes our proposed team structure including the experience


of our proposed team members.

The Technical Bid is supported by the following annexes:

Annex A: ERM Mining Experience; and


Annex B: CVs

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1.1 UNDERSTANDING OF THE PROJECT

African Minerals Limited (AML) is


developing the Tonkolili Iron Ore project
approximately 180 km northeast of Sierra
Leones capital, Freetown. The Project is
being undertaken in three phases, each of
which is described in this section. However
this proposal is only for Phase 2.
Figure 1.1 presents the site location and Figure 1.2 provides an overview of
facilities at the mine site).

Phase 1

Phase 1 included the development of a mine at Tonkolili and a narrow gauge


railway connecting the mine site to port facilities at Pepel. This phase was
authorised by means of three EIA licences (mine, port, rail and quarries)
which were approved and renewed by the EPA covering the period of 26th
July 2011 25th of July 2013. Mining commenced in Q2 2011 with the
production of Direct Shipped Ore (DSO) lump and fines.

Phase 2

Phase 2 includes the expansion of the existing facilities at the mine to include
the following additional components:

Expansion of the current footprint of facilities to facilitate production of


concentrate from Saprolite. More specifically, the RFT notes that additional
studies are required to examine the Kasafoni deposit and waste rock dump
areas, which were not entirely covered under Phase 1, and water resource
management aspects of Saprolite processing;

Impoundment of water resources in the Mawuru river catchment with the


construction of the Mawuru Raw Water Dam (MRWD), inundation of
approximately 10 km2 of land, and the potential development of pumping
facilities between the Mawuru and Tonkolili catchment; and

Development of a Tailings Storage Facility (TSF) close to the MRWD and


covering an area of approximately 33 km2.

Phase 2 also includes the development of a new railway spur (ca 40km) with
additional loops or dual track. This spur will diverge from the existing
railway line, in the area of Lungi Lol and connect to the port facilities at Tagrin
Point, near Lungi Airport. The RFT notes that alternative rail options were
considered (and discounted) prior to the current option being selected. The
ESIA process will therefore focus on the preferred option while also
communicating the option appraisal processes undertaken to date.

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Finally, the RFT notes that the existing out-loading facilities at Pepel are likely
to be used initially as part of Phase 2 but AML envisages that this phase
would eventually be supported by the development of new port facilities, to
include:

berthing structures to accommodate cape size vessels;


ship loader and conveyor structures;
ca. 10 million m3 of dredging to form the shipping channel;
a service port; and
land reclamation of mangrove/ mudflats.

The RFT notes that three alternative options for port development have been
developed, assessed and discounted to date such that a preferred option at
Tagrin point has now emerged. The RFT notes that the ESIA process should
therefore include an appraisal of the various options that have been
considered and an impact assessment of the preferred port location and layout
at Tagrin.

Phase 3

According to the RFT, Phase 3 will comprise of mining and processing plant
facilities at the mine site linked by the narrow gauge rail to handling facilities
and stockyards at the new port area, which is to be located at Tagrin Point,
built as part of Phase 2.

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Figure 1.1 Rail and Port Site Map, including the Location of the Tonkolili Iron Ore Project
Figure 1.2 Mine Site Map
1.2 STUDIES TO DATE

Water resources (quantity and quality) data has been and is collected within
the Mawuru catchment. In addition, various ecological surveys have been
conducted that cover certain parts of the TSF, with a focus on ornithology and
general habitat appraisals, as precursors to more comprehensive surveys that
are required.

Based on our understanding, the following information is available and will


be provided to ERM:

the Phase 1 ESIAs;

the AML Environmental Management Plan (EMP) and Operational EMPs


for Tonkolili Mine and Port & Rail respectively. These EMPs will be used
as the basis for any additions as a result of EIA and SIA findings;

the raw water dam ESIA (Tonkolili river);

data held on the ED GIS which includes aerial photography (high res),
topography, mapped villages and Phase 1 infrastructure;

reports on marine ecology (benthic grab


species ID and statistics, contamination,
PSA, underwater video, photography for
inter-tidal and sub-tidal habitats);

the EIA for dredging of the Pepel


shipping channel;

ecological studies covering flora and fauna already conducted; and

preliminary land use survey and mapping of sections of the Tagrin


peninsula.

1.3 UNDERSTANDING OF THE SCOPE OF WORK

According to AML, two EIA licences are required for Phase 2 and that an EIA
and SIA are required as part of the application for each EIA licence under
Sierra Leonean law. However, the EIA and SIA will be undertaken under an
ESIA process and therefore the term ESIA is used in this document, where
appropriate.

The following deliverables are therefore required under this scope of work:

EIA and SIA for the Tagrin port option and rail extension spur; and
EIA and SIA for the Tonkolili saprolite plant, tailing storage facility (TSF)
and water resource infrastructure.

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The new (draft) Sierra Leonean legislation specifies a separate EIA and SIA
report must be submitted to the authorities for approval. The deliverables and
the proposed Scope of Work for the Tonkolili Iron Ore Project are therefore
summarised as follows:

Support AML in submitting a project screening application to the


Environmental Protection Agency Sierra Leone (EPA-SL);

Conduct a scoping process for the Phase 2 developments, in accordance


with Sierra Leonean legal requirements and produce a scoping report;

Initiate a Public Participation Process, including a communication and


public participation plan and public meetings (at local and national levels);

Conduct specialist environmental and social studies for identified baseline


gaps;

Compile an EIA and SIA for the Tagrin port the 40km rail spur from Lungi
Lol to Tagrin:
Port marine and landside
Considering each of the 3 Tagrin Port options, plus variations in
layout configuration and offshore infrastructure.

Railway, infrastructure
the rail spur ca. 40 km from Lungi Lol to Tagrin ,
a 200km corridor covering the standard gauge rail option from
Tagrin to Tonkolili; options appraisal.

Compile an EIA and SIA for the Tonkolili Mine, including water resources
studies concentrating on the two affected catchments. Consideration of
greenhouse gas emissions and climate change will also be factored into the
reports;

Develop the EIAs and SIAs to include a description of the project options
(for rail and port) considered to date and the rationale supporting the
selection of the preferred options;

Compile the specified suite of Social and Environmental Management


Plans, including on-going monitoring of the physical and biological
environment which will initially be implemented and supervised by ERM
and thereafter routinely conducted by AML.

The EIA, SIA and associated Management Plans for both the mine and rail
and port options will be submitted to the Authorities;

GIS Support; and

Project Management and Support.

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It is important to note that marine baseline data will be collected under a
separate contract, focussing on marine inter-tidal and sub-tidal ecological
data, particle size analyses, potential contamination, water quality and
fisheries. The results of this work will be made available to ERM so as to
incorporate these data into the EIA and SIA for the Port and Rail component.

The EIAs and SIAs will be compiled to adhere to the local legislation,
International Finance Corporations Performance Standards and the Equator
Principles.

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2 REGULATORY FRAMEWORK & INTERNATIONAL GOOD PRACTICE

2.1 LOCAL REGULATIONS

2.1.1 The Environment Protection Act, 2000

The National Environmental Protection Act (NEPA) was enacted in 2000


followed by the setting up of an Environmental Board. Under the First
Schedule of the NEPA an Environmental Impact Assessment (EIA) licence is
required for any project whose activities could constitute major threats to the
environment, including:

Substantial changes in renewable resources;


Substantial changes in farming and fisheries practices;
Infrastructure; and
Waste management and disposal

Contained under Part 3 of the NEPA are EIA guidelines. These guidelines
include three schedules. The first schedule describes projects requiring EIA
Licenses, the second schedule describes the factors determining if a project
requires an EIA and the third schedule states the contents of an EIA.

In Sierra Leone, an Environmental Impact Assessment (EIA) and Social Impact


Assessment (SIA) process is a legal requirement under the Environmental Law
i.e. the Environmental Protection Agency (EPA) Act, 2008 (Act No. 11 of 2008),
the EPA (Amendment) Act, 2010 (Act No. 7 of 2010), the Environmental and
Social Regulations for the Minerals Sector (2011), and the Mines and Minerals
Act (2009).

2.2 ENVIRONMENTAL GUIDELINES FOR MINING OPERATIONS IN SIERRA LEONE

2.2.1 The Mines and Minerals Act, 2009

The promulgation of the Mines and Minerals Act (MMA) 2009 represented a
new era for minerals development in Sierra Leone. Replacing the Act of 1994,
it includes major changes to how the sector is to be governed. It is more
comprehensive with respect to the issues it addresses; more balanced between
the interests of investors and communities; and more rigorous in terms of
governance and oversight. It is intended to bring important benefits to the
economy, local communities and the country. The Mines and Minerals Act
2009 has four main objectives:

Addresses several issues not previously covered by the law including


health and safety, environmental protection and community development;

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Tightens rules for administrators and mineral rights holders including
application and reporting requirements;

Promotes investment and minerals sector development by ensuring


security of tenure and preventing companies from holding land under
license for too long without demonstrable activities; and

Rebalances fiscal benefits including higher royalty rates for precious


stones and precious minerals - between companies, communities and
government.

Additionally, the law is consistent with all the main Economic Community of
West African States (ECOWAS) Commission principles and policies
governing the mining sector, including the acquisition of mineral rights,
respecting the rights of landowners, protection of the environment, financial
terms and conditions and company reporting, access to information, state
participation in mining operations, respecting the rights of local communities,
and providing Government the right to acquire an interest in large-scale
mining operations.

The ESIA will take cognisance of both the Environmental Protection Act and
the Mines and Minerals Act.

2.2.2 The Environmental and Social Regulations for the Minerals Sector (2011)

In terms of Section 25 of the Environmental and Social Regulations, the


Tonkolili Iron Ore Project is classified as a Category A Project and as such,
must be subject to a full EIA and SIA. The environmental and social
management instruments required include a Mine Closure Plan (MCP),
Environmental Management Plan (EMP), Social Management Plan (SMP),
Community Development Agreement (CDA) and a Resettlement Management
Plan (RMP).

Regulated Procedures

In terms of Section 21 and 32 of the Environmental and Social Regulations, the


mine is required to apply to the regulatory board for a license. A project
screening application must be submitted to the Executive Chairman or its
Authorized Officer regarding project category determination for the
environmental and social assessment. The application must be submitted
using the prescribed form (in the fifteenth schedule of the Regulations) and
must include the following information:

Information regarding the project area, its current uses and physical,
biological and social environment;

Project description, work plan and anticipated impacts;

Which documents are contained in the application; and

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Conditions specified in Section 133 (1) of the Mines and Minerals Act 2009.

In addition, the forms contained in the fourteenth Schedule regarding the time
and date that documents have been placed on deposit for public inspection
must also be completed and submitted to the authorities. Thereafter, the
applicant must submit a scoping report to the Authorized officer according to
Section 27 of the Environmental and Social Regulations for the Minerals Sector.
The applicant is expected to receive comments from the Executive Chairman
within 21 days from the date of submission of the report.

As mentioned above, the Tonkolili Iron Ore Project is a Category A mine due
to the potential requirements for resettlement. The EPA-SL have agreed that
AML will submit an EIA and SIA along with the necessary management
plans; MCP, EMP, SMP, CDA and RMP. The EIA must describe the potential
impacts of the proposed project on the surrounding biophysical conditions.
Possible mitigation measures, avoidance recommendations and/or
compensation proposals must also be outlined. The SIA study and report
must describe the social, economic and health issues affecting the host
communities. The adverse social impacts associated with the proposed project
must be detailed and recommendations for avoiding, mitigating or
compensating these must be provided. A contingency plan including a risk
assessment will also be compiled as part of the ESIA process. The required
contents of both are clearly outlined in the draft regulations and will be
complied with.

The MCP must contain proposals for the management of the progressive
rehabilitation to be undertaken, including the restoration of mined out areas.
This Plan must ultimately provide a strategy for the closure and rehabilitation
of the mine and must also include a monitoring and reporting programme for
a minimum period of three years after final closure of the mine, according to
Part 5, Section 53 of the Act. Detailed closure cost estimations, including
restoration, rehabilitation and remedial works costs must also be provided in
accordance with Section 41 of the Act, which details financial assurance.
Financial assurance is the responsibility of the applicant and the mechanism
used must comply with the standards contained in the sixteenth Schedule of
the Act. In addition, proof of financial assurance must also be presented
together with the MCP; at least 6 months prior to the commencement of
mining activities.

The EMP must detail the applicants implementation plan with regard to the
measures recommended to avoid, mitigate or compensate for the potential
adverse impacts caused by the mining activities as identified in the EIA.

The SMP must also detail the implementation strategy regarding the
identified management/mitigation measure to avoid, mitigate or compensate
for the adverse impacts identified in the SIA. Furthermore, the SMP must

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include a community consultation and participation plan and a grievance
management plan.

In accordance with Section 30, a thorough engagement process is required in


order to obtain consent from landowners for the use of the land for mining
purposes and to notify the public of proposed activities. The land consent
negotiations will be incorporated into the Public Participation Process (PPP)
where the local community and Host Community will be informed of all
relevant social issues with potentially harmful effects, and will be encouraged
to participate in the PPP. Although Section 36 of the Environmental and Social
Regulations states that the Executive Officer or Authorized Officer shall
disseminate notice to the public and local community, and also facilitate
meetings and civil society groups, it is recommended that these activities be
included in and budgeted for in the independent PPP, or be handled by the
applicant directly.

The CDA required as per Section 27, must contain details of the planned
agreement between the mine and landowners/local community (specified in
Twelfth schedule) and must also be included in the SMP together with the
RMP. The Executive Officer or Authorized Officer shall refer the SIA and SMP
(including RMP) to the Resettlement Committee for review. AML will
develop the CDA and ERM will provide overview support as required.

Environmental and Social Management Principles and Accountability

According to Part 3 of the Act, the mine must adhere to the following
principles and requirements:

sustainability (Section 8);

polluter pays (Section 9);

precautionary (Section 10);

general duty to protect the environment and legal responsibility (Section


11);

general duty to protect communities and those affected by mining (Section


12);

obligation to implement environmental and social instrument (Section 13);

access to information (Section 14);

public participation (Section 15); and

public consultation (Section 16).

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A suitably qualified corporate environmental officer and possibly a deputy
must be appointed to be in charge of environmental control of the mining
activities and incident record-keeping.

2.3 INTERNATIONAL POLICIES, GUIDELINES AND STANDARDS

In addition to national and local environmental legislation, the Project is


committed to meet international best practice standards established by the
International Finance Corporation and Equator Principles. The World Bank
Groups Safeguard Policies have defined International Best Practice for ESIA
for the last 20 years.

Following this review, greater emphasis has been placed on the consideration
of greenhouse gases, human rights, community health, and safety and
security. Furthermore, there is greater emphasis on community engagement
and requirements for free, prior and informed consultation where there are
significant environmental or social effects on communities. There is an
increased focus on social and environmental performance of Projects that need
to be managed, and monitored through an action plan and/or a management
system on an on-going basis.

The eight PSs are listed below:

Box 2.1 The IFC Performance Standards

PS 1: Social and Environmental Assessment and Management System.


PS 2. Labour and Working Conditions
PS 3. Pollution Prevention and Abatement
PS 4. Community, Health, Safety and Security
PS 5. Land Acquisition and Involuntary Resettlement
PS 6. Biodiversity Conservation and Sustainable Natural Resource Management
PS 7. Indigenous Peoples
PS 8. Cultural Heritage

To supplement the above Performance Standards, the IFC has established both
general and industry specific environmental, health and safety guidelines
which are considered directly relevant to the project and are outlined in Table
2.1.

Table 2.1 IFC Industry Sector Guidelines

Title
Environmental, Health and Safety General Guideline
Environmental, Health and Safety Guidelines for Mining
Environmental, Health and Safety Guidelines for Water Management Facilities
Environmental, Health and Safety Guidelines for Water and Sanitation
The EHS Guidelines for Crude Oil and Petroleum Product Terminals (April 2007
The EHS Guidelines for Shipping (April 2007)
The EHS Guidelines for Railways (April 2007)

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Other relevant guidelines are the IFCs Environmental Health and Safety
(EHS) Guidelines of April 2007 that contain the performance levels and
measures that are generally considered to be achievable by new facilities by
existing technology at reasonable costs. The application of the EHS Guidelines
is tailored to the hazards and risks established for each Project where site-
specific variables, such as host country context and assimilative capacity of the
environment are taken into account. When host country regulations differ
from the levels and measures presented in the EHS Guidelines, Projects are
expected to achieve whichever is more stringent, unless a full justification can
be made for less stringent levels. In December 2007 the IFC launched
Environmental, Health and Safety Guidelines for mining that are industry
sector guidelines designed to be used together with the EHS Guideline
document. The document addresses specific impacts and management and
performance indicators and monitoring for the mining sector.

IFC PS1, which provides guidance on ESIA and management systems, does
not specify a specific process. It does, however provide detailed guidance on
the elements that should be included, as part of a wider environmental and
social management system. The ESIA process should meet the following
criteria:

Box 2.2 ESIA Criteria


Risk and Impact Identification:
Social and environmental risks and impacts of the Project should be considered in an
integrated manner (including labour, health and safety);
Applicable laws and regulations (including host country obligations under international
law) must be taken into account;
Risks and impacts must be analysed in the context of the Projects area of influence
(including Project site and related facilities, associated facilities not funded as part of the
Project; areas potentially impacted by cumulative impacts);
Risks and impacts must be analysed for all key stages of the Project cycle;
The role and capacity of third parties (e.g. local government, contractors, suppliers) must
be considered; and
Vulnerable individuals/groups that may be differentially affected by the Project must be
identified.

Management Programme
A programme of mitigation and performance improvement measures must be established
which will address identified risks and impacts.; and
An Action Plan must be developed where specific mitigation measures and actions are
necessary for compliance with regulatory and IFI standards. This should reflect the
outcomes of consultation on proposed measures to address impacts, and should be
disclosed to communities (including any updates made over time).

Community engagement
ESIA community engagement should form part of a broader, ongoing process of
community engagement that will extend throughout the life of the Project (and should
include a grievance mechanism).

Monitoring
Procedures should be established as part of the management system, to monitor the
effectiveness of the management programme. The ESIA will develop monitoring measures to
support these monitoring procedures.

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2.3.1 Equator Principles

The Equator Principles are a set of principles and procedures voluntarily


adopted by funding institutions and banks, to manage the environmental and
social issues associated with any funded project. The Equator Principles are
summarised in Table 2.2.

Table 2.2 Equator Principles

Title Summary Description


Principle 1 - Review and Projects are classified according to the potential social and
Categorisation environmental risk that may result.
Principle 2 Social and An environmental assessment should be undertaken of the project
Environmental Assessment that addresses the risks identified in the classification category.
Principle 3 - Organization for Projects developed in emerging countries should follow the
Economic Cooperation and performance standards of the IFC in addition to compliance with
Development Countries local laws.
Principle 4 - Action Plan Relevant projects should have an action plan to address the risks
identified in the environmental assessment.
Principle 5 Consultation and Stakeholder consultation should be promoted and undertaken in
Disclosure structured and culturally appropriate way.
Principle 6 Grievance Mechanisms should be established for continual engagement with
Mechanism the affected stakeholders, and allow for grievances or issues to be
raise during development and operation of the project.
Principle 7 - Independent Environmental performance must be audited by an independent
Evaluation professional expert, with experience in the area covered by the
project.
Principle 8 Commitment There must be commitment to abide by all laws and regulations,
licensing, action plans in all respects.
Principle 9 - Indication of a Projects should appoint an independent social and environmental
Specialist specialist, to provide additional monitoring and reporting.

Principle 10 - Information Financial institutions must publish information about their


provided by Financial experiences with loans at least annually, according to Equator
Institutions Principles rules.

ERM has also worked extensively with the requirements of the Equator
Principles (which overlap with the IFC Performance Standards). Further
details of ERMs experience in this respect are provided in Annex A.

2.3.2 Other Considerations

To meet international best practice, ERM would discuss and agree the use of a
collection of the standards and guidelines that the AML could apply for this
Project. These may potentially include:

International Finance Corporation (IFC) General EHS guidelines (April


2007);

IFC Guidelines- Mining (December 2007);

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World Bank EHS Guidelines Mining and Milling - Open Pit (August
2005);

World Business Council for Sustainable Development (WBCSD) Mining,

Minerals & Sustainable Development (MMSD) Project;

International Council on Metals and Minerals (ICMM) Sustainable


Development Framework; and

ICMM, UNEP & DfID - http://www.goodpracticemining.com/.

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3 ERM PROFILE AND SELECTED PROJECT EXPERIENCE

3.1 INTRODUCTION

In order to complete the proposed work, ERM can offer a blend of


international (based in the UK, South Africa, Canada and the USA) and Sierra
Leonean expertise. We propose to work closely with our in-country partners,
Dalan Development Consultants (DDC) and AMLs Social Development
Consultant to ensure the integration of local content throughout this project.

The profile and representative project experience of each organization are


provided below.

3.2 ENVIRONMENTAL RESOURCES MANAGEMENT

ERM is one of the worlds leading environmental and natural resources


management consultancies, with more than 35 years of experience of working
with development agencies, developers and governments to address the
environmental and social impacts of economic development worldwide. With
more than 3,500 staff operating in 40 countries, we have a core expertise that
includes environmental and social assessment, strategic impact assessment,
environmental policy and planning, institutional strengthening and training.
In particular, our key strengths for this assignment include:

Over 30 years international experience of undertaking Environmental and


Social Impact Assessments across a wide range of sectors and
infrastructure developments.

Over 20 years of experience of undertaking projects in accordance with


environmental and social (including resettlement) safeguard policies for
IFI/World Bank funded development programs across Africa, Europe,
Asia, the Americas and the Middle East. This includes significant
involvement in the development of environmental and social safeguard
policies and guidelines for the World Bank and other funding agencies.

A well-recognised and distinguished track record in the international


development arena, for a wide range of clients including multilateral
agencies such as the World Bank, IFC, EC, UNDP, UNEP and UNIDO,
regional development banks such as the IDB, ADB and EBRD, and
bilateral donors such as UK DFID, Sida, USAID, DANIDA, KfW, GTZ and
the Dutch and Swiss aid agencies.

A fundamental understanding of the environmental and social issues


facing the countries of Africa, gained from over 20 years of project
experience in the region. This is illustrated in Figure 3.1.

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3.2.1 ERMs Experience with Mining in Africa

ERMs involvement in mining has encompassed the full mine life cycle from
pre-feasibility processes, Bankable Feasibility Studies, ESIAs to IFC standards,
environmental authorisation and permitting, through to operational
performance management, decommissioning and closure. We have assisted
mining companies with new ventures and operational improvements in a
range of projects throughout the world. In the mining sector, ERMs expertise
lies in managing social and environmental risk, reputation and regulatory
approvals and compliance.

ERM provides ESIA project management services, corporate assurance


advisory services as well as specialised services to manage groundwater,
contaminated land and social issues. The mining clients that are representative
of a sample of the companies ERM has worked for at a corporate as well as an
operational level are Alcoa, Anglo American plc, Anglo Platinum, Anglo Gold
Ashanti, Barrick Gold, BHP Billiton, Vale, Impala Platinum, Newmont
Mining, Rio Tinto, Xstrata, WMC, Northam Platinum, Ridge Mining and CIC
Energy Corporation.

From a regional perspective, ERM has been involved in numerous projects in


Africa over the past 30 years. A selection of those countries in Africa where
ERM have undertaken a range of projects is provided in Figure 3.1. Besides
extensive experience in West Africa, we are currently working on a number of
projects in Sierra Leone, including the London Mining Marampa Mine and
have a strong team of local experts on the ground. Selected international
Environmental and Social Impact Assessment (ESIA) experience in Africa is
provided in Annex A.

ERM offers expert skills in ESIA, Environmental and Social Management


Plans (ESMPs), Environmental and Social Management Systems (ESMSs),
risk assessment, Environmental Health and Safety (EHS) management and
auditing, corporate social responsibility, socio-economic impact management;
soil and groundwater investigations, contaminated land remediation and
specialist groundwater modelling. With experience across West Africa ERM
has a thorough understanding of local legislative requirements and the
challenges faced with implementing large scale projects in Africa. ERMs staff
offer a wealth of experience and appreciation of environmental and social
priorities and are supported by extensive resources and expertise from the
global ERM group and a network of associates.

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Figure 3.1 A Selection of ERMs African Experience
3.2.2 ERMs Experience with Financial Institutions

ERM has a long history of helping clients ensure that projects meet
international environmental and social assessment standards (including those
of the International Finance Corporation (IFC), World Bank, African
Development Bank (AfDB) and JBIC and others. In recent years ERM has been
applying this expertise to develop bankable projects in compliance with the
Equator Principles (EPs) and IFC Performance Standards. This includes
working for project developers seeking finance from the Equator Principles
Financial Institutions (EPFIs) as well as acting on behalf of project lenders in
reviewing project compliance against the Equator Principles. Specific services
include development and review of:

Environmental and Social Impact Assessments;


Management Plans and Systems;
Land Acquisition and Resettlement Plans;
Public Consultation and Disclosure Plans;
Community Development Strategies; and
Covenants for project loan documentation.

ERM is one of only four firms globally that has been licensed to deliver IFCs
Training on Performance Standards on Environmental and Social
Sustainability to EPFIs. Every year ERM supports the development and
financing of hundreds of major projects around the globe.

In addition, ERM has carried out training in the IFC Performance Standards
for a variety of corporate organisations (e.g. Sasol, Chevron and Standard
Bank), financial institutions (banks, private equity firms), and governmental
organisations.

With regard to the above projects, ERM has worked with a number of
financial institutions. They include ABN, ANZ, Barclays, BTMU, Calyon,
Fortis, Goldman Sachs, HSBC, JPMorgan Chase, Mizuho, Royal Bank of
Scotland, SMBC, Standard Chartered, and West LB. We also have project
experience working with developmental finance institutions such as DBSA,
FMO, and DEG.

Further details of ERMs experience are available in Annex A.

3.3 DALAN DEVELOPMENT CONSULTANTS DDC

For the purpose of this Project, ERM will associate with Dalan Development
Consultants (DDC) Limited. DDC is a Sierra Leonean owned Management
and Development Consultancy firm, established in 2003. Over the last 8 years
DDC has provided consulting services including research, to the Government
of Sierra Leone Institutions and Agencies, non-governmental organizations
and multilateral development institutions to support project and programme

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planning, programme delivery and evaluation. DDCs applicable technical
areas of expertise include:

Project Planning and Analysis: Baseline Assessment Studies; Feasibility


Studies; Gender Analysis; and Participatory Rural and Rapid Appraisal;

Project Management: Monitoring and Evaluation Systems;

Development of Strategic and Cooperate Plans;

Grant Management Support; and

Research: Operations Research and Market Research

DDC will provide ERM with a range of local social and environmental
specialists. The following projects demonstrate DDCs experience in Sierra
Leone over the past three years:

Table 3.1 Applicable DDC Project Experience

Project Title Time Span Scope


London Mining ESIA baseline studies and November 2011 to Two districts
public participation/community meetings date
Youth Exclusion and Youth Violence August 2011- - National
Qualitative Study January 2012
Research to inform Maternal, Neonatal and July 2011 Two Districts
Child Health Improvement Interventions January 2013
Survival Analysis For Adults Living With May -August National
HIV/AIDS 2011
Assessment of Priority Needs To Guide April May 2011 One District ( Mining
Social Investment Expenditure district)
Organizational Assessment April June 2011 Three Local
Organizations- Based in
two districts
Situation Analysis of Supportive Feb April 2011 National
Supervision In The Health Sector
Scoping Study for Programme Scale up, to Feb May 2011 Four Districts
Promote Pro Poor Policy
Mid Term Review of the National Anti- Jan April 2011 National
Corruption Strategy
Evaluation of The Community Led Total November 2010- National
Sanitation Project ( CLTS) April 2011
Documenting Key Changes and June 2010- National
Development In Improving Maternal and December 2010
Child Health In Sierra Leone
Evaluation of a Reproductive and Child April May 2010 Six
Health Program Districts
Qualitative Assessment Childhood April May 2010 Two Districts
Illnesses
Situation Analysis of Health and WATSAN November 2009- Tonkolili District and
in Tonkolili District and Western Area, January 2010 Western Area,
Sierra Leone
Beneficiary Impact Assessment October National
December 2009
Baseline Study on Cross Border Movement August-September Kailahun and Kenema

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Project Title Time Span Scope
and HIV/AIDS Transmission in MRU Cross 2009 District
Border Countries
Feasibility Study for the Establishment of a May-July 2009 National
Sierra Leone Produce marketing Company
Program Management Support to the Global 2008-2010 National
Fund Country Coordinating Mechanism
(CCM)
Knowledge, Attitude and Practice Baseline May-July 2009 Five Districts
Survey Human Rights Governance
Survival Analysis of Children with March-June 2009 Western Area
HIV/AIDS on ART

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4 ESIA APPROACH & METHOD

This Chapter provides a breakdown of ERMs proposed approach and


methodology for the completion of the EIA and SIA. A typical ESIA study is
normally divided broadly into 4 discrete phases, each building upon the
previous one as follows:

Phase 1: Application and Scoping


Phase 2: Specialist Baseline studies
Phase 3: Impact Assessment (EIA and SIA) and Reporting
Phase 4: Management Plans

These phases are summarised in Figure 4.1 below and corresponds to the
phases outlined in our methodology below.

Figure 4.1 Process Flow Diagram

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4.1 OBJECTIVES

The overall aim for the EIAs and SIAs will be to investigate the environmental
and social impacts of the Project, including the appraisal of alternatives, and
prepare robust EIA and SIA reports and guidelines for environmental and
social management, in compliance with Sierra Leone legislation and standards
and the requirements of international financing institutions as set out in
World Bank Guidelines and Operational Procedures, and IFC Performance
Standards.

The EIAs and SIAs will cover both the detailed local impacts of the individual
elements of the Project and cumulative impacts as a result of current and
neighbouring operations. The EIAs and SIAs will deal with the permanent
impacts arising from the creation of the Project (for example, the loss of
ecological or cultural resources), the often temporary short term impacts that
will arise during construction, and the long term impacts of the on-going
operation of the Project over the life of mine, once commissioning is complete.

During the course of the study ERM will work closely with AML to provide
advice on the implications of strategic and in-Project alternatives that will
need to be considered, so that informed decisions can be made about the
preferred alternative. Once this is decided, we will continue to provide advice
on the design and mitigation of impacts identified through our
investigations. The plan will be to discuss and agree those measures which
are feasible and affordable for the Project so that these can be taken into
account in assessing the residual impacts of the scheme. If at any stage the
potential for a fatal flaw in the proposals is identified, this will be immediately
communicated.

The results of this final assessment will be reported in the EIA and SIA reports
together with a description and appraisal of the alternatives considered and
the reasons for the choice of the preferred scheme. This will be supported by
detailed Specialist Studies and by reports on the consultation process, and
guidelines on the development of the Project Environmental Management
Plan (EMP). The EIA and SIA reports will include a schedule of proposed
mitigation measures including proposals for monitoring and management
during all stages of implementation. These will be set out in a framework for
the EMP including principles for resettlement, indigenous peoples and
community development, and we will provide guidelines for the completion
of this plan and for development of an ISO 14001 Environmental Management
System for the later stages of the Project. We will also provide proposals for
developing on-going stakeholder engagement undertaken during the EIAs
and SIAs into a longer term Public Consultation and Disclosure Plan (PDCP)
for the future of the Project.

On completion of the Study, the team will continue to be available to provide


advice and support to the Project as required, during the approvals process
and beyond.

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4.2 PHASE 1 APPLICATION AND SCOPING

The objective of scoping is to identify the important environmental and social


issues for detailed study through the ESIA process. The output of a scoping
assessment is a concise summary report that highlights the key environmental
and social issues that need to be considered. The scoping process also builds
consensus on the issues that need to be addressed by the ESIA and provides
for a formal agreement with the relevant authorities on what the process
needs to cover. The main objectives of scoping are set out in Box 4.1.

Box 4.1 What is Scoping?

Scoping is the process of determining the content and extent of future baseline data collection,
consultation and impact assessment to be included within an ESIA. Scoping is undertaken at an
early stage to ensure that the ESIA provides all the relevant information on:

the potential impacts of the project; and


project alternatives.

The findings of a Scoping Study will help to determine the extent of the ESIA including:

Coverage of baseline environmental and information (and methodology for collection).

Coverage, focus and methodology for the impact assessment and development of
management plans (e.g. influx management plan, site rehabilitation plan, environmental
monitoring plan, etc.).

Defining boundary limits for the project, for example those associated facilities such as
access roads and the projects area of influence.

In compliance with the expected enactment of the Environmental and Social


Regulations for the Minerals Sector, ERM will make provision to support the
project screening, application and scoping requirements.

4.2.1 Task 1- Mobilization and Inception

After contract award, we will mobilise the team and arrange an Inception
Meeting with AML (assumed to be in London) to finalise the details of the
Phase I work plan.

The purpose of the meeting will be to:

introduce the core team;

discuss and agree on the work plan and proposed scope of work;

confirm reporting arrangements;

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discuss Project logistics, agree health and safety protocols and any
required security arrangements;

establish the working arrangements with the engineering team;

gather all available information on the Project and its history, including
possible data (such as satellite imagery);

identify sources of information, including relevant government agencies,


research institutes, NGOs and academic institutions as well as the
respective regional level Government Departments;

identify external stakeholders, understand your existing relationships with


them and any resulting sensitivities, and agree the levels of information
that can be discussed with communities; and

discuss and agree arrangements for announcing the study to alert


stakeholders of the forthcoming process.

4.2.2 Task 2 Compilation of Project Screening Application Form

ERM will support AML in compiling the application form for submission to
the authorities. The application form will be in compliance with the structure
and requirements established in the Second Schedule of the Environmental
and Social Regulations for the Minerals Sector.

It is understood that AML will provide in-country support and logistics with
respect to the submission of the application forms to the authorities and any
associated requirements in terms of authority engagement. No in-country
travel or meetings will be required by ERM for this task.

4.2.3 Task 3- Desk Review

We understand that AML has a range of reports and data that will be made
available at commencement of the study. In addition to this data, we will also
gather other secondary data on the local area (from NGOs, government,
university publications, etc.). The data reviewed will include local, regional
and national level data for the following:

Physical environment: geology, topography, soils, ground water and surface


hydrology.

Biological environment: flora, fauna, rare or endangered species, sensitive


habitats including parks and reserves, wetlands, significant natural sites,
etc., species of commercial importance, and species with potential to
become nuisances, vectors or dangerous.

Socio-economic environment: a review of available secondary information,


both present and projected data (where appropriate), covering all social

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and economic aspects of the affected population including census data
(demographics), as well as identification of additional stakeholders.

We will rely on the in-country consultants (as well as AMLs associated social
and environmental specialists mentioned in the RFT and personnel from
AMLs Environmental Department) to collect much of this data, especially that
to be sourced from government ministries. This secondary data review will
inform project planning and focus the activities of the Scoping Study. The
outputs from the desk review will also form the starting point for
development of the Specialist Reports prepared to support the ESIA.

4.2.4 Task 4- Development of GIS and Preparation of Social Base Map

A comprehensive Geographic Information System (GIS) allowing storage,


manipulation and presentation of data about the Project area will be a key tool
for the ESIA.

The environmental and social mapping will be continued during Phase 2 of


the study, creating a detailed resource of accurate information on all aspects of
importance for the study. As per the RFT, it is assumed that up-to-date
satellite imagery and appropriate GIS layers will be made available to ERM
under this phase. The costing for further satellite imagery analyses and GIS
mapping is included within this proposal.

4.2.5 Task 5 Consideration of Project Alternatives/Design Options

A key requirement of an ESIA is the consideration of various Project


alternatives. This may include:

Location alternatives for the port (considering the preferred option and the
alternatives);

Route selection for potential changes to the existing railway and planned
44 km railway extension; and

Design and technology alternatives.

The consideration of alternatives will form


part of a chapter on the project justification
in the EIA and SIA Reports. The preferred
alternative will be considered during the
assessment of project impacts. The team
will carry out an initial desk based
assessment of design options using analysis
of GIS imagery to identify preferred routing
of the railways and port options that minimise impacts such as physical and
economic resettlement.

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It is expected that AMLs engineer will provide support to the team during the
assessment of design and technology alternatives. We will draw on project
engineering study reports that would have been prepared during project
feasibility stage such as siting studies, financial studies and studies of
technology options.

The analysis of alternatives will be a two-way process between the ESIA team
and AMLs design engineers. At some agreed point there will need to be a
design freeze. This design will then form the basis of assessment for the
subsequent EIA and SIA studies.

4.2.6 Task 6- Scoping Trip and Workshop

A scoping visit will be carried out by key project personnel at the proposed
sites to determine the geographical scope for the ESIAs and to develop an
understanding of the environment, communities and the infrastructure within
the projects area of influence. The team will also meet with key project
stakeholders. This will include AML, government officials and community
leaders who might be directly impacted by the development. It is assumed in
the budget that AML will be able to assist with setting up scoping meetings.
Time will also be included within the scoping visit to brief the local
consultants and carry out training in relation to the field tools and information
required during later phases of the project.

The site reconnaissance will involve senior technical social and environmental
experts to allow for an integrated approach to identification of key project
issues, valuable sharing of information across disciplines and a holistic
understanding of the full range of potential impacts associated with the
project.

Key tasks during the scoping trip will include:

visits to the mine site, rail and port looking at preferred routes and options
for the port and the rail, as well as to identify environmentally sensitive
sites (such as all river crossings, areas of undisturbed vegetation, protected
or sensitive areas, fisheries); and

meetings with key informants (e.g. leaders, local authorities, fishing


cooperative leaders) in a sample of potentially directly impacted villages.

The focus of these activities will be to determine the area of impact or


influence of the project including the following:

areas of potentially significant natural habitats and/or protected areas


and/or forested zone that might be affected;

areas with settlements/housing thereby potentially requiring relocation,


including mapping of communities;

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areas with agricultural/pastoral land use potentially requiring
compensation;

important fisheries/fishing grounds;

areas with potential sites of cultural significance;

areas with potentially increased access to sensitive natural habitats as a


consequence of access roads (such as temporary access for construction /
permanent for maintenance);

areas where there may be potential impacts of associated and ancillary


features of the project, including construction camps, access roads and the
like; and

areas preferable for routing of the rail and the various port options.

During scoping, ERM will also meet with the social development consultants,
Sullay Kamara, referred to by the RFT to assess their capability and
experience. For now, our Bid assumes that ERM will work with our local
partners Dalan Development Consultants (DDC) with whom we have
already developed a working relationship in the implementation of ESIAs in
Sierra Leone.

The main aim of the social studies described in this section is to determine the
gaps in social data identified during scoping, through the collection of
additional primary social data that may be required. ERM will work closely
with AML and DDC (or with Sullay Kamara depending on our findings
during scoping) to develop a targeted data collection plan to manage the
collection of this data.

Scoping findings will be documented through photographs, GPS readings and


notes, with all meetings being minuted. ERM assumes that all meetings held
with government officials, communities will be arranged in advance and led
by ourselves and our local consultants as appropriate but with participation
from the AML project team.

At the end of the Scoping Trip, to integrate the work of all team members and
to optimise dialogue with AML, we envisage holding a Scoping Workshop to
agree on the issues and risks identified during the scoping phase. The
workshop will include the Core Environmental and Social Team and selected
specialists. The scope and approach for the specialist studies and the overall
direction of the ESIA process will be discussed and agreed at the Workshop.

4.2.7 Task 7- Development of TOR, Work Plan and Communications and Public
Participation Plan (CPPP)

Following the Scoping Workshop, the team will develop a detailed TOR,
Work Programme and CPPP. The scope and methodology for each specialist

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area including requirements for additional baseline survey work will be
detailed and programmed during this task. Procedures will be worked out to
manage the work of the specialist teams including coordination, integration
and communication, record keeping, GIS interface and Health and Safety.

4.2.8 Task 8 Scoping Report (EPA-SL)

Two separate draft Scoping Reports (one for port/rail and another for the
mine) will be prepared by ERM and will be based on ERMs understanding of
the Project context and key environmental and social risks.

The Scoping Reports will be prepared to meet Sierra Leone legal


requirements, and specifically Section 27, Schedule Four and Schedule Six of the
Environmental and Social Regulations for the Minerals Sector. Schedule Four
and Schedule Six will dictate the report structure and data requirements.
Amendments may be made based on AMLs requirements, however the
general structure of the Scoping Reports include:

Contact details and expertise of the environmental assessment practitioner


undertaking the scoping process;

A description of the proposed activities;

A description of feasible and reasonable alternatives;

A description of the receiving environment, including the properties to be


affected by the activity;

Identification of applicable legislation, policies and guidelines;

Description of key issues, concerns and potential impacts;

Details of the stakeholder engagement process conducted including a


summary of issues raised through the process (issues-trail). Note:
It is recognised that a public meeting will not take place prior to the
submission of the Scoping Report.
The comments and issues raised by stakeholders as part of ERMs
social baseline study as well as those collected by AMLs Community
Liaison Team will be used for the purpose of the Scoping Report
submission.
On-going PPP will be undertaken as part of Phase 3 as described
below.

Terms of Reference for specialist studies and ESIA requirements.

4.2.9 Task 9 Public Participation Process (Scoping Phase)

Public participation or stakeholder engagement is a legal requirement in


Sierra Leonean environmental and mining law. In order to meet the IFC and

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local requirements for stakeholder engagement, there are a number of
activities that need to be completed. These are presented below:

Stakeholder Identification and Participation Planning

As stated in Section XIV of the Sierra Leone Environmental and Social


Regulations for Mining (March 2012), ERM will prepare a Communications and
Public Participation Plan (CPPP). This plan will also be developed in line with
the IFC requirements for a Stakeholder Engagement Plan (SEP). This CPPP
will map stakeholders according to their influence on the project, their level of
interest and the degree to which the project might affect them. The CPPP will
describe the mapping process and level of engagement required for each
group of stakeholders and the best means by which to communicate with
stakeholders.

The CPPP will be treated as a living document. Following each stage of


consultation, it will be updated with the approach and outcomes of meetings
ensuring that they are well documented. The CPPP will form an annex to the
final ESIA report, documenting consultation undertaken as part of the Project.

Scoping Stage Consultation

Following the production of the scoping report, the team will carry out
scoping disclosure with all relevant stakeholders identified in the CPPP. This
stage of consultation will provide details of current and planned activities as
well as findings from the scoping study. As legally required in Sierra
Leone (1), the final scoping report will be published and made available in
publicly accessible places such as the African Minerals website. Copies shall
be provided to the district and chiefdom authorities. Additionally, ERM will
prepare a non-technical summary of the report which explains its key contents
in laymans terms, to ensure that the information is readily understood.
From ERMs experience of working in Sierra Leone, consideration will be need
to be given to the low levels of literacy and as such a participatory approach
will be used when consulting with communities.

Further details of the approach to stakeholder engagement and consultation


are outlined in Section 5.

4.3 PHASE 2 SPECIALIST BASELINE STUDIES

This section describes the proposed methodology for each of the specialist
studies covering Tonkolili mine site, and the preferred options for the port
and rail sites. The specialist studies outlined below also cover associated
facilities including the Kasofoni rock dump areas, the water resource
management aspects of the saprolite processing, the Tailings Storage Facilities
(TSF) and the Mawuru River Impoundment footprint.

(1) Sierra Leone Environment and Social Regulations for Mining, March 2012, Sixth Schedule: SIA Standards. p. 73

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4.3.1 Task 1 Groundwater

ERM will conduct a groundwater assessment for the Port and rail Extension
and Mine areas separately, as described below.

Port/ Rail and Mine Site

For the Port and Rail EIA, ERM


recommends that ASTERs Global Digital
Elevation Modelling (GDEM) and Water
Shed Modelling System (WMS) be used to
map the drainage network within the
study area, a technique that ERM has used
successfully in providing high level data
over vast areas in remote areas, including sub Saharan Africa.

Preliminary outputs from the modelling effort would be based on the water
balance within the defined drainage areas, and would be developed based on
digital elevation data obtained from the satellite imagery. This model can be
used to help identify potential no-go areas based on desired setback distances
from surface water bodies, flow paths from any point within the study area
towards known sensitive groundwater receptors, and optimize the placement
of groundwater monitoring wells if required. Furthermore the watershed and
hydrology model will assist in selecting sampling points for the surface water
baseline.

Hydrocensus

Selected water levels and water quality data will be collected during a wet and
dry season hydrocensus from the following source(s):

Identified private boreholes/wells in the area; and

The measurement and sampling of available exploration/monitoring


boreholes.

For the mine site, selected water levels and water quality data will be collected
during a wet and dry season hydrocensus from the following source(s):

Identified private boreholes/wells in the area;

The measurement and sampling of available/open


exploration/monitoring boreholes; and

Fifteen percussion boreholes for resource evaluation and drawdown


impact studies. The number and position of these boreholes will be
determined during the initial hydrocensus and discussed with AML. It
will be AMLs responsibility to contract a suitable drilling company that

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can construct and test these boreholes. ERM will provide a scope of work
for that part of the investigation.

The data collected will be incorporated into a groundwater database. All


surface water and groundwater samples will be taken and preserved in
accordance to the ERM Fieldwork Manual and QA/QC system, and samples
will be submitted to an accredited laboratory for analysis. Parameters to be
analysed will include: EC, pH, DO and temperature, TSS, BOD, COD, major
ions and the full suite of metals.

ERM approximates 30 samples per monitoring run to be analysed (including 3


duplicate samples for QA/QC) for the Port sites and Rail routes, and 20 samples per
monitoring run for the Mine Site to be analysed (including 3 duplicate samples for
QA/QC). Provision is also made for two sets of environmental isotope data
(approximately 10 samples), to assist with water fingerprinting. This
information is particularly relevant in establishing the interaction between
aquifers and surface water bodies.

Data Collation, Interpretation and Development of a Conceptual Site Model


(CSM)

All additional data collected will be interpreted and a preliminary


hydrogeological Conceptual Site Model (CSM) will be developed, based on
understanding of the regional groundwater flow dynamics, describing the
source-pathway-receptor interaction. The CSM will describe the following:

Subsurface extent and thickness of aquifer(s) and confining units


(hydrogeological framework);

Groundwater flow direction and gradients;

Groundwater bearing units/aquifers and its properties;

Hydrologic boundaries (also referred to as boundary conditions), which


control the rate and direction of movement of groundwater;

The inter-connection between rivers and aquifers (proximity to the coast);

Inter-relationships between source area(s), pathway(s) and receptor(s);

Contaminant transport mechanisms. This will include assessment of


geochemical data (MSDS) that will be collected (as conducted by AML),
including product/contaminant characteristics/test data. The
geochemical interpretation on product/contaminant will be carried out in
relation to the groundwater pathway(s) and receptor(s); and

Preliminary quantification of sustainable yields and hydrogeological


properties of the aquifer(s) for potential water supply if water supply

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boreholes exists and aquifer tests were carried out in the past or could be
carried out during the investigation.

All information will be interpreted and collated to produce cross-sections and


plans explaining the mechanisms of groundwater and contaminant transport
from source areas, along the pathway to the receptors.

Groundwater Impact Assessment and Management Plans

Groundwater impacts will be identified and quantified for the different stages,
including: construction, commissioning, operational, decommissioning and
post-closure phases for the proposed project. Numerical modelling techniques
will be used in the quantification of potential water impacts, as required.

A detailed groundwater management programme and water management


strategy will be compiled based on the outcome of the impact assessment
taking into account engineering design and practicalities, legal, geochemical
and social-economic considerations and will be intergraded with the overall
water and waste management plan.

4.3.2 Task 2 Geochemistry (including ARD assessment)

ERM is of the understanding that the ARD/ML assessment for the Tonkolili
Iron Ore Project is to consider only the following mine facilities:

Three open cast mines;


Waste rock dumps;
Tailings storage facility of unknown volume/tonnage; and
Ore stockpiles.

ERM proposes to follow an approach for the Tonkolili Iron Ore Project
ARD/ML study which is based fundamentally on the recommended approach
to drainage-chemistry predictions in British Columbia, as published in Price et
al. (1997).

Based on preliminary information provided to ERM all geological and mine


waste units that would be exposed, disturbed or deposited by the proposed
mining activities will be investigated:

Waste rocks;
Ore;
Overburden;
Soils underlying or adjacent to mine-related facilities; and
Process tailings material.

ERM will develop a conceptual model of key geochemical and flow processes
associated with each of the mining facilities under consideration in this scope
of work, which ERM currently assumes to be the open pits, the waste rock

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dumps, the tailings storage facility and the ore stockpiles. The conceptual
models will take account of the following factors:

The location and dimensions of facilities and workings;

The volume/mass of materials;

The composition or exposure modes of geological materials and mine


wastes; and

Climate/water flow/balance considerations.

ERM will develop a strategy for sampling and analysis of geological materials,
mine wastes and water resources for the ARD/ML study. The sampling and
analytical strategy should aim to identify and characterise the following for
materials (geological and mine wastes) that will be exposed, disturbed or
deposited during the proposed mining activities:

Geochemical characteristics of materials which may influence their


ARD/ML potential;

Geohydraulic characteristics of materials which may influence the flow of


water through them within the proposed mining scenario; and

Spatial and compositional variations in material geochemical


characteristics across the mineral resource targeted for mining.

Sufficient samples should be collected and analysed to determine the


statistical distributions of relevant geochemical parameters. The selection of an
appropriate number of samples should be based on site-specific information,
the availability of sample materials (often a function of mine phase), and
statistical guidance. It is important to note that sampling is an iterative process
that, based on the statistical variance and required confidence level, can have
multiple phases.

Based on guidelines related to rock volume and tonnage, as well as the


number of rock types anticipated, the number of samples to be taken for the
Tonkolili Iron Ore Project opencast pit overburden and waste rock would be
in the 100 to 300 range. In this Bid it is proposed to collect a considerably
lesser number of samples, the results of which would inform the requirement
for testing of additional samples (i.e. to follow an iterative sampling
approach). The number of ore samples would be significantly less due to the
temporary nature of the ore stockpiles. The number of tailings samples likely
would be dictated by availability of tailings material.

Samples (approximately 6 samples total) will be collected of soils adjacent to


the proposed tailings storage facility, open pit and waste rock dump.

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Please note that the preliminary sampling strategy described above will be
subject to verification after studying the following information:

Geological (structure) model including parameters;


Mine plans of opencast workings;
Layout plan of tailings storage facility, pit, waste rock dump, etc.; and
Confirmation of available sample materials.

Analytical Strategy (Draft)

Samples will be delivered to an accredited laboratory / laboratories for


sample preparation and testing. The following static geochemical tests are
proposed for selected individual solid samples:

Acid-base accounting (ABA) using the Modified Sobek (2001)


methodology. This includes determination of sulphur species (Total S, S2-
and SO4), acid potential (AP) and neutralisation potential (bulk NP,
carbonate NP);

Net acid generation (NAG) testing per the methodology of Miller et al.,
1997. This includes determination of paste pH, sulphur species and mobile
metals under conditions of complete sulphide oxidation, thereby
representing a worst-case scenario;

Major element composition by X-ray fluorescence (XRF);

Trace element composition by whole rock (aqua regia) digestion, and


inductively-coupled plasma mass spectroscopy (ICP-MS) analysis of
digest; and

Mineralogical composition by X-ray diffraction combined with petroscopic


assessment of sulphide mineral form and mode of occurrence. It is
proposed to focus these determinations on samples for which ABA and/or
NAG analysis show uncertain to certain ARD/ML potential.

Statistical analysis of the above static test results will raise our understanding
of the spatial variability of key variables of concern. This understanding will
assist in deriving an appropriate protocol to generate composite rock samples,
which will then be subjected to further static testing, which may include:

Synthetic precipitation leaching procedure (SPLP) testing per EPA Method


1312. This typically involves 24 hour leaching of -9.5 mm sample particles
with pH 5 lixiviant at a 4:1 (by weight) solution:solid ratio. The leachate
solutions are then analysed for physical parameters (including pH, EC,
TDS and alkalinity), major ions and trace elements. Note that a peroxide
leach protocol may be followed instead of the SPLP leach protocol this
will be confirmed ahead of test work proceeding.

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The results of the static geochemical test programme will be used to design
and optimise the kinetic geochemical test programme. The following kinetic
geochemical testing is provisionally proposed:

Running of standard ASTM humidity cells according to the ASTM5744-96


(Re-approved 2001) standard methodology. The method specifies that the
cells be run for a minimum of 21 weeks, with possible extension of the test
programme up to 52 weeks (or more) should leaching rates not have yet
reached steady state conditions. The leachates will be analysed for major
ions and trace metals (by ICP-MS). In this Bid we specify unit costs per
humidity cell for establishing, administering, running and deconstructing
the cells over a 21 week period. We emphasise, however, that the exact
number and duration of these cells will be determined once static test data
becomes available.

Standard static geochemical tests will be conducted on the materials before


and after the kinetic testing program. In this Bid we provide a unit cost per
sample for conducting these static tests.

These collected soil samples will be tested for geohydraulic properties such as
particle size distribution, moisture retention, bulk density and (possibly) in-
situ permeability by field test methods. This data will inform the geochemical
model.

Geochemical Modelling

ERM will conduct numerical geochemical modelling to predict time sensitive


drainage chemistry for each mine facility as a function of material property,
climatic variation, water balance and geochemical process. The geochemical
modelling predicts the operational and post closure seepage qualities for
different mining scenarios and typically involves ARD modelling to calculate
time for acid potential and neutralization potential depletion, and
geochemical speciation modelling to identify key mineral solubility controls.

The mine water qualities obtained through a combination of such geochemical


models will be combined with seepage volumes to obtain probabilistic
seepage loads for operational and post closure phases for input to the
groundwater model. ERM provisionally assumes that the mining facilities
within the scope of this Bid include the Tonkolili Iron Ore Project open pit, the
waste rock dumps, the tailings storage facility and the ore stockpiles.

Having characterised likely Tonkolili Iron Ore Project ARD / ML water


resource impacts, ERM will recommend source and pathway control measures
to prevent, minimise or mitigate these impacts to acceptable levels. This will
include recommendations for developing performance monitoring programs
during the various life cycle phases of the proposed mine.

ERM will ensure that the scheduling of the geochemical assessment ties in
with the overall ESIA / EMPR schedule. Note that humidity cell testing of

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samples may extend beyond this timeframe, but that in such instance the
preliminary test results would nevertheless inform the ESIA / EMPR process.
A detailed schedule for the geochemical assessment will be developed on
award and preliminary review of project information.

Numerical Flow and Transport Model

The numerical model will be the mathematical expression of the CSM. Field
data, such as groundwater levels, aquifer hydrogeological characteristics,
thickness, recharge and boundaries will be used to construct and calibrate the
groundwater flow and contaminant transport model. This calibrated model
will be used to carry out scenario modelling to develop a preliminary estimate
of the long-term groundwater quality and water level impacts.

This information will be used by ERM to assess the potential groundwater


impact(s) associated with the proposed project.
Assumptions
Availability of surface water hydrology (flow rates and quality) baseline data.
Availability of all data gathered during previous investigations in digital form
Topographic data in digital form with minimum 5m contour lines
Mine plans and schedules in digital form
Layout of waste rock dumps, tailing dams, stock piles and deposit schedules over time for
life of mine.
Layout of existing dumps, dams and stockpiles in digital form
ERM will have the opportunity to liaise with the project geologist to obtain the following
information from the core drilling program(s), or to incorporate the following
modifications to boreholes (if required): Depth and volume of water loss during drilling;
Access to geological cross-sections and plans in digital form; Depth of weathering; and
Installations of UPVC standpipes to keep boreholes open for packer testing.
The requirement for assessment of available geochemical data, i.e. the geochemical testing
of all product/contaminant streams to determine its characteristics (MSDS).
All fieldwork will be carried out in accordance to the requirements of the social impact
assessment, to ensure that appropriate communication channels are followed and no
property is damaged.
ERM provisionally assumes that exploration drilling has been conducted across the
Tonkolili Iron Ore Project open pit footprint, that drill core material has been adequately
logged and stored, and that drill core material is available for ERM to sample;
AML is to avail a site geologist to assist an ERM staff member with splitting of drill cores
and with sample selection;
ERM assumes that project tailings material will not be available to ERM for testing;
The calculation of laboratory analytical cost is based on the number of samples presented
and is aimed at achieving an acceptable level of statistical representation of material
geochemical; characteristics. The need to conduct additional test work on the remaining
samples may be refined after receipt and interpretation of the initial analytical results and
in consultation with AML;
Please note that if the sample representation is inadequate based on the statistical variance
of the test results, additional sampling and test work may be required for which no cost is
indicated our Commercial Bid;
The costing of humidity cell testing in our Commercial Bid is based on the cells running for
a period of 21 weeks. Should the analytical results at this stage indicate the need to extend
the cells further (up to 52 weeks or more) then this will first be agreed with AML.

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4.3.3 Task 3 Surface Water

Hydrologic and surface water quality data will be needed to support the
baseline analysis and impact assessment. Baseline water data are essential for
several reasons: stream flow hydrographs will assist in the development of the
mine water management plan and will establish a baseline hydrology to
compare to performance standards, and will drive the scope of the monitoring
program. The following key areas should be addressed with respect to surface
water management:

Assessments of both surface water hydrology and storm water


management are required. Assessments of typical and likely peak flows
are required based on the surface topography around the entire mine site
and rail route; and

The infrastructure design required to manage and monitor the surface


water is required including that required to manage potential high
suspended solid loads in runoff.

Water quality data are important not just for understanding the effects of mine
water and surface runoff discharges, but in establishing realistic performance
standards for the design. Surface water quality data are also essential for the
aquatic habitat and downstream water use analysis required in other specialist
studies, the EIA, and the EMP/monitoring program. If sufficient data are not
available, we will suggest a baseline water quality data campaign that will
address the other resource impact needs as well as the mine water
management design. Cognizance will be made as to the existing surface water
samples taken and analysed under the current scope. In addition to the above
mine-site related surface water considerations, activities associated with the
port facility have the potential of impacting the water quality of the Sierra
Leone Estuary.

ERM proposes to assess the impacts of these activities in the vicinity of the
Port facility. This analysis will quantify the impacts on water quality
characteristics such as turbidity, dissolved oxygen, temperature, and pH
associated with the operations. These impacts will be compared to baseline
conditions in order to assess the relative potential impairment of water quality
due to port activities.

Scope of Work

The water resources scope includes two elements: 1) the land-side hydrology
and water quality associated with the mine expansion, mine facilities and the
railway; and 2) the port and waterside facilities and activities including
dredging, dredge material management, waterside infrastructure and
maintenance. We understand that the landside conditions are largely an
expansion of current activities, including, we assume, a set of baseline data
and a monitoring program. We have therefore assumed minimal additional
data collection on the landside.

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The waterside facility involves extensive dredging and it is our understanding
that there are no data. We have assumed that sediment data will be collected
as part of the aquatic habitat/benthic studies. The volume of dredging
suggests that the depth of dredging may be more than 1 2 meters and coring
as opposed to surface sampling may be necessary, however, this should be
addressed through the aquatic specialist studies.

ERM proposes the following scope of work:

Review of existing data;

Development and implementation of field programs to address data gaps;

Determine peak discharges and overland flows for identified smaller


streams and water courses using a rainfall-runoff model for the 2, 10, 20,
50 and 100 year recurrence intervals;

Drainage control to manage rainfall within the pit limits to be the focus of
mine pit water management, and this study will provide required inputs
to that process;

Surveying of three (3) stream cross-sections with three to four transects per
site to allow development of rating curves on the smaller streams and
water courses at appropriate positions for the purposes of high flood
water level calculations, and model calibration (hydrologic modelling by
the mine water engineer). We assume that AML or their in-country
surveyor will assist with the survey of such transects. We have included
the purchase of data loggers in our expenses. These points should be used
as sampling points for AMLs long-term water sampling programme. We
have assumed that gauging stations will be deployed at these sites. We
assume that the deployment and monitoring of these gauges will be
executed by in-country subcontractors after initial set-up and procedure
assistance from ERM. We have assumed that three such points will be
established in the mine expansion area and railroad area. The scoping,
data review and ToR process will refine the locations. If more sites are
required, the budget and scope will be updated to reflect such changes as
may be required by the data gap, scoping and ToR processes;

Data loggers must be installed at such sampling points, to measure stream


depth (and hence discharges). Both a barometric logger and depth
transducer will be deployed to allow data correction;

Compile a Storm water Management Plan to incorporate the following (to


be integrated with but not replace the Mine Water Management Plan
completed by the mine water engineer):
Water management measures on the mine to take into account and fit
into the broader regional water management context (integrated water
management),

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Storm water management measures design philosophy to be in line
with the regional climate and site location, and applicable for the entire
lifetime of the mine,

Water of different qualities is to be managed separately.

Water re-use to be maximised.

Establishment of a regular monthly water quality monitoring programme.


It is recommended that one sampling site be established near each of the
three proposed port locations to characterize the area affected by the
dredging and port facility construction activities and possibly two or three
additional sampling sites in each of the catchments along the rail line.
Measurements will be made for Turbidity, DO, Temperature, pH and
Conductivity. Creek measurements will be made mid-channel to assess
average conditions. This will be initially deployed by ERM and staffed by
AML or other in-country consultant. We have assumed that all landside
water quality data will be obtained with field probes (no laboratory
samples) and that existing data from the other ESIA for the Phase I mine
will be adequate to describe the other surface water quality baseline
parameters for Phase II.

It is recommended that the water quality monitoring plan be implemented as


soon as feasible in order to better capture seasonal variations in the baseline
conditions. ERM will establish this program including sampling protocols and
supervise the initial round of sampling. It is assumed that AML operations
will continue this sampling monthly after the first round of sampling.

In addition to the monitoring programme, ERM will design a one-time field


program that will provide any additional information needed for the baseline
study specific to Phase 2 of the Project. The field program may include:

ADCP velocity survey of Tagrin Port. This survey will be conducted over
the course of at least 1 or 2 tidal cycles and will provide velocity profiles to
be used in the dredge plume analysis;

Survey of water chemistry. This is conducted at the same locations as used


in the monitoring programme. This assumes that two samples will be
collected at 4 sites at shallow and deep depths for the baseline and these
locations will be used for establishment of the long-term monitoring plan;

Survey of sediments in the vicinity of Tagrin Port.

Some sampling was undertaken as part of the Phase 1 EIA. ERM assumes that
this data will be available and will be analysed and used to supplement the
any additional surveys proposed. We understand that data collection will
likely continue beyond the delivery of the EIA. Post ESIA, ERM will develop a
scope, sampling locations, work plan, parameter list and cost estimate for the
field campaign for a water quality and hydrologic data collection program

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that will mesh with the data needs across resource assessments, and will form
the basis for the long term monitoring that will be part of the Water
Management Plan.

It is essential that data collection start as soon as possible to have adequate


data in time to be useful in the EIA. ERM will consult with the biological team
and with the mine managers and engineers to optimize the locations and
integrate with their existing procedures and anticipated activities. The data
collection will also include water quality and sediment sampling (see the
Ecological Study for sediment sampling which is combined with the benthic
sampling). This must consider the port and the mine area somewhat
separately, but is suggested to have one sampling plan for the whole project.

For water quality, we recommend that 1 sampling event for parameters


requiring laboratory analysis (metals, nutrients) be conducted by ERM. AML
personnel will be trained accordingly and a sampling protocol will be
developed to guide more frequent sampling for data that can be collected with
probes (dissolved oxygen, pH, temperature, conductivity, turbidity, etc.), by
AML. Some projects of this type warrant deployment of continuous loggers
but due to the timing and the complexity of putting such a program in place,
loggers and continuous monitoring are impractical and prohibitive in this
case. Data loggers to measure stream flow within the mine concession area
are, however accounted for. Data collection visits will be made flexible, since
site conditions (particularly weather) can make a rigid event interval
impractical or dangerous.

Impact Assessment

The impact assessment will include the definition of performance standards


and best management practices. The EIA and Mine Water Management
engineering will require input for performance standards and design criteria
that address avoidance, minimization and mitigation of significant adverse
effects of the project on water resources and water dependent resources and
uses. ERM expects this will be primarily focused on sediment control and
turbidity management. Based on our experience in tropical environments, this
is most challenging during the rainy season. To determine an appropriate set
of conditions to manage, ERM will confer with the biological and social teams
to determine the tolerance of aquatic resources and water users for
incremental and episodic excursions above existing conditions. We will also
attempt to estimate the natural variability in the system to quantify the
existing range of conditions.

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After identifying the critical conditions and parameters, ERM will discuss
with the mine engineering team the feasibility of attaining a performance
standard through site design. Impacts beyond those manageable by the mine
can be managed by application of vegetated buffers and strategies for water
release and sequential sediment capture methods, such as overland flows,
siltation controls, etc. ERM will compile a set of performance standards and
suggest management practices in consultation with the mine team.

Assumptions

The following limitations and assumptions form an explicit part of this Technical Bid:

The surface water (hydrological study) requires that rivers and streams in the project area
be surveyed for accurate cross-sections; this for more accurate determination of flood lines
and flood volumes and for calibration of rainfall-runoff models. It is assumed that AML
will make a Surveyor available for such studies if required;
Assumes that baseline water quality and other hydrologic data from the Phase I ESIA are
adequate to allow only the supplemental landside sampling and monitoring described in
this Bid.
Long term monitoring and sampling campaign support including equipment will be
provided by AML or its in-country field sampling consultant and that ERM will provide 1
senior staff for 2 weeks to organize the initial long term campaign and oversee the initial
portion of the baseline data campaign, including a monitoring guidance document and 1
day of training in English;
Long term monitoring costs are not included in our Commercial Bid
Assumes no landside hydrologic modelling;
Assumes only dredge plume modelling for waterside facilities;
Assumes that the scoping or data gap analysis does not require significant changes to this
scope;
Similarly, it is assumed that the Sierra Leone Estuary Bathymetry in the vicinity of Tagrin
Port will be provided to ERM from AML or its contractors. In the absence of bathymetric
data, a one-time survey (not included in this scope) will be necessary;
Should monitoring of surface flows be required, it is assumed that V-notches on site will be
surveyed and monitored by AML staff. The cost of loggers at three sites has been provided
in our Commercial Bid and
It is assumed that precipitation data, Digital Elevation Model (DEM) and land cover data
for the study area and mine site are available.

4.3.4 Task 4 Air Quality Impact Assessment

The approach to the air quality impact assessment will be based upon
IFC/World Bank guidance and international best-practice guidance referred
to by the IFC.

The work will involve the following:

describe the regional climate and local meteorology;

design and implement baseline air quality monitoring surveys;

describe the legislative and regulatory context for the proposed project;

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develop a comprehensive inventory of atmospheric emissions for the
proposed project;

predict ambient concentrations of pollutants arising from the construction


and operational phases of the proposed project using dispersion
modelling, and if required, undertake iterative assessment of built in
mitigation and control measures;

assess the overall impact of the construction and operational phases of the
proposed project, using national and international Ambient Air Quality
Standards and guidelines to describe the impacts in terms of their nature,
duration and frequency of occurrence and the severity of the impact in the
ambient environment using a standardised impact rating system;

recommend how significant negative impacts can be mitigated;

compile a specialist study report that includes a description of all data, the
methodology used, assumptions that have been made, model results
(including in the form of isopleth maps), assessment of impacts, and
recommendations for mitigation; and

compile an Air Quality Management Plan for air quality, taking into
consideration built in and committed mitigation.

The key impacts will be associated with:

emissions of particulate matter (as PM10 and PM2.5) and airborne and
deposited dust from the mining, processing, handling and transportation
of ore; and

emissions of oxides of nitrogen (NOx), nitrogen dioxide (NO2), sulphur


dioxide (SO2), and particulate matter (as PM10 and PM2.5) from combustion
sources, these being primarily mine plant, trains, power generation, ships
and other vehicles.

In addition, it is also understood that some assessment will be required for an


early design option whereby ore would be transported from the mine to the
train loading facility using conveyor belts. Whilst it is understood that this
option will not be taken up in practice, the option will be included where
required in order to allow this to be included in the options appraisal. The key
aspects of this design will be in the mine assessment as the rail assessment will
include only the haulage of ore, and not the loading of ore.

Baseline Air Quality Monitoring

ERM understand that there is only very limited exiting data available. Given
the importance of air quality for mining projects, and the sensitivity of the
receiving environment, ERM propose to design and implement a baseline air
quality monitoring survey. Consideration of the baseline will be made as

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required in the impact assessment on the basis of the results of the baseline
survey.

Baseline monitoring will seek to capture existing air quality at sensitive


receptors in the vicinity of the mine, rail route and port. Consideration will
need to be made of the potential for elevated baseline concentrations of the
pollutants of interest, as a result of both natural and man-made sources. This
will need to consider, as appropriate, any emissions associated with existing
mining operations. The baseline survey will be designed by ERM. This will
involve a site visit to finalise the detail of the design, and implement the
survey. Best practice is for the survey to be run for a minimum of one year,
although initial results from a shorter period may be utilised in the EIA. This
approach allows capture of seasonally variable pollutant concentrations,
particularly particulates and dust which are greatly affected by the occurrence
of wet and dry seasons. On this basis, in country support will be required to
undertake site servicing and sample collection on a two weekly basis for the
duration of the monitoring. The costs for these have not been included, and
the assumption is made that these can be undertaken by African Minerals
personnel, or nominated representative. The proposed monitoring
programme will also take into consideration the effects of local meteorological
conditions, in particular the prevailing wind direction.

The key pollutants of interest identified at this stage include: PM10, PM2.5, dust,
NOx, NO2 and SO2. The baseline monitoring will identify the concentrations of
these pollutants at key receptor locations. For the purpose of the monitoring,
sensitive human receptors are primarily those communities identified as
living close to the mine or port infrastructure or rail route. Sensitive ecological
receptors in the form of the Ramsar site and protected forest have been
identified, and are included in the scope.

On the basis of the pollutants identified, the following techniques are


proposed to be used in the baseline monitoring survey:

Pollutants: NO2, NOx and SO2

Monitoring technique: diffusion tubes;

Number of monitoring locations: 10 to 12;

Mode of operation: passive absorption onto reagent within tube, sent to


laboratory for analysis;

Service frequency: monthly;

Specialist knowledge: none required;

Description: plastic tube, approximately 10cm in length; and

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Deployment: strapped to suitable post (i.e. fence post, lamp post, telegraph
pole etc.).

Pollutants: Ambient Dust, PM10 and PM2.5

Monitoring technique: Osiris monitors (light scattering device) are


included in the budget as optional;

Number of monitoring locations: 10 to 12, using two devices on rotation;

Mode of operation: active sampling recording real time data, requires


power source (battery and solar panel or mains electricity);

Service frequency: 14 days;

Specialist knowledge: IT literacy for data download; technical competency


to inspect and undertake minor routine service to equipment;

Description: metal box approximately 40 cm x 40 cm x 50 cm, and if


required, battery and solar panel; and

Deployment: placed on ground in secure location.

Pollutants: Dust Deposition

Monitoring technique: Bergerhoff dust gauges;

Number of monitoring locations: 10 to 12;

Mode of operation: passive sampling, collection of dust into sampling


bottle;

Service frequency: monthly;

Specialist knowledge: None required;

Description: metal pole, approximately 1.8m high, secured with tethers or


tripod; and

Deployment: secure site required, strapped to suitable post (i.e. fence post,
lamp post, telegraph pole etc.) or placed on ground and tethered,
depending on local ground conditions.

The recommendation is made that the Osiris monitors are deployed on a


rotational basis, with sampling undertaken at each location for one month, as
far as is practical, during the dry season and during the wet season. This
approach is recommended as the Osiris gauges are costly. This approach is not

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necessary for the diffusion tubes or Bergerhoff dust gauges as these are,
relatively, low cost techniques.

The key deployment locations from the perspective of sensitive human


receptors are around the mine and the port, and to a lesser extent, the rail
route. A desk based review will be undertaken to identify the key sensitive
receptor locations in the vicinity of sources of emissions. As previously
mentioned a site visit will be undertaken; during this site visit the identified
monitoring locations will be finalised on the basis of the desk based study.
With regard to sensitive habitats, the key locations are the RAMSAR site and
the protected forest. The extents of the RAMSAR site and protected forest will
be reviewed, and where required included in the monitoring design. It is
acknowledged that a pragmatic approach to the selection of monitoring sites
may be required, as access to some areas of the RAMSAR site and forest may
be difficult.

Air Quality Assessment

On the basis of the understanding of the sources identified for the mine,
railway and port, an emissions inventory will be developed. For the mine, the
emissions inventory will be developed primarily from guidance set out in NPi
produced by the Australian Government and USEPA AP-42 emissions
database. Key input data will include, the tonnages of ore produced, vehicle
specifications, distances travelled by vehicles, and fuel specifications and use.
For the railway, the emissions inventory will reflect emissions arising from the
locomotives and wagons, and will be based upon an understanding of the
numbers of train movements, locomotive specifications and fuel
specifications. If required, emission factors from NPi and AP-42 will be
utilised. For the port, the emissions inventory will need to consider the
tonnages of ore handled, equipment location and specification, stockpile size
and location, conveyor distances, and fuel specifications and use.

On the basis of the emissions inventory, dispersion modelling will be utilised


to quantify the magnitude of impacts arising from the key sources of
emissions. This approach is utilised to ensure robust quantification of impacts
and ascertain the effectiveness of mitigation and emissions controls. The
USEPA AERMOD dispersion model will be utilised; this model is widely
recognised as being appropriate for this type of scheme by several agencies
including the IFC, USEPA and UK Environment Agency. In addition to
consideration of emissions, the model also considers local meteorology, local
topography, and the locations of nearby receptors. The modelling undertaken
for the rail route does not need to be as detailed as that undertaken for the
mine, instead using a conceptual cross section of the rail route to identify
impacts with increasing distance from the rail line.

On the basis of the dispersion modelling, the magnitude of impacts will be


identified. This will then lead into the definition of significance and
identification of any mitigation measures for the port and rail sites.
Consideration of these options will not necessitate a large amount of

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additional effort, due to the less complex nature of the assessment of rail
impacts.

Definition of Significance

The identification of significance will be based upon the comparison of the


magnitude of impacts against air quality standards as set out by the IFC, these
being based upon those set out by the World Health Organisation (WHO). The
significance is defined upon the basis of the magnitude of impacts as a
percentage of the air quality guideline, with due consideration of the existing
baseline conditions, as following the IFC guidance.

In relation to sensitive habitats, in particular the Ramsar site and protected


forest, a similar methodology will be used. However, in this case European
Union standards for NOx and SO2 for the protection of vegetation, and
assessment criteria for dust, based upon a derived evidence base, will be
utilised. The assumption is made that protection of sensitive vegetation in line
with these standards will result in the protection of the sensitive bird species
dependant on that habitat.

Input Information

The impact assessment requires detailed understanding of the construction


activities and proposed operational design, as set out earlier. The assumption
is made that this information will be readily available from African Minerals.

Meteorological data is also required for undertaking the impact assessment.


ERM understand that some limited meteorological data is available, and that
additional data may be collected at specific sites. However, for the purposes of
the assessment, five years of hourly sequential data for a number of
parameters not routinely collected by local monitoring stations would be
required. In addition, there may be significantly different meteorological
conditions at the port and at the mine, as a result of the effect of coastal effects
and elevated terrain at the mine. On this basis, ERM propose to purchase
hourly sequential MM5 modelled meteorological data; the review of local
conditions will determine whether this is required for only one site
representative of the whole project, or two locations representative of the port
and mine locations. The use of MM5 data is considered robust and
appropriate, on the basis of validation studies undertaken.

Development of Mitigation and Controls

The assessment process will not identify impacts before mitigation and after
mitigation but instead will present the predicted impacts with the inclusion of
built in mitigation. Using this approach in developing the assessment allows
focus on the key issues and identification of any critical or major residual
impacts. Following the identification of any significant impacts, any additional
mitigation, controls, or operational monitoring will be identified along with
the likely effectiveness of any such controls.

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Assumptions

The following assumptions are applicable to the air quality study::

ERM assume that all mine design information will be available in a timely manner, will not
be subject to significant change, and where required, will be available in the correct format;
ERM assume that the design of the proposed mine operations and transport arrangements
will not be subject to significant change. Any such changes may necessitate reassessment
and remodelling, which may incur additional costs and delays; and
No detailed consideration will be made of cumulative impacts associated with other
schemes operational or proposed in the vicinity of the mine. It is anticipated that some
schemes may be in place that have the potential for cumulative impacts. However details of
such schemes are likely to be difficult to obtain in any meaningful manner. Where required,
cumulative impacts will be discussed in broad terms in line with the guidance set out by
the IFC. If specific requests are made for assessment of cumulative impacts, these may
incur additional costs.
Equipment costs for PM10 air quality monitoring are included as an optional extra to the
expenses provided in our Commercial Bid..

4.3.5 Task 5 Noise and Vibrations Impact Assessment


Introduction

The purpose of the NVIA (Noise and Vibration Impact Assessment) is to


determine potential noise and vibration levels associated with the construction
and operational aspects of the project, to qualify the magnitude of any impacts
and, where necessary, provide recommendations to reduce any impacts
identified as part of the assessment.

Scope of Assessment

The assessment will not address:

Underwater noise;

Ground borne noise; and

the 200km corridor covering the standard gauge rail option from Tagrin to
Tonkolili, as there is no significant difference between a narrow gauge and
standard gauge railway in terms of noise emissions and that a significant
part of the corridor (160 km) has an existing railway in operation.

The assessment will evaluate noise and vibration impacts from:

Port and Rail

the preferred design option for Tagrin Port (October 2012) as described in
the Revised TOR for the Phase ESIA;

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the 40km extension of the narrow gauge railway from Lungi Lol to Tagrin
including additional loops or dual track;

To conduct the alternative options analysis for each of the alternative


Tagrin Port options, baseline data for Options 2 and 3 (North and South of
Lungi) would be required and was included in the original proposal.
However, as a preferred port option has been chosen, it is considered that
a comprehensive baseline assessment previously proposed is no longer
required and an indicative baseline of these two areas will be undertaken
by conducting short term measurements. The short term measurements
will provide an indicative basis for a comparative assessment of the 3 port
options to be included in the EISA.

Tonkolili mine site

Expansion of mining from Phase 1 to Phase 2 - Kasafoni pit and new waste
rock dump areas.

Phase 2 processing and TSF;

Approach

The following outlines the general approach that will be undertaken to


conduct the NVIA:

Conduct a review of the Phase 1 ESHIA and other studies relevant to the
project or the area:

Assess the baseline noise environment of the (extended) project area and
evaluate the suitability of baseline data from Phase 1 to inform Phase 2
assessments;

Determine suitable noise impact assessment criteria for the project;

Measure existing noise, sources on the mine site, railway and Pepel Port to
be used as inputs for predictive noise modelling;

Conduct predictive noise modelling from the construction and


operational phases of Phase 2 of mining operations, railway extension and
the preferred design option for Tagrin Port;

Compare predicted noise emissions from construction and operational


phases of the project with impact assessment criteria to determine
potential noise impacts and identify potential noise mitigation measures
where predicted impacts may occur;

Evaluate residual and cumulative impacts after the application of feasible


and practicable mitigation options;

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Measure vibration emissions from the railway operations to determine the
scope of potential impact;

Conduct an assessment of blasting emissions from mine operations;

Write a NVIA chapter suitable to be included in the EIA;

Develop a Noise, Vibration and Blast Management Plan for inclusion in


the project ESMP.

Baseline Noise Assessment

An understanding of the baseline noise environment across the project site


may be established by undertaking long-term continuous measurements,
supplemented with short-term attended measurements. This Bid is based on
the premise that the Phase 1 ESIA baseline for the mine, railway and port to
Pepel is suitable for informing the Phase 2 assessments in these areas, and that
a baseline will need to be determined for the railway extension and the
preferred Port Tagrin option. It is envisaged that the following number of
assessment locations would be required for each project area where ERM will
be undertaking the baseline assessment:

Preferred Tagrin port option - 2 receptors; and


Along the 40km railway extension from Lungi Lol to Tagrin - 2 locations.

Measurement locations for each area will be finalised when on-site and once
further information is provided on the various processes and production
phases and potential sensitive receptors have been established. ERM
recommends that long-term unattended measurements are undertaken over a
minimum period of 24 hours at the most sensitive (or most accessible
receivers); along with short-term (15-minute period) attended measurements
at all locations during the day and night period wherever possible to
characterise the existing ambient noise levels.

All measurement locations will be subject to site access and security


constraints. Measurements will only be carried out in dry conditions and
when wind speeds are below 5 m/s. Baseline ambient noise data collection
will be carried out for only one season of the year. For the railway, the
intention is to characterise the existing ambient noise levels at the various
types of receptors along the railway route such as villages, to small
communities and larger towns. This would be achieved by conducting
operator attended noise surveys over the course of 2 days whilst travelling
from Lungi Lol to Tagrin.

Construction Noise Assessment

The following will be conducted as part of the construction noise assessment:


Determine representative construction scenarios to be assessed ERM has
allowed for up to three construction scenarios to be modelled nominally

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for the railway extension, preferred port design and mine expansion;

Conduct predictive noise modelling for the construction of the 40km


extension of the narrow gauge railway from Lungi Lol to Tagrin;

Conduct predictive noise modelling for the construction the preferred


design option for Tagrin Port;

Conduct predictive noise modelling for the construction of Phase 2 of


mine operations - nominally the Processing Plant and TSF area;

Compare predicted noise emissions with relevant noise criteria and


determine impacts and/ or management measures;

discuss and recommend relevant noise mitigation measures and


monitoring actions, to be considered by AML where required for the
development of a noise monitoring and management plan.

Operational Noise Assessment

To meet the operational noise assessment objective, ERM envisages the


following scope of work:

Review any existing project data and/or information relevant to the


assessment, including review of project site plans and proposed
operational scenarios;

Identify the closest and/or potentially most affected noise sensitive


receiver locations in proximity to the operational areas of the project.;

Quantify likely background noise levels at representative assessment


locations (from Phase 1 ESIA or baseline assessment) and develop noise
impact assessment criteria at these assessment locations;

Measure existing railway noise, existing noise sources on the mine site to
be used as inputs for predictive noise modelling;

Measure existing noise emissions from the Pepel Port to inform the
cumulative impact assessment and predictive modelling for the Tagrin
Port operations;

Develop a noise model (refer Noise Modelling below) to predict noise


levels and potential impacts from Phase 2 operation of the mine, railway
extension and preferred port design option.

ERM has allowed for up to two mining scenarios and a single railway
operational scenario to be modelled;

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For the preferred Port option, ERM has allowed for two modelling
assessments being an initial design to present potential noise impacts;
and a final Port design (for EIA) to allow for the inevitable design changes
as potential impacts and mitigations are incorporated;

Compare the resultant noise levels to the noise impact assessment criteria
and determine the magnitude of potential impacts at noise sensitive
receiver locations;

Discuss and recommend relevant noise mitigation measures and


monitoring actions, to be considered by AML for the design of operational
plant and development of the environmental management and monitoring
plans;

Liaise with the social team to understand the information collected


regarding existing noise impacts that are being felt by local communities
during the social baseline data collection activities, which will feed into the
noise assessment. Details of the noise assessment will be included in the
stakeholder consultation and social engagement process. It will also assist
the social team in assessing overall social impacts related to noise
disturbance, including the identification of areas where resettlement will
be required if there is no alternative mitigation strategy; and

Write a noise, vibration and blasting management and monitoring plan for
the operation.

The identification of potentially noise sensitive receptor locations will need to


be given particular effort and liaison with the social team and other ERM
specialists to ensure that all receptors are accurately identified within the mine
vicinity and within the potential affectation area of the railway and port
operations. Where mine plans do not provide the level of detail required, ERM
will work with African Minerals to develop suitable operational scenarios t to
best represent the future operation of the mine.

Noise Modelling

Brel & Kjrs Predictor 7810 (Version 8.1) noise modelling software package
will be utilised to calculate noise levels using the ISO 9613.1 industrial noise
propagation algorithms (international method for general purpose, 1/1
octaves). The Predictor software package allows topographic details to be
combined with ground regions, water, grass, significant building structures
etc. and project specific assessment locations, to create a detailed and accurate
representation of the site and surrounding area. Noise emission sources
deemed representative of worst-case operating conditions under each scenario
can be placed at locations within the site area.

The noise model shall allow quantification of noise levels from multiple
sources, based on sound pressures or sound pressure levels emitted from the
key plant components, as defined in the project design. The model shall

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compute the noise propagation in the project area of influence and specifically
quantify A-weighted decibels, dB(A) in the computational domain.

Operational Vibration Assessment

To meet the operational vibration assessment objective, ERM envisages the


following scope of work:

Review any existing project data and/or information relevant to the


assessment; including review of project site plans and proposed
operational scenarios;

Identify the closest and/or potentially most affected vibration sensitive


receiver locations (buildings and occupants) in proximity to the site. These
locations will be adopted as the project-specific vibration assessment
locations;

Develop the vibration impact assessment criteria at the assessment


locations;

Quantify (via measurement) the typical operational vibration levels from


the railway to determine offset distances at which criterion would be
achieved and to inform the impact assessment;

Discuss and recommend relevant vibration mitigation measures and


monitoring actions, to be considered by AML for the design of operational
plant and for the development of the environmental management and
monitoring plans.

Blasting Assessment

Blasting has two potential effects being blast overpressure noise and ground-
borne vibration. Both overpressure and ground-borne vibration from blasting
are in most cases related to the Maximum Instantaneous Charge (MIC) of the
blast and the distance from the blast to the receptor.
ERM will quantify overpressure noise and ground-borne vibration associated
with blasting within the site, and make in-principle recommendations to assist
blast engineers e.g. attention that should be adopted during the design of blast
patterns and MIC that should be used.
ERM propose to measure blasting emissions from existing operations.
Analysis of blast data allows the development of a specific prediction tool
called a site law and is able to provide a higher confidence levels in
predicted blasting emissions from future operations, rather than a generic
blasting assessment.

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Assumptions

The following assumptions have been made to conduct the scope of works outlined.
Baseline noise survey for the Tagrin port options and railway extension is based from
Lungi and AML are assumed to provide vehicles, drivers and accommodation;
Mine, existing railway and Pepel port noise surveys are from being based at the mine
where AML are assumed to provide vehicle, drivers and accommodation;
All fee estimates are inclusive of travel costs and visa etc.

Additional Work

The assessment will be based on the proposed project design inclusive of noise
mitigation controls identified prior to the design freeze. Once the design is
fixed, the assessment will be undertaken and any changes to the design after
the design freeze could incur additional work. Where significant noise
impacts are identified and further assessment is required, such as modelling
the effect of additional noise mitigation would also been deemed as additional
work and is not included in the proposed scope of work. If source terms and
equipment data is deemed to be insufficient, ERM may need to conduct sound
power level measurements for relevant plant and equipment on site, if
required. Using measured data of the actual equipment in use on the site will
provide a high level of certainty in the predictions from the model.

It is assumed that operational mine plans will be of a suitable standard to


develop realistic operational scenarios. Where extensive liaison is required to
develop mining scenarios, this would be deemed as additional work.

With regards to the site visits ERM has not allowed for delays due to
unsuitable weather for noise monitoring or unplanned plant shutdowns or
breakdowns.

4.3.6 Task 6 Soils and Land Capability Assessment

ERM understand that the mine area will amount to approximately 35km2,
including pits, tailings storage facility and water impoundments, and this area
lacks any soil baseline information. Conversely, intrusive soil investigations
have been undertaken for most of the landside port and rail areas (for Port
Options 1 and 3). This bid assumes that this data is available and is of
sufficient spatial coverage and includes analytical data to support a soil
mapping and soil resource evaluation. Therefore, ERM assume that only
intrusive soil sampling works are required for the mine area.

Results from the mine site investigations will be integrated and assessed
collectively with the existing data, utilising previous site investigation reports
and the updated satellite imagery supplied as part of the data package. The
soil study will focus on the rehabilitation potential of the soils in the study
areas as well as the potential impact resulting from the loss of actual or

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potential arable land resulting from the mine, port, rail and associated
infrastructure.

A specialist soil survey will be conducted in the mine area in order to achieve
a consistent understanding of the soil patterns occurring across the study
areas. This will include the TSF and Mawuru river area. The objectives of the
integrated study will be to identify and determine the presence, distribution
and extent of soil types in the preferred port and rail areas in a detailed
manner.

This study will consist of field observations on an irregular grid supported by


a predictive soil mapping technique (PSM). It will also include and
assessment of:

Soil form classified;


Soil depth;
Estimated texture;
Current land use; and
Land capability, as determined by soil sampling and analysis.

Sampling and Laboratory Analysis

ERM propose to undertake preliminary soil mapping using the existing site
investigation and mapping data for the port. This will develop a soil model for
the observed toposequences in these areas and extend to cover the mine and
the 40 km rail route.

A field survey will then be undertaken with sample locations determined by


the preliminary toposequence and soil model. It is proposed that up to twenty
(20) locations in the mines area, six (6) locations in the port area and rail route
areas (total 6) are obtained. The latter to confirm or re-calibrate the soil model
in the areas with existing site investigation data.

The topsoil (0-300 mm) and subsoil (300-600 mm) of the dominant soil forms
will be sampled and analysed for soil acidity, fertility and textural indicators
as follows:

pH (water) (top & subsoil);


Extractable cations and Na, K, Ca, Mg (top & subsoil);
Cation exchange capacity (topsoil);
Phosphorus (topsoil only);
Carbon content (top & subsoil); and
Soil texture (proportion of sand, silt and clay) (top & subsoil).

Land Capability and Land Use

Soil properties of soil units mapped during the detailed soil assessment will be
evaluated and categorized in land capability classes. This serves as a metric of
resource value of the soil to be utilised in the understanding of the significance

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of any impacts. The extent of all land use practices will be surveyed and
mapped at each location and along access paths to those locations.

Outputs

The soil mapping exercise will be documented in a Soils Baseline Report in the
EIA reports, including a Soils Map, Land Capability map, and details
contributing to the Land Use map.

4.3.7 Task 7 Terrestrial Ecology Assessment

The main objective of this assessment is to identify, describe, classify and


assess the direct and indirect environmental impacts of the mine, the ports
(Tagrin and Pepel), and the rail on the terrestrial ecology. The Terrestrial
Ecology Assessment will assess both flora and fauna within a defined study
area associated with each of the distinct project elements. Review of a larger
area at the regional scale will also be conducted to provide context for the
baseline study and impact assessment. As identified in the RFT, the Project
extends into a documented RAMSAR site in the Sierra Leone River Estuary,
and is a well-documented migratory bird area. Therefore, particular attention
will be required on the avifaunal surveys and impact assessment for project
elements within this designated area.

Desktop Study

ERM will conduct a desktop study which will include, at a minimum:

Review results of previously conducted ecological surveys, including


avifaunal studies, to determine the remaining baseline data needs to
satisfy the national and international requirements for biodiversity;

Review the previous ESIAs;

Detailed aerial photograph review and preliminary habitat mapping,


including vegetation communities;

Obtain and review publically available data regarding the ecological


communities within the study area, including characteristics of the
vegetation communities, faunal composition, and associated habitats.

Following review of the existing data, ERM will establish a study area for
terrestrial ecology specific to the Phase 2 activities. Based on the RFT,
ecological data exist for approximately 40% of the Tagrin site, 20% of the rail
corridor spur, and 10% of the rail corridor. The extent of existing ecological
information at the TSF, the impoundment, and the mine sites will be
determined during this desktop study and ERM will define a study area for
Phase 2 to supplement the existing data and provide complete coverage of
ecological data.

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ERM understands that AML has contracted specialists that will assist ERM (at
no cost to ERM) with the supplementary ecological surveys and baseline data
collection studies. Relative to terrestrial ecology, these AML specialists
include:

Royal Botanical Gardens, Kew, London


Botanists from Njala and Fourah Bay Universities Sierra Leone
James Wolstencrost, ornithologist, naturalist

Working in concert with these specialists, ERM will develop a preliminary


description of the terrestrial flora and habitats within the regions of the
defined study area that have not yet been studied previously by AML using
the existing resources available, including existing studies, maps, and high-
resolution satellite imagery and near infra-red or other remote sensing
technology images and data. In addition to project-specific documents and
studies, sources will be reviewed for existing data including the Conservation
International Convention on Trade in Endangered Species, and International
Union for Conservation of Nature, and other pre-existing data sources relative
to the general area.

Baseline Studies Flora

Once the terrestrial ecology study area has been


confirmed with AML, ERM will work with the
AML-contracted specialists to develop a field
sampling plan to be implemented by the
specialists, with oversight provided by an ERM
technical lead. The major vegetative
communities identified during the desktop study will be confirmed primarily
through a sample site observation program that will largely be dependent on
accessibility of sites. Field events will be required over multiple trips during
both the wet and the dry seasons due to the size of the study area and unique
conditions represented in each of the seasons. A field report will be prepared
following each field event to document methodology, findings, and
preliminary assessment of the findings.

The field reports from each of the sampling events, as well as the previous
ecological data collected for the project will be synthesized into a detailed
baseline study to be included in each EIA. The characterization of soils and
vegetation types (such as dominant flora elements and composition) will be
depicted on an annotated map to be included in the EIAs to show the
distribution of habitats over the affected area. Any sensitive areas, including
the RAMSAR site, will be identified relative to biological diversity, pristine,
rare or unique native habitats.

The mapping of mangroves, if any, within the study area surrounding Port
Pepel is anticipated to overlap with both the Aquatic Ecology study and the
social and cultural technical studies due to the potential sacred nature of

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mangroves within the local communities. Established communication
protocols between technical disciplines will facilitate the transfer of
information for the purposes of reporting and document preparation.
Although field work may cover multiple areas during a single event, one
separate baseline study will be prepared for the Tagrin port and the 40km
railway spur,, and another baseline study will be prepared for the mine site,
including the TSF and impoundment.

In the baseline reports, habitat will be classified as modified, natural, and


critical, a key distinction in determining acceptable levels of impacts in
accordance with IFC PS 6 relating to biodiversity and natural resources. The
baseline studies for flora and fauna will be used to establish the classes of
habitat within the defined study area. The ERM terrestrial ecology technical
lead as well as the overseeing ERM ornithologist will conduct one site visit to
the study area to confirm the limits of the terrestrial ecology baseline studies
and to become familiar with the project setting prior to initiating the impact
assessment.

Baseline Studies Fauna

In addition to flora, the Terrestrial Ecology Assessment will focus on the


presence of terrestrial mammals, reptiles and amphibians, and rare and
endangered species that may inhabit the study area. The species composition
and physical structure of the vegetative community documented in the flora
surveys will provide important information about the existing wildlife habitat.
The main objective of the study is to identify, describe, and classify the fauna
of the study area and to use the data to assess overall ecological health in the
study area.

The major faunal habitats identified during a desktop review (using satellite
imagery) of the study area will be confirmed through in-field sampling. ERM
will prepare a detailed baseline study plan in concert with the AML specialists
to determine the most appropriate methodology that maximizes accessibility,
health, safety, and the opportunity to observe wildlife habitat and their signs.
The AML specialists will implement the field components of the plan with
oversight provided by ERM.

Following each field confirmation of the preliminary mapping, a field report


will be prepared to document observed habitats and faunal species. Similar to
the vegetation mapping, the habitat mapping will include an annotated map
of the study area which will be included in the EIAs.

Where there is substantial overlap with faunal issues between the Aquatic
Ecology and Terrestrial Ecology technical disciplines, and ERM technical
specialists will work together to formulate effective inspection locations and
procedures to maximize field efforts for each technical discipline.

Baseline Studies Birds

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The main objective of the baseline study is to identify, describe, classify and
document the presence of avifauna and associated habitat within the study
area once the study area has been defined. Due to the sensitivity of the Ramsar
site and the international interest in avifauna, the bird study will be robust.
Collaboration with the Sierra Leone Conservation Societies that have been
involved in avifaunal monitoring in the vicinity of the Project will be critical to
refining the baseline study plan described in this Bid. This collaboration
merges with the public participation process described in Section 5 below.
Multiple surveys to confirm existing use patterns of documented migratory
bird habitats, as well as resident birds.

Impact Assessment Flora

The main objective of the impact assessment is to assess the direct and indirect
environmental impacts of the project on the flora and vegetation communities
of the Terrestrial Ecology study area. Primary tasks will include:

Evaluate the direct and indirect environmental impacts of the project on


flora that may occur as a result of the Phase 2 activities; and

Formulate mitigation measures to avoid or minimize adverse impacts on


flora.

Impact identification and assessment will focus on (but not be limited to) the
following:

Habitat loss/fragmentation due to Phase 2 activities;

Estimate the fragmentation/loss of plant habitats within the terrestrial


ecology study area resulting from the project activities; and

Potential impacts to rare or endangered plant species that might occur in


the study area.

Impact Assessment - Fauna

The main objective of the impact assessment is to assess the direct and indirect
environmental impacts of the project on the mammals, reptiles and
amphibians, and rare and endangered species of the terrestrial ecology study
area. Primary tasks will include:

Evaluate the direct and indirect environmental impacts of the project on


mammals, reptiles and amphibians, and rare and threatened species that
may occur as a result of the Phase 2 activities; and

Formulate mitigation measures to avoid or minimize adverse impacts on


mammals, reptiles and amphibians, and rare and endangered species.

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Impact identification and assessment will focus on but not be limited to the
following:

Fragmentation and loss of fauna habitats as a result of the Phase 2


activities and the consequent impacts on select fauna;

Impact assessment on migration corridors for large mammals;

Impacts on mammals, reptiles and amphibians, and rare and threatened


species due to workers exploitation of fauna resources worker poaching,
especially in the construction phase of the project as a result of the
presence of a large number of workers in the project area.

Impact Assessment - Birds

The main objective of the impact assessment is to assess the direct and indirect
environmental impacts of the project on birds and their habitat within the
terrestrial ecology study area.

Evaluate the direct and indirect


environmental impacts of the project
on avifauna, including rare or
endangered bird species, that may
occur as a result of the Phase 2
activities; and

Formulate mitigation measures to


avoid or minimize adverse impacts
on avifauna in accordance with international standards.

Impact identification and assessment will focus on (but not be limited to) the
following:

Important bird area impacts;

Impacts to terrestrial habitats required for migratory and resident


avifauna; and

Fragmentation or loss of habitat due to Phase 2 activities.

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Limitations and Assumptions

The following limitations and assumptions form an explicit part of this assessment:

ERM understands that the AML specialists will implement the field sampling required for
terrestrial ecology, including the bird surveys, at no cost to ERM. ERM will provide
oversight with the field implementation;
The coverage of the high resolution satellite imagery that has been purchased already by
AML is not defined; therefore, budget has been included to cover the cost of remaining
portions of aerials with near infra-red sensor imagery.

4.3.8 Task 8 Aquatic Ecology

This study will focus on the assessment of aquatic ecosystems potentially


affected by the development. The following numbers of sites are considered
necessary for an assessment of the aquatic systems associated with the above
developments:

An overview of Google Earth Imagery has revealed seven potential


aquatic sites along the 40 km new rail route. The new rail route from Lungi
Lol to Lungi follows a watershed and only downstream sites of the
proposed railway line are thus considered.

Port Loading Facilities include aquatic systems. These will be assessed for
the preferred port option;

Maps provided by AML suggest that approximately nine aquatic sites


would be required for the Tonkolili Mine and associated aquatic systems.
These include both upstream and downstream sites to assess the extent of
impacts of the various activities there on the aquatic systems.

A total of 18 sites are therefore considered necessary for this study, and costs
assume the assessment of two aquatic sites per day. Aquatic assessments will
be conducted to meet the 2012 IFC Performance Standards, which require
environmental resources to be assessed through more than a single field visit,
in order to obtain an overview of seasonal variations and migratory species
dependent on the respective ecosystems. Separate High Flow (October /
November) and Low Flow (April) assessments are therefore proposed.

Methodology

Fieldwork at each site will comprise the following


activities:

Water quality samples will be taken and submitted


to an accredited laboratory for analysis of standard
constituents;

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Diatom (unicellular algae) samples will be taken and submitted for
analysis;

The Aquatic macro-invertebrates will be sampled, identified and


sensitivity of the site determined based on composition and abundance of
invertebrate communities using SASS5 assessment methodologies;

Fish will be sampled using a variety of non-lethal techniques that include


electroshocking, fyke nets and hand-operated seine nets. All fish species
will be identified and sensitivity of the systems assessed using Fish
Response Indices based on composition and abundance of fish
communities;

Assessment of the integrity of in-stream and relevant to surrounding


habitats such as the VEGRAI (Vegetation Response Assessment Index).

Equipment required includes various nets, electro-shockers, sieves, trays,


life vests, cameras, binoculars, GPS, batteries and field guides. The travel
arrangements must allow for NSS to bring the above equipment, estimated
at approximately 130 kg;

The study needs to incorporate different seasons, and aquatic studies need to
include both High Flow (Oct / Nov) and Low Flow (Mar / Apr) assessments.
Timing for initiation of the study will determine which of these assessments
are in the first and second field visits.

4.3.9 Task 9 Marine Ecology

As per the ToR, it is understood that this component required for the ESIA,
will be the subject of a separate tendered work package. The results of this
separate work package will be made available so as to incorporate them into
the ESIA for the Port and Rail.

A key consideration which must form the basis of baseline data pertaining to
the marine and coastal environment is the designation of the whole of the
Sierra Leone River Estuary as a Ramsar site (Box 4.2).

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Box 4.2 Sierra Leone River Estuary Ramsar Site

Sierra Leone River Estuary. 13/12/99; 295,000 ha; 0837'N 01303'W. The Estuary, near
Freetown Peninsula, is dominated by mangrove systems, with lowland coastal plains to the
north. As it enters the Atlantic Ocean, the estuary widens to about 11km and deepens to form a
natural harbour said to be the third largest in the world. 19% of Sierra Leone's total mangrove is
included within the site. The site exceeds the 1% threshold for at least eight water bird species,
namely Ringed and Kentish Plovers, Sanderling, Curlew Sandpiper, Whimbrel, Greenshank
and Redshank, and Western Reef Heron; breeding habitat is supported for some of these. More
than 20,000 individuals have been recorded for some water bird species, and in 1995 more than
10,000 were recorded for 36 species. The Estuary is threatened by vegetation clearance and
unsustainable fishing, and efforts are being made strictly to conserve certain core areas within
the site. Vast areas of untouched mangrove forest still exist, however, and traditional fishing
and agro-forestry for fuel wood can be managed sustainably in collaboration with an existing
EU-funded Artisanal Fishing Community Development Programme. Fine beaches in some
areas provide hope for well-managed tourist development, especially in light of the presence of
an historic slave castle on Bunce Island, and so ecotourism development is considering
promising. Ramsar site no. 1014. Most recent RIS information.
Source: http://ramsar.wetlands.org/Database/Searchforsites/tabid/765/Default.aspx

A key focus must be the gathering of additional information regarding the


designation and protection afforded to the
Sierra Leone Ramsar site with a view to
obtaining an understanding of the
ecosystem functioning of the coastal and
marine environment (from plankton
through to birds and mammals). This will
include a review, in line with the
requirements of IFC Performance Standard
6, of any potential critical habitats.

4.3.10 Task 10 - Social Impact Assessment

Social Baseline

There are a variety of elements which form a social baseline as provided in Box
4.3 below.

Box 4.3 Elements of a Social Baseline

Demographic characteristics (ethnicity, religion, in and out migration);


Traditional institutions and community based organisations;
Education;
Health (malaria, HIV/AIDS, river blindness, etc.);
Vulnerability (including ethnicity, child labour) and Human Rights;
Gender issues
Land use and land tenure;
Livelihoods and employment (fishing, farming, petty trading);
Food security
Infrastructure (schools, roads, health facilities, electricity, water, markets, housing, etc.);
Cultural heritage resources
Key local development issues; and
Attitudes and perceptions of the project.

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The RFT does not specify the number of settlements in/near the project
footprint or their populations. For the purpose of the baseline, ERM will
collect data at a representative sample of settlements in the area, including
those that will potentially require resettlement, mainly from within the TSF
and impoundment area for the Mawuru reservoir. Therefore, for the purpose
of this bid, ERM has assumed the number of sample settlements based on the
mapping provided in the RFT:

Mine Lease Area x 20 settlements

Narrow Gauge Railway - 40km spur from Lungi Lol to Tagrin x 10


settlements;

Port Lease Area (Tagrin Point) x 5 settlements

Pepel x 5 settlements

TOTAL 40 settlements

The number of settlements that need


to be surveyed will be confirmed
during scoping. If there is a need to
collect data at more settlements,
ERM will discuss this with AML. It
should be noted that a RAP requires specific asset based surveys at every
affected household. This survey is simply to obtain an understanding of the
social and health context of the project area and the scope/scale of potential
resettlement. If a RAP is required, additional surveys will need to be
commissioned by AML under a separate contract.

A team of social specialists comprising ERM staff, a local social development


consultant provided by AML and DDC will carry out focus group discussions
and settlement level and household surveys, in a sample of settlements within
the 500m corridor. Key informant interviews will also be conducted at a
district and settlement level. These activities are described below:

Focus group discussions (FGDs): Semi-structured meetings with men and


women in every sample settlement to gain a good understanding of the socio-
economic issues in the local communities, including livelihood activities such
as farming, fishing and hunting. A smaller sample of youth FGDs will be
held to understand issues faced by this group such as access to education and
employment. Special attention will be paid to vulnerability, human rights,
gender issues, cultural heritage and health issues.

Key informant interviews (KIIs): Interviews with individuals who have


knowledge of a specific subject or are informed members of the community,
such as government representatives, local leaders, religious leaders, school
teachers, healthcare professionals, NGOs etc.

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Settlement level surveys: Surveys conducted with the village headman in
settlements to gain information that is otherwise difficult to obtain.
Information gathered will include quantitative and qualitative data such as
demographics, livelihoods, infrastructure, presence of associations (livelihood
and traditional groups) and presence of cultural heritage. The survey will
include a ground truthing exercise using a GPS to map all the sites of social
interest such as health centres, schools, water resources/wells, graves,
religious buildings etc.

Household surveys: In Sierra Leone, a household is defined as a person or


group of persons related or unrelated who live together and make common
cooking arrangements (i.e. sharing a cooking pot). (1) Therefore they may be
more than one household in an inhabited structure (a dwelling/house). On
average there are four households per structure. A household survey will be
conducted using a random sampling strategy based on a 95% confidence rate.
Data collected will include qualitative and quantitative information including
demographics, livelihoods and land use and ownership, income and
expenditure, health and information regarding positive and negative impacts
experienced by the household.

Fisheries assessment: An assessment of the fisheries offshore from the preferred


port option will also be carried out. The household surveys and FGDs will
evaluate:

who/how many people use this areas to fish;

what do they catch and when;

how important are these fisheries to their overall livelihoods (compared


with other sources of income);

can they fish elsewhere and how easily could they move to other locations
to fish?

A fish catch survey will also be carried out. The social fisheries assessment
will complement the marine survey aspect of the baseline data collection that
will focus on the ecology of the fisheries and their importance.

As well as collecting socio-economic information, these activities will also


inform the EIA-SIA with regard to positive and negative impacts as well as
community needs and expectations.

Prior to social baseline data collection activities, ERM will work with AML
and DDC to plan fieldwork and to develop the field tools such as interview
protocols, survey forms and data entry spreadsheet. As mentioned in Section
4.2.6 these activities will be carried out at the same time as scoping disclosure.

(1) Government of Sierra Leone, Sierra Leone Integrated Household Survey (SLIHS) 2003/2004. Published November 2007. p. 3

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For the purposes of the Commercial Bid, it is expected that the following
teams will be required:

Social team project manager to oversee all field activities and carry out
consultation meetings with the national and district level authorities
together with an experienced social development consultant provided by
AML;

The corridor will be divided into two areas; Mine lease area and rail east
and port area and rail west. Therefore ERM proposes two data collection
and consultation coordinators to manage activities in these areas; and

For each of the two teams described above, it is anticipate that ERM will
require the following DDC/Sullay Kamara consultants:
Public participation/consultation and focus group team x 8 people
Key informant interviews (district and local level) & settlement level
surveys x 2 people
Enumerators (household survey) x 8 people
Data entry team x 4 people

AML Field Officers will be required to assist with field planning and to
accompany social teams;

Note: The number of local consultants is dependent on the number of


settlements and households identified in the project area. ERM will
decrease or increase these numbers if required, in discussion with
AML following scoping.

These teams will be supported by the following specialists:

Statistician/data entry manager to ensure quality control of the household


survey data entry and analysis;

A health specialist to assess perspective impacts on specific issues related


to large scale mining projects;

Human rights specialists to identify issues that will need to be covered in


the baseline;

Resettlement advisor to provide support to the social team with regard to


issues affecting communities that may be physically and/or economically
displaced;

Local fisheries expert supported by ERM social fisheries specialist; and

A local cultural heritage expert will also work closely with the social team
to provide local context with regard to archaeological and sacred areas.
Full details of the cultural heritage study are provided in Task 11.

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The full team structure is provided in Figure 7.2 of the project team section of
this bid. This team will be discussed and agreed with AML based on further
understanding of the extent of the project and number of settlements
potentially affected by the proposed phase 2 operations.

Social Impact Assessment

A critical element of the social impact assessment is the social baseline as it


allows for an understanding of the social context and issues that could be
positively or negatively impacted by AML. An integrated approach will be
used to assess impacts and assessments from the environmental specialists
including noise, air and hydrology will be used to feed into the SIA.

The SIA will consider the following elements that have already been affected
by phase 1 and those that will potentially be impacted by Phase 2 of AMLs
operations, both positively and negatively:

Health;

Vulnerability and gender;

Livelihoods and the economy;

Social infrastructure (including inhabited structures/dwellings, roads,


water resources, sewerage);

Cultural heritage (including sacred sites and graves);

In-migration;

Human rights; and

Potential physical and economic displacement if there is no alternative


mitigation strategy. Should potential displacement be identified, the team
will develop a Resettlement Management Plan (RMP) as required by the
government regulations. This would be a high level plan outlining the
companies approach to resettlement. Should AML require a detailed
Resettlement Action Plan (RAP), this will need to be commissioned by
AML separately from the EIA and SIA reports detailed in this bid.

Data related to these elements collected during the social baseline survey will
be used to inform the EIA and SIA. However, other impacts identified during
public participation activities will also be considered. All impacts will be
ranked using an integrated methodology. Mitigation measures will be
proposed to minimise impacts in accordance with the IFC Performance
Standards and local requirements.

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Assumptions

An experienced Social Development Consultant will be made available by AML, free of


charge, to assist with impact analysis, development of socio-economic surveys etc., for
three months.
AML Field Officers will be available to assist with the organisation of data collection
activities and accompany teams to meetings and settlements.
AML will finance and coordinate logistical aspects of data collection activities e.g. car hire,
provision of water, accommodation, printing of surveys etc.

4.3.11 Task 11 - Cultural Heritage

ERM will conduct cultural heritage baseline surveys for the Tonkolili mine
site, and within the Tagrin port and 40km railway spur areas. This will
include an assessment of archaeological sites, cemeteries and other
sacred/religious sites. It will be important to visit Bunce Island, where a slave
castle is located, as this is a known tourist attraction located close to the
Ramsar site/Sierra Leone Estuary.

This survey will involve a ground truthing exercise comprising of visits to the
relevant sites in each community with a GPS to identify the exact locations of
cultural/sacred sites and assessing the types of sites to capture and an
understanding of their cultural significance and importance to local
communities. This will be undertaken by a local expert with knowledge of
Sierra Leones cultural heritage. This data from the study will inform the
assessment of potential impacts to cultural heritage during the EIA-SIA
process.

Note: There are secret sites in Sierra Leone which are established by
traditional groups to perform ceremonies. Gathering data on the
location of these sites may be difficult and as such it may not be
possible to locate all significant sites during the survey. The
process for identification of these areas prior to construction will
be outlined in the cultural heritage section of the Social Impact
Management Plan (SMP) to be developed.

At this stage is unknown how many sites will be included in the survey. This
will be assessed during scoping. Any implications to the budget will be
discussed and agreed with AML.

4.3.12 Task 12 Transportation Impact Assessment

The main objective of this task is to identify, describe, classify and assess the
direct and indirect impacts Tagrin port and the 40km rail extension on the
regions transportation. The Traffic Impact Assessment will assess vehicular
(i.e., car and truck) traffic, as well as rail traffic along the transport corridor
described in the RFT. The assessment will also cover assessing traffic related
impacts around the mine.

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Desktop Study

ERM will conduct a desktop study which will include, at a minimum:

Review results of previously conducted studies and previous EIAs listed


in the RFT.

Other publicly available data from government and private-sector entities


regarding traffic and transportation in the study area.

Field Studies

ERM and its sub-consultant (assumed DDC) will conduct observations of


transportation facilities that could be impacted by the Project. ERM and/or
DDC personnel will travel the length of the rail corridor (to the degree
possible, given existing roads), and will document road crossings and other
locations that could be impacted by increased rail traffic. These personnel will
also observe and collect information on water-borne traffic in the vicinity of
the alternative port sites. The study will also include a traffic count around the
mine site.

Under ERMs supervision, DDC will also count traffic at up to four locations
(primarily in the Tagrin Basin area, as specified in the RFT), for two days each
(one weekend day and one weekday). This methodology has been used for
other EIAs in Sierra Leone, and will provide a generalized level of information
about traffic and transportation conditions.

ERM will prepare a baseline study report summarizing the findings of the
desktop and field studies.

4.3.13 Task 12 - Greenhouse Gases (GHG) and Emissions

The new IFC Performance Standards


(2012) explicitly require assessment of
climate change risk and an
understanding of greenhouse gas
emissions and energy use; such
requirements are listed in the IFC PS 1
and 3.

With this in mind, it is important to investigate the risks climate change poses
to new developments. This Climate Change Specialist Study will:

estimate the operational carbon footprint of AMLs proposed activities in


Sierra Leone including the mine, port and rail facilities;

assess options for increasing resource efficiency and minimising the


carbon footprint during design, construction and operation;

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understand exposure to regulation such as carbon taxes and sectoral
emission reduction targets and mechanisms;

undertake a high level assessment of the physical risks facing the


development, such as water availability, floods, lightning etc.; and

Identify adaptation measures which could be implemented in order to


reduce the risk or take advantage of opportunities facing African Minerals
activities in Sierra Leone.

ERMs assessment of the impacts of climate change on AMLs activities will


involve two key work areas with a focus on GHG emissions and physical
climate risks. Table 4.1 indicates the activities which will take place under each
stage of the environmental impact assessment process.

Table 4.1 Overview of Approach to Climate Change Specialist Study

Section GHG Emissions Assessment Climate Risk Assessment


Baseline Specialist Review of Sierra Leones Assessment of existing risk to area
Study National Greenhouse Gas under investigation through analysis
Inventory; of:
Review of the emissions historic weather patterns at the
associated with similar site (e.g. temperature, rainfall
operations in Sierra Leone etc.);
and other countries; site specific stream flow and
Review of the national and drainage information where
international climate change available; and
policy framework for energy natural climate hazards (e.g.
and greenhouse gas floods, droughts etc.).
emissions.
Environmental Development of GHG Development of future climate
and Social Impact emissions inventory for a scenarios based on publically
Assessment year of full operations; available climate change
Development of high level, projections;
indicative, future GHG Analysis of location, layout and
emission scenarios for Sierra nature of the proposed African
Leone; and Minerals facilities/assets/
Assessment of impact of operations/ products/supplies;
project emissions against and
national emissions and in Assessment of vulnerability of
comparison with similar activities to potential physical
operations. climate impacts.
Environmental Assessment of potential Assessment of potential
and Social resource efficiency adaptation interventions to
Management Plan opportunities. minimise risk and enhance
opportunities.

GHG Emissions Assessment

A baseline assessment of GHG emissions in Sierra Leone and from similar


industrial activities will be undertaken through a desktop review of the
following:

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Proposed activities and identification of key greenhouse gas emission
sources expected from activities including the plantations, kilns, quarries,
iron and steel works and pelletising plant;

Sierra Leones National Greenhouse Gas Inventory;

The emissions associated with similar operations in Sierra Leone and


globally; and

The national and international climate change policy framework for


energy and greenhouse gas emissions.

GHG Emissions Impact Assessment

The Greenhouse Gas Assessment will involve estimating the operational


carbon footprint of the African Minerals proposed activities in Sierra Leone as
well as an assessment of the impact of these emissions with respect to national
GHG emissions and against benchmark organisations globally. ERM
proposes using the 2006 IPCC Guidelines for National Greenhouse Gas
Inventories and the GHG Protocols Corporate Accounting and Reporting
Standards as developed by the World Resources Institute (WRI) and the
World Business Council for Sustainable Development (WBCSD) which
includes specific guidelines for calculating emissions from iron and steel
facilities. This will provide a sound basis for estimating the operational carbon
footprint of the activities in line with IFC accepted standards.

Definition of Boundaries and GHG Emission Sources and Data Collection

This activity will review the organizational boundaries and establish the GHG
operating and reporting boundaries for the AMLs carbon footprint.
Organisational boundaries, in this instance, will determine which operations
will be included, while operating boundaries determine which emission
causing activities will be included in the Carbon Footprint, in terms of scopes
1 and 2 as illustrated in Figure 4.2.

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Figure 4.2 Summary of Emission Scopes

It has been anticipated that Scope 3, or indirect, emissions will be excluded for
the purposes of this study. Scope 3 emissions would typically include
emissions from outsourced activities, such as contractor vehicles and
employee business travel. Given that the footprint will be calculated on a
hypothetical basis, the uncertainty associated with Scope 3 emissions is such
that these may not be quantifiable until the sites are operational. This is in line
with IFC Performance Standard 3 which indicates that the client will quantify
direct emissions from the facilities owned or controlled within the physical
project boundary and indirect emissions associated with the off-site
production of power used by the project (i.e. Scope 1 and 2 emissions).

In order to develop the footprint boundary, ERM will review the project
design information provided by AML and will discuss the project and
potential emission sources with African Minerals personnel in order to:

Define sources of emissions;


Delineate the overall boundary for calculating the footprint; and
Confirm additional data requirements and collection responsibilities.

Based on initial assumptions it is anticipated that the Carbon Footprint will


include, but not be limited to, emissions from the sources shown in Table 4.2.

The carbon footprint calculations will be done for the operational phase of the
proposed project only. Emissions from construction and decommissioning
will not be quantified, as this type of assessment involves the assessment of
Scope 3 emissions which is outside the scope of the proposed footprint. An
operational Carbon Footprint will be determined for the development based
on the project description, project design specifications and information
collected from AML as outlined above.

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Table 4.2 Summary of Emissions and Data Sources

Scope Emissions source Possible Data Source


Scope 1 The consumption of energy fuels such as Litres or kilograms of
(direct) diesel, petrol, LPG, coal, heavy fuel oil, planned energy fuels in
coke, naphtha, wood, anthracite and natural stationary and mobile
gas in stationary equipment such as boilers, equipment.
furnaces or generators; Planned kWh of
The consumption of energy fuels such as electricity generated.
diesel, petrol, LPG and natural gas in Kilograms of
mobile operating equipment such as cars, refrigerant used in air
trucks and forklifts; conditioners
Generation of electricity, steam, or heat in
equipment that is owned or controlled by
the reporting company;
Potential refrigerants from air conditioning
unit leakage.
Scope 2 Purchased electricity consumed on site. Planned kWh usage
(indirect)

4.3.14 Task 14 - GIS Development & Support

ERM will provide for Geographic Information Systems (GIS) support during
the EIA and SIA processes. This shall include spatial data management, GIS
support and mapping for the proposed project.

Assumptions

The acquisition of data/information other than noted in this Bid is not provided for;
It is assumed that all data provided to ERM are digitally available in shape file format or
raster based formats and ready to use (i.e. no editing of raw data will be required and
spatially referenced);
No additional data capture is quoted for this Bid assumes that all the data is already
available in digital format (CAD, GIS and imagery) other than what is quoted above;
It is assumed that some of the data sets will have to be re-projected and/or converted from
other digital formats to ESRI shape file format; and
All data that has come from outside of ERM needs to referenced and contain metadata.
ERM will not be liable for the integrity of spatial data provided by other parties.

4.4 PHASE 3 IMPACT ASSESSMENT AND REPORTING

According to the Environmental and Social Regulations for the Minerals


Sector, is required to submit and EIA and SIA compliant with Section 28 and
Schedule Five and Six of the Regulations. The general structure and
information to be provided in the EIA Report includes the following:

4.4.1 Task 1 Project Description

The project description will include descriptions of facilities and activities that
are essential for the successful operation of the Project. We note that this step

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is entirely based on information provided by AML. To ensure that sufficient
time is available for the impact assessment and for the development of
mitigation measures, the Project description will need to be finalized (frozen)
at an agreed point for the purpose of the EIA. The design freeze point will
be discussed with AML throughout and a date will be agreed upon before the
start of the impact assessment study. Any significant changes in Project design
and execution after any such cut-off date may lead to schedule and budget
impacts.

4.4.2 Task 2 Legal and Policy Review

ERM will provide a full description of local and international requirements


deriving from Sierra Leone legislation, World Bank Guidelines and
Operational Procedures, and IFC Performance Standards and EHS Guidelines
affecting the Project and the Environmental Study. A review of the existing
and new Sierra Leone legislation and relevant to the project will be
undertaken.

4.4.3 Task 3 Baseline Summary

This will be compiled from the specialist studies listed above.

4.4.4 Task 4 Appraisal of Strategic Alternatives

ERM will review and consider strategic Project alternatives and document the
Project history and alternatives that have been considered in the past or are
still under consideration during the current studies. This will form an
important part of the information developed to inform and engage
stakeholders in the process, and particularly to brief the affected communities
during the consultations.

4.4.5 Task 5 Impact Assessment and Mitigation

The prediction and evaluation of impacts will be undertaken in accordance


with current international good practice in impact assessment, using
appropriate modelling and other methods to provide quantitative predictions
and qualitative descriptions of impacts. It will cover the positive and
negative, planned and unplanned, permanent and temporary, long term and
short term, direct, indirect and induced, and cumulative impacts of the
development on all aspects of the physical natural, social-economic and
cultural environment affected by the Project. Impact terminology to be used
in the EIA and SIA are provided in Table 4.3.

Table 4.3 Impact Terminology

Term Definition
Impact Direction
An impact that is considered to represent an improvement on the
Positive
baseline or introduces a positive change.
Negative An impact that is considered to represent an adverse change from the

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Term Definition
baseline, or introduces a new undesirable factor.
Grouping of Impact
Routine/Planned Occur as a result of expected common or regular Project activities.
Impact
Non- Occur as a result of exceptional events or upset / emergency
routine/Unplanned conditions including external events such as natural disasters
Impact affecting the Project.

Impacts that occur as the Project is constructed (e.g. the loss of


Permanent
habitats or cultural sites) and that cannot be reversed over time.
Impacts that occur over the long term during operation of the Project
but stop and may be reversed on cessation of Project operations.
These will include impacts that may be intermittent or repeated
Long Term
rather than continuous if they occur over an extended time period
(e.g. repeated seasonal disturbance of species as a result of, for
example, mine operations, operational employment etc.).
Impacts that will occur over a time-limited, short term period, for
Temporary/Short
example during construction activities which may be reversed on
term
cessation of those activities.
Impact Type
Impacts that result from a direct interaction between a Project
activity and the receiving environment (e.g. between occupation of a
site and the pre-existing habitats or between an effluent discharge
Direct (Primary)
and receiving water quality). The Project includes the main
Impacts
development plus all ancillary activities linked to development the
Project without which the Project cannot proceed, such as
construction work camps, borrow pits, power lines, water supply.
Impacts that result from further links in the receiving environment,
Indirect (Secondary for example, an effluent may have a direct impact on water quality
and Higher Order) which then goes on to affect aquatic ecology and fish populations,
Impacts then subsistence and commercial fisheries and, ultimately, the
livelihoods of communities depending on these resources.
Impacts caused by developments stimulated by the Project but which
are not essential to its development.(e.g. influx of migrants seeking
opportunities created by the Project, construction of new housing and
Induced Impact
infrastructure to serve such unplanned in-migration, employment
and development opportunities created by the increased disposable
income of workers hired by the Project or its suppliers).
Impacts that act together with other impacts from concurrent or
planned future third party activities to affect the same resources
and/or receptors as the Project. The assessment will take account of
pre-existing and committed developments and other developments
Cumulative Impact planned in the area which is ahead of the Project in their
development lifecycle. (NB cumulative impacts with other Projects
are distinguished from combined impacts; that is impacts of
different types arising from the Project itself that affect the same
resource or receptor in an additive or possibly synergistic manner).
Those impacts remaining once agreed mitigation measures are
Residual Impact
implemented.

ERM will complete a first round assessment to predict impacts and evaluate
their likely significance, so that mitigation of significant impacts can be
developed with the engineers and Client during the on-going design studies.
This will be an iterative process of identifying options for mitigation,

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exploring their costs and benefits and deciding what is reasonably necessary,
practicable and affordable for the Project.

Once the initial assessment is complete the areas in which significant impacts
on the physical, natural, social, economic and cultural environment of the
Projects area of influence are likely to occur will be clearly identified with an
evaluation of their severity. The evaluation of significance will take into
account the scale, geographic extent and distribution, duration and frequency,
reversibility, and probability of occurrence of changes in environmental and
social conditions, and the value, sensitivity and ability to adapt (resilience) of
affected resources and receptors. It will also explicitly take account of the
perception of the importance of the impact by local communities. The criteria
for evaluation of significance will be clearly explained in relation to each type
of impact.

Where there is the potential for significant adverse impacts, options for
mitigation will be explored. These will include measures to prevent or reduce
impacts where possible, and where impacts are unavoidable, to remedy them
or to provide compensation or offsetting. Options for delivering or enhancing
benefits from the Project will also be identified.

At an appropriate stage in the programme, ERM will hold a Mitigation


Workshop involving the ESIA teams, the engineers and Client teams. The aim
will be to review and approve the mitigation proposals so that these can be
taken into account in the final assessment and presented in the reports.

4.4.6 Task 6 Preparation of EIA and SIA Reports

Once the preferred scheme is defined and mitigation measures have been
agreed, ERM will review the findings of the initial assessment to provide a
prediction and evaluation of residual impacts after mitigation. The results
will be reported in a comprehensive EIA report. This will be supported by a
series of specialist study reports presenting detailed findings from the three
main strands of work. The draft reports will be prepared for internal review
and approval prior to its wider disclosure (see below). We have assumed that
there will be one round of review and comment and that we will be provided
with one set of consolidated comments from AML.

4.4.7 Task 7 Authority Submission of Reports and Review Period Support

ERM will ensure that the aforementioned documentation is prepared to


permit the submission to the relevant authorities. It is understood that AML
will provide in-country support, logistics and printing with respect the
submission of the reports to the authorities, and no in-country travel or
meetings will be required by ERM.

There are no fixed timeframes in terms of the review period by the authorities
in terms of the Environmental and Social Regulations for the Minerals Sector,

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(Draft), and there is likely to be significant uncertainty in terms of the true
timeframes with respect to any responses to the EIA and SIA reports. This is a
political/legislative issue and ERM cannot be held liable for any delays in
terms of the review and responses by the authorities.

ERM will provide three weeks of project management support during the
review process in terms of addressing any modifications to the scope of the
assessment or additional information that may be required. Where additional
studies or requirements, outside the scope of work of this bid, are requested
by the authorities, this will be discussed with AML in terms of potential
variations. This may include additional studies, public meeting or
engagement.

4.4.8 Task 8 - Public Participation EIA-SIA Disclosure

Once the draft EIA and SIA reports have been developed, disclosure will need
to be undertaken. This process should be undertaken in collaboration with the
EPA-SL.

In order to meet internal requirements all stakeholders will need to be re-


visited and invited to comment on the impacts identified, development
benefits envisioned and the appropriateness of proposed mitigation measures.

We have assumed that the same approach will be applied to the EIA-SIA
disclosure as was used during the initial round of engagement held during the
Scoping Phase (Section 4.2.9).

4.5 PHASE 4 MANAGEMENT PLANS

ERM will prepare the suite of management plans, which are required for
submission with the EIAs (Section 4.6.1) and SIAs (Section 4.6.2) in
compliance with the documentary requirement established in Section 29 of the
Environmental and Social Regulations for the Minerals Sector, (Draft) and
applicable schedules. At this stage, the suite of plans is limited to those
defined below. It is important to note that these will be framework
management plans.

4.5.1 Task 1- Environmental Management Plans

An Environmental Management Plans (EMPs) will be prepared as per the EIA


Regulations1. In meeting regulatory requirements, the EMPs will contain, as a
minimum, the following:

Section 1 Project status


Section 2 Description of activities

(1) 1 Environmental Regulations for the Minerals Sector, 2011

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Section 3 Description of environmental values and potential impacts
Section 4 Management measures for each of the following environmental
aspects, were applicable:
Air: micro-climate, dust, odours, point source contaminants;
Water: natural watercourses, stream sediments, water quality,
groundwater, dams and containments, sewage effluent quality and
control;
Noise and vibration;
Wastes: liquids and solids;
Land, landforms, rehabilitation criteria, landform design, gradients
relating to end-uses;
Dams containing hazardous waste;
Infrastructure: roads, power lines, generators;
Biodiversity: flora and fauna; and
Heritage and cultural conservation features.

4.5.2 Task 2- Mine Closure Plan (only applicable to Tonkolili Mine EIA)

ERM will update the current AML Mine Closure Plan (MCP) for joint
submission with the EIA and SIA. The MCP will comply with the
requirements established in Schedule 9 of the Regulations1 for the Minerals
Sector, which provide a guideline as to the contents of the Closure Plan.

4.5.3 Task 3- Monitoring Plans

The monitoring plan will be designed to assess the effectiveness of


environmental control measures (preventive measures, mitigation and
compensation) set forth in the EMPs. It will refer to approved environmental
standards and/or internationally acceptable standards and will indicate the
following (as a minimum):

Environmental aspects to be monitored;


Monitoring and inspection methodology;
Inspection frequency;
Location of monitoring stations;
Reporting schedules;
Equipment and supplies;
Administration; and
Technical team.

4.5.4 Task 4- Environmental Contingency Plans

Section IX of the Draft Regulations refers to an Environmental Contingency


Plan (ECP) which must be included in the EIA reports and must contain an
Environmental Risk Assessment (ERA). These risks must cover reputational
risks and risks that could lead to fatalities, in particular accidents and oil spill
responses. The risks posed by tailings failures and risks as a result of chemical
spills during processing are to be confirmed by AML.

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4.5.5 Task 5- Social Impact Management Plans (SMPs)

Social management plans will be prepared stipulating the measures to prevent


mitigate or compensate for social impacts due to project if necessary. The
SMPs will outlines the measures that will be undertaken by the Applicant to
adhere to all of the obligations detailed in the Regulations1 with regard to the
construction, implementation, operation and closure of mining activities and
operations. They will also contain, as a minimum, the following criteria (as
defined in the Regulations1):

Section 1 project status

Section 2 Description of activities

Section 3 Description of social and local economic values and any sensitive
sites and potential impacts

Section 4 Management measures for each social and local economic value.

In addition, the social management plan shall include sections detailing


the following:-
references and links to a public consultation and participation plan;
a grievance or conflict management plan;
timescales and estimated costs for the work; and
provision for monitoring and evaluating the results, and where
necessary, taking extra measures.

4.5.6 Task 6- Communication and Public Participation Plans (CPPPs)

Communications plans will be developed according to the specifications


presented in the Regulations in order to manage public participation and
stakeholder engagement during the project planning, environmental and
social impacts assessment and follow-up and monitoring processes. The CPPP
will indicate how public consultation is to be conducted, how concerns raised
will be identified and how these concerns will be managed by the Applicant.

4.5.7 Task 7- Community Development Plans

According to Section 139(1) of the Mines and Minerals Act 2009, and the
Regulations1, the holder of a mining license is required to have and implement
a community development agreement with the host community. The
Community development agreement is based on the Community
Development Plan (CDP) and must include:

(2) 1 Environmental Regulations for the Minerals Sector, 2011

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a participatory framework;

a statement on the companys policy, procedures and institutional


arrangements necessary to implement sustainable development
opportunities in the Host Community in the social impact assessment or
environmental and social impact assessment and in the social management
plan.

a local employment and procurement strategy that commits the applicant;-


to a policy of utilizing local employment wherever practical during all
stages of mine development; and
to purchasing local materials and products wherever practical.

a gender strategy outlining actions for improving the condition of women


and children within the Host Community who are likely to be affected by
the planned operations.

The structure of the CDPs will follow the requirements of the Regulations.

4.5.8 Task 8- Resettlement Management Plans (RMPs)

The RMP is a framework which broadly identifies the objectives, principles,


policies, procedures, organizational arrangements and the timeframe and cost
for managing resettlement.

Note: ERM understands that this is a likely component of the


project. Should AML require a detailed Resettlement Action
Plan (RAP) usually required by international lenders, this
will need to be commissioned by AML separately from the
EIAs and SIAs detailed in this bid.

4.5.9 Task 9-Socio-Economic and Health Monitoring Plans (SEHMPs)

This plan will assess the effectiveness of socio-economic and health control
measures (preventive measures, mitigation and compensation) set forth in the
SMP. Reference must be made to the socio-economic, health standards and
other applicable standards.

The SEHMP will indicate the following:

Socio-economic and health aspects to be monitored;


Monitoring and inspection methodology;
Inspection frequency;
Location of monitoring stations;
Reporting schedules;
Equipment and supplies;
Administration; and
Technical team.

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4.5.10 Task 10- Socio-Economic Contingency Plans (SECPs)

These plans will contain a Social and Economic Risk Assessment (SERA) and a
contingency plan. This will be compiled to analyse the likelihood of an
extreme accidental or natural event causing major effects on the social sector
and human health. Socio-Economic Contingency Plan (SECP) will set out
control measures to be applied in case of the emergency situations identified
in the SERA.

4.5.11 Task 11-Social and Economic Components of the Closure Plans

This is a conceptual closure plan for mining operations and this plan will form
the basis for developing a comprehensive MCP as required in Section 47 and
the Ninth Schedule of the Regulations.

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5 PUBLIC PARTICIPATION PROCESS

5.1 PUBLIC PARTICIPATION AND CONSULTATION PROCESS

Public participation or stakeholder


engagement is a legal requirement
in Sierra Leonean environmental
and mining law. In addition, it is
an important element of project
development as it minimises
business risk through
management of relationships with
those directly or indirectly
affected, thereby avoiding conflict and project delays, and allowing
participation of the public in decision making.

In Sierra Leone, the 2009 Mines and Minerals Act states that any mining licence
applicant or mining licence holder required by this or any other law to submit
an environmental impact assessment, shall consult the public to introduce the
project to the public and to verify possible impacts of the project from
stakeholders perspectives.

The Environmental Protection Act 2000 states that the EIA should be circulated
to professional associations, Government Ministries and NGOs for comments.
The Director of the Ministry of Environment will make the EIA-SIA open to
comment through publication in 2 consecutive issues of the Gazette and 2
newspapers (with an interval of at least 7 days). Public comments shall be
submitted to the Director within 14 days of the last publication. Following
this process, AML they will have 21 days to respond.

The above is further supported in the draft Environmental and Social Regulations
for the Minerals Sector, 2011, and specifically with respect to Section 15 and 16
that mandates fair and transparent public consultation throughout the life of
the mine.

In addition, international good practice (as defined in the adopted IFC


Performance Standards) requires the development of a Stakeholder
Engagement Plan (SEP) as well as ensuring an Informed Consultation and
Participation (ICP) process. This involves an in-depth exchange of views and
information in an organised and iterative consultation process between the
Project and stakeholders. The findings of the process should be incorporated
into decision making regarding proposed mitigation measures and
community investment opportunities. Box 5.1 sets out the IFC requirements
regarding stakeholder consultation.

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Box 5.1 IFC Requirements Regarding Stakeholder Consultation

Effective consultation should:


begin early in the process of identification of environmental and social risks and impacts
and continue on an on-going basis as risks and impacts arise;
be based on the prior disclosure and dissemination of relevant, transparent, objective,
meaningful and easily accessible information which is in a culturally appropriate local
language(s) and format and is understandable to Affected Communities;
focus inclusive engagement on those directly affected as opposed to those not directly
affected;
be free of external manipulation, interference, coercion, or intimidation;
enable meaningful participation, where applicable; and
be documented.

In line with the Sierra Leonean requirements, herein stakeholder engagement


is referred to as public participation. In order to meet the IFC and local
requirements for public participation, ERM proposes the following tasks.

5.1.1 Communication and Public Participation Plans (otherwise known by the IFC
as Stakeholder Engagement Plans)

As stated in Section XIV of the Sierra Leone Environmental and Social


Regulations for Mining (March 2012), ERM will prepare a Communications and
Public Participation Plan (CPPP) for the mine and for the rail and port areas.
This plan will also be developed in line with the IFC requirements for a
Stakeholder Engagement Plan (SEP). It will be treated as a living document.
Following each stage of consultation, it will be updated with the approach and
outcomes of meetings ensuring that they are well documented. The CPPP will
form an annex to the final EIA and SIA reports, documenting consultation
undertaken as part of the Project.

Additionally, the CPPPs will present the process for identifying and mapping
stakeholders according to their influence on the project, their level of interest
and the degree to which the project might affect them. It will also include
detail the best means by which to communicate with stakeholders. Those
living or working in the project vicinity, for example, will require more
information and dialogue regarding Project activities than those indirectly
affected, and the means by which this engagement is delivered will need to
differ.

Identification of vulnerable groups, as defined in Box 5.2, will be a key aspect


of this process ensuring full participation and representation of all those
affected.

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Box 5.2 Vulnerability

Individuals or groups within the project area of influence who could experience adverse impacts from the
proposed project more severely than others based on their vulnerable or disadvantaged status. This status
may stem from an individual's or group's race, colour, sex, language, religion, political, or other opinion,
national or social origin, property, birth or other status. In addition other factors should be considered
such as gender, ethnicity, culture, sickness, physical or mental disability, poverty or economic
disadvantage, and dependence on unique natural resources.
Source: IFC Glossary of Terms (2006) (1)

Table 5.1 presents a sample of stakeholders to be consulted throughout the EIA


and SIA process and their connection to the Project. The list of stakeholders
will be further developed with AML and as the project progresses.

Table 5.1 Key Stakeholders for Consultation

Stakeholder Group Connection to the Project


Affected Parties
Settlements, including vulnerable groups Will experience impacts (positive or negative)
located within the 500m corridor, around the as a result of the Project.
mine licence area (MLA), Tagrin port and the
40km railway extension,, as well as those who May have expectations regarding development
may be affected by Project facilities (e.g. and benefits in their local area.
construction camps, and disturbance to access
routes, ship loading facilities). Vulnerable Provide information regarding the local
groups may include female headed community that will enable the identification
households, elderly, farmers, youth, physically of potential impacts and mitigation measures
and mentally impaired, migrants, non- as well as identify community needs.
landowning residents.
Potential for impacts to livelihoods
Representatives of important livelihood
associations such as fishing committees,
agricultural cooperatives, sand miners, market
women. Users of ports in Pepel and Lungi
including ferry operators, boat taxis, goods
transportation etc. Other operators in the
500m corridor, such as mining companies
Other interested parties
Authorities and institutions including the Key authorities for approving the EIA.
Ministry of Mining, Sierra Leone Environment
Protection Agency (SLEPA), relevant District May have expectations regarding development
Councils, Ministry of Agriculture, Sierra Leone and benefits for the country or in the local area.
Roads Authority, Port Authorities and groups
connected to the RAMSAR site / Sierra Leone Will enable the identification of potential
River Estuary. impacts and mitigation measures as well as
identify community needs.

(1) IFC Glossary of Terms. IFC Policy & Performance and Guidance Notes. July 2006. Available at:
http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/pol_PerformanceStandards2006_glossary/$FILE/Gloss
ary+of+Terms.pdf [Accessed 28.05.12]

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Key Informants including agencies May have expectations regarding development
responsible for service provision (health & and benefits for the country or in the local area.
education), local and international
environmental and social NGOs (Plan, BRAC, Solicit information regarding the local
The Cotton Foundation). Any relevant community that will enable the identification
international donors (DFID, EU, USAID, etc.), of potential impacts and mitigation measures
representatives of important livelihood as well as identify community needs.
associations such as agricultural cooperatives,
sand miners, market women.

Note: It is currently assumed that the 500m corridor is divided into 250m either side of
the centreline.

5.1.2 Public Consultation: Scoping and EIA-SIA Disclosure

During the EIA-SIA process, ERM proposes to carry out two stages of
consultation in order to ensure information dissemination and participation in
Project planning and disclosure activities, as presented in Figure 5.1 below.
Consultation for the mine and for the port and rail areas will be carried out
concurrently. It should be noted that as part as the pre-scoping tour, ERM will
consult with national, district and local level representatives including the
Paramount Chiefs and community representatives such as youth, women and
other leaders.

Figure 5.1 Stages of Public Consultation

Stage 1: Scoping Disclosure - This stage of consultation will provide details of


current and planned activities as well as findings from the scoping studies in
particular as described in Section 4.2. It will also include other Project details
as presented in Figure 5.1. As legally required in Sierra Leone (1), the final
scoping reports will be published and made available in publicly accessible
places such as the African Minerals website. Copies shall be provided to the

(1) Sierra Leone Environment and Social Regulations for Mining, March 2012, Sixth Schedule: SIA Standards. p. 73

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district and chiefdom authorities. Additionally, ERM will prepare non-
technical summaries of the report which explains its key contents in laymans
terms, to ensure that the information is readily understood. From ERMs
experience of working in Sierra Leone, consideration will be given regarding
low levels of literacy and as such a participatory approach will be used when
consulting with communities.

Stage 2: EIA-SIA Disclosure once the draft reports have been submitted to
the Environmental Protection Agency (EPA-SL) for review, all the
stakeholders will be re-visited and invited to comment on the impacts
identified, development benefits envisioned and the appropriateness of
proposed mitigation measures using the same that was taken during stage 1.
The reports will also be made publically available for comment through a
variety of mediums which may include periodic radio broadcasts, publication
at local town halls, community halls and/or public notice boards.

As required by the Environmental Protection Act 2000, as described in Section


2.1.1, during stage 2, AML will be required to work with the Ministry of
Environment to publish an invitation to comment on the findings of the
reports in the Gazette and 2 other newspapers. There will be a 14 day time
period between the final publication and comments made.

AML, with support from ERM, will have 21 days to address all the issues
raised and documented during EIA-SIA disclosure.

To aid the public participation process, culturally appropriate communication


materials and consultation tools will be developed as described below in Box
5.3. The tools will be tailored to each of the project areas.

Box 5.3 Communication Materials and Tools

Non-Technical Summary to be produced in appropriate languages and at a level appropriate to


the target audience (different versions may be required for different stakeholders, depending on
literacy levels).

Organisation of other appropriate means of dissemination e.g. posters, radio announcements,


etc.

Question and answer (Q&A) document to ensure accuracy and consistency of responses to
questions. This will also aid the management of expectations raised by stakeholders.

PowerPoint presentation describing the project and EIA-SIA process, to be used with
regulatory authorities and NGOs where appropriate.

Participatory consultation tools to be used with local communities to describe potential project
impacts and seek feedback.

Meeting minute template and guidelines for documentation of consultation activities.

Excel consultation database for tracking issues raised. ERM will prepare a basic consultation
database in excel which will include contact details, dates of meetings, issues raised and by
who, actions and dates.

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The affected public and other stakeholders will be informed of consultation
meetings 2 weeks in advance through mediums such as the radio and
newspapers. Additionally ERM proposes that AML Field Officers visit all
settlements to notify the village headman and community members of the
meetings and arranging an appropriate time for them to be scheduled,
capturing all groups within the community.

In order to manage the public participation process ERM proposes the


following:

ERM will work closely with AML and DDC/Sullay Kamara to organise
meetings;

ERM will work with AML to cluster settlement in the 500m corridor in
order to reduce the number of meetings and time required to conduct
consultation. Clustering will be dependent on available transport to
communities to a central location, weather conditions and the ability to
access settlements and distance between settlements, clustering
settlements within a short walking distance;

To effectively document meetings, DDC/ Sullay Kamara will work in


teams of two one person will take minutes and the other will facilitate
the consultation meetings (there will be two teams). ERM will develop a
method for documenting meetings clearly and efficiently so that they can
be reflected in the final EIA and SIA reports, thus ensuring that where
possible and appropriate, community issues are addressed and
suggestions are taken into account;

In order to respond to high level/national level questions regarding the


Project, meetings in Freetown with Government authorities will be led by
senior representatives from AML with support from ERM and / or
DDC/Sullay Kamara;

District and settlement level meetings will be led by DDC/Sullay Kamara


and a representative from AML who is able to respond to technical
questions, if available;

Due to high levels of illiteracy in settlements in the Project area, ERM will
work with DDC/ Sullay Kamara to develop a participatory approach to
consultation to ensure a fully inclusive process of engagement.

Scoping disclosure will be carried out at the same time as social baseline data
collection activities as described in Section 4.3.10 of this Bid.

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Assumptions

As mentioned in the ToR, dedicated representatives from the AML Community Liaison
Team will be available to assist DDC and ERM with stakeholder mapping and public
participation process, including national, district and settlement level meetings.
AML will finance all expenses associated with public participation meetings e.g. hire of
venues, adverts and radio announcements, printing and distribution of documentation and
notices, travel requirements, PA equipment, chairs, etc., libations for chiefs/elders, and
travel and subsistence costs for staff.
It is assumed that all on-site logistical support will be provided by AML during the
meetings e.g. car hire, provision of water, accommodation etc.

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6 PROJECT SCHEDULE

Our preliminary project schedule presented in Table 6.1 is a draft based on our
current knowledge of the project and dependent on AMLs timelines for
submitting the EIA and SIA reports to the authorities. All reports will be
prepared concurrently. Due to resourcing constraints over the Christmas
period, the 15th December to 15th January is not considered in this timeframe.

Table 6.1 Preliminary Project Schedule

Milestone Date
Kick-off meeting Within 2 weeks of Notice to Proceed
Scoping Visit Within 4 weeks of Kick-off Meeting
Scoping Report Within 4 weeks of end of Scoping Visit
Environment Baseline Survey Dry season February 2013
Wet season August 2013
Social Baseline Survey April 2013
Public Participation Stage 1 April 2013
Draft EIA & SIAs September 2013
Public Participation Stage 2 November/December 2013
Final EIA & SIAs January 2014

We propose to discuss and finalise this schedule in coordination with AML


during Project inception and contract finalisation, taking into account any
particular time or logistical constraints. Please note that any delays due to
factors beyond ERMs control such as delays in provision of Project
information from AML, delays in support to travel arrangements, delays in
responding to solicitations for clarifications etc. will not result in the company
being penalised for changes to the project schedule. Any exposure to delays
in the execution schedule foreseen by ERM will be promptly communicated to
AML, and we would propose solutions in order to limit impacts on the overall
EIA and SIA timelines. Note that this schedule remains dependent on the date
of award of the contract.

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7 PROJECT TEAM STRUCTURE AND PROJECT MANAGEMENT

The team has been structured to ensure that we have a mix of international
specialists that have extensive experience in managing ESIAs for large mining
developments to IFC standards.

ERM can offer a highly experience Project Management Team based in South
Africa who will be the key contacts throughout the duration of the project
managing the project schedule, the financial aspects of the project and alike.
We propose Mike Everett as Partner-in-Charge (PIC) who has experience of
managing project like this in Sierra Leone, who will be supported by a Project
Manager (Stephanie Gopaul) and a Programme Manager (Jonathan Van Gool).

The Partner in Charge is ultimately accountable for ensuring ERM


understands and applies the appropriate resources to meet AMLs needs.
The PIC is required to maintain high-level contact with AML throughout
the project and is responsible for quality control and cost management.

The Project Manager supports the PIC with day-to-day client contact,
ensuring high quality outputs, team briefings, and resource and financial
monitoring..

The Programme Manager is responsible for managing a detailed schedule of


work with milestones and outputs; ensuring delivery of each element of
the project is prepared on time and within budget.

In our approach, specialised subcontractors will carry out parts of the work
under the close management, control, and Quality Assurance oversight of
ERM. A system of controls will need to be in place to assure AML of the
smooth execution of the project and delivery of high quality deliverables.
Management of the following is thus of primary concern and focus:

Management of Work Assignments/Work Orders;


Management of Quality; and
Management of Safety.

7.1 TEAM STRUCTURE

Figure 7.1 presents our proposed overall core team which has been organised
to ensure a blend of local and international expertise with extensive
experience in ESIAs for large mining developments to international standards.
Our core social team is presented in Figure 7.2. The remainder of this section
provides a brief description of these team members. Full CVs are provided in
Annex B. CVs for other team members included in the budget, but not in the
core teams will be available upon request.

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Figure 7.1 Project Team Organogram

Partner in
Charge
Mike
Everett

Project Programme
Manager Manager
Dieter Jonathan
Rodewald Van Gool

Social Biological Biophysical


Tunde
Morakinyo

Transportation Aquatic Terrestrial Groundwater Surface water Soils Air Quality Greenhouse Noise
Jessica Andrew gases
Ben Ward Chris Rod
Caldwell Kevin
Sussman Hazel- Simon
Stefan Leahy/ Linnett/
Harry Zahakos/ Marshall/ Clarke/
Muller Dale Justin
Shwet Prakash Ioanna Lisa
Dalan Hutton Kmelisch
Gegisan Constable
Development Field Survey
Consultants/ Natural
Sullay Kamara Scientific
Services
(NSS)

Dalan
Development
Consultants
Figure 7.2 Social Team Organogram

Social Partner in Charge


Tunde Morakinyo

Social Lead
Tracey Draper

Social Project & Field Manager


Natasha Ezekiel

Consultation & Data Collection Other Social Specialists

Team 1 - Mine Statistician / Data Fisheries Resettlement


Team 2 - Port & Rail Health Human Rights Cultural Heritage
Manager Francesca Zino Advisor
Emma Raven Nomsa Fulbrook-Bhembe Callie Phillips Jo Render Joe Alie
Eva Rossi Kim Beazley

Local Data Collection Teams


Local Fisheries
Expert
Consultation Meetings & Consultation Meetings &
Focus Group Discussions Focus Group Discussions Gabriel Lombie
4 people 4 people

Settlement Level Surveys Settlement Level Surveys


& Key Informant & Key Informant
Interviews Interviews
1 person 1 person

Household Survey Household Survey


Enumerators x 4 people Enumerators x 4 people
Data Entry x 2 people Data Entry x 2 people
7.1.1 Project Management Team

Project Director and Partner-in-Charge - Mike Everett


Mike Everett is a Partner in ERM Southern Africas Impact Assessment and
Planning team. Mr Everett is based in ERMs Durban office in South Africa.
Mike holds an MSc degree in Hydrology and has over 21 years of experience
in a range of environmental projects. As an environmental scientist, Mike
Everett has been involved in project directing several large integrated and
multidisciplinary environmental management projects, including
Environmental Impact Assessments (EIAs), many of which were undertaken
to IFC standards, and environmental screening studies. Some of the projects
that Mike has project managed include: ESIA for the Ncondezi Coal Project in
Tete Province, Mozambique, ESHIA for the Mmamabula Energy Project in
Botswana, including EIAs for ancillary projects to this development including
well fields, road access and power line corridors; ESIA for the Baynes
Hydropower project in Namibia and Angola; ESIA for the Etango uranium
mine in Namibia and an EIA for the Malawi railway line as part of the overall
Moatize coal project in Mozambique. These projects were undertaken in
accordance with the Equator Principles and IFC Performance Standards.

Mike is a registered Environmental Assessment and Management Practitioner


in South Africa and has undertaken environmental assessment and
management work in the following African countries: South Africa, Namibia,
Angola, Botswana, Mozambique, Zambia, Tanzania, Malawi, Sierra Leone and
Ethiopia.

Project Manager - Dieter Rodewald


Dieter Rodewald is an environmental consultant within ERMs Impact
Assessment and Planning (IAP) team based in Durban, South Africa. Dieter
holds a Masters of Agricultural Economics from the University of KwaZulu-
Natal. Dieter has provided environmental consulting support to a wide range
of clients, including private and governmental organisations in the mining,
port, import/export, oil and gas, transport and energy sectors.

Dieters experience includes Project Management of both local and


international Environmental and Social Impact Assessments. His particular
fields of expertise include flora and agricultural/environmental economics, as
well as local socio-economics. Of particular relevance to this Project, Dieter is
currently Project Manager of a large scale Environmental, Social and Health
Impact Assessment for a proposed potash mining project in Ethiopia.

Programme Manager Jonathan van Gool


Jonathan Van Gool is a Senior Project Engineer in ERM Johannesburg, South
Africa. He has 13 years experience in project management, engineering
design and environmental consulting for a wide range of internal and external
clients. He has led large, complex projects and multi-site programs for impact
assessments, site investigations and site remediation works. He has also
directed programs of work for clients on multi-site projects as well as

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managed large scale, multi-contractor projects in sub-Saharan Africa and West
Africa.

7.1.2 Social Team

Social Team Director - Tunde Morakinyo


Tunde is a Partner within ERM based in London. He has over twelve years of
experience in designing, managing and evaluating social performance
activities for the private sector. Much of this has included stakeholder
engagement, social impact assessments, social management plans and social
investment programmes. He has also worked extensively on community
development programmes for NGOs and the public sector. Much of his
experience is with programmes in Africa (including Ghana and Cameroon),
the Middle East, SE Asia, Latin America and the former Soviet Union.

Tunde has extensive experience of working with NGOs, community groups


and Community Liaison Officers during the development of ESIA studies and
in the development of social investment programmes for example. He brings
an understanding of community dynamics and of the ways that NGOs work
to building the capacity of companies to relate more proactively with their
stakeholders. Recent experience with mining specifically includes working on
social surveys and resettlement for gold mines in Ghana and Mali and an iron
ore mine in Sierra Leone. He recently worked with the World Bank on a study
to analyse the conditions for successful Community Development Agreements
(CDAs) being negotiated between mining companies and communities. He
was also a key author for the IFC handbook on Strategic Community
Investment that was published in 2010.

Social Lead Tracey Draper


Tracey is a Senior Consultant within ERM based in London. She has a multi-
disciplinary background with over 10 years of experience working in Africa
and advising the private sector on social performance. Her experience
includes social impact assessment, developing corporate/community
engagement programmes, institution development and governance.

Tracey has benchmarked leading oil and gas and mining companies on
biodiversity and ecosystem services performance; worked in the forestry
sector in Botswana for the Ministry of Agriculture on Community Based
Natural Resource Management Projects; and worked in forest conservation
and livelihoods support in Nigeria. Recently she has also worked on SIAs for
mining projects in Greenland, Sierra Leone and Mali.

Social Project & Field Manager Natasha Ezekiel


Natasha has been working for ERM UK for six years and is a Social Consultant
specialising in Social Impact Assessment (SIA), including Gender and
Vulnerability Assessment. In addition, Natasha has experience working on
health and resettlement issues. Natasha is currently the Stakeholder
Engagement Specialist for a mining EIA in Sierra Leone which includes
collection of baseline data and consultation with local communities affected by

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the project. Other ERM experience includes an oil facility expansion project in
Kazakhstan which involved scoping for the SIA and preparing a Resettlement
Policy Framework, an SIA and HIA for an oil and gas project in Egypt,
interviewing employees of a global oil company on their social performance
and preparing resettlement guidelines and tools for a mining company.

Through her projects, she is very familiar with International Standards,


including the IFC Performance Standards and EBRDs E&S Standards.
Natasha is also an experienced Project Manager who has managed a number
of complex projects including EIAs and European Commission Programmes
up to the value of 3 million. Outside of ERM, Natasha undertook research
for her dissertation paper on Gendered Impacts of Displacement caused by
Environmental Change in West Bengal. This explored the impacts that sea
level rise, drought and extreme weather events including flooding and
cyclones, has on the livelihoods of both men and women already living below
the poverty line.

Consultation & Data Collection Coordinator, Mine Lease Area Emma


Raven
Emma Raven has recently joined ERM as a Social Consultant specialising in
Social Impact Assessments, Social Management Plans, Resettlement Action
Plans and Monitoring and Evaluation. Her experience includes conducting
stakeholder engagement and managing baseline studies, the Social Impact
Assessment and the preparation of Social Management Plans required for the
Chiansi Irrigation Project. She was also involved in a social impact assessment
and resettlement study for motorway project connecting Albania to Serbia,
and Montenegro to Macedonia, running through Kosovo in order to open
trade routes and has extensive data collection experience. More recently she
worked for DfID in Zambia to manage a pilot project across 5 countries
involving the preparation of feasibility reports and cost benefit analysis
studies.

Emma has a Masters in Sustainability (Environment & Development) from the


University of Leeds which involved preparing a dissertation on the social and
economic effects of water scarcity in rural villages in South India. This
included assessing how sustainable initiatives such as rainwater harvesting
can alleviate the burden of water stress, as well as the importance of
community participation in development schemes.

Consultation & Data Collection Coordinator, Port and Rail Nomsa


Fulbrook-Bhembe
Nomsa has two years of experience with ERM primarily working on
Environmental and Social Impact Assessments (ESIAs) for projects in the oil
and gas, mining and agriculture sectors. Nomsa has experience in compiling
environmental and social baselines, impact assessments, and environmental
and social management plans (ESMPs).

Nomsa has also been involved in the design and implementation of


stakeholder engagement processes, in addition to designing social

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management systems for projects in the mining sector. The former has
involved developing public consultation documents, stakeholder engagement
plans and stakeholder engagement strategies. Nomsa is currently involved in
both the Social Impact Assessment (SIA) and stakeholder engagement process
for an ESHIA for a mine in in Ethiopia.

Statistician / Data Manager Eva Rossi


Dr. Eva Rossi is a Senior Consultant based in Milan, Italy. She has specialised
in the processes, methods and tools of social impact assessment, resettlement
planning, community investments, as well stakeholder engagement planning
(IFC, EBRD). Dr. Rossi is a Social Scientist, with 10 years of experience
working in the private and public sectors, from Oil & Gas to the academia,
and with an extensive field experience in emerging and developing economies
in social development issues / international development projects/
community investment assessments.

From her experience in Sub-Saharan Africa, the European Union and South
East Asia, three years of which spent in Malaysia, she has extensive experience
of managing both international and national large scale projects and surveys
and is an expert in socio-economic analysis, qualitative and quantitative
methods, participatory approaches, survey design and management, sampling
strategies and data analysis.

Social Fisheries Francesca Zino


Francesca Zino joined ERMs Hong Kong office in January 2009. She has a
wide range of experience in fisheries related projects as well as in marine and
terrestrial ecological surveys, Environmental Impact Assessments (EIAs),
Environmental and Social and Health Impact Assessments (ESHIAs). She is
also a trained marine mammal observer. Francesca was project manager for an
oil and gas sector project investigating offshore fisheries in Ghana, taking into
account IFC funding requirements and conducting a desktop review and
stakeholder consultations. She helped with a similar project in Angola.
Francesca has also worked on a number of Due Diligence Projects, including
Project Surf where the target was a leading fish food business and Francesca
helped compile the fisheries sustainability information. She also worked on
Project Omega, contributing to the assessment of potential environmental
issues including fisheries resources throughout the Pacific region. Francesca
has a background in fisheries policy having worked for such bodies as
Institute for European Environmental Policy (IEEP) and Marine Resources &
Fisheries Group (MRAG). Her work has involved assessing management
programmes including the EU Common Fisheries Policy and the International
Commission for the Conservation of Atlantic Tunas (ICCAT).
Francesca also has a wide experience in environmental impact assessments
including conducting terrestrial and marine ecological surveys and she is a
trained marine mammal observer. She has undertaken many EIAs where her
roles have included coordinating and conducting wildlife and vegetation
surveys in Hong Kong, collating data and preparing the ecology sections for
the EIAs.

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Resettlement Advisor Kim Beazley
Dr Kim Beazley is a social specialist with particular expertise in land
acquisition & resettlement. She has worked on a range of resettlement
projects developing resettlement frameworks & resettlement action plans,
writing resettlement guidance & conducting resettlement due diligence. Kim
is currently conducting IFC, EBRD & EIB due diligence for a pipeline project
that is pending construction across Southern & Eastern Europe. She is also
advising the African Development Bank on their development of an
Integrated Safeguards System & contributing to an ESHIA for a large oil & gas
project in Kazakhstan that is required to meet the IFC Performance Standards.
A key impact of this project will be the economic & physical displacement &
resettlement of local people & communities.

Over the last two years, Kim has also developed a retrospective compensation
action plan for a gas pipeline company in Nigeria, conducted a detailed due
diligence review of a Resettlement Policy Framework for a hydropower
project in Namibia & Angola, and has written a World Bank-compliant
resettlement action plan for a large-scale resettlement, also in Nigeria. She is
currently working on a RAP in Sierra Leone.

Health Callie Phillips


Callie Phillips is a health and social impact assessment and community issues
management consultant within ERMs London branch. She has a broad range
of health and social consulting experience, including coordination of Health
Impact Assessments (HIA), Social Impact Assessments (SIA), design and
facilitation of public consultation processes, social investment planning and
implementation and capacity building. Callie is also an experienced project
manager.

Callie provides clients with specialist advice on profiling susceptible


communities, understanding and assessing the wider determinants of health
and a risk based approach to health and social impact assessment using
quantitative and qualitative techniques. She has also facilitated a number of
stakeholder consultations including stakeholder identification and
development of field tools and methodologies both for impact
assessments. Callie has worked on a number of health and social impact
assessments since joining ERM including for transport, oil and gas and
infrastructure projects in the UK, Europe, Central Asia and Africa. Callie has
a degree in Medical Science and a Masters in Epidemiology. Callie is able to
use epidemiological data to quantitatively estimate health outcomes
associated with predicted environmental exposures.

Human Rights Jo Render


Jo Render is a Senior Consultant based in ERMs Washington DC office. She
brings to her clients a broad knowledge of trends, standards, and tools within
the corporate social responsibility and sustainable development fields, and
specialized knowledge of company-community engagement and traditional
cultures, stakeholder engagement and communications, and social risk
assessments. She has particular specializations in Indigenous Peoples and

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Human Rights, and extensive experience within the extractive sector both as a
corporate manager and consultant. Some of her most recent projects include
leading stakeholder mapping and outreach for the upstream team of an
American supermajor oil and gas producer; and delivering a social and health
impact assessment for new mine development that meets internal, NEPA, and
international standards. She also continues to play key advisory roles to
international teams in designing stakeholder engagement, impact assessment,
and social investment strategies to extractive sector clients. Prior to joining
ERM in 2010, Jo was the corporate lead for social performance and
sustainability reporting at Newmont Mining Corporation and senior manager
for international NGOs focused on community and civil society
empowerment in relationships with the private sector.

Cultural Heritage Joe Alie (Local Consultant)


Joe Alie is a consultant and academic based in Sierra Leone. He has over 15
years of experience of public and private sector work focusing on African
studies and history. More specifically he has worked on a number of impact
assessments including a mining project in Liberia and on the Bumbuna
Hydro-Electric Project in Sierra Leone which involved mapping of cultural
heritage sites and assessment of cultural significance.

Transport Impact Assessment Ben Sussman


Mr. Ben Sussman is a consultant with ERM based in Annapolis, Maryland. He
has more than thirteen years experience in transportation planning, impact
assessment, local and regional comprehensive planning, and urban design. He
has evaluated vehicular and rail transportation options for industrial,
commercial, and residential land uses. He has prepared EIS documentation in
support of FTA New Starts authorizations (focusing on land use/transit
relationships), and also has considerable airport planning experience, with a
particular focus on landside facilities and operations (curbs, parking
facilities, and consolidated rental car facilities).

Mr. Sussman has prepared and managed EIS and EA evaluations of the land
use, transportation, visual/aesthetic, socioeconomic, and environmental
justice impacts of military airspace, natural gas drilling sites and pipelines,
hydroelectric projects, and other proposed facilities. He has also prepared
comprehensive plans and community plans for small and large cities and
unincorporated communities, with particular emphasis on the linkages
between land use, growth, and water resources. He has also developed and
evaluated regional land use scenarios; waterfront plans; and municipal
economic analyses. Mr. Sussman places emphasis on public presentations and
public engagement as a critical part of impact assessment and planning
projects. He is adept at managing public meetings, stakeholder interviews,
and other forms of information gathering.

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7.1.3 Biological Team

Aquatic Ecology Lead - Craig Reid


Mr Reid is a Partner with over fourteen years of experience in environmental
management at ERM. Mr Reid is the Manager of the Marine Sciences Team in
Hong Kong, responsible for a wide range of projects spanning across sectors
including infrastructure, utilities, oil and gas, property and mining. Mr Reid
specializes in the assessment of impacts as a result of dredging and disposal
activities and has worked on projects for the Hong Kong Government as part
of their port management strategies for over ten years. Mr Reid also has
extensive experience in undertaking international Environmental Impact
Assessments. Projects include studies related to gas pipelines, power stations,
LNG terminals, fuel storage facilities, theme parks, highways, railways,
sewage treatment plants, sewerage schemes, dredged mud disposal facilities,
incinerators, offshore wind farms, onshore wind farms, submarine cables,
overhead power lines, jetties and port developments.

Based in Hong Kong, Mr Reid has worked extensively internationally, having


undertaken studies in Africa (Angola, Ghana, Nigeria, Benin, Togo and
Egypt), Middle East (Abu Dhabi, Iran, Bahrain and Saudi Arabia) South East
Asia (Singapore, Thailand, Philippines, Myanmar, Malaysia, Vietnam, Brunei
and Myanmar) East Asia (China, Hong Kong, Japan and Korea) and the
Pacific Rim (Australia, New Zealand, New Caledonia and Fiji).

Terrestrial Ecology Lead - Andrew Cauldwell


Andrew Cauldwell is a Principal Consultant within the Impact Assessment
and Planning (IAP) team based in Johannesburg, South Africa.

Andrew has over 20 years of experience in ecological and project


management. His key experience includes operating as a biodiversity
consultant with Natural Scientific Services, South Africa and as a wildlife
management advisor and project manager within an EU-funded project with
the Tanzanian Wildlife Department to rehabilitate vast protected areas in
Tanzania.

Andrew has been the lead consultant in a number of projects in many parts of
Africa including South Africa, Tanzania, Mozambique, Botswana, Zambia,
Ethiopia, Sierra Leone and Liberia. His experience has involved baseline and
impact assessments for numerous Environmental and Social Impact
Assessment (ESIA) studies for the mining, oil and gas and infrastructure
sectors. His involvement has focussed on biodiversity conservation and
sustainable management of living natural resources. Andrews projects have
covered a diverse range of ecological studies including vegetation,
ornithological, other faunal, wetland and aquatic ecology assessments in a
diversity of habitats ranging from rainforests, savannahs, and grasslands to
extreme desert conditions.

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Ecology Team On-Site Support - Natural Scientific Services (NSS)
The Natural Scientific Services (NSS) team, based in South Africa, have
extensive experience in project management and fieldwork for numerous
ecological and biodiversity studies as well as aquatic and wetland
assessments. The team have also been involved in the management of
Environmental Impact Assessments (EIAs), Environmental Management
Programme Reports (EMPRs), Strategic Management Plans (SMPs) and
Environmental Management Plans (EMPs) for the Conservation, Mining,
Waste, Commercial and Industrial sectors.

7.1.4 Biophysical Team

Groundwater Lead - Stefan Muller


Stefan Muller, a Partner at ERM, is the Integrated Water Management (IWM)
Practice Lead for ERM Southern Africa based in Cape Town. Stefan is a
mining hydrogeologist with more than 25 years of experience. He specialises
in the analysis of fractured rock aquifers to design mine dewatering systems
and groundwater supply fields. Stefan has conducted numerical modelling to
predict groundwater inflow to both open pit and underground mines and
designed dewatering and depressurisation systems.

He has also designed and analysed specialised aquifer tests to allow


hydrogeological characterisation of sites relative to groundwater
contamination and planned hydrogeological data acquisition programmes for
mineral exploration, groundwater exploration and groundwater development
studies. He has worked on numerous projects in Europe, Asia, and America.
Stefan has been a guest lecturer at the University of Witwatersrand in
Johannesburg, South Africa. Stefan will be responsible for the overall
management and all technical aspects of the groundwater specialist studies,
modelling and deliverables.

Surface Water Lead - Harry Zahakos


Harry Zahakos has over 17 years of experience as an environmental engineer
managing studies focused on the fate and transport of sediments and
contaminants in the aquatic environment. He has worked on numerous
projects for both private and public sector clients with site assessments,
remedial investigations, and natural resource protection. His experience
includes various aspects of contaminated site management including
monitoring, data analysis, conceptual site model development, numerical
modelling, and remedial design and forecasting.

Mr. Zahakos has much experience regarding contaminated sediment sites,


including several under Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA/Superfund). The most notable of
these being the largest such site, the Hudson River in New York. Through
analysis of extensive data and creation of numerical models, he provided the
client the tools to assess the long-term and short-term fate of sediment
contaminated with Polychorinated Biphenyls (PCBs) and to develop an
effective remedial strategy. Over his career, Mr. Zahakos has created several

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such tools for various clients to assist with historical and prognostic
evaluations of sediment and contaminant transport.

Surface Water Support - Shwet Prakash


Shwet Prakash has been involved in managing and developing state of the art
chemical fate and transport models for water quality modelling. He manages
modelling projects in support of hydrodynamic studies, sediment transport
and scour issues, TMDL development and regulatory permitting purposes.
With over 9 years of experience in the field of consulting and mathematical
modelling. Shwet helps facilitate enhanced interactions of transport and fate
models with hydrodynamic models for water bodies.

Soils Assessment Lead - Kevin Leahy


Dr Leahy joined ERM in 2003 and is a Chartered Geologist with 18 years of
experience. Kevin has a diverse earth science background including
geochemistry, hydrogeology, sedimentology, structural geology, basin
tectonics and evolution and field work. Formerly he was a consultant in both
mineral (gold, base metals and diamonds) and hydrocarbon exploration
industries, accruing in excess of 50 weeks actual in-field or in-mine experience
in Britain, Iran, Turkey, South Africa, Namibia, Cameroon, Equatorial Guinea,
Sweden, India, Ireland, Russia, Colombia, Cyprus, DRC, Kazakhstan and
Canada; all involved critical geo-scientific observational skills, synthesis and
sampling. Project management experience has been gained on dozens projects
at ERM and with former employers, including several major projects with
values in the range of US$1 to 3 million.

Kevin has experience in a wide range of projects, predominantly site


investigation and remediation and especially geological synthesis for detailed
conceptual site models, often followed by controlled waters risk assessments
and regulator negotiation.

Other project work has included life cycle planning for aluminium smelters,
environmental due diligence for a zinc mine in Ireland, numerous ESHIA
projects including a gold mine in Iran, a major LNG plant in Russia, oilfield
developments in Kazakhstan, Egypt and Libya, regional EIA and resource
assessment for offshore minerals in the Irish and North Seas, as well as
significant contribution to a community, health & safety and environment
guidebook for exploration geologists at a major global mining house. Kevin is
a proficient user of EVS/MVS (3D visualisation and animation software)
which, along with GIS and other geological software are powerful analysis
and presentation tools for geological structure and the disposition of
contaminants or resources within. Kevin will be responsible for the overall
management and execution of the soil specialist study.

Soils Assessment Support - Dale Hutton


Dale Hutton is a Researcher within ERMs Impact Assessment and Planning
(IAP) team based in Durban, South Africa. Dale obtained a BSc (Honours) in
Environmental Science and Botany, with specific focus on Biodiversity
Conservation. He has experience in field work and data capture throughout

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South Africa. He also has experience in managing teams of field researchers
and technicians, as well as organising large teams of impact management and
rehabilitation field workers. Dale worked in a multidisciplinary team during
the planning and construction of large interprovincial projects. During his
time in the field Dale gained experience in report writing and working with
various stakeholders. He has played a useful role in decision making and
planning teams. He has also been involved in important landowner and
stakeholder negotiation. Dale has worked and lived in rural communities in
the Eastern Cape and has a strong knowledge base in impact management,
biodiversity assessment and biodiversity conservation.

Air Quality - Chris Hazell-Marshal


Dr Chris Hazell-Marshall is a Senior Consultant within ERM based in
Swansea; Chris manages the UK and Ireland Air Quality team. Chris has
worked in the air quality field for thirteen years, nine of which have been as
an environmental consultant. Chris has extensive experience in all aspects of
air quality consultancy and is an experienced project and client manager,
having worked on projects in the UK, Europe and globally. Chris has
managed numerous projects for clients within a wide variety of sectors
including industrial, transport, residential, central government, other public
sector and commercial. He has experience in a wide variety of specialist air
quality areas including: dust; odour; waste management; ecology; bio-
aerosols; and health impact assessment. Chris will be responsible for the
overall management and all technical aspects of the air quality study.

Air Quality Support Dr. Ioanna Gegisian


Dr Ioanna Gegisian is a Consultant within ERM based in Bristol. She has
worked in the air quality field for six years, three of which have been as an
environmental consultant. Ioanna has extensive experience in all aspects of air
quality consultancy including writing proposals, liaising with clients,
conducting technical assessments and compiling assessment reports.

She has completed a PhD in 2007 on the subject of air quality and
environmental justice, exploring sustainability issues of the UKs Local Air
Quality Management framework. Ioanna completed a placement during 2010
in the European Commissions Eco-Innovation Unit, working on a funding
stream for environmental technology projects for SMEs. The work included
the appraisal of environmental technology proposals, selected on the basis of
potential environmental benefits and with a clear focus on Life Cycle
Assessment. Ioanna has experience in a number of environmental disciplines
and endeavours to expand her knowledge base through continual
professional development and through collaborative work.

Greenhouse Gases Simon Clarke


Simon Clarke is a Principal Consultant and Practice Lead of the Sustainability
and Climate Change Team within ERM Southern Africas Risk Team. Simon
has over 9 years experience, with a particular focus on climate change and
sustainability. His climate change experience includes the development of
greenhouse gas inventories, assurance of greenhouse gas data, development

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of climate change strategies and Life Cycle Assessments (LCA) for major
corporate clients in South Africa and abroad. Simons broad sustainability
related experience includes sustainability report development and assurance,
where he has had substantial experience with the Global Reporting Initiative
(GRI) reporting guidelines, and the sustainability data assurance standards
ISAE3000 and AA1000, as well as the corporate governance standard King III.

Simon completed a B.Sc. Hons Degree and a Masters in Environment and


Development through the University of Natal, Pietermaritzburg. Simon is also
a trained ISO 14001 environmental auditor under the International Register of
Certificated Auditors (IRCA) EMS Auditor Scheme, is a registered
Professional Natural Scientist and holds an advanced certificate in project
management.

Greenhouse Gases Lisa Constable


Lisa Constable is a Principal Consultant within the Sustainability and Climate
Change Practice in ERM Cape Town, South Africa. She has over ten years
experience in the climate change and flood management fields in the UK and
South Africa.

Lisas focus area is on assisting clients understand climate change impacts,


vulnerability and risk and has worked on a range of projects in the energy,
mining, ICT and public sectors. The focus of these studies has been on the
physical impacts of weather related events as well as the associated regulatory
and market risks linked to emission limits, taxes and competitiveness etc.

These projects included assessment of adaptation initiatives to reduce the


identified risks with the development of Municipal Adaptation Plans for a
South African municipality including collaboration with stakeholders and
implementation of a multiple criteria assessment approach for ranking the
merit and priority of adaptation interventions. Prior to joining ERM in
February 2008, Lisa worked for the UK Department for Environment, Food
and Rural Affairs in a range of policy advice roles including developing and
implementing the EU Emissions Trading Scheme and policy advice and
communications on flood management issues. Lisa managed the development
of the UK Government Emergency Response Plan for flooding building on
lessons learned from the serious flooding in 2000.

Noise and Vibration Assessment Lead - Rod Linnett


Rod is a Principal consultant based in the Swansea Office in South Wales, UK
and has nearly 20 years of experience in acoustics and specialises mainly in
environmental noise assessment. Rod has nearly 10 years of experience in
assessing noise from mining and extractive projects from small quarries to
large open cut mines. Rod is highly proficient at noise modelling using many
different types of modelling software such as ENM, Predictor and Sound Plan
to assess industrial, manufacturing, utilities, oil and gas, transport,
infrastructure and extractive operations. Rod is in regular contact with
instrumentation manufacturers and software developers which enables him to
keep abreast of the latest trends, technology and changes in the acoustics

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practice. Rod will be responsible for the overall management and all technical
aspects of the noise impact assessment.

Noise and Vibration Assessment Support Justin Kmelisch


Justin Kmelisch joined ERM Southern Africa in 2010 as a Consultant in the
Impact Assessment and Planning Services Team. Justin has two years of
experience as an environmental specialist. He has experience in the field of
noise pollution specifically conducting noise baseline studies in a number of
African countries. Justin has also been involved in the implementation and the
role out of Safety, Health, Environmental and Quality (SHEQ) risk registers
for large multi-national organizations. Over the last two years Justin has
gained experience in undertaking Basic Assessments (BA) and Environmental
Impact Assessments (EIA) in South Africa. He also has experience interfacing
between legal compliance requirements and the developing environment
acting as an Environmental Control Officer (ECO). Justin makes use of
Geographical Information Systems (GIS) to verify and capture assets when
required by clients.

7.1.5 GIS

GIS Development and Support - Michael Longhurst


Michael Longhurst is a Consultant within ERMs Geographic Information
Systems Team based in Johannesburg, South Africa. Michael completed his
Honours degree in Geography at the University of Johannesburg (RAU)
where he researched and completed a waste management project making use
of GIS components for the university. This later became his research project
along with land use classification of Johannesburg and its surrounding
suburbs. ERM was his environmental consultancy of choice. Michael has now
been with ERM for three years now and has been involved in spatial data
acquisition, manipulation, standardisation and production of sensitivity maps
for various environmental projects as well as a number of site contamination
assessments and site suitability mapping.

7.1.6 Dalan Development Consultants Team

Director - Fatu Yumkella


Ms. Fatu Yumkella is the Managing Director of Dalan Development
Consultants Limited (Sierra Leone). DDC is a Sierra Leonean owned
Management and Development Consultancy firm established in 2003. Over
the last 8 years they have provided consulting and research services to
Government of Sierra Leone Institutions and Agencies, non-governmental
organizations and multilateral development institutions to support project
and programme planning, programme delivery and evaluation.

Ms. Yumkella has more than twenty years combined national and
International experience in the fields of demography, population studies and
public health. Ms. Yumkella has proven capability and experience in program
management, social science research and data collection, monitoring and
evaluation, program development, human resources for health (HRH),

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training and performance improvement in Kenya, Sierra Leone, South Africa,
Tanzania, and Uganda.

Ms. Yumkella has in-depth understanding in managing surveys and


monitoring and evaluation (M and E) systems for country and regional
programs. From 1995 to 2002 she worked with IntraHealth International as
Regional Evaluation Officer for the East and Southern Africa region, under the
PRIME project and in 2002/3 she provided technical support in M and E, as
the M and E Specialist, to the Sierra Leone National HIV/AIDS Secretariat
(NAS). Ms. Yumkella also has significant demographic research experience
and worked as the Senior Medical Demographer for the Ministry of Health in
Sierra Leone from 1980 1994.

Ms. Yumkella has also worked extensively in the private sector and lending
institutions and has consulted for World Bank, WHO, UNFPA, and
IntraHealth International /The Capacity Project during the past decade.

DDC will provide a field team who will carry out the collection of the baseline
data. They will also assist with stakeholder engagement, and with the
development of the impact assessment analysis and management plans.

Social Team
The social team will be responsible for conducting social surveys for the social
baseline report. They will also assist with stakeholder engagement and will
input into the development of the impact assessment analysis and
management plans in coordination with ERMs social specialists and Ms.
Yumkella. A sample of team names are listed below.

Kadiatu Sesay Samai


Fatmatta Fornah
Thaimu Kamara
Aminata Alhaji
Ali Timbo
Charnoh Gbla

Environmental Team
The environment team will be responsible the environmental baseline data
collection. They will also input into the development of the impact
assessment analysis and management plans in coordination with ERMs
environmental specialists and Ms. Yumkella. The local team will include:

Gabriel Lombi (DDC) - Fisheries


Julius Mattai DDC) - Air Quality
Amadu Barrie (DDC) - Surface Water
Philip Mornya (DDC) - Flora
In-country undergraduates environmental baseline data collection

Full CVs of the local consultants are available on request.

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7.2 PROJECT MANAGEMENT

ERMs reputation as a leading international consulting company is built upon


our ability to meet client requirements, and to do so on time and on budget.
To support these objectives, ERM has developed tailored project management
and quality assurance procedures. These procedures are described below.
The key elements of project management for each assignment that ERM
undertakes are as follows:

Every project is carried out under the oversight of a Partner in Charge. The
Partner in Charge is ultimately accountable for ensuring ERM understands
and applies the appropriate resources to meet the clients needs. The
Partner is required to maintain high-level contact with the client
throughout every project and is responsible for quality control and cost
management;

Every project has a Project Manager who is responsible for management of


the work and for day-to-day client contact, work planning, team briefing,
production of outputs, and resource and financial monitoring. A detailed
plan of work with milestones and outputs, and individual team briefing
notes defining roles, tasks, outputs and deadlines, is prepared for each
project;

Effective project control systems are applied for monitoring and managing
project work plans and programmes, deliverables, resources and costs and
the Partner in Charge will undertake regular progress reviews with the
Project Manager to ensure these are working successfully to meet ERMs
obligations;

All project deliverables are subject to comprehensive systems for review


and approval prior to their submission to the client; and

Full and up-to-date project documentation is maintained and is open for


inspection by client officers by arrangement.

This regime is instituted for each and every project carried out by ERM.

7.2.1 Project Briefings

Once the start-up work plan is complete, the Project Manager will brief the
team (internal and external). While task requirements and timing would have
been discussed in advance with each team member a final briefing will be
given using written team briefing notes or face-to-face.

7.2.2 Work Orders

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ERM will prepare formal Work Orders for each task order issued under the
contract. The Work Order will be developed in accordance with our internal
procedure documented in our Quality Management System (QMS), which
provides the framework for planning and managing each task order. This is
the main tool for establishing clear expectations for each task. Each element of
the Work Breakdown Structure (WBS) will constitute an explicit, planned
piece of work to be accomplished by ERM or by one of its subcontractors.
Each WBS element will have a task manager responsible for the task and who
will be established at the time of issuance of the Work Order. Each Work
Order will be issued under formal subcontract that we will establish with each
subcontractor consultant upon contract award. The Work Orders address
seven points: work scope, staffing, scheduling, budgets, communication, staff
development, and quality assurance.

If desired, we can include AMLs review and concurrence in the Work Order
process. This review process would ensure that we have a mutual
understanding of the work scope, schedule, and budgets and lays the
foundation for monitoring of task order performance.

7.2.3 Internal Project Meetings

To facilitate coordination of the assessments and communication among staff


members, we will establish a programme of planning and coordination
meetings led by the Project Manager using an agenda developed and
circulated in advance. The meetings will be attended in person or by
teleconference by Task Managers and by managers of subcontractors. The
objectives of the meetings are to ensure that the quality of communication
(both internal and external) is enhanced whenever possible. AML will be kept
updated of key outcomes of project meetings.

7.2.4 Monthly Project Status Review

Because of the technical nature of the work and schedule requirements of the
project, we will hold formal monthly status review meetings in which the task
manager and project manager will review technical, scheduling, and
budgetary progress assessments. The monthly status reviews will provide
inputs to the monthly progress reports, described below.

Monthly Progress Report

Reports of progress will be submitted by the individual task managers


through email to the Project Manager. In turn the contract Monthly Progress
Report deliverable to AML is prepared and submitted. The monthly report
will assess the month in review and project activities, costs and schedule for
the upcoming month. If any task order is in technical or financial difficulty,
the specific circumstances will be analysed and discussed with AML . A
corrective action plan will be agreed upon and prepared. The Progress Report
will document the status of each task, but will serve primarily as a record
rather than as a communication tool.

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