This booklet has been prepared for the ongoing Makuutu Rare Earths Project Environmental and Social

Impact Assessment (ESIA) public disclosure and the forthcoming public hearings.
It aims at providing the background information (the nature of the project and location, etc.) of the project
and the outcome of the ESIA especially, the anticipated positive and negative impacts of the project and
the proposed mitigation measures for the negative impacts. This is to enable the public to provide
informed comments on the Makuutu ESIA report.
The public, stakeholders and interested parties are therefore invited to provide feedback on the Project
and the ESIA report.
Copies of the ESIA Report are available at the following locations:
1. NEMA Library, NEMA House, Jinja Road, Kampala;
2. National Library of Uganda, Buganda Road, Kampala;
3. Makerere University, Main Library;
4. Kyambogo University, Main Library;
5. Bugweri District Headquarters;
6. Mayuge District Headquarters;
7. Bugiri District Headquarters;
8. Ministry of Energy and Mineral Development (MEMD), Amber House, Kampala;
9. Directorate of Geological Survey and Mines, Plot 21-29 Johnstone Road P.O. Box 9 Entebbe,
Uganda
10. Ministry of Water and Environment, Plot 21/28 Port Bell Road, Luzira Kampala.
An electronic version of the Makuutu Rare Earths Project ESIA Report can also be accessed on the
NEMA website (www.nema.go.ug).
The public is encouraged to submit comments and views on the Makuutu Rare Earths Project ESIA to
the undersigned by 29th July 2022.
Executive Director
National Environment Management Authority
NEMA House, Plot 17, 19, 21, Jinja Road
P.O. Box 22255, KAMPALA
Tel: 256 (0) 41 4 251064/5/8
Fax: 256 (0) 41 4 25752
Email: info@nemaug.org
Website: http://www.nema.go.ug
TABLE OF CONTENTS
ACRONYMS AND ABBREVIATIONS.......................................................................................................
1. INTRODUCTION..................................................................................................................................
1.1 Mining Industry in Uganda............................................................................................................
1.2 The Makuutu Rare Earths Project.................................................................................................
1.2.1 Understanding the Project.....................................................................................................
1.2.2 Understanding Rare Earth Elements (REE)..........................................................................
1.3 Project Objective...........................................................................................................................
1.4 Project Justification.......................................................................................................................
1.5 The ESIA Process.........................................................................................................................
1.5.1 ESIA Justification...................................................................................................................
1.5.2 ESIA Approach......................................................................................................................
2. PROJECT DESCRIPTION...................................................................................................................
2.1 Project Location............................................................................................................................
2.2 Mining Process..............................................................................................................................
2.2.1 Mining Operations.................................................................................................................
2.2.2 Mining Equipment..................................................................................................................
2.2.3 Mine Rehabilitation................................................................................................................
2.2.4 Project Infrastructure.............................................................................................................
2.3 Processing Plant...........................................................................................................................
2.3.1 Location of the Processing Plant...........................................................................................
2.3.2 Process Plant Operations......................................................................................................
2.3.3 Site Buildings.......................................................................................................................
2.4 Utilities.........................................................................................................................................
2.4.1 Water...................................................................................................................................
2.4.2 Power..................................................................................................................................
2.4.3 Fuel Services.......................................................................................................................
2.5 Support Infrastructure.................................................................................................................
2.5.1 Site Access Roads..............................................................................................................
2.6 Workforce....................................................................................................................................
2.7 Compensation and Resettlement................................................................................................
3. EVALUATION OF PROJECT ALTERNATIVES...............................................................................
3.1 No Project Alternative.................................................................................................................
3.2 Alternative Minerals.....................................................................................................................
3.3 Alternative Processing Plant Location Option Study..................................................................
3.4 Processing Technology Alternatives...........................................................................................
3.5 Mining Technique Alternatives....................................................................................................

i
4. PUBLIC PARTICIPATION.................................................................................................................
4.1 Stakeholder Engagement Activities............................................................................................
4.2 Grievance Mechanism................................................................................................................
5. IMPACT ASSESSMENT....................................................................................................................
5.1 Potential Project Benefits............................................................................................................
5.2 Potential Impacts and Mitigation Measures................................................................................
6. CUMULATIVE IMPACT ASSESSMENT...........................................................................................
7. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN..............................................................
8. ENVIRONMENTAL MONITORING...................................................................................................
COMMENT AND FEEDBACK FORM........................................................................................................

ii
ACRONYMS AND ABBREVIATIONS
CDP Community Development Plan
CIA Cumulative Impact Assessment
DWRM Directorate of Water Resources Management
ESIA Environmental and Social Impact Assessment
ESMP Environmental and Social Management Plan
ESMS Environmental and Social Management System
FAO Food and Agriculture Organisation
FIFO Fly in Fly out
HREE Heavy Rare Earth Elements
MTPA Million Tonnes per Annum
NDP III Third National Development Plan
NGO Non-Governmental Organisation
PAP Project Affected Person
PPE Personal Protective Equipment
REE Rare Earth Element
RRM Rwenzori Rare Metals
VEC Valued Environmental Component

iii
1. INTRODUCTION
1.1 Mining Industry in Uganda
Uganda is endowed with a wide range of mineral deposits, including both high value minerals (such as
gold, limestone, uranium, marble, graphite, gypsum, iron ore, wolfram, nickel, copper, cobalt, tin, rare
earth elements) and low value minerals like industrial minerals, construction materials, dimension stones
and semi-precious stones (Figure 1.1).
The mining industry in the country is progressively growing. However, the vast potential of mineral
deposits remains untapped. Therefore, to unlock the country’s mineral potential, Uganda’s vision 2040
and the National Development Plan III aim at building a strong mining industry that will contribute to the
country’s economic and social development.

Figure 1.1: Mineral Occurrence Map of Uganda

1.2 The Makuutu Rare Earths Project
1.2.1 Understanding the Project
The proposed Makuutu Rare Earth Elements (REE) Project is one of the mining projects aligned to the
priorities of the NDP III aiming at accelerating mineral development and industrialisation in Uganda for
social and economic development. The project development has been proposed by Rwenzori Rare
Metals Limited, an affiliate of the Australian-based based Ionic Rare Earths who are the major
shareholder.
The project aims at mining Rare Earths Elements (REE) from ionic adsorption clay deposits spanning
Bugweri, Mayuge and Bugiri districts. The grades of the project’s REE are comparable to the grades in
the southern China REE ionic clay mines that produce much of the world’s Heavy Rare Earth Elements
(HREE). According to the review of REE by US Geological Survey which was completed in 2017 and

Makuutu Rare Earths Project ESIA – Technical Extract 1

their map of major mines and advanced projects, no operating ion-absorption REE clay mine and
advanced ion-absorption REE clay projects were identified outside of China. This, therefore, makes
Makuutu one of the very few known major REE ionic adsorption clay deposits that will be outside of
southern China and potentially the first one to be developed.
1.2.2 Understanding Rare Earth Elements (REE)
There are 16 naturally occurring rare earth elements in addition to Promethium which does not occur
naturally. These elements are of great importance in a wide range of applications. They have broadly
similar properties, and it is the unique properties of each that accounts for 75% of their uses in:
 Modern technology: Almost every modern device contains some rare earth elements with electric
motors and permanent magnets containing particularly high amounts.
 Catalytic convertors, phosphors in optical displays, mirror and glass polishing, diesel and petrol
fuel refining processes, media and communications devices including mobile phones, televisions
and computers all contain REE.
 The creation of neo-magnets necessary for the production of wind turbines and the world
transition from fossil fuels to renewable energy especially the Heavy Rare Earth Elements
(HREE).
1.3 Project Objective
The overall objective of the Makuutu Rare Earths Project is to mine REE and establish a processing
plant that will produce a rare earth element carbonate (REEC) for export, in addition to establishment of
other support infrastructure in the project area.
1.4 Project Justification
Global demand for Rare Earth Elements (REE) is increasing based on a shift in macro events relating to
the deployment of renewable energy, electric vehicles and communications. The existing REE supply
chain is dominated by China, with world governments now becoming increasingly concerned with future
supply and access to their own REE supply security. The growing economy of China is creating a
worldwide risk to supply, as China’s increased consumption has led to limited exports of rare earth
elements.
This makes Makuutu a project of significance to both national and global economic development.
Specifically, the Makuutu Project will greatly contribute to the social and economic development of
Uganda in the following ways:
 The US$7.6 billion revenues that the Makuutu Project will generate over its life will add
significantly to Uganda’s income from the mining sector with estimated gross royalty payments of
US$380M plus corporate tax contributions of US$965M over the life of the project.
 With an expected revenue of US$7.6 billion, the project will be a significant step in unlocking the
resource potential of Uganda.
 The Makuutu project is expected to address the challenge of rudimentary mining methods and
informality in the mining sector by adopting best practices.
 Makuutu’s contribution to positive community development outcomes through its progressive
rehabilitation strategies are expected to convert currently degraded farmland used for shifting
agriculture into a mosaic of productive agricultural land, forest plantations and fish farms.
 The project will contribute significantly to the local revenue. Under the Ugandan Tax Law, 17% of
Project royalty payments are required to return to the project area through the mandated local
government and 3% share of Project royalties to the land owner. This amounts to US$76 million
over the life of the Project which would be dedicated to the areas adjacent to the Project.
 The Project will also make significant direct contribution to community development programmes
through its Community Development Plan and other programmes that will deliver economic and
social benefit to local communities and Uganda at large.

Makuutu Rare Earths Project ESIA – Technical Extract 2

  Additionally, the project will also provide employment opportunities to the people of Uganda, and
contribute to poverty eradication and prosperity.
1.5 The ESIA Process
1.5.1 ESIA Justification
The National Environment Act, 2019 defines an ESIA as an analytical process that systematically
examines the likely environmental and social impacts of a proposed project, evaluates alternatives and
designs appropriate mitigation, management and monitoring measures, taking into account interrelated
socio-economic, cultural and human health impacts, both beneficial and adverse.
An ESIA is a requirement in the National Environment Act, 2019 for any development project deemed to
have significant environmental and social impacts. Schedule 5 of the same Act lists the mining industry
and mineral processing projects for which ESIAs are mandatory; the Makuutu Project falls under this
category.
Furthermore, Regulation 53(1) of the Mining Regulations, 2019, requires a holder of a prospecting
license, exploration license, location license, retention license or mining lease, as applicable, to prepare
and submit a project brief or an environmental and social impact assessment before commencement of
work, in accordance with the National Environment Act, 2019 and the National Environment
(Environmental and Social Assessment) Regulations, 2020.
1.5.2 ESIA Approach
The ESIA study was conducted in accordance with the National Environment (Environmental and Social
Assessment) Regulations, 2020 as illustrated in Figure 1.2 in addition to international standards such as
the Equator Principles that the project developer subscribes to.
As an initial stage to the ESIA process, the Scoping Study and Terms of Reference (ToR) for the
Makuutu Project Environmental and Social Impact Assessment (ESIA) were prepared and submitted to
the National Environment Management Authority (NEMA) for review and consideration.
Consequently, the ToR were approved by the Authority in February 2021 which then informed the
Environmental and Social Impact Assessment. The ESIA was completed and the report was submitted
to the Authority in November 2021 for review and consideration. The ESIA report is currently under
review and the decision on the same is yet to be made.

Makuutu Rare Earths Project ESIA – Technical Extract 3

Figure 1.2: Schematic of the ESIA Process in Uganda
Source: Guidelines for Environmental Impact Assessment in Uganda (July, 1997)

Makuutu Rare Earths Project ESIA – Technical Extract 4

2. PROJECT DESCRIPTION
2.1 Project Location
The proposed Makuutu REE project covers three (3) districts of Bugweri, Bugiri and Mayuge in Eastern
Uganda. The project area comprises four (4) licenses covering approximately 182.94 km 2 in the
mentioned districts (Figure 2.1) with an additional fifth exploration lease (EL00147) which was added to
Bugiri District in 2021. These are as follows:

1. The Makuutu Eastern Zone – Buwunga under Exploration License No. EL1766 covers an area of
47.025 km² in Buwunga (Bugiri District), Nankoma (Bugiri District) and Ibulanku (Bugweri District)
Sub-counties. It further covers approximately nine (9) parishes and 34 villages.
2. The Makuutu Central Zone – Makuutu continues towards the west under a Retention Licence No.
RL1693 with an area of 44.2624 km² in Buwaaya (Mayuge District), Makuutu (Bugweri District)
and Buwunga (Bugiri District) Sub-counties. This spreads over about six (6) parishes and 42
villages.
3. Makuutu Western Zone – Buwaya under a Retention Licence No. RL00007 covers an area of
43.3875 km² of Imanyiro and Buwaaya Sub-counties. It spreads over six (6) parishes and 24
villages in Mayuge District.
4. Makuutu Northern Zone – Buwunga (Processing Plant Area & its Environs) under Exploration
License No. EL00148 that covers an area of 48.15046 km² in Buwunga (Bugiri District), Igombe,
Ibulanku and Makuutu (Bugweri District) Sub-counties. It covers about nine (9) parishes and 49
villages.

Figure 2.3: Makuutu Rare Earths Project Locality Map

Makuutu Rare Earths Project ESIA – Technical Extract 5

To note is that the major components of the project including the Process Plant and centralised facilities
will be located in the northern Makuutu Zone outside of the footprint of the ore-body.
2.2 Mining Process
2.2.1 Mining Operations
Active mining and processing will be confined to Bugweri District for the first 15 years of mining with the
first phase commencing in the Makuutu Central Zone which will sustain the first 10 years of mining and
then proceed to Central Zone East. The mine will operate 24 hours a day and 365 days per year over the
life of the mine.
Mining will involve a pre-strip of 1m of topsoil which will be stockpiled adjacent to the pit using a truck
and shovel operational method. (Figure 2.2). The REE are hosted in ionic-adsorption clay within an
average 20m layer of regolith overlying the basement rocks (Figure 2.3).
The ore will be hauled to the Run-of-Mine (ROM) pad and either stockpiled or direct dumped onto the
heap leach pads. Once areas are completely mined out, the mined waste and heap leach residue will be
reclaimed (Section 2.2.3) and the pit will be backfilled prior to top soiling.

Truck and Shovel Mining

Large scale open pit mining similar to what is expected for the Makuutu Project

Makuutu Rare Earths Project ESIA – Technical Extract 6

 Clay-ore will be trucked to a Process Plant
Figure 2.4: Overview of Mining Operations

Figure 2.5: Laterite Regolith Summary

2.2.2 Mining Equipment
The nominated mining fleet (Table 2.1) is based on conservative assumptions of 80% utilisation, 80%
efficiency and 90% availability. In the first Year of mining, the fleet will be about 57 large machines which
will increase to approximately 142 machines in the fourteenth (14) Year of mining operations. Mining will
be done using the truck and shovel method.

Makuutu Rare Earths Project ESIA – Technical Extract 7

Table 2.1: Proposed Mining Fleet for Year 1

2.2.3 Mine Rehabilitation

Upon completion of the mining activities, the mine will be progressively rehabilitated to high quality
agricultural land by:
 Completely filling the mining void with a combination of overburden rich in kaolinite 1 clay and
“spent ore” (from which the REE has been extracted) from the leach pads.
 With appropriate compaction, this will create a stable and largely impermeable landform that will
be contoured to avoid ponding and to strategically direct stormwater to appropriate exit points.
 The contoured landform will then be capped with a metre of stored topsoil.
 The topsoil will be limed with dolomite 2 to increase pH and buffering before being fully fertilised
with triple superphosphate and potassium nitrate as recommended by the Food and Agricultural
Organisation (FAO).
 The cycle of mining through to progressive rehabilitation is expected to take about six (6) months
and create a moving mining void of about 20 hectares.
At the end of the 27-year project life, all the 10 pits encompassing a total mining footprint of about 950
hectares will have been mined and returned to agricultural use or other beneficial uses such as
agroforestry or fish-farms. It is not planned to have any mining voids, tailings dams or waste dumps.
2.2.4 Project Infrastructure
The initial capital provides for a processing plant, mining workshop, mining offices, crib rooms and
ablution blocks and other associated facilities. A mine dewatering plant has also been factored into the
estimate to enable storm water harvested into the open pit to be pumped back to the process plant
where it will be treated to meet water quality discharge limits set by the Directorate of Water Resources
Management (DWRM) prior to any offsite disposal into natural watercourses.
2.3 Processing Plant
2.3.1 Location of the Processing Plant
The proposed base-case processing plant will cover about 200 hectares with much of this area
encompassed by heap-leach pads. While the project mineral deposits are fixed in position, the location
of the processing plant can be selected for minimal impact. The Developer identified five (5) potential
locations for establishment of the 200-ha processing plant. Of the five options, Option 2 was deemed
suitable for the plant location. This is located in Makuutu Sub-county, Kikandwa Parish, near the border
of Igombe Sub-county, along River Kitumbezi. The proposed site area is 2.9 km² covering five (5)
villages under Nakavule, Makandwa and Mawololo in Bugweri District.

1
This is a clay mineral.
2
This is a type of limestone.

Makuutu Rare Earths Project ESIA – Technical Extract 8

2.3.2 Process Plant Operations
The process plant has been designed to produce a rare earth element carbonate (REEC) product, which
will be dispatched to customers in plastic lined FIBC bulk bags. The ore will be transported to this Plant
by trucks from progressively mined orebodies within the Project area. The process plant is planned to be
operated 24 hours per day, 365 days per year.
The process sequence to remove the REE from the clay will follow the heap leaching process as follows:
 Agglomerating the clay (i.e., turning it into small beads to increase its permeability).
 Placing the agglomerated clay into 3m high heaps on top of an impermeable HDPE liner.
 Percolating ammonium sulphate (i.e., a common agricultural fertiliser that is widely used in
Uganda) through the heaped clay. The REE desorbs from the clay and dissolves into the
ammonium sulphate liquor (Figure 2.4). This liquor then drains into adjacent HDPE-lined Process
Water Ponds.
 Concentrating the REE/Ammonium Sulphate solution using nano-filtration processes.
 Precipitating the REE as a REE carbonate through the addition of ammonium bicarbonate. This
step regenerates ammonium sulphate which will then be recycled back to the heap leach
process.
 Filtering, drying and bagging the REE carbonate for export in shipping containers.
At peak production, the project will produce about 4,000 tonnes of REE carbonate a year which is a very
small proportion of the 12.5 million tonnes per annum (mtpa) clay ore that it has been extracted from the
ore.

Figure 2.6: Heaped-ore on impermeable liners being irrigated with lixiviant 3 which drains into
adjacent lined ponds

The process flowsheet (Figure 2.5) presents the material movement from mine to market and the Figure
2.6 shows the conceptual layout of the process plant and supporting facilities.

3
A lixiviant is a liquid medium used in hydrometallurgy to selectively extract the desired metal from the ore or mineral.

Makuutu Rare Earths Project ESIA – Technical Extract 9

 Figure 2.7: Conceptual Process Flowsheet

Makuutu Rare Earths Project ESIA – Technical Extract 10

 Figure 2.8: Conceptual Layout of the Process Plant and Ancillary Facilities

Makuutu Rare Earths Project ESIA – Technical Extract 11

2.3.3 Site Buildings
The anticipated site buildings have been summarized in Table 2.2 below.
Table 2.2: Anticipated Site Buildings

Other offsite infrastructure will include a freight consolidation yard which will be required to support the
rail freight operation and a Jinja office for in country logistics and project support activities.
2.4 Utilities
2.4.1 Water
A preliminary water balance indicates that the Project will be completely self-sufficient with respect to
water supply and will be discharging about 380,000 kL a year of high-quality treated water to the river
system or for beneficial uses including irrigation of crops. Table 2.3 shows the key Makuutu Project water
usage requirements.
Table 2.3: Key Water Usage Requirements
Water Type Utilisation
Process Water A process water pond will be installed on site to collect discharge from neutral
plant operations, plant permeate and mine-dewatering. This pond provides
ongoing rinse water to the heap leach process. The maximum storage of the
process water pond is 30 days’ operation. Process water will be supplied to the
process water ring main with electric pumps. Filtered process water will be
utilised for gland water services.
Gland Water Gland water will be used for a limited number of pumps within the process plant.
The majority of pumps will be specified with mechanical seals or as hose pumps
to avoid having to use water for sealing duties. A gland water tank and pumps
will supply duty points within the process plant.
Raw Water The plant will obtain process water from storm water harvesting and Plant
permeate. A raw water storage tank will be installed on site, which will also
provide for fire water storage. Nominal capacity of the raw water tank is 130m 3.
The raw water tank will overflow to the process water pond.
Fire Water A firewater storage and reticulation system will be provided for firefighting
duties. All substations will be equipped with dedicated fire suppression
equipment to protect the motor control panels and plant control systems.
Potable Water Raw water will be processed through a reverse osmosis plant to provide potable
water for the operation. Potable water will be chlorinated and stored on site in a
potable water tank. Potable water will be distributed via a ring main with electric
pumps supplying potable water to the safety shower ring main and the offices
block, crib room / ablutions and workshop.

Makuutu Rare Earths Project ESIA – Technical Extract 12

2.4.2 Power
132kV, 33kV and 11kV voltage power is readily available in the project area from the national grid.
Based on the mechanical equipment list and assumed energy factors, the operating power requirement
for the Project is 1,864 kW.
2.4.3 Fuel Services
Fuel will be stored on site in fuel storage facilities for distribution to vehicles and for use in the flash dryer
for product drying. As diesel will be supplied in bulk, it will be pumped to a 35m 3 tank located adjacent to
a designated re-fueling area such that heavy vehicles can refuel on their rotations. Machines based at
the mine pits will be refueled by an intermediary fuel truck. At the refueling area there will also be a
separated light vehicle refueling bowser.
2.5 Support Infrastructure
2.5.1 Site Access Roads
The project is approximately 10 km from Highway 109 (Kampala-Jinja Highway) which is a sealed
bitumen road connecting to Kampala and to Kenya (Port of Mombasa) which is the main access road for
goods into Uganda.
All weather access roads connecting the site to the adjacent sealed bitumen highway are already
existing. It is estimated that only moderate internal roads such as haul roads will be required. The
existing paved roads surrounding the project will be used for access to site and deliveries, and an
additional haul road will be used for transportation to the processing plant.
2.6 Workforce
The Makuutu Project intends to source local operations staff from the immediate districts and are to be
trained accordingly. The initial workforce for the first phase of the mining project will require about 546
people and employ about 1,200 full time Ugandan workers in the years of peak operation from year 10 to
Year 25 with likely equivalent numbers of contract workers.
These will be largely residents within the project area and people from the nearby areas within the
project footprint. The project has also assumed that the other experts especially during the construction
phase and project operation will reside in the hotels and guesthouses in the areas of the project. Hence,
the project will not have accommodation on site nor a camp. No fly in – fly out (FIFO) is envisaged and
the number of expatriate staff is intended to be low and to be phased out over the first three (3) years of
operations.
2.7 Compensation and Resettlement
While the resettlement of Project Affected Persons within the Project footprint is the greatest social
challenge for the Project, the Project is committed to ensuring that Project Affected Persons are not
disadvantaged socially or economically. The strategy to achieve this will be through a Compensation and
Resettlement Action Plan that is currently being developed. This Plan has been developed to avoid
marginalisation of the directly impacted communities during the development of the Makuutu Project
from the acquisition of Project land.
This strategy focuses on voluntary resettlement based on fair compensation for loss of assets,
resettlement into a good replacement house with good social services and sustaining livelihoods through
provision of replacement farming land or employment on livelihood projects.
Resettlement will be staged (i.e., people will be progressively resettled in advance of the expanding
mining pit which will be progressively backfilled and rehabilitated) over the 27-year life of the project
allowing proper planning to ensure that the social connections, livelihoods and food security of Project
Affected Persons are sustained. This will also allow resettlement to occur in the rehabilitated mining
areas.

Makuutu Rare Earths Project ESIA – Technical Extract 13

3. EVALUATION OF PROJECT ALTERNATIVES
3.1 No Project Alternative
The ESIA assessed that the Project will deliver significant social, environmental and economic benefits
to local communities, to Uganda and to the world through the supply of critical REE metals necessary for
the world transition from fossil fuel to renewable energy.
The Project is highly consistent with the Uganda Vision 2040 and NDPIII and failure to proceed could
therefore be viewed as a lost opportunity.
3.2 Alternative Minerals
There are other potential minerals that could be mined in the three (3) districts of the Makuutu Project
area and in other areas of Uganda but they haven’t been sufficiently explored to confirm that they are
commercially viable.
The Developer is, however, seeking to maximise the value of the Makuutu ore-body. Recent
metallurgical test work has indicated that an additional rare earth called Scandium that is present in the
Makuutu ore-body could also be exploited and potentially add US$1.2 billion to the value to the Project
with no additional environmental or social impact.
3.3 Alternative Processing Plant Location Option Study
Five (5) potential locations for establishment of the 200 ha processing plant were identified. These sites
were evaluated based on environmental and socio-economic criteria; Option 5 was initially (during the
ESIA study) selected as the one with the lowest social impact (Table 3.1). However, post-ESIA
submission, further test work conducted in 2022 concluded that Option 5 was fatally flawed on
geotechnical grounds due to its location on swampy land.
Option 2, directly to the north of Makandwa Central, has therefore been selected as the preferred option.
This location, despite having a larger population has a number of significant advantages over the
originally preferred Option 5.It is 4km closer to the immediate mining area which removes the need for a
4 km long-haul road and the consequent public safety (i.e., public road crossings), social (i.e.,
displacement of people and loss of farm-land within the haul-road footprint) and environmental (i.e.,
consumption of many millions of litres of additional fuel and need for much larger mining fleet to haul the
ore and spent-ore an additional 8 km compared to Option 2). Below are the five alternative locations for
the processing plant that were identified.
Table 3.4: Processing Plant Siting Options
Processing Plant
Location and Size
Site Option
Option 1 Located in Makuutu Sub-county, Kigulamo Parish, 1 km east of Makuutu Trading
Centre. The proposed site area is 2.08 km² covering five (5) villages under Naitandu
“A” & “B”.
The site was not considered because it is densely populated with some significant
socio-economic infrastructure including Naitandu Primary School, churches, a water
supply scheme, a mosque, coffee/banana gardens, value addition/ agro-processing
facilities, etc.
Option 2 Located in Makuutu Sub-county, Kikandwa Parish, near the border of Igombe Sub-
county, along River Kitumbezi. The proposed site area is 2.9 km² covering five (5)
villages under Nakavule, Makandwa and Mawololo in Bugweri District.
This was initially the second preferred option but it has become the preferred option
following a conclusion that previously preferred Option 5 was fatally flawed due to the
swampiness of the area. The Processing Plant footprint within the Option 2 area was
additionally rationalised to a smaller footprint on the western portion of this area
directly to the north of Makandwa Central but not directly impacting existing villages.
Option 3 Located in Igombe Sub-county, Kikunyu Parish, near the border of Makuutu Sub-

Makuutu Rare Earths Project ESIA – Technical Extract 14

 county (Bugweri District) along River Kitumbezi. The proposed site area is 3.39 km²
covering six (6) villages under Bubinga, Businda and Kikunyu.
The mainland use/cover of the site includes subsistence croplands, permanent
settlements and scattered trees. The main crops grown are banana, sugarcane
plantation, beans and maize.
The settlement pattern is concentrated along the feeder roads and scattered inside the
villages. The nearby small wetlands and swamps along these various rivers draining
Option 3 have been degraded and heavily cultivated with sugarcane, maize and rice
gardens. The site was also not considered due to its more significant environmental
and social considerations.
Option 4 Located in Igombe Sub-county (Bugweri District), Igombe Parish, near Option 3. The
proposed site area is 2.97 km² covering three (3) villages under Igombe Sub-county.
Owing to its environmental and social setting below, this option was not considered:
 The nearby small wetlands and swamps along various rivers and streams
draining Option 4 have been degraded and heavily cultivated with food crops
like rice, among others.
 It is also densely populated (for a rural setting) with some economic
infrastructure that including Igombe Sub-county offices, Igombe HC III,
graves, boreholes, schools, places of worship, etc.
Option 5 Located in Ibulanku Sub-county (Bugweri District), Buniantole and Namiganda
Parishes, near Nakivumbi Trading Centre. The proposed site area is 3.88 km²
covering five (5) villages under Kabugweri and Namiganda.
This was the preferred option owing to less significant environmental and social
baseline. However, geotechnical assessment undertaken in early 2022 concluded that
the land in Option 5 is too swampy to support a Processing Plant and this Option has
been rejected.

3.4 Processing Technology Alternatives

The processing technology alternatives considered for the Makuutu Project are shown in Table 3.2
below. The most preferred for the Makuutu project was the heap leach option which was found to be the
most suitable.
Table 3.5: Processing Technologies Considered
Technology Remarks
In Situ or Solution Currently not a viable option because:
Mining Option  The lixiviant does not readily pass through the clay ore making it very
inefficient at extracting the REE.
 There remains potential for acidic lixiviant to pipe through aquifers in or
near the orebody and leave the site. This could in turn contaminate off-
site areas with ammonium sulphate.
Tank Leach Option There is not yet sufficient fundamental test-work that can be used as a basis for
design. Study of this scenario is deferred until test-work exists that confirms or
repudiates the benefit.
Vat Leach Option This system works best for heavy particles that settle readily and this is ranked
as less likely to succeed as a whole ore treatment method for the lateritic ionic
clay ore type, the case of the Makuutu Project.
Heap-Leach Option Reliable and safe because it is:
 Proven in the mining industry;
 Applicable to whole ore treatment; and
 Has had sufficient test-work completed on it.

Makuutu Rare Earths Project ESIA – Technical Extract 15

3.5 Mining Technique Alternatives
 Mining can be done with scraper trucks which are more efficient than truck and shovel operations
on hauls of less than 1km.
The currently preferred method is by truck and shovel due to its greater flexibility in the whole
mining process and the 4 km distance of the process plant from the initially selected mining pit.
 The ore will be mined with truck and shovel and hauled by truck to the Process Plant. This
method of transport is less efficient than a slurry transport system involving pumps and pipelines
but the difficulty of filtering the slurry makes this alternate method unviable.
 With respect to rehabilitation, the decision to backfill the mining void, topsoil the land-formed area
and, to return the land to productive agricultural use is a preferred option from an environmental
and social impact perspective.

Makuutu Rare Earths Project ESIA – Technical Extract 16

4. PUBLIC PARTICIPATION
4.1 Stakeholder Engagement Activities
Public participation during the ESIA is a legal requirement established in the National Environment Act,
2019 and the National Environment (Environmental and Social Assessment) Regulations, 2020,
Schedule 5.
The law emphasises the need to engage stakeholders and the project affected persons from the earliest
phase of the ESIA process through to project implementation and operation. The purpose is to share
information with the stakeholders, the project affected persons and the general public about the nature of
the project, the location, potential impacts and the proposed measures to avoid, mitigate and manage
the impacts. This is also to provide the public an opportunity to provide comments and views on the
findings and proposed mitigation measures to inform decision making.
The public participation process for the Makuutu project began during the scoping phase of the ESIA in
2020 through to the ESIA study and is still ongoing. The comments and views during the ESIA study are
appended to the ESIA report (Section 8.9.3). Below (Figure 4.1) are sample photos taken during the
consultation for the Makuutu project.

Bugweri District Local Government Stakeholder Makuutu Sub-county Stakeholder Consultation

Consultation Meeting Meeting, Bugweri District Local Government

Bugiri District Local Government Consultation Mayuge District Local Government Consultation
Meeting Meeting

Bugweri Chiefdom Stakeholder Consultation Meeting NGO Stakeholder Consultation Meeting in Bugweri
District

Makuutu Rare Earths Project ESIA – Technical Extract 17

 Meeting with Buseesa Sub-county officials in Mayuge Consulting Women in Makandwa village, Bugweri
District District

Figure 4.9: Stakeholder Engagement during Makuutu Project ESIA Process

4.2 Grievance Mechanism

The Grievance Mechanism is a key process for resolving stakeholder concerns. The Makuutu Project
Grievance Mechanism is summarised in Figure 4.2. Key points include:
 Stakeholder grievances should be reported to the Community Liaison Officers (CLOs) or to the
Makuutu Stakeholder Engagement and Communications Specialist;
 The Project will investigate and provide feedback to the complainant in the stipulated timeframe;
 All complaints will be formally tracked and reported; and
 Solutions to ongoing issues will be developed collaboratively with the relevant stakeholders.

Makuutu Rare Earths Project ESIA – Technical Extract 18

 Figure 4.10: Makuutu Project Grievance Mechanism Process

Makuutu Rare Earths Project ESIA – Technical Extract 19

5. IMPACT ASSESSMENT
The impact assessment process commenced with an overview of the environmental and social baseline
of the proposed project area. The potential impacts of project-related activities were then presented in an
Issues and Impact Register following analysis of the likelihood and consequence of these impacts.
5.1 Potential Project Benefits
Potential Makuutu Project benefits on a local, national and global scale are illustrated in Figure 5.1.

Figure 5.11: Mind-map of the Makuutu Project Benefits

Makuutu Rare Earths Project ESIA – Technical Extract 20

5.2 Potential Impacts and Mitigation Measures
The identified potential impacts of the Makuutu Rare Earths project are summarised in Table 5.1 that follows.
Table 5.6: Potential Impacts and Mitigation Measures
Issue Potential Impact Key Mitigation Measures
Exploration Drilling
Land Access Unauthorised or illegal activity by the Project.  Obtaining an Exploration Lease (EL).
Landowner conflict.  Signing Land Access Agreement with landowners.
Drilling Activity Generation of litter.  Bins provided and all rubbish removed.
Damage to vegetation.  Minimal clearing footprint for safe drilling.
 Spare mature indigenous trees whenever possible and particularly in
areas outside the mining pit.
 Spare nesting trees if possible and if inevitable that a nesting tree has to
be felled, let it be so during non-breeding season.
 Plant trees and other useful habitat in revegetated areas.
Contamination of surface streams  No drilling within 25m of watercourse.
Impact on public safety.  No drilling within 125 m of major road or dwelling.
Spillage of fuels and oils.  All fuels and oils to be stored in a bunded area.
Noise and vibration impacting amenity.  Avoid drilling near any residences.
Designing the Project to Largescale compensation and resettlement. Staged resettlement in line with mining plan incorporating progressive
minimize impacts on the rehabilitation and return to productive agricultural land.
community  Involuntary resettlement avoided by fair payment to landowners.
Compensation paid and livelihoods and food security secured for other
Project Affected Persons (PAPs) in line with Compensation and
Resettlement Action Plan.
Acceleration of land erosion.  Avoid unnecessary land clearing.
 Properly construct bridges and river crossings for high flow events.
Construction Phase
Construction activities. Interference with stream flows.  Installation of appropriate bridges and culverts at river crossings.
Increased sedimentation and turbidity in  Sheeting of roads with laterite/cap-rock limits muddiness.
streams.  Diversion of storm water and stablization of topsoil stockpiles to limit
erosion.
Makuutu Rare Earths Project ESIA – Technical Extract 21
 Issue
General workforce impacts
Communicable diseases
Un-controlled in-migration to the
project area.
Makuutu Rare Earths Project ESIA – Technical Extract
Potential Impact
Generation of litter.
Wildlife hunting by workforce.
Fuel spill in the mining area contaminating
land and surface water.
Chemical spill in processing plant area
contaminating land and surface water.
Excessive dust in dry season.
Project contractors contribute to the spread of
HIV and other communicable diseases in the
local community.
Creation of social conflict.
Inadequate community services.
Increased spread of Covid-19.
Loss of capacity in key community services
such as food security, health, education and
law and order in communities near the project
site.
Child abuse/Child labour
Key Mitigation Measures
 Enforcement of site waste management procedures.
 Enforcement of no hunting or bush-meat Policy on site.
 Fit for purpose fuel storage and handling facilities including bunded bulk
storage.
 Spill prevention and clean-up procedures.
 Well trained and competent workforce.
 Enforce speed limits on haul roads.
 Dust suppression (e.g., water trucks and sprinklers) as necessary to
prevent dust.
 Workforce education on HIV safety and expected standards of workforce
behaviour.
 Condom vending machines.
 Community Health Support Programmes (i.e., as per Community
Development Plan).
 Security of tenure for local landowners.
 Support of local authorities.
 Sustainable livelihood focus.
 Community education.
 Build capacity in the community in partnership with key stakeholders
including District Planners.
 Proof of Covid-19 vaccinations for expatriate visitors plus quarantine as
required by Ugandan authorities.
 No one with cold/flu symptoms allowed to attend work.
 Temperature check on arrival at work.
 Masks and social distancing to be in place at workforce in combination
with hand washing/sanitization.
 Collaborative programmes with government to appropriately serve
growing centres and build capacity as per Community Development Plan.
 Livelihood and food security support projects as per the Community
Development Plan.
22
 Issue Potential Impact
Status of Women (gender inequality)
Gender-Based Violence
Occupational Health and Safety Injuries and occupational health impacts on
employees and contractors.
Land Clearing Loss of timber resources.
Loss of rare species
Loss of topsoil
Acceleration of land erosion and consequent
surface water turbidity.
Makuutu Rare Earths Project ESIA – Technical Extract 23
Key Mitigation Measures
 Scholarships and other support to children.
 Makuutu Employment Policies that prohibit child labour.
 Training and education of women and girls.
 Equitable employment of women at the Project.
 Livelihood and food security support to affected persons including
women who are not landowners.
 Business contracts for women (e.g., cleaning, waste management,
nursery/rehabilitation, fish farming etc.)
 Support of law enforcement capacity.
 Funding of women’s shelters.
 Livelihood Projects for women.
 Support of law enforcement capacity.
 Education for Makuutu workforce on acceptable personal behaviour
standards of employees.
 OHS Management System.
 Fit for Purpose facilities and equipment.
 Good Procedures (including mandatory risk assessment prior to tasks
being undertaken).
 Competent People (appropriately trained, licensed and fit for work with
good supervision).
 Governance (monitoring and audits).
 Critical Safety Rules.
 Avoid trees outside of the mining envelope where possible.
 Salvage all valuable timber.
 Baseline assessment to confirm lack of rare or endemic species in
clearing envelope completed as part of the ESIA.
 Protection/restoration of downstream wetlands over the life of the Project.
 Topsoil conserved for future rehabilitation in grassed (non-erosive)
stockpiles.
 Avoid unnecessary clearing.
 Construct bridges and river crossings for foreseeable flood events.
 Active grassing/ revegetation of disturbed areas and topsoil stockpiles.
 Issue Potential Impact
Damage to archaeological sites.
Displacement of wildlife.
Mining activities Interference with stream flows.
Increased sedimentation and turbidity in
streams.
In-migration of settlers onto
Project land.
Diesel and oil spill contamination of land and
surface water.
Generation of high volumes of greenhouse
gas.
Generation of exhaust emissions impacting
air quality (also applicable to process plant
activities).
Noise and vibration impact to nearby
Communities (also applicable to process
plant activities).
Inappropriate disposal of tyres, batteries and
Makuutu Rare Earths Project ESIA – Technical Extract
Key Mitigation Measures
 Avoid unnecessary clearing.
 Archaeological baseline assessment to identify sites of significance.
 Workforce awareness and observation about archaeological sites.
 Pre-clearing inspection by trained inspector.
 Protect from hunting (i.e., no Bush-meat Policy).
 Supervision.
 Installation of appropriate storm-water diversion structures.
 Diversion to sumps of storm water in pits to minimise sediments in storm
water discharge.
 Stabilisation and greasing of topsoil stockpiles to reduce erosion.
 Installation of storm water pond to capture storm water for clarification
and other treatment as necessary prior to discharge.
 Sheeting of roads with laterite/cap-rock limits muddiness.
 Installation of appropriate bridges and culverts at river crossings.
 Security fencing, security inspections and, security presence on all
access roads.
 Double skinned self-bunded diesel tank.
 Good spill response and clean-up processes.
 Oil traps at truck wash facilities.
 Good maintenance practices including regular change of hydraulic hoses
to prevent rupturing.
 Selection of energy efficient machinery.
 Efficient design of operational layout.
 Well maintained and efficient machinery.
 Appropriate maintenance and operational practices.
 Competent workforce.
 Buffer distance between operations and residences.
 Appropriate noise and vibration control.
 Maximise buffer distance from noise-sensitive premises.
 Good waste management procedures including appropriate disposal
24
 Issue Potential Impact
hydrocarbons and other regulated waste
(also applicable to process plant activities).
Process activities Contamination of surface and groundwater
Plant with process chemicals including potential to
contaminate food crops in downstream
wetlands.
Trespassers onto property from adjacent 
communities.
Un-controlled in-migration into Social conflict.
project areas.
Inadequate community services.
Increase in communicable diseases such as
HIV/AIDS.
Communicable diseases Project workforce contributes to the spread of
HIV and other communicable diseases in the
local community.
Loss of public infrastructure Public roads and facilities consumed by
expanding mining pit.
Food Security Shortage of land for agriculture in expanding
communities near the project site.
Makuutu Rare Earths Project ESIA – Technical Extract 25
Key Mitigation Measures
strategies and facilities.
 Fully contained (bunded) storage facilities.
 Lined heap leach pads and ponds.
 Reverse osmosis treatment of process liquors to remove all ammonium
salts.
 Storm-water pond to contain water prior to release to surface waters.
Buffer zone around operational areas.
 Security fencing, and security inspections.
 Security of tenure for local landowners.
 Support of local authorities.
 Sustainable livelihood focus.
 Community education.
 Build capacity in the community in partnership with key stakeholders.
 Preliminary Compensation and Resettlement Action Plan.
 Influx management.
 Community Health Support Programmes (Community Development
Plan).
 Management of in-migration with District Planners and through clarity of
land ownership.
 Policy to reside long-term workforce in the community.
 Workforce education on HIV safety and expected standards of workforce
behaviour.
 Condom vending machines.
 Compensation and Resettlement Action Plan.
 Staged resettlement.
 Engagement with communities and district planners.
 Livelihood Restoration Plan.
 Clarification/security of land tenure.
 Integrated land use planning with key stakeholders including planned
agriculture.
 Community Development Plan.
 Issue Potential Impact
Public Safety and Security Increased road accidents due to increased
traffic on public access roads.
Poor capacity of external emergency
responders.
Law and Order Breakdown of law and order in rapidly
expanding communities near the project site
due to lack of public law and order capacity.
Community Adverse impact on a range of aspects
Services including education, water security,  Community Development Plan.
community health driven by loss of
infrastructure and demographic change.
Biodiversity impact  Biodiversity impact from habitat loss.
 Biodiversity impact on downstream  Good containment of all chemicals on-site and maintenance of good
habitats due to pollution from the
Project.
Legal compliance with  Activities without securing the
environmental laws requisite permits and approvals.
 Inadequate environmental monitoring
and reporting in breach of
environmental licence and regulatory
requirements.
Poverty Inadequate protection from poverty and
Makuutu Rare Earths Project ESIA – Technical Extract
Key Mitigation Measures
 Security fencing and security staff to guard against public entry into
mining and processing areas.
 Upgrade roads in consultation with District planners.
 Construct and fully separate haul road with security fencing and
controlled crossing.
 Increased public emergency response capacity including hospital
emergency capacity.
 In-house project emergency response capacity and on-site medical
facility.
 Collaborative Emergency/Crisis Response exercises and plans.
 Control in-migration.
 Appropriate government support to enforce law and order.
 Planned development and sustainable livelihoods.
 Compensation and Resettlement Action Plan.
 Baseline assessment and strategic avoidance.
quality stormwater discharge.
 Secure all necessary licenses, approvals and permits as applicable and
meet conditions therein.
 Site monitoring/reporting and public disclosure processes.
 Conditions of Permits including:
o Water abstraction - DWRM (not anticipated but possible);
o Waste-Water Discharge- DWRM;
o Waste Management (NEMA);
o Class 2B Landfill (NEMA);
o Storage of fuel – MEMD; and
o Workplace Registration - DOSH/MGLSD.
 Vulnerability assessment in combination with a rights-based approach
26
 Issue
Community engagement
Community
health
Tailings/spent ore disposal
Community Water supply
Land and water contamination
from mined ore.
Physical completion criteria for
decommissioning in place.
Social completion criteria for
decommissioning in place.
Makuutu Rare Earths Project ESIA – Technical Extract 27
Potential Impact Key Mitigation Measures
other adverse outcomes for vulnerable (e.g., Right to property, fair compensation, education, employment,
Groups. health services etc.).
Inadequate community engagement /  Community Management Plan and ongoing engagement over the life of
information sharing with poorly educated the Project.
communities.  Effective grievance mechanism.
Contamination of land and surface waters  High standard toilets and Sewage Treatment System.
with sewage at Makuutu camps at project  Effluent/water quality monitoring to ensure functionality of system.
site.  Hygiene education of workforce.
Inadequate disposal of tailings/spent clay  In-pit disposal and progressive rehabilitation.
residues leading to pollution.  Site Operational Control.
 Low concentrations of residual process chemicals in spent clay after
washing.
Depletion of natural springs used by local  Complete independence for water supply based on harvested storm
people or wildlife during mining operations. water.
 Mapping of local springs and water sources in ESIA.
 Replacement of any springs or water sources impacted by site footprint.
Contamination of land from direct product  Benign product with negligible impact.
spillage during processing and transport  Spillage recovered as saleable product.
operations.  Well-designed and maintained slurry transfer systems.
Closure and Decommissioning
Rehabilitated mining areas prove unsuitable  Develop physical completion criteria and rehabilitation techniques in
for agreed final land-use at the end of collaboration with and to the satisfaction of key stakeholders including
mining. post-closure monitoring.
 Undertake revegetation/research trials over the life of the Project on
rehabilitated land to validate/optimise techniques and demonstrate long-
term effectiveness.
Closure of project causes severe social  Develop social completion criteria in close collaboration with key
dislocation and adverse social impacts. stakeholders including post-closure monitoring.
 Long-term livelihood projects such as fish farming, intensive agriculture,
agroforestry and other businesses in place to sustain livelihoods after
mine closure and decommissioning.
 High capacity developed in essential social services to sustain high
 Issue
Insufficient funds in place to
achieve physico-chemical and
social closure objectives.
Final Closure Plan in place within
five (5) years of closure.
Makuutu Rare Earths Project ESIA – Technical Extract
Potential Impact
State of Uganda left with legacy issues.
Lack of a fully integrated Final Closure Plan
prepared to the satisfaction of NEMA in
place to ensure that the Project leaves no
adverse physicochemical or social legacies.
Key Mitigation Measures
standards of community health, education, personal security and food
security over the long term.
 Formally determine the Project Asset Retirement Obligation (ARO)
annually and ensure sufficient funds are in place should an unplanned
closure occur.
 Develop a final Project Closure Plan in collaboration with key
stakeholders including the Ugandan Government (National, District and
Local), key institutions, NGOs and other partners.
28
6. CUMULATIVE IMPACT ASSESSMENT
The ESIA addressed potential impacts that could result from the successive, incremental, and/or
combined effects of the Makuutu Rare Earths Project when added to other existing, planned, and/or
reasonably anticipated future projects/development.
At the time of the ESIA, there were no known major planned development projects that will be operating
concurrently with the Makuutu Project to create major cumulative impacts. There are, however a number
of major agricultural support projects being undertaken in the Project area which will impact livelihoods.
These projects include the:
 US $248 million Agriculture Cluster Development Project;
 IFAD Country Strategic Opportunities Programme for the Republic of Uganda which is
particularly relevant to Mayuge District; and
 Igogero and Naigombwa Irrigation Scheme Project.
The cumulative impact risks are anticipated to mainly be associated with people influx as provided in the
table below.
Table 6.7: Outlook for Cumulative Impacts
Impact Planned Control
Expanding population in Project area due to  Integrated land-use planning with key
multiplier effect. stakeholders including the Ugandan
Government, local community and
NGOs.
 Community Development Plan.
Increased road traffic as a result of population  Collaborate with and support Ugandan
expansion causing roads to deteriorate and Government with improving roads in
accidents to increase in the area. Project area.
Development of additional large mining  Provide Ugandan government with a
operations in Uganda driven by the success of good benchmark on planning,
the Makuutu Project multiplying the social and development and management of
environmental impacts assessed for the mining operations for good sustainability
Project. outcomes.
 Provide pool of experienced Ugandan
regulators and specialists benefiting
from the Makuutu experience.

Makuutu Rare Earths Project ESIA – Technical Extract 29

7. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN
A nine-volume Environmental and Social Management Plan (ESMP) has been developed to achieve 37
key performance objectives as indicated in the table below.
Table 7.8: Overview of Management Plans and the Key Performance Objectives within each
Volume
ESMP Volume Key Performance Objectives
Volume 1- Environmental and Social  Implement an Effective Environmental and Social
Management and Monitoring Plan Management System (ESMS) to drive continual
improvement in social and environmental performance
over the life of the project.
 Comply with legal and other requirements.
 Minimise impacts on water quality of rivers and streams
during construction and operation.
 Minimise noise and vibration impacts during
construction and operation.
 Manage dust from stockpiles and materials handling.
Volume 2- Stakeholder Engagement  Consult stakeholders and consider their concerns in
Plan project decisions.
 Engage stakeholders in the development of
management plans.
 Establish strong and enduring relationships with key
stakeholders.
Volume 3 - Community  Plan and manage in-migration of outsiders into local
Development Plan communities directly impacted by the Project.
 Support the principle of land tenure for local people to
prevent loss of land and resources to outsiders in-
migrating into Project areas.
 Improve food security for expanding local communities.
 Combat the spread of HIV and other diseases in
expanding local communities.
 Ensure high standards of road safety on access roads
within Project areas.
 Facilitate community training and education to enable
local communities to take advantage of Project
opportunities and facilitate employment.
 Encourage government to develop appropriate
community infrastructure and services for water supply,
electrical power, communications and roads in local
communities directly impacted by the Project.
 Establish woodlots, aquaculture and intensive
agriculture Projects on revegetated project Land.
Volume 4 - Preliminary  Achieve voluntary negotiated agreements with
Compensation and Resettlement impacted stakeholders to minimise the need for

Makuutu Rare Earths Project ESIA – Technical Extract 30

 Action Plan involuntary resettlement.
 Manage the in-migration of outsiders into the
compensation zone during the negotiation process.
 Ensure adversely impacted people are compensated in
a transparent and consistent manner.
 Ensure that the economic impact of displacement is
mitigated.
 Target development opportunities for displaced people.
 Seek Government support to secure compensated
land.
Volume 5 - Emergency  Proactively manage Project activities to minimise the
Management Plan risk of emergencies.
 Respond quickly and effectively to emergency
situations.
 Fully investigate all emergencies and provide effective
post-emergency support to mitigate consequences and
reduce the risk of a recurrence.
Volume 6 - Waste Management  Implement an Integrated Recycling System.
Plan
 No unauthorised disposal of hydrocarbon and chemical
waste to landfill.
 Management of the site land-fill to ensure legal
compliance and environmental protection.
 Appropriate disposal of medical waste to eliminate risk
of infection to workforce or the community.
 Ensure workforce compliance with waste procedures.
Volume 7 - Greenhouse Gas  Optimise greenhouse gas emissions in design,
Abatement and Climate Change construction and operation of the Project.
Adaptation Plan
 Publicly report progress on greenhouse gas abatement.
 Integrate green-house gas efficiency into operational
decisions.
 Climate Change Mitigation.
Volume 8 - Life of Mine  Develop Physical completion criteria and rehabilitation
Rehabilitation and Closure Plan techniques to the satisfaction of key stakeholders.
 Formally determine the project Asset Retirement
Obligation (ARO) annually and ensure sufficient funds
are in place.
 Develop a conceptual life of mine and closure plan.
Volume 9 - Occupational Health and  Effective Safety Management System.
Safety Plan
 Strong and Sustainable Safety Culture.
 Site Safety Committee.

Makuutu Rare Earths Project ESIA – Technical Extract 31

8. ENVIRONMENTAL MONITORING
Compliance of the Makuutu Rare Earth Elements project to the requirements and commitments within
the ESIA report will be evaluated through inspections by authorised persons and periodic monitoring
through audits undertaken in accordance with provisions of the National Environmental Act, 2019, and
the National Environment (Audit) Regulations, 2020.
The inspections and audits will aim to identify and correct non-compliances and highlight areas for
improvement during the implementation of the Project. Periodic monitoring shall apply to all phases of
project implementation from construction through to the decommissioning and post-closure period.

Makuutu Rare Earths Project ESIA – Technical Extract 32

COMMENT AND FEEDBACK FORM
The National Management Authority (NEMA) received the Environmental and Social Impact Assessment
(ESIA) report for the proposed Makuutu Rare Earths project by the developer, Rwenzori Rare Metals Ltd
and Ionic Rare Earths.
In accordance with the National Environment Act, 2019 and Schedule 5 of the National Environment
(Environmental and Social Impact Assessment) Regulations, 2020, the general public and persons
specifically affected by the Makuutu Rare Earths Project are invited to study the ESIA Report and make
comments to the same.
The invitation to the general public seeks to offer different stakeholders the opportunity to provide
comments on the environmental and social implications of the Proposed Makuutu Rare Earths Project.
Your views are important to the ESIA review process. You are therefore requested to fill this form after
studying the Makuutu Rare Earths Project ESIA Report. Individual or collective comments from
stakeholders can be submitted to the Executive Director, NEMA using the address at the end of this
form.
1 Details of Respondent:
Name(s)
(Optional): …………………………………………………………………………………………………………….
Name of Organisation (if from an organisation): …………………………………………………………………
Address: ………………………………………………………………………………………………………………
Telephone Number: ………………………………………………………………………………………………….
Email: ………………………………………………………………………………………………………………….
2 What is your interest in the Makuutu Rare Earths Project?
o Resident (Bugweri, Bugiri and Mayuge)
o Developer/ Service Provider
o Development Partner
o NGO/ Civil society
o Other Stakeholders (please specify):
............................................................................................................................................................
3 (i) Are you satisfied with the adequacy of the ESIA Report in respect of the following thematic
areas? (Please tick which is applicable in the table below):
Thematic Area (Subject Matter) Yes Yes (Subject No (Give Not sure
to comments reasons
below) below)
Project Description (Nature of project)
Project Benefits to the local community
Anticipated positive and negative impacts of the
project
Proposed mitigation measures to respond to
the potential negative impacts of the project
Overall adequacy of the ESIA Report

Makuutu Rare Earths Project ESIA – Technical Extract 33

4 (ii) If Yes (subject to consideration of comments below), what would you like to see
addressed? (Please use/attach extra paper if space below is not enough).

a) Project Description (Nature of the project)

…………………………………………………………….....

b) Project benefits to the local community

………………………………………………………………......

c) Anticipated positive and negative impacts of the project

………………………………………………..

d) Proposed Mitigation Measures to respond to the potential negative impacts ………………………..

e) Overall adequacy of the ESIA Report……………………………………………………………………..

2 (iii). If No, state reasons why? (Please use/attach extra paper if space below is not
enough).

a) Project Description (Nature of the project) ……………………………………………………………….

b) Project benefits to the local community …………………………………………………………………..

c) Anticipated positive and negative impacts of the project ……………………………………………….

d) Proposed mitigation measures to respond to the potential negative impacts ………………………..

e) Overall adequacy of the ESIA Report …………………………………………………………………….

f) Additional comments (if any)? …………………………………………………………………………….

Thank you for your contribution towards the review of the Makuutu Rare Earths Project ESIA Report,
your views will be taken into consideration. Comments recorded in this form or as presented in any other
format should be sent to the address or email below:
The Executive Director
National Environment Management Authority
NEMA House, Plot 17/19/2 1 Jinja Road
P.O. Box 22255, KAMPALA
Tel: +256-716-013360, Fax: +256-414-257521
Email: info@nema.go.ug
Alternatively, submit your completed form at the respective indicated locations in this document for
collection by a NEMA representative. Please inform us by phone (+256-716-013360) if you need us to
collect your completed form so that we can make the necessary arrangements to pick it up.

Makuutu Rare Earths Project ESIA – Technical Extract 34