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Mako Gold Project Environmental and Social Impact Assessment FINAL Chapter 12 | Niokolo-Koba National Park Impacts and Management Measures

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Page 1: Chapter 12 | Niokolo-Koba National Park Impacts and ... · leopards (Panthera pardus), African lions (Panthera leo), African wild dogs (Lycaon pictus), hippopotamus (Hippopotamus

Mako Gold Project

Environmental and Social Impact Assessment

FINAL

Chapter 9 | Biological Impacts and Management Measures

Chapter 12 | Niokolo-Koba National Park Impacts and Management

Measures

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Mako Gold Project

Environmental and Social Impact Assessment

FINAL

Chapter 12 | Niokolo-Koba National Park Impacts and Management Measures

12 NIOKOLO-KOBA NATIONAL PARK IMPACTS AND MANAGEMENT

MEASURES .................................................................................................... 12-1

12.1 PNNK and Priority Species and Habitats ....................................................................................... 12-2

12.1.1 Existing Threats in and around PNNK .............................................................................. 12-4

12.1.2 Current Status of Priority Large Mammal Populations in PNNK ............................. 12-5

12.2 Potential Impacts Associated with Mako Gold Project ............................................................ 12-6

12.3 Avoidance, Mitigation and Management .................................................................................. 12-12

12.3.1 Avoidance ............................................................................................................................... 12-12

12.3.2 Minimisation .......................................................................................................................... 12-12

12.3.3 Rehabilitation / Decommissioning / Closure ............................................................. 12-14

12.4 Residual Impact Assessment and Offsets .................................................................................. 12-14

12.4.1 Residual Impact Assessment ........................................................................................... 12-14

12.4.2 Offset Strategy ...................................................................................................................... 12-18

12.5 Monitoring and Evaluation ............................................................................................................. 12-19

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Environmental and Social Impact Assessment

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12 NIOKOLO-KOBA NATIONAL PARK IMPACTS AND MANAGEMENT MEASURES

The purpose of this chapter is to assess Project-related impacts on the Outstanding Universal Values1 (OUVs) of

the Niokolo-Koba National Park (Parc National du Niokolo Koba - PNNK) for which the PNNK is listed as a World

Heritage Site (UNESCO, 2012). This chapter also includes a residual impact assessment and a summary of the

Company’s offset strategy that has been designed to offset residual impacts to ensure ‘no net loss’ of

biodiversity.

The Project lies entirely outside of the PNNK and buffer zone; and is located close to the PNNK, 1 km east of the

PNNK at its closest point (Figure 12-1). The PNNK is one of the largest protected areas in West Africa, spanning

9,130 km2. The PNNK is an internationally recognised area for biodiversity, and has been designated as a natural

World Heritage Site, a UNESCO-MAB Biosphere Reserve and an Important Bird Area (IBA) because of remarkable

biodiversity and a range of ecosystems. The Project is not expected to have any direct impacts to the OUVs of

the PNNK arising from habitat clearance for Project development.

There are important linkages between this chapter and other impact chapters in this ESIA Report. The Project

will not be operating in the PNNK or its buffer zone. An assessment of impacts on priority species and habitats

associated with the Project Development Area (PDA) and Project Study Area is presented in Chapter 10:

Biodiversity Impacts. An assessment of the potential impacts of the Project on physical, biological and social

aspects is presented in Chapters 9, 10, and 11.

Detailed plans related to the management of potential biological impacts, and implementation of biodiversity

offsets, are provided in the following components of this ESIA Report:

Biodiversity Action Plan (BAP), which includes the Company’s biodiversity offset strategy (Volume C);

Technical appendices to this ESIA (Volume A);

Environmental and Social Management and Monitoring Plan (ESMMP, Volume C);

Rehabilitation and Conceptual Mine Closure Plan (RCMCP, Volume E); and

Select chapters of the ESIA (which will be specifically referred to).

1 OUV has been defined as “…natural significance which is so exceptional as to transcend national boundaries and to be of common

importance for present and future generations of all humanity.” (IUCN, 2013)

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Environmental and Social Impact Assessment

FINAL 12-2

Figure 12-1 Project location in relation to the Niokolo-Koba National Park and Senegal's borders

12.1 PNNK and Priority Species and Habitats

Niokolo-Koba National Park (PNNK) was inscribed on the UNESCO World Heritage list in 1981 due to its

Outstanding Universal Values (OUVs) in accordance with Criterion (x)2. The PNNK is listed because it “contains

all the unique ecosystems of the Sudanese bioclimatic zone such as major waterways (the Gambia, Sereko, Niokolo,

Koulountou), gallery forests, herbaceous savanna floodplains, ponds, dry forests - dense or with clearings - rocky

slopes and hills and barren bowés. The property has a remarkable diversity of wildlife, unique in the sub-region. It

counts more than 70 species of mammals, 329 species of birds, 36 species of reptiles, 20 species of amphibians and a

large number of invertebrates”(UNESCO, 2012). “Lions, reputedly the largest in Africa, are a special attraction, as well

as the Derby Eland, the largest antelope in existence. Other important species are also present, such as the elephant,

leopard, African wild dog and chimpanzee “(UNESCO, 2015).

The remote and inaccessible areas of the PNNK are known to be inhabited by many species, including the last

wild population of African elephants (Loxodonta africana) in Senegal. Other threatened species known to

inhabit the PNNK are West African chimpanzees (Pan troglodytes spp verus; hereafter referred to as chimpanzee),

leopards (Panthera pardus), African lions (Panthera leo), African wild dogs (Lycaon pictus), hippopotamus

(Hippopotamus amphibius), West African red colobus (Procolobus badius), western giant elands (Taurotragus

derbianus spp derbianus), hooded vultures (Necrosyrtes monachus) and white-backed vultures (Gyps africanus).

The PNNK is intersected by several major waterways and their tributaries; the Gambia, Niokolo and Koulountou

Rivers are distinctive features of the landscape and also create seasonal grass floodplains. The waterways

provide habitat for the three African crocodile species (Crocodylus sp.), tortoises, as well as numerous species

of fish and invertebrates and other wildlife (e.g. otters). The PNNK also supports many bird species including

2 Contains “the most important and significant natural habitats for in-situ conservation of biological diversity, including those containing threatened species of outstanding universal value from the point of view of science or conservation” (WHC 2013)

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Environmental and Social Impact Assessment

FINAL 12-3

biome restricted species and migratory species which are dependent on freshwater ecosystems as stop-over

points in their annual migratory routes.

Terrestrial and aquatic baseline studies (see Chapter 7) and a Critical Habitat Assessment (TBC, 2015) using

criteria as per IFC PS6 (IFC, 2012) were used to more clearly define the OUVs of the PNNK that are relevant to

the Project. The biodiversity features identified as a priority species and habitats for the ESIA are presented in

Table 12-1. Not all of these species and habitats were identified within the PNNK Study Area nor the Project

Study Area (see Chapter 7: Biodiversity Settings for a definition of the study areas applicable to the Project).

This impact assessment considers impacts to priority fauna that inhabit the PNNK and buffer zone and priority

fauna that are known to range outside these areas into the PDA and Project Study Area (e.g. PNNK ranging

species such as chimpanzees and hippopotami). This chapter also considers impacts to priority habitats and

flora located in the PNNK and buffer zone. Impacts to priority habitat and flora outside of this area (e.g. bowal

habitat in the PDA) do not constitute an impact to the OUVs of the PNNK.

Table 12-1 Priority habitats and species

Type of Risk

Receptor

Priority Biodiversity

Features

Critical

Habitat-

qualifying

IUCN

Status

PDA Project

Study

Area

PNNK

Study

Area

Wider

PNNK

Natural

Habitats (and

fauna

habitats)

Gallery Forest + + +

Bowal + + + +

Gambia River + + + +

Flora

Lepidagathis capituliformis + EN ? ? +

Scleria chevalieri + CR ? ? +

Tephrosia berhautiana + EN ? ? +

Albizia ferruginea VU +

Afzelia africana VU +

Khaya senegalensis VU +

Vitellaria paradoxa VU +

Large

Mammals

West African Chimpanzee (Pan

troglodytes spp. verus)

+ EN + + + +

Western giant eland

(Taurotragus derbianus spp.

derbianus) sub-species:

+ CR + +

African Wild Dog (Lycaon

pictus)

+ EN +

African lion (Panthera leo), West

African population - sub-

population

+ CR + +

African elephant (Loxodonta

africana)

VU + +

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Type of Risk

Receptor

Priority Biodiversity

Features

Critical

Habitat-

qualifying

IUCN

Status

PDA Project

Study

Area

PNNK

Study

Area

Wider

PNNK

Hippopotamus (Hippopotamus

amphibious)

VU + + +

West African red colobus

(Procobolobus badius spp

temminckii)

+ EN +

Birds Hooded vulture (Necrosyrtes

monachus)

EN + +

White-backed vulture (Gyps

africanus)

EN + +

Rueppell's vulture (Gyps

rueppellii)

EN +

Egyptian vulture (Neophron

percnopterus)

EN +

Reptiles Cynisca senegalensis + Data

Deficient

+

Dwarf crocodile (Osteolaemus

tetraspis)

VU +

Fish Barbus dialonensis + VU ? ? ? ?

Invertebrate Elattoneura pluotae + CR +

Key: * = Draft Red List assessments carried out by Royal Botanic Gardens, Kew; + = presence; and ? = occurrence unknown, further

investigation required; CR = Critically Endangered (IUCN, 2015); EN = Endangered (IUCN, 2015); VU = Vulnerable (IUCN, 2015)

12.1.1 Existing Threats in and around PNNK

Habitat quality and species diversity in the PDA, Project Study Area and surrounding environs have been

impacted by anthropogenic disturbance including conversion of natural habitats to agro-pastoral systems,

uncontrolled burning, illegal and unregulated hunting and unsustainable collection of natural resources

(timber and non-timber products). These are described in detail in Chapter 7: Biodiversity Settings. These

threats are also known to occur inside the PNNK and buffer zone.

Human pressure on the Park has resulted in it being placed on UNESCO’s List of World Heritage in Danger in

2007. The PNNK was originally listed as being in danger due to imminent threats to its Outstanding Universal

Values (OUVs), including critically low mammal populations, ongoing issues with management and the

potential impacts associated with a proposed hydropower development on the Gambia River upstream of the

Park. The PNNK has remained on UNESCO’s List of World Heritage in Danger since 2007.

The most significant threat to the OUV of the property is commercial poaching for the bushmeat trade

(UNESCO, 2007b; 2015). Poaching appears to have reduced since 2007 due to the permanent presence of

rangers in the PNNK and this appears to be having a positive impact on wildlife in the Park. However, the loss

of fauna reportedly increases with distance from the fixed guard posts (IUCN, 2015).

Threats in the PNNK also include livestock grazing, drought, illegal logging and the spread of non-indigenous

and invasive plants (UNESCO, 2007b). Other threats to habitats and species in the PNNK, identified during

baseline surveys, include artisanal mining, the creation of tracks and roads (facilitating poaching) and the

collection of non-timber products (e.g. fruit) (See Chapter 7: Biodiversity Settings).

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The IUCN has also listed the PNNK as being of “critical conservation outlook”, highlighting that it requires urgent

(additional), large-scale conservation measures, or the Park may lose the values for which it was awarded World

Heritage listing (Osipova et al., 2014).

12.1.2 Current Status of Priority Large Mammal Populations in PNNK

At a meeting in June 2014 (UNESCO, 2014), the World Heritage Committee decided to retain the PNNK on the

List of World Heritage in Danger due to concern over the conservation (and low numbers) of key species. The

World Heritage Committee reiterated “its serious concern as regards the state of conservation of the key species in

the park, notably the elephant and chimpanzee” (UNESCO, 2014). In 2015 the PNNK was retained on the List of

World Heritage in Danger. Corrective measures include updating the ecological monitoring programme of key

species for the Outstanding Universal Values of the property (lion, Derby eland, elephant, chimpanzee and wild

dog) and integrating this information into the management plan (UNESCO, 2015).

Dupuy and Verschuren (1977) state that the elephant population in the PNNK comprised approximately 350

individuals, based on an aerial census carried out since 1968. It was suggested by Dupuy and Verschuren (1977)

that without poaching, elephant numbers could have exceeded 1,500 and other species’ populations would

have similarly increased. However, by 1975 elephant numbers had already started to decline. In a 2006 aerial

survey of the south of the PNNK, six elephants were sighted and Renaud et al., (2006) estimated that the

population comprised of 10 elephants at the time of survey. This group of 10 is only 3% of the 350 individuals,

and although the entire Park was not surveyed during 2006, this is nonetheless a dramatic decline. According

to the Rapport de la Mission UICN au Parc National du Niokolo-Koba (Tiomoko and Van Merm, 2015), the exact

number of elephants currently present in the PNNK is uncertain however, only one elephant is regularly

observed.

Lion numbers also appear to have declined, although exact population numbers are not clear. From 1996 to

2001 estimates of lion populations were between 20 and 150 (Bauer, 2003; Bauer and Van Der Merwe, 2004).

Current lion population estimates in the PNNK are 16 with a maximum of 54 and that dramatic and catastrophic

declines in prey populations are the major causing factor (Henschel et al., 2014). One of the main causes of lion

prey population declines is poaching.

The West African Wild Dog (subpopulation) is Critically Endangered (IUCN, 2014; TBC, 2015). The population in

the PNNK is thought to be the only potentially viable population in the region, and was one of the key values

for the designation of the UNESCO World Heritage Site (TBC, 2015). The population in the PNNK appears to be

recovering and small packs comprising approximately twenty individuals are regularly observed by rangers

and researchers (Tiomoko and Van Merm, 2015).

Populations of some prey species (antelope) of African lions and African wild dogs also appear to be increasing

in numbers (Tiomoko and Van Merm, 2015).

The western giant eland (the West African subspecies of Giant Eland) is listed as Critically Endangered (East,

1999; IUCN 2014). Less than 200 animals are estimated to remain in Senegal, with the majority in the PNNK

(Nezerková & Hájek 2000; Koláčková et al., 2011; IUCN 2014). The PNNK population was also one of the key

values for the designation of the PNNK as a UNESCO World Heritage Site.

The estimated number of wild chimpanzees in Senegal ranges between 200 and 400 individuals (this estimate

does not include individuals identified during the Project baseline study), with most individuals inhabiting

unprotected areas (Kormos et al., 2003). The PNNK is regarded as an extremely important area for chimpanzee

conservation (Pruetz et al., 2002; Kormos et al., 2003), and holds 46% of the species’ national range. The exact

number of chimpanzee individuals in the PNNK is uncertain. It is clear that there are two known communities

(Pruetz et al. 2012), one at Mount Assirik and a second at Anten and the Mako group may be a third. There is

potential for there to be additional communities as large areas of the PNNK have not been surveyed.

There is some indication of population stability in the Mount Assirik community within the PNNK. This

community was studied in the 1970’s (see McGrew et al., 1981) and surveyed again in 2000 by the Miami Assirik

Pan Project. Pruetz et al., (2012) revisited the community in 2012 and found that the population had increased

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since 2000, however the authors admit that caution should be made when interpreting the results as they did

not cover as much area as the 2000 study.

Despite the distance of the Mount Assirik community from the national border or the National Route 7

(>20 km), there is recent evidence of poachers, including shells, footprints and shotgun fire. It is believed that

these poachers were targeting large mammals, particularly antelope but not chimpanzees. However, the

chimpanzees’ behaviour is likely to have been altered from the presence of the poachers, and this activity may

cause them stress. There was a dramatic increase in the detection of poaching evidence in the 2012 study

compared to the 2000 survey. Wildlife densities in the PNNK remain low (Tiomoko and Van Merm, 2015).

Overall, poaching is likely to be a major determining factor in the decline of large mammals in the PNNK in the

future without widespread and multi-agency intervention (Henschel et al., 2014).

12.2 Potential Impacts Associated with Mako Gold Project

The following sections consider the potential Project-related risks for the OUVs in the PNNK Study Area (for a

definition of this area, see Chapter 7: Biodiversity Settings), as well as priority fauna that are known to range

outside this area into the PDA and Project Study Area (PNNK ranging species) in the absence of appropriate

management and mitigation. Management and mitigation measures are outlined in Section 12.3 and residual

impacts are assessed in Section 12.4.

The Project lies entirely outside of the PNNK and buffer zone, hence there will be no direct habitat loss within

the PNNK or its buffer zone, as none of the Project components or roads are located within these areas. In the

absence of appropriate management and mitigation, the most significant potential risks to the OUVs as a result

of the Project are likely to be associated with:

Project-induced in-migration to villages near the PDA, leading to increased risk of indirect habitat loss

and degradation from timber and non-timber collection, habitat clearance for agro-pastoral activities

and artisanal mining in the PNNK Study Area;

Project-induced in-migration and increased poaching in the PNNK Study Area;

Species displacement (of species from the PDA into the PNNK) and increased inter-intra-specific

competition/conflict from habitat loss;

Habitat loss, fragmentation and barriers to movement for some PNNK ranging species associated with

Project development;

Accidental injury and mortality of PNNK ranging species from vehicle collision or poisoning (from

contaminated water within the TMF during operation;

Introduced and invasive species entering the PNNK as a consequence of Project induced in-migration;

Artificial lighting; and

Noise and vibration (e.g. from blasting).

Other less likely/significant potential risks that may alter species assemblage and distribution will be changes

to air quality and downstream water quality/hydrology.

Potential risks to the OUVs of the PNNK associated with each of these aspects in the absence of mitigation are

discussed in the following sections.

In-migration

Project-induced in-migration to villages near the PDA is expected to lead to increased pressure on natural

resources due to increased natural resource exploitation (i.e. increased collection of timber and non-timber

products, poaching and fishing). This risk is most likely to occur during the Pre-construction / Construction and

Operation Phases of the Project with out-migration occurring during the Decommissioning / Closure Phase.

The predicted extent of Project induced in-migration is presented in Chapter 11. Villages such as Mako and the

Niemenike cluster have had relatively high rates of recent migration and population growth (4% per annum

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from 2004 to 2014) which is already putting some strain on local infrastructure and natural resources. Based on

experience of other projects in the region, the population of the villages of Mako and Niemenike could easily

double over the Project life. However, the expected impacts of in-migration on habitat and species are difficult

to quantify.

In-migration and natural resource exploitation of timber and non-timber products will firstly occur around

towns and villages, but may extend to resource-rich areas, such as the buffer zone and the eastern limit of the

PNNK. If unregulated, this may impact upon the habitat and flora in the broader area, including the eastern

extent of the PNNK Study Area, leading to localised habitat degradation. If increased pressure on natural

resources does occur, forests (i.e. gallery forest and woodland) and savannah habitats (i.e. woody savannah, tree

savannah and shrub savannah) are expected to be targeted for timber and fruits. Illegal logging is an ongoing

threat to habitats and species in the PNNK (UNESCO, 2007; 2014; 2015) and many species are targeted for their

commercial value including Vitellaria paradoxa and Khaya senegalensis (IUCN, 2015). Saba senegalensis fruits

are also known to be targeted by local villagers.

The impacts of livestock grazing on the OUV’s of the PNNK are a current concern to the World Heritage

Committee (UNESCO, 2007 & 2015). Impacts arising from increased agro-pastoral activities in the PNNK are

likely to be of Minor significance as migrants and Project affected villages in general are predicted to trend

towards a cash economy which would lead to a movement away from subsistence farming.

In-migration may lead to an increase in artisanal mining outside and inside the PNNK if unregulated. If this does

occur, artisanal mining will be restricted to the PNNK Study Area where there is known gold mineralisation.

Potential impacts arising from artisanal mining include loss of habitat, disturbance caused by mining-related

noise and potential contamination of water sources if chemicals are used to process the gold. The majority of

the sites in the PNNK Study Area are relatively small, however, two moderately sized artisanal sites were

recorded during baseline surveys. Hence there is the potential for some of the smaller sites to expand.

There is a risk that Project-induced in-migration during construction and operation would lead to increases in

poaching and fishing in the PNNK which is likely to be more pronounced in the PNNK Study Area. At closure, a

net out-migration from the area is expected to occur, reducing potential risks. The nature and extent of

poaching arising from Project-related in-migration is difficult to predict. However, any increase in poaching

would exacerbate the current threat to the fauna population in the PNNK. In-migration also increases the risk

that chimpanzees, traditionally excluded from hunting and the bush meat trade by the majority of Senegalese

people because of cultural taboos against eating them, may be hunted by migrants that lack the same cultural

taboos (Carter et al., 2003; Pruetz, 2013). In response to an increase in pressure on natural resources, hunters

may begin targeting fauna not previously included in their repertoire, such as chimpanzees (Pruetz, 2013).

During baseline surveys of the Gambia River, few adult fish were captured and catches were dominated by

juvenile and immature fish. Aquatic ecology specialists stated that this is an indication of over exploitation of

fish stocks, as adult fish are more sought after by fishermen. Increases in fishing activities and the continued

use of illegal fishing equipment in the Gambia River will add to these existing pressures on fish stocks.

If unregulated, natural resource collection, poaching and fishing is likely to lead to the improvement of existing

tracks and the creation of new access routes in the PNNK, particularly in the PNNK Study Area, resulting in

localised habitat loss and fragmentation and an increased presence of human activity.

Species Displacement and Dispersal

Habitat clearance within the PDA during construction will cause fauna (Guinea baboons, leopards,

chimpanzees and other legally protected species) to disperse into the surrounding area, most likely into the

PNNK. This may increase inter- and intra-specific competition for resources, including space, water and food in

the PNNK. The level of impact on the OUVs of the PNNK in the area where species disperse will be dependent

on the availability of resources to support these additional individuals and the current territories of these

dispersing species. The territories of leopards and Guinea baboon that utilise habitats in and around the PDA

may overlap with the PNNK, hence territorial conflicts are unlikely to occur as competition for resources will be

low.

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It is possible that the PNNK holds sufficient resources to support the in-migration of fauna from the PDA and

as such will not impact fauna currently inhabiting the PNNK. Alternatively, there may be insufficient resources

(i.e. late dry season water sources) and this increased dispersal will put pressure on the OUVs. It is very difficult

to predict the outcome of the displacement and dispersal, and wildlife monitoring in the PNNK Study Area

would be required to understand the changes resulting from the Project.

The loss of habitat in the PDA is expected to cause permanent displacement of the chimpanzees from this area.

Territorial conflict resulting from displacement of chimpanzees is unlikely as it is considered that the

chimpanzee habitat in the PDA / Wayako Valley connects with that in the PNNK and buffer zone. Chimpanzees

are likely to disperse into similar habitat types within the PNNK, its buffer zone and north of the PDA, where

there is suitable habitat, food and water sources. Chimpanzees are also expected to continue to use the spring

in the Wayako Valley, which is an important dry season water source.

Habitat Loss and Fragmentation / Barriers to Movement outside the PNNK

Evidence of African elephant, African lion and western giant eland (PNNK OUVs) were found in the PNNK Study

Area but not in the PDA and Project Study Area. It is likely that the presence of the settlements, National Route

7, vehicle traffic, human activity near the Gambia River, steep topography, sub-optimal habitat quality and

exploration activities in the vicinity of the proposed Project already form a barrier to movement of these

species. It is expected that the development of the Project will not change this, and as such there will be a

Negligible impact on these species.

Habitat degradation, loss and fragmentation arising from Project development are expected to create barriers

to the movement of chimpanzees (a PNNK-ranging species) in the PDA and surrounds. Chimpanzees are

selective in their habitat use and often use drainage channels and the associated gallery forest for movement

at Mako and other sites (Pruetz and Bertolani, 2009). The removal of wildlife corridors (e.g. drainage channels),

clearance of 244 ha of land (natural and modified habitat (IFC, 2012) / Critical habitat (TBC, 2015)) for Project

components and infrastructure with significant levels of disturbance, intensification and expansion of

cultivated areas and the creation of roads will create barriers to movement for chimpanzees. The Project is

predicted to restrict chimpanzee movements outside of the PNNK in areas around the PDA including, along

the Wayako Valley (north to south) and to the hills located east of the Wayako Valley. The construction of the

main access road is expected to restrict chimpanzees from accessing habitats and resources in the eastern

extent of the Wayako Velley where chimpanzees and their nests have previously been observed during the

baseline study (see Chapter 7). Chimpanzees may also potentially have to find new routes to access water

sources in the western extent of the Wayako Valley during the dry season due to habitat fragmentation in the

PDA. It is unknown how much the chimpanzees currently use and rely on habitats in these areas.

Female migration and genetic exchange between the Mako chimpanzee community and chimpanzees south

of the Gambia River may be potentially impacted by habitat fragmentation / barriers to movement. In this

instance, female migration is only likely to occur during the dry season when the Gambia River is low enough

to be crossed by chimpanzees and potential crossing points are likely to be restricted to areas away from

settlements. Further research is required to confirm the nature and extent of exchange between these

communities and the impact of the Project. Female migration and genetic exchange between the Mako

chimpanzees and communities within the PNNK are unlikely to be affected. Any impacts from habitat

fragmentation and barriers to movement are expected to be of significance to chimpanzees prior to mitigation.

Some birds, including some biome restricted birds, may perceive the activities around the PDA as a barrier to

movement, however long-ranging birds are unlikely to find ground activities as barriers to movement.

A small area of hippopotami riparian habitat will be removed for the construction of a Project road and pipeline

and a smaller area of aquatic habitat may be degraded by suspended sediments at the confluent of Badalla

Creek and the Gambia River (< 7 ha in total). This is not expected to restrict hippopotami (a PNNK ranging

species) movement within their habitat range and the expected impact to hippopotami is Negligible.

Residual impacts to hippopotami habitat will arise from habitat loss for the construction of a Project road and

pipeline (resulting in the loss of riparian habitat, tree savannah and fallow land) and degradation of aquatic

habitat (e.g. arising from suspended sediments at the confluent of Badalla Creek and the Gambia River). It was

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assumed that all hippopotami habitat is of very high habitat quality. GIS analysis was used to calculate the total

area of impacted habitat and the quality hectares was calculated.

The Project has also been specifically designed to have a compact footprint, reducing the loss and

fragmentation of habitats (refer Chapter 5).

Vehicle Collision

Increased Project-related vehicle and plant activity during all Project phases will increase the risk of accidental

mortality and injury to mammals and birds from collisions with vehicles and machinery. The areas where PNNK

fauna is most at risk of collision is the existing National Road 7 (which passes through the PNNK). Some species

that are known to range outside of the PNNK (i.e. chimpanzees) will also be at risk of vehicle activity in the PDA

and along the Main Access Road in the Wayako Valley where the majority of vehicle movement will occur (see

Chapter 10). Project traffic will be temporary and will cease post-closure.

Fauna that are known to cross the RN7 in the PNNK include African wild dogs and lions. Collisions are most

likely to occur with nocturnal species (i.e. leopards), which are less likely to be seen by drivers and may be

startled by vehicle headlights, and predators feeding on carrion on or beside roads (i.e. vultures) (Forman and

Alexander, 1998). Many species of fauna that inhabit the PNNK are either nocturnal or carrion feeders.

The National Road 7 (RN7) will be used as the primary transportation route during all Project phases for supplies

and material delivery. During operation, it is expected that approximately three trucks per day will transport

materials to the Project. The average number of daily traffic movements recorded on the RN7 during the traffic

survey (Volume A, Appendix D) was 220 (all vehicle types), however since the opening of a customs checkpoint

on the eastern Senegal border (Kidira) daily movements are estimated to be approximately 300. Therefore

Project-related transportation will not significantly add to this traffic load and the risk of Project related vehicle

collisions will be low.

The company is already implementing a variety of measures to minimise the likelihood of any wildlife collisions

associated with vehicle use for Project exploration activities, for example driver safety awareness training,

speed limits and restricting driving at night or in low-light conditions (e.g. dusk). Expected impacts to PNNK

OUVs from vehicle collision are predicted to be of minor significance, prior to mitigation.

Hydrology and Water Quality

Any reduction in the availability of suitable drinking water sources during the dry season would be likely to

have an adverse impact on the Mako chimpanzee community, resulting in increased competition for water

resources and potentially affecting the health of chimpanzees. Therefore, the Project has been designed to

avoid direct impacts (i.e. clearance) to the springs in the Wayako Valley, which are known to be an important

dry season water sources for chimpanzees and other fauna. Furthermore, these springs are not expected to be

impacted by downstream water quality and hydrology impacts generated from suspended sediments and

reduced flow rates.

The main Project impact to surface water is expected to arise from suspended sediments notably that

generated from construction activities (e.g. land clearing, road construction). It is anticipated that suspended

sediments will mainly impact ephemeral creeks in the Project Study Area and outside of the PNNK. However,

an increase in suspended sediments in the Kelendourou Creek could also impact downstream aquatic habitats

in the PNNK buffer zone. It is however unlikely for suspended sediments to reach the PNNK. Impacts on

downstream habitats and fauna in the PNNK buffer zone arising from suspended sediments are expected to

be minor prior to mitigation.

Three small Kelendourou Creek tributaries will be affected by small catchment area losses to the Mine Pit during

operation (and post-closure). There is predicted to be a Negligible change in the natural flow which will not

affect downstream habitats and species in the PNNK and buffer zone (see chapter 9: Physical Impacts).

The Project is not expected to have significant adverse impacts on the flow rates, water quality or the aquatic

biodiversity of the Gambia River (see Chapter 9: Physical impacts). The Mako Gold Project will abstract water

each year from the Gambia River during the rainy season months for storage in the Water Storage Dam (and

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utilisation as process water, dust suppression, and as a camp supply). During a relatively dry year, total flow in

the Gambia is approximately 1,760,000 ML and approximately 2,888,000 ML during the median year. The total

annual supply of mine water proposed during a dry year represents 0.04% of the Gambia River annual flow and

0.03% of the annual Gambia River flow during the median year.

There will be a maximum abstraction rate of 3% from the Gambia River flow, and no abstraction when the

instantaneous river discharge is less than 5 m3/s, in order to protect environmental flow, the water requirements

of downstream users and aquatic biodiversity. This would mean that pumping would be able to be conducted

once river flows have been established in the beginning of the wet season. Impacts to aquatic habitats and

species downstream of the PDA in the PNNK are expected to be of Negligible significance.

Project-related artificial water sources (i.e. TMF surface water, water storage dam) can be attractive to some

wildlife, particularly during the dry season when water is scarce. During operation, there will be a risk of adverse

health impacts (i.e. poisoning) and mortality to wildlife arising from the ingestion of contaminated water

contained within Project facilities. In particular, the TMF surface water may have elevated concentrations of

cyanide, salinity, metals and nutrients (breakdown products of cyanide); see ESIA Report Chapter 9: Physical

impacts. During operation, water will be fully contained within the TMF and there will be no surface discharge

from site. Cyanide destruction, via the INCO (SO2 + air) process, will also be implemented to ensure weak acid

dissociable (WAD) cyanide concentrations are below 50 mg/L in the TMF in accordance with the International

Cyanide Code.

Most wildlife will avoid the TMF due to the disturbance levels in the PDA (i.e. noise, artificial lighting, human

activity) and the fact that the site will be difficult to access. Chimpanzees are unlikely to drink contaminated

water from the TMF or other facilities as they are selective of the quality of water they drink (Galat et al., 2008).

Of the species from within the PNNK, birds (including PNNK biome-restricted birds and vultures) are most at

risk from coming into contact with polluted water sources. Carrion feeders such as vultures may also be at risk

from the consumption of carcasses of birds or other animals that have been poisoned by drinking

contaminated water. The Company is committed to minimising and monitoring the interaction between

wildlife and the TMF, which is expected to largely mitigate this risk.

There is a risk of surface and ground water contamination through accidental spills or seepages of diesel fuel,

hazardous compounds (i.e. cyanide, solvents, metalliferous drainage) and non-hazardous waste during

operation which would be detrimental to the health of large mammals and birds if ingested. This will be

controlled through risk management and emergency response strategies outlined in the Project Risk

Assessment.

Invasive Species Encroachment

The invasive species Mimosa pigra is present along the banks of the Gambia River, tributaries and ponds inside

and outside of the PNNK. This species is an aggressive competitor that is capable of progressively dominating

areas of natural habitat and its spread is being actively controlled and monitored in the PNNK (UNESCO, 2015).

The risk that Project vehicles and personnel may transfer M. pigra seeds from affected areas along the Gambia

River into the PNNK is considered low as the Project and transport corridors are located outside of the PNNK.

Noise, Vibration and Airblast

The primary noise impacts of the Project are expected to occur during operation, where blasting, mining and

processing activities will affect the local ambient acoustic environment. Based on conservative noise modelling

for the Project, relevant international (WB/IFC EHS Guidelines – Noise Management 2007) and national

standard (Senegal Noise Pollution Standards Article R84 of Decree 2001-282) criteria for noise will be exceeded

within the immediate vicinity of the mine and processing plant.

The primary impacts of blasting will be excess noise, airblast, and ground vibration. Under normal operating

conditions, blasting will not occur more than once a day and will typically occur in the late afternoon. Noise

levels are not expected to exceed IFC night-time criteria in villages and sensitive receptor areas. However, noise

is expected to have impacts on wildlife in the vicinity of the mine including the PNNK buffer zone.

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Ground vibrations from mine blasting are predicted to exceed adopted human comfort level criterion (0.56

mm/s) within 500 m of the blast site (see Chapter 9). Vibrations generated from process equipment and

periodic blasting are not expected to impact the PNNK.

Generally large mammals and birds are wary of unfamiliar and/or loud noise and vibration, particularly if it is

associated with anthropogenic disturbance, and are likely to respond with a flight reaction. Mammals and birds

can also experience stress, reduced biological fitness and decreased breeding success (Francis and Barber,

2013). Chronic stress can make species more susceptible to diseases, pathogens and parasites (Dhabhar, 2002,

Sapolsky et al., 2000). Some species may be able to habituate to consistent noise and vibration levels, however

it is unlikely that fauna will habituate to blasting. It is likely that most fauna will disperse away from the source

and thus avoid the ongoing effects.

Airblasts from mine blasting are predicted to be below human discomfort levels level in the eastern periphery

of the PNNK. Airblasts at this level can startle wildlife (Bowles, 1995) and it is likely that wild animals would be

more sensitive to airblasts than humans, and likely to move away. Airblast may be perceptible in Chimpanzee

nesting habitat in the PNNK (4.3 km north-west from Mine Pit; see ESIA Report Chapter 7: Figure 7-5) and as

such may cause disturbance and displacement to chimpanzees and other species in this area.

Most noise, vibration and airblast impacts are likely to be attenuated over the life of the mine, particularly as

the mine pit deepens. Thus, any effect on wildlife from noise and vibration from the Project will reduce over the

course of the mine life. Noise and vibration impacts from the Project will also cease completely post-closure.

Artificial Lighting

It is anticipated that the Project will be in operation on a 24 hour basis, with the main components illuminated

for safety. Skyglow occurring above Project components from poorly shielded lighting, scattered by low clouds

or ambient dust can potentially increase apparent lighting impact by as much as 40%. Direct views to night

lighting associated with the Project would be visible to nearby villages and potentially to vehicles travelling on

National Route 7 (as predicted by GIS viewshed analyses) resulting in disturbance to wildlife in the vicinity of

the PDA. Artificial lighting in the PDA will be visible from within the PNNK and may potentially cause

disturbance to wildlife in the eastern periphery of the PNNK and buffer zone (see Chapter 9) if unmitigated.

Light-spill is known to cause disturbance to crepuscular (fauna that are active primarily during dawn and dusk)

and nocturnal species (i.e. some large mammals, bats and birds) and can cause a range of behavioural changes

and affect the circadian rhythms and cycles of activity of nocturnal, crepuscular and diurnal species, disruption

of seasonal acclimatisation, disrupts predator-prey relationships, increase prey intake and alter reproduction

behaviour (Gaston et al., 2013; Longcore and Rich, 2004). Many species use lightscapes (e.g. moonlight) as cues

for movement around their environment and altering these lightscapes by light pollution may disrupt these

movements by disorienting the animal (Gaston et al., 2013). This can potentially result in physiological stress

and thereby reducing biological fitness. It is unlikely that crepuscular and nocturnal species (i.e. lions, African

wild dogs, African elephants, hippopotami) in the eastern periphery of the PNNK would remain near light-spill.

Impacts to mammals and birds in the eastern periphery of the PNNK from artificial lighting are expected to be

of Moderate significance prior to mitigation.

Air Quality

Fugitive dust emissions (e.g. PM10 and PM2.5) and combustion emissions air pollutants (i.e. CO, SO2, NOx,

particulate matter and VOCs) will be generated during the Pre-Construction / Construction Phase (see chapter

9) which will be short term, localised and staged over a moderately short period of time (approximately 20

months). Localised air quality impacts are expected to occur within approximately 1 km of the construction

areas and 200 m of unsealed roads (depending on weather conditions) and are not expected to impact priority

fauna and their habitats in the PNNK. Concentrations of particulates within 1 km of Project sources are

predicted to exceed international health criteria, if unmitigated. Dust deposition drop-out may also impact

chimpanzee habitats in the PDA, in areas near the source site and adjacent to the Main Access Road in the dry

season.

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The primary Project air emission that may affect fauna during the Operation Phase is dust. Based on

conservative modelling for dust emissions generated by Project activities, international (WHO Air Quality

Guidelines 2005) criteria for air quality may be exceeded in the PDA close to the sources. In the absence of

mitigation, impacts to fauna from emissions are expected to be of Moderate significance. There is also the

potential for minor dust impacts on receptors to occur within approximately 5 km of the PDA during the dry

season. These impacts will primarily relate to fugitive dust emissions from drilling and blasting within the Mine

Pit, as well as excavating, earthmoving and processing (crushers) etc. Combustion emissions from diesel vehicle

exhausts, machinery and generators as well as the operation of the Diesel Power Plant may also contribute to

Minor impacts. It is unlikely that ecologically significant levels of dust or emissions from the Project will reach

the PNNK.

12.3 Avoidance, Mitigation and Management

To ensure that Project impacts do not contribute to the decline of Outstanding Universal Values (OUVs) in the

PNNK, the Company is employing the mitigation hierarchy to avoid, mitigate, manage, restore and offset

impacts on biodiversity for its activities outside of the PNNK. An Environmental and Social Management and Monitoring Plan (ESMMP; Volume C) and a Biodiversity Action Plan (BAP; Volume C) have been prepared

providing detailed plans and procedures for the protection and management of biodiversity for the Project. A

summary of the specific measures to avoid, minimise and manage any potential risk to the OUVs of the PNNK

are outlined below for each stage of the Project.

12.3.1 Avoidance

The Project lies entirely outside of the PNNK and its buffer zone. The Project Study Area is located close to the

PNNK, 1 km east of the PNNK at its closest point. No Project-related habitat clearance will be undertaken in the

PNNK or the buffer zone.

The Project Footprint has been reduced in size since first inception, and has thus avoided impacts on a much

greater area of chimpanzee and other species’ habitat. This has avoided impacting some drainage channels

that are used by chimpanzees for commuting and foraging. Furthermore, the main access road has been re-

routed to the south to avoid impacting an important dry season water source for chimpanzees, leopards,

Guinea baboons and other fauna, located west of the Wayako Valley outside of the PNNK. These springs are not

expected to be impacted by downstream water quality and hydrology impacts generated from suspended

sediments and reduced flow rates. Chimpanzees and other fauna are expected to continue to use these springs

and habitats throughout the lifespan of the Project.

Pre-clearance checks will be undertaken to avoid impacting baobab trees that are important food and nesting

resource for chimpanzees where possible.

Primary sources of potentially mine contaminated water (e.g. waste management facilities, Process Plant, TMF,

hazardous chemicals and fuel storage areas) have been sited within a single catchment away from major

drainage lines with primary and secondary containment facilities in place to prevent potential discharge into

the receiving environment. The TMF has been designed to avoid discharge to receiving waters during Project

operation and employs cyanide destruction, via the INCO (SO2 + air) process (see Chapter 9).

High noise emission equipment and infrastructure are located as far as practicable from potential sensitive

receptors.

12.3.2 Minimisation

An ESMMP (Volume C) and BAP (Volume C) have been prepared providing detailed plans and procedures for

the protection and management of biodiversity for the Project. A summary of the measures to avoid, mitigate

and manage high-risk potential impacts on priority habitats and species in the PNNK and buffer zone is

outlined below:

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Pre-Construction / Construction

Control measures will be implemented to minimise adverse impacts on habitats in the PNNK and buffer zone.

The company will consult with local authorities to minimise the impacts of Project-induced in-migration on

natural resource exploitation (including the collection of timber, non-timber products and hunting). The

Company will also collaborate with PNNK area managers to ensure indirect impacts to the PNNK are adequately

mitigated. Livelihood restoration mitigation measures will also be implemented to incentivise land use change

in the PNNK where this is likely to avert habitat loss and degradation of the OUVs of the PNNK. If successful,

these incentives should reduce pressure on the PNNK and minimise habitat destruction and degradation.

Access to the PNNK and buffer zone by Project staff and contractors is restricted and subject to the prior

approval of the DPN (Direction of National Parks). Project staff and contractors are banned from entering the

PNNK and buffer zone to collect timber and non-timber products, hunt and fish. Project staff and contractors

are banned from hunting, buying or trading wildlife to minimise impacts to fauna populations. Environmental

education and awareness programmes will be conducted for Project staff and contractors (e.g. through staff

inductions). This will emphasise the importance of the PNNK and prohibitions / penalties of natural resource

use in the PNNK.

The displacement of PNNK ranging species from the PDA will be minimised by ensuring a ‘minimal-impact

footprint’ for the Project in which habitat clearance will be restricted to only the land required for the

construction of Project components and the associated infrastructure.

Project staff and contractors will be banned from initiating close contact with chimpanzees and other wildlife,

as humans can act as a vector for the transmission of diseases to chimpanzees. Adherence to hygiene principles

and proper waste management will also reduce the risk of disease transmission to chimpanzees.

The invasive species prevention protocol will minimise the risk of transferring invasive species (i.e. Mimosa

pigra) from infected areas along the Gambia River. This will include wash-down procedures of Project vehicles

moving from the Gambia River and other know affected areas. Project vehicles, staff and contractors will be

banned from entering the PNNK and buffer zone without permission.

Disturbance to fauna from increased noise and vibration will be minimised by restricting the use of particular

machinery and vehicles at dusk, dawn and during the night. Natural sound barriers (i.e. trees and earth mounds)

will be retained, where possible, to attenuate noise and vibration. Staff and contractors will adhere to SOP05:

Noise and Vibration Management throughout the lifespan of the Project

Disturbance to fauna from noise, vibration and airblast from blasting in quarries near the RN7 will be minimised

by continual improvement of mine blast-associated noise and airblast management measures during the

Operation Phase and through adherence to SOP08: Blasting Management.

Impacts to fauna caused by disturbance from artificial lighting will be minimised through the use of capped

and directional lighting. Artificial lighting will be directed away from sensitive areas including the PNNK buffer

zone.

Sediment control dams will be used to minimise the impacts from suspended sediments on downstream

aquatic habitats in the PNNK. Vegetation on steep slopes and riparian corridors will be preserved where

possible to minimise erosion. Surface water management infrastructure (e.g. cut-off / diversion drains, velocity

dissipation devices, culverts) will be installed in appropriate locations to minimise and control surface water

flow over disturbed areas.

Adverse impact to habitats and flora arising from fugitive dust and diesel combustion will be minimised

through adherence to SOP04: Emission and Dust Control. This includes using water to reduce dust levels in areas

of biodiversity sensitivity (i.e. near the PNNK buffer zone), particularly during the dry season, stabilising

landforms and implementing erosion prevention measures.

Operation

In addition to the proposed management and mitigation measures for Pre-Construction / Construction Phase

above, the following measures will be adopted:

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Blasting in the Petowal mine pit will adhere to SOP08: Blasting Management and will only be undertaken during

daylight hours typically in late afternoon (when levels will not exceed IFC night-time criteria) to minimise

disturbance to fauna, particularly chimpanzees. It is anticipated that the on-going excavation of the pit will

provide additional noise shielding from blasting throughout the Project operation as the elevation of the

western pit wall will be maintained above the eastern extent of the pit. Continual improvement of mine blast-

associated noise and airblast management measures during the Operation Phase will also minimise impacts to

fauna.

Fencing will be installed around the site perimeter of the TMF to restrict fauna, including some PNNK ranging

species, from accessing these areas and ingesting TMF surface water. If necessary, a variety of bird scaring

techniques will be tested to assess their effectiveness in deterring birds from the TMF. Any incidents involving

wildlife, including PNNK ranging species, will be reported and monitored and mitigation measures will be

reviewed and adapted where appropriate.

The TMF is designed to contain a 1 in 100 year 72 hour storm event and a 1 in 100 year 12 month wet rainfall

sequence, with an additional 1 m contingency freeboard (Knight Piesold, 2015d). Strict control of freeboard

within the TMF will avoid and minimise requirements for downstream release. Cyanide destruction shall be

employed, via the INCO (SO2 + air). Shallow and deep groundwater monitoring bores will be installed

downgradient of the TMF to detect seepage water quality and quantity (see Chapter 9).

12.3.3 Rehabilitation / Decommissioning / Closure

During Decommissioning / Closure mitigation measures will be implemented as per the Rehabilitation and Conceptual Mine Closure Plan (Volume E). Rehabilitation and closure will aim to re-establish an ecosystem

that functions in a similar manner (or better) than that which existed before mining related disturbance.

Revegetation efforts will utilise native species of local provenance to establish self-sustaining tree savannah,

wooded savannah, or shrub savannah vegetative communities where feasible. This will be favourable for

chimpanzees and other fauna. Species selection will include flora known to provide nesting or forage value for

chimpanzees and riparian corridors will be planted to provide cover for migration to the extent that is feasible.

Rare, threatened and indigenous species including restricted-range species, in addition to protected

vegetation and species of cultural significance will be incorporated into planting programmes. Weed-free seed

sources will be procured to the extent that is possible. This will minimise the extent of habitat fragmentation

and allow PNNK ranging species to return to use habitats in the PDA following closure.

12.4 Residual Impact Assessment and Offsets

12.4.1 Residual Impact Assessment

Notably, there will be no direct impact of the Project on habitats within the PNNK and buffer zone from habitat

clearance, as none of the Project components are located within these areas. Given the successful

implementation of the proposed mitigation and management measures, the residual impacts for the PNNK

Outstanding Universal Values (OUVs) are summarised in Table 12-2 and discussed below in more detail:

In-migration and natural resource collection and agro-pastoral activities – It is difficult to quantify

the residual impacts arising from Project-induced in-migration, however, impacts to habitats and species

from increased natural resource collection and agro-pastoral activities in the PNNK are expected to be

of Minor significance. The Company will collaborate with PNNK area managers to ensure indirect residual

impacts to the PNNK are adequately mitigated through offsetting. Activities proposed as part of the

offset strategy (see below) will incentivise land use change to reduce pressure on natural resources in

the PNNK Study Area.

In-migration, poaching and fishing – The nature and extent of poaching arising from Project-related

in-migration are difficult to predict. There is a risk of impact to species from poaching and fishing,

however these are expected to be of Minor significance. The Company will collaborate with PNNK area

managers to ensure indirect residual impacts to the PNNK are adequately mitigated through offsetting.

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Residual impacts to priority species and their habitats from in-migration will be addressed in the offset

strategy which is expected to include a combination of restoration and averted loss offsets including

strengthening enforcement in the PNNK, community awareness and education. The offset strategy will

also take a collaborative approach to enhance the biodiversity value of degraded habitats through

habitat restoration and enhancement.

Species displacement and dispersal – Most of the threatened species present within the PNNK appear

to mostly stay within PNNK boundaries and therefore their habitat use will not be affected by the Project.

However, habitat loss, fragmentation and degradation, and the cumulative disturbance caused by the

Project (i.e. noise, vibration etc.) within the PDA are expected to cause displacement of chimpanzees (a

species that is known to range inside and out of the PNNK). Due to the length of time that the mine will

be operating and the level of disturbance caused by its operation, chimpanzees are considered unlikely

to return and use the habitat in the PDA as they did before the Project. Residual impacts to chimpanzees

from habitat loss, fragmentation and degradation are expected to be of Moderate significance.

Habitat loss, fragmentation and barriers to movement for PNNK ranging species – Most threatened

species in the PNNK appear to be present within the PNNK boundaries and therefore their movement

patterns will not be affected by the Project. Habitat loss and fragmentation is expected to act as a barrier

to the movement of chimpanzees. The degradation and fragmentation of fauna habitats will be partially

counterbalanced by restoration and rehabilitation activities as per the RCMCP (Volume E), however

habitat will not be completely restored at closure. Rehabilitation of the TMF at decommissioning,

including treatment of the TMF supernatant pond at decommissioning, is expected to reduce the

residual impacts, however, some areas will not be rehabilitated to the same value as before Project

development (e.g. pit and TMF). Monitoring of surface and groundwater post-closure will be

implemented to determine whether additional measures are required to avoid post-closure impacts to

water quality. Many species are expected to return and use the revegetated areas within the Project

Footprint post-closure including leopards, Guinea baboons and other legally protected species.

However, chimpanzees are considered unlikely to return and use the habitat in the PDA as they did

before the Project. Residual impacts to chimpanzees are expected to be of Moderate significance.

Vehicle collisions – With the implementation of the proposed management and mitigation measures,

there should be Minor impact on the OUVs and other biodiversity values of the PNNK from vehicle

collisions with animals.

Invasive species encroachment –There should be no residual adverse impact of the Project on the

PNNK due to spreading of M. pigra. The risk of introduction of other introduced species will be Negligible.

Hydrology and water quality – There is expected to be no residual impacts to aquatic and terrestrial

biodiversity following implementation of mitigation and management measures.

Noise and vibration – The proposed mitigation and management program for noise and vibration will

greatly reduce the potential for noise, vibration and airblast impacts on the wildlife of the PNNK, but it

will be impossible to mitigate all impacts. In particular, there will still be some noise and vibration from

blasting reaching the eastern periphery of the PNNK which may cause some disturbance to priority

species including African elephant, western giant eland, African lion, chimpanzee and potential African

wild dog (if present). Residual impacts are expected to be of Minor significance to OUVs.

Artificial lighting - There is expected to be a Minor residual impact to PNNK ranging fauna due to light

spill from the Project areas during operation.

Table 12-2 Summary of key expected pre-mitigation impacts, mitigation measures and residual impacts to PNNK

OUV’s for each Project phase

Receptor / Value:

OUVs

Expected Pre-

Mitigation Impact

Significance

Key Management & Mitigation

Measures

Key Expected Residual

Impacts and Overall Impact

Significance

Pre-Construction / Construction

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Receptor / Value:

OUVs

Expected Pre-

Mitigation Impact

Significance

Key Management & Mitigation

Measures

Key Expected Residual

Impacts and Overall Impact

Significance

Priority terrestrial habitat MINOR

Livelihood restoration mitigation measures

Project staff and contractors banned from accessing PNNK

Project staff banned from collecting timber and non-timber products.

Adherence to the invasive species prevention protocol

NEGLIGIBLE

No terrestrial habitat

clearance from the PNNK

or buffer zone

Possibly some risk of

increased natural resource

collection in eastern

periphery of PNNK

Priority aquatic habitat MINOR

Suspended sediment and erosion controls

Adherence to SOP07: Hazardous Materials Management and SOP02: Water Quality and Pollution Management

NEGLIGIBLE

No aquatic habitat

clearance in the PNNK

Possibly some risk of

impacts from increased

artisanal mining

Priority threatened

terrestrial fauna

MODERATE

Project staff and contractors banned from hunting, buying or trading wildlife and entering PNNK and buffer zone

Prohibited driving at night outside of the PDA, unless permission has been sought or in the event of an emergency.

Adherence to SOP07: Hazardous Materials Management and SOP02: Water Quality and Pollution Management

Driver training and adherence to the Highway Code

Avoidance of using artificial lighting

Capped / directional lighting

Adherence to SOP05: Noise and Vibration Management

Avoid using noisy machinery and vehicles at dusk, dawn and at night

Retention of natural sound barriers (trees / mounds)

MODERATE

Possibly some risk of increased poaching in the in eastern periphery of PNNK

loss of chimpanzee habitat outside of the PNNK (Note: these chimpanzees range inside and out of the PNNK)

Increased risk of poaching

Priority threatened

aquatic fauna

MINOR

Suspended sediment and erosion controls

Adherence to SOP07: Hazardous Materials Management and SOP02: Water Quality and Pollution Management

NEGLIGIBLE

Possibly some risk of increased fishing in the Gambia River

Operation

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Receptor / Value:

OUVs

Expected Pre-

Mitigation Impact

Significance

Key Management & Mitigation

Measures

Key Expected Residual

Impacts and Overall Impact

Significance

Priority terrestrial habitat MINOR

As per Construction Phase, plus:

Habitat Restoration

NEGLIGIBLE

Possibly some risk of increased natural resource collection in eastern periphery of PNNK

Priority aquatic habitat MINOR

As per Construction Phase, plus:

Abstraction of Gambia River during wet season

Habitat Restoration

NEGLIGIBLE

Priority threatened

terrestrial fauna

MINOR

As per Construction Phase, plus:

Adherence to SOP08: Blasting Management

Blasting in afternoons only.

Fencing and monitoring the TMF

MODERATE

Most chimpanzee habitat loss, degradation and fragmentation impacts outside the PNNK will remain in Operation

Risk of disturbance to fauna (i.e. chimpanzee) from blasting

Risk of disturbance from blasting

Priority threatened

aquatic fauna MINOR

As per Construction Phase, plus:

Abstraction from the Gambia will occur during high flow months

NEGLIGIBLE

Decommissioning / Closure

Priority terrestrial habitat MINOR

As per Construction Phase

NO IMPACT

Priority aquatic habitat MINOR

As per Construction Phase NO IMPACT

Priority threatened

terrestrial fauna MINOR

As per Construction Phase, plus:

Restoration activities in the

PDA conducted in

accordance with the

Rehabilitation and

Conceptual Mine Closure

Plan

Routine checks for

compliance

NEGLIGIBLE

Habitat restoration in the PDA will reduce overall residual impacts to chimpanzee habitat Post-Closure

Some areas of permanent habitat loss will remain (e.g. pit and TMF)

Priority threatened

aquatic fauna

MINOR

As per Construction Phase, plus:

Restoration activities in the

PDA conducted in

accordance with

Rehabilitation and

Conceptual Mine Closure

Plan

Routine checks for

compliance

NEGLIGIBLE

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12.4.2 Offset Strategy

The Company is developing an offset strategy with the aim of achieving no net loss on biodiversity, and

preferably a net gain. This strategy is summarised in the Biodiversity Action Plan (Volume C). The Project has

aligned with best practice and employed the mitigation hierarchy to avoid, minimise and restore adverse

impacts to biodiversity. The Company is also committed to developing and implementing a comprehensive

biodiversity offsets programme that adequately compensates for residual impacts (e.g. from indirect habitat

degradation from in-migration).

The Company is developing an offset strategy for the residual impacts to chimpanzee habitat. The offset

strategy will make a significant contribution to the conservation of the remaining habitat for the Mako

chimpanzee community, including areas of this habitat both in and outside the PNNK. Chimpanzees use

multiple habitat types and their range overlaps the ranges of other priority species. This approach will therefore

also benefit other priority species of fauna that share the habitat range of the Mako chimpanzee community in

the PNNK. This may include African lion, Western giant eland, African elephant, African wild dog (if present) and

other fauna.

A number of candidate offsets sites have been identified and provisionally assessed for technical feasibility i.e.

being potentially able to achieve the gains required to offset the residual impacts (losses). The five candidate

offset sites include areas inside and outside of the PNNK, and suggested offset actions will include a range of

activities such as restoration of degraded habitats, enhancement of species migration corridors, law

enforcement against poaching and illegal mining within the PNNK, and community programmes to incentivise

land use change. Indicators will be identified to demonstrate and monitor quantifiable biodiversity gains

achieved through offsetting. Where possible, offsetting will align with regional, national and international

strategies and management plans for biodiversity conservation including government lead approaches to

conservation.

At this point, losses from direct impacts have been quantified. However indirect impacts are more complex, and

are more difficult to quantify. Therefore, indirect impacts to PNNK have not yet been quantified. Stakeholder

input, along with additional baseline information is needed for these calculations. The Company is committed

to calculating indirect impacts in the next steps of the offset strategy, so that appropriate offsets are developed,

and no net loss is achieved (see BAP).

Supporting conservation actions to be conducted alongside the biodiversity offset program will include:

Support conservation actions in the PNNK in partnership with the DPN;

Supporting landscape scale ecological research;

Data and information sharing regarding the species and habitat ecology in the PNNK, buffer zone and

surrounding landscape;

Contribution to the development of biodiversity management plans through sharing data, technical

knowledge, skills and partnership alliance;

Investment in a number of community programmes which will also achieve biodiversity gains; and

A seed collection and propagation programme will be established with the aim of contribution to the

global conservation of rare and threatened flora.

The Company is developing the governance structure for the offset programme and will collaborate with

technical partners (probably a multi-stakeholder agency) to monitor compliance, assess performance against

the management plan and evaluate biodiversity gains achieved through offsetting.

The Company has committed to conducting a transparent stakeholder consultation and engagement process

with regards to biodiversity management and the development of the offset strategy. In particular, biodiversity

experts with knowledge of World Heritage and protected areas from the Biodiversity Group of Independent

Experts have been consulted throughout this process. The opinions and suggestions of stakeholders obtained

through the stakeholder engagement process have been, and will continue to be, considered in the design of

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the Project, biodiversity management and offsetting. Ongoing consultation activities are outlined in the BAP

and Stakeholder Engagement Plan (refer Volume C).

12.5 Monitoring and Evaluation

Monitoring and Evaluation Programme

The Mako Gold Project will implement a monitoring and evaluation programme to assess the effectiveness of

mitigation measures and to inform the requirement for adaptive management. The success of the offset

program will also be validated through a programme of monitoring conservation gains. A detailed description

is presented in the BAP and the ESMMP. A few of the key approaches that will be undertaken inside the PNNK

and buffer zone are listed as follows:

Remote sensing: A structured camera trapping monitoring programme will be developed, which will entail

the establishment of key monitoring sites and a schedule for the rotation of camera traps inside the PNNK,

buffer zone and around the PDA. Camera trapping will primarily be used to monitor any changes in priority

species habitat and resource use, particularly chimpanzees. However the camera trapping programme will also

capture information on other species of fauna including African lion, elephant, western giant eland and

important prey species for carnivores and omnivores. The camera trapping will further the existing knowledge

regarding species’ ecology, population dynamics and numbers of individuals. Monitoring may also provide

information on human activity within the PNNK and buffer zone.

Target chimpanzee survey: Walkover chimpanzee surveys will be undertaken every two years during the wet

and dry seasons. Repeat census will target sensitive areas and sites of main habitat usage in the PNNK and

buffer zone. Surveyors will search for direct evidence of chimpanzees (i.e. sightings and calls) and indirect

evidence of chimpanzee activity (arboreal nests, faeces, prints, feeding remains) either side of predetermined

transect routes.

Targeted hippopotami survey: Surveys will be undertaken twice a year during the wet and dry seasons.

Sample points will include the PNNK and buffer zone.

Water quality: An aquatic monitoring programme will be established to measure any changes to the baseline

parameters and overall health of the Gambia, including continuation of water quality monitoring at sampling

sites; monitoring appropriate site specific bio-indicators (i.e. freshwater macro-invertebrate diversity and

abundance); and an assessment of fish diversity and abundance including continued search for Barbus

dialonensis.

Threat related measures will also be used for monitoring offsetting (e.g. land use changes, enforcement,

enhancement and revegetation etc.). Stakeholder consultation and ground-truthing will be required to confirm

the suitability of these indicators.

The Company will commission an independent review of the offset programme to evaluate offsetting. A panel

of independent experts established by the Company, and comprising Senegalese specialists in aquatic and

terrestrial ecology, will review and monitor performance of the Company’s Biodiversity Action Plan.