Environmental Assessment
Volume A-6
Introduction
Consultation
However, it was suggested that all these off-site mitigations are directly linked to
the success of mitigation of direct project impacts on biodiversity. For example,
buffer zone management is required to help assure the viability of the on-site
azonal protection areas and assist with on-site reclamation. Likewise the off-site
azonal conservation area is required as a back-up to ensure successful
conservation of rare azonal habitat and associated species. The group challenged
the project proponent to also support biodiversity off-sets, not related to project
impacts, to a value of at least three times the amount of biodiversity being lost as
residual impacts from the project. It was noted that QMM had perhaps set a bar
with such a level of net biodiversity enhancement for their project.
6.5.3
Torotorofotsy
The same attendees referred to above, plus additional representatives from social
NGOs, took part in a meeting in Antananarivo on September 23, 2005, to consult
on the efficacy of proposed mitigation with respect to the Torotorfotsy Wetlands.
Minutes are provided in Volume H, Appendix 5. This meeting was a follow-up
from a similar one in March 2005, where project details were disclosed and
issues discussed. The consultation emphasized two main areas in need of
additional attention:
•
The first main area was the issue of predicted sediment loadings in
water to flow into the Torotorofotsy during construction and operations.
There should be a good analysis of alternatives in the EA, showing the
advantages of a 1-in-10 year storm design for the water reservoirs.
There is a need to complete additional work on predicted TSS loads in
extreme storm events greater than 1-in-10 years, plus additional baseline
recording of current TSS during cyclones. After that work is done, there
should be a re-analysis of alternatives for reservoir sizing, to see if the
1-in-10 year design is still most advantageous when all engineering,
risk, cost, social and environmental factors are compared. If, as is likely,
this could not be finished in time to go in the EA, it should be
undertaken and reviewed before construction.
•
The Ambatovy Project and its surrounding forest buffer zone
management area overlaps with several regional planning initiatives,
such as the Ramsar site, regional land use planning (Gelose) and
regional water management and irrigation initiatives. The project
proponents need to be well linked and integrated with such initiatives,
especially as regards regional water management for both ecological and
social requirements. The project proponents should be linking at the
community level in this regard, as well as at the management level.
Ambatovy Project
47
January 2006
