Recomendations On The Ramu Nickel Project

In broad policy terms, the projected economic benefits by the Ramu Nickel Mine Project of K200 million over twenty years must be weighed against the " integral human development needs of the people of Madang, the Biodiversity Conventions of which PNG has signed, the State of Biodiversity of Madang’s Terrestrial Ecosystems and Marine Ecosystems, the Dynamics of the Vitiaz Basin from which upwellings along the Madang coast is critical for the productivity of the Bismarck Sea and hence the fisheries resources of the receiving water-body into which mine tailings will be dumped and the clear misuse of streams of economic benefits from the mining sector that has paralyzed Papua New Guinea into a vicious circle of continuing national debt with no tangible benefits to show for mining the non-renewable resources of Papua New Guinea.

1. Firstly, with a mine life of twenty years, one expects that K200 million is achievable by the Ramu Nickel Project (RNP). The K20 million annually will be reality if international market prices remain as predicted. This amount when paid out, will be dissipated to every land-owner group, local contractor, the Provincial Government and individual companies but tangible benefits will be hard to find because of a lack of current disposable incomes. Currently disposable incomes in most of the mine and refinery land-owning groups is probably nil. If RNP does make the money and injects say K1000,000 to a clan group every quarter as part of the package deal for the group, a number of things happen. At that level, the money according to custom will again be shared with clan members if the clan leader is honest. If so, then within days, because of lack of current income, the money is used up on immediate needs and not re-invested into another economic activity. Once the money is gone, because of lack of re-investment, the clan will again wait for the next hand-out. Historical evidence from other mining projects, land-owning forestry projects, large plantation estates show that because disposable incomes at subsistence levels are so low, such large amounts of money create many immediate social problems amongst clan groups, families and other people. Alcoholism and prostitution runs high with such large developments as well as the typical hand-out mentality that has become entrenched in most local people where they sit around and do nothing but wait for the company to give out payments. Once the economic engine which is the Ramu Nickel mine shuts down, the land has been damaged, the fish are gone from the streams, the people have grown lazy and do nothing. This is totally against the Constitutional rights of Papua New Guineans for integral human development. Integral human development means that we (in government) in the "know" make decisions or plan out projects that our subsistence people can cope with and we in turn assist our own people to do it themselves and make the money and sustain their own activities rather than opt for large industrial projects like mining which generate large amounts of money, large amounts of human greed, large amounts of environmental damage and large amounts of social problems to trap our own people.

There are alternate forms of development that our people can do and sustain within their own capacity. While another mine might seem as the large boost of income a struggling village needs, indeed it will generate short-term cash-flow, in the longer term, the people in Papua New Guinea at the subsistence level still have to face reality and work at activities that they can sustain at their level. The history of the Panguna Mine (North Solomon’s Province), the Misima Gold Mine (Milne Bay Province), the OK Tedi Mine and all the other mines still leave Papua New Guinea worse off and not better. The Panguna Mine crippled PNG for ten years economically and as a people coping with large mines. The Ok Tedi Mine has had million kina lawsuits, while 200 kilometers of the Fly River lies dead, while the people downstream look for water and fish. Once mining stops, the money stops. Misima Gold Mine is about to close in less than 18 months; Milne Bay Province is still the same, the people rely on natural renewable resources for survival. The point is that mining has not achieved sustained economies nor improves social structures in PNG. It has broken down families and leaves crippling economic situations at all levels of PNG society. There are other developmental projects suitable to PNG conditions and mining is not one of them because it is environmentally destructive and our people have always been sustained at the local level by the continuing existence of a functional environment, not large industrial projects.

2. Madang Province must have seen a lot of losses to terrestrial biodiversity over the last two decades if some-one had been monitoring the logging activities the Province has undergone. The marine reef systems supported by coral and fish bio-diversity ranks equally with Malaysia , the Philippines and Indonesia, these areas have the highest coral and reef fish biodiversity in the world. The value of life and the biological support systems that are inherent in functional ecosystems which renders natural beauty to Madang Province is the key to "beautiful Madang, Tourist destination" we see plastered at Madang airport and hear on the radio. In support of that, this country has signed numerous Biodiversity Conventions listed on page 8 in Box1 of Volume A of the Ramu Nickel Mine Project Executive Summary. PNG has paid lip-service to these Biodiversity Conventions in that there has been no regional thinking that has gone into the types of so-called developments this country should have. If Madang Province has a high biodiversity in the terrestrial ecosystems as well as the marine sector, the logical economic activity is Tourism, Sport Fishing and Nature walks. Most biodiversities in various parts of the developed world are gone, and people in those countries will appreciate Madang’s biodiversity. It is time for PNG to start waking up to the rich natural beauty this country can contribute to the Total Environment and the value that natural beauty holds and appreciate nature and realize that other people whose lives have been enslaved by a highly monetary society will look for places like Madang. Local people can handle and sustain such simple activities that maintains the Environment and still provides an income and food for survival.
3. The Vitiaz Basin, into which the planned Deep Sea Tailings Placement is planned for is in an area of regular upwelling (Appendix 1&2). NOAA Satellite imagery has proven that upwelling of cold water at depth can be brought to the surface by wind driven forces. Upwellings are a dynamic and real event on the Madang Coast which includes Basamuk Bay. Whilst, it was clear that the depth at which the Deep Sea Tailings Placement (DSTP) has been proposed will be below both the euphotic zone and surface mixing layers, the Current studies indicate pronounced upwellings to the surface along the Madang Coastline. Further, the bathymetry of the Canyons leading into the Vitiaz Basin does not support DSTP, the slope of the Canyon is increasingly gentler, not sharper. The Company indicated that for DSTP to function, the slope of the receiving basin has to be greater than 12 degrees yet the company has clearly produced evidence that the bathymetry at Basamuk is an increasing gentle slope, clearly unsuitable for DSTP ( Figure 2.5 of Appendix 1). The company made reference to the DSTP’s employed at Misima and Lihir Gold Mines, but information provided by Lihir and Misima indicate that the bathymetry there is sharper and in fact sheer drops at the point of discharges is typical, a situation totally different to Basamuk Bay. If DSTP has to be properly done, the Depth of DSTP has to be either at 350 meters or at 950 meters to account for the two distinct currents that exist at 140 meters which brings water up and down a 100 meter range from 140 meters and a second current at 700 meters which brings water up and down over a 200 meter range above and below the 700 meter mark. The proposed 150 meter depth is in-effective if we consider the impact of the current stream at 140 meters which moves water up to 40 meters below the surface from 140 metres or moves water down to 240 meters. During the northwest monsoon wind forcing occurs by bringing water from 100 meters to the surface, and if this is concurrent to the 140 meter current stream, tailings will be brought to the surface. The current dynamics of the Vitiaz basin precludes any form of DSTP.
4. The fisheries resources of the Bismarck Sea is valuable as food security for Papua New Guinea as well as a source of renewable revenue generating source. These reef and tuna resources of the Bismarck Sea rely on the continuing clean and productive environment of the Bismarck Sea. The Vitiaz Basin into which the proposed DSTP will be placed, as shown clearly by the Oceanographic and Current studies detailed in Appendix 1& 2 of Volume C of the Environment Plan stated clearly is complex, is regularly up welled and moves sediment flows up and along the Madang Coastline. These oceanographic and current systems entrain terrestrial sediments that sustain the natural productivity’s of the Bismarck Sea and hence the living resources.

In the Fisheries Sector, Papua New Guinea is now at the point of domesticating its Tuna Industry. The current largest tuna fleet is based in Madang. Madang has a tuna cannery based on surface schooling tunas of the Bismarck Sea and an export tuna quota to the European Union. To enter the European Union market, the industry must prove product quality. The marketing label is "environmentally clean" caught tuna, Bismarck Sea. The losses to PNG through any hints of environmental contamination from DSTP from the proposed Ramu Nickel Mine if known, will kill the international market for PNG’s domestically caught tuna. This cannot be.

Further, Papua New Guinea’s tuna resources of the Bismarck Sea is the largest in the southwestern pacific region. The grounds provide feeding and spawning sustenance to migratory tuna. The potential value of the tuna resource is US$400 million annually for which PNG now has the Fisheries Management Act and the National Tuna Fishery Management Plan in place and to start participating in a domestic industry to make a living from; in both food security and economic value. To have another mine dump tailings into the Bismarck Sea via the Vitiaz basin is irresponsible when considering that the Lihir Gold Mine is also dumping into the sea. The proposed Ramu Nickel Mine is worth nothing to Papua New Guinea in the longer term except to fill the pockets of the greedy compared to a resource sector such as fisheries which meets food security and revenue generating capacity when sustainably managed on a renewable basis and not a specific life in number of years such as in the case in a mining project.

 

5. The mining revenue in Papua New Guinea has been the source of intense human greed and financial mismanagement that has crippled the financial capacity of government today. The Panguna Copper Mine, the OKTedi Copper Mine, Misima, Lihir, Porgera; where are the infrastructures supposedly created by these mines? This country is in financial ruins. The mining sector did generate millions of kina of revenue but where has all that money gone to? Arguably the Ramu Nickel Project may be what we need to raise some cash but the costs are huge and the returns are low.

• That Highlands Pacific Limited as a National Company consider diversifying and investing in the renewable fisheries resources sector as opposed to a mining sector that only provides 2 % of the Mining Proceeds to Madang Province over twenty-years but keeps the rest for itself at a cost to environmental damage to the Fisheries Sector.

NOAA satellite images indicated strong upwelling occurring off southwest New Britain and billows of cold water are carried westward through Vitiaz Strait along the Rai Coast. Fast west-ward wind flow through the Vitiaz Strait entrain nearshore waters from along the Eastern Rai Coast and are replaced by colder waters.

The above local oceanographic features may have a better chance of transporting particulates from the outfall pipeline (those carried by bubbles to surface) and mixed with the cooler water from the upwelling and may be discharged to the archipelagic waters. Experiences from fisherman (purse seine or longline) shows greater currents (both surface and mid water) causing difficulty for the fishermen. The presence of strong currents during fishing in the Bismarck Sea and sea areas near Madang show that current movement in the area is high, hence DSTP is not a good idea.

The other concern would be to look more carefully at the same water body from the New Guinea upwelling that crashes onto the continental shelf of the Vitiaz Strait from which the refracted current will definitely sink into the ocean floor and may cause upwelling in situ. This upwelling over a time scale will be transported to the surface and be transported by surface currents to the neritic zone which will impact the pelagic resources, our major concern.

The continental slope from the dumping site is steep (about 15 deg.) and may work but again the concern would be the density gradient of the sinking tailings. Tailings associated with oxygen will definitely have some bouyancy that will cause the tailings to surface. Suspension of tailings may cause the water to be turbid therefore hinders the photosynthesis process of the organisms of the euphotic zone. This euphotic zone accommodates organisms that sustain the bases for the entire ecosystem of the surrounding waters, the Bismarck Sea.

The Bismarck Sea is renowned for its high productivity of tuna species especially around New Britain and off the coast of Madang. Madang local waters are a very productive area supporting game fishing and other fisheries. With these in mind, the deployment of tailings onto the ocean floor has to be reconsidered given the fact that pelagic resources worth millions of kina are yet to be exploited as clearly outlined in the National Tuna Management Plan and the 1998 Fisheries Management Act.

The placement of mine tailings in the deep marine environment, precisely both below the ocean mixing zone where wind and waves promote fluid mixing and below the biologically active zone may cause problems to the general ecology of fisheries. Astrolabe Bay is renowned for its great potential for future development of fisheries industries like prawn and other inshore marine resources. The current status of these fisheries are that they are not developed, however, these resources are still part of the ecological chain of the entire ecosystem of Basamuk Bay and the Bismarck Sea.

Further;

1. Diet analysis of fish species was not conducted during the sampling trips. These should be done to be included as part of the baseline studies.
2. Benthic communities or invertebrates are most sensitive to short term increases in sediment

loads than fish and crustaceans. Although some samples were collected during the sampling

trips, those samples were not analysed for inclusion in the EP. These samples should be

immediately analysed as part of the baseline studies.

• The document is very comprehensive. The general impression from the document is that the possible impacts that may arise from the development of the proposed nickel mine development in Madang Province is the increased sedimentation and metal loads in the streams draining the Kurumbukari area to the Ramu River. Most of the arguments and conclusions are based on experts with broad experiences in environmental impacts associated with major mining projects in Papua New Guinea (PNG). Because of their independence assessments and conclusions, we may also conclude that the level of impact to the freshwater biological community would be as predicted.

• There should not be any correlation between similar work done in other parts of the tropical world to the present project. This is because there is no perfect duplication of the ecology and hydrology between those places and the freshwaters of the Ramu River System. The Ramu River System and the Fly River System would be comparable, because of high-suspended sediment loads and similar taxonomic composition. Therefore, the impacts generated from this project would most likely to be similar to that of the Fly River System. For example, the monitoring program implemented by Ok Tedi Mine has revealed significant reductions in fish catches at most riverine sites in the Ok Tedi, upper and middle Fly River (areas in the vicinity of the mine) than the areas further down the mine. The sediment water quality criteria that Papua New Guinea adopted (especially from Australia and New Zealand) are irrelevant to the situation in Ramu River System because of the clear water systems in those countries. Most of the fish species found in the Ramu River System are able to tolerate high sediment loads, especially the ariid catfish, but major impact would be on the fish species that naturally prefer clear water streams such as gobies and gudgeon. It is likely that there will be a reduction on species diversity and abundance particularly in the vicinity of the mine. Similar impacts occurred at the Ok Tedi Mine as a result of increased sediment loads in the Ok Tedi River. If such will be the case in the Ramu River System, then it would mean that loose or avoidance of clear water fish species would be expected, which could result in an increase in relative abundance of sediment tolerant species, particularly ariid catfishes. This was the case in the Fly River System.

• Biological sampling trips were conducted when there was a very strong El Nino event in the Madang area. The assessment permitted extreme natural variability of the aquatic fauna, but has limited the usefulness of the results for establishing "typical" baseline conditions. The study was carried out on few occasions and the estimates on yearly variability on the species diversity and abundance are yet to be established. These are some of the questions to be answered.

• Prawn samples taken from the off-river water bodies (e.g. Banap Lake) tend to be dominated by juvenile stages. This perhaps may indicate that the lake acts as a nursery ground for those species. Experiences from the Fly River indicate that such water bodies tend to act, as breeding grounds for the fish. Sediment impact on such water bodies will have negative effects on the survival of the prawn populations and will eventually affect the production of subsistence fishery. This subsistence fishery is the only income generating activities for the local people in the area. It is estimated that 200 kg is taken annually. Care should be taken not to destroy the early stages of the prawns’ habitats, as the early stages are sensitive to any impacts. It should be also noted here that fish species that inhabit turbid rivers rely on terrestrial and floodplain areas as food sources and sediment deposition on these areas would limit their access for food.

• As pointed out in the document, some species are sensitive to sediment impacts. The bulmer’s goby, Glossogobius bulmeri has a restricted distribution in the Ramu River system. The species is a visual predator and is likely to lay eggs on hard substrata and guard them until hatching. These aspects of the life history and habitat requirement make this species sensitive to sediment impacts. Another species, the fringe-lipped mullet, Crenimugil heterocheilus is known to be intolerant of long-term sediment impacts. One species that is listed in the World Conservation Union Red List as Threatened Animals is the bulolo rainbowfish Chilatherina bulolo. The species may attract international environmental attention.

• The fish fauna of the project area streams is dominated by clear-water forms such as gobies, gudgeons and rainbowfishes and most are visual predators. The gobies and gudgeons are all demersal egg layers, requiring hard substrata for breeding. Water quality in these streams have indicated background levels of suspended solid concentrations. It is likely that the fish species in these streams are likely to be intolerant of changes to the sediment load resulting from the proposed project.

• Metal concentrations of fish tissue, liver and kidney were taken during the sampling trips. The trace metal impacts would most likely to adversely affect recruitment and growth of young organisms than adults.

• Benthic communities or invertebrates are most sensitive to short term increases in sediment loads than fish and crustaceans. Although some samples were collected during the sampling trips, those samples were not analysed for inclusion in the EP. These samples should be immediately analysed as part of the baseline studies.

In conclusion, suspended sediment and metal loads are likely to cause major impacts on the freshwater biological communities as a result of the operations of the proposed nickel mine in the Kurumbukari area.

The Ramu Nickel Project like all other major projects has its share of benefits and costs. In the socio-economic impact study, benefit streams were itemised and possible negative effects identified. In this impact, obviously monetary gain is seen as positive impact, hence the negative impacts outlined are to allow monetary gain to take precedence over a cultural way of life as a valuable item. If monetary gain is to be seen as the positive impact, then;

The organisations responsible for carrying out the recommendations to minimise perceived negative impacts to maximise monetary gain must be in place. This should commence with the awareness and education programs for the people at Kurumbukari and at Basamuk to prepare them for this development as well as preparing them to face the negative impacts of this project. For instance, prior to re-locating local people into new locations and houses, it would be necessary to educate them to adapt to their new environment and also the modern houses that will be built for them. Proper land lease agreements or other traditional agreements suitably practised at Kurumbukari and Basamuk should be entered into between all parties concerned prior to the commencement of the relocation exercise.

The Report also states that the views of land-owner groups were not taken into account due to these groups not being recognized yet. This would have to change. Land-owner associations would have to be registered and have a legal constitution so that they can participate in the development of the nickel project. It should be pointed out that without proper constitution and by-laws governing the interest of the land-owners themselves, positive developmental contributions can cause disharmony in local societies.

The project has an expected life span of twenty years but this may increase to 30-50 years. The socio-economic impact study will need to be conducted every five (5) years from the commencement of the project so as to determine the type of economy and society after the life-span of the mine. This would assist in planning and will also place more emphasis in areas of investment, which are independent of the activities of the mine, such as agricultural cash crop development such as cocoa, coconut, coffee and oil palm. In the medium to long term, this will ensure the building of a stable and sustainable economy that is independent of the mine. In that light, projects identified for development should be properly screened through Project Design Format as discussed in the Report.