Foreign mining companies like Rio Tinto need to talk less about their tales of success, and listen more to the realities experienced by local communities. And they must be answerable for the damage they cause.
The fourth largest mining company in the world, Rio Tinto, claims to be a leader in Corporate Social Responsibility (CSR) and positions its QMM mine in Southeast Madagascar as a model for the industry. But is this story all it seems?
Extracting ilmenite from 6,000 hectares of mineral rich sands along unique littoral forests, QMM claims it has rehabilitated over 1000 hectares, provided jobs, initiated new livelihoods, and has promised a net positive biodiversity impact (NPI) for the region. In 2009 its highly promoted environmental conservation programme earned the company a green accolade.
However, this story is somewhat dissonant from the accounts of local communities and international activists who have challenged the company's claims and commitments around social and environmental benefits and sustainable development.
For example, see this account of a Villager in Antsoto: "We are really suffering now because we had to stop cultivating on the hills. We moved our cultivation into the dunes, but it's so sandy there that growing anything is difficult. Plus they took our land and did not even compensate us. They said they would, but they never did."
Environmental compliance of Rio Tinto's QMM mine in Madagascar looks increasingly shaky. So much so, the independent Biodiversity Committee to QMM resigned in October last year, claiming the current position of Rio Tinto "produced an untenable level of reputational risk" to its members.
The committee was set up in 2003 to provide guidance on the QMM Biodiversity Action Plan. It counts international experts, including representatives from Fauna & Flora International, Birdlife International, Conservation International, Kew and Missouri Botanical Gardens, amongst its advisers.
These individuals state in their resignation letter to Rio Tinto that they are now deeply uncomfortable with "the fact that mention of the environment is totally absent from the five stated corporate priorities of Rio Tinto." Moreover they express a "lack of confidence that adequate long-term resourcing and capacity will be provided for the biodiversity program at QMM."
They are not alone in questioning the company's real environmental and social commitments . Over the last few years, researchers have challenged both QMM's claims of net positive biodiversity impact and a flawed Offsetting programme.
Failed compensation stories have been shared by local people since the first displacement of villagers, and concerns have also been raised about the infringement of mining boundaries  and encroachment into buffer zones and waterways.
Crossing the line
The breaching of boundaries is of particular concern. An 80 metre legal boundary is set by national law  in Madagascar to create a buffer zone for environmentally sensitive areas, for example to protect waterways.
Google Earth images demonstrate that where QMM is operating its Mandena site, the company has breached the legal limits of this 'buffer' and introduced an artificially extended landmass where forest and lake were originally situated.
It is unclear if this infringement has occurred to increase access to the mineral deposit or to correct a miscalculation. 2016 images suggest the extended land mass has enabled the mine to dredge close to the original waterline of the lake.
The extension of the mining operations into the 80 metre buffer zone raises a number of questions, not least how national laws were ignored or renegotiated.
Also, whether the new man made buffer is robust enough to protect the water table, which is particularly fragile due to seasonal flooding; whether dredging close to the original waterline has unseen impacts e.g., if toxic waste in tailings, a by product of the extraction process is now more likely to leach into the lake and water system where local people fish.
The glow of whiter than white
Ilmenite is a mineral extracted to create titanium dioxide (TiO2), an industrial whitener used in everything from paint to toothpaste. In country research by the INSTN (National Institute of Nuclear Science and Technology), reports that 23 million tonnes of heavy metal concentrate (HMC) are processed by QMM to deliver approx. 750,000 tonnes of ilmenite annually, over a projected 40-year operation.
The presence of naturally occurring radioactive materials (NORM) such as uranium and thorium, occurs naturally in the mineral sands in Madagascar. In the rich ilmenite deposit that QMM is dredging, Zircon and Monazite are present as by-products in the extraction process.
Both Zircon and Monazite contain radionuclides and together concentrate up the uranium-238 and thorium-232 content, thereby increasing the NORM. For example, when Monazite is separated from ilmenite it contains between 5-7% thorium (Th232) and between 0.1-0.3% Uranium (U238).
The high quantity of mineral sands being exploited in the QMM operation further increases the NORM and gamma dose rate in the vicinity of mining operations. The elevated levels of NORM may therefore increase the emission of radiation and are cause for concern.
The INSTN report estimates the highest hourly whole body dose of gamma-radiation to workers exposed to the various intermediate and final products is 23.56 microsieverts per hour. In which case, assuming a 40-hour working week, a worker would exceed the annual dose limit in the UK of 20 millisieverts (msv) in around 1,000 hours or 25 weeks.
More importantly thorium is an alpha emitter so inhaled dust may be a significant radiological hazard, which has not been dealt with in the INSTN's paper.
The INSTN study also fails to consider adequately all the significant radiation exposure pathways that are typically associated with mineral sands mining operations. In particular whether QMM's monitoring and management methods are effective in tackling and closing down these pathways.
For example, Thorium is a principle radioactive component of Monazite, and can leach from tailings into water bodies and farmlands. Such NORM-bearing leachate can be taken up by fish, making them radioactively contaminated, and affect the public who buy and eat the fish from local markets. The waterways adjacent to the QMM mine are used for fishing and also feed into the nearest town, Tolagnaro, to provide drinking water.
The full rehabilitation of the mine site and tailings is a further concern. Long-term presence of thorium residue in tailings can take thousands of years to disperse and present a low-level radiation hazard. The sandy soil of the southeast coastline makes the area hard to restore.
As the QMM mine is slow to rehabilitate its dredging pathways, and its environmental commitments now appear to be under question, this aspect of rehabilitation also presents an important aspect of enquiry.
Same old story
Currently heading the Chambres des Mines, a national body coordinating the interests of extractives in Madagascar, Rio Tinto would be expected to set a good example and demonstrate industry standards, not least to secure Madagascar's membership to the EITA.
In this, it is reasonable to demand the company accounts for how and why QMM has renegotiated or flouted national laws in extending their mining operations into the environmental buffer zone, and how it is managing the mine's radioactivity risks.
However, QMM's track record on communications and building trust with the local community has been notoriously poor and the local Antanosy people have complained and publicly protested about QMM's failed CSR promises, like Ilay, from Ambinanimbe:
"Since people felt betrayed they no longer trust anything QMM says or wants to implement ... People are sad about the whole situation but they feel powerless ..."
Continued stories of abuse, such as the buffer zone infringement and communities carrying the costs of QMM's Biodiversity Offsetting, suggest lessons have still not been learnt. Such failures do not substantiate QMM's social licence to operate or bring Rio Tinto any closer to delivering the 'model mine' it wants to write into the history books.
No oversight, no recourse
The recent resignation of the Biodiversity Committee, just three years after the dissolution of QMM's Independent Advisory Panel (IAP), will deepen concerns over the lack of oversight of QMM operations. Indeed, if Madagascar is to protect its people and unique biodiversity from the 'resource curse' it requires more robust monitoring of the extractives sector, both nationally and internationally.
With a Government still largely in disarray following almost five years of political crisis (2009-2014), local institutions lack the capacity and wherewithal for monitoring and regulating foreign extractives projects. A weak civil society and insufficient consultation around the country's new mining code has disenfranchised communities who live under an increasing threat of land grabs, as described by one Public Officer in Andasibe:
"It seems clear to me that people no longer have the right to secure their land. Why is it so easy for big companies to obtain the right to use the land, while people who live in these areas do not have possibilities to secure their rights?"
Inadequate legal frameworks to protect citizens' rights, and allegations of corruption on other environmental issues, such as illegal rosewood trafficking, suggest the administration is failing Malagasy citizens. In this context, local people have little recourse when powerful, international corporations fail in their obligations and negatively affect their livelihoods and health.
Scripting alternative narratives
This year the UN Human Rights rapporteur to Madagascar has appealed to the Malagasy Government to address these failings; most particularly that revisions to the Mining Code meet human rights standards.
He calls on Madagascar to become a fully compliant member of the EITA, with "citizen access to courts to ensure that environmental laws are being enforced", and requiring that citizens are not criminalised or otherwise prevented "in the exercise of "their rights to freedom of expression, association and assembly."
He particularly calls on businesses and other organisations that work in in Madagascar to "respect communities' rights of information, participation and remedy." If the Malagasy Government and corporations such as Rio Tinto can adopt these recommendations there may yet be some hope of protecting local people and their environment.
This story is far from over. Whatever happens, foreign companies like Rio Tinto operating in Madagascar need to talk less about their tales of success, and listen more to the realities experienced by local communities. And they must be answerable for the damage they cause.
Malagasy citizens need support in righting wrongs, and in writing a more sustainable and fairer narrative for the island's future.
Yvonne Orengo is an independent communications practitioner and a Director of the Andrew Lees Trust a British charity set up following the death of its namesake in Madagascar in 1994. She lived and worked in the South of Madagascar for over six years, developing the Trust's social and environmental programmes and has followed the evolution of Rio Tinto's QMM project for over 20 years.
Public event: The Andrew Lees Trust is co-organising an event on April 8th 2017 at Friends of The Earth in London to debate questions and challenges around Biodiversity Offsetting, with testimony from Malagasy community representatives. For more information see here.
1. Seagle, C., 2012.Inverting the impacts: Mining, conservation and sustainability claims near the Rio Tinto/QMM ilmenite mine in Southeast Madagascar. The Journal of Peasant Studies, 39 (2), pp. 447-477.
2. 'Je veux mon part de terre', Film by En Quete Productions, Fred Lambolez and Jean-Marie Pernelle
3. Malagasy National Law on Buffer Zones: Arrêté interministériel nº4355/97.