From : Zambezi Society

13 September 2012


On  31st August 2012, The Zambezi Society attended a stakeholders meeting at the invitation of  Impact Assessment Consultancy  IMPACO ( )  on behalf of Habbard Investments, to discuss the Environment Impact Assessment for heavy minerals exploration in the Chewore and Rukomechi Rivers in Northern Zimbabwe.  This was a follow up to the company’s press publication in July 2012, inviting stakeholder inputs.

The invitation stated:  “ Habbard Investment is required by law, to undertake a series of Environmental Impact Assessments (EIAs). These assessments seek to establish the likely impacts of mineral exploration activities and to recommend how proposed operations should minimize such impacts. Habbard Investments also organized consultation meetings to provide awareness of the techniques it intends to use; resistivity survey and the sonic drill rig. IMPACO was appointed to undertake this work in an impartial manner and produce a report and recommendations for field operations, which Habbard Investments will be obliged to follow. To this end IMPACO has employed a team of consultants in various fields of expertise to successfully complete this EIA. I therefore encourage you to voice any concerns on behalf of your organization. There is a time constraint, in that the EIA must be finalized by September.”


The meeting was professionally conducted and well attended by about 50 stakeholders from the public and private sectors.   Habbard Investments was represented by Mr Paul Chimbodza and Mr Lloyd Hove and by IMPACO, the consultancy employed by them to conduct the EIA.

The Zambezi  Society was represented  by, Richard Maasdorp (Strategic Director),  Peter Musto  (Projects Co-ordinator), Des Matete  (Legal Advisor), Nyasha Madziva (MIT student and Youth representative),  and Wonder Matemaska (Mining engineer advisor).


Habbard Investments explained that they have acquired Special Grants for Exploration for Heavy Minerals Sands in the Zambezi Valley under Section IX of the Zimbabwe Mines and Minerals Act as follows: –

SG 5553 Rukomechi (45ha)

SG 5554 Chewore (65ha)







Why the Zambezi Valley?

According to Habbard Investments, the rivers in the Zambezi Valley have been chosen for the following reasons:

  • “Favourable geology
  • High grade metamorphic belt of the Zambezi escarpment contains source rocks for Heavy Mineral Sands
  • All drainage is into the valley offering a natural mineral sorting mechanism
  • Geologically known and mapped fluvial fan is of geologic interest
  • Reduction in gradient from escarpment into the Valley encourages deposition of heavies
  • Potential multi-million dollar revenue earner”

The EIA process & stakeholder consultation

They are statutorily required to seek approval from the Environment Management Agency (EMA) via an Environmental Impact Assessment EIA process for exploration only for heavy mineral sands at this stage.  They explained that if their explorations are successful, they will have to seek separate approvals.   This EIA process requires the involvement of the following stakeholders:

—        Ministry of Mines and Mining Development

—        Parks and Wildlife Authority

—        National Museums and Monuments

—        Chamber of Mines

—        Local Authorities, Council and Chiefs

—        Local Business

—        Special Interest Groups

—        Individuals

 Exploration Process

They described their exploration process as follows:

  • Excavation of 1-metre-deep pits in the sand of the rivers,
  • Drilling of augur holes every 1km down the centre of the riverbeds
  • Trucking of samples out of the area and driving of vehicle through the access roads of the National Park/Safari Areas.
  • An exploration team  consisting of a team of 5 people using a mobile camp.  T

They estimate that the exploration will take two months per river.

 Future Mining

Habbard Investments did not give details of their possible future mining operation, should explorations be successful,   saying they need the exploration result first.   However, it is clear that their intentions, subject to viability, are to mine.  IMPACO said that they would be making a request from their client for the possible mining methods, and these would then be circulated.  They insisted that in all their operations they would take all reasonable measures to protect the environment, including, if necessary sanitising certain areas.   They made much of the “positive” economic and social benefits of mining in this area, and urged that Zimbabweans need to engage each other in finding “home-brewed solutions towards sustainable exploitation of resources.. without the influence of external forces”.


Strong objections to the proposed minerals exploration (and subsequent mining) were voiced by conservation NGOs and representatives of both the private and public sectors.  The major objections raised had to do with the potential long term impacts of such a proposal on the cultural, biodiversity and tourism benefits of the Mana Pools/Sapi/Chewore area as a UNESCO World Heritage Site, National Park, Biosphere Reserve, International Bird Area, wetland and Trans-Frontier Conservation Area.  Objections from the public sector came from The Zimbabwe National Water Authority (ZINWA)  (which expressed itself strongly opposed to alluvial mining in river beds, citing existing examples throughout Zimbabwe of the destabilisation of river systems through mining activities), from  from the Zimbabwe Parks & Wildlife Management Authority, from the Department of Museums and Monuments which objects to mining activity but not necessarily exploration, and from the Ministry of Tourism which was concerned that the issue should not become an international one.    It was pointed out by many that since the area is already internationally recognised as a World Heritage property, this is already a global issue and will unavoidably attract international publicity through the internet and be subject to pressure from the outside world.

 Response to Objections

Habbard gave the following “Corrections” in response to some of the objections raised:

  • “Impaco (the EIA consultancy) is fully legitimate
  • Exploration is not mining
  • Habbard is not insensitive to the environment and fragile nature of Mana Pools
  • EIA process is Habbard’s initiative
  • Process not politically driven  (they have received e-mails and verbal abuse to this effect)
  • Mining activities can take place in World Heritage Sites (they gave examples of a $400 million uranium project in a Tanzanian game park;  Mt Nimba Iron Ore Project-Cote d’Ivoire and Kangaluwi Copper project in Zambia by Australian owned Mwembeshi /Zambezi Resources.”

World Heritage Sites threatened by Mining

According to the International Union of Conservation (IUCN), African natural World Heritage sites that are increasingly threatened by commercial mining and oil/gas projects include:

  • Virunga National Park (DRC)
  • Comoe National Park (Cote D’Ivoire)
  • Mt Nimba Strict Nature Reserve (Cote D’Ivoire and Guinea)
  • Dja Wildlife Reserve (Cameroon)
  • Kahuzi-Biega National Park (DRC)
  • Selous Game Reserve (Tanzania)
  • Air and Tenere Nature Reserve (Niger)
  • Manovo-Gounda Nature Reserves (Central African Republic)
  • Mana Pools National Park, Sapi and Chewore Safari Areas (Zimbabwe).

This represents 24% of the 37 African natural and mixed World Heritage Sites, or one in four sites is threatened.  This is an increase from 16% in 2009.


All stakeholders were asked by IMPACO to make formal written submissions and agreed to meet with as many of those present as possible on a one-to-one basis.

IMPACO informed the meeting that the EIA needed to be completed by September, but many present felt this was unrealistically short.  No firm date was given.

Formal objection submissions

The Zambezi Society will seek an interview and then review and resubmit its objections.

We encourage other stakeholders to similarly submit responsible and considered objections ONLY via the following contact details:-

Impact Assessment Consulting (IMPACO)

185 Willow Creek,  Good Hope, Harare, Zimbabwe

+263 775 884 176   or

Habbard Investments

51 Dunkeld Road, Mount Pleasant, Harare, Zimbabwe

+263 772 325 666