The Sappi Pulp Mill at Ngodwana, 50km west of Nelspruit in Mpumalanga Province, South Africa, is a huge wood-pulping plant alongside the N4 highway. This Pulp Mill, being the largest in Southern Africa, currently produces almost 500 000 tons of pulp per year. It is notorious for the stench and pollution it emits, for its health risks, truck traffic and its seemingly insatiable hunger for millions of alien trees. These alien plantations cover many thousands of hectares of escarpment land, like conquerors of forgotten battlefields where grassland fauna and flora have lost the struggle to survive.
Memorandum to be presented to Sappi and Golder Associates at the open day meeting at the Sappi Ngodwana Club, on 29 July, 2004 by civil society organizations listed.
The Sappi Pulp Mill at Ngodwana, 50km west of Nelspruit in Mpumalanga Province, South Africa, is a huge wood-pulping plant alongside the N4 highway. This Pulp Mill, being the largest in Southern Africa, currently produces almost 500 000 tons of pulp per year. It is notorious for the stench and pollution it emits, for its health risks, truck traffic and its seemingly insatiable hunger for millions of alien trees. These alien plantations cover many thousands of hectares of escarpment land, like conquerors of forgotten battlefields where grassland fauna and flora have lost the struggle to survive.
Now there are plans to expand production at the Ngodwana Pulp Mill by 69 per cent, in order to supply global pulp demand. Despite this massive increase in the productivity of the mill, not a single permanent job opportunity will be created on the premises. This expansion will include a change from the current "Main line" of pulping pine trees, to pulping predominantly eucalyptus trees. To cope with this ever increasing demand for eucalyptus timber, a minimum of 25 000 hectares of local pine plantations will be converted to eucalyptus plantations.
The EIR (Environmental Impact Report) summary states that: “the change in forestry, from pine to eucalypt, is considered to have an insignificant impact in terms of catchment yield and runoff quality”. This statement is being contested, as broad-leafed eucalyptus trees consume much more water than pine trees. Eucalyptus trees use a disproportionate amount of water from the first year plantations are established, in relation to pine trees that only starts to seriously effect water resources from the fourth year onwards. The new plantations will be short rotation for maximum yield, which will place an even heavier burden on a seriously water-stressed region.
The impact of industrial timber plantations on soil microlife and the resulting loss of soil nutrient availability, is an issue critical to the sustainability of the pulp and paper industry in South Africa. Although this issue was raised during the EIA "scoping" process, and was to be dealt with in a specialist report, it receives no mention in the draft EIR.
Currently, permit conditions allow the mill to release 10 tons of chloride into the effluent daily. This effluent is irrigated onto a pasture which is saturated and leaches into the Elands River. The water from the Crocodile and Houtbosloop Rivers is sufficient to dilute the chloride content to 'acceptable' levels. However, at a time of more frequent and severe climatic extremes, it would be careless not to consider the impact of a severe drought: will chloride levels in rivers rise, impacting on downstream users? Or will the mill reduce production and perhaps be forced to shut down?
Delve deeper into the dirty business of making white paper, and find horror stories about persistent dioxins in the effluent. Contamination of our river systems which inadvertently impacts on aquatic life, such as induced hormonal changes in fish populations, are just one of them.
What is the long term repercussion of such chemicals on the holistic environment?
• Can we afford more pulpwood, and less water?
• Can we afford more pollution, and less health?
• Can we afford more mono-culture, and less diversity?
The Sappi Ngodwana Expansion draft Environmental Impact Report summary is available from Golder Associates (PSewmohan@golder.co.za) and will be discussed at a public meeting at the Sappi Ngodwana Club on 29 July 2004, from 09h30.
You are urged to become involved in the process that will determine the future state of YOUR and YOUR FAMILY'S environment.
GEASPHERE is an environmental organisation opposed to the expansion of the pulp industry in Southern Africa.
We believe alien industrial timber plantations exert unsustainable pressures on soil and water resources. The costs (such as loss of grassland biodiversity and services) have never been comprehensively quantified, and it would therefore be irresponsible to allow the expansion of the Sappi Mill at Ngodwana and the further entrenchment of the industrial monoculture plantation model.
. GEASPHERE advocates a fundamental change in the way the timber plantation industry operates: a move away from industrial monocultures towards a different model using ‘mixed species’ plantations of indigenous trees for a long term, high value investment. Also incorporating organic biodynamic systems designed to build the health and capacity of the soils.
If you are concerned about the impact of the proposed mill expansion on the integrated environment and would want to make a difference by taking part in a peaceful protest/awareness campaign, please contact Nicole at 083 626 2221 or Philip at 082 6369129.
Sappi proposes the following production increases:
* Unbleached softwood pulp capacity from 350 to 550 tons per day, for
linerboard production (Number One Pulp line)
* Bleached hardwood pulp capacity from 630 to 1050 tons per day.
* 250 tons per day of ground-wood pulp replaced by 550 tons per day of mechanical plant pulp, for
newsprint production.
* Linerboard production from 700 to 1000 tons per day.
* Newsprint production from 320 to 500 tons per day.
* Waste paper use from 110 to 240 tons per day.
Memorandum to be presented to Sappi and Golder Associates
at the open day meeting at the Sappi Ngodwana Club, on 29 July, 2004
by the Civil Society organisations listed.
We wish to raise the following issues with respect to the Sappi Proposed Expansion Draft EIR.
It is our contention that the impacts associated with ITPs - Industrial Timber Plantations - have not yet been comprehensively quantified. It is therefore not possible to make informed decisions regarding the ‘costs and benefits’ of expanding the mill at Ngodwana, that will lead to the further entrenchment of the industrial timber plantation model.
Consider the following impacts:
Impacts on Water
ITPs are alien, evergreen, high yielding timber species that consume considerable amounts of water.
Eucalyptus have deep penetrating roots which draw down the groundwater resource. These trees have a high evapo-transpiration rate, and are often used to help ‘drain’ marshy soils. In addition, eucalyptus trees are notorious for the ‘hydrophobic’ conditions they induce in the soils. According to experts, a waxy coating is deposited on the soil grains which inhibits water penetration. This effect is worsened by fire, and results in a decrease in groundwater recharge and an increase in ‘flash flooding’ and resulting soil erosion.
Impacts on Soil
ITPs are managed as vast monocultures that decreased biodiversity / biological activity. It is acknowledged by science that the ‘living’ component of the soil is vital to sustained long-term biological health and nutrient values. This is a legitimate concern, which affects the long-term sustainability of the timber industry, and should be comprehensively researched, reviewed and debated in order to enable proper decision-making in respect of timber plantation issues.
Impacts on Biodiversity
ITPs in South Africa are of alien tree species, and are established at the cost of the local natural environment. Grasslands and ITPs are not compatible, because grasslands are adapted to abundant sunlight and regular veld fires. ‘Remove the fire and you destroy the grassland’. Grasslands in South Africa are home to an estimated 4000 plant species, many endemic to the biome. Without exception, indigenous fauna and flora cannot survive confined within a managed alien timber plantation compartment. Most grassland plants have well established perennial root systems, and they can not ‘move away’ to other areas. Animals and birds are often territorial and can cause problems when migrating into other areas when trying to escape the advancing ‘fake forests’.
Impacts on Communities, Culture, and Indigenous Knowledge Systems
ITPs impact on culture and communities by impoverishing the natural resource base and limiting land-use options. Once timber plantations have been established, the land cannot be used to graze livestock as before:
People cannot collect medicinal or edible plants; People cannot harvest thatching grass, nor can they utilise the wild game resource for food and clothing material. African Indigenous knowledge systems are closely linked to an intimate understanding of, and respect for the natural environment. By impoverishing the natural environment we place the survival of this wealth of knowledge in jeopardy.
Recommendations
In order to ensure that people are guaranteed their right to a healthy environment, and that future generations have access to sufficient resources:
• A transparent, multi-stakeholder process to conduct a comprehensive cost and benefit analysis of the activities of the timber industry, that internalises all the social and environmental costs that are normally hidden.
• Local Community rights must be recognised and affected communities must be empowered to participate meaningfully in decision making processes that could affect their rights and resources.
• A minimum 3 months extension for comments on the draft EIR should be allowed. This would allow broader input from local community based organisations who need sufficient time to engage with the implications of the proposed expansion and to review the current environmental, social and economic implications of the existing project.
• Impacts on groundwater recharge by industrial timber plantations should be subjected to a full investigation.
• The impact of induced hydrophobic conditions in plantation soils should be subjected to close examination.
• Impacts on soil-health should be re-evaluated using the latest available scientific methods, data and technology. The issue of soil health is critical to the long term sustainability of the region (and the industry) and should be dealt with in a dedicated specialist report.
The issue of water consumption is a critical one, affecting the potential sustainability of the timber plantation industry. We challenge the assumption made in the Golder Associates, Sappi Ngodwana Proposed Expansion EIR that changing from pine to eucalyptus will have an ‘insignificant’ impact on catchment water yield and run-off quality. There is broad consensus that eucalyptus use much more water, and we believe that this issue has not been adequately addressed in the EIR.
An EIA should be used to identify all possible impacts so as to enable stakeholders to make informed decisions. Sometimes, negative impacts can be mitigated through proper planning and compromise. However If all impacts are not comprehensively considered an EIA becomes useless as a planning tool and serves only to promote the selfish interests of corporations and their consultants.
In this regard, it is noted for instance, that Sappi actually declared that this huge expansion of pulp production for export will not generate a single extra full-time job. Whatever the extra "outsourcing" or "subcontracting" opportunities the company says the expansion may generate, these are widely considered today to be of dubious long term social or economic value-added, in a society challenged by 40 percent unemployment; and moreover, where recent statistics show that even 44 per cent of all those who are employed, do not have medical, pension or redundancy benefits.
We are faced here with an expansion that is export driven, serving the interests of international shareholders, as opposed to being driven by local or regional environmental and social needs.
For a company like Sappi to be planning a 69 per cent increase in its core production, at the same time specifically excluding the creation of a single permanent job on site, could be judged as irresponsible.
We call on the Government to facilitate a “Industrial Timber Plantations Commission” to independently access, review and evaluate all available information in order to advise the appropriate decision makers on a way forward.
Furthermore, we urge Government to review the ‘National Forest Act’ so that a clear distinction can be drawn between the Conservation and wise utilisation of Natural Forests, and the establishment and management of Industrial Timber Plantations, that should logically be administrated and regulated by the National Department of Agriculture.
This Memorandum is endorsed by:
GEASPHERE
www.geasphere.co.za
TimberWatch Coalition
www.timberwatch.org.za
SAWaC
www.sawac.co.za
World Rainforest Movement
www.wrm.org.uy
International Rivers Network
www.irn.org
Southern African Green Revolutionary Council
South African Water Caucus
Environmental Justice Networking Forum, Mpumalanga
Rainbow Mantis Project
3. Environmental Impact Assesment (EIA) for the proposed Expansion of the Sappi Ngodwana Mill near Nelspruit, Mpumalanga Province.
Attention:
Ms Vassie Maharaj / Ms Qondile Sibiya
Public Participation Office
Golder Associates Africa
E-mail: vmaharaj@golder.co.za
27 August, 2004
Comments by:
Full Name: Philip R. Owen
Organisation: GEASPHERE
Comments:
1. I have read the Summary of the Draft Environmental Impact Report for this project and verify that the issue/s I have raised during the Scoping Phase have NOT been addressed in the report.
The issue of the impact of industrial timber plantations on soil micro-life, and the associated long term impact on soil nutrient availability has not been addressed in the EIR.
This issue is critical to the sustainability of the industry, as the availability of raw material (trees) depend upon the productivity of the soils. An expansion of the magnitude proposed by Sappi can not be considered if soil productivity is not assessed.
2. If your issue is not specifically addressed in the report, verify that an indication has been provided of where and when it will be addressed. If not, please indicate below:
No indication was given that this issue will be addressed. In fact, I have been informed that this issue will not be addressed as no new plantations will be established. However, a 69% increase in productivity at the mill will no doubt require larger volumes of timber (faster rotations of eucalyptus) and the impacts on soils will be accelerated. Thus it is important that this issue is comprehensively addressed.
3.We dispute the EIR findings that the change over from pine to eucalyptus will have and ‘insignificant’ impact on catchment yield and water run-off. It is our contention that eucalyptus plantations consume at least 20% - 30% more water than pine plantations and this can hardly be described as ‘insignificant’.
Attached please find the minutes of the 6th Community Forestry Initiative meeting (CFI), held at White River on 12 May, 2004. The presentation by Prof. Peter Roberts (Forestry South Africa Consultant) clearly shows the vast differences in water use by eucalyptus, pine and wattle plantations in deep, medium and shallow soils. Comparing the figures, it is clear that eucalyptus is by far the heavier water user. These calculations were based on the ‘Gush’ model, the same model used by the ‘specialist’ who conducted the water use studies in the draft EIR.
A serious flaw in the EIR is the fact that impact of eucalyptus on groundwater recharge is not considered.
In a Water Research Commission Report, # 730-1-98 (Interaction between vegetation and groundwater) it states that the roots of eucalyptus trees can penetrate 50m+ into the soil profile. (p27 3.2.1.5).
In contrast, hard woody (indigenous) trees have root systems penetrating +- 7m,
On p42 4.1.1.1 the WRC report states that eucalyptus trees a mere three (3) years old can alllready have root systems penetrating (and extracting water) 10m deep.
It is clear that eucalyptus trees start using water early in the rotation and will root as deeply as the soil profile will allow. The eucalyptus roots is also capable of fracturing weathered rock in the search for water.
In the Mkubulana area (in the Sappi Sudwala area – which has been identified in the EIR as an area to be changed from pines to eucalyptus) a eucalyptus plantation was clear felled at 16 years of age. It took 5 years for stream flow to return to ‘near normal’ conditions.
It is clear that the impacts on groundwater is severe, and considering that the Sappi Expansion will include an additional 25 000ha of deep rooting eucalyptus trees the matter should be comprehensively dealt with in the EIR.
During a presentation delivered at the GEASPHERE / TimberWatch Conference in November, 2003, entitled “Southern African Grasslands: Aspects of their Biodiversity, Dynamics and Management” Prof Braam van Wyk mentions that eucalyptus is notorious for the ‘hydrophobic’ conditions they induce in the soils. A waxy layer is deposited on the soil grains, which inhibits water penetration. This phenomenon accelerates runn off and increase soil erosion and the risk of flash flooding. (The presentation is attached for your reference)
Surely, this issue should be identified and addressed in the EIR.
4. Any other comments: GEASPHERE has, on behalf of several NGO’s and CBO’s asked for an extension on time for comments. We are aware that several organisations became aware of the scope and possible impacts of the proposed extension only recently, and has not had sufficient time to comment. Comprehensive public participation should form the back bone of any EIA process, and by not allowing this extension the process is undermined. It should also be noted that Goder Associates Africa runs the risk of being ‘black-listed’ by organisations who could feel disempowered by not having the opportunity for their voices to be heard.
Due to the fact that the impacts of the proposed expansion will reach far beyond Ngodwana and affect the whole region a SEA should be conducted to comprehensively address all the cumulative impacts.
