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1 July 2019
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Newsletter n° 116 [ENG]

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During this period, Malagasy citizens are awaiting the decision of the President of the Republic on the continuation or the stop of the Ilmenite project Base Toliara, after the visit of the Minister of Mines and Strategic Resources and his delegation in the field, the announcement of the results of the pre-feasibility study of the Australian mining company Base Resources concerning this project caused various reactions.

Some are happy to swallow the statements of the company Base Resources without chewing, and to emphasize that they support the continuation of the mining project at any cost. Others have questions about the public statements of the subsidiary company’s managers, and about the sometimes different data contained in the document "Toliara Project Prefeasibility Study - Summary outcomes" of March 21, 2019.

Consideration of the legal rights of Malagasy citizens on their lands, job creation forecasts, announced financial impact and - the last and not the least - radioactivity will be the subjects of further questions and comments by the signatories of this Communiqué.

Great concern about the land rights of the population.

The document Toliara Project Prefeasibility Study - Summary outcomes of March 21, 2019 by Base Resources Limited
- (1) which will be referred to as "PFS" in the rest of this release is available on the Internet, and begins with an alert about inaccuracies or possible changes in the content of this document for different reasons. Nevertheless, critical differences between the content of the document and the information provided to the public by company officials will be raised by the authors of this release.

A reading of pages related to the land acquisition in the Ranobe area shows that Base Resources plans to lease the land to the state. For this purpose, the State must appropriate the parcels concerned that belong to the inhabitants and titrate them in its name. According to the PFS, in the area currently covered, 106 out of 1,041 plots are titled, the remainder being held according to “customary interests”. Everyone will translate the word "interests" according to the importance they will give to the rights of local communities and Malagasy citizens on their lands, but we
would like to remind everybody that according to the Malagasy law 2006-031 (2), the occupants of the untitled private properties (PPNT) have a presumption of ownership, and therefore have not just "interests". Madagascar is famous all over the world for the inaccessibility of land titles because of their high cost and lengthy numerous procedures (over 20 stages) (3). The municipalities affected by the Base Toliara project do not have a municipality land office (guichet foncier in French, or BIF in Malagasy), so residents do not have the opportunity to apply for or obtain a land certificate as an alternative. This situation should not lead officials to ignore the land rights of occupants who are duly recognized by law. In this regard, the absence of this law 2006-031 in references to Malagasy laws and regulations in the PFS of the company Base Toliara and Base Resources worries to the highest
point the signatories of this release.

In addition, the identification of properties/ownership and land rights is mentioned as « completed » in the PFS document, while advertising and making available to the public the Local Land Use Plan (PLOF) describing the result of this work are not effective. We urge the Evaluation and Compensation Committee (CAE), which is responsible for this work according to the PFS, to urgently inform all citizens in the affected areas so that any oversights and errors are identified quickly and rectified with the participation of all stakeholders, including the occupiers concerned and their associations, the relevant State services, the mining company and the civil society organizations involved.

On the other hand, the PFS document mentions the declaration of public utility (DUP) which will provoke expropriations on the grounds intended for the extraction sites, the road and the port. However, this DUP was already challenged by several civil society organizations in July 2018 (4), followed by an action for annulment which was filed with the Council of State. We reiterate this challenge, in particular because the areas concerned are
intended solely for the realization of business in favor of private interests and for the profits of the private entity that constitutes the mining company, but will not even be accessible to the public.

The number of future jobs proclaimed to the general public is higher than the one mentioned in the PFS document.

In their statements of 21 March reported by the press, officials of the company Base Toliara mention the figure of
3,800 jobs (5). However, it is well known that the number of jobs is never stable during the life cycle of a mining
project : it tends to increase during the construction phase and then drops a lot. This fact is confirmed by the PFS which states at least in two places that

  • during the construction phase, apart from the staff already working for Base Toliara, jobs will be created for 15 months, the maximum number of which will be 1,600. Seven hundreds to 800 of them will not be recruited among the inhabitants of the vicinity of Toliara, and some will come from other countries ("expatriates") ;
  • During the operational phase (of actual operation), the number of workers including contractors will be 1,031 at first, then 1,140 when the second extraction unit and the concentrator are installed. It is planned to recruit 610 unskilled and semi-skilled workers in the Toliara region, with expatriates number going from 71 to 27.

The PFS document specifies that other jobs may be created. But why did not the Base Toliara leaders who presented the PFS dare to quote the actual numbers and details mentioned in the results of this pre-feasibility study ?

When a mayor and an association held a press conference to express their wish to see the Base Toliara project start, as 5,000 young people have already submitted an application for employment with the project (6), had the leaders of Base Resources assumed the responsibility to explain that not all job seekers will be hired by the project ? The PFS document states that 5,000 people are now in training and that following a selection that will take place soon, 200 to 500 candidates out of 1,000 will be selected for specific training in the construction and operation phases.

This serious lack of transparency on the part of Base Toliara officials vis-à-vis local communities and the Malagasy
population on the number of jobs, whose creation is proclaimed as the main benefit of this mining project, contributes greatly to undermine the credibility of this argument.

The mining company shines light on the expected financial benefits of the project

In the face of Base Toliara executives statements published in the press about the financial benefits to be expected from this mining project, economists ask for more details on the explanation of the contribution of $ 226 million a year to the Malagasy GDP (5) and how that amount was calculated. In particular, does this amount take into account the revenues that the state and the population will not earn through tourism in the areas affected by mining, while the Atsimo Andrefana region has been selected as one of the priority areas for tourism development ? (7)

The other figure mentioned concerns the $ 900 million of direct taxes and royalties that the Malagasy State will earn (5). If the project lasts 40 years, that means $ 22.5 million a year. It is a derisory amount that is not worth the sacrifice of the environment, livelihood and the habits and customs of the population.

Some mayors of municipalities impacted by Base Toliara have begun to dream of an enrichment of their commune thanks to the rebates that will bring the mining company. Do they know that Ambatovy, the largest mining project in Africa and the Indian Ocean, started mining at Madagascar East region and exporting minerals in 2012, and paid the government rebates intended for municipalities only in July 2018 ? In addition, we are wondering whether these rebates have already actually been paid to the municipalities today (8).

Other promoters of the Base Toliara project speak of the rapid development of Toliara and its region through its future activities. A visit to Taolagnaro, where RioTinto-QMM has been operating and exporting ilmenite for the last ten years, and exchanges with locals will teach them that while a small number of structures and families have benefited from this mining, communities Riparian communities are witnessing the destruction of their livelihoods
and the deterioration of the living conditions of the majority of the population (9), to such an extent that the Anosy region is now one of the poorest regions of the Big Island.

The concept of radioactivity is skillfully but very seriously obscured

The other worrying subject concerns the components of ilmenite mentioned in the PFS : the treatment of ilmenite in Taolagnaro/Fort-Dauphin highlights one (or more) radioactive product(s) included, about which the Director General of the National Office for the Environment said in 2018 that "the maximum level of radioactivity concentration is not yet exceeded in Fort Dauphin" (10). In the context of the Mainland Mining mining project that operated along the East Coast, mining experts had pointed out that zircon is often accompanied by traces of radioactive thorium and uranium (11).

All decision-makers should sharpen their critical thinking and wonder why society is talking to some of ilmenite, rutile, zircon and leucoxene without explicitly mentioning the concept of radioactivity, but use the following subterfuge to talk about it : "high levels U + Th (above 500 ppm industry standards for "premium" zircon may limit access to geographic markets (eg Japan and USA will not be accessible under current conditions) (12)

The non-explicit way in which the pre-feasibility study of the Base Toliara project addressed this topic of radioactivity in its paper and the perseverance of some senior officials to show enthusiasm for the project after the publication of this study raises serious questions about the competence of certain state officials and confirms the doubts already expressed about the interest they attach to the negative consequences of this mining project on the entire riparian population.


While all citizens are awaiting the decision of the President of the Republic on the halt or continuation of the Base Toliara mining project, the civil society organizations CRAAD-OI and the TANY Collective recall that this project has received its permit for Operation during the Transition periode in a very questionable manner, and note that the current Minister of Mines and Strategic Resources, prior to his field visit, clarified that this project is "a priority for the ruling power" (13). The data highlighted in this release lead them to

  • reiterate their call for the definitive cessation of this mining project in solidarity with local communities who have been opposed to it for several years (14), and in the name of protecting the livelihoods, culture and environment of the communities living in the areas affected by the project in the Atsimo Andrefana region ;
  • support economic projects that improve the income and well-being of local communities through the development of their own activities, while respecting their rights to their land and culture, while safeguarding their environment.

The signatories of this communiqué also pose the important question of whether the President of the Republic and the government will publish their decision on the Base Toliara project before or after the parliamentary elections ?

This is the translation of the communiqué issued in French language on 28 march 2019 :

The parliamentary elections took place on 27 May, the Republic President has not publicly shared his decision yet on 17 June 2019 

CRAAD-OI : Research and Support Center for Development Alternatives – Indian Ocean ;

Collective for the defense of Malagasy Lands – TANY ;,

References :

(2) (,
(4) (
(5) mars 2019).
(6) (,
(7) 26 mars 2019 : 06:00 - DÉVELOPPEMENT DU TOURISME - Les zones de développement prioritaire pour le développement du Tourisme sont les régions Diana, Boeny, Itasy, Menabe, AtsimoAndrefana et Anosy, les localités de Sainte Marie et d’Antananarivo, ainsi que les zones en périphéries des Parcs nationaux.
(8) ;
(9), ;
(12) « Elevated levels of U+Th (above an industry norm of 500 ppm for premium zircon) may limit access to some geographic markets (e.g. Japan and USA will not currently be accessible) » page 17 du PFS (traduction française par nos soins)