Fishermen on the lake in Mandena

Please see the Andrew Lees Trust’s WATER BRIEFING for the main summary findings from studies conducted between 2018 – 2019

This blog post provides a brief UPDATE regarding the latest water data as well findings from new research into community perceptions of water quality around the QMM mine in Southern Madagascar.

French version of this update available here


The Rio Tinto QMM mine in south-eastern Madagascar generates radionuclide enriched waters, which it releases through surface discharge and groundwater seepage into the surrounding environment. Independent studies have demonstrated that in some places elevated concentrations of uranium, and lead, exceed WHO safe drinking water guidelines by up to 52 and 40 times, respectively. For the majority of the 15,000 villagers who collect their drinking and domestic water from the lakes and rivers surrounding the QMM mine, a recent survey shows most are concerned about the degradation of water quality over the last ten years and the possible health impacts from pollution.

Joint Action

The Andrew Lees Trust (ALT UK) together with Publish What You Pay (PWYP) in Madagascar and UK, and Friends of the Earth (England, Wales & N Ireland), have jointly collaborated as a group to bring attention to these issues, including via media coverage, blogs and events, advocacy, direct lobbying of the executives at Rio Tinto HQ and, together with the London Mining Network, also at the company’s AGMs. The group has demanded that Rio Tinto recognise QMM’s contamination of local lakes and rivers where thousands of local people collect their domestic and drinking water, that it urgently manages the mine’s waste-waters, and provides access to safe drinking water to the affected communities.

New Water Data and Analyses 2020

Following recommendations made by Dr Stella Swanson (Swanson, 2019), Rio Tinto commissioned a twelve-month radioactivity study by JBS&G at the end of last year. In July 2020, QMM shared the first water data from JBS&G with the group and claimed “all results…were within the relevant WHO guidelines for drinking water quality.”

In order to provide an independent assessment of the data and these conclusions, the Andrew Lees Trust (ALT UK) commissioned Dr Steven Emerman, a hydrology expert, to review the JBS&G study.

Dr Emerman noted that Rio Tinto did not acknowledge the existence of any pre-existing water data in its objectives for the JBS&G study. In this regard, Rio Tinto failed to adhere to standard procedure.

Analysis of the JBS&G water results by Dr Steven Emerman shows that the integration of the new water quality results from JBS&G (2020) with the results from previous studies (Swanson, 2019; Emerman, 2019) strengthens the conclusion of Dr Emerman’s findings (2019) that the QMM mine has a detrimental impact on water quality by showing increases in uranium, thorium and lead in surface water from the upstream to the downstream side of the mine that are statistically significant at better than the 99% confidence level. Please see the new Emerman 2020 report here

He goes on to explain that “Even repeating the new water-quality study 20 times with the same results, and combining the additional results with the existing data, would still yield increases in aqueous uranium and lead from the upstream to the downstream sides of the mine that would be statistically significant at better than the 99% confidence level.”

In concluding his analysis of the JBS&G water report Dr Emerman warns that “the collection of additional data for the sole purpose of reversing the statistical significance of an existing conclusion is not a recommended procedure”.

Access ALT UK’s independent studies here: http://www.andrewleestrust.org/studies_and_reports.html

Community Perceptions and Concerns

A study by Publish What You Pay Madagascar (PWYP MG, November 2020) of the perceptions, concerns and needs of the local communities living around the mine in Mandena concur with the groups’s recommendations and reinforce the demand for safe drinking water.

Over half the population interviewed in a recent study of community perception of water quality around Mandena draw their domestic and drinking water directly from the surrounding lakes and rivers, and more than half of the users of surface water respondents deemed it of poor quality and having been degraded over the past ten years, being either suspicious in colour, bad tasting or foul smelling.

These perceptions were confirmed during focus groups which noted “strong pollution” since the installation of the QMM weir and mining operation. Villagers see that the change in the water quality over the last ten years (since the mine began its operations) has had a detrimental effect on their health, their livelihoods – principally fishing, and consequently on their income. 

Local leaders and notables in the three communes perceive the water to have bad effects on the health of the population, and a significant number attribute the degradation of the water quality to proximity to the QMM mine operations (extraction of the sands). More than half of the respondents reported health problems in relation to local water consumption, and almost all who draw their water from surface water reported health issues related to water, with over half perceiving the mine to be responsible for the poor quality of water (due to mine waste).Contamination of their water source is a principle concern of the communities. More than half of those surveyed have already taken their concerns to the local authorities, and/or to QMM. However, the researchers observe from the discussions with villagers that locals fear repression and/or imprisonment for making complaints. Please see the PWYP MG Mandena report.

Almost all those villagers who use surface water sources want support for and restitution of access to good quality water. A number also claim they want compensation for damage done and remediation for the impacts of polluted water.

Publish What You Pay Madagascar invitation to a meeting in Antananarivo on 4th December 2020 for a presentation about water contamination issues around the Rio Tinto/QMM mine in Anosy

Recommendations and Requests for Safe Drinking Water

Dr Emerman emphasises that “enough data have been collected by both the mining company and the community to show the need for Rio Tinto to prevent further discharge of contaminated mine water and to provide appropriate water treatment to the community without further delay, especially considering the potentially serious consequences of uranium and lead poisoning”.

Dr Swanson recommended that Rio Tinto provide safe drinking water to communities in her 2019 report. She has cautioned that “it is certainly too early to dismiss the possibility that uranium and other metals pose a risk to human health”[1].

International experts, Malagasy civil society (PWYP MG, CRAADO-OI/COLLECTIF TANY, Plate-Forme Nationale des Organisations de la Société Civile de Madagascar PFNOSCM), international NGOs and environmental campaigners (ALT UK, PWYP UK and Friends of the Earth/Craig Bennett) and local communities in Mandena, have all raised concerns, made clear recommendations and demanded investigations into the QMM mine concerning the fears around its impact on the environment, local governance, water contamination and local communities’ health and livelihoods.

Rio Tinto must accept responsibility for the elevated levels of uranium, thorium and lead related to its QMM mine operation in Anosy region, transparently demonstrate how it will manage the QMM wastewaters more effectively, and immediately provide safe drinking water to local communities.

[1] Email correspondence from Swanson to ALT UK August 2020.

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Environmentalism in a time of Covid

An Article by Tony Long, Trustee of Andrew Lees Trust. The original is published by the Harkness Fellows Association – available at https://www.harknessfellows.org.uk/features/environmentalism-in-a-time-of-covid

Not a year goes by without news of some environmental disaster happening somewhere or another around the globe. 2020 is no exception. Wildfires across Australia and California, temperatures of over 35° Celsius in the Arctic, locust swarms in eastern Africa brought on by exceptional
climatic conditions, hurricanes along the Gulf Coast and perhaps the worst fire season in the Amazonian forests on record. These events are coming on top of the daily normal which include the dangerous levels of air pollution in world cities, huge floating islands of plastics in the oceans and the extinction of terrestrial and marine species just about everywhere.

And just when you thought it could not get any worse, along comes the SARS-CoV-2 virus. The steady disappearance of previously uncultivated wild lands, and the ensuing transfer of animal pathogens into humans, is now commonly thought to be a principal cause of the resulting pandemic. Environmentalism has morphed into a first order public health concern and gained a place in mainstream politics, a far cry from its previous frequent put down as a niche concern of tree huggers.

Gro Harlem Brundtland, Prime Minister of Norway and Chairwoman of the World Commission on Environment and Development, addresses the United Nations Conference on Environment and Development (UNCED) held in Rio de Janeiro, 3-14 June 1992. The World Commission Report, ‘Our Common Future’, published in 1987 is widely credited with bringing the concept of sustainable development into the political mainstream.

And not before time. How did it come to this? How did we miss the early warnings sounded decades ago by leading scientists and academics, including Rachel Carson, Garrett Hardin, Gro Harlem Bruntdland, the Club of Rome and many others? How did we allow a perfect storm of climate disruption, degradation of nature, resource depletion topped off by a global health pandemic, and all the resulting human misery, to come and smack us between the eyes in 2020?

Fifty years ago, on 1st January 1970, President Richard Nixon signed into law the US National Environmental Protection Act (NEPA), landmark legislation setting a model for the rest of the world. It is interesting to look back at the Act’s Preamble to see the early beginnings of green thinking – a vision tempered somewhat, at least for deeper green environmentalists, by its pronounced utilitarian leanings.

“To declare national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation….”

On the other side of the Atlantic, public opinion in Europe was shifting. A growing number of pollution incidents started to capture public attention, more localized in the 1950s and 60s but becoming regional and even global in their impact in the following two decades. Acid rain particularly affecting Scandinavia, the widening hole in the ozone layer and the Chernobyl nuclear disaster in Ukraine in 1986 all showed the limitations of national borders in guaranteeing environmental and hence national security. These, and other environmental controversies of the time, helped to kick start European countries and institutions on a journey that three or four decades later would see them emerge as the global environmental leaders on the world stage.

That world stage included a succession of United Nations Earth Summits held roughly every 10 years or so since 1972. Looking back, the high water mark for the environmental movement may have been the 1992 UN Earth Summit in Rio de Janeiro. Not just the US and the EEC, of course, but over 100 Heads of State and Government joined in agreeing a far reaching global environmental concord, the so-called Agenda 21. A desertification convention, a convention on climate change and a biodiversity convention were all opened for signature at the conclusion of the global summit.

There have been many setbacks since. The political events of the last 30 years, including the aftermath of the 2001 terrorist attacks in the United States as well as the 2008 financial collapse, have had huge chilling effects on progressive policies across the board. Environmental policy is not alone in having suffered from these geopolitical “earthquakes” which obviously diverted political attention elsewhere; social and human rights policies were clearly other casualties.

But the environmental field had particular characteristics to contend with. The most obvious is the increase in human population numbers, roughly speaking a doubling of global population over the past 50 years to now stand at 7.8 billion people.

It is not only the numbers that matter. Rising living standards and disposable income available to people across the globe have led to ever increasing consumption of resources and fueled wildly optimistic expectations of unlimited planetary abundance. Put simply, nature is competing for space with people and is invariably the loser.

The curse of “market failure” as it relates to environmental goods and services is another. The negative consequences for the environment of pollution in its many forms are often dismissed at best as a necessary price of growth or, at worst, simply as “externalities”. Nature gets short shrift by virtue of seeming to have no intrinsic value in the modern calculus which falsely equates rising economic growth with increased human well-being.

Sir David Attenborough addressing a WWF audience. The WWF Living Planet Report published by WWF in September 2020 revealed that the population sizes of mammals, birds, fish, amphibians and reptiles have seen an average drop of 68% since 1970. https://livingplanet.panda.org/en-us/
WWF photo/Michael Owens

And now a global pandemic has laid waste to some of the pillars of the global economy bringing parts of it to an almost complete standstill. In doing so it has given rise to an intriguing question. If the coronavirus pandemic can unlock trillions from national exchequers to mitigate the worst economic, social and human impacts of the deadly disease, then why not a similar level of response to head off run away climate change or biodiversity extinction or any of the other environmental threats looming large? After all, their consequences are likely to far outstrip the virus in terms of adverse impacts on human populations and on national and regional economies.

Questions like these raise the interesting prospect that investing in greener futures suddenly looks a lot brighter than it did even just a few short months ago. But it is by no means certain that the profundity of the intersecting crises now upon us has penetrated mainstream political thinking. For that to happen, there has to be a much bolder recognition in mainstream politics that future economic development depends on well-functioning ecological systems and a continuing abundance of natural resources necessary to sustain life on earth. This was of course the original vision foreseen in the framing of the US National Environmental Protection Act 50 years ago. With hindsight, perhaps the utilitarian perspective on the environment foreseen in NEPA’s opening articles was not so far off the mark, at least given the predicament we find ourselves in now.

About the Author

Anthony Long served as a legislative assistant in the US Congress as a Congressional Fellow of the American Political Science Association followed by political appointments in Oregon and New Mexico. He later founded and led the World Wide Fund for Nature’s (WWF) European Policy Office in Brussels for 25 years. He is a Trustee of The Andrew Lees Trust.

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CERCLE – Access to education for disadvantages children in Anosy Region, Southern Madagascar

The Andrew Lees Trust continues to find ways to generate support for the activity of local NGO Andry Lalana Tohana (ALT MG) and its work in the south of Madagascar .

In 2019 ALT MG launched the CERCLE – the Centre for Education, Reintegration, Communication and Exclusive Leadership, with funds provided by the UK based Aldama Foundation.


ALT Mg’s CERCLE programme is based in Ft Dauphin, Anosy region, southern Madagascar and helps disadvantaged children and young people to access vital education and training. Last year the CERCLE advanced literacy and numeracy classes for over a 100 children from the most disadvantaged households in five communes of Anosy. The classes enabled children who would otherwise fall out of education from the state system to re-enter full time education at the state school, with the necessary skills and equipment.

108 children advanced from the CERCLE into main stream state schools in Anosy at the start of the school term in October 2019.

The Regional Directorate of National Education (DREN) had motivated local school directors to prioritise the children from the CERCLE into the mainstream school classes. However, a test was carried out first in order to determine which level of class each child should be placed.

of the 108 children from the CERCLE, 56 children were placed in primary school class level T1, 49 in level T2 and 3 in level T4

Receiving primary schoolFokontany (village) Number of CERLE students received
EPP OISSELAmparihy39
EPP Centre IBazaribe18


Some students came regularly to the CERCLE office after they began at their new local school in order to tell their ex-trainers about their progress and their day in class. CERCLE trainers also visited the four schools at least once per month from the start of the new school year to monitor progress. The teachers congratulated them because the children of the CERCLE are among the best in class:  

“We have no difficulty in teaching the children from the CERCLE, they are assiduous and motivated”

Children from CERCLE enter the state primary school


A meeting was held at the CERCLE with the parents of students in October 2019 so that they could have information on the results of the CERCLE training given to their children and to discuss the next steps in the programme.

A substantial problem for parents of students at the start of the school year is to find the necessary funds to pay the school entrance fees, school supplies and the required clothing for each child (apron and formal wear). Parents whose children were identified to participate in the CERCLE programme do not have stable working lives or regular income generating activities, and they look every day for the means to provide for the basic needs of their families.


Child receives notebook and pens and backpack from the CERCLE

In order to support the children’s’ entry into the local schools, the CERCLE took charge of:

– Registration fees, overheads and insurance for each child-

– All school supplies with schoolbag

– Outfits: apron, t-shirt and party outfit (pants / skirt with shirt)

Parents of students were extremely happy because they would never be able to afford all of these supplies for their children.

Parents thanked the CERCLE / ALT for the assistance with equipment and school registration fees. They hope that the programme will continue in this direction for other parents who also want their children to be educated but lack the means to make it happen.


Young people enrolled at the Life Skills programme in class at the CERCLE

This CERCLE programme was introduced to young people over 15 who have not had the chance to continue their studies for various reasons, for example: inability of parents to pay school fees, pregnancies during studies or early marriage, absence of parents.

The training supports young people to strengthen their capacities to assert themselves, to have confidence to say “no”; to set goals; to make decisions, and to manage emotional situations.

An information meeting was organised at the CERCLE office in October 2019 and 48 young people were identified for the class. The identification of young people was carried out in collaboration with the Presidents from each of the fokontanys (villages) who participate with the CERCLE programme: Tanambao, Ampotatra, Esokaka and Amparihy.


Role play in the Life Skills training programme for young people
Role play in the Life Skills training programme for young people

The programme extended across 16 sessions and covered a variety of themes including understanding child rights, substance addiction, health, nutrition, sexual reproductive health, child marriage, abortion, polygamy (still practiced in the south), violence (e.g. forced labour), communications and environmental awareness.

Many of these young people already have a work occupation to support their family as a cleaning lady, a help in a store, or accompanying younger children to the school. Consequently, it was difficult to find a time which was favourable for the sessions. Unanimously 2 afternoons per week were approved: Wednesday afternoon and Saturday afternoon. A revision of the previous session is always carried out with the active participation of the young people for those who were absent from /missed the session.

29 young people followed and completed all 16 of the life skills sessions

mini dramas and role play help young people explore difficult subjects in class, especially around gender relations

A small evaluation was carried out after session 10 by answering the following questions:

  • Name 5 of the 10 themes we saw
  • List 2 themes you like, their definition and their life skills
  • What theme do you dislike, why?

According to the evaluation, 99% of the young students had learnt about the 10 themes covered, the definitions and life skills generated, and there were no themes mentioned that were not appreciated.  The sessions are largely participatory.

The classes were closed by the Director of ALT using cards for each of the big ideas from the 16 sessions. The slogan “Tanora vanona sy vonona” (worthy young people ready to take charge of their lives) was shared and adopted.


After the parents’ meeting for the students on October 4th, before the start of the school year, some parents asked if they could learn to read and write too as they were not fortunate enough to learn when young.

The request came from each individual and it was difficult for the ALT team to refuse, even if this activity was not planned in the CERCLE programme and the parents had no free time to learn except Sunday afternoons at midday. Their needs were met.

16 mothers attended literacy training at the CERCLE

Mother of a CERCLE student attends adult literacy class at the CERCLE

The training follows the same programme as that for children. The sessions are not yet complete. Nevertheless, some mothers have already developed the ability to read and write their names and are able to do simple maths e.g. addition.

ALT MG is seeking funding to support the delivery of vital education to 600 children and young people in 2020-2021 – whilst ensuring maximum safety through the pandemic and providing school meals to strengthen the most vulnerable, youngest children.

The Andrew Lees Trust (ALT UK) continues to assist local NGO Andry Lalana Tohana (ALT MG) in its work by helping with proposal writing/preparation and seeking donors to support ALT MG’s work directly. The Trust promotes the strengthening and autonomy of local civil society in Madagascar.

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Open letter with questions to Rio Tinto from five countries – including Madagascar (regarding the QMM mine in Anosy)

Open letter to Rio Tinto demands answers to questions posed by civil society actors/NGO representatives acting for communities in five countries where Rio Tinto mines (and proposed projects) are having detrimental impacts, violating the environment and abusing human rights.

Read the joint May 2020 joint letter to Rio Tinto here

Read the follow up joint letter of July 22nd to Rio Tinto here

This year, the Rio Tinto shareholder engagement part of the 2020 AGM was held virtually due to Covid-19 restrictions.

Eight organisations for five countries that are host to (or currently threatened by) Rio Tinto mining projects – Papua New Guinea, Arizona USA, Serbia, Mongolia and Madagascar – brought questions for the Board of Directors and were invited to submit these either via email or to dial them in via a free-call facility.

As this was a new format for the company and for shareholders, it was unsurprising that there were some technical difficulties, although a multi-billion dollar company like Rio Tinto might have been expected to provide a state of the art, customised service that would have offered visual connectivity, good sound quality, and allowed for direct calls from two of the countries where the company has mines (Madagascar and Mongolia).

Technology aside, the main issue was the lack of substance in the company’s responses, and the inevitable dissatisfaction arising from the answers to those questions that were asked. The frustrations were multiplied for those who sat in a phone-in queue never to have their questions and concerns voiced because the facilitator reported no more calls on the line – when there were.

For more about the Rio Tinto/ QMM mine in Madagascar issues read here

For those who were able to connect at the AGM, and for those were not but who have sent written questions to the company and still not received full answers, the failure of Rio Tinto to be responsive in any meaningful way is not being ignored.

An open letter has been sent to the company demanding that questions be answered in full and supporting documentation provided , where relevant.

This is a joint action co-ordinated by London Mining Network. The Andrew Lees Trust is a member of the network and was also a participant at the 2020 AGM, alongside Publish What You Pay Madagascar, to ask questions about the QMM mine in Anosy.

The company has been given 21 days to respond.

UPDATE July 2020

Rio Tinto having failed to respond to the questions raised at the AGM and in the subsequent letter sent in May, in July the nine organisations sent a further follow up letter to Rio Tinto asking when they can expect answers. Visit London Mining Network

and read the letter :

Read the follow up joint letter of July 22nd to Rio Tinto here

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WATER BRIEFING : an introduction to water contamination and environmental governance issues surrounding Rio Tinto’s QMM Mine in Madagascar

QMM mine in Mandena (2018)

The Andrew Lees Trust 2020 Water Briefing on the QMM mine buffer zone breach and water contamination issues is now available


Between 2013-2014, Rio Tinto’s mine in Madagascar, operated by subsidiary QIT Minerals Madagascar (QMM), exceeded its authorised permissions in the Anosy region in southeast Madagascar where the mine extracts ilmenite, an ingredient of industrial whiteners. QMM breached an environmental buffer zone designed to protect local waterways, and encroached onto the bed of the adjacent Lake Besaroy in an estuary where local people fish, gather their drinking water and emergency food supplies.

A key concern arising from the QMM breach has been the health risks related to the discharge of QMM mine wastewaters containing concentrations of radionuclides (uranium and thorium) and heavy metals (lead) well above WHO guidelines for safe drinking water.

As part of its advocacy work, the Andrew Lees Trust (ALT UK) has produced a Water Briefing to bring together in one place the key findings from independent hydrology and radioactivity studies, which it commissioned as part of its research into the QMM buffer zone breach and QMM impacts on regional water quality.

The Briefing includes broader human rights and environmental governance themes which are not explored in the expert’s studies, but which are pertinent and may help frame discussions about the concerns arising and what and who might be involved to address them.

The ALT UK Water Briefing is not exhaustive on the subject matter, nor is it designed to present all the views of Rio Tinto; it cannot cover all the technical aspects of the exchange between ALT UK and the mining company in detail. However, ALT UK is able to provide the relevant documentation to support and substantiate statements, as necessary.

After more than three years of research and advocacy, ALT UK and collaborating NGOs continue to lobby the mining corporation Rio Tinto to address water contamination related to the activity of QMM in Anosy region – in particular to demand the provision of safe drinking water to communities living around the mine.

To access all the relevant studies see here

To access media articles see here

To read related blogs visit here


Violating the environment

  • In the waterways of Mandena where local people fish and gather their drinking water, the QMM mine is discharging its process waters from ilmenite and monazite extraction. Additionally, lakes and waterways adjacent to the mine are only protected against seepage or overflow of mine wastewaters from the QMM mining basin by a dam of stacked mine tailings made of reject sands (tailings).
  • Despite the company’s public assurances that it is managing its mine tailing facilities to the highest standards, the QMM ‘berm’ (or dam) structure was found to have breached permitted buffer zone limits by at least 90 metres in places and entered the adjacent lake (Emerman, 2018; Ozius, 2018; Rio Tinto, 2019).
  • The breach raised concerns about possible toxic impacts on the waterways and lakes. A review of the radioactivity of the Rio Tinto QMM mine by Dr Stella Swanson (2019) identified elevated levels of uranium in the waters surrounding the QMM mine 50 times higher than the WHO guidelines for drinking water in some places.
  • Elevated levels of uranium are a serious concern because they can create health risks. Exposure to high levels of uranium in drinking water for a long time could affect kidneys and bones (Health Canada, 2019). Young children, infants and foetuses are particularly vulnerable to exposure from lead contamination.

Water contamination related to QMM activity

  • To address Rio Tinto’s claims that the uranium levels in waters around QMM operations were all naturally occurring, ALT UK advanced additional studies.
  • Mineral sands in the region of Anosy have unusually high background radiation. However, it is a common occurrence for radionuclides such as uranium present in mineral sands to be concentrated by the extraction process, and to levels that are “problematic” (WHO 2011). Swanson explains “while uranium naturally occurs in the ore, once the ore is dug up and processed, uranium is released into the water in larger quantities than if it was left in place on the ground”.
  • Swanson reviewed the QMM data (August Memo, 2019) and found elevated uranium in the QMM mining pond, as high as 1.9mg/L, and concludes “The QMM mine definitely releases more uranium into water on the site, thus creating an enhanced source of uranium to the Mandromondromotra River and Lac Ambavarano (Swanson Memo, 2019).
  • To further explore the source of elevated uranium, water samples were collected by local residents/researchers from sources downstream and upstream of the QMM mine site in 2019. These were sent to a US lab and tested. The results analysed by expert hydrologist, Dr Emerman, demonstrated “a detrimental impact of the mine on regional water quality, indicated by the increases in uranium, thorium and lead in surface water from the upstream to the downstream side of the mine, which are statistically significant at better than the 99% confidence level” (Emerman, 2019).
  • The studies by Swanson and Emerman demonstrate surface and groundwater discharges from the QMM mine have resulted in increases in uranium, thorium and lead in surface water from the upstream to the downstream side of the mine. Both have called for the immediate provision of safe drinking water for communities.

Failures to act

  • At their AGMs in 2019 and AGM 2020 Rio Tinto has denied any relationship between QMM’s mine and uranium levels in adjacent lakes and waterways; the company claims that the uranium levels are consistent with naturally occurring radioactive material (NORM) in this region; they also claim that the QMM extraction process does not involve any chemicals (which is irrelevant) or change anything in the natural environment and there are no health impacts. They have not been able to provide any evidence to substantiate these claims.
  • There are no available health studies that demonstrate monitoring of health impacts from the mine in the region. While there has yet to be an in-depth health study, available indicators are significant enough to require action e.g. given uranium concentrations are as high as 1 mg/L in Lac Ambavarano near the weir, alternative safe drinking water must be provided.
  • Rio Tinto acknowledges that its “process water may have higher concentrations of minerals and metals than deemed safe by drinking water standards”‘. (Rio Tinto, letter Feb 2020)
  • Rio Tinto’s explanations of QMM’s wastewater management process are not in themselves evidence that the “settling time” provided by the holding pond system prior to release of wastewater from the mining site into the surrounding environment is successfully addressing contamination issues (ibid).
  • Rio Tinto/QMM is unable to provide evidence that levels of uranium and heavy metals in wastewaters leaving the QMM site into adjacent wetlands and streams are “under permitted limits” or are “safe to the community and the environment” (ibid).
  • Rio Tinto has attempted to publicly assuage concerns about the QMM buffer zone breach and the uranium levels by quoting the government regulator, the Office Nationale pour L’Environnement (ONE), who they claim has deemed the impact of the QMM buffer zone breach to be “negligible”. However, neither the ONE nor the company have been able to provide any evidence for the basis of such a status, e.g. technical surveys/reports.
  • Swanson criticised QMM’s monitoring of radionuclides for ingestion pathways e.g. via water, food, and soil, as “unacceptable”. Rio Tinto has advanced radioactivity research only after issues were raised by ALT UK at the Rio Tinto AGM in 2017, and in 2019 following Swanson’s review.  However, if earlier reports had been acted upon, QMM would have advanced “expected” further studies some six years previously, based on a World Bank report that flagged “measurements that indicate a higher level of radioactivity in areas that have been mined” (World Bank PIC IAP, 2014).

Call to action

  • Following the release of ALT UK’s water studies in December 2019, Malagasy civil society platforms have demanded an investigation and an audit of the QMM social and environmental issues.
  • Andrew Lees Trust (ALT UK), Publish What You Pay (PWYP UK and Madagascar) and Friends of the Earth (England Wales and N Ireland) have lobbied for urgent action by Rio Tinto to  1) provide safe drinking water to communities 2) manage QMM wastewaters 3) improve transparency around environmental monitoring and 4) ensure an open and inclusive communications campaign to educate and inform local people.
  • 10 Malagasy CSOs and 20 international supporters have signed a letter to the Government of Madagascar to review arrangements between the mining company and the environmental regulator, the National Office for the Environment (ONE) to improve environmental monitoring and transparency around the mine.


Necessity to acknowledge and act

  • A key action required under WHO guidelines is the provision of alternative sources of safe drinking water (WHO 2011) for the communities affected. Approximately 15,000 people are situated close to the Mandena mine site and are affected by its impact on the immediate environment. They rely on rivers and lakes around the QMM mine for their drinking water, food security and survival.
  • Provision of Safe drinking water requires Rio Tinto/QMM to accept that management of the risk associated with QMM mine-related uranium concentrations in receiving waters is a priority (Swanson, 2019).
  • Rio Tinto corporate and sustainability pledges demand the company recognise the multiple benefits of the provision of safe drinking water to nearby communities in accordance with its commitment to the management of human rights risks, including risks to water resources, and to directing benefits to those affected by mining activities.
  • Rio Tinto needs to ensure equitable inclusion of local stakeholders and affected communities. This includes developing local staff and community capabilities in communications, social engagement and environmental monitoring skills in order to increase understanding among community members, contribute to informed and inclusive decision making, and provide independent monitoring of the mine’s radiation levels, water quality and other environmental impacts over the project lifetime, and beyond.

see all at www.andrewleestrust.org/advocacy.html

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RIO TINTO 2020 AGM : questions about the QMM mine in Madagascar

Malagasy civil society Representative Eryck Randrianandrasana

Eryck Randrianandrasana of Publish What You Pay Madagascar (PWYP MG) had planned to come to the UK to participate in the Rio Tinto AGM and ask the company some thorny questions about its QMM operation which is mining ilmenite in the south east corner of his country. The London Mining Network was supporting Eryck’s travel and participation at the AGM, in collaboration with its member organisation The Andrew Lees Trust (ALT UK) . The Trust has been working closely with PWYP MG and PWYP UK since 2018 to address questions arising around the QMM breach of a buffer zone and related environmental and governance issues.

This year’s Rio Tinto AGM was held virtually because of the Covid 19 restrictions. There was no visual contact with the RT executives and rather poor sound quality. There was no dial in number/code for Madagascar for the virtual AGM, so Eryck was having to call in using the internet via a UK freephone number. The line cut every ten-fifteen minutes.

Eryck had already submitted his question in advance and it was the first to be read out by the Chair of Rio Tinto, Simon Thompson.  Yvonne Orengo, Director of Andrew Lees Trust (ALT UK), also attended the virtual AGM to pose questions about QMM and the contamination of local waterways.

BELOW is a transcription of the exchange at Rio Tinto’s 2020 AGM concerning the QMM mine (caveat: any omissions or incorrect words are due to poor sound quality)

FIRST is some commentary …….

The Q&A raised more issues than it provided answers: The company completely avoided the issue of there being no evidence on which they based their claim to shareholders in 2019 that the impact of the QMM buffer zone breach was “negligible”. Instead the CEO talked about overflow incidents that happened at least four years later, emphasising the national regulator, the National Office for the Environment (ONE) ‘s actions on these matters. Any recent improvement in monitoring of QMM by the ONE is subsequent to complaints formally raised with the Malagasy Government about failures in environmental governance, transparency, and concerns that the ONE – QMM relationship in Anosy was compromised.

Rio Tinto tried to highlight the lack of chemical additives in the extraction process to defend questions about QMM’s water contamination. The mention of chemicals is designed to obfuscate. The contamination is caused not by chemicals but because in separating the mineral sands – sands which contain naturally occurring radionuclides such as uranium and thorium – the extraction process concentrates radionuclides and heavy metals in the mining pond. This concentration effect is a well know phenomena of mineral sand extraction (WHO 2012). Elevated uranium is clearly identified in the QMM mining pond water using QMM’s own water data by Dr Swanson, a radioactivity expert, and as high as 1.9mg/L. Swanson concluded “The QMM mine definitely releases more uranium into water on the site, thus creating an enhanced source of uranium to the Mandromondromotra River and Lac Ambavarano.

Rio Tinto has been unable to provide scientific evidence to counter ALT UK’s additional independent water study findings by Dr Emerman, which have reinforced Swanson’s findings, demonstrating elevated uranium, thorium and lead and QMM’s negative impact on downstream water quality with 99% confidence. Nor can the company demonstrate that QMM’s water management system using settling ponds (paddocks) successfully removes the contaminants so that waste waters are “safe for the community and environment” when they are discharged. They simply say it does.

Separately, the radioactivity study that Rio Tinto cites (ALT UK’s independent study by Swanson, 2019) explains that it is impossible to draw general conclusions about radiation impacts of the mine, due to the “unacceptable” level of QMM monitoring. However, the study was able to identify elevated uranium in water 50 times higher than WHO guidelines and recommended safe drinking water provision. The radiation study Rio Tinto is now undertaking is their first to address radiation in the wider environment e.g. ingestion pathways post mining, but will not measure environmental contamination such as from heavy metals. The other studies mentioned by Rio Tinto were pre mining in 2001 (baseline), then focused on worker exposure (2012); one followed ALT UK raising the radiation issue in 2017; and the “2018” study was in fact ALT UK’s independent review by Swanson, published in 2019, in which all previous, available QMM studies were reviewed. There are no available health studies about the impacts of the QMM mine in Anosy.

The water contamination, and the lack of safe drinking water provision remain on the table. All the Trust’s independent studies are available here.

Transcription of Q&A Below

FULL AUDIO RECORDING of the Rio Tinto 2020 AGM is available HERE

Eryck’s Question is read out at 32.43 – with answers until 42.00

Yvonne’s question is presented 43.00 and answers /exchange to 50.55

Eryck Randriandrasana’s (PWYP MG) question to RT:

At its AGM last year Rio Tinto admitted that its QMM mine had breached a protective environmental buffer and had encroached onto the adjacent lake bed.  It said this was “a mistake”. Rio Tinto assured shareholders and the public that the impact of the QMM breach was “negligible”. It cited the Malagasy state regulator for this analysis. We have repeatedly asked for evidence as to how the regulator reached this analysis.

It is important because the breach raised concerns about exposure to contamination of local waters by QMM processing and local people fish and draw their drinking water from the lakes and rivers around the mine.

Rio Tinto knows that our requests to the state environmental regulator in Madagascar and QMM have failed to produce evidence that any technical studies were evercarried out by the regulator on this question. Last December, Rio Tinto told an international journalist “We are not aware of any formal inspection report”. That means Rio Tinto reported no “negligible impact” of the breach, knowing this was based on nothing.

Under its obligations to the people of Madagascar and its shareholders, Rio Tinto is legally obliged to report clear information about the status and risks of its assets, as well as those of its subsidiaries. Rio Tinto is also committed to applying the highest standards and, where local ones may fail to meet these, states Rio Tinto will default to its international standards.

Rio Tinto knows that the Malagasy regulator does not have the capacity to objectively monitor QMM mine performance against realistic indicators. Also, that the regulator has been financially dependent on QMM, which is a problem. Local people also do not have capacity to monitor the mine. For this reason, we have welcomed the independent studies about the QMM buffer breach, radiation issues and water quality. These studies provide clear evidence of water contamination downstream from the mine – with elevated levels of uranium, and lead, at least 50 times higher than WHO safe drinking water levels. We do not think this is a “negligible” impact of QMM on our environment.

We welcome QMM’s contribution to help the Covid 19 effort in Anosy – but if it can find the means and goodwill to do this, why won’t it provide safe drinking water to communities when its mine is contaminating their natural water sources…

Will RT produce hard scientific evidence that there is absolutely no water contamination from its QMM mine from heavy metals, and no negative environmental impacts or health risks to communities living around the mine?   If it cannot do this, will it 1) stop making unsubstantiated claims 2) provide safe drinking water to local people and 3) urgently mitigate its waste water and mine tailings management.

Jean Sebastien Jacques (JS), CEO Rio Tinto response:

The question relates to the QMM mineral sands operation in Madagascar. The poverty in this area is very high and Rio Tinto is making a “significant” contribution to Madagascar; it has invested 1 billion $ since construction began around 2000 employees and contractors and 95% are from Madagascar. 80,000 people in the region using electricity provided through the QMM partnership with the Jirama (utility provider). I have been to Madagascar a few times and met with the team and stakeholders. I have also met with ALT UK, PWYP MG and FOE so I have some knowledge of the items.

On the Buffer zone and role of the ONE. We had 2 incidents in 2018 following heavy rainfalls when there were uncontrolled water transfers into the environment from former mining areas. The ONE confirmed the water involved has no impact on people or the environment. ONE issued an initial warning and we subsequently received an official report from their investigation… ONE concluded where some of the transfers changed some of the perimeters of the water in the system, the system returned to normal within two weeks.

To prevent such incidents in the future, ONE provided a recommendation for further analysis. QMM carried out its own investigation to prevent such occurrences from happening again and the berms have been reinforced.  It’s important to know that we do not add anything, any chemicals to the water during mining. We are committed to meeting our commitments and responding to any recommendation by the regulator. In terms of the ONE, we follow Malagasy law, as we do in all our jurisdictions. We have provided Publish What You Pay with details on the governing regulations and the governance relationship with the regulator. We are obliged to follow the law and we are supportive of any action  to improve the governance and the regulatory framework including the chamber of mines dialogue with the government on this specific issue.

The question of water relates to the zones in mining lead area where the communities are not permitted. And also, the water supplies are outside of these. As already said, our process does not use any additive or chemicals only the water. The mining pond has high concentrations of suspended solids and a low PH as a result of the churning action of the mining process. The water from the mining pond is run through a circuit of settling ponds (paddocks) to passively remove the solids until the water meets the permitted criteria. We have been monitoring water quality and discharges into the natural environment since the operation began. All monitoring reports are reported to the Madagascar regulatory body. We continue to sample both water in the town and the outside environment as part of our ongoing monitoring programme and controls. Using these controls there is currently no evidence to suggest the activities at QMM result in health impacts to surrounding communities.

Now on radiation. It is worth noting that a limited amount of naturally occurring radioactive minerals such as uranium and thorium are characteristic of the geology in Madagascar where QMM is situated. The actual  scoping of public exposure as a result of QMM activities was rated low in prior baselines study that have been conducted.

After ALT UK raised concerns about radiation exposure pathways from these naturally occurring radioactive materials in 2018 we agreed to participate in a supplementary study to review once again the risk of radiation in this area. The report concluded that it’s highly unlikely that exposures to naturally occurring radiation as a result of NORMS exceeded the IAEA dose limits, consistent with previous baseline studies.

We agreed that available monitoring data does not currently allow us to prove this in a concrete way especially in terms of ingestion pathways. So, we have asked an international consultancy JBS&G to begin a year-long study from December 2019 to collect this supplementary data and the design of the study takes recommendation from the ALT UK report.   So, the work is underway and when we have the results, we will make sure that the relevant findings are made public and we are committed to all stakeholders as well as peer review panel of experts at the end of the study. So that I think covers most of the items raised by Eryck.

Yvonne Orengo, Andrew Lees Trust (ALT UK)’s question followed straight after by phone:

We welcome the new radiation studies as these were a recommendation of ALT UK’s independent review. But this does not address the urgent water contamination issues that we have urgently raised since last year. 15,000 people continue to draw drinking water from natural water sources around the mine which are contaminated by uranium and lead discharged by the mine.

You said last year and again just now that the mining process only uses water, and changes nothing in the natural environment…   but you have conceded in writing that the extraction process concentrates radio-nuclides, like uranium, and also heavy metals, in the mining basin; these are related to the mining operation and are well in excess of WHO safe drinking water guidelines. You have also admitted that the QMM ” process water may have higher concentrations of minerals and metals than deemed safe by drinking water standards”. 

Despite claims that your processes are monitored, and everything is “fine” you have not provided us or other CSOs with any evidence about how your waste water management using the settling ponds system is removing contaminants before the process waters are released into the local environment. You simply state that it does. Saying it does not make it true. We are still waiting for evidence. The burden of proof rests with Rio Tinto.

Meanwhile, local people are drinking water from these contaminated lakes and rivers and Rio Tinto refuses to provide safe drinking water to local communities, in line with WHO guidelines. RT/QMM knows that it can contribute to national potable water targets in Madagascar and must do so under the polluter pays principle. You did not answer this question from Eryck. Will you please provide drinking water to the community in Anosy and not put the burden of cleaning up water on the cash-strapped Malagasy government?


I can only repeat what I said. We are not using chemicals in our process at all, is the first thing. We are monitoring the quality of the water before it is discharged and at this point in time the monitoring shows us that the water is fine as and when it is discharged.

We shouldn’t forget that the very important point I just made about the geology of the ground in this part of Madagascar where you have uranium in the natural form and so on and so forth  so the baseline studies are very clear; the new studies will share this information – I fully accept there has been some delays in the study because of Covid 19 the laboratory which his doing the work is currently closed but I really hope this situation will change very quickly and we will be able to conclude the study in order to establish the facts so we can move from this position.

Yvonne responds

You keep re-emphasising that you don’t add anything, but you know that the process concentrates up the metals and radionuclides. The uranium in water downstream of the mine was 350 times higher than upstream. You cannot make the claim that there is no impact from the mine when these kind of results come through from water sampling tests;  it indicates there is a serious concern, concerns that were also raised by the radioactivity specialist whose result you never mention, which was that she found elevated uranium 50 times higher than WHO guidelines ; and her first recommendation was for the provision of safe drinking water to the communities. I am pleading with you, as I have for over a year, to please give communities safe drinking water.


So, you refer to one of the studies that you asked for and you shared the finding with us. Our experts did  review the latest report and we did summary response to yourself and your organisation at the beginning of this year but what the experts are saying is that we do not agree the findings are supported by the data…but we have taken the report ….. to support the year-long study by JBS&G.

Yvonne adds

But you said that your study will not look at water contamination so there is a disjoint.


We said we would do the work we said would do in order to establish the facts – but on the back of what we have we do not believe that the findings in the report are correct…so we need to have the science what we are saying is very important , we need to make sure there is no misunderstanding on the situation and then we continue the dialogue as we have for many years

Simon Thompson, Chair of Rio Tinto, said:

We have had third party audits of radiation issue in water in 2001, 2012, 2014 and 2018. We are now doing a fifth study using the consultants which JS referred to, and we will make the results publicly available and try finally to address this issue.



London Mining Network co-ordinated an online AGM action with multiple organisations, and questions collectively covered multiple themes including water and tailings management, environmental contamination, mine closure, governance and transparency, and related to the following Rio Tinto mines: QMM in Madagascar, Oyu Tolgoi in Mongolia, Resolution Copper in Arizona, Jadar lithium in Serbia Grasburg in West Papua, Panguna in Bougainville.

London Mining Network’s Report of the Rio Tinto 2020 AGM

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Remembering Andrew – Marking 25 years…..

Andrew Lees 1949-1994

At some point I had to stand up and be
counted. Who speaks for the butterflies?”

AT this time of year, the custom is to put the past behind and make resolution for the future. The turning of the year, a turning of a page, charged with new hopes and aspiration for the days ahead.

Sometimes, at this time of year it also helps to reflect and remember, what has been achieved, what learnt, and what can be measured out in memories and important moments from the time passed.

For the Trust, the ending of this year marks 25 years since Andrew Lees made his last, fateful mission into southern Madagascar to film its unique biodiversity and capture the voice of local people. He aimed to produce a campaign film to help protect the southeastern littoral forests from destruction by a proposed Rio Tinto mining project, set to change the lives of local people and their environment forever.

Andrew Lees, botanist, environmental activist and campaigner

1995 Film about Andrew’s mission to Madagascar

Andrew never walked out of the forest of Petriky. His spirit, and his love of nature met a final resting place in one of the most biodiverse places on the planet. A traditional stone marks the place where he fell and the local Antanosy people have designated the area around it sacred, recognizing Andrew’s spirit to reside there, along with their ancestors.

Andrew Lees Memorial stone in Petriky

In the year that followed, Andrew’s family, close friends and colleagues at Friend of the Earth where Andrew worked as Campaigns Director set up the Andrew Lees Trust (ALT UK.) The Trust first helped generate funds towards the launch and development of an environmental training centre, the Centre Ecologique Libanona (CEL). The schoolroom was dedicated to Andrew’s memory at the opening day in December 1995. A commemoration, and a small seed of hope planted in the sandy soil of Libanona.

Andrew Lees dedication plaque on the schoolroom at Centre Ecologique Libanona

The choice of supporting this centre reflected what Andrew’s family and partner believed he would want – something to help develop the skills of local people so they could advance the work of protecting their environment and shaping the future of their region. That small seed grew and bore fruit, helping hundreds of local Malagasy students to gain the higher education they needed over two decades. It also served as a learning centre for students visiting Madagascar from overseas, and a local training venue, creating an enriching exchange of cultures and ideas.

A training day at CEL

Libanona was to become the base not just of a CEL, which reached Malagasy University status over the course of its 20-year history, but also home to the Trust’s office and field programme in 1999. No one imagined we would still be serving the people of Madagascar twenty years later.

Between 1999-2009, the Malagasy team were trained and became experienced in the Trust’s approach, management techniques and working practices, which successfully delivered its programme for food security, natural resource management, communications, and non formal education using radio to communities in some of the most remote and challenged areas across the southern arc of the island.

ALT “Project Radio” 1999-2009 – and the wind-up radio with village listening group

Life has a way of turning circles, or perhaps more accurately spirals. Ten years into our work in Madagascar, in 2009, the Trust handed over to its local field team in a responsible exit. It supported the birthing of a Malagasy NGO directed and peopled by the local animateurs, technicians and managers from the Trust’s ten-year field programme. The team brought the skills and specializations they had learnt with Andrew Lees Trust (ALT UK) into their new organization, Andry Lalana Tohana (ALT MG).

The team of Andry Lalana Toahana (ALT MG) December 2019

Between 2009-2019 the Trust has supported the growth and development of the Malagasy NGO Andry Lalana Tohana, developing joint projects in equal partnership (2009-2013) and providing assistance in response to requests from the ALT MG management team to support their field programme and initiatives. These range from famine relief, food security and health education to communications for empowerment, including interactive media for human rights promotion and participatory video.

In 2019, we celebrate a decade of Andry Lalana Tohana’ s field programme. In particular its opening of a new local education centre, The CERCLE. The Centre for Education, Reintegration, Communication and Exclusive Leadership, is dedicated to helping the most underprivileged children and young of the Anosy region of southern Madagascar. It helps infants to gain basic literacy and numeracy skills, enabling them to enter the state school system; it also provides life skills training for young people and literacy classes for mothers.  142 children went through the first term at the CERCLE and reentered local schools in September – the teachers report that the children are achieving excellent results!

Antanosy children at the CERCLE in Ft Dauphin, Anosy Region, Southern Madagascar

This initiative reflects a cycle of dedication towards local empowerment and learning that underscores and echoes The Trust’s commitments when it began its story some 25 years ago: a commitment towards local ownership and leadership. A story of tragic loss turned into acts of hope.

The legacy of a man who inspired so many people – and whose name is immortalized in dedications in the UK, in Wales, London, Norfolk, as well as in Madagascar at Libanona, Petriky, and Ft Dauphin  – lives on in these acts of hope, like the CERCLE.

On December 14th, the team of Andry Lalana Tohana (ALTMG) held a ceremony and event to mark the 25 year anniversary of Andrew’s mission to Madagascar and his passing in Petriky. They created their own plaque to commemorate him and the 25 years.

ALT MG’s 25 year anniversary plaque for Andrew Lees

This coming year, in 2020, we give thanks for that inspiration and the legacy. Those who knew Andrew personally, worked with him, grew with him, and many who just met him for a moment, remember how he touched their lives.  Today, people who never met Andrew are still touched by his spirit, by the special character and passion he brought into the world. In Madagascar and in the UK, in connections that span across the planet, he is not forgotten.

Sorghum Festival in Androy: a celebration in the Trust’s food security programme for the reintroduction of Sorghum for drought affected communities

We extend our gratitude to all those who have worked with and supported, the Trust and its actions over the last twenty five years. We remember Marek Mayer, one of the Trust’s co-Founders, and Mme Olga Marovavy Solondrenibe of ALT MG, and we thank all who have contributed to honouring Andrew’s memory, and his legacy.

Immortal Love.

Commemorative Plaque to Andrew Lees created by ALT MG in Anosy

Hanitra Raharimanana (left), Director and Co-Founder of ALT MG, leads a celebratory dancing at the 25th anniversary event in Ft Dauphin
Co Founder of ALT MG Sosthene Robson (right) with team holding Andrew’s 25th Anniversary plaque
friends, family and team of ALT MG gathered in Ft Dauphin on December 14th for the commemorative event for Andrew Lees, marking 25 years
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Children with their school packs for the CERCLE class

In response to a request from local Malagasy NGO Andry Lalana Tohana (ALT MG) the Trust secured funds from the Aldama Foundation to help launch this important local initiative : The CERCLE, Centre for Education, Reintegration, Communication and Exclusive Leadership, for children and young people in the Anosy region of southern Madagascar.


In Madagascar, almost half of the population is under 18. Approximately 33% of those under are of school age within the Malagasy state education system, starting at the age of six. According to a study done by the World Bank, the level of education in Madagascar remains one of the lowest in the world; the average schooling rate for children aged 6 to 10 fell from 80% to 75% between 2005 and 2010. This rate is still decreasing in the southern part of Madagascar. The dropout rate before T5 (CM2) is 50%, especially in rural areas.

The city of Fort Dauphin has not escaped this situation despite the development of the city for the past 10 years. The high cost of living leaves the majority of vulnerable households to abandon the education of their children.

Lack of money for school supplies and fees is the main cause of school exclusion and leads to aggravating phenomena such as child labor. Young people attracted by easy money engage in prostitution. Young girls without occupation readily accept to marry early and experience early pregnancy, which can have long term impacts on the health and prosperity of the family.

A child sings at the launch of the CERCLE in Anosy region

In recognition of the importance of education as a key factor in development outcomes ALT MG launched the CERCLE : Center for Education, Reintegration, Communication and Exclusive Leadership, which aims to help children and young people who have not had the opportunity to access formal education or other training for various reasons, including:

  • High levels of poverty preventing the family from sending their children to school
  • Security issues (sexual harassment, violence, intimidation)
  • Girls deprived of education by tradition, boys’ education is considered more important
  • Girls become mothers (early pregnancy)

Depending on the case of children / young people, the CERCLE offers critical support for their schooling and social reintegration. The children have a fundamental right to appropriate education for their situation and such as can help them develop essential skills, critical thinking and self-confidence, creating a healthy foundation for them to succeed in their lives. The CERCLE is also open to young people so that they can discuss, ask for advice, and access practical training useful for their development and knowledge of new technology such as computers and the Internet.

The existence of the CERCLE will help these children / youth to flourish and access the education they need.


The CERCLE was launched by Andry Lalana Tohana (ALT MG) on 10th April 2019 after two months of preparations including building refurbishment, meetings with local authorities, identification of families and children for enrolment, location of additional local classroom space outside the CERCLE building, equipment purchases, and the training of teachers in literacy and life skills training.

Registration with families and children

The CERCLE Classes began on the 15th April 2019 for 142 identified children who were not attending school and who come from vulnerable families in four of the Fokontany (villages) in Tolagnaro commune.

The children were organized into separate classes according to their ability. Each student received the necessary school supplies including notebooks, pens, slates, rulers, and chalk. Blackboards were provided for each classroom.

142 students received four months of schooling in basic literacy, numeracy and life skills to prepare them to re-enter the formal state school system with the necessary capabilities.

Towards the end of August, students went through revision and final tests and the results act as the guideline as to whether the child is then able to return to primary elementary school level 1 (T1) of level 2 (T2) classes in the public school system.  During the holidays, the CERCLE students will join the public school for the CREN (National Education Review Course) before their level test for reintegration into classrooms in public primary schools closest to their homes.

142 CERCLE students will join classes in September in local primary schools. The Regional Director of Education had asked primary school principals to prioritise the return of students from the CERCLE classroom because he is convinced of the effectiveness of the methodology used by ALT MG at the CERCLE.


Meeting with parents at Tanambao


A series of courtesy visits was conducted with the local authorities and potential partners to announce the existence of the project and ask them for their support and collaboration. The local Prefect for the District remarked on the importance of the project in the urban commune and also expressed that he would like to see the expansion of the project in the most remote areas of Anosy region. The Mayor of the city of Tolagnaro, capital of Anosy, thanked the team for recognising that the city needs this project. He believes that this kind of project is a great help to reduce the juvenile delinquency that is gaining momentum in the city of Tolagnaro.

The eleven Fokontany chiefs (village leaders) of the urban commune were visited, although only four Fokontany were targeted for the first phase of the project.

Outreach- meeting with villagers in Isokaky

At the level of the Ministry of Education, the Regional Director of Education was very motivated to support this project because the activities are aligned with the national programme of education for the reintegration of children into school. He facilitated the ALT MG team to approach the School District Service (CISCO), ZAP Heads and School Directors.

During the courtesy visit to the Regional Directorate of Youth and Sport (DRJS), the Director of the DRJS was interested in the Life skills part of the CERCLE programme because the Ministry will be developing this activity in the region. They were poised to bring a Life Skills trainer to deliver a training course in Amboasary. The ALT MG team seized the opportunity and asked if they could attend this training. The Director gave his agreement and the team attended training from February 7 to 17, 2019.

The Regional Technical Assistant in the Child Protection Section of UNICEF came to the ALT MG office to learn more about the project.


For the first phase of CERCLE activity the main target Fokontany (villages) in the Tolagnaro urban community were: AMPARIHY, ESOKAKA, TANAMBAO, AMPOTATRA.  According to the information given by the municipality and the school district, these four Fokontany have a high rate of vulnerable parents with children who do not go to school.

Children registered for class by their families

After the presentation of the project in the Fokontany, the team asked the Fokontany Chief to support the ALT MG team in identifying those children who had not had the opportunity to go to school and those who could not continue to go to class because their parents do not have the means. Each Fokontany Chief had a village meeting to explain the programme to their community and invited parents to then register their child.

Community workers with the ALT MG team went door-to-door to ensure information reached vulnerable parents with children who do not attend class and who were not able to be present at the Fokontany meeting. The team obtained a list of children aged 6 to 17 eligible for literacy training that will encourage and enable them to return to formal state school class in the next school year.

Given the geographical challenges of the position of the ALT MG office, which is some distance from some of the four Fokontany of Amparihy, Esokaka and Tanambao, the ALT MG team requested collaboration from the Fokontany Chiefs that they find a room/space for the CERCLE children in their respective villages. Each Fokontany were able to use the CERCLE classroom or offered a dedicated space for the literacy classes in their commune.


The official launch of the project was carried out on April 10, 2019 at the CERCLE classroom space.

Director of ALT MG presents the CERCLE during the launch ceremony

The Representative of the Prefect of the Region, the Deputy Mayor, the representatives of the Ministry of Education (Chief ZAP), the Presidents of the four Fokontany, the Regional Technical Assistant in the Child Protection Section of UNICEF all attended, as did the parents and students.

The national TV reporter reported on the CERCLE Launch and the show aired on TVM.

The official opening of the CERCLE followed a series of speeches by the local authorities and by Mme Hanitra Raharimanana, Director of Andry Lalana Toahana (ALT MG). The opening was well attended and warmly welcomed by parents and authorities who recognize the need to reach and support the most vulnerable families and children in the region.

To increase awareness of the CERCLE, ALT MG also participated in the “day of schools” in Ft Dauphin, Anosy.

ALT MG team create awareness of the CERCLE at the “Day of Schools” in Tolagnaro


Two trainers from ALT MG already had literacy teaching capacity. To increase their capacity in teaching literacy to young children, ALT MG appealed to the FFMM Grand Trainer (Fifampiofanana Fanabeazana Fikolokoloana Ho Malagasy Mahomby) based in Fianarantsoa, a specialist recognized in the effective Methodology for literacy training throughout Madagascar.

In addition to the specialised training, all the necessary tools including reading books, calculation books, brochures and mimeographs were provided to the trainers.  The training for trainers took place over two weeks from May 31 to June 15, 2019.

Training of CERCLE Trainers in Amboasary

As well as literacy training, young people will also have support and training in Life Skills so that they can have the capabilities necessary for advancing their personal life, education and work prospects.  This includes building important psychological foundations such as confidence and self esteem.

The two trainers of ALT MG attended a life skills training of trainers organized by the Regional Directorate of Youth and Sport (DRJS) of Anosy from 7 to 17 February 2019. This has helped to provide them with the necessary coaching elements that they can use to support youth for strengthening their psychosocial skills


To ensure that each child will receive the support needed during their learning process, a maximum of 25 students per class was established.

Children in literacy class at the CERCLE classroom

After identifying the children in the four Fokontany, a small test was conducted to facilitate the grouping of students according to their ability.  The test results enabled two classes to be set up: one class for those who never attended school  (T0) and children who have already gone to primary elementary school 1  (T1) ; and a second for those who had already gone to primary elementary school 2 (T2).

Two classes per Fokontany were organized and two ALT MG trainers were allocated to take care of the students as part of this CERCLE project. The class hours are the same in the four Fokontany from Monday to Thursday; Friday is devoted to preparation of next classes by the trainers.  Classes T0-T1 works from 8h to 11h in the morning and classes T2 and more from 14h to 17h in the afternoon.


THE CERCLE is now helping the mothers of children attending the CERCLE and who have asked to learn how to read and write. ALT MG trainers go beyond the call of duty to teach at the weekend because these mothers have to work weekdays in order to meet the needs of their families.


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Fisher village in Anosy, southern Madagascar

As part of its research and advocacy around the Rio Tinto/QMM mine in southern Madagascar, in particular its inquiry into the breach of the environmental buffer zone and concomitant questions around water contamination, the Trust has been working closely with Publish What You Pay (PWYP) in the UK and in Madagascar to address questions around the relationship between Qit Minerals Madagascar (QMM) and the national environmental regulator, The National Office for the Environment (ONE).

The ONE is responsible for monitoring the mine and its adherence to laws and regulations that protect the environment and the natural resources upon which local people rely for their survival. Local communities fish and draw their drinking water from the lakes and waterways adjacent to the QMM mine. They also collect reeds for weaving, Viha plants for roofing, and other water products, so the quality of the water, land and forest resources must be free from contamination.

Viha water plant grows in abundance in the waterways in Mandena where the QMM mine is situated

However, the rigour of current environmental monitoring around the QMM mine is currently under question. The breach of the buffer zone by QMM, by as much as 90 metres in places, has broken laws and agreements without any penalties or sanctions. Concerns have been raised by communities and complaints made at local level (by a local deputy) that the relationship between QMM and the ONE is compromised and the mechanisms for environmental monitoring and consultation processes are neither transparent nor equitable.

August 2019 – Following months of engagement with Rio Tinto, Publish What You Pay (PWYP) UK and the Trust (as a member of PWYP) worked closely with PWYP Madagascar to prepare a letter and briefing to send to Malagasy ministers raising urgent concerns about extractive industry governance in Madagascar. It took the QMM mine in Anosy as a case study in the briefing by way of exposing how the current mining code in Madagascar affords gaps in accountability and transparency that risk undermining local governance and environmental protection, as well as citizens’ rights. The letter was sent in August 2019 by PWYP Madagascar and calls for a review of the Mining Code with civil society in order to address these gaps and promote greater transparency.

In addition to Malagasy civil society co-signatories, many PWYP member organisations and others from around the world co-signed the letter as supporting organisations. The letter and briefing have been shared widely with key agencies and stakeholders, including with the external advisory committees for QMM, the Extractives Industry Transparency Initiative (EITI), the International Council for Mining and Minerals(ICMM), The Business and Human Rights Resource Centre and disseminated broadly through local, national, international and online networks.

On receipt of the letter at the end of August 2019, the Minister for the Environment informed PWYP in Madagascar that there would be an investigation.

Read the letter and briefing in English and French

Letter English version

Letter French version/Version Francais

Briefing English version

Briefing French version / Version Francais

Read the Mongabay Article – published November 20th 2019

See: https://news.mongabay.com/2019/11/madagascar-regulator-under-scrutiny-in-breach-at-rio-tinto-controlled-mine/

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ALT UK’S inquiry into the violation of an environmental buffer zone by Rio Tinto’s QMM mine in southern Madagascar

Traduction de cet BLOGpost en Francais disponible ICI

QMM mine in Mandena (2018)

Rio Tinto/QMM’s breach of an environmental buffer

Since 2016, the Andrew Lees Trust (ALT UK) has been researching the breach of the environmental buffer zone by Rio Tinto’s QMM mine operations at the Mandena site in the Anosy region, southern Madagascar.

The Trust has been concerned about the breach because local people have the right to a safe and healthy environment and, being highly dependent on direct access to natural resources for their food security and survival, the breach has potentially impacted water quality and the estuary system of lakes and rivers on which local people depend for fishing, drinking water and other important services. Citizens also have a right to information in relation to any release of pollutants to the environment due to QMM’s operational activities.

The Trust first raised the issue of the buffer breach and concomitant risks at the 2017 Rio Tinto AGM and has engaged with the company’s HQ in London over the last two years on questions arising.

The Trust commissioned two independent studies in relation to the breach of the buffer zone: one from the hydrogeology expert Dr Steven Emerman of Malach Consulting, to evaluate the extent of the QMM breach; the second from Dr Stella Swanson from Swanson Environmental Strategies, to review the radioactivity levels of the mine.

Reports and related articles can be found at www.andrewleestrust.org/andrew.htm

Key issues are also explained here: https://theecologist.org/2019/apr/09/rio-tinto-admits-buffer-breach.

For almost two years Rio Tinto /QMM denied the breach and claimed that the works in Mandena were “compliant”, despite the findings of their own contracted experts, Ozius, in 2018, who demonstrated the mine’s encroachment beyond approved permissions.  ALT UK continued to pursue answers and demand transparency. As a result, in a report issued by Rio Tinto in March 2019, and publicly at the 2019 AGM, the company finally admitted to the QMM breach of the buffer or sensitive zone by as much as 90 metres in places, and beyond legally approved permissions. Additionally, the company admitted to using QMM mine tailings to build its “berm”, which has extended onto the bed of Lake Besaroy.

The QMM breach at Mandena is of concern for a number of reasons: it violates the public protection of waterways where people fish and gather drinking water; it exceeds the permissions granted to Rio Tinto/QMM by the Government of Madagascar to observe an already reduced buffer zone (from the statutory 80 metres to just 50 metres wide) as negotiated in 2014. The 50m limit was approved by the environment regulator, the Office Nationale pour L’Environnement (ONE) in 2015, after QMM had already breached the 50m limit that they proposed in their Social and Environmental Management Plan (SEMP); the breach violates national environmental law that protects sensitive zones, such as the waterways and lakes adjacent to the QMM mine, which are also protected under public domain legislature; it has exposed the lakes to mine tailings and increased the risk of toxic waste water from the mining basin entering the lakes; in this, it exposes local people who depend on the lakes and waterways for fishing, drinking water and other services, to health risks. See Google Earth Images of the mine breach here

The violation of the buffer zone by QMM received no sanction or penalties from the state regulator, ONE, as would be expected, and despite the obvious breach of national laws and agreements, and impacts on the local peoples’ environment.

Fisherfolk on the waterways next to the QMM mine ( image courtesy of A Kraemer)

QMM Mine tailings and radioactivity

Rio Tinto has admitted that QMM’s mine tailings have been used to build the QMM “berm”. Moreover, the berm construction has encroached onto the bed of Lake Besaroy next to the mine site, bringing mine tailings into contact with the local estuary system.

Mine tailings and waste water from the mining basin contain enriched radionuclide content, because the ilmenite extraction process concentrates the radionuclides that are present in Monazite and Zircon, contained in the mineral sands.

The QMM ‘berm” is a structure intended to prevent tailings and waste-water from the mine basin from entering the adjacent lakes and waterways. As such, it would need to adhere to international dam construction standards, safety requirements and monitoring. However, in Rio Tinto’s recent listing of their mine storage facilities, the QMM mine is rated by Rio Tinto as having  “No embankment: excavated storage facility” (Rio Tinto, 2019). This description ignores the existence of the “berm”, or its function as a dam, and thereby potentially circumvents the prerequisite safety criteria.

The concern that toxic waste has entered the local water system has been deepened by ALT UK’s independent radioactivity review that identified elevated uranium levels in the water around the mine’s waste water discharge points, 50x times higher than World Health Organisation (WHO) safe drinking guidelines in some places.

The company has claimed that the elevated uranium levels identified in the water around the mine are all naturally occurring due to high background radiation levels. In reality RT/QMM cannot make this claim since they failed to carry out the necessary monitoring, or deliver relevant scientific data to support their argument. Indeed, ALT UK’s radioactivity expert, Stella Swanson, who has some 40 years standing in the industry and who consulted closely with Rio Tinto’s own expert, found QMM’s monitoring of ingestion pathways for radioactivity around the mine (water, soil, food) to be “unacceptable”.

Questions and demands

In April 2019 ALT UK brought its concerns to the Rio Tinto AGM, and is still in discussion with Rio Tinto HQ about what has happened and what needs to be done.  This includes asking that the company follow WHO guidelines to provide alternative safe drinking water sources for communities living around the mine site; a full translation into French of the main 68 page Swanson radioactivity review for local stakeholders, QMM staff and government and national agencies involved in monitoring the QMM mine; also a full, independently led and appropriately designed local communications programme to understand and address local concerns about the mine’s radioactivity levels – such as can educate and inform local communities about radioactivity, address their questions and concerns, and help them manage their lives around the QMM mine to assure their health and safety e.g. reduce incremental exposure.

woman with Eel Andrakaraka (image courtesy of A Kraemer)

In 2017, before commencing its studies, the Trust insisted that the findings of its independent radioactivity review be shared with local communities in appropriate and accessible ways. The Trust has this year offered a six-page communications advisory paper to Rio Tinto, which advocates an independently led communications programme and identifies experts who can assist QMM with this challenge. As yet the company has not responded to this communication paper.

Rio Tinto’s CEO did respond to two questions/demands at the Rio Tinto 2019 AGM: to agree the translation and address the communications issue. However, the company declined to take up the Trust’s and Swanson’s recommendation to address a high priority item: the provision of alternative safe drinking water sources for locally affected communities.

A recording of the entire Rio Tinto 2019 AGM is available here ; ALT UK questions appear at times : 49.25 and again at :  1.45.26

The Trust believes the safe drinking water issue should be placed within the context of understanding that 1) it is a WHO guideline given the health risks to local people, 2) QMM has failed to distinguish between pre-existing natural background levels in the water and the impacts of their mining operation, and 3) the violation of the buffer zone by QMM received no sanction or penalties from the state regulator, ONE, as would be expected, and despite the obvious breach of national laws and agreements, and impacts on the local peoples’ environment.

Local governance and transparency

Additionally, ALT UK is finding it extremely hard to access the 2018 ONE report that reported the QMM buffer zone work as “compliant”; and then, subsequently, a further ONE document that apparently evaluates the breach impact as “negligible”. ALT UK has repeatedly asked Rio Tinto to provide the relevant ONE reports but without success; the ONE also failed to respond to a request for relevant report/s.

This failure to share reports, especially when Rio Tinto/QMM is paying ONE for the evaluations of the QMM mine, reinforces local concerns about the relationship between QMM and ONE. At local level there have already been complaints that the relationship between QMM and ONE is “compromised”- including a public complaint made by a local deputy to the Minister of Environment during a visit to Ft. Dauphin in 2018.

More about the governance issues in the joint briefing and the letter sent to government ministers from Publish What You Pay here

Following a letter of enquiry sent in 2019 by ALT UK in collaboration with Publish What You Pay, Rio Tinto has shared details of payments made to ONE during the relevant SEMP approval and evaluation reporting time frames. On average the company appears to be providing support to ONE in the region of USD$30-40,000 per year, with a tendency toward on-going financial contributions, such as may risk dependency and create conflicts of interest; especially if works undertaken by ONE are not then readily available for scrutiny.

The amounts also suggest that no external, independent expertise was engaged by ONE to assess the buffer zone breach in 2018, or the impacts of constructing a berm using mine tailings that extended into the lake – e.g. on water quality; this suggests that the validation of the QMM works as “compliant” has not been concluded following a thorough technical examination such as would be necessary. For example, Rio Tinto paid almost USD$60,000 to Ozius just to study the buffer zone encroachment. No such increase in funds appear to have been made available to ONE in order to engage its own experts for the evaluation process; nor has it been suggested that ONE have referenced the Ozius report, which in any case clearly demonstrates the breach of the buffer and encroachment onto the lake. Indeed it remains unclear how ONE reached its conclusions on the status of the breach or the impacts of the encroachment as “negligible”.


Rio Tinto/QMM openly states that the company is making payments to ONE, as allowed under the MECIE decree; however, the company’s failure to make the ONE reports available when asked represents a serious lack of transparency and risks undermining robust, objective and credible governance at local level.  Most especially so when Rio Tinto/QMM are citing the ONE regulator and its reports publicly to claim “compliance” with their government approved Social Environmental Management Plan (SEMP) or convince shareholders of the “negligible” impact of QMM’s buffer breach on the local environment.

Weaving Mats in the villages around Mandena (image courtesy of A Kraemer)

Community engagement and accountability

Throughout the process, ALT UK has learnt that many community members knew little or nothing about changes to the QMM mine plan e.g. a reduced, 50 metre buffer (SEMP 2014-2018); or of further changes to the operational plan made in January 2019, such as normally require open community consultation. ALT UK is concerned that full consultation processes may not be happening, or may be confined and simplified to direct engagement with Mayors and Chef du Fokontany for rapid decisions and approvals.

Following complaints made to Rio Tinto HQ in 2017, the Trust was informed that internal training and procedural processes at QMM have been reviewed in order to improve QMM’s local social engagement mechanisms with communities; a new “Norme des Procedures” has been developed and apparently came out of that work. ALT UK has been promised sight of this document – but so far has not received a copy.

Poor or limited consultation processes with communities and lack of transparency over availability of data and information has been a concern of the Trust over many years.  Throughout this inquiry, ALT UK has had to be extraordinarily persistent throughout the dialogue with Rio Tinto in order to advance its enquiries and it took significant pressure from ALT UK for the company to finally admit the buffer zone violation. Rio Tinto has still not addressed many of ALT UK’s technical questions and documentation requests. Importantly, ALTUK has had to work full-time on these issues for over two years.

Research and advocacy work of this kind is demanding, time consuming and requires considerable technical assistance from independent scientists. No such resources are readily available to local communities in Anosy. In this, the two-year process highlights the difficulties for local citizens to hold the company to account, especially when they are faced with the daily challenges of surviving on less than $2 per day.

Indeed villagers appear to have had no capacity to prevent the loss of the inland Lake Ambavarano to the new perimeters of QMM’s 2019 butterfly mining (next phase of dredging), which QMM claims local people “rarely use” but which locals do employ for at least four months of the year in the “Asiotry” period, as well as accessing forest products around the lake all year; nor to stop QMM’s destruction of forest in the buffer area of the conservation zone in Mandena to create a new access route; both of which demonstrate a disregard for local people’s access to vital natural resources, and the power asymmetry that favours the company’s interests.

ALT UK’s research around QMM buffer breach/radioactivity levels has not involved any locally based NGOs /CSOs.  The work has been highly technical in nature with the focus on establishing scientific facts. Additionally, ALT UK was required to work under a confidentiality agreement from Rio Tinto in order to access QMM’s radioactivity monitoring data and associated reports, which has further impeded partnerships or local collaboration in the process. ALT UK has ensured some direct contact with community members in Anosy, thanks to the ALT UK Director’s long-standing personal relations in the region. This has helped maintain checks on local realities and concerns, but has only been possible intermittently, and on an ad hoc basis.

In this regard there is still a great deal of work to do in order to understand what is happening around the QMM mine in Mandena, how consultation and communications with communities is happening with QMM, whether citizens’ rights to a safe and healthy environment and their rights to information are being fully respected, how good governance can be achieved around the mining operation, and in what way any environmental or social abuses will be appropriately and justly addressed and remedied.

Vegetable gardens

Impacts, discussion and dissemination

The ALT UK research and advocacy work on the QMM breach has already had a number of impacts, with the company making a series of admissions and commitments. However, follow up on the outcomes of these commitments is required, as well as improved independent monitoring and evaluation of the QMM mine.

The Trust has engaged with a number of international agencies throughout this research and advocacy work, and collaborated closely with some NGOs, including Publish What You Pay, the London Mining Network and Friends of the Earth. It has also communicated with groups, researchers and individuals who have concerns or interests in the Rio Tinto QMM operations, including members of QMM’s International Independent Advisory Panel (IIAP) and Biodiversity and Natural Resource Management Committee (BNRMC), to alert them of the buffer breach and concomitant risks.

The issues and the studies /findings have been shared widely through online networks such as POLLEN and the Madagascar Environmental Justice Network, and via direct correspondence from ALT UK, including with activists, researchers, members of the Malagasy diaspora, academics, shareholders/investors, conservation organisations such as the IUCN and WWF Madagascar, other relevant bodies such as Extractives Industry Transparency Initiative, Transparency International, and with the World Bank – under whose project funding timeline the QMM violation occurred (World Bank PIC programme).

Ethical investors are particularly focused on the extractives industry’s management of mine tailings following the Brumadinho tragedy earlier this year. The Church of England Pensions Fund, for example, has launched an initiative to promote improved safety and regulation of mine tailings storage facilities. The breach of the buffer zone in Madagascar raises specific questions about QMM’s management of its mine tailings, and associated risks; these have been explained in detail in Emerman’s second report, and been the subject of extensive enquiry by ALT UK to the company.

The QMM buffer zone breach raises questions about Rio Tinto/QMM’s respect for local people’s human rights to a safe and healthy environment and their rights to information. It also raises questions about the manner in which public private partnership projects of this kind are monitored, evaluated and held to account when they fail to respect the environmental standards expected of them – including in terms of their own corporate commitments, the national regulatory frameworks and laws, and by the international funders and organisations who have partnered with them.

Reports and Contact

For further information please contact: yorengo@andrewleestrust.org

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