Prosperity

unto
Death

Is Zambia Ready
for Uranium Mining?
Review of the Uranium Mining Policy in Zambia
 Review of the Uranium Mining Policy in Zambia

Prosperity unto Death: Is Zambia ready for Uranium Mining?

© 2010

Published by the Council of Churches in Zambia

Financed by Norwegian Church Aid

Acknoweledgements
Our deepest gratitude goes to the following people without whom this report would not be in your hands; the
Chiefs in the Sikoongo, Simamba, Sinadambwe, Mumena, Makumbi and Matebo chiefdoms. This we do, not
forgetting the Headmen and the community members who were instrumental towards unveiling the information
and taking the study team to the areas where more facts could be found.

This report shows that it was not a mistake for the General Conference, CCZ Board Members, and Heads of
Churches to give their blessings on the programme on the Extractive Industry and Ecological Debt – EIED, the
Social and Economic Justice Programme Committees in the areas which are covered by this study and the
Churches in the same areas who gave both their valuable time and moral support to bring this study to you.

We would also like to direct out appreciation to the Norwegian Church Aid Zambia for both moral and other
logistics support to enable us carry out this important study, to Dr. Daniel Nkhuwa and Mr Sakwiba Musiwa of
the University of Zambia – UNZA; for their readiness and commitment to conduct the study.

Last but not least, we want to thank all who were involved at one point or the other in the consultative discus-
sions on the findings of this report before going to Print NOT forgetting the tireless efforts and dedication of the
staff members at the Social and Economic Justice programme office.

It is our hope that the facts presented on this report will compel us all to action against injustice.

To all of you we say a heartfelt;

TWALUMBA KAPATI! TWASANTA MWANE! ZIKOMO KWAMBILI!

THANK YOU!!!

PEACE, LOVE & JOY

THE COUNCIL OF CHURCHES IN ZAMBIA – CCZ

Seeking Justice for ALL... Proverbs 31:8 – 9

All pictures were taken at the respective Chiefdoms were Uranium operations are scheduled to take place by
the CCZ team.

Front page - photos by Evans Rubara

Design & layout by Alain Kayihura
Printed by Mission Press- Ndola, Zambia

For more information contact:

The Council of Churches in Zambia - CCZ
 Review of the Uranium Mining Policy in Zambia

Contents
Acronyms v
Foreword vi
Executive Summary viii
About the Authors xi

Introduction 1
Background 1
Objective of the study 1
Scope of the study 1
Deliverables 1
Methodology of the Review 1
Desk review 2 iii
Field work 2

Facts about Uranium 2

General 2
Radioactivity 2
Fission 3
Radon and Radon Daughters 3

Status of Uranium Mining in Zambia 4

Introduction 4
Denison Mines Zambia Limited (DMZL) 4
African Energy Resources (AER) 4
Lumwana Mine Company (LMC) 4

Institutional and Legal Framework of Uranium Mining in Zambia 6
Institutional Framework 6
Policy, Legal and Regulatory Framework 6
Introduction 6
The Mines and Minerals Development Act No. 7 of 2008 6
Environmental Protection and Pollution Control Act No. 12 of 1990 7
Ionising Radiation Protection Act, 2005 8
The Land Act of 1995 and the Land Acquisition Act of 1970 8
 Review of the Uranium Mining Policy in Zambia

Current Levels of Adherence to Legisation by Mining Companies Operating in Zambia 9

Environmental Impact Assessments (EIA) 9
Commitment to Environmental Protection and Land Rehabilitation 9

Adequacy of Legislation fro Uranium Exploration and Mining 11

Introduction 11
Community Concerns and Safety 11
Chief Sikoongo’s Area – AER 11
Chief Sinadambwe’s Area – DMZL 13
Chiefs Matebo’s, Mukumbi’s and Mumena’s Areas – LMC 14
Worker Safety 16
Community Participation in the Mines’ decision-making Process 17
Corporate Social Responsibility (CSR) 20
Dangers of some CSR programmes 22

Capacity of Zambia to Oversee Uranium Exploration and Mining 23
Introduction 23
Experience from other countries 23
Canada 23
Namibia 23
Institutional set up 24
Technical Expertise 24

Advantages and Disadvantages of Uranium Mining in ZAmbia 25

Introduction 25
Advantages of uranium mining 25
Disadvantages of uranium mining and Possible pitfalls 25

Discussions 27

Conclusion 29

Recommendations 29

iv References 30

Appendices 31
Appendix 1. Decision letter for Denison Mines Zambia Limited 32
Appendix 2. Decision letter for Lumwana Mine Company’s Uranium Project 35
Appendix 3. Environmental Project Brief (EPB) submitted by African Energy Resources 39
Appendix 4. Minutes of the Denison Mines Zambia Limited EIA Public Consultation 49
Appendix 5. Minutes of the Lumwana Uranium EIA Public Consultation 60
Appendix 6. Lumwana uranium awareness document 72
 Review of the Uranium Mining Policy in Zambia

Acronyms
AER African Energy Resources
AMEX American Stock Exchange
ASX Australian Stock Exchange
CCNR Canadian Coalition for Nuclear Responsibility
CCZ Council of Churches in Zambia
ECZ Environmental Council of Zambia
EIA Environmental Impact Assessment
EPB Environmental Project Brief
IAEA International Atomic Energy Agency
LML Large Scale Mining Licence
LMC Lumwana Mining Company
NRMG Natural Resource Management and Governance
OML OmegaCorp Minerals Limited
PWYP Publish What You Pay
RPA Radiation Protection Authority
TSX Toronto Stock Exchange
UNZA University of Zambia
WNA World Nuclear Association
WNTI World Nuclear Transport Institute
ZCCM Zambia Consolidated Copper Mines
v
 Review of the Uranium Mining Policy in Zambia

Foreword
“We of this generation are the stewards of the land in which we live.  The next generation will call upon us to
give and account of our stewardship.” Anonymous

Should Christians care about the way in which the God-given wealth in the natural realm is managed, the
social welfare of fellow human beings, the economy and environment? Christians are sometimes reluctant to
take governance and natural resource management issues seriously, leaving all these issues under the over-
sight of politicians.

In some cases this is because we do not understand governance with regards to natural resource manage-
ment, socioeconomic and environmental issues from God’s perspective. Or out of fear of the dynamics on
the way and the fact that the political environment in the African soil always sees such engagement from the
vi Church as opposition.

Let’s therefore, take a moment to reflect upon stewardship as individual Christians, Churches and as a nation
with respect to Natural resource management and the entire environment that houses us – mother earth.

The three general principles of a Christian environmental ethic namely; Stewardship and Creation value, Stew-
ardship, sustained order and Purpose, and Stewardship, Universal corruption and redemption have practical
implications for the role of people as caretakers, or managers of nature.  The Bible teaches that as caretakers
or managers of nature, people are to practice good stewardship.  The word “steward” and “stewardship” is
used throughout the Old and New Testaments of the Bible (Genesis 15:2; Genesis 44:1; 1 Chronicles 28:1;
Matthew 20:8; 1 Corinthians 4:2; Luke 12:42; Luke 16:1-2).  The word used for steward in the Bible can also
be interpreted as manager or servant.  

The general characteristics and responsibilities of a steward include being faithful, wise and responsible.  The
steward should be concerned with meeting daily needs and is not to abuse or waste what he or she has been
put in charge of managing.  The steward is to maintain self-control (not overindulging), be a “problem-solver”,
and follow the household or estate owner’s wishes and instructions with respect to management (Luke 12:42-
46; Luke 16:1-9).

Under the Principle of Creation Value, all of God’s creations are important and valuable to God.  People hold a
special particular value to God as living beings created in His image (Genesis 1:26-30).  Part of God’s provision
for the well-being of people is the use of plants, animals, minerals and other elements of nature for meeting
our material needs. 
 Review of the Uranium Mining Policy in Zambia

When using elements of nature for human benefit, the Christian natural resource [manager] keeps in mind that
all of creation ultimately belongs to God and is valuable to God independent of human use (ref. Psalm 24:1)
Godly respect and love for elements of nature leads the Christian natural resource manager to be a respon-
sible caretaker of nature who does not abuse or misuse what has been entrusted into his or her care by God. 
Respect, love, care and realistic use of the natural wealth God has given to humanity are overarching facts that
encompasses all mankind irrespective of religion and race.

Genesis 1 establishes that although both people and nature are created works of God and under God’s author-
ity, God has given people dominion over nature.  But, how are people to exercise this dominion?  God created
people in His own image - as His representatives on earth. 

Specific instructions pertaining to managing nature are given in Genesis 2: “The Lord God took the man and
put him in the Garden of Eden to work it and take care of it”(Genesis 2:15, NIV).  The phrase, “to work it” means
“to till it” or “to cultivate it”; the general meaning is to use productively.  To “take care of” means “to keep”, “to
guard,” and “to exercise great care over”.  The intent of “keeping, guarding, caring over” is to sustain the func-
tion for which the element of nature or natural system being cared for was originally designed, namely; to cater
for the present and future generations.

The “good steward” according to the Bible will therefore, manage nature in a wise, self-controlled, and non-
wasteful manner, always taking care to sustain the original functions of elements of nature and natural sys-
tems.  The “poor steward”, in contrast, lacks self-control, is wasteful and irresponsible, and cannot be trusted to
take proper care of what he or she has been put in charge of managing.  The “poor steward” allows the original
functions of elements of nature or natural systems to be degraded or ruined.

Unfortunately, the poor management or stewardship model often describes how men and women of the world
improperly exercise their dominion over nature.  Examples of poor management of natural resources can be
seen among us – Zambians and other mineral rich countries in Africa in the way the mining developments are
contracted leading to the land being totally “burned out” and incapable of further production and the environ-
ment becomes poisonous to mankind. 

In the current state of affairs in the Mining sector and the general management of the God given natural re-
sources in Zambia; we clearly find ourselves at fault with God. We have forgotten the sole responsibility that
was given to us by God and turned to heaping up His wrath for disobedience.

To carry out [our] responsibilities and properly utilise the natural resources God has given us, the Church and vii
other stewards of nature must learn as much as [we] can about the God-intended order and purpose of nature. 
This effort includes learning about individual elements of nature, and how these elements of nature function
within natural systems created and sustained by God (ref. Jeremiah 6:16).

If high levels of poverty among the people of Zambia in the rural, peri-urban and urban areas and corruption
named within the decision-making offices in the government on mining development agreements leading the
country into more social, economic and environmental woes and will not make us rethink the way in which
[we] utilise the natural resources then let this report challenge [our] understanding and be a means to tracing
back our paths to better decision-making and ensure that the God given wealth benefit the people of Zambians
to achieve the TRUE One Zambia, One Nation.
 Review of the Uranium Mining Policy in Zambia

Executive Summary
Background

The advent of uranium exploration/mining activities in Zambia in the early to mid 2000s has generated discus-
sions focused in two main areas of concern, especially for the affected communities in these areas. One such
concern pertained to whether or not the economic benefits accruing to, and the health effects related to these
activities on local communities justified some of the associated risks created by such activities. In an attempt
to get some clear understanding of this concern, the following needed to be answered:

 Does Zambia have the technical expertise to regulate and supervise the exploitation and mining of ura-
nium?
 Are the socio-economic benefits accruing to the affected communities justified, considering possible some
viii known and unknown health risks associated with uranium exploitation and mining activities?
 What role does the rural communities that are directly affected by uranium exploitation and mining played
in the decision-making processes of these mines?

It was against this background that the Council of Churches in Zambia (CCZ) commissioned this study. The
study documents outcomes of a review of policies and laws that govern the extractive industries in the mining
sector in Zambia and how these policies/laws address issues of transparency, equitable distribution of benefits
accruing from the extractive industries in these sectors, and management of the environment.

Objectives of the study

The main purpose of the study was to comprehensively review the uranium policy and related statutes in
Zambia with respect to health issues, environmental protection, transparency, accountability and equitable
distribution of benefits realized from the exploitation and mining of uranium.

Methodology
The study was undertaken in two stages, namely:
a) Desk review that comprised identifying and reviewing existing relevant documents, and
b) Fieldwork involving visiting areas affected by uranium exploration and mining activities of Siavonga and
Solwezi to discuss with District Commissioners, Chiefs and their Headmen and subjects, and concerned
citizens.

Uranium exploration/mining areas in Zambia

Currently, three major exploration companies – African Energy Resources (AER), Denison Mine Zambia Lim-
ited (DMZL) and Lumwana Mining Company (LMC) – have acquired concessions for uranium exploration and
subsequent mining in Zambia.

AER is operating in the Chirundu area, where it holds
a 70% interest in the Chirundu Joint Venture project,
with Albidon Limited (ASX: ALB) holding the remain-
ing 30%. The Company is also involved in another
venture called the Kariba Valley Joint Venture Project,
where it holds a 30% interest, with Albidon Limited
holding 70%. DMZL is currently developing its Mu-
tanga-Dibwe Project located in Siavonga District of
Southern Province. LMC uranium mining activities fall
within the confines of the Company’s copper explora-
tion and mining operations at Malundwe and Chimi-
wungo copper, cobalt, gold and uranium deposits 95
km west of Solwezi.
So far, these companies have reported findings of
commercially viable deposits, with AER and DMZL
having delineated some commercial deposits in their
Siavonga District concessions, and the latter targets
to commence production in 2012. LMC, on the other
hand, is already stock-piling uranium ore that comes
as a by-product of its copper mining activities. has
delineated commercial deposits in Siavonga.
Facts about Uranium
Uranium is the heaviest naturally occurring element
on earth. It is concentrated in certain types of rocks. It
is classified as the deadliest metal on earth because
it is:
 Radioactive – emits (gives out) radiation (ener-
gy), when it breaks down. This radiation is in form
of streams of particles – alpha and beta – with
very high energy.
 Fissionable – spontaneous or induced splitting
of an atomic nucleus into smaller parts, usually
accompanied by a significant release of energy –
about 400 times as much energy as is produced
by a radioactive disintegration event.
Thus, the radioactivity and fissionability of uranium is
responsible for introduction into the human environ-
ment a tremendously large range of radioactive ma-
terials which are all very unfavourable to biological
organisms. Since these particles are like fragments,
they eventually get into water, food, and air that the
humans drink, eat and breathe, respectively. And be-
cause of their high energy, they can be damaging or
fatal to health of people exposed to them, especially
when ingested or inhaled.
Institutional Framework
The administration and regulation of all mining activi-
ties are the portfolio responsibility of the Ministry of
Mines and Minerals Development (MMMD). Three
line departments - Geological Survey Department
(GSD), Mines Development Department (MDD) and
Mines Safety Department (MSD), perform the techni-
Review of the Uranium Mining Policy in Zambia
cal functions of the MMMD. The GSD is a national
depository of all geological information in the country,
while the MDD issues all prospecting, retention and
mining licences. The MSD enforces mining regula-
tions.
Other institutions include:
a) Environmental Council of Zambia (ECZ), which is
mandated to do all such things as are necessary
to protect the environment and control pollution,
so as to provide for the health and welfare of per-
sons, animals, plants and environment. This man-
date is fulfilled by:
 Ensuring developers submit mandatory Envi-
ronmental Impact Assessment (EIA) reports for
all major projects (both new and existing).
 Collecting and disseminating environmental
and social information, and improving the
public’s environmental awareness.
b) Radiation Protection Board (RPB), which is re-
sponsible for the management of all potentially
harmful sources of radiation thru occupational and/
or environmental exposures. Another mandate for
the RPB is issue licenses for processing, storage,
transportation, importation, exportation and use of
radioactive material within specified levels.
Policy Framework
Zambia has no specific policy framework on ura-
nium. Issues of uranium exploration/mining are only
embedded in the Mineral resources development
policy. However, the extra-ordinary characteristics of
uranium require mining policies that are specific to it.
ix
Legal and Regulatory Framework
The main law that is specific to uranium exploration/
mining is contained in the Mines and Minerals Devel-
opment (Prospecting, Mining and Milling of Uranium
Ores and Other Radioactive Mineral Ores) Regula-
tions of 2008. These Regulations (i) form the major
basis for uranium exploration and mining, and (ii) are
intended for the protection of the environment, as well
as health and safety of workers and the general pub-
lic.
Other Legal Regulatory Frameworks include:
a) The Environmental Protection and Pollution Con-
trol Act No. 12 of 1990, which provides guidance on
the development of Environmental Project Briefs
(EPBs) and/or the Environmental Impact State-
ments (EISs), depending on scale of project.
b) The Ionizing Radiation Protection Act, 2005, which
provides for the protection of the public, workers
and the environment from hazards generated by
use of devices that produce ionising radiation.
c) Land Act of 1995:
• Is intended to guarantee peoples’ right to land,
 Review of the Uranium Mining Policy in Zambia
while enhancing national development.
• Recognises the holding of land under custom-
ary tenure, while legally recognising the Chief’s
role, wherein land may not be converted or
alienated without the latter’s approval.
d) Land Acquisition Act of 1970 sets out regulations
for the compulsory acquisition of land and prop-
erty and compensation for such acquisition. It also
stipulates that compensation for acquired prop-
erty, losses and damages shall be paid as may be
agreed upon between the parties. However, it also
states that the president may acquire any property
in the interest of the Republic.
Gaps and weaknesses in Legislation and Enforce-
ment
1. The lack of a specific policy on uranium exploration
and mining in spite of its peculiarity and dangers.
The absence of a policy on uranium may have led
to some of the inherent weaknesses in the cur-
rent legislation, resulting in inadequate attention to
communities’ interests. Issues that indicate inade-
quate attention to communities’ interests include:
 Approval of an EPB report, which lacked as-
sessment of socio-economic and environmen-
tal impacts.
 Drilling of exploration holes very close to peo-
ple’s houses.
2. According to the Land Act, no land can be convert-
ed without approval of chief. However, chiefs com-
plained about investors invading their chiefdoms
without their permission. This may arise from the
x fact that the president may acquire any property in
the interest of the Republic
3. The Land Acquisition Act sets regulations for the
compulsory compensation for all acquired land
and property. In spite of this stipulation, people ap-
pear to have been forced to relocate from areas of
their ancestral inheritance, without any commen-
surate compensation.
4. Inadequacies of information to communities –
People to be relocated were not informed that this
was permanent, and they would not return to their
land again.
5. Signed Memoranda of Understanding (MoUs)
– Although chiefs sign MoUs with investors that
promise, among others, to create jobs for the local
communities, most of these jobs have remained
casual and of a general-workers’ nature.
6. Worker Safety – storage of drill holes cores in
some of the exploration camps poses great chal-
lenges to workers’ safety
7. Community Participation in decision-making –
some clauses in the Mines and Minerals Develop-
ment Policy like ‘to encourage mining companies
to develop a participatory & collaborative approach
to mine planning, development and decommis-
sioning’, are loose, ineffective and noncommittal.
Possible health and environmental effects
Mining leaves behind waste rock, while crushing and
chemical winning processes for uranium leave behind
pulverized material in form of tailings. If mismanaged,
especially arising from some gaps and weaknesses in
legislation and enforcement, most of the waste rock
and tailings may get washed by rain into water sys-
tems and/or inevitably spread into the environment.
Therefore, radioactive materials will be introduced
into the air, water, and food that man breathes, drinks
and eats, respectively, thereby introducing into the
human environment materials that are very inimical
(foreign) to body.
Consequently, there might be an extraordinarily high
incidence of lung diseases – cancer, fibrosis, and oth-
er lung diseases – all of which take decades to mani-
fest. Available scientific evidence indicates that every
dose of radiation is likely to cause a corresponding
increase in cancers and other diseases.
With the current arrangements, where there is no pol-
icy on uranium, and enforcement of existing subsid-
iary pieces of legislation still requires strengthening,
the following questions arise:
 Who becomes responsible to look after such mate-
rial forever once mining companies close down?
 How does anyone guard millions of tonnes of ra-
dioactive sand safely forever, and keep it out of
the environment?
Transparency, Accountability and Equitable dis-
tribution of Benefits
So far, no deliberate policy/legislation addresses eq-
uitable distribution of wealth that accrues from mining
activities.
Thus:
 Communities, where mining activities take place,
only benefit from national programmes, if at all
included in those programmes.
 The only statement in statutes is where govern-
ment encourages investors to carry out some
community work in their areas of operation.
Recommendations
On the basis of some gaps and weaknesses in legis-
lation and enforcement, the need for a policy on ura-
nium is imperative as this will set the pace for:
 The revision of the current Regulations that, among
others, adequately address community concerns.
 The educational and awareness programmes for
communities ahead of any uranium exploration
and mining operations.
 Review of the Uranium Mining Policy in Zambia

About the Authors

This research was carried out by Daniel CW Nkhuwa (PhD) and Sakwiba Musiwa (MSc), both of the Depart-
ment of Geology in the School of Mines at the University of Zambia.

Dr. Nkhuwa holds a PhD in Engineering Geology and Hydrogeology from Aachen University of Technology in
Germany, which he completed in June 1996. He has worked for the then Zambia Consolidated Copper Mines
(ZCCM) Limited, Luanshya Division from 1982 to the end of 1988. At the start of 1989, he joined the Geology
Department in the School of Mines at the University of Zambia, where he is currently Senior Lecturer.

During this period, he has supervised and graduated a PhD in Hydrogeology; he has researched and pub-
lished widely within the repertoire of engineering geology, hydrogeology and mining geology and contributed
Chapters in books, and published articles in peer reviewed Journals and refereed Conference Proceedings.
In addition, he has made several presentations at national and international conferences, seminars and work-
shops. He has also made several Public Service contributions – consultancies and awareness creation pro-
grammes – to national and international institutions. He is a member of five local and international professional
institutions.

Mr. Musiwa holds an MSc in Mining Exploration from the International Institute of Aerospace Survey and Earth
Resources (ITC) in the Netherlands, which he obtained in 1996. He worked for the then Zambia Consolidated
Copper Mines (ZCCM) Limited, Chingola Division from 1979 to 1981. Between 1981 and 1982, Mr. Musiwa
worked as Exploration Geologist with the Geological Survey Department. Between 1982 and 1992, he worked
as Project Geologist and promoted to Senior Project Geologist at the Hydrocarbon Unit of the Ministry of
Mines. From 1992 to 1996, Mr. Musiwa worked as a Senior Geologist at the Geological Survey Department in xi
the Economic Geology Section.

In 1996, he became Coordinator of the Mining Sector Reform Programme, a World Bank financed project,
where he was involved in geological data acquisition, investment promotion, and institutional capacity building.
Between 2000 and 2004, Mr. Musiwa was a private consultant and did part time lecturing in the Department of
Geology at the University of Zambia. In 2004, he became the Coordinator of the Gemstone component of the
Support for Economic Expansion and Diversification (SEED) Programme. In 2008, he joined the Department
of Geology in the School of Mines at the University of Zambia, where he is currently lecturer.
Review of the Uranium Mining Policy in Zambia

Prosperity unto Death

Is Zambia ready for Uranium Mining?

Introduction
Background
The advent of uranium exploration and subsequent
mining activities in Zambia in the early to mid 2000s
has generated discussions focused in two main ar-
eas of concern, especially for the affected communi-
ties in these areas, namely:
a) Economic benefits of these activities accruing to
them, and
b) Health effects related to these exploitation and
mining activities.
To this effect, the following questions have been sig-
nificant in the discussions and debates that have en-
sued:
i) Does Zambia, as a country, have the technical
expertise to regulate and supervise the exploita-
tion of the deadly metal – uranium?
ii) Do the socio-economic benefits accruing to the
affected communities outweigh the health risks
associated with these exploitation and mining ac-
tivities?
iii) What role do the rural communities, that are di-
rectly affected by uranium exploitation and min-
ing, play in the decision-making processes lead-
ing to commencement and operation of these
activities?
It was against this background that the Council of
Churches in Zambia (CCZ) commissioned this study,
within the framework of the Extractive Industry Trans-
parency Initiative (EITI) and Publish What You Pay
(PWYP) umbrella, under the Natural Resource Man-
agement and Governance (NRMG) programme. The
study gives the outcome of a review of policies and
laws that govern the extractive industries in the min-
ing sector in Zambia in order to assist in answering
the numerous questions about transparency, equi-
table distribution of benefits accruing from the extrac-
tive industries in these sectors, and management of
the environment.
Objective of the study
The main purpose of the study was to come up with
a comprehensive review of the uranium policy and
related statutes in Zambia that highlights gaps and
weaknesses in health issues, environmental protec-
tion, transparency, accountability and equitable distri-
bution of benefits realized from the exploitation of the
mineral resource.
Scope of the study
The Consultants undertook the following tasks:
a) To establish the existence or absence of Poli-
cies and/or Legislatures on Uranium mining in
Zambia.
Review of the Uranium Mining Policy in Zambia
b) To identify and review legislatures in place that
regulate the mining of uranium in Zambia with
respect to;
• Corporate Social Responsibility
• Safety of local communities and manpower
in the processing Unit
• Health and Environment
• Land Rehabilitation.
c) To establish the existence of Environmental
Impact Assessment (EIA) reports for Lumwana
Mine Company and Denison Mines Zambia
Limited, both of which are currently undertak-
ing uranium exploration/mining activities in the
country.
d) To establish clauses in the Policies that promote
participatory strategies in negotiations.
e) To analyse Zambia’s capacity to oversee the
mining of Uranium.
f) To assess advantages and disadvantages of
uranium mining in Zambia.
g) To identify gaps and weaknesses in the uranium
Mining Policy, if it exists.
h) To compare issues in the policy with what is ob-
taining on the ground.
i) To formulate recommendations for key advo-
cacy issues and effective strategies for civic
engagement in promoting transparency and ac-
countability in the mining sector.
Deliverables
A comprehensive report detailing findings of the
above.
Methodology of the Review 1
The study was undertaken in two stages, namely:
a) Desk review that comprised identifying and re-
viewing existing relevant documents, and
b) Fieldwork involving visiting areas affected by ura-
nium exploration and mining activities of Siavon-
ga and Solwezi to discuss with District Commis-
sioners, Chiefs and their Headmen and subjects,
and concerned citizens.
A homestead in Siavonga District community where
uranium mining is expected to start soon
 Review of the Uranium Mining Policy in Zambia
Desk review
This involved a review of the following:
• Mines and Minerals Development Act No. 7 of
2008
• Mines and Minerals Development (Prospecting,
Mining and Milling of Uranium Ores and other ra-
dioactive mineral ores) Regulations, 2008
• The Ionising Radiation Protection Act, No. 16 of
2005
• The Environmental Protection, Prevention and
Control Act No. 12 of 1990.
• A number of reports from Canada and Namibia.
Field work
This involved visitations to the Chiefdoms in Siavon-
ga and Solwezi District s, where Denison Mines Zam-
bia Limited (DMZL) and the Lumwana Mine Company
(LMC), respectively, are carrying out uranium explo-
ration and/or mining activities. This was with a view
to:
 Finding out how the uranium exploration and min-
ing activities have blended in with communities’
activities.
 Determining how communities in the affected
Chiefdoms were engaged and involved in the de-
cision-making process that have a direct bearing
on their livelihood, such as possible relocation,
loss of immovable assets and agricultural fields
that fall within the mine area.
 Determining how societal and national interests
have been addressed (whether there were any
2 mechanisms for equitable distribution of wealth).
 Establishing what community awareness pro-
grammes were undertaken to highlight the pos-
sible positive and negative effects of uranium,
and benefits that would accrue to them from the
mining and processing of uranium in their areas
and how this enabled them to make informed
decisions on issues that would eventually affect
their lives and the well-being of their future gen-
erations.
Facts about Uranium
General
Uranium is the heaviest naturally occurring element
on earth. It is quite widespread in the earth’s crust,
but concentrated in certain rock formations. As the
uranium atoms slowly disintegrate over time, a host
of radioactive by-products are formed – thorium-
230, radium-226, radon-222 and the infamous radon
daughters, including lead-210 and polonium-210.
Canada is the world’s largest producer and exporter
of uranium. The commercial value and the dangers
of uranium are based on two extra-ordinary proper-
ties which it possesses and these are: a) radioactivity,
and b) that the element is fissionable. The two prop-
erties are quite different.
Radioactivity
Uranium’s property of radioactivity was discovered
by Henri Becquerel in 1896. Afterwards, Marie Curie
observed that even after chemically separating ura-
nium from the rest of the crushed rock, the crushed
rock remained very radioactive – much more so than
the uranium itself. Essentially, most of the radioactive
decay products (about 85%) of the uranium remain
in the crushed rock, when uranium is separated from
the ore. This tallies with the research findings of Marie
Curie that most of the radioactivity is left behind in the
residues. In her research, Curie discovered that this
phenomenon was because of two elements – polo-
nium and radium – that are by-products of uranium.
Radioactive substances have unstable atoms which
can, and will explode microscopically, and when they
do, they give off a burst of energy (Edwards, 1992).
This process is called radioactive disintegration or
radioactive decay. When radioactive atoms explode,
they give off highly energetic charged particles of two
types: alpha and beta. These are particles and not
invisible rays. They are like pieces of shrapnel (metal
balls) from an explosion. And this microscopic shrap-
nel does great damage because of the high energy
of the particles which are given off. Edwards (1992)
explains that when a radioactive atom explodes, that
atom is changed permanently into a new substance.
And radium turns out to be one of the results of ex-
ploding uranium atoms. He goes on to explain that
wherever uranium is found on the earth, radium will
always be found with it because the latter is one of
about a dozen so-called decay products of urani-
um.
When uranium disintegrates it turns into a substance
called protactinium, which is also radioactive. And
when that disintegrates it turns into a substance
named thorium, which is likewise radioactive. When
thorium disintegrates it turns into radium; when ra-
dium disintegrates it turns into radon gas. And when

radon gas atoms disintegrate, they turn into what
are called the radon daughters, or radon progeny, of
which there are about half a dozen radioactive ma-
terials, including polonium. Finally this progression
ends up with a stable substance, which in itself is
highly toxic – lead.
Fission
In 1938, it was discovered that uranium is not only ra-
dioactive, but that it is also fissionable, which makes
it unique among all naturally occurring radioactive
materials. When uranium atoms undergo the fission
process, large amounts of energy are released. Un-
like the process of radioactive decay, which cannot be
turned on and off, nuclear fission can be controlled.
The energy release caused by fission can be speeded
up, slowed down, started or stopped. It can be used
to destroy cities in the form of nuclear weapons, or to
boil water inside a nuclear reactor (Edwards, 1992).
Uranium atoms are radioactive and will disintegrate
with time if they are left alone. However, if uranium
atoms are neutrons – elementary particles without
electric charge – much more violent disintegration of
the atom takes place, which is called fission. When
fission occurs, the uranium atom does not just disin-
tegrate, it actually breaks apart into two or three large
chunks (Edwards, 1992). In the process, it gives off
some extra neutrons and about 400 times as much
energy as is produced by a radioactive disintegration
event.
Review of the Uranium Mining Policy in Zambia
By starting with just one neutron, one uranium atom
can be split, and the extra neutrons can go on to split
two more uranium atoms, giving even more neutrons
which can then split four atoms, which can then split
eight atoms, and so on. In this way, forty quintillion
uranium atoms can be split with only sixty genera-
tions of splittings, all triggered by a single neutron. 3
According to a report by Edwards (1992), this whole
chain reaction, as it is called, takes place in less than
a thousandth of a second. This is what constitutes an
atomic bomb.
It is worth of note that uranium travels in many dis-
guises: in every sample of uranium ore, one finds ra-
dium, but radium is, in a sense, just a transformation
of uranium. In other words, radium is a disguised form
of uranium – one of the many elements in the chain of
decay. Similarly, polonium and radon gas are also just
different manifestations of uranium, so to speak.
Radon and Radon Daughters
Science has found out that as the radon atoms disin-
tegrate, they produce other radioactive substances,
leading to a multiplication of materials which may
not have been there to begin with. And those other
substances – the radon daughters – are extremely
dangerous. Incidentally, polonium is the worst of the
radon daughters – the same polonium that Marie Cu-
rie discovered so many years ago. Recent scientific
evidence shows that polonium is, in many circum-
stances, as toxic as plutonium, and in some cases,
more toxic.
 Review of the Uranium Mining Policy in Zambia

Status of Uranium Mining Policy in Zambia

Introduction
Uranium exploration has been quite active in Zambia
since the beginning of the Millennium. Many explora-
tion companies have since acquired a number of con-
cessions and notable among these are African Ener-
gy Resources (AER)1, Denison Mine Zambia Limited
(DMZL) and Lumwana Mining Company (LMC).
The three Companies have so far reported findings
of commercially viable deposits with LMC already
stock-piling uranium ore that comes as a by-product
of its copper mining activities. DMZL has delineated
commercial deposits in Siavonga and targets to com-
mence production in 2012. AER has also delineated
some commercial deposits in its Siavonga District
concessions.
African Energy Resources (AER)
AER is operating in the Chirundu area, where it holds a
70% interest in the Chirundu Joint Venture project,
with Albidon Limited (ASX: ALB) holding the remain-
ing 30%. The Company is also involved another ven-
ture called the Kariba Valley Joint Venture Project,
where it holds a 30% interest, with Albidon Limited
holding 70%.
The Kariba Valley Joint Venture Project is located
about 250km from Lusaka by road, and is about 50
km to the south-west of Denison Mines’ tenement that
contains the Mutanga-Dibwe uranium deposits (Fig-
ure 1).
AER concessions lie within close proximity to DMZL
Concessions and fall within the same geological envi-
ronment.

Denison Mines Zambia Limited (DMZL)

DMZL is currently developing its Mutanga-Dibwe Proj-
ect located in Siavonga District of Southern Province,
about 175km south of Lusaka and approximately
39km northwest of Siavonga town (Figure 1). Access
to the site from Lusaka is via the Lusaka-Chirundu
and Chirundu-Siavonga tarmac roads and then by a
gravel track to the mine.

4
Uranium exploration in Mutanga-Dibwe Area started
in 2005, when OmegaCorp Limited (OL), through
its Zambian subsidiary, OmegaCorp Minerals Lim-
ited (OML), acquired 946.3km2 Prospecting Licence
– Large Scale (PL-LS) 237 from Okorusu Fluorspar
Limited (Okorusu). Figure1 shows the location of the
DMZL Prospecting Licence area.
Figure 1. Location of the Denison Mines Zambia Limited and Afri-
In 2007, OL, an Australian Stock Exchange (ASX) can Energy Resources’ Chirundu and Kariba Valley Joint Venture
listed company, was 100% acquired by Denison Projects in the Zambezi Valley. Source: African Energy Report
Mines Corp (DMC), a company listed on both the To- (2010).
ronto Stock Exchange (TSX) and American Stock Ex-
change (AMEX). Consequently, Denison Mines Zam-
bia Limited (DMZL), a Zambian subsidiary of DMC
acquired PL-LS 237 from OML.
Lumwana Mine Company (LMC)
Geologically, DMZL Concession lies within the area LMC uranium mining activities fall within the confines
underlain by rocks of the Karoo Supergroup in a of the Company’s copper exploration and mining op-
northeast trending fault-bounded Mid-Zambezi Rift erations at Malundwe and Chimiwungo copper, co-
Valley. The rocks have a shallow dip and are dis- balt, gold and uranium deposits. These are located
placed by a series of normal faults, which in general, in the North Western Province, 95 km west of the
trend parallel to the axis of the valley and the bound- provincial centre of Solwezi on the North West (T-5)
ing faults. The relief in the Valley is generally hilly and Highway (Figure 2), approximately 300 km by road
well-drained. from the Copperbelt city of Kitwe.

The Project lies within a Large Scale Mining Licence
(LML) 49 granted in January 2004 for a period of 25
years and renewable for a further 25 years. The min-
ing licence covers an area of 1 355 km2 and contains
the. Uranium occurs within the Malundwe and Chimi-
wungo copper deposits as discrete uranium-enriched
zones.
Figure 2. Location of Lumwana Copper Project. Source: Lumwana Copper Project EIA Report.
Review of the Uranium Mining Policy in Zambia
Geologically, the Lumwana deposits of Malundwe and
Chimiwungo are hosted within the Mwombezhi Dome,
which is a north-east trending basement dome in the
western arm of the Neoproterozoic Lufilian Arc thrust
fold belt. The Lufilian Arc is a major tectonic province
characterized by broadly north-directed thrust struc-
tures and antiformal basement inliers or domes sur-
rounded by Katanga meta-sediments which host the
Central African Copperbelt.
 Review of the Uranium Mining Policy in Zambia
Institutional & Legal Framework of Uranium Mining in Zambia
Institutional Framework
In Zambia, the administration and regulating of all
mining activities are the portfolio responsibility of
the Ministry of Mines and Minerals Development
(MMMD). Three line departments - Geological Survey
Department (GSD), Mines Development Department
(MDD) and Mines Safety Department (MSD), perform
the technical functions of the MMMD.
The primary role of the GSD is to provide geological,
geophysical and geochemical data on countrywide
basis, to act as a national depository of all information
related to geology in Zambia, and to provide support
and advisory services to the public.
The MDD’s key responsibilities are the issuance of
all prospecting, retention and mining licences,
monitoring of mining operations to ensure that
development is in line with approved programmes
and in accordance with the Mines and Minerals De-
velopment Act.
The Department is also responsible for the collec-
tion of all licence fees and maintains an inven-
tory of all data related to the licences through its
Cadastre Unit. The MSD, on the other hand, deals
with aspects of Mines Safety – enforcing the regu-
6 lations. Whether or not there is the expertise to see
through the challenges posed by uranium exploration
and mining, and to enforce the law, remains another
matter.
Environmental Council of Zambia (ECZ) became op-
erational in 1991. It was created by an Act of Par-
liament to oversee activities of all industrial, mining,
agricultural and service companies that may have en-
vironmental and social impacts in order to minimise
and mitigate these impacts. The ECZ requires the de-
velopment of Environmental Impact Assessments for
all new and existing projects. The ECZ is responsible
for the collection and dissemination of environmental
and social information, and for improving environ-
mental awareness of the public.
In addition, the ECZ issues annual licences with re-
spect to environmental activities e.g. waste manage-
ment, effluent discharge, gas releases.
1 Although African Energy Resources was not included in the Terms of Reference for this study, it was discovered during
the field visitations that the Company was also very actively involved in exploration activities in Siavonga. So, a decision
was taken by the client to include it in this study.
The Radiation Protection Board (RPB) was estab-
lished through the Ionising Radiation Act, 1972, which
was responsible for the responsible management of
all potentially harmful sources of radiation through oc-
cupational or environmental exposures. In 2005, the
Radiation Protection Authority (RPA) was established
through the Ionising Radiation Protection Act, 2005.
The RPA is a corporate body and is responsible for
advising the Government of Zambia on all policy mat-
ters related to ionising radiation, implementing all leg-
islative measures related to ionising radiation to pro-
tect employees and the public, and for educating the
general public on radiation issues. The RPA is also
responsible for issuing licenses for processing, stor-
age, transport, import, export and use of radioactive
material within specified levels.
Policy, Legal and Regulatory Framework
Introduction
Zambia has no specific policy framework on ura-
nium. Issues pertaining to uranium exploration/ min-
ing are only embedded in the general Mines and Min-
erals Development Policy of 2008. However, there
are a number of principal and subsidiary legislation
that relate to exploration and mining of uranium in the
country, each addressing a specific area of interest in
the administration. Collectively, they provide the guid-
ance, regulatory platform and service facilitation of
the industry in particular.
In addition, most of the legal and regulatory frame-
works were enacted long before the advent of ura-
nium exploration and mining, except the Prospecting,
Mining and Milling of Uranium Ores and Other Ra-
dioactive Mineral Ores Regulations of 2008. As such,
they are generalised in their nature and are not ad-
equate for uranium development. The extra-ordinary
characteristics of uranium, as indicated above, re-
quire mining policies and regulatory frameworks that
are specific to it.
The Mines and Minerals Development Act No. 7 of
2008
In 2008, the Mines and Minerals Development Act No.
7 of 2008 was developed and passed by Parliament
to repeal the Mines and Minerals Act of 1995. In the
same year, a subsidiary legislation specifically on ura-
nium operations – the Statutory Instrument No. 85 of
2008 – was put in place.

WE HAVE NOT BEEN EDUCATED: Local community members sharing their concerns with the team from
the Council of Churches in Zambia during the field trips
This Statutory Instrument, Mines and Minerals
Development (Prospecting, Mining and Milling
of Uranium Ores and Other Radioactive Mineral
Ores) Regulations, 2008, forms the basis for mining
of uranium and other radioactive mineral ores in Zam-
bia. It stipulates the requirements concerning applica-
tion, exploration and mining licensing. It is aimed at
ensuring the protection of the environment, health
and safety of workers and the general public.
The legislation also stipulates requirements regarding
the security and transportation of finished products,
and bars the diversion of the mineral for use in making
nuclear weapons or devices.
The law gives all powers to the Minister of Mines to
issue licences for mining and exportation of uranium
as well as to safeguard and ensure that the mineral is
sold to the right consumers.
It also makes it mandatory for mining companies
and exporters of uranium to provide documentation
on the source of uranium concentrate or radioactive
materials and to prove the authenticity of importers
under the International Atomic Energy Agency (IAEA)
Guidelines. Foreign and local firms seeking to export
uranium would have to apply for export licences from
the Radiation Protection Authority under the Ministry
of Health.
Review of the Uranium Mining Policy in Zambia
Further, the legislation imposes strict management
plans for natural water, water coming from mining ac-
tivities, and waste products from the uranium mining
activities to avert major damage to the environment 7
and health of miners and others. Mining firms are
required to initiate radiation protection management
plans, waste management plans and quantitative ra-
diological hazard and safety assessments plans be-
fore obtaining a mining licence, the regulations state.
Environmental Protection and Pollution Control
Act No. 12 of 1990
The Environmental Protection and Pollution Control
Act (EPPCA) provides for the establishment of the
ECZ to enforce the provisions of the Act and the SIs.
The Act provides guidance on the development of en-
vironmental assessments in the form of Environmental
Project Briefs (EPBs) or Environmental Impact State-
ments (EISs), depending upon the scale or magnitude
of project activities and anticipated impacts.
All environmental assessments are reviewed and de-
cisions are made on the implementation of the respec-
tive projects. Under this Act, the ECZ is responsible
for the collection and dissemination of environmental
and social information, and for improving public’s en-
vironmental awareness.
 Review of the Uranium Mining Policy in Zambia
The EPPCA outlines the requirements of license ap-
plications under the following subsidiary legislation:
a) Statutory Instruments No. 28 of 1997 Environmen-
tal Impact Assessment Regulations – provides
the framework for conducting and reviewing envi-
ronmental impact assessments for any project.
The requirement of these Regulations is that no
developer shall implement a project for, which a
project brief or an environmental impact state-
ment is required, unless the project brief or an
environmental impact assessment has been con-
cluded in accordance with these Regulations and
the Council has issued a decision letter. It also
provides regulations for auditing project imple-
mentation.
b) Statutory Instrument No. 71 of 1993 Waste Man-
agement (Licensing of Transporters of Wastes
and Waste Disposal Sites) Regulations – The
act provides for licensing of solid non-hazardous
waste transportation and the operation or man-
agement of a non-hazardous waste disposal
site;
c) Statutory Instrument No. 125 of 2001 Hazardous
Waste Management Regulations – provides for
licensing of solid hazardous waste transportation
and operating/owning of a hazardous waste dis-
posal site;
d) Statutory Instrument No. 72 of 1993 Water Pollu-
tion Control (Effluent and Wastewater) Regula-
tions – The act discusses licensing requirements
for the discharge of liquid waste to the environ-
ment and supplies statutory discharge limits for
respective parameters;
8 ter publication in the Gazette. Any disputes except for
e) Statutory Instrument No. 20 of 1994 Pesticides
and Toxic Substances Regulations – provides
for licensing of importation, transportation, distri-
bution and storage of pesticides and toxic sub-
stances; and
f ) Statutory Instrument No. 141 of 1996 Air Pollu-
tion Control (Licensing and Emission Standards)
Regulations – provides for licensing of gaseous
waste emission to the environment and also pro-
vides for statutory discharge limits for respective
parameters.
Ionising Radiation Protection Act, 2005
The Ionising Radiation Protection (IRP) Act, 2005 re-
pealed the Ionising Radiation Act, 1972, and estab-
lishes the Radiation Protection Authority (RPA). The
Act provides for the protection of the public, workers
and the environment from hazards generated by the
use of devices or proximity to materials that produce
ionising radiation. The role of the RPA is similar to that
of the ECZ, in that it also acts to:
 promote safety, health and the protection of the
environment;
 implement the IRP Act and ensure compliance
from licensees;
 conduct all licensing of ionising radiation devices,
sources or activities;
 conduct audits of facilities and staff monitoring as
required during licensing; and
 provide educational material, workshops and
programs to improve public awareness and un-
derstanding of ionising radiation.
The Land Act of 1995 and the Land Acquisition
Act of 1970
The Land Act of 1995
The Land Act of 1995 was enacted to guarantee peo-
ples’ right to land while enhancing development. The
Act recognises the holding of land under customary
tenure and the Chief’s role has been legally recogn-
ised, such that land cannot be converted or alienated
without approval of the chief.
The Lands Acquisition Act No. 2 of 1970
Land acquisition is governed by the Lands Acquisi-
tion Act No. 2 of 1970. The Act sets out regulations
for compulsory acquisition of land and property and
compensation for such acquisition. The president (his
designated and authorized person) may acquire any
property in the interest of the Republic. Notice shall
be given in person not less than two months in ad-
vance and shall be gazetted.
Compensation for acquired property, losses and dam-
ages shall be paid as may be agreed or, finally deter-
mined by the National Assembly in case agreement
on compensation is not reached within six weeks af-
disputes related to the amount of compensation may
be instituted for court proceedings. The Act also pro-
vides for compensation to be granted by allocation of
new land to the property owner.
The Act instituted a Compensation Advisory
Board to advise the Minister of Lands in assessment
of compensation payable under the Act. The func-
tions of the Board have been delegated to various
committees. Various forms to be used in proceedings
of property acquisition are prescribed in the statutory
Instrument No. 60 of 1970.
 Review of the Uranium Mining Policy in Zambia

Current Levels of Adherence to Legislation by Companies

Operating in Zambia
vironmental impacts consequential to the implemen-
tation of any Project are assessed well in advance,
and to propose possible mitigation measures for any
negative impacts.
Environmental Impact Assessments (EIA)
However, in the state, in which the EPB is presented
In accordance with the provisions of Environmental
here, no socio-economic and environmental impacts
Protection and Pollution Control Act No 12 of 1990,
have been assessed. According to an AER official,
LMC and DMZL produced and submitted Environ-
they just went with an ECZ official to the project area,
mental Impact Assessment (EIA) reports to the En-
who discussed with some members of the commu-
vironmental Council of Zambia (ECZ) on 28 August
nity, made his/her assessment of the situation on the
2008 and 13 August 2009, respectively.
ground, and approved the exploration programme
without any documentation of the consequential so-
LMC held its public consultation meeting with the
cio-economic and environmental impacts that would
communities and interested stakeholders on 3 – 4
arise from execution of the exploration programme.
October 2008, while DMZL held a similar meeting on
4 June 2009.. Alongside the EIA Report, DMZL also
submitted a Resettlement Action Plan. Cover pages The question is, when is ECZ supposed to demand
of the Reports are given in Figure 3. for an EIA? DMZL would appear to still be in the ex-

Figure 3. Cover pages for the Environmental Impact ploration stage, why would they have been asked to
Assessment Reports for Lumwana and submit an AIE report?
Denison Mines Zambia Limited.
Commitment to Environmental Protection and
The EIA Reports by DMZL and LMC were considered
Land Rehabilitation
and approved on 29 October 2009 and 31 October
The DMZL’s EIA report outlines a Radiation Manage-
2008, respectively. Approval for each project was
ment Plan (RMP) for the protection of workers, mem-
communicated to the proponents through Decision
bers of the public and the environment in accordance
Letters, which also stipulated a number of conditions
with Regulations 6, 7 (1) and 8 of the Mines and Min-
that needed to be fulfilled before and during the ex-
erals Development (Prospecting, Mining and Milling
ecution of each project as contained in Appendices 1
of Uranium ores and other Radioactive mineral ores)
and 2 for DMZL and LMC, respectively.
Regulations, 2008.
AER submitted an Environmental Project Brief (EPB)
before commencement of its exploration programme,
The EIA report also contains the Company’s Safety,
which is contained in Appendix 3. This was to fulfil the
Health and Environment Policy that would direct and
EIA regulations’ demand that socio-economic and en-
govern operations of its facilities in dealing with the
 Review of the Uranium Mining Policy in Zambia

safety of its workers, its community and the environ- With regard to Land Rehabilitation, both Companies
ment. The Company pledges that whenever issues of complied with the Statutory Regulation 11 (1) by
safety conflict with other corporate objectives, safety detailing their Mine Decommissioning and Closure
shall be the first consideration. Plans. In spite of the availability of these plans, the
major anticipated challenge pertains to staffing levels
Similarly, LMC also formulated a RMP in accordance at the ECZ and the MSD to monitor the implementa-
with the Regulations cited above for the protection of tion of these plans.
workers, members of the public and the environment.
Like DMZL, LMC’s EIA also incorporates an envi-
ronmental and social management plan to mitigate
against environmental impacts envisaged to arise
from mining activities by the Company.

10

Adequacy of Legislation for Uranium Exploration & Mining
Introduction
Exploration, mining, and processing activities in the
mining sector appear to have brought some harm to
the people that may have lived in areas, where these
activities have been undertaken. In some instances,
people have been forced to relocated from areas,
where they have lived in excess of 200 years, without
commensurate compensation to facilitate an honour-
able fresh start to a sustainable livelihood in their new
areas of settlement.
Most of the foregoing may be attributed to the his-
torical perspective, where the mining industry usually
took a evil may care attitude to the impacts of its op-
erations on the communities – by operating in areas
without social legitimacy, causing major devastation,
and then leaving when an area has been exhausted
of all economically valuable resources (Jenkins &
Obara, 2008).
Whilst it is recognised that mining may bring enor-
mous economic benefits to a state, these benefits
must not be undertaken at the expense and well-
being of rural communities and their way of life. The
book of Genesis calls upon all of us to look after the
earth and to have domination over the earth in a re-
sponsible stewardship manner.
In order to protect communities from irresponsible
stewardship of their environment by institutions ex-
ploiting and processing what lies in the soil below
their houses, measures must apply at all stages of
exploration, mining, processing and plant decommis-
sioning to ensure that people and the environment
are not harmed. This would generally be assured
through enforcement of appropriate legislation.
Currently, uranium exploration/mining in Zambia is
governed by legislation outlined in Section 4.2 above.
However, it is worth of note that most of the uranium
exploration activities started before the legislation
was enacted to direct and govern such activities. So,
the pertinent question is, how adequate and effec-
tive is this legal framework, particularly in the
governance of uranium exploration, mining and
processing in Zambia? A general reflection is given
about what people, in the areas, where these activi-
ties are taking place, feel about its adequacy.
Review of the Uranium Mining Policy in Zambia
Community Concerns and Safety.
With regard to the safety of the community, dissemi-
nation of information to make them aware of what per-
tains to the exploration and mining of uranium would
appear not to have been adequate, particularly that
the mining of uranium is not like of any other metal
that has hitherto been dealt with in Zambia.
Chief Sikoongo’s Area – AER
One major concern of the community in Chief Sik-
oongo’s area, where AER is undertaking uranium ex-
ploration drilling was that they were not given enough
information, either by government or AER, on the
benefits and the cumulative (long-term) challenges
that would accrue to them (and the environment) from
uranium exploration and subsequent mining in their
chiefdom. They report that conflicting information was
given by the Company with regard to the dangers of
uranium, which they say, has left them very uncertain
as to what is true. As such, the community is not sure
how best to deal with the information given to them.
As a result of this information, they expressed worry
about some of the drilling activities, which, they say,
were undertaken very close to some houses. Their
worry is that they may have inhaled some dust from
drilling operations, from which they have fear for the
long-term implication of this exposure on their health
and that of their children. AER did not dispute carry-
ing out drilling activities close to people’s homes, but
that this, they say, was done after consultations with
the affected families. The agreement was that the af-
11
fected families were asked to stay away from their
houses during the two-three hours of drilling. Each
family was compensated with 2 x 50 kg bags of maize
for this inconvenience.
However, the community has expressed concern and
fear emanating from recent observations of a sudden
increase in abortions in, and deaths of, particularly,
goats. There is a feeling that the dust generated from
drilling activities may have been washed by surface
water into the animals’ watering basins, thereby cre-
ating these problems in their livestock. Yet, without
any baseline study undertaken before the operations
started, it is difficult to scientifically confirm this asso-
ciation in Chief Sikoongo’s area.
In spite of the aforesaid, similar incidences have
been reported from South Africa’s Krugersdorp
Game Reserve, where miscarriages and high mor-
tality among wildlife, suspected to have arisen from
animals drinking water suspected to have contained
high levels of uranium, have been reported (Box 1).
 Review of the Uranium Mining Policy in Zambia
Box 1. Acid Mine Drainage (AMD) in Kru-
gersdorp Game Reserve, South Africa
The issues expressed above are what were supposed
to have been addressed by an Environmental Impact
Brief (EPB), which the project proponents submitted
to the ECZ for the approval of their exploration activi-
ties in the concerned areas.
Any EPB is supposed to adhere to the requirements
of the Environmental Impact Assessment (EIA) reg-
ulations of the Environmental Protection and Pollu-
tion Control Act (EPPCA) of 1990. These regulations
demand that socio-economic and environmental
impacts consequential to the implementation of any
planned Project are assessed well in advance, and
propose possible mitigation measures ahead of proj-
ect implementation.
However, in spite of such stipulations, the EPB sub-
12
mitted ahead of these exploration activities (Appendix
3) does not indicate any assessment of socio-eco-
nomic and environmental impacts that would result
from implementation of the project. According to the
project proponents, the impacts were assessed in the
field in the company of an official from the ECZ, who
also talked to/with the affected people and made their
own assessments that led to the approval of the proj-
ect.
Had an assessment been done, challenges of drilling
near people’s homes and the resultant livestock prob-
lems would not have arisen as these would probably
have been foreseen, and remedial measures would
have been recommended for mitigating against nega-
tive environmental effects.
When mining starts, a number of villages will need to
be relocated, and this notification has already been
given to the people. However, the community feels
that the land which has been earmarked for their relo-
cation is not suitable to support their livelihood activi-
ties. And if this should be the case, the relocation of
the community will not result in improved, but worsen-
ing of its livelihood status.
In addition, memories of a relocation to pave way for
the construction and flooding of the Kariba Dam are
still fresh on the minds of most of the communities in
Chief Sikoongo’s and many other areas in the Zam-
bezi valley area (Box 2).
Box 2. Population displacement and resettlement to pave
way for the Kariba Dam
The Kariba Dam is one of the largest dams in the world
at 128 m high and 579 m long. The double curvature con-
crete arch dam was constructed between 1955 and 1959
by Impressit of Italy at a cost of $135,000,000 for the
first stage with only the Kariba South power cavern. Final
construction and the addition of the Kariba North Power
cavern by Mitchell Construction was not completed until
1977 due to largely political problems for a total cost of
$480,000,000.
In addition to men losing their lives during construction,
the creation of the reservoir forced resettlement of about
57,000 Tonga people living along the Zambezi in both
Zambia and Zimbabwe. Several thousand large animals
threatened by the rising water were rescued by Operation
Noah. After consultations broke down, the Tonga people
were forced to leave their homes and fertile lands that had
been under cultivation for hundreds of years. The reservoir
flooded the communities, where for centuries these peo-
ple had farmed, fished, worshipped, raised their children
and buried their dead. The Rhodesian government did,
however, provide some aid to the displaced Tonga tribe.
According to an extract from ‘The Shadow of The Dam”, a
first-hand account written by David Howarth in the 1960’s,
“Everything that a government can do on a meagre budget
is being done. Demonstration gardens have been planted,
to try to teach the Tonga more sensible methods of agricul-
ture, and to try to find cash crops which they can grow. The
hilly land has been ploughed in ridge contours to guard
against erosion. In Sinazongwe, an irrigated garden has
grown a prodigious crop of pawpaws, bananas, oranges,
lemons, and vegetables, and shown that the remains of
the valley could be made prolific if only money could be
found for irrigation. Cooperative markets have been orga-
nized, and Tonga are being taught to run them. Enterpris-
ing ‘Tonga have been given loans to set themselves up as
farmers. More schools have been built than the Tonga ever
had before, and most of the Tonga are now within reach
of dispensaries and hospitals.’ There are many different
perspectives on how much resettlement aid was given to
the displaced tribe. According to anthropologist Thayer
Scudder, who has studied these communities since the
late 1950s, ‘Today, most are still ‘development refugees.’
Many live in less-productive, problem-prone areas, some
of which have been so seriously degraded within the last
generation that they resemble lands on the edge of the
Sahara Desert.’ A 1961 book, The Shadow of the Dam by
David Howarth focused on the resettlement of the Tonga
tribe during the construction of Kariba Dam. A 2005 book,
Deep Water by Jacques Leslie focused on the plight of the
people resettled by the dam, and found the situation little
changed. Kariba remains the worst dam-resettlement
disaster in African history. http://en.wikipedia.org/wiki/
Kariba_Dam
 Review of the Uranium Mining Policy in Zambia

From the Kariba experience, the community is not
sure about the duration of these exploration and min-
ing activities in the area, and whether or not the land
that has been taken from them to pave way for these
mining activities will revert to them at cessation of
mining activities.
Another major concern by the community is the is-
sue of casualisation – that although government pro-
pounded the creation of employment as one major
benefit to be derived from the opening up of these
mines, there was no contract signed with the locals
that were employed by the Company. In addition,
those employed were generally in the category of
general workers.
From information gathered from the community, an
impression was created that there may not have been
enough prior information given to the people about
the activities of AER in the area. In which case, it may
be necessary for concerned authorities at AER and
officials from government to give enough information
to the people so that they may be guided in their ne-
gotiation-process in giving consent on how the proj-
ect should progress in that Chiefdom.
Whether communities agree to be relocated and allow
the project to proceed, or not, the challenge will be to
ensure that if they are relocated, they are better off,
and not worse off. And without any assessment the
baseline environmental trends and socio-economic
data in the Project area, the long-term health status
of the communities in the area is a challenge they will
have to deal with themselves – unfortunately!
Chief Sinadambwe’s Area – DMZL
The Uranium mining and processing activities envis-
aged to begin in Chief Sinadambwe’s Chiefdom in
2012 will displace a total of 107 households with 342
people from Chiyobeka, Kasambo, Kapita, Chilundu,
Sinangosi and Kumulilansolo Villages (AMC, 2009).
According to the community, the directive to get the
villagers relocated was given by the government. So,
communities did not give consent to their being relo-
cated, although they did not have any choice. These
are the same people that were once forcibly removed
from the areas that were flooded to pave way for the
development of the Kariba Dam, and they are being
forced to relocate again – like the case of Bushmen in
Botswana (Box 3).
Their key concerns then, and now relate(d) to the re-
location activities, the amounts of compensation and
the assets compensated for.
The agreed relocation site for the affected households
at Kashudi2 is only 9 kilometres from the Mutanga
mine site, where uranium mining and processing will
be undertaken, although, in the opinion of DMZL, even
3 km would be sufficient. This is in strong contrast
with what Chiefs Simaamba and Sinadambwe are
said to have experienced in Namibia, where DMZL
took them on a familiarisation tour to acquaint them
with operations of uranium mining/processing (Box
3). Their experience was that such uranium mining
activities took place far (in excess of 100 km) away
from any areas of human habitation.
Another concern from the community was that DMZL
did not undertake any lung function tests for the vil-
lagers, especially primary school children, to deter-
mine their pre-mining health status. The reason for
this failure is said to have been the non-availability of
local health facilities at which the testing could have
been done. However, DMZL will subject all employ-
ees to lung function testing before being hired and 13
would be tested regularly throughout their period of
employment.
Members of community expressed some knowledge
of the dangers of uranium and asked DMZL during
the public consultation (Appendix 4), how the people,

Box 3. Sixteen uranium exploration licenses granted on Bushman land since evictions

Since the Bushmen were forced off their land in the Central Kalahari Game Reserve (CKGR) in 2002, the Botswana
government has granted 112 mining licenses for mining companies to explore in the reserve. 16 licenses have been
awarded for uranium exploration and 40 for coal. It is just over six years since the government evicted more than
600 Bushmen from the reserve, although it has always denied any connection between mining and the evictions.

The Bushmen won the right to return to their land inside the reserve in a landmark ruling at Botswana’s High
Court in 2006, where the judges recognized that the evictions had been ‘unlawful’ and ‘unconstitutional’. But the
Botswana government is doing all it can to stop the Bushmen from going home, banning them from using a water
borehole to get water inside the reserve, and stopping them from hunting for food. Meanwhile, any mines in the
reserve will have to drill multiple boreholes to operate, and will create massive disruption to both the Bushmen
and the wildlife. (Survival International March 3, 2009)

2 Kashudi was selected as the area of relocation because it was felt to have plenty of water for people and livestock, the
area was big enough to settle all villagers, had a good drainage system and good pastures for animals.
 Review of the Uranium Mining Policy in Zambia
who had been laid off, would be looked after. The re-
sponse from DMZL was that if it could be proved
that the people developed health problems attribut-
able to their employment, then DMZL would look after
them. However, the irony of this answer is that it ap-
pears to be elusive, particularly that proof of a worker
developing health issues attributable to employment
could only have been established if a pre-mining
health status of this employee were established, but
which was not. What must be borne in mind, when
discussing this issue, is the fact that some of the ef-
fects may only be manifested after decades – long af-
ter the mining company has wound-up its operations.
So, who would take care of such persons?
One of the final concerns from the community in Sia-
vonga is that, from the location of DMZL and AER ac-
tivities (Figure 1), great care must be taken, by both
the Government of the Republic of Zambia and the
two project proponents, to ensure that no accidental
spillages occur into the environment (and into Lake
Kariba). However, the report that the heap leach will
be on top of the hill around Mutanga to the South of
the area, and that large volumes of water pumped
from the Mutanga Pit will be used for such other pur-
poses like irrigations (minutes of the public consulta-
tion), raises worry for such accidental spillages. The
community’s worry is that, if such an accident oc-
Box 4. Environmental and human rights issues
spillage of hazardous material from the Konkola
Mine into the Kafue River in December 2006. The
Environmental Council of Zambia threatened to take
the company to court but did not proceed, leaving
14
some Zambians questioning why the council did
not take action when it had a legal right to do so.
Pollution from the mining of copper also threatens
the health of the residents in the area. For instance,
continued use of reverberatory furnaces for smelting
produces a large volume of hazardous sulphur diox-
ide gas. A number of respiratory illnesses have been
recorded among inhabitants in Copperbelt Province,
with asthma and lung diseases two of the most re-
ported cases. In addition, open-pit mining deforms
the surface of the land and creates waste materials
containing dangerous substances that pollute the
water, soil and atmosphere.
A fatal accident at BGRIMM factory in April 2005 was
responsible for the deaths of over 45 Zambians. The
cause of the accident has not been made public of-
ficially but it has been speculated that the accident
was caused by inadequate or poor safety measures,
including the use of untrained Chinese personnel.
The Chinese government offered US$10 000 com-
pensation to the victims of the accident, although
no negotiations were held with the families of the
victims. (Mwitwa & Kabemba, 2007).
curred, as experienced at KCM and BGRMM (Box
4), this would have far-reaching consequences for
tourism and fishing in Siavonga District, and on the
well-being of the country and other Zambezi River’s
riparian states downstream of the dam.
Chiefs Matebo’s, Mukumbi’s and Mumena’s Areas
– LMC
Lumwana has been active in mining for a much lon-
ger period than any of the other two Companies in
Siavonga, although its initial operations involved cop-
per, while uranium has been produced as a by-prod-
uct. Expectations of communities in the Lumwana
area, in the initial stages of the mine, evolved around
the mine creating jobs for them. However, like with
communities in Chiefs Sikoongo and Sinadambwe,
most of the employment has remained casual and
of a general-workers’ nature. As such, the bitterness
of the community in the Chiefdoms is that most of
the high calibre employment opportunities have been
taken up by outsiders. This has been attributed to the
highly ‘advanced technology’ that is employed by the
mine, and which local communities do not measure
up to, academically. In spite of this challenge, there
has not been any deliberate and proactive policy to
capacitate and empower the local community mem-
bers with the same knowledge.
However, Chief Mumena considers this as a positive
development because ‘it has made the youths in the
area to appreciate the value of education’. As such,
most of them are now trouping to school to attain edu-
cation levels that are commensurate with the technol-
ogy employed at the mine. Although no necessarily
capacitating local communities with high-level educa-
tion, Lumwana offers full and partial sponsorship to a
number of students in the schools of Engineering and
Mines at the University of Zambia.
Since LMC started with the mining of only copper,
the issue of relocation of local communities to distant
places to ensure their safety from uranium-related
hazards may have been a non-issue. However, new
developments to include uranium mining necessi-
tated relocation of the local communities. However,
the Company appears to have made relocation an
optional issue for the communities. This is probably
because the Company had not included this cost in
its budget. This may be deduced from the relocation
package, which according to Chief Mukumbi, was
meagre and only compensated for cassava fields and
not any other immovable asset, like houses, kraals,
crop barns, etc.
According to Chief Mumena, the people could not ar-
gue about the value of their fields, because the situ-
ation was turned into one of take-it-or-leave-it. As a
result, some of the people in the chiefdom opted not
to shift.

Further, people involved in the relocation in Lum-
wana, like their colleagues in Siavonga, were not in-
formed that this shift was permanent, and they would
not return to their homelands ever again. This again
shows that lack of information disabled the local com-
munities to make informed decisions, because it is
uncertain that they would have agreed to move had
they known that the loss of their ancestral lands was
a permanent feature.
From Figure 2, it can be seen that even Chief Muku-
mbi’s Palace is within the Mine Licence Area. With
this arrangement, disclosure by Equinox Minerals
Limited president Craig Williams (Post Newspa-
pers, 25 January 2010 (http://www.postzambia.com/
post-read_article.php?articleId=4928) that mining
and stockpiling of high-grade uranium mineralisation
at Lumwana Copper Mine continued during the last
quarter of 2009, with uranium ore stockpiled on the
Run-of-Mine (RoM) pad standing at 2.5 metres, gives
another dimension of concern for the safety of com-
munities within the mine licence area, who may have
resisted relocation on account of meagre packages
and a lack of, or misinformation on the dangers of
uranium. The question is, who will speak for these
people?
So, although LMC maintains that there are no private
land holdings or residential dwellings within the pro-
posed disturbance area of the Project, the situation in
the mine licence area may need to be re-evaluated by
the MSD and ECZ.
Even institutions, like Mopani Copper Mines, whose
staff would have been expected to be quite enlight-
ened to handle and deal with issues of uranium pro-
cessing, refused to handle and process Lumwana
copper because of its uranium content (Box 5).
Box 5. Zambia’s Chambishi smelter processing Lum-
wana copper
Chinese-owned Chambishi copper smelter has start-
ed processing concentrate from Zambia’s Lumwana
copper mine, initially rejected by another smelter
after claims it contained uranium, a senior official
said on Saturday (Sep 26). Harry Michael, chief ex-
ecutive of Lumwana mine, a unit of Equinox Minerals
Ltd, said Chambishi smelter would treat 55 percent
of the company’s annual output under a five-year
agreement. Lumwana’s copper concentrate was re-
jected by Mopani Copper Mines (MCM), majority
owned by Glencore International AG of Switzerland,
after Mopani claimed in March that the concentrate
had high uranium traces. (Reuters Sep. 26, 2009).
Review of the Uranium Mining Policy in Zambia
Therefore, if uranium mining and processing pro-
ceeds at Lumwana, these people are likely to be af-
fected by such activities.
A critical review of the questions and answers con-
tained in the minutes of the public hearing of the ura-
nium EIA (Appendix 5) indicates that stakeholders
were not convinced that the project could be imple-
mented in a safe and healthy manner and with negli-
gible short- and long-term effects on the environment.
Arising from this observation, the Public Hearing Fa-
cilitation Consultants recommended that project ap-
proval should have been linked, among others, to the
following:
a) The project’s approval should have been subject
to the ECZ developing adequate professional
competency and capacity to monitor the project,
especially radiation monitoring, both within the
work environment and the wider environment.
Further, that the roles and responsibilities be-
tween the ECZ, the MSD and the RPA, for this
project, needed to have been well-defined and
agreed upon.
b) Mandatory education and communication pro-
grammes aimed at informing and educating
stakeholders on;
 what is involved in uranium mining
 potential sources of radiation contamination
 measures to minimise/prevent and compensate
for its likely effects
 measures to be taken by workers and the com-
munity to safeguard themselves and the environ-
ment against this contamination up to the time of
mine closure.
15
In spite of none of these recommendations being ful-
filled, the Lumwana uranium mining project has been
approved, while the community’s concerns and anxi-
eties still remain unaddressed.
The community still requires assistance to raise its
awareness on the benefits and challenges arising from
uranium mining and processing, and how they can
safeguard themselves against any adverse health ef-
fects arising from these activities. This will ensure that
the community have information; they are adequately
empowered and equipped with knowledge to enable it
to make well-informed decisions. Equipped with such
information and knowledge, people of south-eastern
New Brunswick were able to voice out on issues of
uranium (Box 6).
The absence of a policy on uranium, with its spe-
cial peculiarities and dangers, may be the reason
for some of the inherent gaps and weaknesses in
the current legislation, especially with regard to its
inadequacies to attend to community interests, as
discussed in the sections that follow below.
 Review of the Uranium Mining Policy in Zambia

Worker Safety
Worker safety issues for the DMZL and the LMC ap-
pear to have been elaborated in their environmental
Box 6. Public voices uranium mining concerns – Pe-
titions promised to alert government to opposition
to exploration.
A group of Metro Moncton residents attended an
information session on uranium mining at the Mag-
netic Hill Lions Club on the evening of 6 May 2008.
About a month earlier, a 35-year-old Gorge Road resi-
dent was filling a plastic bottle at a nearby spring, like
he had done countless times before, when his daugh-
ter Madison asked why so many of the surrounding
trees had pretty blue ribbons around them.
McLaren had never noticed the ribbons before, but
he did some research and discovered they were not
for decoration. The ribbons were tied to the tall trees
by mineral exploration companies to show the area
had been explored for uranium.
“That scared me,” McLaren said. “When you’re talk-
ing about exploration, you’re talking about having an
effect on the water supply. When you’ve got young
kids like I do, you don’t want anything interfering
with the water supply.”
McLaren doesn’t get his water from any of the Gorge
Road’s dozen or so natural spring sources anymore.
McLaren told his story to about 100 concerned citi-
zens who attended a public awareness session on
test drilling and uranium mining that evening at the
Magnetic Hill Lions Club.
His son Patrick convinced him it was not enough to
just be outraged at the increased presence of ura-
16 nium exploration in south-eastern New Brunswick.
“It was time to get off the couch and do something
about it so we’re going to spend an hour a day cir-
culating a petition,” McLaren said. “We’ll walk the
streets and get as many signatures as we can. I’d
like to get two or three thousand signatures before
it goes to the provincial government. They’ll have to
notice that.”
Article by Dwayne Tingley; Times & Transcript Staff;
7 May 2008 (http://www.minesandcommunities.
org/ article.php?a=8603).
With regard to the disposal of the cores, an AER of-
ficial said that these would be milled and processed
on a leach pad together with the other mined ore.
However, there is no guideline in the statute books
as to what would happen to these cores in the event
that AER did not proceed to the mining stage of its
operations.
Although legislation may be available, its major weak-
ness lies with its enforcement. This appears to arise
from the recognised deficiency in manpower levels at
ECZ, MSD and RPA to do so. For instance, although
one of the objectives stated in the Mines and Miner-
als Development Policy, to ensure worker/community
safety, is
‘to achieve a socially and internationally accept-
able balance between mining and the bio-phys-
ical environment and to ensure that acceptable
standards of health, safety and environmental
protection are observed by all participants in the
mining sector through putting in place an institu-
tional framework for providing effective mecha-
nisms for enforcing, monitoring and regulating
safety, health and environmental standards
in the mining sector by implementing capacity
building programmes for the personnel in the
Mines Safety Department’
not much has so far been done towards realising
this goal, even when uranium exploration and min-
ing activities are already being actively pursued on
the ground. What government needs is to realise the
gravity of these activities on the environment and its
people and quickly move to put action to its words in
order to safeguard their well-being.

policy and training manual incorporated in the com-

panies’ EIA reports. The major challenge will be for
government’s regulatory bodies to ensure their imple-
mentation.
However, with regard to AER, the challenges posed
to workers’ safety may need to be examined from the
manner, in which drill cores are stored (Figure 4). Al-
though project proponents say that monitoring results Figure 4. The open core sheds (left) storing uranium
for the sheds obtained from a South African labora- exploration drill cores (right) at the African Energy
tory show values below what would pose threats to Resources shed in Chief Sikoongo’s area.
human health, it would have been important to get
comparative results from a local laboratory.

Headmen and local community members at a meeting with the team from The Council of Churches
in Zambia at the Sikoongo’s Chiefdom
Community Participation in the Mines’ decision-
making Process
The community and professionals engaged in ura-
nium mining and processing worldwide recognise
that managing radiation, health and safety, waste
and the environment is of paramount importance for
the protection of workers, the public and the environ-
ment (WNA). This recognition, and the acceptance of
commensurate responsibility, is what is required to be
fundamental to the vision, values and measures of
success for any up-starting mining company.
However, what needs to be clarified in Zambia at the
moment is how the mining houses consult with com-
munities, by making grandiose promises to communi-
ties about the benefits (and not obligations), creation
of jobs, contribution to GDP and overall economic
benefits associated with the mining investments. Little
is said of how such investment will shape economic
development, especially that of communities, most of
whom are forced to relocate to make way for mining.
To ensure that communities participate in the deci-
sion-making process on issues that eventually end
up defining the final destiny of their livelihoods, there
must be a deliberate move by government to protect
its citizenry. This would be attained by formulating
and enforcing legislation that promotes active partici-
pation of communities in the decision-making process
Review of the Uranium Mining Policy in Zambia
of these mines to replace some of the existing ones.
For instance, Clauses in the Mineral Resources De-
velopment Policy, which remotely appear to promote
participatory strategies in negotiations include:
a) Commitment by Government to ensure sustain- 17
able exploitation of mineral resources for the
maximum benefit of Zambians.
b) Commitment by Government to apply modern
principles of transparency, checks and balances,
and accountability in administration of mining
laws and regulations.
c) Encouraging mining companies to develop a
participatory and collaborative approach to mine
planning, development and decommissioning,
taking into account the need s and concerns of
local communities, thereby fulfilling their role as
socially responsible corporate citizens.
In addition to these Clauses only remotely promot-
ing participatory strategies in negotiations, they have
very inherent enforcement weaknesses. For instance,
with regard to:
 (a) above, the clause has no quantity of measure/
indicators, and appears very general, and apply-
ing at National level. It would have been useful if
the Clause were more specific at societal or com-
munity levels by indicating (i) the level/stages of
participation and who-by,
 Review of the Uranium Mining Policy in Zambia
THIS IS THE ROAD: Lack of infrastructure to rural settings hosting Uranium rich fields where multi-national
Uranium mining companies expect to operate
(ii) the benefits that would accrue to the commu-
nity in terms of, for instance, per cent of taxes or
royalties that would be ploughed back into com-
18 munity development programmes, etc.
 (b) above, the Government has not provided
a functional system for the attainment of this
clause. What is, in fact, not certain is what really
constitutes modern principles?
 (c) above, the aspect of Encouragement is not
binding. While this might work for some elements
of mining, uranium mining requires mandatory
measures because of the deadly consequenc-
es that would accrue, if things were not done
correctly.
Even the Mines and Minerals Development Act is
not explicit in its stipulations to promote participa-
tory strategies in negotiations. Clauses in the Act that
may appear to promote participatory strategies in ne-
gotiations include the following:
a) Section 127. (1), (c) – A holder of a licence or
permit shall not exercise any rights under this Act
or the licence or permit upon land occupied as a
village, without the written consent of the chief
and the local authority for the district in which the
village is situated.
Attainment of this legislation has some chal-
lenges, particularly with regard to land tenure
arrangements, where, according to the Land Act
of 1995, all land in Zambia is vested in the Presi-
dent of the Republic, which he holds for, and on
behalf of, the people of Zambia.
In the advent of increased investor interest, it has
been heard that prospecting companies have
snapped up prospecting and mining rights, by-
passing communities and the latter’s interests.
This has created dissatisfaction among tradition-
al rulers that allocation is done is done in Lusaka
with them having had no say.
The traditional leaders’ main concern is that local
communities, from whom this land is taken, are
not adequately informed that, once converted
from customary tenure into leasehold tenure, this
land is permanently taken away and will never
revert to them.
Therefore, although well-intended, this legisla-
tion has not facilitated communities to participa-
tion in the mines’ decision-making process.
b) Section 132. (1) A holder of a mining right shall,
on demand being made by the owner or lawful
occupier of any land subject to the mining right,

promptly pay the owner, or occupier fair and rea-
sonable compensation for any disturbance of
the rights of the owner or occupier and for any
damage done to the surface of the land by the
operations and shall, on demand being made by
the owner of any crops, trees, buildings or works
damaged during the course of the operations,
pay compensation for the damage.
(2) In assessing the compensation payable under
subsection (1), account shall be taken of any im-
provement effected by the holder of the mining right
or by the holder’s predecessor in title, the benefit of
which has or will inure to the owner or lawful occupier
thereof.
(6) Where a holder of a mining right fails to pay com-
pensation when demanded under the provisions of
this section, or where the owner or lawful occupier
of any land is dissatisfied with any compensation of-
fered, the dispute shall be determined by arbitration.
All these may mean well, although in the absence of
the forceful arm of Government to monitor and en-
force them, there is nothing that will assist the local
communities to determine what and/or how much
compensation must accrue to them for the distur-
bance to their peace.
In many instances, it begins and ends with ‘huge’ re-
wards – of a few million to say, K20M – being dangled
at the communities, as compensation, thereby com-
pelling them to oblige to the investor’s needs.
Figure 5. Difficulties faced by local community members to access the Sinadambwe’s Chiefdom Palace and
the surroundings
Review of the Uranium Mining Policy in Zambia
In many cases, this has been the most money some
people living in rural communities may have ever re-
ceived. The temptation of this, along with new and
better houses, and may be jobs, became too big an
offer to resist. At the time of receiving this compensa-
tion, the people were very happy, but the reality is
now dawning on them that they did not strike the best
of deals – that they may have been cheated, after
all.
Further, the royalties from mining activities are all re-
mitted to the government treasury, with nothing ac-
cruing directly to the communities directly affected by
impacts of mining. Further, there is no transparency
over these revenue flows to mining communities, and
how much, if at all, is spent on corporate community
initiatives. Communities have no idea, how these rev-
enues are used.
The only revenue that the mining companies pay to
Siavonga and Solwezi District Councils are the land
rates, which equally do NOT trickle down to improve
the lives of those in the chiefdoms. It is an annual oc-
currence, for instance, that every rainy season, Chief
Sinadambwe’s palace is cut off from Siavonga district,
when most of the rivers and streams break their banks
because they do not have bridges (Figure 5). So, al-
though upgrading of the road to the Chief’s palace
was one important item that Chief Sinadambwe would
have wanted to be contained in the memorandum of
understanding, this was refused by the investor.
19
 Review of the Uranium Mining Policy in Zambia

Therefore, for communities to ably participate in ne- and Matebo. The money will fund 19 infrastructural
gotiations, available legislation requires reinforcing development related projects in the education, health
and enforcing so that it is not left to the discretion of and social economic sectors. These were broken
the investor on how they should deal with the com- down as follows:
munities. They also need information and knowledge
 Fourteen (14) projects in the education sector
about the:
targeted at building 23 staff house, 21 new class-
a) Land tenure arrangements to enable them to
rooms and two science laboratories.
make informed decisions before leasing their
 Three (3) projects for the social economic sector,
land out.
which will involved the construction of three com-
b) Revenue remitted to the government and
munity training centres to be equipped with some
how this is used. To this effect, it is impera-
sewing machines.
tive that the idea of Zambia affiliating to the
 Two (2) projects in the health sector aimed
Extractive Industries Transparency Initiative
at building a new rural health post and 1 staff
(EITI) is quickly adopted as this, it is hoped,
house.
will assist in ensuring that the revenues from
extractive industries contributes to sustain-
Through this funding under the LDTF, the company
able development and poverty reduction.
hopes to help government achieve the 5th National
Development Plan and the Millennium Development
Corporate Social Responsibility (CSR)
Goals by 2015 in the areas of education, health and
Corporate Social Responsibility is a concept, where-
poverty alleviation in the targeted communities.
by companies integrate social and environmental
concerns in their business operations, and in their
In Chief Sikoongo’s area, AER are reported to have
interaction with their stakeholders on a voluntary ba-
promised the community with funding to support
sis. The European Commission describe it as a com-
brick-making and start some out-grower schemes for
mitment of business to contribute to sustainable eco-
jatropha. However, nothing has since happened.
nomic development, working with employees, their
families, the local community and society at large, to
According to an AER official, the brick-making proj-
improve their quality of life.
ect fell off because (i) the Bankable Feasibility Study
(BFS) has been put in hold as the company is not
In other words, CSR describes the principle that com-
sure how it will proceed with the project in the face of
panies should make a positive contribution to society
the economic down-turn, and (ii) the company wants
by managing the social, environmental and economic
to increase the confidence and size of its reserve so
impacts of the company, being responsive to stake-
that, in the event of any turbulence in the metal’s mar-
holders – those who would be affected by a business
ket, the company will still survive.
20 operation – and behaving according to a set of val-
ues which are not codified in law.
With regard to the jatropha out-grower scheme, the
For instance, in the relocation of communities in its project has died a natural death because the compa-
concession area, DMZL pledged, a memorandum of ny – Oval Biofuels – with which AER had partnered to
agreement signed between the Company and HRH buy off the produce from the out-growers, folded up.
Chief Sinadambwe, to:
It would appear that investors can get away with of
 Clear the relocation site at Kashundi village. unfulfilled agreements because CSR programmes
 Provide a house and a small plot for each relo- are NOT codified in the Mines and Minerals Develop-
cated household. ment Act of 2008, and it is known what legal recourse
 Clear a field to replace each one left behind. the affected local communities have in the event of
 Clear old structures. such unfulfilled obligations.
 (with the Ministries of Health and Community De-
velopment) assist with the building of a school, Although there is some stipulation in the Mineral Re-
clinic and community water bores. sources Development Policy to the effect that govern-
ment will encourage mining companies to undertake
corporate social responsibility programmes, from its
In LMC, the Development Trust Fund has been cre-
reading, this statement is non-committal and non-
ated, from which Lumwana approved over K4 billion
binding on the part of the investor, and yet this is
in September 20093 for infrastructure development
what would constitute the major benefit to the com-
projects in three Chiefdoms of Mukumbi, Mumena
munity (Box 7).

3 This is according to a report posted on the Lusaka Times – (http://steelguru.com/news/index/2009/09/09/

MTEwOTgy/LDTF_ approve_ZMK_4_billion_for_infrastructural_development.html)

Box 7. Corporate Social Responsibility under the
era of ZCCM Limited
Before privatisation, the ZCCM operated a ‘cradle
to the grave’ corporate social responsibility welfare
policy. It provided social services to all the people
residing in mine communities, which included medi-
cal services, schools, recreational facilities, water,
electricity and other social amenities. However, all
ended with the privatisation of the copper mines
in the late 1990s. Under the terms of the privatisa-
tion, new mine owners were not obliged to contin-
ue providing social services. It was argued that the
new privatised mines should concentrate on their
core business, which was mining copper. However,
though the mining companies withdrew from social
service provision, government and local authorities
did not fill in the vacuum, with the result that there
has been a deterioration in social services in most
mining towns on the Copperbelt.
( h t t p : / / w w w. i s s . c o . z a / i n d e x . p h p ? l i n k _
id=4056&slink_id=6432&link_type=12&slink_
type=12&tmpl_id=3)
It is in this regard that these new mine owners need
to do a little more than just making glossy statements
and showcase a few corporate responsibility initia-
tives, yet fail to go to the heart of social responsibil-
ity and sustainability. It is true that these mines will
contribute large numbers of morbidity cases to the
already overstretched health facilities in Solwezi and
Siavonga. Therefore, for these mining companies to
only contribute to the health sector by constructing a
clinic each, one is not sure how they hope to look af-
ter their sick workers and members of the community,
who will be found to have developed health problems
attributable to mining.
Therefore, when investors undertake CSR pro-
grammes, they would appear to do so, according to
Walker and Howard (2002), purely to:
a) Correct the poor public opinion of the mining
sector as a whole; the current opinion of natural
resource extraction industries is influenced more
by concerns over environmental and social per-
formance than by performance in areas such as
product pricing, quality, and safety.
b) Pacify pressure groups that have consistently
targeted the sector at local and international
levels, challenging the industry’s legitimacy. Ex-
amples of this are the numerous environmental,
community and indigenous groups who opposed
the development of the uranium mine at Jabiluka
in the Kakadu National Park in Australia.
‘The community’ is a key stakeholder for all mining
Review of the Uranium Mining Policy in Zambia
companies, and therefore a strong focus for the lat-
ter’s CSR initiatives. Therefore, mining companies
must invest in communities through the CSR pro-
grammes in order to make a positive impacts on
people’s way of life and a sustainable access to liveli-
hoods, especially that of women, who bear the most
negative consequences.
With information, knowledge, determination and sup-
port from their government, local communities will no
longer be pacified by little gifts dangled at them by
investors, but will be able to challenge industry’s
legitimacy in whatever they propose to do in their
areas, just like the numerous environmental, commu-
nity and indigenous groups in the Kakadu National
Park in Australia, who opposed the development of a
uranium mine at Jabiluka (Box 8).
Box 8. The Jabiluka Mine and Aboriginal Land Rights
in Australia’s Northern Territory
The land of Jabiluka belongs to the Mirrar Aboriginal
people. Jabiluka was a land where it was supposed to
be built a uranium mine. The land of Jabiluka is sur-
rounded by Kakadu National Park. In 1998 the Mirrar
people decided to blockade the construction of the
mine, which should have been made by Energy Re-
sources Australia, they called for activists from the
whole world and from Australia to help them in the
blockade. During the blockade over four hundred
people were arrested. The Energy Resources Aus-
tralia were able to dig the entrance of the mine but
were not able to continue. Rio Tinto Group bought
the holding company of Energy Resources Australia, 21
North Ltd and they told that the mine will continue
till the Ranger uranium mine is mined out. The Mir-
rar people have been against the Rio Tinto Group
and asked them to clean the site and restore it. And
in August 2003, the site started to be rehabilitated.
……The controversy surrounding uranium mining has
become increasingly volatile in the wake of nuclear
accidents like Chernobyl. Likewise, the by-product
tailings of uranium mining, which often contain 85%
of the radioactivity of the original element, are be-
ing targeted as toxic environmental pollutants. Com-
munities near uranium production or tailings dump-
ing facilities are becoming aware of the inevitable
health dangers that result from uranium mining.
The siting of uranium mines in people of colour and
low-income communities is tragically a global phe-
nomenon. (http://www.travel-australia.org/kakadu/
jabiluka.html)
According to Frynas (2005), the effectiveness of CSR
initiatives in the oil, gas and mining sectors has been
increasingly questioned because of the mounting evi-
dence of a gap between the stated intentions of com-
 Review of the Uranium Mining Policy in Zambia
panies and their actual behaviour and impact in the
real world as experience has shown in the Zambian
copper mining industry (Box 9).
Box 9. The new investors lack human heart
Despite the huge return on their activities, foreign-
owned copper mining companies in Zambia are not
investing in the local communities or workforce in
the areas in which they mine. As such, Zambia’s
economy has been growing at a rate of 5 per cent a
year over the past couple years, but this growth has
not been passed on to the Zambian people.
Prior to the privatisation of the mines, the Zambian
government used the assets of the ZCCM to diversify
the economy. For example, the ZCCM established
subsidiary firms that focused on tourism (Kasaba
Bay Lodge, Manchichi Bay in Siavonga), agriculture
(Mpongwe Farm in Ndola), agro-processing (Mu-
lungushi Milling) and transport (Mulungushi Travel-
ler). The copper mining companies (both in private
hands before independence and in public hands af-
ter independence) developed and maintained social
infrastructure such as hospitals, schools and sports
facilities. The investors knew that it was in their best
interests to motivate the workers in some measure.
.....a comparison between copper mining towns
before privatisation and now during the boom will
show that conditions have not changed for the bet-
ter. The roads have potholes and are still in poor con-
dition, training programmes for artisans has been
abandoned, football fields are unkempt, and the
22 new mine owners no longer operate hospitals and
schools.
......as much as the country needs foreign invest-
ment, it must also ensure that it is self-sustaining.
It is not judicious for the Zambian government, with
its highly educated economic technocrats, to allow
foreign companies to operate without having to pay
import or value added taxes indefinitely. When will
the finance minister levy taxes on minerals that will
eventually result in decent salaries being paid to
Zambian civil servants? (Mwitwa & Kabemba, 2007)
Considerable effort is usually made by the industry,
like in the case of AER, DMZL and LMC, to highlight
their commitment to both protecting the environment
and addressing the needs of communities. As re-
corded of the Tonga people by David Howarth in the
1960’s, during the construction of the Kariba Dam....
....there are many different perspectives on how
much resettlement aid was given to the displaced
tribe. According to anthropologist Thayer Scud-
der, who has studied these communities since
the late 1950s, ‘Today, most are still ‘develop-
ment refugees.’ Many live in less-productive,
problem-prone areas, some of which have been
so seriously degraded within the last generation
that they resemble lands on the edge of the Sa-
hara Desert.’....
In this regard, there is need to undertake research
to determine the accuracy and impact of commit-
ments given by investor institutions to the execution
of agreed CSR programmes and their sustainability.
This will ensure that lapses encountered in the ex-
ecution of CSR initiatives are addressed, and com-
munities do not lose out on investment meant for their
areas. This aspect is what may constitute one of the
major advocacy and monitoring components for the
human rights campaign groups.
Dangers of some CSR programmes
A significant aspect of the companies’ livelihood focus
for communities in mining areas, particularly Lumwa-
na, has been the reported establishment of alterna-
tive and sustainable livelihood programmes. These
are intended to reduce the communities’ economic
dependence on the mine, and develop alternative
and sustainable employment opportunities for them-
selves.
However, Swift and Zadek (2002) note that while
these programmes may have a strong potential for
CSR initiatives to make a positive contribution to ad-
dressing the needs of disadvantaged communities
in the mining areas, CSR could, whether by mistake
or by design, also damage communities. This would
arise, particularly, where:
a) CSR programmes may have no strong legal
backing, as the case may appear to be in Zam-
bia.
b) Lack of political will has created the confusion
of local economic development imperatives of
government being performed by mining houses,
thereby promoting mining as the keystone for
economic growth at the expense of community
interests.
The starting point of economic life must be communi-
ties and how these actually benefit from mining. This,
for Zambia, will require a fundamental mind shift, to
making a big difference on the lives of communities
in areas affected by mining activities. This will require
that government begins to influence a different busi-
ness model with all investment in the country, which
is underpinned by ethical business practices and sus-
tainability aimed at protecting present generations
and ensuring a sustainable environment for future
generations.

Capacity of Zambia to Oversee Uranium Exploration & Mining
Introduction
Despite Zambia’s long experience in metal mining,
uranium mining and subsequent downstream opera-
tions, require different types of skill and expertise.
Since the first focused uranium mining operations
in Zambia are targeted for 2012 by Denison Mining
Zambia Limited, the question that begs for an answer
is: Has Zambia got the capacity to oversee such
operations?
To adequately assess Zambia’s capacity to oversee
such operations, it might be useful and important to
examine some experiences from other countries with
a lot more experience with uranium mining than Zam-
bia.
Experience from other countries
Canada
Canada is the World’s largest producer and exporter of
uranium with a long experience. Despite this very long
experience in uranium mining, Canada is still struggling
with the regulatory and administrative needs of the in-
dustry.
According to a report that was prepared by a con-
sultant for the Saskatchewan Environment Ministry
and released by CBC on 7 April 2009, the Ministry
has a ‘massive capability and capacity deficit’ in the
uranium mining sector. The report states that the
Saskatchewan Environment Ministry is falling behind
critical work, especially in the uranium mining sector,
and should undergo a complete reorganisation.
The report found that, despite the Province’s long
uranium mining history, the ministry does not have
the necessary skills and expertise to oversee the
uranium industry. “Saskatchewan does not have ad-
equate staff or capability to monitor and regulate the
current industry,” the report found. It said that only a
handful of people have the appropriate expertise and
experience to perform the ministry’s oversight func-
tions relating to uranium mining and milling.
The ministry, the report said, “is in a massive capabil-
ity and capacity deficit when considering new mining
and milling projects, let alone support the value-add-
ed activities the province has announced it intends
to pursue.” The environmental consultant suggested
Saskatchewan could contract a private sector expert
to support its uranium regulation work.
Much earlier than that, on 14 February 2003, the Gov-
Review of the Uranium Mining Policy in Zambia
ernment of Saskatchewan and the Canadian Nuclear
Safety Commission (CNSC) announced the signing
of an agreement “that will lead to greater administra-
tive efficiency in regulating the uranium industry. This
initiative was in response to a recommendation that
was made by the Joint Federal-Provincial Panel on
Uranium Mining Developments in Northern Saskatch-
ewan, and which laid a foundation for the two groups
to coordinate and harmonize their respective regula-
tory regimes.”
In New Brunswick the Government was seriously
criticised by the public for not doing enough to pro-
tect the environment and health of residents. The crit-
ics wondered why the government would introduce
guidelines, that aren’t mandatory, rather than regula-
tions. The critics argued that the guidelines are pretty
much standard conditions that are applied to all sorts
of development projects.
Canadian churches protest at uranium mining expansion
Environmental concerns have prompted British Colombia,
Nova Scotia and the Labrador Inuit territory of Nunatsiavut
to enact a moratorium on uranium mining, while in 2008
New Brunswick imposed stricter guidelines on uranium min-
ing.
Jim Harding, author of Canada’s Deadly Secret: Saskatch-
ewan Uranium and the Global Nuclear System, told the Ca-
nadian Press the concerns about uranium mining were well-
founded. “If I lived in an area where they were doing uranium
mining, based on what I know about toxicity, lifespan and en-
vironmental health and increased risks, I’d move,” he said. 23
http://www.religiousintelligence.co.uk/news/?NewsID=4106
Namibia
According to a report by NAMPA of 29 February
2008, the Namibian Chamber of Mines had decided
to establish a Uranium Stewardship Committee to
safeguard the interest of the uranium industry in the
country. The Chairperson of the Uranium Stewardship
Committee was Michael Leech, who was the Man-
aging Director of Rössing Uranium. The committee
was to develop minimum standards for environmental
health and environmental management for uranium
mines and to assist with a Regional Strategic Envi-
ronmental Management Plan (SEMP). This was done
with participation of public and private stakeholders
and also in conjunction with the Southern African In-
stitute for Environmental Assessment (SAIEA), the
World Nuclear Association (WNA) and the Interna-
tional Atomic Energy Agency (IAEA).
The Chamber of Mines of Namibia established a com-
mittee that would deal with radiation protection issues
 Review of the Uranium Mining Policy in Zambia
in the uranium industry. In addition, the chamber has
appointed a medical practitioner as principal adviser.
He will help with the development of minimum stan-
dards for occupational health and environmental man-
agement for uranium mines (which in Zambia have
been left to individual uranium mining companies to
develop). At that time, Namibia had adequate legisla-
tion to effectively deal with radiation protection, occu-
pational health, and environmental management.
Institutional set up
As has been established in Section (4.1), activities
related to uranium exploration and mining in Zambia
are regulated by three statutory bodies, namely, (i)
Mines Safety Department (MSD) under the ministry of
Mines and Minerals Development, (ii) Radiation Pro-
tection Authority (RPA) under the Ministry of Health,
and (iii) Environmental Council of Zambia (ECZ) un-
der the Ministry of Tourism, Environment and Natural
Resources.
These institutions were established long before the
advent of uranium exploration and mining in Zambia.
In this regard, there are critical questions regarding
their capacity, and thus, Zambia’s capacity, to over-
see uranium exploration and mining.
Technical Expertise
One of the challenges identified in the Mining Policy of
1995 was the constraint placed upon the MSD – the
lead-regulatory wing in the mining sector – to moni-
tor, supervise and regulate standards of safety, health
and environment due to increased mining operations
24 countrywide.
The new Mines and Minerals Development Policy of
2008, aims to address this aspect by building capac-
ity of the Mines Safety Department. This situation is
not different for the other two institutions – the ECZ
and the RPB. Since exploration and mining activities
have already started in the country, two critical ques-
tions arise, namely:
 how much have staff, from all the three statu-
tory institutions, been brought up-to-date to
deal with challenges posed by uranium min-
ing?
 how has this staff been capacitated, in terms
of knowledge and numbers, to enforce the
statues and monitor the activities of com-
panies engaged in uranium exploration and
mining?
Further, the building of capacity stipulated in the Mines
and Minerals Development Policy of 2008 does not
explicitly spell out the improvement of incentives and
remunerations to these officers. Some of the highly
trained staff at ECZ and MSD are reported to have
left to join the mines, where they are offered much
better conditions.
The current deficiency in the availability of technical
and regulatory personnel with uranium experience in
the country has already been recognised by some of
the uranium exploration/mining companies. For in-
stance, DMZL proposed at a public consultation to:
 Bring into Zambia world experts to help train the
Zambian authorities.
 Train local employees in all aspects of their job
and radiation safety.

For example, as a result of such staff deficiencies, lo-
cal communities have not been adequately informed
by the ECZ – the task they are mandated by law to
perform – about the benefits and dangers of uranium
exploration/mining. This, ECZ says, arises from prob-
lems posed by staffing levels.
During the Lumwana uranium EIA public consulta-
tion in Solwezi, for instance, a suggestion was made
that in view of a fast growing population, more mining
operations and growing environmental concerns, the
ECZ should consider opening on office in the town so
as to monitor mining developments closely. The re-
sponse from an ECZ official was that resources per-
mitting, an office would be opened, but that for now,
ECZ did not have these resources.
Another contribution given during the public consulta-
tion in Solwezi was the need for regulatory bodies to
monitor operations at LMC for the safety and health
of workers. The contributor noted that if left alone, the
mine could be compromised in that it would want to
maximise benefits at the expense of other consid-
erations, thereby leaving the workers to fight for the
protection of their safety and health.
The contributor strongly recommended for a felt-pres-
ence of the ECZ, the MSD and the RPA at the mine
to ensure all business was conducted according the
set standards.
Canada is one country with long experience in urani-
um mining and has much more advanced technology,
but it has still been found to be wanting in the area of
legal enforcement and monitoring.
Uranium exploration/mining is new to the country, and
going by the dangers it poses both to the environment
and health of human beings and animals, the Govern-
ment needs to take a pragmatic programme to train
personnel specifically for regulating the industry.
Therefore, examples of results from work carried out
in Canada on its capability and capacity to manage
uranium activities should give an indication of how
much work is required to bring Zambian personnel
 Review of the Uranium Mining Policy in Zambia

Advantages and Disadvantages of Uranium Mining in Zambia

up to standard.
Introduction
Because of the large contribution that minerals make
to the national economy, the decision-making pro-
cess of developing new finds is often done in haste,
downplaying the detrimental effects that accompany
mineral extraction and processing. When properly
handled, minerals have the potential of massive
positive impact on a country or society that seeks
to develop a sustainable economy. However, if not
properly handled, mining activities can lead to dev-
astating long term consequences on the environment
and societies. In case of uranium overlooking critical
issues that may lead to radiation can lead to deadly
consequences.
Further, mining leaves behind waste rock5 (Figure
6), while crushing and chemical winning processes
leave behind pulverized material called tailings (Fig-
ure 7). Both these materials are inevitably spread into
the environment, when they are washed by rain water
into surface water systems (Figure 8). Further, as the
tailings are left on the surface of the earth, they are
blown by the wind, and they inevitably spread. Sub-
sequently, different levels of these particles enrich the
air, water and food that man breathes, drinks and
eats, respectively, thereby introducing into the human
environment a tremendously large range of radioac-
tive materials that are generally very inimical to the
human body. These are not invisible rays, but materi-
als that are exactly like other materials, except for the
fact that they are radioactive.

Advantages of uranium mining

It is an undisputed fact that minerals make a large
contribution of wealth in international and national
economies. Many countries are frantically searching
for yet unknown mineral deposits and expanding the
resource base of the known fields. Rural settings are
opened up to development, taking financial resources
to areas which otherwise would be “dead”.

The new mine offers a livelihood choice for many

people. Mining then can yield much needed capital Figure 6. Waste rock heap at a mine site (source: internet)
to develop and support other positive economic and 25
social activities including farming, trading, education,
health care and infrastructure. This is the case in
Zambia where almost all the potential uranium mining
areas are in rural settings that are badly affected by
lack of employment options and general poverty. This
is all at societal level. At national level, uranium min-
ing will contribute significantly to the national revenue
collection through various taxes.

Disadvantages of uranium mining and Possible

pitfalls
The exploitation of uranium requires extraction of ura-
nium from the ground, crushing and then chemical
enrichment. As the miners dig and open up the urani-
um-bearing ore, the latter releases large quantities of
radioactive radon gas into the atmosphere due to a
change of environment. Radon has a relatively short
half-life4 (3.8 days), which would make the air in the
mine to get heavily contaminated with radon daugh-
ters within a very short time.
Figure 7. A tailings dump at a mine site (source: internet)
The crushing and chemical winning processes leave
behind pulverized material – uranium tailings. As Ma-
rie Curie observed, 85% of the radioactivity in the ore
remains behind in that crushed rock. The pulverisa-
tion of the natural rock further liberates the radioac-

4 THalf-life is the time a radioactive substance takes to lose half of its radioactivity through decay.
5 Waste rock is rock associated with, and containing a mineral or ore, but which has insufficient mineral content to justify
(further) processing.
 Review of the Uranium Mining Policy in Zambia

Figure 8. Impacts of waste rock and tailings dump materials on the environment and as a possible pathway
to humans (source: internet)

tive elements and accelerates radioactivity.
Science has shown that the effective half-life of ura-
nium’s radioactivity is 80,000 years (Edwards, 1992),
which means, in 80,000 years, there would be half
as much radioactivity in these tailings as what would
have been initially there.
receive a 25 percent increase in lifetime radon daugh-
ter radiation (http://www.ccnr.org/bcma.html).
Edwards further states that, available scientific evi-
dence indicates that every dose of radiation is likely
to cause a corresponding increase in cancers and
other diseases.

According to Edwards (1992), as the tailings are sit-
ting there on the surface, they are continually gen-
erating radon gas. Since radon is about eight times
heavier than air, it stays close to the ground.
Edwards (1992) argues that radon can travel over
1,000 km in just a few days in a light breeze. And as
it drifts along, it deposits on the vegetation the radon
daughters – its radioactive by-products – including
polonium. Effectively, radon daughters may get into
26
animals, fish and plants that are thousands of kilome-
tres away from where the uranium mining is done.
So, as the Government of the Republic of Zambia
takes the decision to go ahead with mining and pro-
cessing uranium, the following forward-looking ques-
tions will demand to be critically examined:
 Who becomes responsible to look after such ma-
terial forever once the mining companies close
down?
 How does anyone guard millions of tonnes of ra-
dioactive sand safely forever, and keep it out of
the environment?

Adhering to microscopic dust particles, these tiny, per-

nicious particles are breathed into the miners’ lungs,
where they lodge, delivering a massive dose of alpha
radiation to the sensitive lung tissue. The result is an
extraordinarily high incidence of lung cancer, fibrosis
of the lungs, and other lung diseases, all of which
take decades to manifest.
The carcinogen (cancer-causing) effects of radon-
daughters have been studied for many years. Since
the radon is airborne, these daughters have a high
probability of being airborne and to be breathed-in by
humans.

The medical evidence is overwhelming and indisput-

able that radon (with its daughters) is one of the most
potent carcinogens known (Edwards, 1992). Accord-
ing to a report by Edwards, who was the President
of the Canadian Coalition for Nuclear Responsibility
(CCNR) in 1992, there is no such thing as a safe dose
of radiation, as conservative calculations have shown
that the public near uranium tailings have potential to

Discussion
Zambia has not developed a uranium policy. At Policy
level, the operations related to uranium mining fall un-
der the much generalised Mining Policy of 2008. This
policy is not adequate considering the peculiar and
deadly nature of uranium.
Figure 9. Signage at the entrance into/exit out of Siavonga in Zambia scribed in a foreign language
The Government needs to come up with a deliberate
uranium policy that addresses, but not limited to:
 Measures to protect both the people and the en-
vironment
 Formulate specialised training for personnel in-
volved in regulating the sector
 Codify guidelines for societal and national ben-
efits accruing from the uranium mining activities.
 Formulate measures for commensurate com-
pensations related to short- and long-term distur-
bances to the communities.
Further, one major disadvantage of uranium explora-
tion and mining in Zambia is the lack of information
Review of the Uranium Mining Policy in Zambia
to the affected communities such that, even though
exploration and mining are done on traditional land,
it is government that appears to make decisions on
their behalf, sometimes without sufficient knowledge
on its part, of the implications on the people.
With the influx of investors in uranium mining and oth-
er investment sectors, there will be need for the Gov-
ernment to assume the role of overseer and custo-
dian of its people and their interests than is currently
the case. The Government of the Republic of Zambia
must cease to treat investors with kids gloves – that
they can do like they please (Figure 9).
27
With current low levels (and, in some cases , even in
terms of qualification) of manpower at the ECZ, the
MSD and the RPA to enforce existing legislation and
monitor the activities of mining companies to ensure
safety of communities in the uranium exploration and
mining areas, the disadvantage of uranium mining in
Zambia is immense.
Compounded by a government that does not appear
to take the interests of its citizenry at heart, the follow-
ing will constitute some of the major disadvantages
(and against which some activist groups are protest-
ing (Box 10)):
 Review of the Uranium Mining Policy in Zambia
Box 10. Canadian churches protest at uranium min-
ing expansion
The Anglican bishops of Saskatchewan have joined
their Roman Catholic, Lutheran and Ukrainian Cath-
olic brethren in protesting against government plans
to expand uranium mining in the prairie province,
and permit the construction of a privately owned
nuclear power plant.
In a joint statement released on Feb 26, the An-
glican bishops of Saskatoon and Qu’Appelle ques-
tioned whether the government had fully studied
the environmental risks of nuclear development in
the province. A government-appointed panel is ex-
pected to release a report this month encouraging
“value-added” initiatives to expand the uranium
industry. Saskatchewan is the world’s largest pro-
ducer of uranium ore and last year (2008) a private
company, Bruce Power, began work on a feasibility
study for building a nuclear generating station. Be-
fore any decision is taken, the bishops said it was
‘critical that any recommendations be made only
after full and open consultation with the people of
this province.’
They noted that ‘Christian churches affirm that God
created the earth and that God continues to estab-
lish and preserve a just and ordered life for all cre-
ation. Human beings are part of the vast ecosystem
of the planet.’ However, ‘Choices made by human
beings must respect God’s creation in its careful
interrelationship of earth, water, air and all living
things. Exploiting the earth’s resources without re-
28 gard for the consequences is sinful against God and
God’s creation,’ the bishops argued.
Article by George Conger, Monday 16 March
2009 (http://www.religiousintelligence.co.uk/
news/?NewsID=4106).
a) Continued displacement and disorientation of
communities because of loss of farming, graz-
ing and hunting grounds, and the amount of time
spent to find new ways of survival.
b) Continued exploitation of displaced communities
through compensations that are NOT commen-
surate to the assets left behind, as determination
of what is compensated has had no input from
communities.
c) Although consultation with communities is a pre-
requisite for attaining mining concessions, public
meetings that are supposed to be consultative in
nature are used by mining houses to baffle com-
munities with scientific jargon.
No matter the level of representation from com-
munities and their lack of understanding of is-
sues, government has usually gone ahead to
grant mining concessions, overlooking issues of
good governance on the part of communities.
The greatest danger and major disadvantage of ura-
nium exploration and mining in Zambia is the lack of
capacity and competence at regulatory level.
Take the case of Lumwana, where it declares that
health hazards arising from uranium mining are just
like those in any other metal mining operation, and
the company is allowed to circulate such literature
(Appendix 6) without any reaction from regulatory in-
stitutions.
Capitalising on this lack of competence, the company
dispels all the dangers related to uranium from its
operations, negating all the concerns spelt out in the
regulations and scientific findings. The question is,
where are the regulators?
As regards the distribution of wealth, the Zambian
Mining Policy does not address the distribution of the
benefits between what should go to the central trea-
sury and that, meant for the communities, where min-
ing activities take place. In fact, in the tax regimes,
this distribution is not mentioned at all.
The benefits designed for the communities only come
under what is termed corporate social responsibility
by the companies or investors. Even in the legisla-
tion, these are not mandatory but come as recom-
mendations or encouragements to companies to do
likewise.
The strides the country has taken with regard to the
treatment of its citizens, on one hand, and the inves-
tor, on the other, requires that people must pause,
think and ask:
 What will Zambia look like in 10, 20, 30, 50 years
from now?
 Will the country still have any drinkable water?
 Will all our people not have been forced off their
land into the cities, and how will they cope?
 How much future do the people have as a coun-
try?
Therefore, it is important for Government to come up
with a clearer fiscal regime that is binding with regard
to (i) the distribution of benefits from mining activities
to communities, in which these mining activities take
place, and (ii) the protection of human health and the
environment, long after cessation of mining activities.
According to Chief Mumena, ...’apart from handouts,
people have not had any control on taxes and royal-
ties paid to government, yet they see trucks loaded
with copper and other mining products going out ev-
ery day. One day, these people will rise because they
do not feel the benefit of mining activities in their ar-
eas’.

WE HEAR YOU: Consultants meet with local community members at Sikoongo’s Chiefdom
Conclusion
There is no escaping the fact that local communities
may not adequately profit from uranium mining ac-
tivities earmarked to start in their areas to the same
extent that foreign investors will.
It is also doubtful if the amounts received in taxes
from these mining activities will accrue any visible
socio-economic impact to the local communities.
Under current legal and regulatory arrangements, the
Zambian people have not seen a notable improve-
ment in their living standards since the copper boom
and they have begun to question whether things will
be any different with uranium operating under similar
legal regimes.
Since government has interest for the money, its reg-
ulatory role of the uranium mining sector is likely to be
biased. Therefore, there is need for an independent
organ to safeguard the interests of the local people.
Review of the Uranium Mining Policy in Zambia
Recommendations
In order to address the issues observed above, there 29
is need for:
a) the Government of the Republic of Zambia to de-
velop a policy on uranium, on which basis;
 Current Regulations can be revised
 Community concerns can adequately be ad-
dressed
 Educational and awareness programmes for
communities can be formulated ahead of any
uranium exploration, mining and processing
operations.
b) CCZ to champion the formation of an indepen-
dent watch-dog group composed of representa-
tives from the Private Sector, Civil Society, NGOs,
Scientists and Medical Experts to champion the
interests of the people affected by uranium min-
ing operations.
c) Government to immediately embark on a vigor-
ous training programmes for public officers in the
three regulatory institutions that are involved in
regulating uranium mining operations.
 Review of the Uranium Mining Policy in Zambia

References
a) African Energy. 2010. Update on Zambian uranium resources and 2009 exploration programmes. Inter-
nal electronic technical report.
b) African Mining Consultants, 2009. Environmental Impact Assessment – Mutanga Project, Siavonga
District, for Denison Mines Zambia Limited.
c) Auty, R.M. 1998. Social sustainability in mineral-driven development, Journal of International Develop-
ment, 10: 487-500.
d) Edwards, G. 1992. URANIUM: Known Facts and Hidden Dangers – Invited address (http://www. ratical.
org/radiation/WorldUraniumHearing/GordonEdwards.html )
e) Frynas, J.G. 2005. The false developmental promise of Corporate Social Responsibility: evidence from
multinational oil companies, International Affairs, 81(3): 581-598.
f) EPA Facts about Uranium. http://www.epa.gov/superfund/health/contaminants/radiation/pdfs/uranium.
pdf
g) http://www.travel-australia.org/kakadu/jabiluka.html
h) http://www.ccnr.org/bcma.html
i) http://www.postzambia.com/post-read_article.php?articleId=4928
j) http://www.minesandcommunities.org/article.php?a=8603
k) http://steelguru.com/news/index/2009/09/09/MTEwOTgy/LDTF_approve_ZMK_4_billion_for_infrastruc-
tural_development.html
l) Jenkins, H. & Obara, L. 2008. Corporate Social Responsibility (CSR) in the mining industry – the risk of
community dependency.
m) Knight Piésold Consulting. 2008. Lumwana Uranium Project Environmental Impact Assessment Re-
port, Project No: 5249/30.
n) Mwitwa, C. & Kabemba, C. 2007. Copper boom in Zambia – Boom for Whom? Resource Insight, Issue
No. 3, Southern Africa Resource Centre, ISSN: 1994-5604
o) Simutanyi, N. 2008. Copper Mining in Zambia – The Developmental Legacy of Privatization, Occasional
Paper 165; (http://www.iss.co.za/index.php?link_id=4056&_id=6432&link_type= 12&slink_type=12&tmpl_
id=3)
p) Wood, D. 1991. Corporate Social Performance Revisited. The Academy of Management Review,
Vol. 16, No. 4, http://www.jstor.org/stable/258977
q) Swift, T. and Zadek, S. 2002. Corporate Responsibility and the Comparative Advantage of Nations, The
30 Copenhagen Centre and Accountability: Copenhagen and London.
r) Titley, M. 2009. The Mutanga Project, NI43-101 Technical Report, CSA Global (UK) Ltd.
s) Walker J. & Howard, S. 2002. Finding the way forward: how could voluntary action move mining towards
sustainable development? Mining, Minerals and Sustainable Development Project, IIED
 Review of the Uranium Mining Policy in Zambia

Appendices
31
 Review of the Uranium Mining Policy in Zambia

Appendix 1. Decision letter for Denison Mines Zambia Limited

CZ/INS/l0l/4/1

November, 9th 2009

The Project Director - Africa
Denison Mines Zambia Limited
Lusaka

Attn: Mr. Andrew Goode

Dear Sir,
RE: RESETTLEMENT ACTION PLAN (RAP) FOR THE MUTANGA PROJECT IN
SIAVONGA DISTRICT BY DENISON MINES ZAMBIA LIMITED

Reference is made to the above captioned project report submitted to the Environmental Council of Zambia
(ECZ) on August 13, 2009 for consideration in accordance with the requirements of the Environmental Impact
Assessment (EIA) Regulations, Statutory Instrument No. 28 of 1997.

The ECZ has since reviewed the Resettlement Action Plan (RAP) and based on the information provided by
yourselves and from written and verbal comments from interested and affected parties and our site verification
inspection findings, the said RAP has been approved.

Find attached to this Decision Letter, conditions governing this approval.

32 Yours faithfully,

…………………

Paul M. Banda
Director
ENVIRONMENTAL COUNCIL OF ZAMBIA

Cc: The Director - Mines Safety Department, KITWE

The Council Secretary - Siavonga District Council, SIAVONGA
The Director - Radiation Protection Authority (RPA), LUSAKA
 Review of the Uranium Mining Policy in Zambia

1.0 PROJECT BACKGROUND

1.1 PROJECT TITLE:

Proposed Resettlement Action Plan (RAP) for the Mutanga Project in Siavonga District by Denison
Mines Zambia Limited

1.2 PROJECT PROPONENTS:

Denison Mines Zambia Limited

Lusaka

Contact Person:
Mr. Andrew Goode
Project Director- Africa
Denison Mines

1.3 PROJECT LOCATION:

The Mutanga project is located in Matuba area, Siavonga District in Southern Province of Zambia,
approximately 175km South of Lusaka and 39km Northwest of Siavonga town center. The project
can be accessed from Lusaka-Chirundu road along the Siavonga turnoff. The project lies within HRH
Chief Sinadambwe’s chiefdom. Chief Sinadambwe resides in Sianyoolo Village, approximately 35km
by road from the Mutanga Project site.

1.4 DATE OF SUBMISSION BY PROPONENT:

13th August 2009

1.5 DATE OF CONSIDERATION BY COUNCIL:

29th October, 2009

2.0 DETAILS OF THE PROJECT:

Denison Mines will develop two open pits, one at Mutanga (33ha) and the other at Dibwe (54.3ha).
This development will entail involuntary relocation of 107 households with a total affected population
of 342 people from six villages.
The compensation of the housing and fields will be done through a combination of monetary and
physical compensation. These settlements are Chiyobeka, Kasambo, Chilundu, Kapita, Sinanjosi and 33
Kumulilansolo.

3.0 DECISION BY COUNCIL

3.1 The Project is approved subject to the following conditions:

3.1.1 Denison Mines Zambia Limited shall operate in the manner the project has been presented in
the Resettlement Action Plan.
3.1.2 Denison Mines Zambia Limited shall implement the project and all the proposed social and en-
vironmental management commitments as proposed in the Resettlement Action Plan
(RAP) with modifications as per conditions governing this approval.
3.1.3 Denison Mines Zambia Limited shall not commence with construction activities until engineer-
ing drawings for the houses are approved by 5iavonga District Council.
3.1.4 The affected people shall be relocated only when Denison Mines Zambia Limited completes
construction of houses for resettlement.
3.1.5 After compensation, no person or family shall be left in a worse state, economically or other-
wise, than they were before the involuntary relocation.
3.1.6 The proposed relocation site shall not be in the wind direction of the mine.
3.1.7 Denison Mines Zambia Limited shall speed up the process of relocation so that people subject
to resettlement may clear uncertainties and continue leading a stable life.
3.1.8 Denison Mines Zambia Limited shall resettle the affected people prior to commencement of
the Mutanga Project.
3.1.9 Dust suppression on exposed surfaces shall always be implemented as proposed in the
RAP.
 Review of the Uranium Mining Policy in Zambia

3.1.10 A suitable site shall be identified for disposal of waste and the community educated on sound
waste management practices.
3.1.11 Denison Mines Zambia Limited shall obtain the necessary permits from the Environmental
Council of Zambia (ECZ) and comply in full with the Waste Management Regulations (51
No.71 of 1993).

3.2 The Council advises Denison Mines Zambia Limited to:

3.2.1 Obtain any other relevant authorizations such as but not limited to the:
a. Public Health Act;
b. Town and Country Planning Act;
c. Local Government Act;
d. Employment Act.
3.2.2 Make available information on malaria control and HIV / AIDS to construction employees and the
affected people.
3.2.3 Provide all workers with personal protective clothing.

3.3 The Council may suspend or cancel this Decision Letter without notice should Denison Mines Zambia
Limited fail to comply with the conditions stated above.

3.4 Denison Mines Zambia Limited shall comply with environmental standards and/or specific limits of
particular pollutants as its responsibility. Thus, compliance with ECZ recommended measures does
not exempt the developer from its responsibility if such measures do not achieve compliance with
environmental control standards

3.5 Denison Mines Zambia Limited shall in accordance with Section 84 of the Environmental Protection
and Pollution Control Act, 1990, Cap 204 of the Laws of Zambia allow ECZ Inspectors unrestricted
entry to the project site at any reasonable time without making prior notice throughout the project
cycle.
3.6 The project shall be implemented within three years from the date of approval. Failure to implement
the project within the stated period shall render this decision letter invalid and the Denison Mines shall
be required to re-submit the Resettlement Action Plan for consideration.

34

Date Paul M. Banda

Director
ENVIRONMENTAL COUNCIL OF ZAMBIA
 Review of the Uranium Mining Policy in Zambia

Appendix 2. Decision letter for Lumwana Mine Company’s Uranium Project

ECZ/INS/101/4/1

November 14, 2008

The Managing Director

Lumwana Mining Company Limited
Mwinilunga Road
Lumwana East
P. O. Box 110199
SOLWEZI

Dear Sir
RE: Proposed Lumwana Uranium Project by Lumwana Mining Company Limited

Reference is made to the above captioned project submitted to the Environmental Council of Zambia (ECZ)
on 28th August 2008 for consideration in accordance with the requirements of the Environmental Impact As-
sessment (EIA) Regulations Statutory Instrument No. 28 of 1997.

The ECZ has since reviewed the Environmental Project Brief (EPB) and based on the information provided by
yourselves and from written and verbal comments by interested and affected parties and our site verification
inspection findings, we have approved your project proposal.

Find attached to this Decision Letter, conditions of approval.

Yours faithfully,

Julius P.Daka
Acting Director
ENVIRONMENTAL COUNCIL OF ZAMBIA

Cc: The Town Clerk- Solwezi Municipal Council, SOLWEZI 35

The Director - Mines Safety Department, KITWE
The Director - Mines and Minerals Development Department, LUSAKA
 Review of the Uranium Mining Policy in Zambia

1. PROJECT BACKGROUND
1.1 PROJECT TITLE:

Proposed Lumwana Uranium Project by Lumwana Mining Company Limited

Project Proponent:
Lumwana Mining Company Limited
Mwinilunga Road
Lumwana East
P. O. Box 110199
SOLWEZI.

Contact:
Harry Michael - Managing Director
Tel: +2608249000
Fax: +2608249001

1.2 PROJECT LOCATION:

The Uranium Project is located in the North Western Province approximately 95 km west of Solwezi
District, the provincial centre of North Western Province, off the Mutanda-Mwinilunga road (T-5). The
proposed site for the Uranium Process PI2nt aild associated facilities is situated within the Large Scale
Mining Licence 49 (LHL 49).

1.3 DATE OF SUBMISSION BY PROPONENT:

28th August, 2008

1.4 DATE OF CONSIDERATION BY COUNCIL:

31st October, 2008

2.0 DETAILS OF THE PROJECT:

The project involves mining and processing of uranium using a metallurgical processing plant. The
uranium ore will be mined from within the existing Malundwe and Chimiwungo Open Pits.

36 The project will process the stockpiled high grade uranium mineralization onsite. The ore will be re-
claimed from the uranium ore stockpile and hauled along a dedicated road to the processing plant.
The processing plant will use conventional milling and flotation to produce copper concentrate for trans-
portation and sale to a copper smelting and refining facility. The processing plant flotation tailings will re-
port to the uranium leaching circuit for the production of uranium oxide (yellow cake), using conventional
leaching, solvent extraction, precipitation and calcination.
The yellowcake will packaged sealed in UN certified drums, weighed and Labelled prior to being stored
in sea containers, ready for shipment. Each sealed drum will hold approximately 400 kg of uranium ox-
ide. Each shipping container will store approximately 45 drums (16 to 18 t) and will be transported under
International Atomic Energy Agency (IAEA) guidelines at a frequency of approximately once per week
to a shipping port likely to be Walvis Bay in Namibia. The container will subsequently be loaded onto a
ship and exported to a uranium conversion facility, consistent with the Non-Proliferation Treaty (NPT) of
Nuclear Weapons.
The tailings from the leaching circuit will be treated with lime to pH 9.5 to neutralise acid and precipitate
residual heavy metals, including copper, cobalt, manganese and uranium. The neutralised tailing slurry
will be pumped approximately 4 km from the process plant to a dedicated Tailings Storage Facility (TSF).
Recovered water from the TSF will be pumped back to the process plant for re-use.
The process plant is designed to treat Malundwe or Chimiwungo uranium bearing ore at a rate of 1 Mt/a
to recover approximately 15,000 t/a copper concentrate and 2 Mlb/a of uranium oxide (U3Os). Copper
recovery to copper concentrate is estimated to be 80% and uranium recovery to uranium oxide is esti-
mated to be 93%. The process plant is designed to operate for approximately 800 hours per year.
 Review of the Uranium Mining Policy in Zambia

3.0 DECISION BY Council

3.1 The Project is approved subject to the following conditions:
3.1.1 Lumwana Mining Company Limited shall implement the project as stated in the Environmental
Impact Statement (ElS).
3.1.2 All proposed mitigation measures as stated in the ElS shall be implemented.
3.1.3 After exploration activities on a particular site, Lumwana Mining Company Limited shall under-
take ecological restoration by planting of trees and grass in areas where vegetation and soil
have serious disturbance by the project.
3.1.4 The radiation level under routine conditions of transport shall not exceed :2 mSv/h at any
point and 0.1 mSv/h at 2 m from the external surface of the conveyance.
3.1.5 Lumwana Mining Company Limited shall ensure that no oil spills occur during construction.
3.1.6 Effluent from the uranium tailings storage facility shall be recycled back to the uranium pro-
cess plant.
3.1.7 To retain the wilderness value of the area and unintentional introduction of invasive alien
species (IAS), no exotic plants shall be introduced without the consent of the Environmental
Council of Zambia.
3.1.8 A Radiation Monitoring Programme shall be developed and the results shall be submitted to
ECZ and the Radiation Protection Authority every six months,
3.1.9 Lumwana Mining Company shall develop and implement a continuous water monitoring pro-
gramme and shall submit results from the monitoring programme to ECZ and MSD every six
months.
3.1.10 Lumwana Mining Company Limited shall develop a Radiation Protection Programme aimed
at providing adequate radiation protection measures for the workers, surrounding local com-
munities and members of the public.
3.1.11 Lumwana Mining Company Limited shall take readings of radiation levels of workers at the
beginning and end or a daily shift.
3.1.12 Lumwana Mining Company Limited shall inform ECZ, MSD and the Radiation Protection Au-
thority in advance of the scheduled transportation of uranium oxide (yellow cake) from the
mine to Walvis Bay in Namibia. 37
3.1.13 The transport of radioactive sources shall be subject to the requirements of the IAEA Regula-
tions for the Safe Transport of Radioactive Material and any applicable international conven-
tion.
3.1.14 Freight containers containing radioactive material shall be segregated during transport and
during storage in transit from places occupied by persons.
3.1.15 Freight containers shall be assigned transport indices to provide control over radiation expo-
sure.
3.1.16 In the event of accidents or incidents during the transport of radioactive material, Lumwana
Mining Company Limited shall observe emergency provisions, as established by relevant na-
tional and/or international organizations, to protect persons, property and the environment.
3.1.17 Lumwana Mining Company Limited shall, upon receiving notification of pregnancy from a
female employee, modify/adapt the working conditions in respect of occupational exposure
so as to ensure that the embryo or foetus is afforded the same broad level of protection as
required for members of the public.
3.1.18 No person under the age of 16 years shall be subjected to occupational exposure.
3.1.19 No person under the age of 18 years shall be allowed to work in controlled areas unless su-
pervised and then only for training purposes.
3.1.20 Lumwana Mining Company Limited should submit an Environmental Emergency Prepared-
ness Plan to Mines Safety Department (MSD) and ECZ within one month from date of project
approval.
 Review of the Uranium Mining Policy in Zambia

3.1.21 A mine decommissioning plan should be submitted to ECZ and Mine Safety Department im-
mediately within one year from date of project approval.
3.1.22 After mining activities at the site have ceased, Lumwana Mining Company Limited shall en-
sure that the land in that c;1rea is rehabilitated to almost its baseline condition.
3.1.23 Lumwana Mining Company Limited shall ensure that workers receive appropriate training
concerning the radiation hazards and the precautions to be observed in order to ensure re-
striction of their exposure and that of other persons who might be affected by their actions.
3.1.24 Noise levels throughout the project cycle shall be maintained within acceptable levels.
3.1.25 Lumwana Mining Company Limited shall obtain water abstraction rights from the water Board
prior to commencing the project.
3.1.26 Lumwana Mining Company Limited shall obtain permits from ECZ and comply in full with the
following regulations throughout the project cycle:
a) Waste Management Regulations, SI No.71 of 1993;
b) Water Pollution Control Regulations, SI. No. 72 of 1993;
c) Air Pollution Control Regulations, SI No. 141 of 1996;
d) Hazardous Waste Management Regulations, SI. No. 125 of 2001.

3.2 The Council advises Lumwana Mining Company Limited:

3.2.1 To obtain any other relevant authorizations such as but not limited to:
a) The Public Health Act;
b) The Lands Act;
c) The Town and Country Planning Act;
d) The Mines and Minerals Development Act;
e) Mines and Minerals Development (General regulations, 2008)
f) The Zambia Wildlife Act.
g) Ionizing Radiation Protection Act
h) Forestry Act

38 3.2.2 To make available information on malaria control and HIV/AIDS to employees.

3.2.3 To provide all workers with adequate and appropriate Personal Protective Equipment.
3.2.4 To provide all workers with adequate and appropriate fire-fighting equipment and training in fire
fighting.

3.3 Lumwana Mining Company Limited shall comply with environmental standards and/or specific limits
of particular pollutants as its responsibility. Thus, compliance with ECZ recommended measures does
not absolve Lumwana Mining Company Limited from its responsibility if such measures do not achieve
compliance with environmental control standards.

3.4 The Council may suspend or cancel this Decision Letter without notice should Lumwana Mining Com-
pany Limited fail to comply with any of these conditions.

3.5 Lumwana Mining Company Limited shall implement the project within three years from the date of ap-
proval. Failure to implement the project within the said period shall render this decision letter invalid and
the developer shall re-submit the EIS.

Julius P. Daka
Acting Director
Environmental Council of Zambia
 Review of the Uranium Mining Policy in Zambia

Appendix 3. Environmental Project Brief (EPB) submitted by African Energy Resources

KARIBA VALLEY URANIUM PROJECT

ENVIRONMENTAL PROJECT BRIEF

FOR THE CHISEBUKA AND NAMAKANDE EXPLORATION

PROGRAMME

Prepared by

AFRICAN ENERGY RESOURCES LTD 39

SEPTEMBER 2008

Project Proponent

Developer Name: AFRICAN ENERGY RESOURCES LTD

Address: Anglo American Building, 74 Independence Avenue, P.O. Box 51403, Lusaka, Zambia
Telephone: + 260 1 250743
Fax: + 260 1 222639
Project Manager: Mr. W. Banda
Email: WiscortB@africanenergyresources.com
 Review of the Uranium Mining Policy in Zambia

EXECUTIVE SUMMARY
This Environmental Project Brief (EPB) has been produced to comply with Zambian legislation and World Bank
(WB) policy requirements as they relate to the environmental assessment of Projects to be carried out within
the framework of the Chirundu Uranium Project.
African Energy Resources is exploring for uranium on a number of Albidon’s mineral tenements in southern
Zambia (see Figure 1 – page 6). The exploration program, which is sole-funded and operated by AFR, has
identified some anomalies within the Chisebuka/Namakande areas. Albidon currently holds a 70% interest in
the Kariba Joint Venture under which these prospects fall. These activities are being undertaken because of
the positive results from the exploration activities on the Njame/Gwabe project areas, where now, the project
is now a Bankable Feasibility Study is being undertaken. This programme is aimed at increasing the resource
within the entire project area. To this effect, they have sanctioned the programme to include the Chisebuka/
Namakande areas, hence the need to undertake this study.
The potential environmental impacts of the Project have been systematically assessed using the source-
pathway-receptor framework in this EPB. An Environmental Management Plan (EMP), included in this EPB,
details the actions that will be taken during the various phases of the Project to mitigate the potential adverse
environmental impacts that have been identified.
The Project will encompass air and waste water monitoring exercises that will be linked to the wider Project
monitoring program, which will be implemented by the Company. The Project specific monitoring exercises
are designed to support the objective of monitoring and demonstrating the human health and wider environ-
mental benefits of the mitigation works.
It is expected that the most significant beneficial social – economic impact to arise as a result of the implemen-
tation of the Project will be the improved quality of life in surrounding areas of the Project site.

40
 Review of the Uranium Mining Policy in Zambia

TABLE OF CONTENTS
1. INTRODUCTION 5
2. PROJECT DESCRIPTION 6
3. LEGISLATIVE REQUIREMENTS 13
4. PROJECT SETTING 15
5. PROJECTED ENVIRONMENTAL AND SOCIAL IMPACTS 22
6. MEASURES TO MITIGATE NEGATIVE IMPACTS 30
7. OCCUPATIONAL HEALTH HAZARDS 37
8. ASSESSMENT OF ALTERNATIVES 37
9. CONCLUSION 38

41
 Review of the Uranium Mining Policy in Zambia

Acronyms and Abbreviations

AFR African Energy Resources Ltd
JORC Joint Ore Resources Committee Standards (Australia)
ASPT Average Score Per Taxon
CDF Community Development Fund
DA District Administrator
DACO District Agricultural Coordinator
DDCC District Development Co-ordinating Committee
EA Environmental Assessment
ECZ Environmental Council of Zambia
EIA Environmental Impact Assessment
EIS Environmental Impact Statement
EMP Environmental Management Plan
EO Environmental Officer
EPB Environmental Project Brief
EPPCA Environmental Protection and Pollution Control Act
GRZ Government of the Republic of Zambia
MMD Movement for Multiparty Democracy
MSD Mine Safety Department
NGO Non Governmental Organisation
NGOCC Non Governmental Organisations’ Co-ordinating Committee
OP Operational Policy
PDCC Provincial Development Co-ordinating Committee

42 PFS Pre – Feasibility Study

WB World Bank
WHO World Health Organisation
YWCA Young Women’s Christian Association
 Review of the Uranium Mining Policy in Zambia

1. INTRODUCTION
African Energy Resources Limited (AFR) is exploring for uranium on a number of Albidon’s mineral tenements
in southern Zambia (see Figure 2.1 – page 6) as well as other wholly owned tenements within the same region.
The exploration program, which is sole-funded and operated by AFR, has identified a JORC Inferred Resource
at the Njame deposit and more recently identified a new uranium discovery at the Gwabe prospect, approxi-
mately 20km to the north. Both areas are located within the Chirundu Project and are subject to a joint venture
recently signed by Albidon and AFR. Albidon currently holds a 70% interest in the joint venture. Because of the
positive results from the exploration, the Board has determined to proceed with other potential areas so as to
increase on the resource. The Decision to Proceed with this programme follows on the successful soil sam-
pling that was conducted last year. The soil sampling demonstrated the potential for an economically viable
Project using proven technology and bench marked costs for the areas of Namakande and Chisebuka. The
exploration programme in the areas will commence immediately after all the necessary approvals have been
secured. The study will focus on drilling to upgrade the resource status.
This Environmental Project Brief (EPB) encompasses the entire project areas i.e. the Chisebuka and Nama-
kande Project sites and the surrounding areas. The baseline study, comprising part of the EPB, was undertak-
en in order to fulfil the requirements for an EPB to be conducted for any Project before its implementation. AFR
was required to undertake the EPB study as it intends to commence its exploration activities in the areas.
The Environmental Project Brief study adheres to the requirements of the Environmental Impact Assessment
(EIA) regulations of the Environmental Protection and Pollution Control Act (EPPCA) of 1990. The EIA regu-
lations demand that socio-economic and environmental impacts consequential to the implementation of the
Project are assessed well in advance.
AFR commissioned the Environmental Project Brief (EPB) to assess the baseline, environmental trends and
socio-economic data of the Project area to identify significant environmental and socio-economic impacts of
the Project and propose possible mitigation measures. This study addresses positive as well as negative im-
pacts and recommends measures for mitigating negative environmental effects.

1.1 Study Methodology

The study was undertaken to obtain the views and concerns of the interested and affected parties. The follow-
ing steps were involved in the process:
• Consultative discussions with AFR members of staff and local residents in the immediate environment of
the Project;
• Review of relevant legislation;
• Review of environmental literature; and 43
• Identification of significant environmental impacts and development of mitigating measures.
Responses from consultations and data from literature provided the significant environmental impacts and
helped in the development of an environmental management and monitoring plan.

1.2 Scope of Study

The Environmental Project Brief study adheres to the requirements of the Environmental Impact Assessment
(EIA) regulations of the Environmental Protection and Pollution Control Act (EPPCA) of 1990. The EIA regula-
tions demand that socio-economic and environmental impacts consequential to the construction and operation
of the Project are assessed well in advance.
AFR commissioned the Environmental Project Brief (EPB) to assess the baseline, environmental trends and
socio-economic data of the Project area, identify significant environmental and socio-economic impacts of the
Project and propose possible mitigation measures. This study addresses positive as well as negative impacts
and recommends measures for mitigating negative environmental effects.

2. PROJECT DESCRIPTION

2.1 Introduction
African Energy Resources (African Energy) is undertaking exploration activities on the Namakande - Chise-
buka Uranium project areas in Zambia. The project is located about 206 km south of Lusaka, Zambia’s capital
city through Gwembe. The nearest town to the project site is Gwembe – some 80 km south-east of the town
i.e. Gwembe Namakande and 77 km from Gwembe to Chisebuka. Please note that the two sites Namakande
and Chisebuka are separated by the hill and this makes the route from Namakande to Chisebuka not possible
 Review of the Uranium Mining Policy in Zambia

to cross through the hill. The only way to the other site is from Namakande back to Munyumbwe and then to
Chisebuka.
Figure 2.1 – Project Location

The Kariba project contains the Namakande and the Chisebuka deposits Chirundu which are sandstone host-
ed Uranium deposits with potential economic value.
44
This is the second of the two joint venture projects with Albidon arising from the Albidon Exploration Agree-
ment, i.e. the Kariba Valley Project (see Figure X). It comprises an area of 1,968 sq km and includes parts of
three Albidon prospecting licenses (PLLS.250 Mugoto, PLLS.245 Sinazeze and PLLS.193 Masuku).

Previous exploration on this project area has identified three prospects. The Chisebuka, Munyumbwe and Na-
makande prospects have a similar geological setting to Njame. Chisebuka is characterised by a well defined,
intense radiometric anomaly over an area of 1,500m x 400m, and appears to have undergone little previous
drill testing. A drilling program to test this anomaly has been planned and will commence in the near future.

At Munyumbwe, two prospects have been identified. Munyumbwe ‘A’ consists of a broad ground radiometric
anomaly which has been tested by African Energy through reconnaissance drilling. Evaluation of the drill cut-
tings suggests that significant mineralisation has not been identified. Munyumbwe ‘B’, further to the north, has
not been tested to date. Namakande consists of a series of poorly constrained ground radiometric anomalies
over an area in excess of 7km x 2km. Field work is required at this prospect to evaluate the potential of these
and to prioritise targets for drill testing.

No work was undertaken by the previous holders of the relevant prospecting licenses on the Sinazongwe
blocks due to security concerns related to possible minefields near the shore of Lake Kariba. The potential
of this area has thus not been tested to date. African Energy has recently completed an airborne radiometric
survey over the Sinazongwe blocks to assess the uranium potential, and has identified three areas of uranium
anomalism for further evaluation (Figure 7).
 Review of the Uranium Mining Policy in Zambia

In addition to the uranium potential, there are several coal occurrences in Lower Karoo sediments within the
Kariba project area. The Company intends to undertake a program to evaluate the coal potential, and particu-
larly the scope for accumulations of coal-bed methane, and will utilise the services of an expert consultant to
help design this program.

2.2 Exploration Programme

AFR’s exploration programme within the project areas commenced in year 2007. Field exploration activities are
generally conducted in the dry season from March to November (8 calendar months). No drilling or trenching is
carried out in the wet season (4 remaining calendar months). AFR’s exploration programme comprises:-

1. Regional exploration across the project areas to identify anomalies, which will then be the focus of more
detailed exploration work; and
2. Concurrent detailed investigation of known smaller and medium size uranium deposits to determine their
potential and the likelihood of occurrence of larger ore bodies.

The exploration programme includes the following activities:-

• An airborne magnetic and radiometric geophysical survey across the project area;
• Preliminary geological mapping of selected targets;
• Geochemical survey of stream sediment:
• Geochemical survey of surface soils;
• Trenching in shallow soils; and
• Exploration drilling is carried out when suitable exploration targets are identified from the results of
geological mapping, soil sampling and/or airborne geophysical survey. Construction of access tracks
to drill sites may be necessary.

Ground exploration work is concentrating on areas accessible by existing roads and tracks in order to generate
fast-track prospects wherever possible.
AFR is carrying out repairs to the existing road infrastructure including roads, bridge structures and culverts,
where necessary to gain access into exploration areas.
45
2.3 Description of Exploration Activities

2.3.1 Field Surveying and Baselines

All surveying will be carried out using Global Positioning System (GPS) instruments.
Soil geochemical surveys and geological mapping will be conducted using handheld low-accuracy non-differ-
ential GPS receivers.
Exploration drill hole collars will be positioned using an Omnistar, high accuracy differential GPS receiver fol-
lowed up by traditional survey methods if required.

No permanent baselines or grids will be established in any exploration project area.

 Review of the Uranium Mining Policy in Zambia

2.3.2 Earthworks and Excavations

Only small-scale earthworks or excavations will be undertaken as part of the exploration programme. Appropri-
ate safety measures as required by mining regulations will be implemented during the excavation of trenches
to ensure the safety of AFR employees and the public.

Figure 2.2: Map Showing Locations Where Drilling Activities will take place in Namakande Area

46 2.4 Sampling Methods

2.4.1 Stream Sediment

No stream sediment samples have been collected to far. If stream sediment sampling is carried out, the pro-
cedure will be as described below.
A 1 kg sediment sample is collected from the watercourse using a tube sampler, trowel or spade. The sediment
is sieved on site and the coarse reject returned to the watercourse. Three 100g samples are prepared from the
initial sample and submitted to an accredited laboratory for geochemical analyses.
4x4 vehicles will be used to access sampling sites via existing roads and tracks. Where vehicles cannot pass,
access is on foot. Sediment sampling will be conducted between March and November.

2.4.2 Soils
Soil samples are being collected on a 400 to 800 meter grid across the project areas. The initial sampling density
is 12 to 24 samples per square kilometer. Further soil samples will be collected in areas where favourable uranium
anomalies are found. The soil sampling procedure is described below.
A small 25cm x 25cm x 50 cm deep holes is excavated at each soil sampling site, using a spade. A 1kg soil sample
is collected from the bottom of each hole. The reject material is placed back in the hole as soon as the sample has
been collected. The sample is transported to the regional field site in Njame for final sample preparation. Three
100g samples will be prepared from the initial sample and submitted to an accredited laboratory for geochemical
analyses.
4x4 vehicles will be used to access sampling sites via existing roads and tracks. Where vehicles cannot pass,
access will be on foot. Road construction and clearance of vegetation will be kept to a minimum during soil sam-
pling.
 Review of the Uranium Mining Policy in Zambia

2.4.3 Trenching and Pitting

In areas where the soil cover is thin, small trenches could be excavated to sample bedrock mineralisation.
The trenches dimension will be 0.8 meters wide and up to 4 meters deep. The trench will be excavated per-
pendicular to the strike of mineralisation. The length of individual trenches will depend on the specific target
under investigation. Digging will be done by hand using picks and shovels. AFR will employ local labour to dig
the trenches.
Trench or pit perimeters will be marked using red and white fluorescent barrier tape, from the start of excava-
tion until the hole has been backfilled. This will reduce the risk of inadvertent access and injury to the public.
A geologist will log the exploration trenches and collect rock samples using a hammer and chisel. Approxi-
mately 1kg of material will be collected per meter length of trench.
All excavations will be backfilled following interpretation of geochemical test results and if no further sampling
is necessary.

2.4.4 Rotary Diamond Core Drilling

Rotary diamond core drilling is one of two drilling methods employed by AFR to sample rock types below 4
meters depth.
The diamond drill is mounted on a 20-ton truck together with all ancillary equipment. Diamond drilling samples
are cut using a diamond-impregnated bit and double tube core barrel. Diamond drilling produces a stick of rock
that is recovered from the inner tube of the core barrel. The bit and core barrel are connected to the surface
by a continuous length (or string) of steel rods, which allow the bit plus core barrel to be lowered into the hole,
and lifted back to the surface.
Water is circulated down the inside of the drill rods, washing over the cutting surface of the drill bit and return-
ing to the surface through the narrow space between the outside of the rods and the wall of the drill hole. The
water lubricates and cools the drill bit, and removes crushed and ground rock fragments from the bit surface.
Water may be used in combination with various clays and other additives. The drill fluid is collected in a settling
pond (sump) and recycled throughout the course of the drilling process.
It is sometime necessary to clear access to each drill site. Vegetation is carefully moved aside to allow maneu-
verability of the drill rig and ancillary equipment. Trees are only felled if necessary. No mature indigenous trees
are or will be felled during the drilling programme.

2.4.5 Reverse Circulation Drilling 47

The second drilling method is reverse circulation drilling (RC). The RC drill rig is mounted on a 20 tonne truck.
A second support truck of similar size carries an air compressor and ancillary drilling equipment The RC drill-
ing technique employs a double walled string of drill rods equipped with a compressed air driven percussion
hammer at the cutting end of the string. Drill cuttings (commonly rock chips) are brought to the surface up the
centre of the rods. On surface, the cuttings are passed through a cyclone and the underflow deposited in a
sample collection container or plastic bag. Sub-samples are split on site and prepared for laboratory analyses.
The split material is stored at the regional field office.
It is sometimes necessary to clear access to each drill site. Vegetation is carefully moved aside to allow ma-
neuverability of the drill rig and ancillary equipment. Trees are only felled if absolutely necessary. No mature
indigenous trees are felled or will be felled during the programme activities.

2.5 Exploration Camps

AFR’s regional field exploration sites will be in Namakande and when the work is hear is finished, will then shift
to Chisebuka. The facilities comprise a sample storage area and an office.
Temporary, mobile field exploration camps are used to accommodate drillers, exploration geologists and sup-
port staff.
The camps consist of canvas tents and are serviced by 12-volt battery lighting, and cooking facilities. The camps
accommodate up to 7 persons and are guarded 24 hours. When a mobile camp is to be established in a new
area, the headman or his superior in the village closest to the proposed camp is notified in advance, and con-
sulted. Relevant government officials living in the area are also notified.
AFR does not erect permanent structures at any of its field exploration camps.
 Review of the Uranium Mining Policy in Zambia

Please note that for sanitation purposes, pit latrines will be dug and these will be located away from any water
resource. The pit latrines will also be kept clean all the time. The pits will also be covered so as to maintain
high hygiene standards.

2.6 Access Routes

Road infrastructure within the exploration permits is generally poor or non-existent. All roads within the explo-
ration permits are unsealed roads. Some unsealed roads, bridges and culverts require minor rehabilitation.
This work will be carried out as and when necessary.
It will sometimes be necessary to construct access tracks to drill sites.

48 Plate 1: Repairs being done to the Access Route Washed during the Rains

2.7 Sampling Materials and Equipment

Sampling equipment will consists of shovels, picks, plastic buckets, sieves, brushes and plastic bags. All sam-
pling equipment will be stored in metal trunks and carried in a vehicle.
No chemicals will be used in the exploration programme except for biodegradable additives to drilling fluids.
AFR will be using an environmentally friendly biodegradable drilling additive.
AFR will maintain an inventory of all sampling materials and equipment used on site.
 Review of the Uranium Mining Policy in Zambia

Appendix 4. Minutes of the Denison Mines Zambia Limited EIA Public Consultation

Denison Mines Zambia Limited

Meeting Minutes
Public Consultation Meeting
4 June 2009
Opening:
The Public Consultation Meeting for the Mutanga Project was called to order at 11:00hrs on 4th June 2009.
The meeting was chaired by Mr Aaron Siamuzyulu, District Administrative Officer (DAO), Siavonga District.
The meeting was delivered in English and Chi’Tonga; translations were provided by Alexander Kansenzi, Har-
vest Help Zambia.
Present:
The meeting was open to the public and was attended by 32 dignitaries, officials and Denison Mines Zambia
Limited staff as shown in Table 1. A complete list of the 443 public attendees is given Table 3.
A. Call To Order
11:00 DAO declared the meeting open.
B. Opening Prayer (Charles Hamaimbo)
C. National Anthem (All)
D. Introduction of Invited Guests (DAO)
11:02 DAO introduced dignitaries and officials to the meeting per Table 2.
E. Welcoming Remarks (AG)
11:07 Welcomed all meeting attendees;
• Advised the purpose of the meeting was for the company to receive public comments “so we know
what to do”,
• Said this is an important meeting.
F. Official Opening Remarks (DC)
11:10 Welcomed the attendees,
• Advised she was struggling with her medical condition, asked for the attendees’ understanding.
• Welcomed the mine development so long as it was conducted within the laws of Zambia.
• Advised this meeting is required by law. It is intended to link investors to the local community.
• Thanked attendees for coming. 49
• Requested attendees be open in their discussions to have a fruitful meeting.
G. Overview of Denison Mines Corp, Denison Mines Zambia Limited and the Mutanga Project (AG)
11:12 Overview of Denison mines:
o 3 operating uranium mines in Canada and USA,
o 2 operating uranium (production) mills in USA.
o Other projects in Mongolia and Zambia.
o Only mines uranium, but some vanadium produced as a byproduct form US operations.
o 2008 production was 1.6 million pounds (Mlb) uranium oxide (U3O8); approximately twice the 2007
production.
o 2009 production estimated to be 1,4Mlb
• The uranium market
o Expanding rapidly.
o 436 reactors in 30 countries produce 2.6 trillion kilowatts of power; i.e. 15% of the world’s power.
o Around the world:
 44 reactors are under construction,
 110 reactors are in the planning stages,
 14 countries currently without nuclear power are planning to adopt it.
o By 2015 the demand for uranium will exceed supply,
o In 2008 world consumption of uranium was 181Mlb,
o In 2009 demand is estimated to be 171 to 184Mlb; compared with production of 125Mlb; 50Mlb of this
will come from reprocessing Russian and US nuclear weapons,
o By 2015 annual consumption is estimated to be 214Mlb so new sources, such as Mutanga, will be
required.
 Review of the Uranium Mining Policy in Zambia

o It is expected that the uranium prices will increase in the near future. Most of the product from Mutanga
will be sold on the long term contracts market.
• As a business, DMZL needs to ensure that the long term selling price of uranium is higher than what it
costs to produce.
o To evaluate this, the company has been doing a feasibility study for the past year. It was completed
last week.
o All economic indicators of the feasibility study are that the Mutanga project is very viable.

• The 2008 feasibility study increased the total resource from 13.1Mlb to 21Mlb U308
• The feasibility study included:
o Environmental and social baseline studies,
o Metallurgical testing,
o Process design,
o Project design,
o 3,300m water resources drilling.

• At the open pit sites the groundwater tables needs to be lowered to ensure pit wall stability. The water
pumped from the ground will be used in the processing operation and excess will be pumped back into
the ground away from the pit; it will not just be dumped on the ground.

• Other Infrastructure
o A 66kilovolt power line will be built from Chirundu to Mutanga,
o The power line will follow the same alignment as the Zyiba Meenda road – which will also be upgraded
to provide access to the mine.
o The Zyiba Meenda road will be further demined by ZAMAC before any construction.

• ZAMAC advised last week that they will be producing a report documenting the demining requirements.

11:34 Revised mineral processing strategy.

• The meeting was being held within what is proposed to be the Mutanga open pit; that the surrounding
area (approximately 1km in diameter would be part of the open pit).
• Assurance that that radiation levels were very low and that the meeting attendees were safe – even
50 though 400m away was a naturally occurring outcrop of the highest grade uranium in the district.
• Indicated that the processing plant would be 1km away (pointed).
• One of the reasons to hold this meeting is because DMZL has changed the proposed mineral process-
ing method of leaching the uranium from the rock. Until now the company had proposed to use an
alkali solution in large tanks. The recent test work has indicated that it will be more cost effect to use
an acidic solution on heaps of ore.
o The heap leach pads consists of several 3m high layers, stacked one on the top of the last – with
a double layer of thick plastic membrane at the base to prevent any leakage.
o An acidic solution is “irrigated” over the heaps to dissolve (i.e. leach) the uranium from the ore.
The “pregnant leach solution (PLS)” flows downwards to the plastic membranes where it is col-
lected and piped to a storage pond (which is also lined with a plastic membrane).
o The PLS is pumped to an Ion Exchange (Ionex – or IX) plant where the uranium is extracted.
o The uranium (as ‘yellow cake’; i.e. uranium oxide, U308) is precipitated then dried and packed in
certified 200 litre metal drums for shipping in sealed and certified 20 feet sea containers.
o The sea container will be shipped to a port certified to handle radioactive materials – most likely
this will be Walvis Bay in Namibia (it already handles ore from the Rossing and Langer Heinrich
uranium mines).

• The advantages of acid heap leaching over alkali tank leaching?

o Lower capital and operating costs,
o Simpler to operate.
 Review of the Uranium Mining Policy in Zambia

• Acid heap leaching of ores is proven technology (20% of world gold production and 18% of world cop-
per production)
• Heap leaching of uranium ores is being proposed for:
o African Energy’s project at Chirundu, Zambia
o Two mines in Namibia,
o Mines in Australia.

11:45 Project Benefits:

• Denison has 54 years experience in producing uranium in North America,
• The Mutanga Project ore is very close to the surface so it is economic to mine,
• The Mutanga Project is close to required infrastructure,
• There is a large local labour supply.

Project Challenges:
• The availability of technical and regulatory personnel with uranium experience.
o DMZL plans to bring world experts to help train the Zambian authorities.
o DMZL will train local employees in all aspects of their job and radiation safety.
• The rainy season will affect the construction timetable.
• Need to be diligent in the mining phase because the Mutanga and Dibwe ores are very low grade.

Project Plans:
• Continue the environmental and social baseline studies,
• To successfully relocate the people of the six villages affected by the mine:
o 300 people from six villages are affected.
o The Relocation Committee has been meeting monthly since December 2008.
o Three relocation sites were proposed by the Relocation Committee; of these Kashundi (9kms from
Mutanga) seems to be the best.

• Continue small scale social projects:

o Support for the Mutanga Community School and Machinga Basic School.
51
o Reestablish the 2008 Mutanga vegetable garden project (which failed for lack of water in 2008).
DMZL will supply the seed and fertilizer and guarantee to purchase the produce.
• Expand programs for scholarships, medical and health facilities and schooling.
• Intention is to work through an independent committee and liaise with local NGO empowerment pro-
grams.
• DMZL’s major shareholder is the founder of the Lundin for Africa Foundation. DMZL’s intention is to
involve this NGO in local social projects.

Production Timetable
• Now - DMZL is in the process of applying for the permits required to mine uranium.
• Later in 2009 – DMZL will apply for a permit to build and operate a uranium processing plant.
• 2010 – Continue detailed site work.
• July 2010 to August 2011 – Relocation related activities.
• January 2012 – First production of uranium.

11:55 AG finished speaking; advised that questions would be fielded after AD had spoken.

11:56 DAO:
• Thanked AG for his presentation,
• Introduced AD; requested she make her presentation as slow as possible because this section related
to people who are to be relocated.
 Review of the Uranium Mining Policy in Zambia

H. Environmental Impact Assessment and Relocation Action Plan. (AD)

12:00 Introduced African Mining Consultants

• Advised that the legislative background for the project is the 2008 Mines and Minerals Development
Act.
• This will be the first uranium mine in Zambia; until now there has only been stockpiling of uranium ore
at Lumwana; no processing.
• To date there DMZL (and OmegaCorp) have only been exploring the Mutanga Project lease; there has
not been any mining or production of uranium.
• Mining can only proceed if given the “go ahead” by the local community and that of the government
of Zambia.
• The Environmental Protection and Pollution Control Act 1990 applies.
o The ECZ will govern the environmental aspects of all current and future projects.
o The regulations describe what needs to be done to develop a mine.
• The Radiation Protection Board: Legislation is the Ionising Radiation Protection Act 2008.
o Ionising radiation can be natural and can be harmful in high amounts.
12:07 Described the environmental assessment process:
o Managed by ECZ, Head Office is in Lusaka and local regional office is in Chirundu.
• Baseline study has been conducted at site before development. Includes:
o Soil
o Groundwater,
o Surface water,
o Local populations,
o Air quality etc.
• Methods and activities are detailed in the legislation:
o Terms of Reference (to be used by consultants),
o The Public Meeting requirements,
o Conducting an Impact Study; developing a report (including management plan – by development
consultant)
o All these are assessed by the ECZ in its decision whether to permit the operation to proceed.
NOTE: Public Disclosure is a key part of the legislation and the process.
o Input from local government and local community stakeholders is also an important component.
52 12:13 The Mutanga Project – In Detail
• Project life is currently scheduled for 10 years
• Two open pit mines – these are large holes from which rock is removed.
o One at Mutanga (at the Mutanga village),
o One at Dibwe (which is several kms from Dibwe village) NOTE: The Dibwe open pit is not scheduled
for commencement until Year 6 of the mining operation, i.e. 2017).
• Two heap leach pads.
• Two waste rock stockpiles.
• A processing plant at Mutanga.
• Main access to the mine and plant is via the Zyiba Meenda road.
• A power line from Chirundu will follow the Zyiba Meenda road for some of the way.
o The electricity substation will be near the processing plant.
• Total area affected by the plant and mine is 32.2sqkm.
• Affected villages will be relocated – at this stage the planned relocation destination is the Kashundi
area, 9kms from Mutanga.
o The villages to be relocated are:
 Kasambo,
 Chilundi,
 Kapata,
 Chiyobeka,
 Malilansolo
 Sinanjose
o People from these villages have been consulted and their representatives are members of the
Relocation Committee meeting which meets monthly.
 Review of the Uranium Mining Policy in Zambia

• Water quality assessment

o Three streams have been tested and their baseline mineral levels recorded.
o Groundwater from hand pumps and boreholes have been tested and recorded. Quality is “generally
fairly good”.
• Air quality testing
o The results are “good” based on radon sampling. NOTE: Radon is a gas, and a daughter product
that comes from the radioactive decay of uranium. It can be harmful to people and so its presence
needs to be monitored continuously.
• Flora and Fauna studies
o Described the major vegetation types at the site,
o Described the prevalent animal species; commented that there are no permanent populations of
large mammals but that some elephants (one or several individuals, not any herds) pass through
the district from time to time.
12:23 Impacts
• The mine is in an area that relies on tourism and fishing (at Siavonga),
• The project will encourage district development,
• The project will assist national development through the fees and royalties paid by DMZL,
• Sustainable projects will be implemented by DMZL and NGOs,
• The site’s access road will provide improved accessibility to the area,
• There will be improved health and education facilities,
• Environmental and social Impacts:
o Clearing of vegetation a site,
o Possibility of soil contamination,
o Possibility of water contaminations form spills.
o Air quality – If there was to be blasting at the open pit operation (as in the Copper belt) there would
be potential for dust generation. However, the material to be mined is soft and can be dug with-
out blasting – so much less dust generation potential and better air quality than the Copper belt.
NOTE: All mines have these risks; the site’s Environmental Impact Statement (EIS) details these
factors and their proposed management.
o Radioactive dust particles are of concern and will be managed by spraying with water to suppress
the dust and/or sealing the main access road(s).
o AD described the process of dewatering the open pit areas. This water will be pumped from bore 53
holes surrounding the pit and is not contaminated. It will be pumped to raw water dams at Mutanga
and Dibwe and any excess pumped back into the ground elsewhere.
o Possible impact from water at the leach pads. AD described the double layer of polypropylene
beneath each leach pad and associated leak detection systems.
o There will be higher noise levels than there are now. This may impact upon the local communities
and animals. The management strategy of this issue is to relocate the affected communities and
maintain an ongoing monitoring program.

• Safety and security impacts. The mine’s security team will manage all access points to maximize on
site safety and security.
• Radiation. Under law, DMZL must monitor and manage the emission of ionizing radiation.
o All employees will be part of the site’s radiation monitoring program. Employees will be trained in
radiation management methods to ensure their own protection.
o A plan detailing the personal protective equipment (PPE) for employees has been developed.
o DMZL will also ensure public education with the local communities and stakeholders.

• Waste. There are no local waste disposal facilities. The site will generate waste metal, containers,
wood, plastic, grease/oil and food. A waste management program (detailed in the EIS).
o The waste management plan also details how items contaminated with radiation will be managed
at site.
 Review of the Uranium Mining Policy in Zambia

• Zambian law requires that a detailed Management Plan requires a General Manager or their repre-
sentative at site at all times. Safety, Health and Environment (SHE) will be coordinated by the Director
of Mine Safety, an onsite Radiation Safety Officer (RSO) and a department staffed by company SHE
officers.
• The storage and transport of radioactive material is given in the EIS. It has been developed in ac-
cordance with Zambian law which in turn reflects the International Atomic Energy Association (IAEA)
requirements.
• A mine water management plan (detailed in the EIS) will be implemented at site. It details the manage-
ment of clean, dirty, process and uranium contaminated water.
12:41 Relocation Action Plan (RAP)
• ….will ensure the local communities are relocated to a safe area.
• Follows legislation regarding compensation for loss of home, buildings, fields and income (relocated
small shops and guest house).
• Relocation statistics:
o Six villages,
o 107 households,
o Approximately 342 people.
• Representatives from these villages are involved in the Relocation Committee.
o 62 fields,
o Some small shops and a guesthouse
• AD described development of the relocation plan and committee; stated relocation was the ongoing
task of Denison’s Community Consultation and Development Coordinator (CCDC) and an indepen-
dent committee.
• Denison will:
o Clear the Kashundi village site,
o Provide a house and a small plot for each household,
o Clear a field to replace each one left behind,
o Clear old structures,
54 o (with the Ministries of Health and Community Development) assist with the building of a school,
clinic and community water bores.
• Minutes of relocation meetings and photographs will be submitted to the ECZ

I. Question and Answer Session

12:50 Call for Questions (DAO)
Requested that questioners give their name, Chiefdom and/or organization.
(Q) Inspector of Mines: Does the company have a health policy; has the company established the status
of the community’s health?
(A) AG. Yes. DMZL has a strong safety and health policy developed within IAEA guidelines. All
employees will be monitored. On site Occupational Safety and Health (OSH) staff will monitor
health levels against IAEA guidelines.
(Q) Inspector of Mines: Regarding baseline testing. Has there been any lung function tests for local villag-
ers, especially primary school children – pre mining. “To me this is very important?”
(A) AG. No. There are no local health facilities so first pass baseline testing has not been possible.
DMZL envisages a two year start up time and will use this time (and have the budget) to do this
testing. All employees will complete lung function testing before being hired and will be tested
regularly throughout their employment.
(Q) Patrick Makukisi, representing HRH Chief Chipepo. Will there be nuclear power plants in Zambia?
(A) AG. This is a matter for the Government of Zambia to pursue, not DMZL.
(Q) Patrick Makukisi, representing HRH Chief Chipepo. How will the mineral royalties be spent?
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(A) AG. This also is a matter for the Government of Zambia. Denison will pay its taxes and royal-
ties but cannot control how they are used.
(Q) Patrick Makukisi, representing HRH Chief Chipepo. The relocated people – will they be affected?
(A) AG. What is “affected”?. Everyone will be affected; the majority of the affects will be positive;
employment etc.
(Q) Patrick Makukisi, representing HRH Chief Chipepo. How far is the new community (i.e. the relocation
area?) from the open pit?
(A) AG. As stated in the presentation, about 9kms. In my experience, about 3kms is sufficient.
The company will monitor dust, noise and radiation and any issues arising will be managed..
(Q) Patrick Makukisi, representing HRH Chief Chipepo. (How will) the waters and rivers
(be affected)?
(A) AG. We will have done the test work and proved that we will have no impact on the flow of the
rivers. Other water will be got out of the ground – and any excess put back there.
(Q) Eric Kaluba, Harvest Help, Zambia. How will the company promote and provide education and health
in the local area? Local children walk barefoot; how will they be kept away from dumping sites (i.e. ore
leaching heaps)?
(A) AG. All areas (especially heap leach pads) will be fenced and patrolled by security officers).
(Q) Eric Kaluba, Harvest Help, Zambia. Radon 22 will be emitted; it will be 14-15 years before it appears.
There would be a risk to pregnant women’s children. What safety measures will there be?
(A) AG. As part of the monitoring the company will monitor health and safety of people in the com-
munity. The company has well established monitoring programs in place in North America.
For example, at the White Mesa mill in Utah the company has records that go back 50 years.
We can say from this that there has been no negative impact on community health. These
programs will be used at Mutanga. Reinforced that safety and health programs for workers
and community are important in the uranium business.
(Q) Eric Kaluba, Harvest Help, Zambia. Investment attracts social life, sex workers and HIV/AIDS. What
will happen to our girl children?
(A) AG. This is an important question the world over; it is a part of social fabric. It is the responsi-
bility of the company and the whole community, the elders; the seniors – all must manage this.
DMZL will assist in the development of schools with the Ministry of Education and engage with
55
NGOs to assist. All stakeholders have to be involved, though DMZL will probably provide the
bulk of the funding for these programs.
(Q) Collins Sitali, National Assembly, Constituency of Siavonga. There has been mines closing down in
Zambia, including Munali in the Southern Province. Has the economic climate affected Denison and
what measures are in place to prevent the mine closing down?
(A) AG. No one that runs a business can be 100% sure it will be 100% successful. Nuclear power
stations need a continual supply of (uranium) fuel; they just can’t be turned off. So the opera-
tors sign up for long term supply contracts. These negotiations are going on now; the company
is looking to confirm a contract of at least 10 years. Should be aware that the long term con-
tract price has nothing to do with the “spot” price.
(Q) Collins Sitali , National Assembly, Constituency of Siavonga. What happens after 10 years – when the
mine is shut down? Will DMZL leave the country?
(A) AG: Part of my job description is business development; the company is looking for other
projects in southern Africa.
(Q) Collins Sitali , National Assembly, Constituency of Siavonga. Regarding the long term effects of ura-
nium on the area, will there be a trust fund set up to deal with other issues that may arise?
(A) AG: Referred the question to the Mines Safety Department (MSD) representative – asked
what programs are in place elsewhere in Zambia?
(A) MSD representative: Referred to the incidence of silicosis in the Copper Belt and ongoing
programs. Said the MSD will work with DMZL because this will be the first uranium mine in
Zambia.
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(A) AG: We will develop programs with the MSD, we want to be a responsible company.
(Q) Rodes Mbamunya, Kafue Businessman: Is it possible to partner/profit share with the community?
(A) AG: Some of the company’s profits will go back into the community via social empowerment
programs. It is very difficult to hand out cash; experience shows this doesn’t work.

(Q) Charles Halubanje, Simamba Chiefdom. The road from Kariba Store (at Matuwa) to site – will it be
maintained (by DMZL)?
(A) AG: The company will do some maintenance on the Simamba road. Reminded all that oth-
ers use this road and also damage it – e.g. cotton trucks. When the Zyiba Meenda road is
installed that is the road the company vehicles (and the cotton trucks) will use. We need to
work with the District of Siavonga on the Simamba road; treat it as a joint long term project.
(Q) Charles Halubanje, Simamba Chiefdom. Will the company be involved in the maintenance of the Sia-
vonga airstrip?
(A) AG: An air strip is not a priority for the company, we do not need one. The search for an alterna-
tive will be a long term project for the Siavonga District Council. The airstrip is currently under
water and is regularly covered with water.
(Q) Charles Halubanje, Simamba Chiefdom. There is one hospital in the district, will the company main-
tain the road to it?
(A) AG: The company will be building a new hospital at Kashundi.
(Q) Oliver Muunga, Siavonga community. 62 fields will be affected by mining; how many hectares?
(A) AD: Consultants measured and valued the fields. The company proposes to replace these with
the same area at the new village, after ensuring that the ground is at least fertile as the old
fields. Each household will be compensated individually.
(Q) Oliver Muunga, Siavonga community. How many people will be employed at the mine; how many
people will benefit from the mine?
(A) AG: Construction will be 15 months and will employ about 1,500 people. There will be 385
people when the mine is operating; as many as possible will come from local community. The
company needs to develop education programs to train locals. (Commented that he knew ev-
eryone wants a job but decisions will be made on skill levels).
(Q) Joseph Musonda, Sinadambwe Chiefdom, Waste management business in Lusaka. The HDPE mem-
56 brane lining the heap leach pads will only last 400 years, what happens then? Also, how will the pads
be monitored once the company leaves?
(A) AG: The heap leach process takes up to six months to extract 90% of the uranium from the ore
on the pads. The ore is very low grade and, six months after treatment commences, there will
be only 10% less. This is likely to be less than the local, naturally occurring levels.
There won’t be any acid left after 400 years; it is consumed during the process.
The company will have a presence long after the mine is closed. To use a North American ex-
ample, 30 years after the operation closed monitoring of the site is still being done.
Monitoring will continue until the level of contamination is at minimum levels; the specific levels
to be agreed with the ECZ and MSD.
(Q) HRH Chief Simamba. Regarding infrastructure. Will the buildings be of temporary or permanent con-
struction style? Requested that permanent structures be built so they can be donated at the end of
mining.
(A) AG: The plan is to build buildings with concrete block construction and they will be donated
once the mine closes down. The processing plant will be of no use to the local community so
it will be sold when no longer required. The power line and the roads will stay.
(Q) HRH Chief Simamba. What plans are there in place to ensure the local animals are OK?
(A) AG: The company has discussed building a viable game farm on the site and would hand this over to
the community upon mine closure. All operational areas will be fenced to prevent animal access as
much as possible. Gave an example in Botswana where a 2.4m high fence was built around the entire
site and all animals inside captured and relocated. Within six months there were 3 leopards and 20
kudu residing inside; they had jumped the fence.
(A) AD: The Company will minimise habitat destruction on the mining lease and will leave vegeta-
tion corridors
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(Q) Prisca Chilundu – Sinandambwe Chiefdom. What plans have you put in place for women’s affairs?
(A) AG: The company is now working with NGOs regarding women’s empowerment programs.
The company CCDC will be conducting a survey to investigate what women want.
(Q) Derek Velemu Councilor Sikoongo ward. The company left open drill holes after the exploration pro-
gram. What are the plans for these holes
(A) AG: The holes will be capped or backfilled.
(Q) Derek Velemu Councilor Sikoongo ward. What support is the company providing to communities
around Mutanga now?
(A) AG: Referred to a vegetable garden project which failed due to lack of water? This program
will be reintroduced – with a water supply this time.
There has been some support for the Mutanga Community School and the Machinga state
school.
The company provides transport if there is a vehicle available.
The greatest contribution has been employment of up to 200 people over the past four years;
this has had a very big impact on the local communities. When the project is approved (by the
Zambian government and Denison Mines’ Board of Management) a very big drilling program
is needed before construction can begin. A lot of people will be reemployed then.
(Q) Mary Matope, Sinadambwe Chiefdom. Will you be bringing in workers from the outside?
(A) AG: Every time we need to employ someone we look to see can do the job, starting at the lo-
cal villages, then in Siavonga, then in Zambia and finally, internationally. So, people are only
brought if suitably skilled people cannot be found locally.
(Q) Peter Hagunze Councilor ibbwe munyama. Regarding relocation. Is the new village area big enough
to cater for new children, visitors and returning relatives?
(A) AG: Yes – but note that the size will be a relocation committee decision. The committee pro-
posed three areas; they need to be assessed to check (i) If there is any economic uranium
deposits, (ii) the ground fertility. The company will assist with the farmers’ first crops to make
sure everything is suitable before relocation occurs.
The decision regarding the proximity of the village to the farms will be a joint process with the
community. The company will not just say “This is how it is to be done”.
(Q) Serbion Sikongo, Sinadambwe Chiefdom. Why have people been laid off when you say the mine is
being developed?
(A) AG: Denison was affected by the global economic crisis; it could not get any money for further
work programs at the end of 2008. However the world outlook is looking better so we hope to 57
get busy again soon.
(Q) Serbion Sikoongo Sinandambwe Chiefdom. We are told uranium is dangerous. How will the people
who have been laid off be looked after?
(A) AG: If it can be proved that they have developed health issues attributable to their employment
then they will be looked after.

14:15 End of Question and Answer Sessions

14:15 Comments Session

DC Delegated DAO to speak on her behalf. We have discussed, we have asked questions, questions have
been answered. Now we wait decisions. Thanks to the management of Denison for calling this meeting. It has
not been easy to arrange, but it is a requirement under Zambian laws. A message to local girls: The mine will
bring young men; study them, you will have many to choose from. I wish DMZL success (in this project) for the
betterment of the District. Thank you very much.
DC Delegated DAO to speak on her behalf. We have discussed, we have asked questions, questions have
been answered. Now we wait decisions. Thanks to the management of Denison for calling this meeting. It has
not been easy to arrange, but it is a requirement under Zambian laws. A message to local girls: The mine will
bring young men; study them, you will have many to choose from. I wish DMZL success (in this project) for the
betterment of the District. Thank you very much.
MSD Representative: Advised that AG/DMZL is asking for permission to come and invest. Positives are em-
ployment, clinic construction, rehabilitation of road. Potential negative impacts are possible, for example, the
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long term effects of uranium. Urged DMZL to work with the ECZ and MSD to ensure worker health.
Said he had been in the MSD for 21 years and wants to say that when investors invest and are told to make
safety improvements, they usually go to politicians to short cut the system. He doesn’t want this to happen with
this project. He begged DMZL to “complete the job” at the level of mines inspector to reduce the risk of injuries
and fatalities.
In closing, “You (DMZL), are welcome to come and invest”.
RPA Representative: Apologised for coming late, had to come from Choma. Appealed to the investor to work
with the RPA because radiation is a risk to health and worldwide security.
Urged DMZL to provide the necessary protection to its workers, the environment and surrounding communi-
ties.
Urged local mine workers to follow the protocols given to them. Use the PPE that is supplied; “Ensure you
know what PPE you should have and, if it’s not provided, approach the RPA – who will visit as Inspectors.
Said that the RPA are already working with DMZL and urged DMZL to continue doing so.
HRH Chief Sinadambwe: Welcome officials and all other guests to his Chiefdom. Stated this is the first time
his Chiefdom had seen such a gathering. The reason is to agree to unite with DMZL – it’s important to meet,
gather, ask, discuss because things will be difficult to change if they are not discussed.
Thanked DMZL for bringing employment and guaranteeing employment for locals if the mine proceeds.
Urged those who are interested to approach DMZL to register their interest. Stated, “This is the honey that has
dropped for us; we have been producing nothing and we are poor”.
Asked gathering to raise their hands if they were from Sinadambwe Chiefdom; keep hands up if they are wom-
en with a grade 12 education or higher? (Two people). Asked how many men from Sinadambwe with grade 12
or higher? Answered himself, “Very few”.
All four Chiefdoms will benefit from employment. “We don’t want a quarrel, but there must be an agreed bias
towards Sinadambwe people”. Suggested 60%; “skilled or unskilled”. Said he wants to appoint the Human Re-
sources (HR) person to the mine – will hunt for a suitable candidate. Said he must be involved in this process
or otherwise an HR person from “outside” will be appointed. Joked that an outsider will only employ Lozis.
In regards to relocation, said the company has already done what it must do [i.e. census and valuations]. Said
that some people are saying that they don’t intend to move because they were relocated once before. Said
58 that, as Chief, he had already endorsed the relocation, that the government has endorsed the relocation – so
that is what must happen. Appealed to the six villages [to be relocated], “Please move – but be observant; has
what was promised been delivered?”
Said, “We want this development”.
Said, “It is important we all move together. If you choose to remain you will go alone; who will support you?”
“Once you have been paid [compensated] your life will improve”.
“We were invited, we have met and discussed, there are records and we know where to find them [the com-
pany]”.
“There is a change in all Chiefdoms, now companies are required to pay money (a percentage of profits) to
Chiefdoms”. Said that he wants to bank this for the Chiefdom; he wants cash, not just schools and clinics. Ap-
pealed for another meeting with the DC’s office, Council Secretary and DMZL to Minutes – decide upon the
social responsibilities. Referred to two other Chiefs who received an endowment fund.
Referred to the Zyiba Meenda road; said it will end here [at the mine site] – wants it extended to his palace.
Said, “Thank you” to the mining company; added he was not upset or angry but, “It should not be a habit that
you say - and I follow. It should be negotiated with me”.
In closing; thanked all for coming and said to go with God’s blessing. Added he is comfortable [with the meet-
ing] – “I am old so I am getting wiser”.
Area Member of Parliament’s Representative Mr L. Haziiba : Apologised on behalf of the MP; said he had
parliamentary commitments.
Said the proposed development was very welcome to this ward and district as a whole. It will uplift the standard
of living for our people.
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Said he was glad to hear DMZL’s corporate responsibility – the old and new schools, clinic and social facili-
ties.
Appealed that DMZL at all times adheres to international standards; to reduce accidents and illnesses that may
be attributed to uranium. Added that uranium is new to the Zambian people so they will need to be sensitized
– and have ongoing sensitization.
Said that DMZL should also improve local water supplies; added that this was a point for the communities and
the relocation village.
14:55 Vote of Thanks (Roger Staley, Exploration/Country Manager, DMZL)
15:00 Closing Prayer (Ethel Maguswi, DMZL Staff)
15:01 Meeting Closed (DAO)

Minutes submitted by: R Staley (Signed) Approved by: A Goode (Signed)

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 ISBN 998207461-X

Council of Churches in Zambia 9 789982 074612