In April 2024, the Australian company Base Resources and US-based uranium and critical minerals producer Energy Fuels Resources Inc. reached a binding agreement for the latter to acquire 100% of the issued shares in Base Resources by way of a scheme of arrangement. The transaction will establish a global leader in the critical minerals sector with a focus on rare earth elements (REE), uranium and heavy mineral sands (HMS: ilmenite, rutile and zircon) production, in addition to a platform for the funding and development of the Base Toliara integrated project in Madagascar, with future monazite concentrate production from the project to be processed at Energy Fuels’operating White Mesa mill, in Utah, in the United States of America (USA).

The Base Toliara mining project is located in a region of Madagascar where it has met fierce opposition from the affected communities, hence its suspension since 2019. The Base Toliara integrated project is based on the combined production of HMS and monazite concentrate, which is most likely to have serious human rights impacts, given the high vulnerability of the local population to any negative impact of the project on their access to water, land, and forest resources on which they critically depend for their survival, as well as to any form of pollution of their natural environment.

In particular, the risks associated with radioactivity emanating from the ilmenite, zircon and rutile mining site in Ranobe are among the main reasons given by local communities that have been opposing the Base Toliara HMS mining project for many years. Since 2014, several scientific studies^[1] have demonstrated the danger of radioactivity for the local population and environment caused by HMS mining at Ranobe. Thus, a scientific study carried out in 2014 indicated that the levels of uranium and thorium emissions at Ranobe are so high that “serious radiation protection measures” will have to be taken to prevent workers in direct contact with the ores, such as miners, and the surrounding population from running the risk of “cancer or congenital pathologies”.^[2]

According to the research results, this danger is due to the fact that Ranobe ilmenite contains Thorium 232, whose radioactive activity (10600-10700 Bequerel/kg), once in the open air, is above the IAAE (International Atomic Energy Agency) standard of 10,000 Bequerel/kg tolerated by the human body. It is therefore certain that such radioactivity will affect the population, endemic species and natural environment of Ranobe and the surrounding area. The pre-feasibility study published by Base Resources itself on 21 March 2019^[3] asserted the fact that the zircon contained in the Ranobe mineral sands deposit contains uranium and thorium whose radioactivity will prevent the products from being exported to the United States and Japan.

The toxicity and dangerous nature of the Base Toliara integrated project have been further confirmed by the monazite mining pre-feasibility study published by Base Resources in December 2023, which points out that the extraction and concentration of monazite would increase exponentially the high risks to the health and lives of workers and local residents. Indeed, the pre-feasibility study underlines that “there would be risks of radioactivity for workers and the community, which would have to be properly managed. (…) Monazite from the Toliara project will be classified as Class 7 dangerous goods (…) due to the levels of radioactive material it contains, and will require specialized handling and distribution » (…) as well as a dedicated vessel (« sharing with other cargoes on board a vessel is not permitted) « ^[4].

We are calling on the competent State authorities in Madagascar and the USA not to give the licence to operate to this integrated HMS and monazite mining project. This is not only because of the unacceptable risks associated with its expected health and environmental impacts, but also because of the significant evidence that, in the past, such mining projects supported by US public funds have undermined fundamental human rights, destroyed unique habitats, and heavily polluted the environment^[5].

Whilst Energy Fuels Resources Inc. is facing strong protest against the deleterious impacts of its operations from the Ute Mountain Ute Tribe living in the White Mesa Band next to its White Mesa Uranium Mill in Utah, the company is prepared to wreak havoc on the communities affected by its mining project in the Toliara II district of Madagascar, who are unfortunate enough to live on land bearing valuable mineral resources. Energy Fuels will do so in the name of resource nationalism, as expressed in its statement that “…(..)… as the only fully integrated producer of separated REE products from monazite in the US, we expect the Merged Group to be uniquely positioned to capitalise on the US Government’s drive for domestic security of supply, as well as the desire of North American and European automobile manufacturers to diversify their sources of REE products supply, to support growth in their electric and hybrid vehicle production targets.”^[6]

Whereas Energy Fuels’ project to supply REE products enjoys strong support from the US Government, there is no adequate regulation in place^[7] to hold mining corporations accountable for their overseas operations. Instead, the US Government is counting mainly on the extractive industry’s self-policing through voluntary schemes that have often failed in the past, as evidenced in the telling case of “the Brumadinho tailings dam that broke in 2019, killing 272 people in Brazil despite an inspection having certified the dam’s stability just four months before”^[8].

To make things worse, the meaningful consultation of the affected communities is key to avoiding the environmental and social problems caused by the Base Toliara integrated project. Despite the glaring lack of such public consultation, its resumption has been announced by the Malagasy Minister of Mines and Strategic Resources on 16 September 2024 without properly informing affected communities, let alone obtaining their consent that they have constantly refused to give to this project over the past ten years.

In solidarity with:

• RSCDA-IO – Research and support Center for Development  Alternatives – Indian Ocean (CRAAD-OI – Centre de Recherches et d’Appui pour les Alternatives de Développement – Océan Indien)
• Fikambanan’ny Fiherena Manombo Mangoky (FI.FI.MA.MA.).
• Femmes en Action Rurale de Madagascar (F.A.R.M),

farmmadagascar@gmail.com; https://farm-madagascar.org/

• Réseau des Jeunes pour le Développement Durable (R.J.D.D.),

Rjdd.madagascar@gmail.com; https://web.facebook.com/RJDDMadagascar

• Collectif pour la défense des terres malgaches – TANY
  malgache@yahoo.fr; http://terresmalgaches.info, www.facebook.com/TANYterresmalgaches

Signing Collectives, organizations and individuals:

• John Feffer, Global Just Transition and Foreign Policy In Focus
• Observatori del Deute en la Globalització ODG
• Alternative Information and Development Centre (AIDC)
• The Right to Say No Campaign (R2SN)
• The Southern African Dismantle Corporate Power Campaign (SA DCP).
• GroundWork/ Friends of the Earth South Africa.
• Jean-Michel Dewailly, professeur honoraire des Universités
• ONG TSINJO AINA Mahajanga
• KMF/CNOE – Education des citoyens
• Réseau des Jeunes pour le Développement Durable – Madagascar (RJDD)
• Femmes en Action Rurale Madagascar (FARM)
• FIKAMBANAN’NY FIHERENA MANOMBO MANGOKY (FI.FI.MA.MA)
• Georges Christé, 38090 Bonnefamille, France
• Yes to Life, No to Mining
• Environmental Justice Atlas (ejatlas.org)
• Association Action and Research for Global Environmental Justice
• Monique RAKOTOANOSY
• WORTH Mada / KM3A
• Emile Thomas RAZAFINDREMAKA
• SETEM Federación
• Global Witness
• Servei Civil Internacional de Catalunya
• Mathilde Gingembre, chercheuse indépendante
• MiningWatch Canada
• Research and Degrowth International (R&D)
• Otros Mundos Chiapas/Amigos de la Tierra México
• The Andrew Lees Trust (ALT UK)
• Snowchange Cooperative
• Réseau international du Comité pour l’Abolition des Dettes Illégitimes cadtm.org« . CADTM international, 8 Rue Jonfosse, 4000 LIEGE Belgique
• Mining Injustice Solidarity Network
• Matthieu Brillet
• Accountability Counsel
• Claude Micmacher, Ecocentre Périgord-Limousin, 24450 St Pierre-de-Frugie
• Melbourne Rainforest Action Group – Australia
• AidWatch – Australia

class_mineral_sands_development.pdf

https://mb.cision.com/Public/22548/3893356/89a168c3d231921e.pdf

^[1] By researchers from the University of Toliara and Antananarivo in 2014, and by a team from Madagascar’s Institut National des Sciences et Techniques Nucléaires (INSTN)

^[2] Presented at the 9th International HEPMAD17 Conference (October2017) at the Malagasy Academy and published on : http://www.slac.stanford.edu/econf/C170921 of the University of Stanford–California.

^[3] https://www.baseresources.com.au/wp‐content/files/Toliara_PFS_confirms_a_world‐

class_mineral_sands_development.pdf

^[4] Toliara Monazite Project Pre-Feasibility Study, 14 December 2023.

https://mb.cision.com/Public/22548/3893356/89a168c3d231921e.pdf

^[5] https://www.theguardian.com/us-news/2017/feb/22/us-export-import-bank-africa-mines-financing-slave-labor

^[6] Base Resources, Scheme Booklet, 2 August 2024.

^[7] https://icar.ngo/making-the-case-for-a-u-s-corporate-accountability-agenda/

^[8] https://www.ecchr.eu/en/case/the-safety-business-tuev-sueds-role-in-the-brumadinho-dam-failure-in-brazil/