Senegal: Tomboronkoto Gold Project EIES Submitted Under New Code

• The Tomboronkoto gold project, a joint venture by Ardimines Sarl and Toro Gold Limited, aims to extend the Mako gold project's operational life in Senegal.
• The project involves extracting 6,000-6,200 tonnes of ore daily, requiring an open-pit mine and the realignment of National Road 7.
• Senegal's new environmental code (Law n°2023-15) and the Direc are imposing strict requirements for the project's Environmental and Social Impact Assessment (EIES).
• Direc has emphasized that the EIES approval depends on the quality and transparency of public consultations, with any failure risking rejection.
• The project's location near the Gambie River, a chimpanzee corridor, and Niokolo Koba National Park raises significant ecological concerns.

The Direction de la réglementation environnementale et du contrôle (Direc) has explicitly stated that the ultimate approval of the EIES hinges on the integrity and thoroughness of the public consultations conducted.

The Tomboronkoto gold project in Senegal is poised to significantly extend the operational lifespan of the existing Mako gold project, located approximately 705 kilometers from Dakar in the Kédougou region. Situated near the village of Tomboronkoto in the Bandafassi department, this ambitious venture is a joint-venture operation between Ardimines Sarl and Toro Gold Limited, a subsidiary of the mining giant Resolute Mining. The project, detailed in its satellite project plan and Environmental and Social Impact Assessment (EIES) submitted to the Direction de la réglementation environnementale et du contrôle, is designed as a satellite mine feeding the processing plant of the Mako gold project, which is owned by Petowal Mining Company (PMC).

Preliminary estimates indicate substantial mineral resources at the Tomboronkoto site, with approximately 5 million tonnes of ore grading 2.1 grams per tonne of gold, translating to an estimated 343,000 ounces of gold. The proposed mining operations, anticipated to commence by 2028, involve the daily extraction and road transport of 6,000 to 6,200 tonnes of ore to the Mako facility. This scale of operation necessitates the creation of an open-pit mine spanning over 20 hectares, the establishment of sterile rock deposits covering tens of hectares, and the realignment of National Road 7 (RN7) to accommodate the increased traffic and infrastructure.

The regulatory framework governing the Tomboronkoto gold project has seen significant clarification, particularly with the introduction of Senegal's new environmental code, Law n°2023-15. The initial research permit, known as "Tombo," was granted in February 2019, and its first three-year renewal, effective from February 2023, was formalized through Arrêté n°024329 on July 7, 2023, signed by Minister Oumar Sarr. This renewal stipulated a minimum financial commitment of 2.1 million US dollars from the project proponents.

The Direction de la réglementation environnementale et du contrôle (Direc), operating under the Ministry of Environment and Ecological Transition, is exercising stringent oversight. Following a site visit on October 25, 2024, Direc officially validated the Terms of Reference for the project's Environmental and Social Impact Assessment (EIES). The regulatory body has explicitly stated that the ultimate approval of the EIES hinges on the integrity and thoroughness of the public consultations conducted. Any deficiencies in this process, Direc warns, could lead to the outright rejection of the EIES report. Despite a request for an extension by the project promoter in June 2025, Direc granted only an additional three months for the submission of the provisional EIES report, reiterating its demand for an imperative, inclusive, and transparent public consultation process.

The proposed mining infrastructure for the Tomboronkoto gold project presents complex environmental and social challenges, particularly given its proximity to the Gambie River. This vital waterway is crucial for regional ecosystems and serves as a primary water source for downstream communities. The EIES, prepared by the specialized consulting firm Earth Systems, highlights several sensitive ecological aspects, including the project's influence zone overlapping with a chimpanzee passage corridor and its location near the Niokolo Koba National Park (PNNK).

Beyond the potential financial and industrial benefits, the project's implementation faces significant environmental and social hurdles. The state's heightened environmental compliance requirements and emphasis on community participation underscore the need for careful management. Preserving these fragile ecosystems and ensuring the well-being of local populations necessitates robust compensatory measures and a genuine, transparent social dialogue. The quality and sincerity of public consultations are paramount, not only for regulatory approval but also for fostering sustainable development in the Kédougou region.

Lawyers advising mining companies in Senegal, particularly those involved in projects like Tomboronkoto, must ensure strict compliance with the new environmental code (Law n°2023-15) and the Direc's heightened scrutiny of Environmental and Social Impact Assessments (EIES), especially regarding the quality and transparency of public consultations, to mitigate risks of project delays or rejection.

Source: Original reporting via Le Quotidien