Proposed Irrigation Scheme Expansion Project, Stampriet, Hardap Region

PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION

ENVIRONMENTAL MANAGEMENT PROGRAMME

Prepared for: Tristone Business Trust

Client Ref: Stampriet Irrigation EIA

SLR Project No: 733.20070.00001 Report No: 1 Revision No: Final Month/Year: March 2019

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

DOCUMENT INFORMATION

Title PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION Project Manager Gerhard Jacobs Project Manager e-mail [email protected] Author Immanuel Katali Reviewer Alex Pheiffer Keywords Environmental Management Plan, Tristone, Irrigation, Abstraction, Hardap Status Draft SLR Project No 733.20070.00001 Report No 1

DOCUMENT REVISION RECORD

Rev No. Issue Date Description Issued By

1 December 2018 First draft issued for client comments IK

BASIS OF REPORT

This document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescales and resources devoted to it by agreement with (Tristone Business Trust) part or all of the services it has been appointed by the Tristone to carry out. It is subject to the terms and conditions of that appointment.

SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any person other than the Tristone. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or collateral warranty.

Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Tristone and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.

SLR disclaims any responsibility to the Tristone and others in respect of any matters outside the agreed scope of the work.

The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this report remain vested in SLR unless the terms of appointment state otherwise.

This document may contain information of a specialised and/or highly technical nature and the Tristone is advised to seek clarification on any elements which may be unclear to it.

Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents referenced explicitly herein and should then only be used within the context of the appointment.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

CONTENTS

1 INTRODUCTION ...... 1 1.1 INTRODUCTION TO THIS REPORT ...... 1 1.2 DETAILS OF THE PERSONS WHO PREPARED THIS EMP ...... 2 1.3 SCOPE OF THE EMP ...... 2 2 RELEVANT LEGISLATION AND POLICIES ...... 3 2.1 INTRODUCTION ...... 3 2.2 PERMITS AND APPROVALS ...... 3 3 PROJECT OVERVIEW ...... 4 4 OVERALL ENVIRONMENTAL OBJECTIVES FOR THE EMP...... 6 5 MANAGEMENT PLANS ...... 7 5.1 STAKEHOLDER CONSULTATION/COMMUNICATION MANAGEMENT PLAN ...... 7 5.2 ECOLOGY MANAGEMENT PLAN ...... 8 5.3 GROUNDWATER MANAGEMENT PLAN ...... 9 5.4 SOCIO-ECONOMIC MANAGEMENT PLAN ...... 10 6 PARTIES RESPONSIBLE FOR THE IMPLEMENTATION OF THE EMP ...... 11 6.1 GENERAL MANAGER ...... 11 6.2 CONTRACTORS ...... 11 6.3 EXTERNAL SPECIALISTS ...... 11 7 MONITORING AND AUDITING ...... 12 7.1 MONITORING ...... 12 7.2 AUDITING COMPLIANCE OF THE EMP ...... 13 8 CONSULTANT EXPERIENCE AND DECLARATION OF INDEPENDENCE ...... 14

LIST OF TABLES TABLE 1: CONTENT OF THE EMP ...... 2 TABLE 2: RELEVANT LEGISLATION AND POLICIES...... 3 TABLE 3: LIST OF PERMITS OR CERTIFICATES THAT MAY BE REQUIRED ...... 3 TABLE 4: CURRENT WATER SUPPLY AND PROPOSED WATER ABSTRACTION AMENDMENTS ...... 4 TABLE 5: ACTIONS RELATING TO STAKEHOLDER COMMUNICATION ...... 7 TABLE 6: ACTIONS RELATING TO PROTECTION OF ECOLOGICAL SYSTEMS ...... 8 TABLE 7: ACTIONS RELATING TO PROTECTION OF GROUNDWATER ...... 9 TABLE 8: ACTIONS RELATING TO SOCIO-ECONOMIC CONDITIONS ...... 10

LIST OF FIGURES FIGURE 1: REGIONAL LOCATION OF THE TRISTONE IRRIGATION SCHEME ...... 1

LIST OF APPENDICES APPENDIX A: CONSULTANT EXPERIENCE AND DECLARATION OF INDEPENDENCE ...... ERROR! BOOKMARK NOT DEFINED.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

ACRONYMS AND ABBREVIATIONS

Acronym / Definition Abbreviation EAPAN Environmental Assessment Professionals of Namibia ECC Environmental Clearance Certificate EIA Environmental Impact Assessment EMP Environmental Management Plan DAE Division of Agricultural Engineering GAP Good Agriculture Practice MAWF Ministry of Agriculture, Water and Forestry MET Ministry of Environment and Tourism

iii

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

1 INTRODUCTION

1.1 INTRODUCTION TO THIS REPORT

Tristone Business Trust (TBT) has been operating an irrigation scheme since 2005. The irrigation scheme is located ±40km south east of Stampriet, in the Hardap Region (Figure 1) and covers a total area of 38 855 hectares (ha). Given that the land has already been cleared, this EMP focuses on the operational phase of the project.

A Scoping (including impact assessment) Report has been produced by SLR Environmental Consulting (Namibia) (Pty) Ltd (SLR) to cater for the potential environmental issues associated with the project. This Environmental Management Plan (EMP) documents a series of management plans (MPs) which are designed to meet legal requirements as well as avoid, minimise or mitigate the impacts associated with the proposed Irrigation Scheme Expansion Project. The EMP gives the commitments, which form the ‘environmental contract’ between TBT and the Government of the Republic of Namibia; represented by the Ministry of Environment and Tourism (MET).

FIGURE 1: REGIONAL LOCATION OF THE TRISTONE IRRIGATION SCHEME

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

1.2 DETAILS OF THE PERSONS WHO PREPARED THIS EMP

SLR Environmental Consulting (Namibia) (Pty) Ltd (SLR) is the independent Environmental Assessment Practitioner (EAP) who undertook the EIA process and compiled this EMP.

Gerhard Jacobs, the Project Manager has three years of relevant experience in Hydrogeology and has previously managed projects in the mining and agriculture industries, amongst other. Ester Gustavo, the project assistant and co-author has seven years’ experience in groundwater and surface water assessment and has previously managed projects in the mining, power and energy industries, while, Immanuel Katali, the project assistant and co-author has three years of experience in the Environmental Management discipline dealing with EIAs and EMPs. Immanuel is certified under the Environmental Assessment Professionals of Namibia (EAPAN). Alex Pheiffer, the Reviewer, holds a Master’s Degree in Environmental Management (from the Rand Afrikaans University) and has over 16 years of experience in a range of environmental disciplines, including EIAs, EMPs, Licensing, Environmental Auditing and Monitoring, Review and Public Consultation. She has expertise in a wide range of projects. She is certified under the Environmental Assessment Professionals of Namibia (EAPAN).

1.3 SCOPE OF THE EMP

Table 1 outlines the EMP requirements as set out in the Environmental Impact Assessment Regulations that were promulgated in February 2012 in terms of the Environmental Management Act, 7 of 2007.

TABLE 1: CONTENT OF THE EMP

EIA Regulation requirement EMP Reference Details of the persons who prepared the EMP and the expertise of those persons to Section 1.2 prepare an environmental management plan. Information on any proposed management or mitigation measures to address the Section 5 environmental impacts that have been identified in a report contemplated by these regulations, including environmental impacts or objectives in respect of – i. Operation or undertaking of the activity ii. Rehabilitation of the environment A detailed description of the aspects of the activity that are covered by the EMP. Section 3 An identification of the persons to be responsible for the implementation of the mitigation Section 6 measures. Where appropriate, time frames within which the measures contemplated in the EMP Section 5 must be implemented. Proposed mechanisms for monitoring compliance with the EMP and reporting on it. Section 7

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

2 RELEVANT LEGISLATION AND POLICIES

2.1 INTRODUCTION

In the context of the proposed irrigation project, there are several laws and policies currently applicable. These are reflected in Table 2.

TABLE 2: RELEVANT LEGISLATION AND POLICIES

Year Name Current Namibian legislation & Bills 1990 The Constitution of the Republic of Namibia of 1990 1997 Namibian Water Corporation Act, No. 12 of 1997 2003 Pollution control and waste management bill, 2004 2003 Agricultural (Commercial) Land Reform Amendment Act of 2003 2013 Water Resources Management Act, 2013 2007 Environmental Management Act No. 7 of 2007 2013 Water Resources Management Act, (Act No. 11 of 2013) Former South African and SWA legislation still applicable in Namibia 1919 Public Health Act No. 36 of 1919 1956 Water Act No. 54 of 1956 1969 Soil Conservation Act No. 76 of 1969 1974 Hazardous Substances Ordinance No. 14 of 1974 Namibian policy 1995 Namibia's Environmental Assessment Policy for Sustainable Development and Environmental Conservation 1995 National Agricultural Policy 2000 National Water Policy White Paper 2008 Green Scheme Policy International law to which Namibia is a signatory 1989 The Rotterdam convention on the Prior Informed Consent Procedure for Certain Hazardous chemicals and Pesticides in International Trade

2.2 PERMITS AND APPROVALS

Permits and approvals required for the project are outlined in Table 3 below.

TABLE 3: LIST OF PERMITS OR CERTIFICATES THAT MAY BE REQUIRED Permit name Regulator Environmental clearance for EIA and EMP MET Water abstraction permit (NamWater) Ministry of Agriculture, Water and Forestry (MAWF)

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

3 PROJECT OVERVIEW

The existing irrigation scheme is on commercial land with existing associated infrastructure. Existing infrastructure comprises boreholes, pipelines, tanks, on-field irrigation systems, plantations, a logistics centre and accommodation. No infrastructure exists on the new Steyn’s Halt farm portion.

The proposed project includes the following activities:  Proposed expansion of the irrigation scheme to include an 8th farm portion namely Portion A, Steyn’s Halt of the farm De Duine (198) (Steyn’s Halt), covering a total area of 5100 ha and with three existing boreholes  Proposed renewal of groundwater abstraction Permits 10 450; 10 472; 10 423; 10 475; 11 151; 11 116; and 11 159  Proposed amendment of the permitted groundwater abstraction quotas from 970 000 m³/annum to 1 800 000m³/annum inclusive of 210 000 m³/annum from a new borehole to be drilled on Steyn’s Halt.

The main operational components of the proposed project include:  A new borehole to be established on Steyn’s Halt equipped with an irrigation pump station.  A standalone system on Steyn’s Halt  A Centre Pivot Irrigation system covering approximately 15 ha in total  Extension of the existing electrical distribution network to include Steyn’s Halt

To support the administrative activities of the irrigation scheme, the irrigation scheme includes a Logistics Center which includes:  an office  chemical store and mixing facility used to store all pesticides, herbicides, fungicides and fertilizer as well as related hazardous waste – this is a controlled facility with fire suppression, emergency showers, and containment measures  above ground diesel facility for storage, handling and refuelling vehicles and machinery – the storage tanks have a maximum capacity of 2500 litres each.

The above facilities would also support the activities on the new Steyn’s Halt. Given that no new employees are required existing accommodation will be used. An existing empty house is located on the Steyn’s Halt portion. There is currently no plan to make use of this facility.

In terms of water supply, Table 4 summarises the existing and proposed abstraction volumes including the volumes required for Steyn’s Halt.

TABLE 4: CURRENT WATER SUPPLY AND PROPOSED WATER ABSTRACTION AMENDMENTS

Farms Permit No & Borehole Existing Proposed Quota (m³/a) amendment (m³/a) Dikbos (Eerstbegin) (197/1) PN: 10 423, WW 32118 and WW 40316 190 000 250 000 Witpan (De Duine) (198B) PN: 10 475, WW 727 and WW 41056 220 000 250 000

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

Hartebeestloop (202) PN: 10 450, WW 37690 80 000 120 000 Hartebeestloop (202/1) PN: 10 472, WW 37688 140 000 220 000 Oserikare (Breedestraat) (204) PN: 11 115, WW 204028 150 000 250 000 Okongona (203) PN: 11 116, WW 203986 100 000 250 000 Grunfeld (Fricourt) (199) PN: 11 159, WW 203984 100 000 250 000 Steyn’s Halt of farm De Duine New - 210 000 Total 970 000 1 800 000

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

4 OVERALL ENVIRONMENTAL OBJECTIVES FOR THE EMP

The following overall environmental objectives have been set for the proposed Irrigation Scheme Expansion Project:  To comply with national legislation and standards for the protection of the environment  To keep surrounding communities informed of irrigation activities through the implementation of forums for communication and constructive dialogue  To ensure the legal and appropriate management and disposal of general and hazardous waste, through the implementation of a strategy for the minimisation, recycling, management, temporary storage and removal of waste  To undertake rehabilitation wherever possible during the life of the irrigation project;  To develop, implement and manage monitoring systems to ensure good environmental performance in respect of groundwater  To support and encourage environmental awareness and responsibility amongst all employees and service providers  To provide appropriate environmental education and training for all employees and service providers  To prevent pollution and clean up if incidents occur  To comply with the requirements of this EMP.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

5 MANAGEMENT PLANS

The management plans (MPs) presented below are applicable to the proposed Irrigation Scheme Expansion Project. The MPs cater for:  Stakeholder Consultation/Communication  Biodiversity  Groundwater  Socio-economic.

5.1 STAKEHOLDER CONSULTATION/COMMUNICATION MANAGEMENT PLAN

It is important that channels of communication are maintained over the life of the project for surrounding landowners and other relevant stakeholders. Section 5.1 shows the stakeholders’ communication management plan.

Objectives To ensure that regular communication is provided on the relevant irrigation activities, together with feedback on the environmental management performance of the irrigation scheme and that opportunity is provided for interested and affected parties to continue to raise comments and concerns (complaints) on the same.

Actions Actions to be implemented are outlined in the table below.

TABLE 5: ACTIONS RELATING TO STAKEHOLDER COMMUNICATION

No Issue Management commitment These commitments apply to operational phase of the irrigation project 1 Understanding Maintain and update the TBT stakeholder register. Ensure that all relevant who the stakeholder groups are included. 2 stakeholders are Record partnerships with local suppliers and investors as well as their roles, responsibilities, capacity and contribution to development. 3 Liaison with Devise and implement an appropriate stakeholder communication and interested and engagement strategy. affected parties 4 Cooperative Use appropriate communication channels to consult with, and disseminate working information to, the identified stakeholder groups, where required relationship with stakeholders 5 Managing Develop and implement a concerns/complaints (grievance) process for perceptions, issues stakeholders. and/or complaints  Document complaints in an external communications register  Acknowledge receipt of complaints and comments  Investigate and report on findings of issue to the complainant  Keep complete records of complaints, responses and actions taken.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

5.2 ECOLOGY MANAGEMENT PLAN

The commitments derived from the Scoping Report with regards to ecological management forms the basis of this MP.

Objectives  Responsible use of pesticides.  Minimise the generation of dust.  Prevent degradation of ecological systems.

Actions Actions to be implemented are outlined in the table below.

TABLE 6: ACTIONS RELATING TO PROTECTION OF ECOLOGICAL SYSTEMS

No Issue Management commitment These commitments apply to operational phase of the irrigation project 1 Pesticide use Chemicals should not be used as the main form of pesticide control; use should form part of an integrated pest management (IPM) approach. IPM is an approach to pest management that blends all available management techniques - nonchemical and chemical - into one strategy. Use pesticides only when pest damage exceeds an economic or aesthetic threshold. 2 Bio-degradable and / or environmentally acceptable chemicals and pesticides will be used as far as possible. 3 TBT will follow international standards of best practice in the use of pesticides in agriculture. This will include:  Select and use chemicals with low toxicity outside target groups (i.e. highly specific), short half-lives and high levels of adsorption to reduce leaching issues.  The eco-toxicity of each chemical will be confirmed using an independent database such as the Pesticide Action Network (PAN) Pesticide Database.  Use optimal, not maximal doses  Apply herbicides and fungicides with boom sprayers or during planting  Apply for as short periods as possible and select days that are not windy  Ensure that there is no overspray that drifts into the adjacent indigenous habitats or into areas of human habitation. 4 Given that most of the chemicals will be applied through the irrigation system, using an optimal water management approach based on measured soil moisture levels will also mean that leaching and runoff will be limited. 5 Strictly control and allow for direct application of herbicides to minimise effects on native ecosystems. 6 Dust Avoid as far as possible ploughing if the soil is dry and/or if there are high winds generation (exceeding 24 km/h). Planting should occur shortly after ploughing. 7 Do not till on fallow and bare ground when average wind speeds exceed 40 km/h. 8 Cover piles of fertilizer, compost, or soil. Use surface coverings like wood chips, mulch, or plastic sheeting to help stabilize soil. 9 Use cover crops like grasses and legumes to help reduce wind erosion. 10 Use physical barriers such as fences, straw bales, large trees to minimize flow of dust. 11 Carry out visual dust monitoring and use water or dust suppressants when substantial dust is blowing offsite. 12 Avifauna Make the top-most lines on all types of electrical lines visible to birds.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

5.3 GROUNDWATER MANAGEMENT PLAN

The commitments derived from the Scoping Report with regards to groundwater management forms the basis of this MP. This plan covers both groundwater quantity and quality.

Objectives  Reduce concentration of contaminants in irrigation water to prevent pollution of underlying aquifer  To reduce the threat of lowering groundwater levels in the local aquifer which consequently infringes on the volume available for surrounding water users.  To prevent the dewatering of the aquifer.

Actions Actions to be implemented are outlined in the table below.

TABLE 7: ACTIONS RELATING TO PROTECTION OF GROUNDWATER

No Issue Management commitment These commitments apply to operational phase of the irrigation project 1 Groundwater The irrigation scheme will comply with the GAP codes and standards. 2 quality With regards to the storage and handling of pesticides, TBT will:  Provide appropriate storage on-site (well-marked, closed and covered storage area(s), on impermeable substrate and with containment measures that can contain 110% of the total volume stored).  Regular monitoring and maintenance of storage facilities for early detection of any potential leakages.  Mixing or handling of materials within designated areas to minimise unnecessary spills to the environment.  Immediate clean-up of any accidental spills.  Disposal of used containers and waste packaging in a suitable and approved manner. 3 Groundwater With regards to the storage, handling and use of hydrocarbons, TBT will: quality  Provide appropriate storage on-site (well-marked, closed and covered storage area(s), on an impermeable substrate and with containment measures that can contain 110% of the total volume stored).  Regular monitoring and maintenance of storage facilities for early detection of any potential leakages.  Handling of hydrocarbons and maintenance of equipment and machinery within designated areas with containment measures to minimise unnecessary spills to the environment.  Immediate clean-up of any accidental spills.  Disposal of used containers and waste packaging in a suitable and approved manner. 4 Crops that are adapted to the climate and soil conditions and that do not require excessive volumes of pesticides and fertilizers will be planted. 5 An optimal water management plan that records and controls the volumes of water used, measures soil moisture levels to limit leaching, and includes efficient irrigation methods will be implemented. 6 High sodium levels at Osirekare, Okongona and Grunfelde can cause salinization and crust formation on the irrigated lands. Gypsum should be considered to mitigate these effects.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

No Issue Management commitment 7 Special management for salinity control may be required. A 90% relative yield of moderately salt tolerant crops can be maintained by using a low frequency irrigation system. 8 Groundwater Abstraction permits must be obtained from DWAF and conditions of the permit which quantity include installation of water meters, maintenance of equipment to prevent leakages and monthly water level readings must be adhered to and documented. 9 Permits must be renewed every two years supported by an updated impact assessment by a hydrogeologist.

5.4 SOCIO-ECONOMIC MANAGEMENT PLAN

The commitments derived from the Scoping Report with regards to groundwater management forms the basis of this MP. This plan covers both groundwater quantity and quality.

Objective  To enhance the positive socio-economic impacts

Actions Actions to be implemented are outlined in the table below.

TABLE 8: ACTIONS RELATING TO SOCIO-ECONOMIC CONDITIONS

No Issue Management commitment These commitments apply to operational phase of the irrigation project 1 Enhancing positive TBT will ensure that the irrigation scheme is operated in a manner that ensures impacts the sustainable use of resources while maximising the production potential and economic value of the scheme. 2 Local labour will be used and on-going skills training will be undertaken.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

6 PARTIES RESPONSIBLE FOR THE IMPLEMENTATION OF THE EMP

This section describes the roles and responsibilities for implementing the various management plans.

6.1 GENERAL MANAGER

The General Manager has overall responsibility for environmental management and for ensuring this EMP is implemented. The General Manager must ensure the Environmental Management Plan is included in all contracts and to ensure that contractors adhere to the conditions of the EMP.

Contract documents should consider the inclusion of penalties for non-conformance to the EMP, or to link the sign off of the Contract to a retainer clause.

The General Manager will be responsible for the following aspects related to compliance of this EMP:  Regular inspections and auditing compliance to this EMP and any other relevant legal requirements e.g. permits and authorisations  Conduct environmental awareness training during induction training and on an ad hoc basis thereafter  Conduct scheduled monitoring as outlined in Section 7 as well as any additional monitoring required by permit and authorisations issued to TBT by relevant authorities  Submit required information to relevant authorities such as reporting related to monitoring and with regard to compliance with the EMP, permit and relevant authorisations  Liaise with TBT Management and various external stakeholders such as authorities on environmental management (where required).

6.2 CONTRACTORS

All contractors and their sub-contractors and employees will be contractually required to comply with the various commitments in this EMP.

6.3 EXTERNAL SPECIALISTS

TBT may appoint external environmental specialists, as and when required, to assist with the implementation of certain commitments made in the various management plans. An independent auditor will also assess compliance against the EMP (see Section.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

7 MONITORING AND AUDITING

7.1 MONITORING

As a general approach, the monitoring procedures will comprise the following:  A formal procedure;  Appropriately calibrated equipment – regular inspections and calibration of equipment will be undertaken in line with the equipment calibration/validation procedure;  Where samples require analysis, they will be preserved according to laboratory specifications;  Where practical, an accredited, commercial laboratory will undertake sample analyses;  Parameters to be monitored can be identified in consultation with a specialist in the field and/or the relevant authority;  If necessary, following the initial monitoring results, certain parameters may be removed from the monitoring programme in consultation with a specialist and/or the relevant authority;  Monitoring data will be stored in a structured database;  Data will be interpreted and reports on trends in the data will be compiled on a quarterly basis; and  Both the data and the reports will be kept on record.

Monitoring boreholes (not used for pumping), intersecting both, the Kalahari and Auob aquifers, will be established downstream of the irrigation scheme, near the southern border of the site. If monitoring points become damaged or redundant then they can be replaced with new points.

Water samples from all production and monitoring boreholes will be taken annually and analysed for pesticides, fertilisers and hydrocarbons. The data will be analysed for trends and where required additional mitigation will be implemented in consultation with a specialist.

Water levels will be measured at monitoring boreholes on a monthly basis. The data will be used to determine changes in groundwater levels due to pumping from the irrigation scheme. The data will be analysed for trends and where required additional mitigation will be implemented in consultation with a specialist. The monitoring data must be submitted as part of the monthly reporting to DWAF.

Regular pump testing of active boreholes should be undertaken to confirm the aquifer capacity and sustainable long term abstraction rates.

A monitoring programme that caters for both the presence and abundance of different pests (fungi as well as invertebrates) and the effects of different management options will be implemented.

Monitor electrical lines regularly and install markers if there is any bird mortality.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

7.2 AUDITING COMPLIANCE OF THE EMP

The commitments contained in this EMP will, once an environmental clearance has been obtained, be TBT’s contractual agreement with the Namibian authorities for sound environmental management. All employees, contractors and sub-contractors and any visitors to site will be expected to comply with the commitments contained herein.

The Environmental Manager / Officer will conduct weekly inspections quarterly internal audits against the commitments in the EMP. The audit findings will be documented for both record keeping purposes and for informing continual improvement.

In addition, an independent professional will conduct an EMP performance assessment every six months. The EMP performance assessment will measure compliance with the provisions of the EMP and the adequacy of the EMP relative to the on-site activities.

As a minimum, the following documents will be submitted to the MET:  The bi-annual report required by the MET will be submitted every six months  Monitoring reports will be provided to MAWF as per the permit requirements.

Tristone Business Trust 733.20070.00001 PROPOSED IRRIGATION SCHEME EXPANSION PROJECT, STAMPRIET, HARDAP REGION March 2019

8 CONSULTANT EXPERIENCE AND DECLARATION OF INDEPENDENCE

SLR Environmental Consulting (Namibia) (Pty) Ltd (SLR) is the independent firm of consultants that has been appointed by TBT to undertake the EIA and related process.

The undersigned herewith declare that this report represents an independent, objective assessment of the environmental impacts associated with TBT’s Irrigation Expansion project in the Hardap Region of Namibia.

SLR has no vested interest in the proposed project other than fair payment for consulting services rendered as part of the EIA process.

Immanuel Katali Gerhard Jacobs Alex Pheiffer (Report Author) (Project Manager) (Project Reviewer)

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