ENVIRONMENTAL MANAGEMENT PLAN:
FOR ODILA LODGE WITHIN THE OHANGWENA REGION
Client: Consultant: Odila Lodge Investment (Pty) Ltd. Urban Dynamics Africa P O Box 13824 P O Box 20837 EENHANA WINDHOEK Namibia Namibia Submission: Reference: 1161 Enquiries: Heidri Bindemann-Nel Ministry of Environment and Tourism
Private Bag 13306 WINDHOEK Tel: +264-61-240300 Fax: +264-61-240309 Namibia
APRIL 2019 ENVIRONMENTAL MANAGEMENT PLAN
TABLE OF CONTENTS
1 INTRODUCTION ...... 1
2 RESPONSIBILITIES ...... 2
2.1 Lodge Operations ...... 2
2.1.1 Key role players ...... 2
3 RELEVANT LEGISLATION ...... 3
4 BACKGROUND ...... 4
4.1 LODGE FACILITIES ...... 6
4.2 TOPOGRAPHY ...... 7
4.3 INFRASTRUCTURE ...... 7
4.3.1 Sewerage System: ...... 7
4.3.2 Waste Management: ...... 7
4.3.3 Water Supply Systems: ...... 7
4.3.4 Electrical Supply: ...... 7
4.3.5 Access and Circulation: ...... 7
5 OPERATIONAL MITIGATION DETAILS ...... 8
5.1 PLANNING COMPONENT 1: WASTE MANAGEMENT ...... 9
5.1.1 General Waste ...... 9
5.1.2 Sewerage Waste ...... 9
5.2 PLANNING COMPONENT 2: HAZARDOUS SUBSTANCES ...... 10
5.2.1 Storage of Hazardous Substances: ...... 10
5.2.2 General Preventive Measures: ...... 10
5.2.3 Safety Data Sheets ...... 11
5.3 PLANNING COMPONENT 3: HEALTH AND SAFETY ...... 11
5.3.1 Emergency Prevention ...... 11
5.3.2 Fire System ...... 11
5.3.3 First Aid ...... 12
5.3.4 Emergency Site Notices ...... 12
ENVIRONMENTAL MANAGEMENT PLAN
5.4 PLANNING COMPONENT 4: NOISE ...... 12
5.4.1 Noise Control ...... 12
5.5 PLANNING COMPONENT 5: ENVIRONMENTAL TRAINING AND AWARENESS ...... 13
5.6 PLANNING COMPONENT 6: ENVIRONMENTAL CONSERVATION ...... 13
5.6.1 Conservation of Vegetation ...... 13
5.7 PLANNING COMPONENT 7: EMPLOYMENT/RECRUITMENT ...... 14
5.7.1 Recruitment ...... 14
5.7.2 Legislation ...... 14
LIST OF TABLES
TABLE 1: PERMIT REQUIREMENTS ...... 3 TABLE 2: ODILA LODGE FACILITIES ...... 6 TABLE 3: GENERIC AND SITE-SPECIFIC ENVIRONMENTAL MANAGEMENT ACTIONS ...... 8
ENVIRONMENTAL MANAGEMENT PLAN
1 INTRODUCTION
Odila Lodge Investment (Pty) Ltd. is operating a lodge, which comprises of 20 guest rooms, 10 bungalows, and 15 camping sites within the Ohangwena Region.
The lodge provides accommodation to tourists that are travelling through the Ohangwena region towards the Omusati or Kavango regions. Figure 1 shows the location of the Ohangwena Region in relation to the Omusati, Kunene, Otjozondjupa, Oshana and Kavango Regions.
However, operation requires a set of management measures laid out in the form of an Environmental Management Plan (EMP) to guide the management of the lodge in a sustainable manner.
Figure 1: The Locality of Odila Lodge in Relation to the Surrounding Regions
ODILA LODGE
As part of this legal permit process, an EMP has been drafted as part of the environmental scoping process.
An EMP is one of the most important products of an Environmental Assessment (EA) process. An EMP synthesises all recommended mitigation and monitoring measures, laid out according to the various stages of a project life cycle, with clearly defined follow-up actions and responsibility assigned to specific actors. This EMP has been drafted in accordance with the Namibian Environmental Management Act (No. 7 of 2007) and Environmental Impact Assessment Regulations (2012). This plan describes the mitigation and monitoring measures to be implemented during the Operational phase of Odila Lodge.
Since Odila Lodge has been in existence since 2013 this report focuses on the measures required to ensure that the operation is environmentally sustainable.
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2 RESPONSIBILITIES
This section of the EMP provides specifics environmental actions, procedures, and responsibilities as required for this phase of Odila Lodge operations.
2.1 Lodge Operations
2.1.1 Key role players
Each role player’s responsibilities are described below.
Lodge Owner
The Owner is ultimately accountable for ensuring compliance with the EMP and conditions contained in the EMP.
Lodge Manager
The Lodge Manager has the overall responsibility for managing the lodge and ensuring that the environmental management requirements are met. All decisions regarding environmental procedures must be approved by the Lodge Manager. The Lodge Manager has the authority to stop any operational activity infringing on the EMP.
The Lodge Manager will manage the day to day on-site implementation of the environmental specification during the operational phase.
Environmental Control Officer (ECO)
The Lodge Manager will function as the ECO. If the ECO has no training in occupational safety and health on a lodge site, they should be sent for such training. The ECO is the owner on-site representative primarily responsible for the monitoring and review of on-site environmental management and implementation of the EMP.
The ECO’s duties include the following:
Ensure that the necessary legal authorisations have been obtained;
Monthly site inspection of the lodge areas with regard to compliance with this EMP;
Monitor and verify adherence to the EMP (audit the implementation of the EMP) and verify that environmental impacts are kept to a minimum;
Taking appropriate action if the specifications for the EMP are not adhered to;
Find environmentally responsible solutions to problems;
Training of all personnel with regard to the mitigation measures of this EMP and continually promoting awareness of these; Prepared by Urban Dynamics Africa 2 ENVIRONMENTAL MANAGEMENT PLAN
Ensure that all personnel shall received adequate environmental awareness training (see Plan Component 4) and that all workers and newcomers receive an induction presentation on the importance and implications of this EMP. The presentation shall be conducted, as far as is possible, in the employees' language of choice;
Monthly inspection to verify if new personnel have received appropriate environmental, health and safety training and training those who have not;
Advising on the removal of person(s) and/or equipment not complying with the specifications of the EMP ,
Recommending the issuing of fines for transgressions of lodge rules and penalties for contraventions of the EMP; and
Undertaking a 3-years review of the EMP and recommending additions and/or changes to the document if practical or necessary.
3 RELEVANT LEGISLATION
Table 1: Permit Requirements
THEME LEGISLATION INSTRUMENT MANAGEMENT REQUIREMENTS
NATIONALLY: The Constitution of the Republic The state shall actively promote and of Namibia of 1990 maintain the welfare of the people by adopting, inter-alia, policies aimed at the following:
(i) management of ecosystems, essential ecological processes and biological diversity of Namibia and utilization of living natural resources on a sustainable basis for the benefit of all.
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ENVIRONMENTAL: Environmental Management Act. Applicant must adhere to all applicable 7 of 2007 provision of the Environmental Management Act, EIA Regulations and EIA Regulations (EIAR) GN the Pollution Control and Waste 57/2007 (GG 3812) Management Bill regarding waste management.
Applicant need to option an Environmental Clearance Certificate from the Ministry of Environmental and Tourism.
AUTHORITY: Applicant need to have approval Traditional Authorities Act. 25 of 2000 from the Traditional Authority.
The applicant needs to obtain a FORESTRY: Forest Act. 12 of 2001 permit from the Ministry of Agriculture, Water and Forestry for the removal of protected tree species and any vegetation within 100m from a watercourse.
LABOUR: Health and Safety Regulations Applicant must adhere to all (HSR) GN 156/1997 (GG 1617) applicable provisions of the Labour Act and the Health and Safety Labour Act. 11 of 2007 regulations.
HEALTH AND SAFETY: General Health Regulations (GN Applicant need to obtain a 121 of 14 October 1969 as “Certificate of Fitness” from the amended Ministry of Health and Social Services.
4 BACKGROUND
Odila Lodge is a private lodge owned and managed by Odila Lodge Investment (Pty) Ltd. Odila Lodge is located at atitude ’ ” and ongitude ’ 4” E, situated about 0 km west from Eenhana, off the C 45 main road. The lodge is located within the Ondobe Constituency in the Ohangwena Region. Figure 2 shows the locality of Odila Lodge in relation to Eenhana. The lodge falls under the jurisdiction of the Ohangwena Regional Council and that of the Oukwanyama Traditional Authority. Odila Lodge Investment (Pty) Ltd. obtained approval to operate as a lodge from the Traditional Authority in July 2009.
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The lodge site covered approximately 17.8 ha. However, the actual footprint of the lodge is smaller. The nearest homestead is situated approximated 700 meters from the lodge. The area on which the lodge is located is shown in Figure 3.
Figure 2: The Locality of Odila Lodge in Relation to Eenhana
’ 4” E ’ ”
Figure 3: The Locality of Odila Lodge in Relation to the Site
’ 4” E ’ ”
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4.1 LODGE FACILITIES
The lodge comprises of 20 guest rooms, 10 bungalows, and 15 camping sites. Table 2 shows all the facilities. The guestrooms can accommodate up to 40 tourist beds, the bungalows up to 20 tourist beds, while the camping sits accommodate a maximum of 50 persons.
Table 2: Odila Lodge facilities
FACILITIES ODILA LODGE 20 rooms Number of rooms with all en-suite 10 bungalows Campsites 15 campsites Restaurant Yes Kitchen Yes Gas cylinder for cooking Yes Refrigeration units Yes Air conditioning Yes Laundry Yes NamWater water supply Yes Water treatment plant (Sewage treatment plant) Yes Backup generator Yes Swimming pool Yes Gardens Yes Waste area Yes Storage yard Yes Fire extinguishers Yes Fireplace Yes
Figure 4: Odila Lodge
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4.2 TOPOGRAPHY
The lodge is situated on a flat area with sandy soil and is covered with Mopani trees. The site and surrounding areas are not prone to flooding.
4.3 INFRASTRUCTURE
4.3.1 Sewerage System:
Odila Lodge’s sewerage system links all the toilets with a gravity flow system. The effluent is taken to a closed oxidation dam, where it is treated using microorganisms called EM Bokashi.
This system treats water for re-use and the lodge reuse the water for the trees. The effluents are decomposed and dried to same level as ash and can be removed.
4.3.2 Waste Management:
Odila Lodge make use of a relatively organized waste management system which comprises of composting their organic waste and collecting recyclables on site in dedicated drums. When the drums are full the waste is transported 10 km to the Eenhana’s local authority waste disposal site, where individuals in the community recycle products. The lodge also provides selected beer and wine glass bottles to a local entrepreneur who comes and collects it for the distillers in Oshakati.
4.3.3 Water Supply Systems:
The main source of water for the lodge is through the Directorate of Rural Water Supply and Sanitation Coordination Pipeline. The lodge pays a monthly bill to NamWater for this water usage hence is used wisely in order to cut utility cost. Water is stored within elevated tanks on the lodge premises.
During the rain seasons, the lodge harvests rainwater, which is used to flush toilets and to water the garden and trees when needed.
4.3.4 Electrical Supply:
The lodge is supplied from the NORED distribution network.
4.3.5 Access and Circulation:
The Odila Lodge is accessed via the C 45 between Oshakati and Eenhana and is well marked. There is only one entrance into the property, which ensures security. There are also marked parking bays for both guest and day visitors. Traffic is never very heavy on the main road to Eenhana, making the impact of guests travelling to the lodge low.
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5 OPERATIONAL MITIGATION DETAILS
Table 4 provides a scaled overview of all the major environmental management themes pertaining to both generic and site-specific operational mitigation details. This table serves to act as a quick reference, for the detailed mitigation details that follow subsequently for each theme. This is done to simplify the implementation of the operational component of this EMP.
Table 3: Generic and site-specific Environmental Management Actions
THEME OBJECTIVE MITIGATION DETAIL
GENERIC SITE-SPECIFIC
WASTE MANAGEMENT Minimise and avoid all pollution PLAN YES associated with the operation of a COMPONENT 1 lodge.
HAZARDOUS Minimise and avoid all pollution PLAN YES SUBSTANCES associated with the hazardous COMPONENT 2 substances.
HEALTH AND SAFETY Focusing on the wellbeing of the PLAN YES guest, staff and the community COMPONENT 3 near the lodge.
NOISE Minimise and avoid all noise PLAN YES associated with a lodge. COMPONENT 4
ENVIRONMENTAL Awareness creation regarding the PLAN YES TRAINING provisions of the EMP as well as COMPONENT 5 AND AWARENESS the importance of safeguarding environmental resources.
ENVIRONMENTAL Protect the natural environment in PLAN YES CONSERVATION which the lodge is situated. COMPONENT 6
EMPLOYMENT/ Minimise conflict through legal and PLAN YES RECRUITMENT fair recruitment practices. COMPONENT 7
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5.1 PLANNING COMPONENT 1: WASTE MANAGEMENT
Minimizing operational waste needs to be performed on a daily basis. Solid waste is the expected major source of waste at the operation phase of the lodge and therefore a Waste Management Plan is necessary. Being a small and simple operation, the following should guide waste management action at the lodge.
5.1.1 General Waste
The lodge should be kept tidy at all times. All general waste produced should be cleaned and contained daily.
No waste may be buried or burned.
No waste may be dumped in any watercourse in and around the project area.
Lodge personnel should be sensitised to dispose of waste in a responsible manner and not to litter.
A sufficient number of separate waste containers (bins) domestic/general waste must be provided on site. These should be clearly marked as such.
The general waste need to be sorted according to recyclables and organic waste.
Selected bottles for the distillers need to be sorted and place in separated containers from which it needs to be collected when full.
When the bins are full the waste needs to be transported to Eenhana’s local authority waste disposal site.
Organic waste will be placed on a allocated compost site.
5.1.2 Sewerage Waste
Sewerage waste water shall be treated and used to water trees.
Decomposed dried effluents shall be removed and place on the compost site.
No sewerage waste shall be used for food production.
The timeframe of the above-mentioned actions are continuous and the responsibility lies with the Odila Lodge Manager.
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5.2 PLANNING COMPONENT 2: HAZARDOUS SUBSTANCES
Although, it is unlikely that any significant hazardous substance will be used and stored at the lodge a Hazardous Substance Management Plan, must address measures for the uses and storage of chemicals and hazardous products at the lodge, as indicated in the Labour Act:
5.2.1 Storage of Hazardous Substances:
Hazardous substances shall at any time be stored in such a manner that they do not create a risk to the health and safety of employees or other persons, or any risk of contamination of the environment, due to seeping, leaking, fire or accidental release.
Areas designated for storage of hazardous substances shall be isolated from other activities and be clearly marked with appropriate warning signs.
Smoking, eating and drinking shall be prohibited in areas contemplated and, as far as possible, only authorised persons shall enter such areas.
Substances which by means of a reacting with each other on contact can create a dangerous situation such as an explosion, a fire or the formation of a third hazardous substance, shall be stored and handled separately in such a manner that no unintentional contact can occur.
Hazardous substances shall be stored in such a way that they are not exposed to heat, radiation or moisture which can give rise to an increased risk of a dangerous situation referred to in sub-regulation.
Hazardous substances which during storage can give rise to contamination of the work environment, shall, as far as reasonably practicable, be stored in securely sealed containers to prevent contamination. Containers intended for storage of hazardous substances shall be constructed from such materials and be of such shape and strength, that they will not create a risk of contamination by such hazardous substances.
Hazardous substances shall not be stored in containers which by means of their appearance can be mistaken for containers containing harmless substances.
Inflammable and explosive substances shall be labelled, stored and handled taking into account the risks associated with such substances.
5.2.2 General Preventive Measures:
General preventive measures, including administrative and technical measures, shall, to the satisfaction of an inspector, be taken to prevent or reduce the contamination of the work
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environment to the lowest possible level, or, if appropriate, at least to the levels specified by the exposure limits established by these regulations.
Whenever possible, hazardous substances shall be replaced by harmless or less harmful substances.
Operations likely to result in contamination of the work environment by hazardous substances shall be isolated from the remainder of the premises so as to reduce the number of people exposed.
Only employees duly authorised by the manager concerned and, to the satisfaction of an inspector, adequately trained for such purpose, shall participate in operations concerning hazardous substances: Provided that the training of such employees shall be upgraded at adequate intervals.
5.2.3 Safety Data Sheets
The manager shall ensure that all containers containing hazardous substances, including pesticides, which are stored, handled or used at the workplace, whether temporarily or permanently, are properly labelled according to regulations pertaining to the classification, marking and labelling of hazardous substances.
The timeframe of the above-mentioned actions are continuous and the responsibility lies with the Odila Lodge Manager.
5.3 PLANNING COMPONENT 3: HEALTH AND SAFETY
The health and safety aspect is something that cannot be overemphasized; considering that a serious unexpected event can occur at any given moment. A safety representative needs to be identified.
5.3.1 Emergency Prevention
An emergency prevention plan is to be provided in the lodge through good design, operation, maintenance, and inspections to reduce the probability of occurrence and consequential effect of eventualities.
The following aspects should be included at the Lodge:
5.3.2 Fire System
Portable fire extinguishers should be provided at specified locations as per the prevailing fire norms.
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5.3.3 First Aid
At least two employees of the lodge need to undertake training in first aid.
“first-aid kit” means a portable container which is –
(a) water and dust resistant; and
(b) stocked with adequate and unexpired medical supplies, equipment and remedies reasonably required for giving first aid treatment in any injury or other emergency situation, in particular situations likely to arise from the risks and dangers inherent to a particular activity offered by a regulated business.
5.3.4 Emergency Site Notices
A list of emergency numbers should be displayed prominently where employees can see it.
Police: (065) 264 247
Ambulance: 081 444 7807
Fire Brigade: (065) 264 300
Eenhana Clinic: (065) 263 064/23/25
A sign should be provide with the floor plan which shows the emergency exits and actions to be taken on identifying fire emergency signals are identified and explained.
A copy of the “certificate of fitness” issued by the relevant health authority shall be submitted with the application for registration.
The timeframe of the above-mentioned actions are continuous and responsibility lies with the Odila Lodge manager.
5.4 PLANNING COMPONENT 4: NOISE
The nearest homestead is about 700 m from the lodge buildings. Therefore, high priority will be placed on mitigation measures at the lodge site to manage noise. The following measure is provided below to minimise noise:
5.4.1 Noise Control
No playing of loud music after 24h00.
The timeframe of the above-mentioned actions are continuous and the responsibility lies with the Odila Lodge manager.
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5.5 PLANNING COMPONENT 5: ENVIRONMENTAL TRAINING AND AWARENESS
All lodge workers at Odila Lodge are to undergo environmental training and awareness programs. The following aspects should be included:
Explanation of the importance of complying with the EMP. Discussion of the potential environmental impacts of lodge activities. Employees’ roles and responsibilities, including emergency preparedness. Explanation of the mitigation measures that must be implemented when particular workgroups carry out their respective activities.
Explanation of the specific mitigation measures within this EMP especially unfamiliar provisions.
During the training sessions, an attendance register should be completed, including the names, positions designations and signatures of everyone who attended the training and kept on file for auditing purposes. Thereby, all the training sessions prior to it being conducted must be approved by the ECO.
The timeframe of the above-mentioned actions are yearly and the responsibility lies with the Odila Lodge Manager.
5.6 PLANNING COMPONENT 6: ENVIRONMENTAL CONSERVATION
The lodge site contains limited protected tree species. However, the owner wishes to keep the natural environment untouched. The following conservation measures should, therefore, be included:
5.6.1 Conservation of Vegetation
Any post-construction layout and building design submitted for constructing a building within the lodge boundaries should incorporate existing large indigenous trees. Thereby future contractors should compile a Tree Management Plan, which should include the following as content at minimum level:
As an initiative, trees with a trunk size of 250 mm and bigger should be surveyed, marked with paint and taken into consideration in the design of the servitudes and roads;
Trees with a trunk size of 250 mm and bigger, which are impossible to conserve, need to be identified and their location recorded on a map.
All trees, which are to be retained, are to be clearly indicated on a site plan and demarcated.
A permit from the Ministry of Agriculture, Water and Forestry is needed before any protected trees may be removed prior to development.
Trees can be obtained at the Eenhana forestry office or at a commercial nursery. The forestry officers can also direct to nearby nurseries where additional trees may be bought.
Select vegetation carefully to retain biodiversity.
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Plan gardens carefully to limit disturbance of pristine areas.
The timeframe of the above-mentioned actions is when operations start and annually. The responsibility lies with the Odila Lodge Manager.
5.7 PLANNING COMPONENT 7: EMPLOYMENT/RECRUITMENT
The formal recruitment process should be compiled and shall include the following minimum provisions:
5.7.1 Recruitment
A recruitment process whereby local residents shall be given preference shall be designed by the ECO and the Manager.
Ensure that all sub-contractors are aware of recommended recruitment procedures and discourage any recruitment of labour outside the agreed-upon process.
Contractors should give preference in terms of recruitment of sub-contractors and individual labourers to those from the project area and only then look to surrounding towns.
Clearly explain to all job-seekers the terms and conditions of their respective employment contract (e.g. period of employment, etc.) – make use of interpreters when required.
5.7.2 Legislation
The manager needs to adhere to the legal provisions in the Labour Act for the recruitment of labour (target percentages for gender balance, optimal use of local labour and ME’s, etc.) in the contract.
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