(ESA) Report for the Proposed Exploration and Mining of Dimension Stone on Mining Claims 71609 – 71617 in the Erongo Region

Environmental Scoping Assessment (ESA) Report for the Proposed Exploration and Mining of Dimension Stone on Mining Claims 71609 – 71617 in the Erongo Region

MEFT Application No.: 001763

Document Version: Final

Proponent: Okonde Mining and Exploration CC

Date: 23 November 2020

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

EXECUTIVE SUMMARY Okonde Mining and Exploration CC (hereinafter referred to as Okonde Mining and Exploration or the Proponent) with the assistance of their technical and financial partner, Best Cheer Investments Namibia (Pty) Ltd intends to undertake exploration and subsequent mining activities on their nine mining claims (MCs) northeast of Arandis Town in the Erongo Region (the project). The mining claims are 71609, 71610, 71611, 71612, 71613, 71614, 71615, 71616 and 71617. Although these MCs are in the same area, they are grouped into two sites (clusters). The two groups that are about 6 km apart comprise of MCs 71609, 71610, 71611, 71612, 71613 & 71614 (southern cluster about 38 km out of Arandis) and then MCs 71615, 71616 & 71617 (northern cluster, 45 km outside Arandis). The total (combined) surface area of the nine mining claims is 140 hectares (ha).

The proposed exploration and mining are however among the listed activities in the Environmental Management Act (EMA) No. 7 of 2007 and its 2012 Environmental Impact Assessment (EIA) Regulations that may not be undertaken without getting the environmental clearance certificate (ECC). Consequently, Okonde Mining and Exploration CC appointed OMAVI Geotechnical & Geo-Environmental Consultants CC (hereinafter referred to as OMAVI Consultants) to undertake the required EIA / Environmental Scoping Assessment process and apply for the project ECC.

It is for this reason, that this Environmental Scoping Assessment (ESA) Report was compiled. The Report contains all the information that was gathered from the environmental assessment process. The information contained herein include the description of the proposed project activities and alternatives, legal requirements, the pre-project environmental conditions, public consultation means, identified potential impacts, their assessment and provision of the necessary practical measures to manage avoid and or minimize each impact’ significance.

Public consultation and Impact (Key issues Raised)

First Round of Public Consultation (issues and concerns to the proposed project): Feedback

The first round of public consultation took place from the 17th of June to the 25th of July 2020. The main issues (negative impacts) that were raised during the first round of public consultation and as pre-identified by the Consultants are as follows:

• Physical disturbance of soils and land surface due to exploration and mining activities.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

• Soil and groundwater pollution from potential project waste.

• Impact on air quality (dust generation).

• Impacts on general roads/vehicular traffic (linked to the project activities).

• Impact on water quantity/aquifers (water demand and availability).

• Impacts on biodiversity (fauna and flora) to enable project activities and firewood for exploration camps.

• Potential increase in noise level from project activities.

• Impact on aesthetics (visual impact).

• Impact on archaeological or cultural heritage through uncovering and damaging of archaeological objects or sites from unintentional project activities such as drilling and excavation on selected explored and mined sites of the mining claims.

• An issue of site rehabilitation during and or after exploration and mining activities have ceased.

Other impacts identified by the OMAVI Consultants based on experience similar projects.

• Lack of proper liaison between project Proponent and farmers or occupiers of land.

• Impact on farm and surrounding services infrastructure such as roads, water, fences and gates, potential water pipelines damage by heavy trucks.

The positive impacts anticipated from the project are as listed below:

• Socio-economic development through employment creation and skills transfer

• Improved geological understanding of the site, regarding dimension stone (dolerite)

• Investment opportunities into the area due to the global sought-after commodity such as the explored and mined dimension stone (dolerite).

• Contribution towards national economy through the payment of taxes and royalties to the responsible institutions of the Government of the Republic of Namibia.

Second Round of Public Consultation (comments to the Draft ESA Report/Review): Feedback

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

The draft ESA Report with all its appendices was circulated to all registered I&APs for review and comments for a period of eleven (11) days, i.e. from 17 August 2020 to 27 August 2020. The Report circulation to all registered I&APs was done via emails, for those with access to email addresses and a hard copy for those without email access.

Feedback on the draft ESA Report review was received from two I&APs. A nine (9) page document containing thirty-five (35) comments (excluding the first two acknowledgment points) received from one I&AP and a letter with comments from the National Heritage Council of Namibia (NHC) – Appendix H. These comments have been recorded as received under Appendix I. The responses to these comments by OMAVI Consultants are also part of the Appendix I.

Recommendations and Conclusions

The aim of this environmental scoping assessment was to identify the potential impacts associated with the proposed exploration and mining activities on the nine mining claims, assess and recommend practical mitigation measures. The public was consulted as required by the EMA and its 2012 EIA Regulations (Section 21 to 24). The public was informed via the newspapers used for this assessment; site/public notices placed in the project site area, relevant local and regional offices notice boards. A one-on-one interaction (public meeting) was held with the public and a virtual meeting done with the national authorities. The interested and affected parties raised their comments and concerns on the proposed project activities. The concerns and comments received from the public and the local community members formed the basis for this report as well as the Draft EMP.

The conclusions reached and recommendations provided are presented below.

Recommendations

It is therefore recommended that an Environmental Clearance Certificate be issued for the proposed exploration and mining activities on mining claims 71609-71617, subject to the following recommendations:

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Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

• All required permits, licenses and approvals for the proposed activities should be obtained as required (please refer to the Permitting and Licensing Table in the Environmental Management Plan (Appendix A). These include permits and licenses for borehole drilling on farms, water abstraction & use permits, land/farm access agreements to explore and mine, etc. as well as ensuring compliance with these specific legal requirements.

• The Proponent complies with the legal requirements governing this type of project and its associated activities.

• All mitigations provided in this ESA Report and the management action plans in the EMP should be implemented and monitoring conducted as recommended.

• All the necessary environmental and social (occupational health and safety) precautions provided should be adhered to.

• Site areas where exploration and mining activities have ceased should be rehabilitated, as far as practicable, to their original state.

• The monitoring of the implementation of mitigation measures should be conducted, applicable impact’s actions taken, reporting done and recorded as recommended in the Draft EMP.

Conclusions

The potential (positive and negative) impacts stemming from the proposed exploration and mining activities were identified. The two impacts types were described, assessed and mitigation measures where provide (where necessary).

As main potential impacts of concern, the negative impacts were carefully described, assessed, and mitigation measures provided thereof to avoid and/or minimize their significance on the environment. These impacts were found to be of medium significance. The effective implementation of the recommended management actions (mitigation measures) will see the significance reduction in impacts (that cannot be avoided) from medium to low rating. Furthermore, to maintain the low rating, monitoring of the potential impacts by the Proponent (an Environmental Control Officer (ECO)) is highly recommended. Monitoring will not only be carried out to maintain the low rating of impacts' significance but to also ensure that all potential impacts identified in this study and other (new potential) impacts that might arise during project implementation are well identified in time, properly addressed and that suitable and adequate mitigation measures are provided and implemented.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Apart from the project information provided by the Proponent, the findings of the impact assessment conducted, i.e., concerns and comments received from the public, particularly the affected farm owners and neighboring property/farm owners also formed the basis of this assessment and eventual reporting. Therefore, based on these inputs, it can be concluded that that the proposed activities may be granted an Environmental Clearance Certificate. The ECC issuance will be on condition that the recommendations and impact mitigation measures in this report and all the provisions in the EMP are adhered to.

The findings of this scoping assessment were deemed sufficient and conclude that no further detailed assessments are required.

With that being done, the positive impacts of the project activities as indicated in the Report will be able to overweigh the negatives and ensure socio-economic development.

In conclusion, it is unlikely that the proposed project activities will have a high significant impact on the biophysical and social environments in the project area. Therefore, it is vital for the Proponent and their contractors (if any) to effectively implement and monitor the recommended management measures to protect both these environmental components. All these would be done with the aim of promoting environmental sustainability while ensuring a smooth and harmonious existence and purpose of the project activities in the hosting biophysical and social environment.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

TABLE OF CONTENTS EXECUTIVE SUMMARY ...... i TABLE OF CONTENTS ...... vi LIST OF FIGURES ...... viii LIST OF TABLES ...... ix LIST OF APPENDICES ...... x LIST OF ABBREVIATIONS ...... xi 1 INTRODUCTION ...... 1 1.1 Brief Project Background and Location ...... 3 1.2 The Mining Claims Ownership ...... 5 1.3 Project Need and Desirability ...... 6 1.4 The Need for the Environmental Scoping Assessment ...... 7 1.5 Purpose of the Environmental Scoping Report ...... 8 1.6 The Environmental Assessment Process ...... 8 1.7 Appointed Environmental Consultant...... 10 1.8 Limitations of the Study and Justifications ...... 11 2 PROJECT DESCRIPTION, ACTIVITIES AND PROCESSES ...... 12 2.1 Resource Inputs (Exploration and Mining) ...... 12 2.2 Exploration: Processes and Outputs ...... 15 2.2.1 Project Staff Accommodation and Equipment and Vehicles Storage ...... 15 2.2.2 Processes ...... 15 2.3 Proposed Exploration Methods (Technologies) ...... 16 2.3.1 Desktop study ...... 16 2.3.2 Field Evaluation ...... 16 2.3.3 Detailed exploration ...... 16 2.3.4 Feasibility Study ...... 17 2.4 Mining Phase: Project Inputs, Process and Outputs ...... 18 2.4.1 Project Staff Accommodation and Equipment and Vehicles Storage ...... 18 2.4.2 Mining Technology and Process ...... 18 2.4.3 Mining Output ...... 20 2.5 Rehabilitation of Mined Sites and Decommissioning ...... 21 2.6 Project Alternatives ...... 21 2.6.1 Limitations to the Project Alternatives ...... 22 2.6.2 Project Location Alternative ...... 22 2.6.3 Exploration and Mining (Quarrying) Methods and Technology ...... 23

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

2.6.4 Supporting Services Infrastructure...... 24 2.6.5 No-Go Alternative ...... 25 3 APPLICABLE LEGAL FRAMEWORK, POLICIES AND GUIDELINES ...... 26 3.1 National Legislation ...... 26 3.2 International Treaties and Conventions ...... 40 4 DESCRIPTION OF THE RECEIVING (BASELINE) ENVIRONMENT ...... 42 4.1 Biophysical Environment ...... 42 4.1.1 Climate ...... 42 4.1.2 Topography and Hydrology ...... 45 4.1.3 Soil and Geology ...... 46 4.1.4 Hydrology and Catchments ...... 49 4.1.5 Hydrogeology...... 49 4.1.6 Biodiversity: Fauna and Flora ...... 55 4.2 Social Environment ...... 59 4.2.1 Demographic Overview: Regional, Constituency and Local ...... 59 4.2.2 Economic Development ...... 59 4.2.3 Project Site Land Use ...... 60 4.2.4 Archaeology and Cultural Environment ...... 62 4.2.5 Services Infrastructure ...... 63 5 PUBLIC CONSULTATION PROCESS ...... 65 5.1 Registered Interested and Affected Parties (I&APs) ...... 65 5.2 First Round of Public Consultation: Summary of Activities Undertaken ...... 66 5.2.1 Consultation/Public Meetings ...... 66 5.2.2 Public Site Notices ...... 68 5.3 First Round of Public Consultation Feedback: Issues &Concerns ...... 70 5.4 Second Round of Public Consultation: Draft ESA Report Review ...... 71 6 IMPACT IDENTIFICATION AND ASSESSMENT ...... 71 6.1 Impact Identification ...... 72 6.2 Impact Assessment Methodology ...... 73 6.2.1 Impact Assessment Screening ...... 73 6.2.2 Impact Assessment Criteria ...... 74 6.2.3 Impact Significance ...... 76 6.3 Positive Impacts: Description and Assessment ...... 77 6.3.1 Socio-economic development (Employment and Social Responsibilities) ...... 77 6.3.2 Socio-economic development (Value Added Taxes and Royalty)...... 79

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Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

6.3.3 Improved geological understanding of the site ...... 79 6.3.4 Investment opportunities ...... 79 6.4 Negative Impacts: Description and Assessment ...... 80 6.4.1 Impact on Groundwater Quantity (Over-abstraction) ...... 80 6.4.2 Impact on Soils (Physical Land Disturbance) ...... 84 6.4.3 Soils and Water Resources Pollution ...... 84 6.4.4 Impact on Biodiversity (Fauna and Flora) ...... 88 6.4.5 Visual impact ...... 89 6.4.6 Noise ...... 91 6.4.7 Vehicular Traffic ...... 92 6.4.8 Impact on Surrounding Air Pollution (Dust) ...... 94 6.4.9 Impact of Poor Communication (Proper Liaison): Proponent and Landowners ...... 95 6.4.10 Impact on Farms and Surrounding services Infrastructure (roads, fence, and pipelines) ...... 96 6.4.11 Health and Safety ...... 96 6.4.12 Archaeological impact...... 98 6.4.13 Waste Generation ...... 100 6.4.14 Social Nuisance: Job seeking and Differing Norms, Culture and Values ...... 101 6.4.15 Social Nuisance: Property intrusion and Disturbance or Damage ...... 102 6.5 Cumulative Impacts ...... 102 6.6 Decommissioning (Cessation of Exploration and Mining Activities) ...... 104 6.6.1 Loss of Employment, Revenue and Royalties ...... 104 6.7 Site Rehabilitation ...... 105 6.7.1 Planning for Rehabilitation ...... 105 7 RECOMMENDATIONS AND CONCLUSIONS ...... 108 7.1 Recommendations ...... 108 7.2 Conclusions ...... 109 8 REFERENCES LIST ...... 111

LIST OF FIGURES Figure 1: Location of the mining claims (project site) near Arandis in the Erongo Region (Zoomed Out map) ...... 3 Figure 2: Location of the mining claims (project site) near Arandis in the Erongo Region (Zoomed-In map) ...... 4

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Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 3: Mining claim 71609 & 71617 on the Portal (link https://portals.landfolio.com/namibia/) 5 Figure 4: Schematic process flow of the Namibia’s Environmental Assessment Process ...... 10 Figure 5: A typical example of a Down-The-Hole drill rig ...... 17 Figure 6: The typical loosening of large volumes of the bedrock by means of primary cutting for large-scale mining operations of dimension stones ...... 19 Figure 7: The typical mining quarrying by diamond wire technology and front-end block loader 20 Figure 8: The maximum, minimum and average temperature Arandis area (source: World Weather Online, 2020) ...... 43 Figure 9: The spatial distribution of potential evaporation in Namibia (after BGR, 2005) ...... 44 Figure 10: The rainfall patterns for the Arandis area (source: World Weather Online, 2020) .... 45 Figure 11: Topography within the mining claims’ site boundary (photo: OMAVI Consultants, 2020) 46 Figure 12: Geological map of the project area ...... 48 Figure 13: Typical grading of topsoil on the flat plains adjacent to host rock koppies ...... 49 Figure 14: Hydrogeological map of Namibia with rock bodies groundwater potential with the approximate location of project site indicated by the light green arrow on the map...... 51 Figure 15: Location of the sampling points for the 2010 Khan-Swakop River Catchment groundwater quality assessment (edited after Kringel et al., 2010) ...... 53 Figure 16: Spatial distribution of Electrical Conductivity (EC) at the sampled area (Kringel, 2010) 54 Figure 17: Sparse vegetation on relatively flat land characteristic of the succulent dwarf shrubland (Left Photo) and the Dolerite outcrop shrubland (Right Photo) ...... 57 Figure 18: Dwarf succulent – small bushman grassland ...... 58 Figure 19: Some of the small livestock (goats and sheep) on the site farms ...... 61 Figure 20: The abandoned quarry site on Farm Hakskeen ...... 61 Figure 21: Mining Claims 71609-71617 on farms Sukses and Hakskeen (small polygons) shown in relation to previously known archaeological sites (green squares) and archaeological sites found during the present survey (red squares), source: Kinahan, 2020 ...... 63 Figure 22: Some photos taken at the public meeting at the farms on site ...... 68 Figure 23: Public notices at the Karibib and Daures Constituency Offices’ notice boards ...... 69 Figure 24: Some of the site notices at Farm Sukses (left) and Erongo Regional Council (right) 70 Figure 25: Screening process for determining key impacts (source: Resilient Environmental Solutions, 2019) ...... 74

LIST OF TABLES Table 1: Approximate GPS Coordinates of the Okonde Mining and Exploration mining claims 4 Table 2: The presentation of service infrastructure alternatives considered for the project ...... 24 Table 3: Applicable legislation, policies and guidelines to the proposed exploration and mining activities...... 28 Table 4: Summary of relevant acts and applicability thereof (in terms of licenses, authorisations and or permits) as listed in the 2012 EIA Regulations ...... 39 Table 5: International Treaties and Convention applicable to the project (after Resilient Environmental Solutions, 2019) ...... 40 Table 6: Details of consultation meetings held ...... 66

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Table 7: Impact Assessment Criteria employed for the OME exploration and mining activities 75 Table 8: Impact significance rating scale ...... 76 Table 9: Assessment of the project impact on water resources abstraction (quantity) ...... 81 Table 10: Impact assessment of project activities on soils (physical disturbance) ...... 84 Table 11: Assessment of the project impact on groundwater resources (quality) ...... 86 Table 12: impact assessment of project activities on biodiversity ...... 89 Table 13: Visual impact assessment ...... 90 Table 14: Noise impact assessment ...... 91 Table 15: Vehicular traffic impact assessment ...... 92 Table 16: Air quality impact assessment ...... 94 Table 17: Impact of poor communication between the Proponent and farm owners or occupies 95 Table 18: Assessment of impacts on local (farms) infrastructure ...... 96 Table 19: Health and Safety impact assessment ...... 97 Table 20: Archaeological impact assessment ...... 99 Table 21: Impact assessment of waste generation on the environment ...... 100 Table 22: Social impact assessment of outsiders’ influx into the area (job seeking related) ..... 101 Table 23: Social impact assessment of outsiders’ influx into the area (locals’ properties) ...... 102 Table 24: Impact assessment of project activities closure on employment ...... 104

LIST OF APPENDICES APPENDIX A: Draft Environmental Management Plan (EMP)

APPENDIX B: Curricula Vitae (CV’s) of the Responsible Environmental Assessment Practitioners (EAPs)

APPENDIX C: List of Registered Interested and Affected Parties (I&APs)

APPENDIX D: Newspaper adverts/notices for the Environmental Assessment Process

APPENDIX E: Consultation/Public Meetings’ Minutes

APPENDIX F: Original format of Issues, Concerns and Comments as Received from the I&APs

APPENDIX G: Desktop Hydrogeological (Groundwater) Impact Assessment Report

APPENDIX H: Original Copy of the Comments Received from the two I&APs on the Draft Scoping Report (Review) – Nagenoeg Investments: Gecko and National Heritage Council of Namibia

APPENDIX I: Comments and Response Trail for the Draft Scoping Report Review Feedback

APPENDIX J: Archaeological Assessment Report for Mining Claims 71609-71617

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

LIST OF ABBREVIATIONS BGR: Bundesanstalt für Geowissenschaften und Rohstoffe (The Federal Institute for Geosciences and Natural Resources of the Republic of Germany)

CC: Close Corporation

DEAF Department of Environmental Affairs and Forestry

DTH: Down-The-Hole drilling

DSMGMR Dimension Stone Mining Global Market Report

EA Environmental Assessment

EIA / ESA Environmental Impact Assessment / Environmental Scoping Assessment

EMP Environmental Management Plan

EMA Environmental Management Act

ECC Environmental Clearance Certificate

I&APs Interested and Affected Parties

IUCN International Union for Conservation of Nature

MC Mining Claim

MEAC Ministry of Education, Arts and Culture

MAWLR Ministry of Agriculture, Water & Land Reform

MEFT Ministry of Environment, Forestry and Tourism

MLIEC Ministry of Labour, Industrial Relations and Employment Creation

MME Ministry of Mines and Energy

MoHSS Ministry of Health and Social Services

MURD Ministry of Urban and Rural Development

MWT: Ministry of Works and Transport

NHC National Heritage Council of Namibia

OME Okonde Mining and Exploration cc

OGGC OMAVI Geotechnical and Geo-environmental Consultants cc

TA Traditional Authority

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

1 INTRODUCTION Mining is the backbone of the Namibian economy constituting about 9.3% contribution to Gross Domestic Product (GDP). About 52.7% of export-earnings from mining were recorded in the Chamber of Mines’ 2013 Annual Report. Other sectors contributing to the GDP include fisheries, agriculture, and tourism (Mweemba, 2014). Minerals extracted in Namibia range from diamonds, uranium, base metals (copper, lead, zinc, etc.), gold, industrial minerals (sand, limestone, and graphite), dimension stones (marble, dolerite) and semi-precious stones/gemstones. Some listed minerals and stones are either mined at a small, medium, or large-scale level, depending on the; ore deposit, specimen size sought after, available resources and geological extent, etc.

Dimension stone which the basis of this assessment and document, is a collective generic term used for various natural stones used for structural and decorative purposes in the construction industry. The dimension stone industry is relatively large in value when compared to non-fuel minerals, and consumption of natural stone is growing at a rate significantly higher than most mineral products, with a Compound Annual Growth Rate of about 0.8% anticipated in 2020 (Motloung and Ashmole, 2008, Cosi, 2015 and DSMGMR, 2020). According to the DSMGMR (2020), the dimension stone mining market is expected to reach a value of nearly US$5.22 billion by 2022, with growth largely being driven by increasing demand for high value natural stone in the construction and real estate sectors in China, India, and Eastern Europe.

According to Demarco et. al (2011), black dimension stones occupy a prominent place on the international market, with prices for these stones primarily driven by two aspects: the intensity of the black colour (the darker the stone, the more expensive it is) and the block size (the larger the block the more expensive it is). Classic examples of key structures where black dimension stone have been used are widely spread across the globe, demonstrating the widespread market availability for this product. A few key examples are listed below:

• The Dusseldorf Airport in Germany in which the Shanxi Black (dolerite) from northern China were used for the interior floor tiles. • The office of the Federal President in Berline in which the Impala Dark (gabbro/norite) where used for the building façade. • The masts of a footbridge in Bad Homburge which were constructed from Nero Assoluto (gabbro) from Zimbabwe. • The base façade of the Empire State Building which utilizes the Ebony Black (dolerite) from Sweden. • The entrance columns of the Antel Tower in Uruguay which are constructed from Uruguayan Black Absolute dolerite; and

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

• Many more structures across the globe.

Due to these industrial demands, exploration and mining companies pursue the exploration activities on prospective mining claims and or exploration prospecting licenses and upon confirming feasibility, mine/quarry the highly sought-after dimension stone, such as the black dimension stone (dolerite) for the global market. However, exploration and mining activities of these above-mentioned minerals groups are usually associated with both potential positive and negative (adverse) impacts on the biophysical and social environment. If these issues (adverse impacts) are not well understood prior to project implementation, to enable their timely avoidance or significance reduction, they can potentially harm some or both environmental components during and after the project lifecycle.

The potential impacts that stem from new projects or developments trigger an Environmental Impact Assessment (EIA) Study as stipulated in the Environmental Management Act No. 7 of 2007 and its 2012 EIA Regulations. These Regulations list certain activities that may not be undertaken without an Environmental Clearance Certificate (ECC) and these are as follows:

• ‘’3.1 The construction of facilities for any process or activities which requires a license, right of other forms of authorization, and the renewal of a license, right or other form of authorization, in terms of the Minerals (Prospecting and Mining Act, 1992). • 3.2 other forms of mining or extraction of any natural resources whether regulated by law or not. • 3.3 Resource extraction, manipulation, conservation, and related activities.’’

With every new project planned for in the natural and social environment, it is vital that all possible impacts on the environment are considered, how to prevent them and or minimize their significance (if avoidance is impossible) and come up with practical mitigation measures. All this is done to ensure that the projects and development activities run in an environmentally and socially manner to ensure sustainability, while maximizing the positive impacts (benefits) of the projects.

This document aims to confirm and assess potential environmental impacts associated with the proposed exploration and mining activities in the Erongo Region, inland of the west coastal side of Namibia. The main aims would also be to provide practical mitigation measures to avoid and/or minimize the significance of these impacts, where complete avoidance is impossible.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

1.1 Brief Project Background and Location In commitment to their line of operations and as one of the dimension stone exploration and mining companies in Namibia, Okonde Mining and Exploration CC (hereinafter referred to as OME or the Proponent) with the assistance of their technical and financial partner, Best Cheer Investments Namibia (Pty) Ltd intends to explore on prospective target areas of mining claims (sites) for black dimension stone (dolerite) and eventually mine on economically confirmed portions of these sites. The proposed exploration and mining activities are planned on nine mining claims (MCs) located about 38 and 45 km northeast of the Arandis mining Town, overlying parts of both the Daures and Karibib Constituencies in the Erongo Region - Figure 1 and Figure 2. The dimension stone and industrial mineral mining claims covered by the project are 71609, 71610, 71611, 71612, 71613, 71614, 71615, 71616 and 71617. The nine mining claims are split into two clusters, the northern and southern cluster. The southern cluster (MC 71609 to 71614) is located between coordinates 22.195141°S / 15.112205°E and 22.169890°S / 15.129027°E while the northern cluster (MC 71615 to 71617) is located between coordinates 22.128019°S/ 15.152470°E and 22.113893°S/ 15.159117°E. The two sites collectively occupy an area of 140 Hectares (ha).

The GPS coordinates of the mining claims are presented in Table 1.

Figure 1: Location of the mining claims (project site) near Arandis in the Erongo Region (Zoomed Out map)

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 2: Location of the mining claims (project site) near Arandis in the Erongo Region (Zoomed-In map)

Table 1: Approximate GPS Coordinates of the Okonde Mining and Exploration mining claims

Mining Claim number GPS Coordinates boundaries

71609 -22.193176° 15.113424°, -22.189573° 15.115982°

-22.190781° 15.117595°, -22.193522° 15.115874°

71610 -22.190737° 15.117644°, -22.189032° 15.115401°

-22.184889° 15.117690°, -22.186916° 15.119891°

71611 22.184889° 15.117690°, -22.186916° 15.119891°

-22.183098° 15.122210°, -22.181249° 15.120287°

71612 -22.183098° 15.122210°, -22.181249° 15.120287°

-22.178020° 15.122985°, -22.179793° 15.124917°

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Mining Claim number GPS Coordinates boundaries

71613 -22.177772° 15.122688°, -22.179638° 15.124765°

-22.175847° 15.127550°, -22.173976° 15.125444°

71614 -22.175847° 15.127550°, -22.173976° 15.125444°

-22.169497° 15.128937°, -22.172513° 15.130294°

71615 -22.126182° 15.150060°, -22.127694° 15.152530°

-22.124305° 15.155302°, -22.122447° 15.152789°

71616 -22.121903° 15.152069°, -22.123553° 15.154293°

-22.119834° 15.157286°, -22.118139° 15.155005°

71617 -22.117561° 15.154246°, -22.119196° 15.156419°

-22.113889° 15.159351°, -22.113752° 15.155909°

1.2 The Mining Claims Ownership The nine mining claims on which the proposed exploration and subsequent mining activities are proposed to be undertaken are owned by Okonde Mining and Exploration with the application for works on these claims submitted to the Ministry of Mines and Energy (MME) on 10 January 2020. However, the mining claims’ application is pending approval as it is subject to an environmental clearance certificate (ECC) by the Ministry of Environment, Forestry and Tourism (MEFT) which would also be the resulting decision from this environmental scoping assessment.

The mining claims’ application is shown on the Namibia Mining Cadastral Portal (upon searching) on this link https://portals.landfolio.com/namibia/. The example of how the mining claims appear on the Portal is shown in Figure 3 below – with the Mining Claims 71609 and 71617 only. The other seven mining claims’ details can also be searched by their numbers using the search box on the upper left corner of the Portal page.

Figure 3: Mining claim 71609 & 71617 on the Portal (link https://portals.landfolio.com/namibia/)

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

As mentioned above, the Proponent are the owners of the mining claims, however they lack the financial and technical capacity to undertake the works, i.e., exploration and subsequent mining. It is for this reason that once the ECC is approved and granted by MEFT, Best Cheer Investment Namibia will then provide the necessary financial and technical assistance for the proposed works and operate in a partnership with the Proponent.

1.3 Project Need and Desirability The consumption for dimension stone is growing at a rate significantly higher than most mineral products, with a compounded annual growth rate of about 0.8% anticipated in 2020 and an expected global value of nearly US$5.22 billion by 2022 according to the 2020 Dimension Stone Mining Global Market Report. This growth is largely driven by increasing demand for high value natural stone in the construction and real estate sectors in China, India, and Eastern Europe. It is partly on these grounds that Okonde Mining and Exploration decided to pursue the quarrying and subsequent beneficiation of black dimension stone. According to Demarco et. al (2011), black dimension stones occupy a prominent place on the international market, with prices for these stones primarily driven by two aspects: the intensity of the black colour (the darker the stone, the more expensive it is) and the block size (the larger the block the more expensive it is).

Another motivator for pursuing the proposed exploration activities stems from the fact that there are already set up and fully operational factories in Karibib and Walvis Bay for processing and beneficiating dimension stone blocks, which coupled with the good road and rail infrastructure to the port of Walvis Bay makes dimension stone mining in the region economical and a source of employment.

It is therefore without doubt that to date the quarrying of dimension stone, supplemented by the processing factories in Karibib and Walvis Bay, are significant sources of reliable employment for communities in the Daures, Arandis and Karibib constituencies. However, most of the present quarries have been operating for some time and their reserves are depleting.

To ensure that the industry remains sustainable for the benefit of shareholders, employees, and organs of state such as the Ministry of Mines and Energy and tax collecting agency, there is need to carry out further exploration geared towards finding good quality rock masses for dimension stone production purposes. This will ensure that the processing factories in Karibib and Walvis Bay remain operational, thereby sustaining employment and tax revenues for the Namibian government.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Therefore, to realize the vision of OME, a basic exploration program will be carried out and shall involve both non-intrusive and intrusive techniques such as surface clearing of the sites, followed by excavation to bedrock. Subsequently, the butterfly cutting of the exposed dolerite is done to identify its colour and pattern, and to provide faces for mapping out the frequency of geological structures/ discontinuities in the rock mass. This is also done to provide fresh rock faces where hand samples can be taken to confirm other physical properties of importance such as strength parameters, ability to polish surfaces, and mineralogy through thin section inspections.

Where this exploration program yields positive results subsequent medium-scale quarrying for black dimension stone will commence using the diamond wire-saw cutting method. The general layout of the quarry(s) and associated infrastructure will depend on the outcome of the exploration program.

1.4 The Need for the Environmental Scoping Assessment Subsequently, in terms of the Environmental Management Act (No. 7 of 2007) (EMA), an Environmental Scoping or Impact Assessment (ESA/EIA) is required to obtain an Environmental Clearance Certificate (ECC) from the Ministry of Environment, Forestry and Tourism: Department of Environmental Affairs and Forestry (MEFT: DEAF) before the projects can proceed. In line with this requirement, OME appointed OMAVI Geotechnical & Geo- Environmental Consultants cc (OGGC) to carry out an environmental scoping assessment (ESA). The ESA is aimed at:

• investigating the potential biophysical and socio-economic environmental impacts that would arise from the planned exploration and quarrying activities • based on its (ESA Study) outcomes, support the Proponent’s application (as a required process and resulting documents) for the environmental clearance to the Ministry of Mines and Energy (MME, as the Competent Authority) by providing recommendations to enable the planned exploration and mining/quarrying activities. The findings of the impact assessment are aimed at providing the Ministry of Environment, Forestry and Tourism’s (MEFT) Department of Environmental Affairs and Forestry (DEAF) with sufficient information that will assist them to make an informed decision on the granting of an Environmental Clearance Certificate (ECC) for the proposed project and its related activities.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

The scoping study documented herein investigates the significant potential positive and negative impacts of the proposed activities on the biophysical and socio-economic environment that would be affected by the proposed activities. This is done by considering all phases of the project from exploration to decommissioning of the exploration sites and subsequent mined out sites (quarries). In addition, the scoping process served to provide Interested and Affected Parties (I&APs) with an opportunity to comment and participate in the impact assessment process and formulating of the mitigation measures to the potential impacts, particularly the adverse impacts.

A single Environmental Clearance Certificate (ECC) application was launched for the two mining claims’ clusters. The ECC application was submitted to the Ministry of Mines and Energy (MME) as the project’s Competent Authority as required by the Environmental custodian, Ministry of Environment, Forestry and Tourism (MEFT). The date stamped ECC copy was then uploaded on the MEFT’s EIA Portal for registration and application purposes

1.5 Purpose of the Environmental Scoping Report The scoping report is prepared for the Environmental Assessment for proposed exploration and quarrying activities on mining claims 71609-71617 located about 38 - 45km northeast of Arandis in the Erongo Region. The claims occur in two clusters with the southern cluster consisting of 6 claims occupying farm Hakkseen and the northern cluster consisting of 3 claims occupying farm Sukses. Environmental scoping is a critical step in the preparation of an EA for the proposed mining activities. The scoping process identifies the issues that are likely to be most important during the EA and eliminates those that are of little concern and develops mitigation measures for those that are of major concern. The purpose of this scoping report is to:

• identify any important environmental issues to be considered and planned for before commencement and during the quarrying activities on the proposed mining claim sites. • identify information required for decision-making. • Inform the public about the proposed activities. • Identify the main stakeholders and consider their comments and concerns. • define and evaluate reasonable and practical alternatives to the proposed activities.

1.6 The Environmental Assessment Process These assessment processes and steps followed in undertaking this environmental assessment are summarised below: 1. Project screening process. 2. Preparation of the Background Information Document (BID) and ECC Application and their submission to the Office of the Executive Director in the Ministry of Mines and Energy (MME) (Competent Authorities) for notification and recommendations.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

The date stamped copy of the ECC Application from the MME was uploaded to the MEFT’s EIA online portal for registration (Application number APP-001763) and notification of the commencement of the ESA. 3. Invitation / notices to stakeholders (I&APs) and the public to participate in environmental assessment process issued through local newspaper advertisements as well as via direct emails communications to key authoritative institutions such as Line Ministries, Regional and Local Governments, and affected Traditional authority and farm/landowners or occupiers of land. 4. Compilation of the Draft ESA Report (consolidating all findings from the I&APs/public consultation, and based on the provided project activities and research) and Environmental Management Pan (EMP) – Appendix A. 5. Implement groundwater (hydrogeological) specialist study as the project area is deemed to have low groundwater potential. 6. Circulating the Draft ESA Report (with all appendices) to the public (I&APs) for review and comments. 7. Incorporate comments and inputs from stakeholder consultations into the Final Scoping and EMP Reports. 8. Submission of the final ESA report (and EMP including all appendices to the report) to the Department of Environmental Affairs and Forestry and to the in fulfilment of all the requirements of the Environmental Impact Assessment (EIA) Regulations No. 30 of 2012 and the Environmental Management Act, (EMA), 2007, (Act No. 7 of 2007) for application of the Environmental Clearance Certificate (ECC) for the proposed project.

A summary of the processes followed is provided in Figure 4 below.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 4: Schematic process flow of the Namibia’s Environmental Assessment Process

During the scoping phase, potential impacts were identified and assessed for the entire life cycle of the project, inclusive of the different stages, namely: the exploration phase, the developmental phase, the mining or extraction phase and decommissioning or closure phase.

1.7 Appointed Environmental Consultant In accordance with the Environmental Management Act (2007) of Namibia and its Regulations of 2012, Okonde Mining and Exploration cc appointed OMAVI Geo-technical and Geo-environmental consultants cc (hereinafter referred to as OMAVI Consultants or OGGC) as an independent environmental consultant to conduct an Environmental Scoping Assessment (ESA) and submit the required documents as part of an application for an Environmental Clearance Certificate (ECC) to the Environmental Commissioner.

The ESA was conducted by the OMAVI Consultants’ team members (with their project responsibilities) listed below:

• Ms. Linda Uulenga (a qualified Land Management specialist and experienced Environmental Assessment Practitioner (EAP)): Environmental Assessment, facilitation of the Public Consultation and ESA Report co-author of the ESA Report and Environmental Management Plan (EMP).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

• Ms. Fredrika Shagama (a qualified and experienced hydrogeologist and experienced and registered EAP): Compilation of the ESA Report, EMP and Desktop Groundwater (Hydrogeological) Impact Assessment Report and Lead Environmental advisor (co-facilitator of the public consultation, mainly addressing the comments from I&APs).

The curricula Vitae (CV’s) of the EAPs are attached as Appendix B of this document.

The findings of the ESA process, incorporated in this report together with the Environmental Management Plan (EMP) and related documentations (in the form of appendices) will be submitted for the ECC application to the Department of Environmental Affairs and Forestry at the Ministry of Environment, Tourism and Forestry for evaluation and ECC consideration.

1.8 Limitations of the Study and Justifications The following assumptions apply to this scoping assessment and its report (this document):

• This report has been compiled on a scoping level with the Desktop Groundwater Assessment Study and Archaeological Assessment only that have been undertaken for it, i.e., no other specialist studies were done as part of this scoping assessment. The other concerns that were raised by I&APs that other specialists’ such as noise and visual studies are to be done, these were not found to be necessary by OMAVI consultants. This is because the consultants believed that the (small) magnitude of the proposed activities and the existence of similar projects in the broader areas of the Region can be used to sufficiently address these potential impacts from the proposed project under the impact assessment section of the ESA Report and mitigation measures provided accordingly. The reviewed literature under the site baseline, residents’ input, site observations and professional experience on similar studies in Erongo and other Regions have also been considered in addressing these impacts. Furthermore, this is because these potential impacts are already cumulative, given the existing similar activities in the project area such as active dimension stone mining on other sites and abandoned sites (in terms of visual) in the area. Despite these cumulative effect, OMAVI consultants provided mitigation measures that will be implemented by OME to reduce the impacts’ significance of their activities, thus improving on / not adding onto the existing/cumulative impacts. The project specific information used in this document is as provided by the Proponent, Site observations, OMAVI Consultants experience and relevant literature reviewed/research.

• OMAVI Consultants assumes that all the project technical information and data that is relevant to the scope of the environmental scoping assessment process provided by the Proponent is correct and accurate, and that all necessary information has been disclosed.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

• It is also assumed that the relevant information obtained from different literature consulted is accurate; and

• This environmental scoping report has been compiled on an assumption that there will be no significant changes to the proposed project activities or the affected biophysical and social environment between the time of compiling this report and implementation of the proposed project that could substantially influence findings of this document. New potential impacts that may arise during the project life cycle would need to be addressed as soon as they are identified, and mitigation measures thereof provided (hence the emphasis on monitoring under Table 4 of the Draft EMP) – Appendix A of this document); and

• It is also assumed that there will be no significant changes to the project activities that could substantially influence the mitigation measures given and recommendations made for the management and protection of the host environment.

To ensure that the ESA sufficiently addresses the right/key concerns and potential impacts that are anticipated from the proposed project, a description of the project activities needs to be provided. This is crucial in providing a clear understanding of the project inputs, processes, outputs and how these processes and activities would really impact the environmental components in the long run. The proposed project description and its related activities are therefore presented under the next chapter.

2 PROJECT DESCRIPTION, ACTIVITIES AND PROCESSES The project inputs, processes, outputs as well as methods are presented under the following sections of this chapter. These activities and processes would be implemented or carried out, respectively on the mining claims, starting with the exploration phase, but only after the ECC has been issued by the Environmental Commissioner.

2.1 Resource Inputs (Exploration and Mining) The following resources will be required for the exploration and mining activities:

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

• Water Requirements (exploration): the amount of water required for the activities ranges between 3 000 and 6 0000 litres per day. A worst-case scenario of the water requirements, a daily volume of 5 000 litres has been considered for the assessment and as maximum for the proposed exploration activities. This value would amount to an average of 155 000 litres per month (1 860 m3 or 1 860 000 per year). It is important to note that during this phase, this water will not be abstracted from existing site boreholes but carted from outside the project area (Proponent’s Warehouse water supply line in Swakopmund) as required but not to be transported every day. The water will be stored in industry standard water tanks onsite for project use. The water required for this project will be mainly used for down-the-hole drilling, butterfly cutting during exploration, cleaning, and cooling off drilling/exploration equipment. Water recycling will be prioritized to conserve water. With this said, there will be no water abstraction from the local aquifers during exploration works. Water Requirements (mining phase): A daily volume of 6 000 litres has been considered for the assessment and as maximum for the proposed mining activities. This value would amount to an average of 186 000 litres per month (2 232 m3 or 2 232 000 litres per year). The water required for the project will be mainly used for cleaning and cooling off mining equipment. Water recycling will be prioritized to conserve water. Once feasibility to mine has been confirmed, an identified dry borehole within the site area (on Farm Hakskeen) will be rehabilitated to supply the required water volume or part of it. If, upon pump testing and determining the capability of the borehole to yield optimal volumes of water, then it will be pumped for 2 hours on certain days of the week to supplement the required 6 000 litres or less per day. In events that the borehole would only supply a certain amount of water that is even less than the required volumes, for instance 3 000 litres only, then the borehole will be pumped for approximately 0.5 hours to provide half of the water required for mining. However, water will not be pumped from the borehole daily, but only when it is necessary to refill the onsite water storage tanks. These durations are recommended in consideration of the maximum yield (groundwater potential) of 3 m3/h in such an area - as explained under section 5.4.1 of the Groundwater (Hydrogeological Assessment Report) -Appendix I. If need be (upon unsuccessful rehabilitation of the existing dry borehole), a new borehole would be sited, drilled, and installed on or near the mining sites. Given the poor nature of water potential in the project area (low groundwater potential), the Proponent may need to continue with water augmentation in the mining phase from their Warehouse water supply and stored in industry standard water tanks onsite.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

The augmentation action would aid in relieving pressure of the local aquifers by complementing the site borehole water with water from outside the area. This could potentially also minimize the number of borehole pumping hours from 2 hours to 1 hour or even 0.5 hour. The aim is not only to avoid over-abstraction but also to ensure long-term resources sustainability for the benefit of both people, animals, and the natural ecosystem. • Fuel (exploration): A trailer mounted diesel bowser will be on-site to store fuel for the exploration/drilling vehicles, machinery, and equipment. The amount or volume of diesel required per day has not been determined. A diesel bowser truck will be filling the smaller onsite trailer mounted bowser, as and when required to ensure that the activities are uninterrupted due to insufficient or no fuel. • Fuel (mining): A bunded fixed 30 000 litre diesel tank will be on-site to store fuel for the mining vehicles, machinery, and equipment. A diesel bowser truck will be filling the onsite tank, as and when required. • Electricity for both exploration and mining: will be supplied by a diesel generator and consideration will be done to connect the site offices/buildings to the existing nearby power grid and or solar energy. • Sanitation: portable chemical toilets will be available at the temporary accommodation near working sites or a type of pit latrine (where excreta in the pit are treated to prevent the waste from being a potential water pollution risk. Sanitation will be enhanced for the mining phase by the installation of standardized ablution facilities near the mining sites and administrative structures/offices. • Site (road) access: Simple access roads to access the Trans-Kalahari Highway (B2) road and D1918 turn in to Henties Bay will be utilized for the project vehicular movements. • Personnel: Based on the experience of their technical and financial partner (Best Cheer Investment Namibia) elsewhere in the Erongo Region, about seven (7) people will be employed for exploration, a minimum of 3 skilled people will be the drill rig supervisor(s), operators/drillers, and driver, i.e., a three to four men crew. The remaining workers would be semi and unskilled who will be carrying out other necessary casual works. Mining phase: Thirteen (13) people will be added bringing the total number of employees to twenty (20) for this phase. The workers from the exploration phase retained from the exploration phase are expected to continue with their respective tasks, given that most of the exploration activities are also necessary (very similar) to the mining phase, especially the dimension stone quarrying/extraction process. • Fire management: A fire extinguisher will be available on each drilling site and in vehicles in cases of fire outbreaks while carrying out exploration and mining activities.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

• Health, safety, and security: All site workers will be equipped with adequate and appropriate personal protective equipment (PPE), that will be replaced or repaired to ensure workers’ occupational health and safety. For safety and security reasons, the localized high-risk working sites will be temporarily fenced off. • Waste management: waste buckets/drums for different waste generated onsite (ranging from household waste to hazardous waste) will be available on site and emptied weekly at the nearest approved waste site, such as Karibib or Arandis.

2.2 Exploration: Processes and Outputs The inputs required for the exploration activities in terms of vehicles and equipment include the following:

• 4x4 exploration vehicles. • Air compressor. • Camping tents. • Prefabricated office structures. • Shade structure for near working areas. • Dozers (to clear vegetation along planned drilling site access roads). • Excavator / front-end loader to scoop up sandy overburden. • Water tanker to cart water to site during exploration. • Two-way radios for constant communication on site activities and matters. • Trailer mounted diesel storage tank (bunded bowser). • Down-the-hole (DHT) drill rig and associated trucks. • Drilling fluids stored in manufacturers approved containers. • Diesel bowser / tank (bunded) of about 30 000 litres; and • Water tanker to cart water to site during exploration.

2.2.1 Project Staff Accommodation and Equipment and Vehicles Storage This phase will employ about seven people (both skilled, semi and unskilled). The exploration workers who may not be from the project area will be accommodated in tented camp facilities or rented farm buildings where available. Workers who will be sourced from the site area/farms will be commuting from their homes to the work sites. However, should the commuting turn out to be not feasible for the working schedules, those local workers would be expected to be housed in exploration camps with others.

All equipment and vehicles will be stored at a designated area near the temporary accommodation on site.

2.2.2 Processes The dimension stone exploration activities intended can be divided into the following two categories:

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

1. Non-invasive techniques: Geological mapping, reviewing of existing geological maps and historical drilling/quarrying data, Field evaluation and sampling; and 2. Invasive techniques: Detailed exploration (Down-The-Hole drilling).

2.3 Proposed Exploration Methods (Technologies) The proponent intends to adopt a systematic prospecting approach starting with desktop study, field evaluation and mapping, then drilling and possibly test quarrying in selected areas where activities may then proceed to mining where outcomes are positive. The proposed activities are summarized as follows.

2.3.1 Desktop study The exploration program will commence with a review of geological maps and historical drilling and/ or quarrying data for the area, if any.

2.3.2 Field Evaluation The field evaluation is to be carried out by a qualified geologist, aimed at locating suitable host rock outcrops in the field from where the:

• General soundness (intactness). • Appearance (patterns and colour); and • Joint and vein spacing can be evaluated.

Small samples (about 30 cm3 in dimension) will be removed for cutting and polishing to provide insights on whether the stone can be polished to an acceptable finish, as well as to give an indication of the hardness of the stone from a sawing and finishing point of view. Where field evaluation indicates a potentially economical viable deposit, detailed geological mapping will be conducted by means of mapping transversely across exposed/ cleaned segments of the rock unit. Where cleaning of the rock unit is required to aid geological mapping, air compressors will be used to expose the rock. The mapping is aimed at delineating major geological structures such as fault and shear zones (zones of weakness), the extent of veins, as well as further delineation of fracture/ discontinuity frequencies.

Collectively, field evaluation and detailed geological mapping will result in the production of a refined and detailed geological map for the targeted sites.

2.3.3 Detailed exploration The refined geological map would then assist in target generation for subsequent detailed exploration such as drilling and possibly test quarrying. A typical drill rig is shown in Figure 5 below.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 5: A typical example of a Down-The-Hole drill rig

A vertical and inclined core drilling with a down-the hole (DTH) drill rig will be carried out in selected areas to provide information on the:

• Vertical extent of the host (dolerite) formation. • Color and texture. • Joint spacing or • Possible defects at depth.

It is anticipated that drilling activities will require a small (6m wide) tracked access roads to gain access to the actual drilling sites for the air compressor and water truck.

2.3.4 Feasibility Study Where drilling yields positive results test quarrying by means of butterfly cutting will be conducted to fully evaluate the recovery of saleable blocks, and better optimize the extraction methods, production rates and operational costs. This will be carried out in select targeted areas only and shall be performed on as small an area as possible to minimize environmental impacts. Project feasibility will also be measured in terms of accessibility from site of occurrence to nearby relevant infrastructure such as roads, etc.

Once the feasibility of the target dimension stone is confirmed (by exploration results), the Proponent will prepare for the mining phase by developing the quarry

Quarry Development: this stage includes setting up of temporary support facilities such as container office, septic tank ablution, shade structures, narrow access roads, drilling or rehabilitation of new or existing old boreholes for water supply; proximal to areas of high potential.

Once quarry development and associated activities are completed, mining commences soon after as per the following section.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

2.4 Mining Phase: Project Inputs, Process and Outputs The inputs required for the mining activities in terms of vehicles and equipment include the following:

• 4x4 mining vehicles. • Construction of office structures and ablution facilities and shade structure for near working areas. • Excavator / front-end loader to scoop up sandy overburden where exploration works could not sufficiently clean, to enable mining, and for block handling • Water tanker to cart water to site (from the onsite borehole and out-of-area water source). • Two-way radios for constant communication on site activities and matters. • Mining drill rig and associated trucks. • Drilling fluids stored in manufacturers approved containers; and • Diesel truck (bowser). • Diamond wire saw cutters for block extraction

2.4.1 Project Staff Accommodation and Equipment and Vehicles Storage About twenty (20) people (both skilled, semi and unskilled) are anticipated for the mining phase (works). The skilled employees/workers who may not be from the project area will be accommodated in rented farm buildings, where available. Since mining workers are likely to work in shifts, those that are residents of the project site area will be commuting from their homes to site (according to their daily shifts).

All equipment and vehicles will be stored at a designated area near the working sites or site temporary structured offices (administration buildings).

2.4.2 Mining Technology and Process According to Ashmole and Motloung (2008), dimension stone mining methods themselves generally have a low impact on the surrounding environment due to the need to carefully extract large blocks or slabs without damage to the stone. Recent advances in dimension stone mining technology have also had the effect of reducing environmental impacts.

Where exploration outcomes are successful in terms of economic viability, environmental friendliness of the extraction/ quarrying technology, full scale quarrying of the dolerite dyke would most likely commence guided by the Environmental Management Plan (EMP).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

It is envisaged that quarrying will be conducted using a combination of best practice non- explosive technologies encompassing Down-the-Hole (DTH) rotary air blast drilling, diamond wire-saw cutting and most likely plugs and feathers splitting. This generally will entail loosening of large volumes of the bedrock by means of primary cutting, and subsequent stepwise division into smaller pieces until blocks of a commercial size are obtained, stockpiling waste rock as the process is performed - Figure 6.

Diamond wire saw cutting involves drilling of two holes, which are drilled to intersect each other, and subsequent passing of the diamond wire through these holes.

The diamond wire through the two holes is then joined to form a continuous loop, which is placed over the flywheel of the saw. As the flywheel rotates, driving the diamond wire through the stone, the saw moves backwards along a track to maintain sufficient tension in the wire. This cutting technology has the advantage that it is associated with low noise and dust generation (Chatterjee et al. 2005).

Figure 6: The typical loosening of large volumes of the bedrock by means of primary cutting for large-scale mining operations of dimension stones

Diamond wire saw cutting involves drilling of two holes, which are drilled to intersect each other, and subsequent passing of the diamond wire through these holes. The diamond wire through the two holes is then joined to form a continuous loop, which is placed over the flywheel of the saw – Figure 7 below (left photo). As the flywheel rotates, driving the diamond wire through the stone, the saw moves backwards along a track to maintain sufficient tension in the wire. This cutting technology has the advantage that it is associated with low noise and dust generation (Chatterjee et al., 2005).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Depending on the final geometry of the quarry, handling of blocks from the quarry will most likely be by means of front-end loaders fitted with fork attachments (Figure 7, right photo). The same front-end loaders will be fitted with a quick coupler attachment which permits for fast interchanging of the bucket with fork or boom, thereby enabling the same machines to be utilized for removal of overburden, handling waste material and cleaning the quarry when fitted with the bucket and pulling blocks down from exposed faces when fitted with the boom. Collectively, this will reduce the number of machineries on site, thereby reducing hazards such as machine-machine collisions, machine-person/ fauna collisions, as well as noise and dust pollution.

Figure 7: The typical mining quarrying by diamond wire technology and front-end block loader

2.4.3 Mining Output The annual production of the dimension stone cannot be established at this stage, but only after exploration and deposit evaluation. However, a review and update of the ESA Report and EMP will be done, once the deposit/reserves evaluation is confirmed. All this information (deposit reserves, annual production planned for mining and ESA/EMP updates) will be communicated to all the registered interested and affected parties of this project.

Once mined, the dimension stone will be transported by trucks to Best Cheer Investment Namibia’s factories in Karibib and if necessary, to Walvis Bay for processing and further beneficiation. Therefore, no processing of the dimension stone blocks will be done onsite. Once processed at the respective processing facilities, the stone will be exported for international market with some value added. This is a positive highlight as most other local producers of dimension stone tend to export the blocks in their raw form.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

2.5 Rehabilitation of Mined Sites and Decommissioning During the operational phase of a quarry’s life, the impact on the environmental can be lessened by planning with future closure in mind. It is also good practice to plan mining where possible in such a way as to be able to utilise waste from operational quarries to fill the voids of worked out quarries. By planning properly, many voids from quarries and gravel borrow pits can be filled up during mining at very little extra cost (Ashmole and Motloung, 2008).

Therefore, towards the end of mining activities on active sites on the mining claims, progressive/ongoing rehabilitation will be carried by the Proponent. This will be done through rock shading, and partial backfilling with topsoil.

Once mining is completed, following the depletion of the quality dolerite deposit, the activities will be decommissioned, and the sites will be rehabilitated to their pre-mining activities as much as possible.

2.6 Project Alternatives This section deals with the alternatives that have been weighed and the ones that have been considered viable. The viability of the selected alternatives/options is based on these that were found to be less damaging to the environment, while maximizing the positive sides (benefits) of the proposed development/project.

According to the 2012 EIA Regulations the definition of the “alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to –

• (a) the property on which or location where it is proposed to undertake the activity. • (b) the type of activity to be undertaken. • (c) the design or layout of the activity. • (d) the technology to be used in the activity; and • (e) the operational aspects of the activity

In other words, the role of alternatives is to find the most effective way of meeting the need and purpose of the proposal, either through enhancing the environmental benefits of the proposed activity, and/ or through reducing or avoiding potentially significant negative impacts. This concept of considering alternatives thus ensures that the environmental assessment is not reduced to the defence of a single project proposal that is the desire of the proponent, and therefore, provides an opportunity for unbiased considerations of options, to determine the most optimal course of action.

The alternatives weighed and considered for this project are with regards to:

• Project location.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

• Exploration and Mining methods • Supporting infrastructure during different stages of the project. • The ‘’No-action’’ alternative.

2.6.1 Limitations to the Project Alternatives In evaluating alternatives to each of the above-listed and below explained aspects, the following factors were considered in line with best practice procedures as outlined under DEAT (2004):

• Resource locality – where alternative locations could be considered for the same resource and such alternatives are justified by economics.

• Technological limitations - where high costs or the environmental unfriendliness of a technology may prevent it from being considered as a viable option, or the lack of technological development may preclude certain options from consideration

• Environmental limitations – where environmental factors such as climate, geology, hydrology, hydrogeology, potential impacts on the local ecology may prevent or favour consideration for an option.

• Socio-economic limitations – where socio-economic factors such as distance to market, availability of infrastructure, current and future land-use, cultural significance, presence of archaeological sites and impacts on livelihoods may hinder or enhance consideration for an option.

2.6.2 Project Location Alternative Mining claims locations are determined by the mineral deposits in an area, and eventually, the preference of an individual or company that is interested in exploring for and mining a specific commodity. The Proponent chose to explore and quarry the dolerite (dimension stone) from the nine mining claims found in this area. It is not possible to find an alternative location of the proposed exploration and mining activities because the preferred mineral is area specific, which is primarily determined by the site geology. Furthermore, the mining claims are owned by the Proponent which also, grant them the right to undertaken exploration activities (upon signed agreements with land/farm owners), and if exploration yields favourable results, mining will commence. The national mineral resources potential locations are also mapped and categorised by the Ministry of Mines and Energy in exclusive prospecting licenses, mining licenses and claims, mineral deposit retention licenses, reconnaissance licenses and exclusive reconnaissance licenses. Available information on these claims and licenses are available on the Namibia Mining Cadastral Map available here https://portals.landfolio.com/namibia/.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Furthermore, similar host rocks (dolerites) which are young, un-deformed, intact, and occur in laterally extensive volumes (yet as narrow dykes) to justify the required capital inputs are non- existent in the area. Hence, OME could not find available alternative deposits that meet their market requirements and are of a significant size to justify the required capital input. For these reasons, alternatives to the locality of the resource were not considered further. Consequently, other alternatives including the “no action” alternative (section 2.6.5) were explored.

2.6.3 Exploration and Mining (Quarrying) Methods and Technology Technologies and methods to be adopted for field evaluation, trenching, test quarrying and actual mining include:

• Bull dozers and front-end loaders to create access roads and remove rock rubble on the surface to expose bedrock. • Air compressors to expose bedrock faces for detailed geological mapping of structures. • Down-the-hole rotary air blast drilling to evaluate rock mass quality at depth. • Butterfly cutting to extract sample blocks; and • Diamond saw cutting.

For the creation of simple and narrow access roads shallow excavation with the front-end loader bucket is deemed to be most economically and environmentally feasible option. Where the ground is flat this method would basically entail dragging the front-end loader’s bucket across the envisaged footprint of the road, thus creating a pathway that can be used by small and large vehicles. Unlike in conventional road construction where the subgrade is ripped and re-compacted, this method ensures less modification of the soil’s structure. Roads for accessing the “koppies” which involve dozing of surficial rubble into gently sloping access ramps, placing borrowed sandy material on top of such rubble, and ultimately, compacting the sandy material on those access ramps. The sand material will be borrowed along trenches at the toe of these “koppies”, particularly targeting patches that are free of vegetation.

Once the surficial overburden rubble has been removed, bedrock surfaces shall be exposed using air compressors. From an efficiency and effectiveness point of view air compressor technology is deemed to be most suitable compared to other traditional methods such as sweeping.

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Down-the-hole rotary air blast drilling was selected as the preferred method for both block splitting and creation of holes for the diamond wire sawing cutting process. This is because in comparison to other drilling methods such as percussion drilling and diamond core drilling it is quick and relatively inexpensive, and therefore works well for block splitting purposes which typically require high drilling densities. The low cost makes it suitable for exploration and mining of low value products such as dimension stones. Although the method typically produces debris and dust the rig to be used is fitted with a cyclone that prevents most dust from escaping. Additionally, due to the remote nature of the project sites and the sparse vegetation cover it is reasonable to argue that dust generated would not immediately affect surrounding communities immediately.

For test quarrying, butterfly and diamond saw wire cutting techniques were selected as the most favourable extraction methods for separating, cutting, and splitting blocks because of the reasons outlined below:

• Diamond wire sawing permits efficient cutting through the hardest of materials, and is thus deemed suitable for this project because the targeted host rock is hard • Both butterfly and diamond wire saw cutting are associated with low noise levels and low dust generation compared to other block splitting technologies such as controlled blasting. • Cutting is more accurate thereby enhancing recovery and minimizing generation of waste rock.

2.6.4 Supporting Services Infrastructure Alternatives were considered for the different supporting infrastructures envisaged to ensure that the most feasible options were selected. Due consideration was given to technological, economic, and environmental limitations in selecting the most feasible option. The alternative considered in this regard are presented in Table 2 below.

Table 2: The presentation of service infrastructure alternatives considered for the project

Category of Infrastructure Alternatives Considered Justification for selected option Install fixed facility with septic -To avoid long-term visual tank impacts & minimize Ablution facilities Portable facilities with septic rehabilitation costs portable tank facilities were selected as the best option

Shade structure made from -Shade structure made from blue/ red corrugated sheets corrugated sheets deemed Shade Structure for working Shade structure made with most suitable due to robustness, areas shade net & resistance to wind destruction

Use existing farm boreholes -During exploration phase bring Drill own new borehole water from elsewhere

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Category of Infrastructure Alternatives Considered Justification for selected option Water supply Bring water from elsewhere -During mining drill own borehole after obtaining water abstraction permit

Install fixed above-ground diesel -During exploration use trailer tank on site mounted diesel tank for fuel Trailer mounted diesel tank storage due to great mobility requirements during exploration Diesel storage -Install fixed above ground tank during mining

Diesel generator set -Most practical & economically viable for exploration & early mining phase Power supply Install photovoltaic panels -Option likely to be considered for long-term operations if economic deposit with high life of mine is found

Erect dis-mantable Favoured during field prefabricated units exploration phase due to: (a) Ease of installation, (b) Low installation costs and (c) Ease of Offices, accommodation dismantling & moving Erect Permanent buildings Lease favoured & unlikely No office, accommodation Favoured during quarrying/ structures on site mining phase to minimize risk of veld fires, bush hunting, visual impact from such structures, security risk, & minimize number of people on site

2.6.5 No-Go Alternative The “no action” alternative implies that the status quo remains, and nothing happens. Should the proposal to explore and mine on the mining claims be discontinued, none of the potential impacts (positive and negative) identified would occur. If the proposed project is to be discontinued, the current land use for the proposed site will remain unchanged.

This option was considered and a comparative assessment of the environmental and socio- economic impacts of the “no action” alternative was undertaken to establish what benefits might be lost if the project is not implemented. The key loses that may never be realized if the proposed project does not go ahead include:

• Loss of foreign direct investment. • About 12 jobs for community members will not be realized. • Loss of potential income to local and national government through land lease fees, license lease fees and various tax structures.

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• Socio-economic benefits such as skills acquisition to local community members, borehole upgrades, etc would be not realized. • Compromise towards ensuring sustainability of dimension stone processing factories in Karibib and Walvis Bay, with potential job losses and comprise on livelihoods in future

Considering the above losses, the “no-action/go” alternative was not considered a viable option for this project.

The above-described project activities and their alternatives are governed by certain legislations and these need to be complied with throughout the project life cycle. The applicable/relevant legislations, policies and guidelines are presented under the next chapter.

3 APPLICABLE LEGAL FRAMEWORK, POLICIES AND GUIDELINES

3.1 National Legislation In Namibia all mineral rights, related to small to medium-scale mining, are vested in the state and are regulated by the Ministry of Mines and Energy (MME) whereas sustainable exploitation and management of the environment and use of natural resources is regulated by the Ministry of Environment, Forestry and Tourism (MEFT) under the Environmental Management Act (EMA) of 2007.

The Minerals Prospecting and Mining Act (Act No. 33) of 1992 is the principal act governing exploration and mining of mineral resources in the Republic of Namibia. From an environmental management standpoint, this Act stipulates the undertaking of an environmental impact assessment during prospecting or mining operations, coupled with the development of thorough implementable environmental plan where any pollution is anticipated. The Ministry of Mines and Energy is the custodian agency for the administration of the Mining Act.

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Conversely, MEFT is the overseeing custodian agency for the administration and enforcement of EMA whereas the enforcement of the Environmental Impact Assessment Regulations of 2012 is specifically entrusted with the Department of Environmental Affairs and Forestry within MEFT. This Act stipulates that possession of an Environmental Clearance Certificate is a pre-requisite for issuing any license or permit by any authority for any activities related to listed activities under the Environmental Impact Assessment Regulations of 2012. The act further sets out under Section 58 and in the Government Notice No. 29 of 2012 a detailed framework and schedule for conducting Environmental Impact Assessments for mining companies.

A review of applicable and relevant Namibian legislation, policies and guidelines to the proposed development are given in this chapter. This review serves to inform the project Proponent, Interested and Affected Parties and the decision makers at the DEA of the requirements and expectations, as laid out in terms of these instruments, to be fulfilled for them to carry out the proposed exploration and mining activities. The applicable local (national) and where necessary international legislation, policies and guidelines are given in Table 3.

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Table 3: Applicable legislation, policies and guidelines to the proposed exploration and mining activities

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts The Constitution Government of the Republic of The Namibian government has adopted several policies that promote sustainable of the Republic Namibia development. Most of these originate in clauses of the Constitution of the Republic of Namibia. of Namibia In Article 95 (i), the State undertakes to actively promote and maintain the welfare of the (1990) people by adopting policies aimed at the utilisation of natural resources on a sustainable basis for the benefit of all Namibians. Articles 91(c) and 95(l) are also of relevance to sound environmental management practice. In summary, these refer to:

• Guarding against over-utilisation of biological natural resources. • Pursuing sustainable natural resource use • Limiting over-exploitation of non-renewable resources. • Maintaining biological diversity • Ensuring ecosystem functionality. • Protecting Namibia’s sense of place and character.

Through implementation of the mitigation measures set out in this Scoping Report (ESA) and Environmental Management Plan (EMP), the owner of the ECC shall be advocating for sound environmental management as set out in the Constitution.

Environmental Part 2 of the Act sets out 12 principles of environmental management, summarized as follows: Management MEFT: DEA Act No. 7 of • Community involvement in natural resources management, must be promoted and 2007 and its facilitated. 2012 EIA • The participation of all I&APs must be promoted and decisions must consider the Regulations Government interest, needs and values of I&APs. Notice 28-30 • Equitable access to environmental resources must be promoted and the functional

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts (Government integrity of ecological systems must be considered to ensure sustainable systems. Gazette • Assessments must be undertaken for activities which may have significant effects on 4878 the environment or the use of natural resources. • Sustainable development must be promoted in all aspects relating to the environment. • Namibia’s cultural and natural heritage including, its biological diversity, must be protected and respected. • The option that provides the most benefit or causes the least damage to the environment, at a cost acceptable to society must be adopted to reduce the generation of waste and polluting substances at source. • The reduction, re-use and recycling of waste must be promoted. • A person who causes damage to the environment must pay the costs associated with rehabilitation of damage to the environment and to human health caused by the pollution. • Where there is sufficient evidence which establishes that there are threats of serious or irreversible damage to the environment, lack of full scientific certainty may not be used as a reason for postponing cost-effective measures to prevent environmental degradation; and • Damage to the environment must be prevented and activities which cause such damage must be reduced, limited, or controlled.

The proponent has the responsibility to ensure that the proposed activity, as well as the ESA process, conforms to the principles of this Act. In developing the ESA process, OGGC has been cognizant of these requirements, and accordingly the ESA process has been undertaken in conformance with this Act and the EIA Regulations (2012). Several listed activities in terms of

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts the Act, are triggered by the proposed activities.

Mineral MME Sections 50, 52, 54, 57 and 130 of this Act sets out provisions for environmental management for Prospecting & activities arising from mineral exploration and mining, as follows: Mining Act (Act no. 33 of 1992) • That the mineral license holder is required to prepare an ESA or EIA and an EMP and make revision of such EMP from time to time • That the mining license holder is liable to pay compensation where in course of the mining operations; any damage is done to the surface of land, water source, cultivation, building or any other structure • That the holder of a mineral license cannot exercise any rights on a private land until the holder has entered into an agreement with the owner regarding payment of compensation • That the license holder shall take all necessary remedial steps to reasonable satisfaction of the minister for any damage caused by any mining operations on closure of mines. • That the minister is empowered to direct the mineral license holder for carrying out good reconnaissance, mining and prospecting practices for the protection of the environment, and conservation of natural resources payment of liability fees and royalty and remedial steps for any damages and • That the mineral or mining license holder shall report pollution in course of any mining or prospecting operations and make remedial measures for such. The abovementioned provisions are all relevant to the proposed activities and were thus considered in the ESA process and drafting of the EMP.

Pollution Control MEFT and others This Bill serves to regulate and prevent the discharge of pollutants to air and water as well as & Waste

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts Management providing for general waste management. The Bill repeals the Atmospheric Pollution Prevention Bill Ordinance (11 of 1976). In terms of water pollution, it will be illegal to discharge of, or dispose of, pollutants into any watercourse without a Water Pollution Licence (apart from certain accepted discharges). Similarly, an Air Quality Licence will be required for any pollution discharged to air above a certain threshold. The Bill also provides for noise, dust or odour control that may be considered a nuisance. The Bill advocates for duty of care with respect to waste management affecting humans and the environment and calls for a waste management licence for any activity relating to waste or hazardous waste management.

The proposed exploration and quarrying of dimension stone and industrial minerals would not entail the discharge of large quantities of gaseous pollutants into air but might result in the generation of noise and dust during the construction, operational and closure phases.

Water Act (No. MAWLR: Department of Water Makes provision for several functions pertaining to the management, control and use of water 54 of 1956) Affairs resources, water supply and the protection of water resources.

The Proponent should prevent any potential pollution of groundwater. Water should be used in a sustainable way. Water abstraction and use should be done in a responsible and sustainable manner.

Water This Act provides a framework for managing water resources based on the principles of Resources integrated water resources management. It provides for the management, development, Management protection, conservation, and use of water resources. Should the proponent wish to undertake Act (Act No. 11 of 2013) activities involving water abstraction and/or effluent discharge, the relevant permits will have to be applied for.

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts Furthermore, any watercourse on/or near the site and associated ecosystems should be protected in alignment with the principles above. Mitigations measures were included in the EMP to reduce impacts on watercourses that could not be avoided

Nature MEFT The Nature Conservation Amendment of 1996 (section 73.1) provides for an economically Conservation based system of sustainable management and utilization of game in communal areas; to Ordinance (Act delete references to representative authorities; and to provide for matters incidental hereto. No. of 1996)

Although the proposed sites for development are not located within protected areas, there is indigenous vegetation on the sites and therefore this Ordinance is relevant. A permit is required should any species onsite, with a protected or endangered status, be damaged or removed. If required, the proponent will apply for such a permit prior to commencing with the proposed activities.

Forestry Act MEFT The Act provides for the management and use of forests and forest products. (Act No. 12 of 2001)

Section 22. (1) provides: “Unless otherwise authorised by this Act, or by a licence issued under subsection (3), no person shall on any land which is not part of a surveyed erven of a local authority area as defined in section 1 of the Local Authorities Act, 1992 (Act No. 23 of 1992) cut, destroy or remove - (a) vegetation which is on a sand dune or drifting sand or on a gully unless the cutting, destruction or removal is done for the purpose of stabilising the sand or gully; or (b) any living tree, bush or shrub growing within 100 m of a river, stream or watercourse.”

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts The proponent will apply for the relevant permit under this Act if it becomes necessary.

Soil MAWLR The Act makes provision for the prevention and control of soil erosion and the protection, Conservation improvement and conservation of soil, vegetation and water supply sources and resources, Act (Act No. 76 through directives declared by the Minister. of 1969)

This Act is applicable since stripping of topsoil will take place to expose the targeted rock units. Mitigation measures are included in the EMP to preserve topsoil and reduce impacts on topsoil.

Regional MURD The Regional Councils Act legislates the establishment of Regional Councils that are Councils Act responsible for the planning and coordination of regional policies and development. (Act No. 22 of 1992) The main objective of this Act is to initiate, supervise, manage, and evaluate development in the regions.

The relevant Regional Council for this project is the Erongo Regional Council which is an I&AP and has been provided with the opportunity to comment on the proposed project.

Petroleum MME: Petroleum Affairs Division Regulation 3(2)(b) states that “No person shall possess or store any fuel except under authority Products of a licence or a certificate, excluding a person who possesses or stores such fuel in a quantity and Energy Act of 600 litres or less in any container kept at a place outside a local authority area. (No. 13 of 1990)

Regulations (2001) The Proponent should obtain the necessary authorization from the MME for the storage of fuel on-site.

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts The Road Traffic MWT: Roads Authority The Act provides for the establishment of the Transportation Commission of Namibia; for the and control of traffic on public roads, the licensing of drivers, the registration and licensing of Transport Act vehicles, the control and regulation of road transport across Namibia's borders; and for matters (No. 22 of 1999) incidental thereto.

Should the proponent wish to undertake activities involving road transportation or access onto existing roads, the relevant permits will be required.

Traditional MURD Namibian legislation recognizes both statutory and customary forms of governance. The Authority Act Traditional Authorities Act recognizes Traditional Authorities (TAs), as the customary leadership (Act No. 25 of of traditional communities as legal entities. 2000)

The primary functions of these authorities are to promote peace and welfare amongst the community members, as well as to supervise and ensure the observance of the customary law of that community by its members.

The Act also stipulates that TAs should ensure that natural resources are used on a sustainable basis that conserves the ecosystem. The implications of this Act are that TAs must be fully involved in the planning of land use and development for their area. It is the responsibility of the TA’s customary leaderships, the Chiefs, to exercise control on behalf of the state and the residents in their designated area.

The mining claims considered under this project are predominantly located on farms Hakskeen 89 and Sukses 90, which are communal farms under the! Oe#Gan Traditional Authority. As such this TA is a key I&AP and will therefore be provided with the opportunity to comment on the

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts proposed project.

National MEAC The Act makes provision for the protection and conservation of places and objects of heritage Heritage Act significance and the registration of such places and objects. Part V Section 46 of the Act (Act No. 27 of prohibits removal, damage, alteration, or excavation of heritage sites or remains, while Section 2004) 48 sets out the procedure for application and granting of permits such as might be required in the event of damage to a protected site occurring as an inevitable result of development. Part VI Section 55 Paragraphs 3 and 4 require that any person who discovers an archaeological site should notify the National Heritage Council. Section 51 (3) sets out the requirements for impact assessment.

No objects of heritage concern were noted onsite. However, should any objects of heritage significance be identified during exploration, quarry development and mining phase, the work must cease immediately in the affected sites and the necessary steps taken to seek authorisation from the Council.

Public Health MoHSS: Occupational Health The Act serves to protect the public from nuisance and states that no person shall cause a Act (Act No. 36 nuisance or shall suffer to exist on any land or premises owned or occupied by him or of which of 1919) he is in charge any nuisance or other condition liable to be injurious or dangerous to health.

The proponent should ensure that the facility is designed and operated in a way that is not unsafe, or injurious or dangerous to public health and that the noise and dust emissions which could be considered a nuisance remain at acceptable levels. This will be applicable during the exploration, structure construction and mining phases of the proposed project to the

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts employees but not so much to landowners as farmhouses and settlements are located far away from where quarrying will take place.

Labour Act, MLIEC Sections 3, 4, 5, 11, 16, 23-27, 44 and 135 make provision for the following: 2007 • That a person may not employ a child under the age of 14years • That children are prohibited for employment in a mine and other dangerous circumstances • That forced employment of persons is prohibited • That an employee is entitled to monetary remuneration daily, weekly, fortnightly, or monthly in cash, cheque, and direct deposit into a bank account • That the work hours of an employee are 45 hours in a week, over and above which an employee is entitled to additional payment overtime wage • That employees are entitled to (a) annual leave on the basis of the average number of days worked over the year, (b) a day’s sick leave for every 26days worked, (c) compassionate leave for a period of 5days in 12 months which is fully paid, and (d) leave on public holidays, • That female employees that have completed 6 months of employment are entitled to 12 weeks of maternity leave, which can be extended for a further period of one month • That the minister is empowered to make regulations in relation to safety, health, hygiene, sanitation, and welfare of persons employed in or about mines, including sea- bed operations

The proponent is expected to be compliant with the above provisions and as such the above

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts provisions were accounted for in the ESA report and EMP.

Relevant Policies and Regulations

Environmental MEFT: DEA This policy aims to promote sustainable development and economic growth while protecting Assessment the environment in the long term by requiring environmental assessment prior to undertaking of Policy (1994) certain activities. Annexure B of the policy contains a schedule of activities that may have significant detrimental effects on the environment, and which require authorisation prior to undertaking. Please see Table 4 for a summary of the activities that would require authorisation for the proposed exploration and quarrying of dimension stone and industrial minerals.

Mine Health & MME: Mine Safety & Services These set of regulations are aimed at ensuring that mines are operated in a safe manner to Safety Division prevent fatalities, injuries, and long-term health hazards. The regulations make provision for: Regulations (under section MoHSS: Occupational Health • Employee’s right to leave unsafe working places 138A of the Division • Obligation of a mine manager to provide for all safety measures in a mine or quarry Mining Act, 1992) • Reporting of accidents to the chief inspector and keeping a record of such accidents • Requirements for the mine manager to provide occupational health services at area of mining activity • Requirements for stability of excavations; provision of waiting areas; provision of fencing and gates; schemes for working in vicinity of water body. • Provision for mine dump or mine tailings facility • Ensuring that all parts of a mine are well ventilated with minimum standards of air quality • The mine manager’s responsibility to formulate a scheme for safe movement of vehicles being use in the mine/ quarry • The mine manager’s responsibility to formulate a scheme for identifying hazards at the

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LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts area of mining activity and provision of appropriate protective equipment • Ensure that the mine manager provides first aid and firefighting equipment and procedures where exploration/ quarrying activities are being conducted All the above-mentioned provisions are relevant to this project and were thus considered in the ESA process and EMP.

Atmospheric MoHSS This ordinance provides for the prevention of air pollution and is affected by the Health Act 21 Pollution of 1988. Under this ordinance, the entire area of Namibia, apart from East Caprivi, is Prevention proclaimed as a controlled area for the purposes of section 4(1) (a) of the ordinance. Ordinance (1976) Hazardous MoHSS The ordinance provides for the control of toxic substances. It covers manufacture, sale, use, Substance disposal and dumping as well as import and export. Although the environmental aspects are Ordinance, No. not explicitly stated, the ordinance provides for the importing, storage, and handling. 14 of 1974

Road MWT: Roads Authority Width of proclaimed roads and road reserve boundaries (S3.1) Control of traffic on urban trunk Ordinance 1972 and main roads (S27.1) (Ordinance 17 of 1972) Infringements and obstructions on and interference with proclaimed roads. (S37.1)

Some of the project activities as distinctively listed in the EIA Regulations will require authorizations (permit or license) prior to commencement. The activities are presented below (Table 4) and the specific permits or license required will be provided in the EMP for implementation.

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Table 4: Summary of relevant acts and applicability thereof (in terms of licenses, authorisations and or permits) as listed in the 2012 EIA Regulations

ACTIVITY DESCRIPTION OF ACTIVITY RELEVANCE OF LISTED ACTIVITY

Activity no. The construction of facilities for waste The proposed activity will require development of stockpiles for waste rock not suitable for 2.1 sites, treatment of waste and disposal of dimension stone production as well as stockpiling of topsoil stripped off to access the waste targeted rock unit

Activity No. The construction of facilities for any The proposed project will entail exploration and quarrying activities, both of which require 3.1 process or activities which requires a environmental clearance and prospecting/ mining permitting prior to commencement license, right or other form of authorization, and the renewal of a license, right or other form of authorization, in terms of the Minerals (Prospecting & Mining Act), 1992

Activity No. Other forms of mining or extraction of The proposed project would require surface clearing and excavation over the footprint of 3.2 any natural resources whether regulated the targeted rock unit, followed by subsequent butterfly cutting & splitting of the targeted by law or not bedrock (during exploration) and finish diamond wire-saw cutting (during quarrying of dimension stone blocks). If market demand for construction aggregates is identified Activity No. Resource extraction, manipulation, certain areas of the mining claims might be used for crushing and production of such 3.3 conservation & related activities products but at this stage the focus is dimension stone production

Activity No. The abstraction of ground or surface The proposed exploration and quarrying activities may require drilling of a borehole and 8.1 water for industrial or commercial subsequent abstraction of groundwater for both domestic and exploration/ quarrying purposes activities

Activity No. The storage and handling of a It is anticipated that a portable diesel generator will initially be used for power generation 9.4 dangerous goods, including petrol, for both domestic and industrial use at the site. The use of solar technology is anticipated

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ACTIVITY DESCRIPTION OF ACTIVITY RELEVANCE OF LISTED ACTIVITY

diesel, liquid petroleum gas or paraffin, in at a later stage if the operation grows containers with a combined capacity of more than 30 m3 (30 000L) at any one location

Activity No. The construction of – public roads The proposed project may include the construction of access roads for access to the sites 10.1 (b)

3.2 International Treaties and Conventions The international treaties and conventions applicable to the project are as listed in Table 5 below.

Table 5: International Treaties and Convention applicable to the project (after Resilient Environmental Solutions, 2019)

STATUTE PROVISIONS PROJECT IMPLICATIONS

The United Nations Convention to Combat Addresses land degradation in arid regions with the The project activities should not be such that they purpose to contribute to the conservation and contribute to desertification. Desertification (UNCCD sustainable use of biodiversity and the mitigation of climate change

Convention on Biological Diversity 1992 Regulate or manage biological resources important Removal of vegetation cover and destruction of for the conservation of biological diversity whether natural habitats should be avoided and where not within or outside protected areas, with a view to possible minimised ensuring their conservation and sustainable use.

Promote the protection of ecosystems, natural habitats, and the maintenance of viable populations of species in natural surroundings

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STATUTE PROVISIONS PROJECT IMPLICATIONS

Stockholm Declaration on the Human It recognizes the need for: “a common outlook and Protection of natural resources and prevention of common principles to inspire and guide the people Environment, Stockholm (1972) any form of pollution. of the world in the preservation and enhancement of the human environment.

The proposed project and its activities will be undertaken in a specific biophysical and social environment. Therefore, to understand the baseline environment with regards to the potential impacts stemming from the proposed project, the affected environmental components and features are presented under the next chapter.

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4 DESCRIPTION OF THE RECEIVING (BASELINE) ENVIRONMENT It is crucial to understand the baseline (pre-project site conditions) information of a project area because it aids in undertaking a concise assessment and make informed conclusions on the proposed project’s impacts on the affected biophysical and social environmental components. The baseline information (conditions) of the site area and broader area that are relevant to this project and its assessment are briefly described below.

The data source used to compile this chapter ranges from the review of existing published academic papers, old project reports and books containing the information on the area. The information sourced from online (soft copies) and physical source research has been complemented by raw data collected on site during the site visits, assessments and public engagement meetings undertaken between 18 and 25 July 2020.

Other existing reports of similar or related studies conducted in the area were also reviewed. This also entailed the review of relevant books in the field of hydrogeology that significantly contributed to the study.

4.1 Biophysical Environment

4.1.1 Climate Temperature

Namibia has four very large and arid regions which set them apart in various ways from the rest of the country; Kunene and Erongo region in the west and Karas in the south (Mendelson, Jarvis, Roberts, & Robertson, 2002). The project site is in the hyper-arid Namib Desert. Hot dry conditions during the day and cool nights are common with temperatures ranging between 5 – 45 degree Celsius (Namibia, 2012), this could be an attribute of its proximity to the coast therefore climate is influenced by both the desert and the coast. Rainfall in the area is generally both low and extremely variable which means that years of abundant rain often followed by extreme dry conditions (Mendelsohn, et al., 2002). Consequently, there is no surface water in the area very scarce on the site, except during rare periods of exceptional rainfall.

Fog precipitation of close to 20 mm also provides an important source of moisture for the ecosystem functionality as fog annual fog within the Erongo region is reported to extend up to 110km inland and is therefore expected to affect the project site (SLR Environmental Namibia, 2012).

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The maximum temperatures recorded for the site area for the period of 2010 and 2020 range between 17°C and 27°C whereas the minimum temperatures range between 13°C and 21°C. The average temperatures between 13 and 19°C. These temperature components are shown in Figure 8 below.

Figure 8: The maximum, minimum and average temperature Arandis area (source: World Weather Online, 2020)

Rainfall

According to African Planning Forum (2019), Arandis generally experiences all year healthy and bearable climatic conditions where warm days are followed by cool nights. Thus, Arandis can be considered to have a desert climate. The spatial potential evaporation distribution in Namibia map is presented in Figure 9 with the project area being in the range of 3 200 to 3 400 mm/a. The location of the Arandis area being the nearest town to the mining claims’ site is estimated by the red arrow (between Swakopmund and Usakos) on the western coastal part of Namibia.

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Arandis Area

Figure 9: The spatial distribution of potential evaporation in Namibia (after BGR, 2005)

The only rains fall during the summer months and on average most of this rainfall is experienced from February to April (African Planning Forum, 2019). In the past 10 years, the highest rainfall recorded for Arandis was 51 mm (in February 2011) – Figure 10. African Planning Forum (2019) further states that occasional thunderstorms however do occur turning the small river courses into fast flowing rivulets and flash flood conditions do occur. The average rainfall for the region over the long term is less than 100 mm per year but due to the erratic distribution, much of the area receives less than 50 mm per year.

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Figure 10: The rainfall patterns for the Arandis area (source: World Weather Online, 2020)

4.1.2 Topography and Hydrology The topography of the project area is based on the nearest town being Arandis that has available information. The project area is located some 581 metres above mean sea level. The area is characterized by undulating hills and sandy valley areas (Africa Planning Forum, 2019). In the Erongo Region, the land rises steadily from sea level to about 1,000 m across the breadth of the Namib. The Namib land surface is mostly flat to undulating gravel plains, punctuated with occasional ridges and isolated ‘inselberg’ hills and mountains (Southern African Institute for Environmental Assessment (SAIEA), 2011). Aurecon Environment and SLR Environmental Consulting (2014) further state that broad geomorphological characteristics include a shore of mixed sand and rock, with gravelly coastal plains in the study area, with the Arandis Mountain (just over 600 m high) further to the east and a narrow dune belt further to the south.

The mining claims’ sites are characterized by hilly mountains and the Proponent is targeting these mountains for dolerite exploration and extraction/mining. Coupled with inspection of the aerial view of the site, it was confirmed that the proposed project is in a topographically high area characterized by narrow (~300 m wide) southwest – northeast trending linear koppies of Cretaceous dolerite (71609-71614) and Cambrian red granites (for mining claims 71615 - 71617). The topography of the two mining claims clusters is shown in Figure 11 below.

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Figure 11: Topography within the mining claims’ site boundary (photo: OMAVI Consultants, 2020)

In terms of hydrology, the site area does not have significant natural surface bodies such as rivers. According to Africa Planning Forum (2019), the only nearby surface water body is the Khan River, a prominent ephemeral river located south of the Arandis Town. The town therefore falls within the Kahn River catchment area of which in turn is part of the greater Swakop River catchment area. Further north of the town the catchment area of the Omaruru River is found. Therefore, the overall project site and area in the Omaruru and Khan catchments, all these rivers are ephemeral and are dry for most parts of the year and drain westwards into the Atlantic Ocean.

The main surface water flow in the vicinity of the project site is in a south-westerly direction, following the gradient towards the ocean. There are small and shallow poorly to moderately developed channels flanking the targeted dolerite and granite ridges. Considering the shallow and not so-well developed nature of the channels, overland flow in the vicinity of the proposed sites is expected to be in the form of sheet-like flow.

4.1.3 Soil and Geology According to GCS Water & Environmental Consultants (2017), the soils of Namib Desert are knowns as “syrosems” and calcareous soils. The syrosem soils were formed when solid rock is exposed, mainly broken down by mechanical weathering. Rock fragments and exfoliation chips gather around the outcrops, where they undergo further processes of weathering. The calcareous (from limestone) soils were formed during a pluvial period when a minimum of groundwater was available. The subsoil rises to the surface through capillary action and deposits the dissolved CaCO3 on evaporation, forming the deep soils. The texture of the Namib Desert soil is classified as coarse to moderately coarse. These soils are prone to collapse when disturbed.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

The project site area is located within the southern Central Zone (sCZ) of the Neo-Proterozoic Damara Orogenic Belt. The area is underlain by the Abbabis Metamorphic Complex (AMB) characterized by basement dome structures and antifoams with northeast elongation exposed along the Swakop and Khan Rivers. The Abbabis Metamorphic Complex is overlain un-conformably by the Damara Supergroup, which comprises mainly metasedimentary rocks deposited in the period from about 900 to 700 Ma (Miller, 1983a). The lower part of the Damara Supergroup is dominated by meta-arkoses and calc-silicate rocks of the Nosib Group, while the upper portion of the sequence consists of alternating marbles, calc-silicate rocks, and schists of the Swakop Group.

The Swakop Group in the area is represented by rocks of the Chuos (diamictites and boulder-bearing schists), Karibib (Calcitic marble, calc-silicate interlayers, and schists), and Kuiseb (inter-bedded schist, arkosic quartzites and calc-silicate) Formations. The area was later intruded by numerous syn-to post-tectonic granitic plutons, which include minor meta- gabbro, dolerites, diorite and tonalite, abundant coarse-grained granite, leucogranite and pegmatite, which form areas of high relief as in the project area (Miller, 2008). Unconsolidated Quaternary sediments consisting mainly of alluvium, fanglomerates and calcretes cover large parts of the area, particularly in the low-lying areas. Of interest to present project are the black Cretaceous dolerite sills and dykes in the area that intruded the red granites. The three mining claims to the north are targeting Cambrian red granites as shown on the geological map in Figure 12 below.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 12: Geological map of the project area

On the koppies the soil profile is generally poorly developed, with a thin cover of sandy soil covering mechanically weathered boulders of dolerite and granite. On the flatter plains the soil profile is relatively more well-formed and is thicker, especially in the vicinity of drainage channels, and comprises silty sandy fine gravels as shown in Figure 13. The formation of a gravelly surface layer suggests that these soils are sensitive to wind erosion, which results in the winnowing out of finer silty/ sandy particles leaving a uniformly graded gravelly surface layer.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 13: Typical grading of topsoil on the flat plains adjacent to host rock koppies

4.1.4 Hydrology and Catchments The site area does not have significant natural surface bodies such as rivers. According to Africa Planning Forum (2019), the only significant nearby surface water body is the Khan River, a prominent ephemeral river located south of the Arandis Town. The town therefore falls within the Kahn River catchment area of which in turn is part of the greater Swakop River catchment area. Further north of the town the catchment area of the Omaruru River is found. All these rivers are ephemeral and are dry for most parts of the year.

Given the proximity of the project site to the Town of Arandis, it is assumed that the site also falls within the same (Khan River) catchment. According to Strohbach (2008), the Khan River has a surface area of 8 399 274 km2.

4.1.5 Hydrogeology The project site is within the groundwater basin of the Central Namib-Windhoek Area, which according to Christelis and Struckmeier (2011) extends from Windhoek in the east to the Atlantic Ocean in the west. Several towns are situated in the catchment of the Swakop and Khan rivers: Okahandja, Otjimbingwe, Karibib, Usakos and Arandis as well as the Rössing uranium mine. A groundwater basin is a physiographic unit containing one large aquifer, or several smaller connected and hydraulically interrelated aquifers (Robins, 2020)

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

The fact that most towns in the western Central Region are situated on or near rivers reflects groundwater availability in the area. Sufficient water for larger settlements can only be obtained by surface water storage in dams or from alluvial aquifers, while the potential of bedrock aquifers is very limited. This is partly due to the low rainfall and lack of recharge, and partly to the generally unfavourable aquifer properties of Damara Sequence rocks (Christelis and Struckmeier, 2011). Groundwater reserves in the vicinity of the study area are limited to the Kuiseb, Swakop, and Omaruru alluvial bed aquifers of the Erongo groundwater basin, which supply Henties Bay, Swakopmund and Walvis Bay as well as Arandis, and historically Rössing Uranium and Langer Heinrich Mines (Aurecon Environment and SLR Environmental Consulting, 2014).

Christelis and Struckmeier (2011) further states that moderate yields are also encountered in the marble and schist aquifers around Karibib and the calcrete aquifer in the Kranzberg area at Usakos. But while the marbles supply the much larger town of Otjiwarongo further north, the recharge at Karibib is insufficient to maintain the required yields, and the water supply to the town and Navachab gold mine is augmented by the Swakoppoort Dam. Borehole yields decrease to very low and limited in the Namib.

The Hydrogeological map of Namibia with groundwater potential of rock units is shown in Figure 14. According to this map, the project site area (as shown by the green arrow) is largely found in generally low, locally moderate groundwater potential and in some further areas, very low and limited potential.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 14: Hydrogeological map of Namibia with rock bodies groundwater potential with the approximate location of project site indicated by the light green arrow on the map

4.1.5.1 Baseline Groundwater (Borehole) Yields and Levels With regards to borehole yields in the groundwater basin, moderate yields are encountered in the marble and schist aquifers around Karibib and the calcrete aquifer in the Kranzberg area at Usakos. But while the marbles supply the much larger town of Otjiwarongo further north, the recharge at Karibib is insufficient to maintain the required yields, and the water supply to thetown and Navachab gold mine is augmented by the Swakoppoort Dam. Other bedrock aquifers in the eastern part of the Namib, e.g., in the former Damaraland, are barely able to supply enough water for stock watering. Many dry boreholes were drilled in this area. The yield potential is generally low, but locally moderate. Yields decrease to very low and limited in the Namib (Christelis and Struckmeier, 2011).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

The groundwater map (in Figure 14) presents a color scheme that subdivides the rock bodies into aquifer (blue, green) and non-aquifers (brown) and further into fractured (green) or porous (blue) ones. Dark blue and dark green illustrate aquifers with high potential and yields generally above 15 m3/h, while the light colors describe aquifers with moderate potential and yields between 3 and 15 m3/h (Winker, 2010). With that said, it can be safely concluded that the light and dark brown colors in the same map represent areas of very low, limited and generally water potential with yield less than 3 m3/h. This is the scenario with the project area (Arandis Town and the mining claims). However, moderate potential and yield areas could be encountered on certain local aquifers (small light green patches around the project area in the map). The probability of encountering such aquifers would be depended on correct siting of boreholes in the area targeting these specific moderate aquifer bodies.

During the site visit conducted on 25 July 2020, three good yielding boreholes were observed within the mining claims’ site area, specifically Farm Sukses. These boreholes belong to the homesteads that are found on this Farm. The homesteads have small livestock that is supplied with water from the boreholes. The farm communities also obtain water for consumption from the same boreholes. The baseline water levels could not be measured from the boreholes because of the borehole installations, covered with fixed concrete slabs making the water levels inaccessible.

On the Farm Hakskeen, there is one operational borehole that is also fully equipped and covered with a concrete slab, which made it difficult to access the water level. Powered by a windmill, the borehole supplies water to the community. However, the water is slightly saline, therefore not fit for human consumption such as drinking. This borehole water is primarily used for small livestock watering, cooking, and making tea and coffee. For fresh or drinking water, the four homesteads or houses on this Farm obtain this water from a borehole located on Farm Black Range and stored the water in farm tanks. The borehole on Farm Black Range is said to be less saline compared to the water in Farm Hakskeen boreholes. On Farm Hakskeen, there is another borehole that is said to be dry and the Proponent is considering it for rehabilitation to supply water for the mining activities.

The borehole information is presented in the Groundwater Assessment Report attached to this document.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

4.1.5.2 Groundwater Quality According to Christelis and Struckmeier (2011), groundwater in fractured aquifers between the coast and 20-150 km inland is mostly saline. Fractured aquifers with inadequate yields are used at the Spitzkoppe (94) and Tubussis (101) water supply schemes. The Spitzkoppe is a popular tourist attraction in the Erongo Region. The mountain consists of granite intruded into meta-sediments of the Swakop Group. A settlement established at the foot of the mountain depends mainly on tourism and some small stock farming. The water scheme’s boreholes are sited on fractures intersecting the small Spitzkoppe River. Their yields are low, recharge is erratic, and its absence leads to poor water quality of Group C-D. A treatment plant to improve water for domestic consumption has been built.

A local groundwater quality assessment was conducted by BGR for the Khan and Swakop River Catchments in 2010 – Figure 15.

Mining Claims

Arandis

Figure 15: Location of the sampling points for the 2010 Khan-Swakop River Catchment groundwater quality assessment (edited after Kringel et al., 2010)

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

The spatial distribution of Electrical Conductivity (EC) from groundwater samples from this assessment (study) is shown in Figure 16. According to Kringel et al (2010), generally, the occurrence of low salinity groundwater is restricted to the headwater region of the two rivers. In the downstream region, groundwater is saline. For the Khan River catchment samples with high EC also occur upstream of any discharge point from the Rössing Uranium Mine. Elevated EC is also found upstream of the Langer Heinrich Uranium Mine. Apart from a few exceptions, samples east of 15.35° latitude are in group “excellent” (A) and “acceptable” (B) while to the west of this latitude the groundwater is in group C or lower, making it unsuitable for human consumption. The unsuitability of this water for drinking (due to poor-quality) could also be explained by complaints received from some farm owners (about salty borehole water in the area) during the project site visit on the 25th to 26th July 2020.

Mining Claims

Arandis

Figure 16: Spatial distribution of Electrical Conductivity (EC) at the sampled area (Kringel, 2010)

More information on the Groundwater characteristics of the area including vulnerability to over-abstraction and pollution is given in the Desktop Groundwater Specialist Report.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

4.1.6 Biodiversity: Fauna and Flora

4.1.6.1 Fauna According to Aurecon Environment and SLR Environmental Consulting (2014), the Namib Desert is one of five coastal deserts world-wide. The frequent coastal fog is a significant source of moisture and supports a unique terrestrial ecology. The Namib Desert is estimated to be around 80 million years old. The long evolutionary history and occurrence of diverse ecological niches have given rise to an exceptional biodiversity with a high level of endemism. In this hyper-arid environment species redundancy is low and the ecosystem is highly susceptible to disturbance and slow to recover.

Mammals: according to the study by Pallett et al, in 2008 around the Rössing and Arandis areas, the mammals list showed a medium diversity – 43 species – which is typical for the central Namib. While larger mammals such as kudu and baboon are conspicuous and quickly recognized by lay people, the mammal list includes 6 hoofed mammals, 9 carnivores, 11 bat species and 16 small terrestrial mammals including rodents and one each of shrew, sengi (elephant shrew), hare, dassie and hedgehog. Many of these, particularly the carnivores, are naturally uncommon to rare, while a few others, such as hedgehog and fruitbats, are likely to occur only very rarely as vagrants linked to the Khan River linear oasis. Eight of the mammal species are classified as Near Threatened, one as Vulnerable and one as Endangered. The latter, Namibian Mountain Zebra, is confined to the Namib Desert. African Wild Cat, the Vulnerable species, is threatened most by hybridization with domestic cats. The latter are likely to occur in and around the Rössing buildings, but the existence or threat posed by feral cats at Rössing has not been assessed. The threat is probably low (Pallett et al., 2008).

No significant fauna was observed on site. However, according to the locals, regarding wildlife, some mammals such as springboks, Gemsbok, Kudus existed in the area after good rain seasons. The long dry seasons (lack of drinking water), farm resettlements and partly bush hunting contributed to the drastic reduction in the number of these mammals. Jackals are also said to be found in the area and a diverse range of reptiles.

Birds: The Rössing bird list records high diversity for an area this barren, largely due to the influence of the Khan and its tributaries as linear oases. There are no birds found in the area which are restricted to the area or threatened by the mine expansion. Two raptor species – Martial Eagle and Lesser Kestrel - carry IUCN Threatened status and another – Verreaux’s Eagle – is Near-Threatened, but their populations are scattered over southern Africa, and the mine expansion will not significantly increase the factors causing their decline (Pallett et al., 2008).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Amphibians and Reptiles: Three species of frogs are known to occur or are expected from the Rössing area. Reptile diversity is high in the Namib Desert and the central Namib has a surprisingly high diversity of lizards, especially geckos. total of 33 lizard species recorded or having a high probability of occurrence in the Rössing area. This comprises 15 Geckos, 2 Agamas, the Namaqua Chameleon, 7 Skinks, 7 Sand Lizards and one Plated Lizard. Of these 33 species, 8 are endemic to the Namib and one, the Husab Sand Lizard, has a distribution range that is restricted to the mountainous Rössing-Husab area (Pallett et al., 2008).

In terms of domestic animals, the surrounding farms actively do small stock farming consisting of sheep and goats but on a small scale.

4.1.6.2 Flora The study area lies falls within the Central Namib Desert Biome (Mendelsohn et al., 2002). All endemic plant species found within the proposed project area are drought tolerant, drought resistant or succulent. Short lived annuals, which occur after local rainfalls and floods, provide a vital source of food for game grazing within the Namib plains (African Planning Forum, 2019). The dominant vegetation structure is sparse shrubs and grasses. Botanical Surveys in similar habitats indicate that shrubs and herbs such as Blepharis grossa, and Arthraerua leubnitziae (pencil bush), Zygophyllum stapfii, Zygophyllum clavatum, Psilocaulon kuntzei and Salsola sp. are likely to occur. Occasional specimens of Commiphora saxicola and Sarcocaulon marlothi (bushman’s candle) occur, often in patches in the lower lying areas (Aurecon Environment and SLR Environmental Consulting, 2014).

Due to the predominantly low rainfall and extreme weather conditions vegetation in the area is sparse, with a predominantly scattered distribution. Despite this however, the area is home to some botanical diversity as documented by Gibbs Russell et al. (1984), Giess (1998) and Burke (2008). Background information from a semi-quantitative to qualitative study conducted by Burke (2008) coupled with the field survey conducted during the present assessment provide insight on the local-scale botanical diversity on Farms Hakskeen and Sukses. The most recent local study (by Burke, 2008) partly aimed to establish the recovery potential and sensitivity of plant species in the Spitzekoppe area and surrounding farms, and adopted a subjective qualitative approach based on expert opinion to establish recovery potential and sensitivity.

According to Jacobson et al (1995), variation in rainfall is the primary determination of the western catchment vegetation. The classification of Giess (63) provides a broad overview of vegetation types found in the western catchments. The mountainous highlands associated with the headwaters of the Swakop and Kuiseb catchments, the highland savanna is composed of a complex mixture of Acacia species along with Combretum, Euclea, Rhus and perennial and annual grass species (Jacobson et al, 1995).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Moving westward off the inland plateau and towards the Namib Desert, the vegetation shifts from upland savannas to vegetation more suited to arid conditions. The transition zone between savanna and semi-desert is composed of a great variety of species, many of which are endemic to the Erongo Region (Jacobson et al, 1995). These vegetation species include Euphorbia, Cyphostemma, Moringa, Adenolobus, and Acacia.

From site observations, the site and surrounding areas are poorly vegetated, with few vegetation sparsely distributed in some areas of the site and some areas completely bare (no vegetation cover). This is common for inland coastal area, given their desert characteristic.

Based on this information plant diversity in the vicinity of the dolerite ridges targeted for mining can be grouped into four distinct vegetation zones, namely:

• The Succulent dwarf shrubland. • The Dolerite outcrop shrubland. • The Dwarf succulent -small bushman grassland; and • The Dwarf succulent – twiggy commiphora shrubland.

The typical vegetation (flora) onsite is shown in Figure 17 and Figure 18.

Figure 17: Sparse vegetation on relatively flat land characteristic of the succulent dwarf shrubland (Left Photo) and the Dolerite outcrop shrubland (Right Photo)

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 18: Dwarf succulent – small bushman grassland

The succulent dwarf shrubland and the dwarf succulent – small bushman grassland domains generally lie outside of the mining claim boundaries on the surrounding low-lying veld and gently undulating plains surrounding the dolerite ridges. According to Burke (2008), these zones are largely composed of the central Namib endemic low succulent shrub Zygophyllum cylindrifolium, with individual shrubs being widely spaced and reaching about 10% to 20% cover. These shrubs generally grow on extensive gravel plains within calcareous crusty soils characterized by relatively high pH and calcium content. These shrubs are palatable and are an important source of fodder for the close to non-existent livestock and wildlife in the area. This zone generally has a low to medium recovery potential and was assigned a medium level of sensitivity by Giess (1998) and Burke (2008).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

According to Giess (1998) and Burke (2008), the Dolerite outcrop shrubland domain covers all dolerite outcrops and the higher dolerite ridges targeted for quarrying. The vegetation is generally diverse including Commiphora tenuipetiolata, Commiphora virgate, Euphorbia virosa, stem-succulents, and various grass (such as Erasgrostis nindensis, Stipagrostis hirtigluma and S. uniplumis) and dwarf shrub species (such as Monerchma cleomoides, Monescma genistifolium). The dolerite outcrops of various heights and extent provide a habitat for this vegetation type, and in the project area these are characterized by medium to steep slopes, and it is reported that the soils derived from weathering of the dolerite are relatively more fertile. Collectively, the various plant life of this domain provide forage for the close to non-existent livestock and wildlife. Burke (2008) reports that this vegetation zone has high sensitivity and a low recovery potential.

4.2 Social Environment

4.2.1 Demographic Overview: Regional, Constituency and Local The total population of the Erongo Region as per the 2011 National Population and Housing Census was recorded at 150 809, of which 70 986 were females and 79 823 males. The population density for the Region was 2.7 people per square kilometres (Namibia Statistics Agency, 2011a).

The project site covers parts of the Daures and Karibib constituencies each with a population of 11 350 and 13 320, respectively. The Karibib Constituency population was made up of 6 412 females and 6 908 males while Daures recorded 5 309 females and 6 041 males (Namibia Statistics Agency, 2011b). The two constituencies have a population density of 0.6 people km2 for Daures and 0.9 people per km2 for Karibib.

On a local level, the site Farms of Hakskeen and Sukses have a total of -+30 people combined who mostly reside in the coastal towns as well as Arandis, Karibib and Usakos. The residents who reside in the towns have moved there due to employment opportunities and provision of basic services such as schools, clinics, etc.

4.2.2 Economic Development The Coastal Zone of the Erongo Region is predominantly urban, because of the unique character of the landscape, which precludes agriculture. The population is thus concentrated in the urban areas of Walvis Bay, Swakopmund, Arandis and Henties Bay and a few small settlements such as Langstrand and Wlotzkasbaken. The rural population in the coastal area includes a group of Topnaars (approx. 500 persons) residing along the Kuiseb River (Bender, 1999).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

According to the Erongo Regional Council (2015), the economy of the Erongo Region mainly depends on mining, fishing, agriculture, and tourism. The Mining Sector in the Erongo Region has been characterized by the establishment and expansion of several Uranium mines over the past decade due to an increased demand for this energy source. The Erongo Region also accommodates the mining of commodities such as gold, marble, granite, salt, and semi-precious stones.

The fishing industry is the third largest economic sector contributed about 6.6 percent cent to the Gross Domestic Product (GDP). The Region’s whole eastern part and certain western parts are characterized by livestock farming on commercial farms in the districts of Karibib, Usakos and Omaruru, and in the communal areas. The Erongo Region further offers some of the most spectacular and popular tourist destinations as well as a variety eco-, wildlife, cultural and adventure tourism opportunities (Erongo Regional Council, 2015).

According to the Namibia Statistics Agency (2011a), the main source of income in households in the Erongo Region comes from farming (3%), wages and salaries (73%), cash remittance (5%), business and non-farming (9%) and pension (8%).

Project Site area: area is generally dominated by a mixed age population of youth as well as pensioners, with a high level of unemployment and lack of economic activities because the area is under-developed. Accordingly, most families on the two directly affected communal farms primarily rely on support income sourced from the working force employed in surrounding towns such as Arandis, Karibib and Usakos.

4.2.3 Project Site Land Use

4.2.3.1 Farming Both Hakskeen and Sukses farms are communal farms mainly occupied by different families. Due to water scarcity in the area means of making a living on these farms is very limited and for this reason a number of these farmers are resided in nearby towns such as Usakos, Arandis, Henties Bay and Karibib where some of them are employed. Most of the areas on the farms are sitting barren with no signs of active wildlife. Personal communication with farmers revealed that gemsbok, springbok and to a limited extend Kudus used to be dominant wildlife on the farms but these have since disappeared either due to drought, hunting and possibly migration triggered by scarcity of water. Small scale farming of small stock such as sheep and goats was evident on either farm during the site assessment (please refer to Figure 19 below).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 19: Some of the small livestock (goats and sheep) on the site farms

4.2.3.2 Mining There are also signs of abandoned dimension stone quarries on farms Hakskeen and Vergenoeg (see photos of abandoned quarry on Farm Hakskeen in Figure 20), suggesting that there is some level of disturbance and that the targeted area is not pristine. The unrehabilitated scar left by historical mining on farm Vergenoeg is visible from the B2 tarred road between Usakos and Arandis and is generally sour to the eye as the rocks mined there are white and give off a high reflection.

Figure 20: The abandoned quarry site on Farm Hakskeen

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

4.2.4 Archaeology and Cultural Environment The most abundant traces of human occupation in the Namib Desert are stone artefacts. These are easily recognizable as isolated finds and as surface scatters on the gravel plains of the Namib. Other less common traces include shell middens (usually within less than 5 km of the coast), natural rock shelters with evidence of occupation, including rock art, and stone features such as hut circles, hunting blinds and grave cairns. Historical sites include cemeteries, old mine workings, and remnants of World War I military camps. While some kinds of archaeological sites such as the larger grave cairns are highly visible, their significance is not obvious (Kinahan, 2012).

According to Kinahan (2020), due to its aridity, western Namibia including the vicinity of Arandis and the proposed Okonde project location, presents a marginal environment for human occupation, and in the past, particularly during periods of climatic cooling and hyper-aridity, the region may have been quite inimical to settlement. These conditions are reflected in the available archaeological evidence, which spans the last 0.8 million years with a sequence that is characterized by short periods of relatively intensive occupation, and long periods in which there appears to have been little or no human presence.

The region surrounding Arandis has been the focus of several archaeological surveys and assessments during the last two decades. These surveys have helped to determine the local archaeological sequence and to establish the relationship between archaeological sites and the types of terrain that characterize the area, including gravel outwash fans, granite outcrops and the many dolerite ridges that criss-cross the landscape. However, archaeological surveys for mining and infrastructure projects are highly focussed on the area of a particular project footprint and do not therefore as a rule reflect the wider archaeology of the area.

A detailed foot survey of the area surrounding Mining Claims 71609-71617 on the farms Sukses and Hakskeen was conducted by Dr John Kinahan (the Archaeologist) on 26 and 27 September 2020. The survey yielded several late pre-colonial archaeological sites related to grass seed exploitation and hunting of migratory antelope. These sites included both seed diggings and grinding sites as described in the previous section as well as a few stone hunting blinds. However, only a small number of seed digging sites fell within the indicated boundaries of Mining Claims 71609-71617 as shown in Figure 21. These sites do not include any cultural material or other artefacts and are therefore not considered to be significant.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Figure 21: Mining Claims 71609-71617 on farms Sukses and Hakskeen (small polygons) shown in relation to previously known archaeological sites (green squares) and archaeological sites found during the present survey (red squares), source: Kinahan, 2020

According to Kinahan (2020), in summary, the area to be affected by Mining Claims 71609- 71617 on the farms Sukses and Hakskeen does not contain any significant archaeological sites that fall directly within the mining claims. On the other hand, it should be stressed that there has been no information provided on the layout of access tracks, waste rock dumps, field camps or any other infrastructure that may affect the archaeology of the area.

Further and detailed information on the Archaeological environment of the site area as conducted by Kinahan (2020) can be found in the Archaeological Report attached as Appendix J of this document.

4.2.5 Services Infrastructure In terms of local services infrastructures, the following are available in the area:

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

• Roads: The Erongo Region is connected to the rest of the country by the B1 and B2 main roads. The B2 which passes through Arandis connects the project site area to Windhoek and Swakopmund. The project site, surrounding farms and settlements are then connected to this main road by local gravel (access) roods. • Electricity: power supply is supplied by the Erongo Regional Electrical Distributor (ErongoRed). ErongoRed is responsible for the supply and distribution of electricity to the Region, combining the electricity distribution departments of the Local Authorities, Regional Councils and NamPower. The project site is in a rural set up of the area where some farms may be connected to the Regional power grid, whereas some may be relying on other sources of energy like domestic solar and generators. • Water: is supplied in bulk to industries, municipalities by NamWater (the bulk water supplier). NamWater abstracts water from the large Kuiseb River and Omaruru delta (model) aquifers, which is then pumped to several reservoirs that provide water to towns in the Region such as Walvis Bay, Swakopmund, Henties Bay, Arandis and the mining industry. Water in the rural areas is either supplied by the Directorate of Rural Water Supply or through privately owned boreholes on farms.

In terms of basic services for the site, there is a school and clinic in the Spitzekoppe area on which all surrounding farms rely.

As required by Section 21 to 24 of the EIA Regulations, the public needs to be consulted and involved in the environmental assessment process. The public was consulted and involved as presented under the next chapter.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

5 PUBLIC CONSULTATION PROCESS The Public Consultation process aims to ensure that all persons or organizations that may be affected or interested in the project are informed of potential issues and can register their views and concerns. Building from there, the process provides opportunities to influence the project design so that its benefits can be maximized, and potential negative impacts be minimized. The current best practice model is to engage in a process of continuous dialogue with the affected community and other stakeholders as plans for the project evolve and the environmental assessment is prepared. A high level of interaction is maintained, potential and real social and environmental impacts are identified, and community needs, and concerns are discussed and wherever possible built into the planned activities of the project, including decision-making and management practices. Good consultation helps foster genuine and positive relationships with mutual respect, shared concerns and objectives between the company pursuing the development and the community.

The public participation facilitator’s role is to facilitate that process of dialogue to ensure there is transparency and accountability in decision-making and public confidence in the proposed project and its management.

5.1 Registered Interested and Affected Parties (I&APs) At the beginning of the environmental assessment process, a list of stakeholders who needed to be informed about the proposed project was drawn up. As the public participation process evolved, this list of Interested and Affected Parties (I&APs) was continuously updated. A complete summary of the I&APs identified and registered for the project can be found in Appendix C. The pre-identified I&APs were informed about the ESA process by email and additional I&APs registered their names upon seeing the newspaper adverts and at the public consultation meeting held for the project.

The summary of registered groups of I&APs or their representative bodies is as follows:

• Central or national government: Ministry of Environment, Forestry & Tourism, Ministry of Mines & Energy, Ministry of Works & Transport, Ministry of Agriculture & Land Reform, Ministry of Urban &Rural Development, National Heritage Council of Namibia (under the Ministry of Education, Ats & Culture) • Regional government: Erongo Regional Council, Karibib, Arandis and Daures Constituencies • Local authority: Karibib Town Council, Usakos Village Council and Arandis Town Council • Traditional Authority: !Oe#Gan Traditional Authority • Parastatals: NamWater, Roads Authority, TransNamib, Epangelo Mining

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• Non-governmental organisations (NGOs): Namibian Chambers of Mine, Botanical Society • Members of the public including land/farm owner or occupiers of land: Namib Plains, Farming and Tourism cc (Namib Plaas 93), Farm Valencia 122, Nagenoeg Investment (Pty) Ltd (Farm Vergenoeg 92), Farm Trekkopje, Farm Suskses 90, Karibib Farmers Association, Namibia Botancial Gardens CC, Farm Black Range, Klein Spitzkoppe, Kameroenpost, Uiba-oascoop, Farm Hakskeen, farm Sandamab, Farm TOS 1, Farm Maronika, Farm Kruising, Black Range Pos, Satamab Noord and Usakos (Headman)

5.2 First Round of Public Consultation: Summary of Activities Undertaken To ensure that the I&APs were adequately consulted and involved, the following activities were undertaken:

• A list of pre-identified I&APs was compiled and updated as new I&APs showed interest and requested to be registered. The majority that makes up the pre-identified I&AP list are farmers or occupiers of land overlain by the mining claims. Further I&APs included representatives from government institutions (ministries, regional and local authorities) and representatives from non-governmental organisations (NGOs). • A notification email with BID was distributed to all preidentified I&APs whose email addresses were available, on 17 June 2020. • Public notices announcing the commencement of the EA and an invitation to register as an I&AP were placed in Die Republikein and Allgemeine Zeitung newspapers (dated 17 June 2020 and 20 July 2020 in The Namibian Sun – please refer to Appendix D). • Site notices were placed at the relevant constituency offices, radio announcements by the project area Chief Usa Uiseb, and by word of mouth.

5.2.1 Consultation/Public Meetings A face-to-face public meeting was held at the water point on Farm Hakskeen. Another face to face-to-face consultation meeting was also held with the local traditional authority representatives on site. A virtual consultation meeting was also undertaken with the authorities (national, regional, and local). The details of these meetings are as given in Table 6 below.

Table 6: Details of consultation meetings held

Meeting with Venue & Date Invitees Organs of State Virtual (zoom), 9th July 2020, Daures, Karibib, & Arandis constituency; 10h00 Roads Authority, Namwater, MME, MEFT, Department of Water Affairs; Ministry of Urban & Land Development; Erongo

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Regional Council;

!Oe#Gan Traditional Farm Black Range, 25th July !Oe#Gan Traditional Authority personnel Authority (representing 2020, 10h30 (chiefs, headmen, senior councilors) directly affected farms, Trekkopje, Hakskeen & Sukses)

Public Farm Hakskeen water point, Public 25th July 2020, 14h00

At each of the consultation/public meetings (Figure 22), a presentation was given by OMAVI Geotechnical and Geo-environmental Consultants cc (with the assistance of a local translator). The presentations entailed an outline of the project, the environmental assessment process and the main potential issues or impacts identified to date. Issues that were raised in both Afrikaans and Damara-Nama were summarized and translated into English. The audience were invited and strongly encouraged to give comments, either verbally during the meeting or written on paper. They were also encouraged to send comments later by e-mail either individually or through their traditional esteemed traditional authority.

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Figure 22: Some photos taken at the public meeting at the farms on site

The meeting minutes were compiled and e-mailed to all those registered as I&APs who had e-mail addresses in July 2020. The meeting minutes are attached to this document as Appendix E.

5.2.2 Public Site Notices Site notices/posters informing the public and affected communities of the proposed project and ESA process were placed at the following strategic locations:

• Official notice board at the Karibib and Daures Constituency offices (Figure 23) • The main gate to Farm Sukses from the B2 main/national road (Figure 24 – left hand side photo). • At the turn off board to Farm Hakskeen from the D3716 district road to Henties Bay. • At the Erongo Regional Council notice board in Swakopmund (Figure 24 – right side photo).

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Figure 23: Public notices at the Karibib and Daures Constituency Offices’ notice boards

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Figure 24: Some of the site notices at Farm Sukses (left) and Erongo Regional Council (right)

5.3 First Round of Public Consultation Feedback: Issues &Concerns There have been several issues raised by different I&APs, most of which are like one or the other. Although these issues were not considered very crucial for the assessment, and compilation of this document, they were not critical with the potential to stop the proposed exploration and mining activities. Regardless, the issues were recorded as received for consideration and feedback.

All comments, concerns, issues, and feedback regarding significant issues received from I&APs (including authorities) have been summarised below, responded to or clarified as part of the impact and issues assessment under Chapter 6 (including feedback that does not raise significant issues). A copy of all the original email and written correspondence is attached as Appendix F.

These issues (potential adverse impacts) have been summarized as follow:

• Physical disturbance of soils and land surface/environmental damage due to exploration and mining activities. • Impact on farm and surrounding services infrastructure such as roads, water, fences and gates, potential water pipelines damage by heavy tracks. • Soil and groundwater pollution from potential project waste. • Lack of proper liaison between project Proponent and farmers or occupiers of land • Potential increase in noise level from project activities. • Impact on air quality (dust generation). • Impacts on general roads/vehicular traffic (linked to the project activities). • Impact on water quantity/aquifers (water demand and availability). • Impacts on biodiversity (fauna and flora) to enable project activities and firewood for exploration camps. • Impact on aesthetics (visual impact).

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• An issue of site rehabilitation during and or after exploration and mining activities have ceased. • Adverse impact of the proposed activities on the heritage (archaeological) sites and objects that are very common in the project site area and surroundings.

5.4 Second Round of Public Consultation: Draft ESA Report Review The draft ESA Report with all its appendices was circulated to all registered I&APs for review and comments for a period of eleven (11) days, i.e., from 17 August 2020 to 27 August 2020. The Report circulation to all registered I&APs was done via emails, for those with access to email addresses and a hard copy for those without email access.

The identified impacts and issues raised that are likely to affect the biophysical and social environment of the project site and surrounding area are described and assessed under the following chapter. The mitigation measures are also provided under the respective potential impacts in the same chapter.

6 IMPACT IDENTIFICATION AND ASSESSMENT The proposed exploration and mining activities are expected to have various impacts on the immediate and surrounding socio-economic and biophysical environment. Understanding these impacts, especially the negative ones and their significance will aid in providing the suitable mitigation measures. The provided or recommended measures can then be implemented to reduce or minimize the impacts’ significance, and even avoid these impacts in certain instances. Some impacts might be insignificant while others might need special attention or even further investigation.

The chapter is aimed at presenting the positive and negative impacts that are anticipated from the project activities, their description, assessment, and mitigation measures thereof.

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6.1 Impact Identification The proposed project activities are associated with different environmental impacts, whether positive or negative. The general aim of an environmental assessment is to assess these impacts, mainly the negative ones as they are likely to cause more damage to the environment if measures are not properly taken and implemented. This is done to ensure that the negative impacts are adequately addressed so that an impact’s significance is brought under control, while maximizing the positive impacts. The potential positive and negative impacts that have been identified from the proposed exploration and mining activities are as follows:

Potential positive impacts:

• Socio-economic development through employment creation and skills transfer

• Improved geological understanding of the site area regarding dimension stone (dolerite)

• Investment opportunities into the area due to the global sought-after commodity such as the explored and mined dimension stone (dolerite).

• Contribution towards national economy through the payment of taxes and royalties to the responsible institutions of the Government of the Republic of Namibia. Potential negative impacts:

• Impact on water resources (groundwater) in terms of quantity (over-abstraction) to meet project water demand.

• Loss of biodiversity (fauna and flora) through the removal of vegetation that may be found within the project footprints (for both exploration and mining). The moving of some site rocks may lead to loss of habitats for small animal species like reptiles that live under these rocks. Movement of heavy project vehicles may disturb the local livestock grazing on the farms and around the project site.

• Impact of poor communication (proper liaison) between the Proponent and the farmers or occupier of land with regards to the project activities.

• Air pollution by potential dust and gas emissions from exploration and mining activities.

• Vehicular traffic: potential increase in local traffic due to project activities; related vehicles. A potential impact on general road use.

• Impact on farm and surrounding services infrastructure such as roads, water, fences and gates, potential water pipelines damage by heavy trucks

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• Health and safety: improper handling of site materials and equipment may cause health and safety risks.

• Noise (nuisance): potential increase in noise level generated by machinery and vehicles may lead to nuisance to locals.

• Physical Soil disturbance to enable exploration and subsequent mining works.

• Soil and water pollution: improper handling of wastewater may lead to surrounding soil pollution and water resources systems.

• General environmental pollution through mishandling of waste leading to environmental pollution.

• Archaeological or cultural heritage impact through uncovering and damaging of archaeological objects or sites from unintentional project activities such as drilling and excavation on selected explored and mined sites of the mining claims.

• Visual impact from the mined-out areas on the project sites may pose as an eyesore to travellers (including tourists) using the B2.

• Social nuisance and property disturbance: The presence of strangers (out-of-area project workers) in the area may lead to sexual relations between them and the locals, which may encourage unprotected sex leading to sexually transmitted diseases (STDs) such as HIV/AIDS. Some of the project workers may damage and or intrude private properties belonging to the farmers.

6.2 Impact Assessment Methodology The methodology used to assess and determine the significance of the above-listed potential project impacts on the biophysical and social environmental components is as explained below.

6.2.1 Impact Assessment Screening The potential impacts identified by Interested and Affected Parties (I&APs), presented as issues during public consultation period and by OMAVI Consultants based on professional experience was screened according to a set of questions (Figure 25). This resulted in highlighting the key impacts requiring further detailed assessment of each impact in the respective sections of this chapter.

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Figure 25: Screening process for determining key impacts (source: Resilient Environmental Solutions, 2019)

6.2.2 Impact Assessment Criteria The methodology employed for this assessment was adopted from other environmental assessment reports based on research and analysis of other consultants’ reports (GCS Water & Environmental Consultants, 2017) on the suitable project impacts’ assessment methodology.

The proposed exploration and mining activities will likely to some scale/extent (spatial scale), magnitude (severity) and duration (temporal scale) have impacts on certain biophysical and social components. The potential impacts were assessed as per criteria presented in Table 7. To enable a scientific approach to the determination of the environmental significance, a numerical value is linked to each rating scale. This methodology ensures uniformity and that potential impacts can be addressed in a standard manner so that a wide range of impacts are comparable.

It is assumed that an assessment of the significance of a potential impact is a good indicator of the risk associated with such an impact. The following process will be applied to each potential impact:

• Provision of a brief explanation of the impact.

• Assessment of the pre-mitigation significance of the impact; and

• Description of recommended mitigation measures.

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The recommended mitigation measures prescribed for each of the potential impacts contribute towards the attainment of environmentally sustainable operational conditions of the project for various features of the biophysical and social environment.

Table 7: Impact Assessment Criteria employed for the OME exploration and mining activities

Nature Description Rating Extent (Spatial scale) An indication of the physical Low (1): Impact is localized within the and spatial scale of the impact. site boundary: Site only.

Low/Medium (2): Impact is beyond the site boundary: Local.

Medium (3): Impacts felt within adjacent biophysical and social environments: Regional.

Medium/High (4): Impact widespread far beyond site boundary: Regional

High (5): Impact extend National or over international boundaries.

Duration The timeframe, over which the Low (1): Immediate mitigating impact is expected to occur, measures, immediate progress measured in relation to the Low/Medium (2): Impact is quickly lifetime of the project. reversible, short term impacts (0-5 years)

Medium (3): Reversible over time; medium term (5-15 years).

Medium/High (4): Impact is long-term.

High (5): Long term; beyond closure; permanent; irreplaceable or irretrievable commitment of resources

Intensity, Magnitude / The degree or magnitude to Medium/low (4): Low deterioration, Severity (Qualitative which the impact alters the slight noticeable alteration in habitat criteria) functioning of an element of the and biodiversity. Little loss in species environment. The magnitude of numbers. alteration can either be positive Low (2): Minor deterioration, nuisance or negative or irritation, minor change in species / habitat / diversity or resource, no or very little quality deterioration.

Probability of occurrence Probability describes the Low (1): Improbable; low likelihood;

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Nature Description Rating likelihood of the impacts seldom. No known risk or vulnerability occurring. This determination is to natural or induced hazards. based on previous experience Medium/low (2): Likely to occur from with similar projects and/or time to time. Low risk or vulnerability to based on professional judgment natural or induced hazards.

Medium (3): Possible, distinct possibility, frequent. Low to medium risk or vulnerability to natural or induced hazards.

Medium/High (4): Probable if mitigating measures are not implemented. Medium risk of vulnerability to natural or induced hazards.

High (5): Definite (regardless of preventative measures), highly likely, continuous. High risk or vulnerability to natural or induced hazards.

6.2.3 Impact Significance This is determined through a synthesis of the above impact characteristics (in Table 7 above). The significance of the impact “without mitigation” is the main determinant of the nature and degree of mitigation required. As stated in the introduction to this chapter, for this assessment, the significance of the impact without prescribed mitigation actions was measured.

Once the above factors (Table 7) have been ranked for each potential impact, the impact significance of each is assessed using the following formula:

SP = (magnitude + duration + scale) x probability

The maximum value per potential impact is 100 significance points (SP). Potential impacts were rated as high, moderate, or low significance, based on the following significance rating scale (Table 8).

Table 8: Impact significance rating scale

Significance Environmental Significance Points Colour Code

High (positive) >60 H

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Significance Environmental Significance Points Colour Code

Medium (positive) 30 to 60 M

Low (positive) <30 L

Neutral 0 N

Low (negative) >-30 L

Medium (negative) -30 to -60 M

High (negative) >-60 H

For an impact with a significance rating of high, mitigation measures are recommended to reduce the impact to a low or medium significance rating, provided that the impact with a medium significance rating can be sufficiently controlled with the recommended mitigation measures. To maintain a low or medium significance rating, monitoring is recommended for a period to enable the confirmation of the significance of the impact as low or medium and under control.

The assessment of the project impacts is done for both pre-mitigation (before implementing any mitigation) and post-mitigation (after mitigations are effectively implemented).

The potential impacts listed under section 6.1 are described and assessed under the subsequent sections.

6.3 Positive Impacts: Description and Assessment

6.3.1 Socio-economic development (Employment and Social Responsibilities) A. Employment Creation

The exploration and if found to be feasible, the mining phase will create job opportunities for the locals (both skilled, semi and unskilled), resulting in socio-economic development through employment creation and skills transfer. The Proponent ‘s partner (Best Cheer Investment Namibia) currently employs about five-hundred (500) people on their existing dimension stone operations and associated processing facilities in Walvis Bay and Karibib. Some of these operations are reaching their end, which would mean loss of employment by the employed people.

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To ensure that their employees also keep their jobs and continue to make a living, the proposed exploration and subsequent mining activities on the nine mining claims would assure the existing employees of their income and creation of income for the new people who will be employed on the project. Due to data protection and privacy, the specific details (such as names and contact numbers) of the people employed by the ongoing operations cannot be included in this document and published. Therefore, OMAVI Consultants suggest that if any I&AP or other member of the public is interested in this information, they can do so by requesting it from and or arranging with Best Cheer Investment Namibia directly.

The skills transferred to these workers (existing and new ones) will ensure improved employability for those workers in the industry or at other similar project operations in future (even after the Proponent and their partner cease operations). The income earned by the employed locals (workers) will positively impact their lives, individually and that of their households (families). This impact is assessed as follows.

• Impact type: positive

• Extent: Local to regional

• Duration: short-term for exploration, but since the same employees are likely to be kept and continue with the mining phase (should exploration yield favorable results), it would turn into long-term.

• Probability: Probable

• Significance (no mitigation): Low, Significance (post-mitigation): medium

• Mitigation measures: Namibian citizens and permanent residents from the locally affected area should be employed for the unskilled labour preferentially to out-of- area people (outsiders) where possible. Out-of-area employment should be justified, for example by the unavailability of local skills only.

- Equal opportunity should be provided for both men and women, when and where possible.

B. Corporate Social Responsibility

In addition to employment created (by Best Cheer Investment Namibia) and to be created (from the Proponent and Best Cheer Investment Namibia’s partnership), Best Cheer Investment Namibia, with their ongoing operations are committed to corporate social responsibility. They have been doing this by supporting the Ojihorongo Primary School for about 5 years now and others. The details of how this is done can be obtained from Best Cheer Investment directly.

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6.3.2 Socio-economic development (Value Added Taxes and Royalty) Once proved to be economical in the exploration phase, the mining and sale of the processed dimension stone (off site) will result in the payment of national taxes and royalties to the responsible institutions of the Government of the Republic of Namibia. This will contribution towards national economy from the mining sector. The impact assessment is as follows:

• Impact type: positive

• Extent: Local to national

• Duration: Long-term

• Probability: Probable

• Significance: medium

• Mitigation measures: The Proponent to ensure compliance with their project’s requirements by the National Tax Agency (Inland Revenue) and Ministry of Mines and Energy on payment of taxes and royalties, respectively.

6.3.3 Improved geological understanding of the site The geological information reviewed and gathered during the exploration phase and eventual mining will be made available to the Ministry of Mines and Energy. The Ministry would then consolidate the information as a public institution for archiving and future use a baseline for projects or educational research. This impact is assessed as follows:

• Impact type: positive

• Extent: Local to national

• Duration: Long-term

• Probability: Probable

• Significance: medium

• Mitigation measures: The Proponent to ensure availability and accessibility of exploration findings to the responsible department at the Ministry of Mines and Energy (Mines Department and possibly Geological Survey of Namibia) for archiving.

6.3.4 Investment opportunities The demand for the mined and processed dolerite globally may potentially attract investment not just for the project area but elsewhere outside the project site area where the dimension stone deposit may occur. More investors may develop interests to invest further in the Namibia’s exploration and mining sector. The impact assessment is as follows:

• Impact type: positive

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• Extent: national to international

• Duration: Long-term

• Probability: Probable

• Significance: medium

• Mitigation measures: Not applicable.

6.4 Negative Impacts: Description and Assessment Although the project is divided into two phases (exploration and mining), given the similarity in most of the activities, some of the potential impacts are likely to occur in both phases. Therefore, these impacts have been described and assessed collectively, but where attention is required for one of the phases specifically, this have been indicated as such. This is done to avoid repetition of information on the same component/impact and therefore, preventing confusion to the readers.

The mitigation measures are also provided under each assessed impact. These measures are then ‘’translated’’ into management plan actions in the project’s Environmental Management Plan (EMP).

6.4.1 Impact on Groundwater Quantity (Over-abstraction) Groundwater resources is impacted by project developments/activities in two ways, namely through pollution (water quality) or over-abstraction (water quantity) or at times both. However, this section only deals with the impact on water quantity with regards to the water requirements given under Chapter 2 (the quality is discussed under the next sections). The detailed assessment of the impact on groundwater resources is outlined in the Groundwater (Hydrogeological) Impact Assessment Report attached to this Report as Appendix G.

Based on the groundwater potential map, it could be clearly seen that groundwater resources in the project area are already scarce. The abstraction of more water than it can be replenished from an area with low and limited groundwater potential would negatively affect the local communities (farmers) that depend on the same ("struggling") groundwater resource (aquifer) and low yielding boreholes.

The impact of the project activities on the resources would be dependent on the water volumes required by each project activity (exploration and mining). Commonly exploration activities use a lot of water, mainly in drilling. However, this depends on the type of drilling methods employed (diamond drilling is more consuming compared to drilling methods such as reverse circulation for instance) and the type of mineral being explored for.

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The required water for exploration (5 000 litres per day) will be used for drilling purposes and cooling drilling equipment. Given the low groundwater potential of the project site and area, the required water will be carted into the area from outside. The proposed option will be to supply the project from the Proponent’s Warehouse water supply in Swakopmund and stored in industry standard water reservoirs/tanks on site. Although exploration may be requiring a lot of water, this would also be dependent on the duration of the exploration works and number of exploration boreholes required to make reliable interpretation on the commodity explored for.

In terms of water abstraction and use for mining, the project activities will not use a significant amount of water that would impact the resources in the area as only about 6 000 litres will be required per day. The water will be sourced from a local borehole within the site boundary that will be rehabilitated to a new groundwater level to be able to supply the project. This volume can still be considered reasonable for the project, however, given the potential of local aquifers, the borehole may not be able to supply that amount as needed (even after rehabilitation). Therefore, abstraction from local aquifers may need to be complemented by carted water from areas with good water availability (potential) to ensure that demand pressure is less on the local aquifers, i.e., from areas with little to no water availability issues. Should it come to light that the rehabilitated old borehole cannot not even supply the minimum of water volumes required, then the Proponent may need to have a new borehole sited, drilled and installed in a carefully studied area with the mining claims’ site boundaries.

Without the implementation of any mitigation measures, the impact can be rated as medium, but upon effective implementation of the recommended +measures, the impact significance would be reduced to low as presented in the Table 9 below.

Table 9: Assessment of the project impact on water resources abstraction (quantity)

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 M/H - 4 L/M - 4 M/H - 4 M - 44 Post mitigation L/M - 2 L/M - 2 L - 2 L/M - 2 L - 12 Mitigation measures (please refer to the Groundwater Assessment Report) • The groundwater abstraction and use should be controlled by Regulation, i.e., water abstraction and use permit. As required by the Water Act that all activities that uses water for commercial purposes, the Proponent should apply for and obtain a Water Abstraction and Use Permit from the Department of Water Affairs’ Directorate of Water Resources Management. The Proponent will be required comply with the conditions set in the Permit. With regards to the two project activities, the specifications are as follows:

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o Exploration: No need for a permit. Although it is part of the overall project, the activities are not yet for commercial purposes. This is true because during this stage, the Proponent is still in the process of verifying the size and quality of the host rock deposit and evaluating feasibility for the actual quarrying of the dimension stone (economically feasible). For this phase, water will be carted from outside the project site in water tanks and use will be limited to exploration activities only (short-term), pending deposit evaluation and meeting criteria for commercial extraction in the next phase. o Mining: Once the dimension stone deposits are verified and have met the criteria for mining viability, the Proponent will have to apply for the Groundwater Abstraction and Use Permit (GWAUP) prior to commencing with mining activities. This permit must be applied for and obtained from the national Department of Water Affairs (DWA) at the Ministry of Agriculture, Water and Land Reform (MAWLR) to regulate and manage water abstracted from borehole for the project. In the Permit, the Water Regulatory Authority would set objectives (abstraction targets), conditions, annual abstraction threshold, monitoring requirements and enforce compliance by the Proponent.

• As part of the commercial water user’s responsibilities, an annual report that includes water returns and any new changes to the water use should be prepared and submitted to the responsible unit of the DWA. Reporting will be used as a tool by the Regulatory Authority to ensure that monitoring implementation is effective, and that the Proponent commits and complies with the water resources management legislation. This action also enables the Authority to make further informed decisions on groundwater management and protection.

• There is a ‘’potential water source’’ (borehole) within the site area (on Farm Hakskeen - located at 21°57'22.23"S 15° 8'49.76"E and as shown under Figure 12 of the Groundwater Report) that is planned for rehabilitation. The rehabilitation will either entail the removal of pumping equipment from the borehole to re-drill the borehole to a new depth where water can be encountered or re-installation of the pump to lower it down to the new water level that may have dropped below the pump over time. The rehabilitated borehole would then be pump tested by a suitably qualified and experienced hydrogeologist or geologist so that it can supply (some of the) water for the mining activities. However, given the low potential of local aquifers and should it come to light that the rehabilitated old borehole cannot even supply the minimum of water volumes required, then the Proponent may need to have a new borehole sited, drilled, and installed in a carefully selected area within the mining claims’ site area.

• As per the preceding point, if it comes to siting a completely new borehole, this borehole should be carefully sited, drilled, installed and their sustainable yields determined during the aquifer test (pumping test) by a qualified and experienced hydrogeologist. The hydrogeologist will then recommend a safe (sustainable) abstraction yield for the site to the Proponent to ensure that the local aquifers are not stressed, i.e., not negatively impacted by this local over abstraction.

• Given the nature of the project area in terms of groundwater potential, the proposed new borehole may not be able to supply the required daily amount of water. Therefore, the Proponent should make provision for continued water carting to site to augment site water needs.

• During mining phase, the water user (Proponent) should consider voluntary water use reduction by sticking to the proposed threshold volumes. The proposed threshold for water abstractions are as follows:

o For the exploration activities, 5 000 litres (5 m3) per day or 155 000 litres (155 m3) per month, and

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o For the mining activities, 232 m3 or 2 232 000 litres per year (6 000 litres x 31 days = 186 000 litres per month or 186 m3 which is 2 232 m3 per year, i.e., 186 m3 x 12 months).

• Like with their previous operations, the Proponent should aim to use water efficiently, recycle and re-use where necessary and possible.

• To meet the water demand of 6 000 litres per day during the mining phase, a combination of site borehole water and water carting from Swakopmund (or anywhere else nearby preferred by the Proponent) should be considered to avoid further stressing of the already struggling site aquifers. In other words, it is recommended that 3 000 litres of the required water or less can be pumped from the site borehole (depending on the hydrogeologist’s recommendations from borehole pump testing). The remaining 3 000 litres of water or more should be supplied from areas with less water stress (better water availability) through water carting/trucking to site.

• Putting into consideration the low borehole yields in the project area, the project borehole should be pumped for 0.5 hours in a day (also as backed up by the Hydrogeologist’s pump test recommendations above) during mining to cover at least half of the required volumes of water while considering the minimum hourly yield that a borehole on a dark brown area of the groundwater map can provide. Therefore, the Proponent would need to pump this water from the borehole on certain days of the week only (not every day) and store the required water in industry standard water tanks on site. This is to avoid abstracting water from the borehole daily (which would stress the aquifers further) and allow the borehole water level some time to recover from the pumping.

• Water reuse/recycling methods should be implemented as far as practicable for both exploration and mining activities. The water used to cool off exploration and mining equipment should be captured and used for the cleaning of project equipment, if possible.

• The site borehole water should be used efficiently, i.e., by limiting water use to the intended project activities only. The aim is to ensure that general environmental sustainability is not compromised in terms of water supply to both the natural and social environmental components that depend on this already struggling water resource.

• Water conservation awareness and saving measures training should be provided to all the project workers in both phases so that they understand the importance of conserving water and become accountable.

• The most important abstraction management plan is a GWAUP (permit/license), which clearly stipulates the amount of water that should be abstracted from an aquifer and outlines all the conditions that need to be complied with during abstraction. It is important that the Proponent strictly adhere to the abstraction volumes given in their water permit and if necessary, use less water. • Groundwater Monitoring: please refer to the EMP and Groundwater Assessment Report for monitoring exercises recommended during the mining phase

With that explained and assessed, the potential impact of the project activities on groundwater abstraction is slightly moderate (pre-implementation of mitigation measures/management plans). After the effective implementation of management measures, the impact significance will be reduced to low.

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6.4.2 Impact on Soils (Physical Land Disturbance) The exploration and mining activities such as excavations and land clearing to enable siting of project structures and equipment will potentially result in soil disturbance which will leave the site soils exposed to erosion. This impact is probable since most parts of the mining claims has very little to no vegetation or grass cover that would hold the soils in place with their roots and the fact that desert soils are prone to disturbance and erosion.

The impact can be rated as medium if no mitigation measures are implemented. However, with the effective implementation of mitigation measures and monitoring, the impact significance will be reduced to low. The impact is assessed in Table 10.

Table 10: Impact assessment of project activities on soils (physical disturbance)

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M/H - 4 M/H - 4 H - 5 M/H - 4 M – 52 Post mitigation L/M - 2 M - 3 L - 2 L/M - 3 L - 21 Mitigation measures • Overburden should be handled more efficiently during both exploration and mining operations to avoid erosion when subjected erosional processes

• Prevent creation of huge piles of waste rocks by performing sequential backfilling.

• Stockpiled topsoil and overburden waste rocks should be used to backfill the explored and mined and disturbed site areas/spots.

• Soils that are not within the intended and targeted footprints of the site should be left undisturbed and soil conservation implemented as far as possible.

• Project vehicles and machinery should stick to access roads provide and or meant for the project operations but not to unnecessarily create further tracks on site by driving everywhere resulting in soil compaction.

6.4.3 Soils and Water Resources Pollution In areas where activities such as extensive agricultural, mining, waste management and industrial activities are practiced with poor planning prior to project implementations, soil, and water, particularly groundwater pollution becomes one of the main environmental and social concerns. This mainly caused by improper storage and handling of hazardous waste such as hydrocarbons (fuel) spills, and wet waste such as effluents on project sites. These may lead to surrounding soil pollution and eventually water resources systems resulting into poor water quality.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

However, poor water quality does not only come from direct pollution from the ground surface, but also from over-abstraction of aquifers, especially the poorly recharged and managed ones. Given the nature, type and scale of the proposed project activities, groundwater vulnerability to pollution owing to the project activities is rather low - please refer to the Desktop Groundwater Assessment Report’s relevant section to understand why this is the case).

The anticipated potential source of pollution to groundwater resources from the project activities would be hydrocarbons (oil) from project (exploration and mining) vehicles, machinery, and equipment as well as potential wastewater/effluent from exploration and mining works. The spills (depending on volumes spilled on the soils) from these machinery, vehicles and equipment could infiltrate into the ground and pollute the already shallow and permeable aquifers on site, and with time reach further groundwater systems in the area.

The Groundwater Resources Vulnerability Map of Namibia in the Groundwater Assessment Report shows that the vulnerability of groundwater to pollution in the project area ranges from rather low to moderate. This vulnerability status could be explained by the geology of the site area that is mainly characterized by metamorphic rocks such as granites, dolerite, basalts, marbles, and schists. Groundwater is hosted in both these secondary aquifers (fractured or faulted rocks units) and at some places in unconsolidated sediments in this part of the Namib Desert. These rock units without any fractures/faults or joints are considered aquitards (rock units that restrict water flow or hardly transmit water from one rock unit to the other).

The main concern regarding groundwater pollution would be on areas that are underlain by fractured/faulted rock units or partly overlain by the limited sediments. These sediments or fractured rock structures would provide ready passage for pollutants into groundwater, but without faults or fractures, these rock units would behave as aquitards, but not aquifers. If there is a significant point source of pollution, the pollution vulnerability would be bound to fractured/faulted rock units, therefore low (for fractured/faulted rocks) and slightly moderate (for distinctive unconsolidated sediment aquifer areas).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Furthermore, although not significant, measured nor monitored, there could already be an existing pollution from other pre-proposed project (existing) anthropogenic activities undertaken in the site area. These existing activities or some of them could also have been the sources of such pollution. Therefore, it is of great importance to first assess the baseline (water quality) information pre-exploration and mining activities so that future pollution scenarios will not be solely pointed to the proposed project activities, but to also to consider the possibility of cumulative occurrence of such an impact (pollution) in the area given its proximity to the Rössing Mine. Groundwater pollution risk can also arise from low and prolonged periods of no recharge (less water with increased concentrations of groundwater chemical constituents) as well as localized pollution sources, in combination with the aquifer’s vulnerability to pollution.

Overall, the likelihood of significant pollution to groundwater in the project area is low due known low rainfall in the area and eventually little to no groundwater recharge, which could carry polluted water into the local aquifers.

From the above description of the impact, it can be concluded that without implementing any measures to avoid or minimize the impact, the impact significance will be moderate and once the mitigation measures have been implemented, the significance will be reduced to low. The assessment also presented in Table 11 below.

Table 11: Assessment of the project impact on groundwater resources (quality)

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 M/H - 4 L/M - 4 M/H - 4 M - 44 Post mitigation L/M - 2 L/M - 2 L - 2 L/M - 2 L - 12 Mitigation measures • Spill control preventive measures should be in place on site to management soil contamination, thus preventing and or minimizing the contamination from reaching groundwater bodies. Some of the soil control preventive measures are:

✓ Identification of oil storage and use locations on site and allocate drip trays and polluted soil removal tools suitable for that specific surface (soil or hard rock cover) on the sites. ✓ Maintain equipment and fuel storage tanks to ensure that they are in good condition thus preventing leaks and spills. ✓ The oil storage and use locations should be visually inspected for container or tank condition and spills. ✓ Maintain a fully provisioned, easily accessed spill kit. Spill kits should be located throughout the active project sites contain the floor dry absorbent material and absorbent booms, pads, mats. These would be suitable for ground surface areas that are covered mainly by hard rocks. ✓ All project employees should be made aware of the impacts of soil pollution and advised to follow appropriate fuel delivery and handling procedures. ✓ The Proponent should develop and prepare countermeasures to contain, clean up, and mitigate the effects of an oil spill. This includes keeping spill response procedures and a well-stocked cache of supplies easily accessible.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

✓ Ensure employees receive basic Spill Prevention, Control, and Countermeasure (SPCC) Plan training and mentor new workers as they get hired in each phase of the project.

• Exploration and mining site areas where hydrocarbons will be utilized, the surface should be covered with an impermeable plastic liner (e.g., an HDPE liner), carefully placed so as to minimize risk of puncturing, to prevent any spillages from getting into direct contact with the soils and prevent eventual infiltration into the ground.

• Project machines and equipment should be equipped with drip trays to contain possible oil spills when operated during exploration and mining works.

• All wastewater and hydrocarbon substances and other potential pollutants associated with the project activities should be contained in designated containers on site and later disposed of at nearby approved waste sites in accordance with MAWLR’s Water Environment Division standards on waste discharge into the environment. This is to ensure that these hazardous substances do not infiltrate into the ground and affect the groundwater quality.

• In cases of accidental fuel or oil spills on the soils from site vehicles, machinery and equipment, the polluted soil should be removed immediately and put in a designate waste type container for later disposal as per the preceding bullet point. The removed polluted soil should either be completely disposed of or cleaned and returned to where it was taken from on site or can be replaced with a cleaner soil. This is to ensure that the pollutants contained int the soil does not infiltrate into the site soils and eventually reach to groundwater.

• During the mining phase whereby fuel (diesel) storage tanks are fixed in one place, the containment (wall) of same or larger volume as the fuel tanks must be bunded around the tank. This is aimed at preventing accidental fuel spills or leaks from spreading to the soil and eventually to groundwater

• Although fuel (diesel) required for exploration equipment will be stored in a tank mounted on a mobile trailer, drip trays must be readily available on this trailer and monitored to ensure that accidental fuel spills along the tank trailer path/route around the exploration sites are cleaned on time (soon after the spill has happened).

• The fuel storage tank should be placed on a bunded and impervious surface.

• Polluted soil must be collected and transported away from the site to an approved and appropriately classified hazardous waste treatment facility.

• Washing of equipment contaminated hydrocarbons, as well as the washing and servicing of vehicles should take place at a dedicated area, where contaminants are prevented from contaminating soil or water resources.

• Toilet water should be treated using one of the following methods:

✓ Discharged into chemical toilets and periodically emptied out before reaching capacity and transported to a wastewater treatment facility. ✓ A type of pit latrine (where excreta in the pit is treated to prevent the waste from being a water pollution risk).

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

After assessing the site area based on the available information, literature and professional judgement, the impact of pollution on the groundwater resources, this impact is considered low. Furthermore, the project impact is short-term, i.e., the potential impact will only exist during the exploration phase and long-term for the mining phase following exploration works.

6.4.4 Impact on Biodiversity (Fauna and Flora) The proposed activities usually have some potential impacts on both surrounding fauna (animals) and flora (vegetation) and these are described below.

Fauna: As indicated under the Baseline Chapter, the project site currently only has livestock (goats and sheep) as they animals kept at the farms. The movement of heavy project vehicles may disturb the local livestock grazing on the farms and around the project site.

Regarding wildlife, some mammals such as springboks, gemsbok, kudus used to be in the area after good rain seasons. However, due to long dry seasons (lack of drinking water), farm resettlements and partly bush hunting contributed to the drastic reduction in the number of these mammals such that they are barely seen now in the area. Therefore, the impact on these is minimal to none.

Another potential impact of the project activities is the faunal habitat loss and reptiles and small mammals that live under the targeted rock units on the mining claims. Although this impact may not be entirely avoidable, the workers will be educated on the importance of conserving faunal biodiversity by not killing any of the small mammals or reptiles encountered at site. These animals may be trying to migrate from the targeted and disturbed rocks to seek shelter and habitat elsewhere, therefore, they would not be harmed in any way.

Flora: this impact is anticipated through the removal of already scarce vegetation that may be found within the project footprints (for both exploration and mining). This would be done to enable mining activities and movement of vehicles. The moving and displacement of some site rocks may lead to loss of habitats for vegetation and small animal species like reptiles that live under these rocks. The movement of project vehicles may also destroy the vegetation within project site tracks, especially small shrubs.

All these actions will potentially lead to the destruction of animal and plant species within the targeted exploration and mining sites within the mining claims. Thus, resulting in the loss of such species and eventual loss of biodiversity in the area. The project site area however is already poorly vegetated at some areas, thus minimizing the need to remove vegetation.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Consequently, given the already scarcity of plants (vegetation) in the project site area, the impact would be of slight medium significance, if no mitigation measures in put in place for implementation to protect the existing vegetation. This conclusion would also apply to the existing fauna (both farm livestock and site rock animal species). Therefore, to reduce the pre-mitigation impact significance from medium to low, the recommended measures in Table 12 below will need to be effectively implemented.

Table 12: impact assessment of project activities on biodiversity

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 M - 3 M - 6 M - 3 M – 36 Post mitigation L/M - 2 L/M - 2 L/M - 4 L/M -2 L - 16 Mitigation measures Flora

• The Proponent should avoid unnecessary removal of vegetation, thus promoting a balance between biodiversity and their operations.

• Vegetation found on the site, but not in the targeted mining areas should not be removed but left to preserve biodiversity on the site.

• Movement of vehicle and machinery should be restricted to existing roads and tracks to prevent unnecessary damage to the vegetation.

• No onsite vegetation should be cut or used for firewood related to the project’s operations. The Proponent should provide firwood for his onsite camping workers from authorized firewood producer or seller.

• Even if a certain shrub or tree is found along exploration and mining sites, this does not mean that it should be removed. Therefore, care should be taken when exploring and mining without destroying the site vegetation.

Fauna

• Workers should refrain from killing species (big or small and all types) that may be found on and around the site.

• Workers should refrain from disturbing, killing or stealing locals’ animals and killing small soil and rock outcrops’ species found on sites. This prohibition also applies to future re-appearance of wild animals in the area during good rain seasons.

• Environmental awareness on the importance of biodiversity preservation should be provided to the workers.

6.4.5 Visual impact Surface mining activities usually leave scars on the local landscape. If the mining sites are located close to or along roads or frequented areas, these scars in many cases contrasts the surrounding landscape and thus may potentially become a visual nuisance, especially in tourist-prone areas (Excel Dynamic Solutions, 2019). The project is located close to the B2 road that is used not only by local travelers and coastal holiday makers, but tourists too. The sight of the mined-out areas of the site may be an eyesore to those people.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Given the proximity of the mining claims to the B2 road (4 and 5 km from the two mining claim clusters), the impact can be felt by the traveller on this road due to the lack any other high structure like buildings, vegetation or mountain between the mining claims visible and the road to obscure the mined-out sites. The visual issue is already a concern for other dimension stone miners in the Erongo Region, especially those around Karibib who are mining the white marble from the mountain foot upwards. These existing mining activities leave white scars that are clearly visible from the nearby roads.

In comparison to the proposed dolerite mining, this dimension stone is dark in colour and its quarrying/mining would not leave such a huge contrast between the explored/mined-out areas and the mountain parts where it is extracted. Therefore, this impact can be rated as of medium significance. With progressive backfilling during and after exploration and mining activities, the significance can be reduced to low. This would reduce and improve on the already ongoing issue of visual nuisance owing to other dimension stone mining activities in the area/Erongo Region.

According to Ashmole and Motloung (2008), the correct location and construction of waste dumps can significantly assist in lowering the final reclamation cost for the quarry. Waste dumps that are constructed on flat areas should be built up in layers of 6-10 metres in height, with a terrace of at least 6 metres wide between the crest of one layer and the foot of the succeeding layer. In this way, the outside perimeter of a completed layer can be reclaimed concurrently with the dumping of the next layer.

Further, if the waste dump is planned in such a way that the final perimeter is constructed first, and then filled back towards the quarry, it is possible to reclaim the outside perimeters at a very early stage, thus reducing the visual impact during the operating phase of the quarry (Ashmole and Motloung, 2008).

Without consideration of the preceding paragraph and implementation of the mitigation measures provided in Table 13 below, the visual impact’ significance will be rated medium. However, upon careful and effective implementation of these, the impact significance can be reduced to low.

This impact is assessed in Table 13 and the mitigation measures thereof are also provided.

Table 13: Visual impact assessment

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 M/H - 4 L/M - 4 M/H - 4 M - 44 Post mitigation L/M - 2 L/M - 2 L/M - 4 L/M -2 L - 16 Mitigation measures • The Proponent should consider the implementation of continuous rehabilitation programme, by using overburden waste rocks.

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• The Proponent to utilize waste rubble to rock blind exposed rock faces and stockpiled topsoil to partially back fill.

• Please refer to section 6.7 on progressive rehabilitation of mined-out sites.

• The Proponent should carry out progressive working and restoration/rehabilitation over the shortest timescale possible, to avoid excessive areas of disturbance.

• Consider a phased exploration/mining and direct placement of overburden (topsoil and waste rocks) and other site-derived materials to allow progressive restoration around the margins of the explored and mined out site areas.

6.4.6 Noise The blasting and excavation activities as well as heavy vehicle movements associated with exploration and eventual mining on sites may lead to increase in noise level which can be a nuisance to surrounding site locals and immediate neighbours. High levels of noise may also pose a health risk to workers that are working within proximity to noisy equipment and machinery.

Particularly in granites quarrying, improvement in diamond wire sawing efficiency has significantly reduced the use of explosives in the extraction of blocks. This has resulted in higher recovery of saleable blocks and therefore less waste to be disposed of, as well as reducing the emissions of blasting gases (SO2 and NOX), noise and ground vibration (Ashmole and Motloung, 2008).

Excavations and blasting will be limited to a certain extent, exploration, and mining activities and within site boundaries only. The activities will be limited to working hours of the day only and five days in a week. With that said, noise level will be limited to the active worked sites only for the duration of the works on these sites, and therefore, the impact likelihood is minimal. The nearest neighbours (noise receptors) to the mining claims’ sites are the people who reside in the farms that are hosting the claims, that are located more than 1 km away.

With regards to project workers working with or operating noisy machines, they will be provided with appropriate personal protective equipment (PPE) during working hours and while onsite.

Without any mitigation measures being implemented, the impact is rated as of medium significance. To change the impact significance from the pre-mitigation significance to low rating, the mitigation measures have been provided for this. The impact is assessed in Table 14 below.

Table 14: Noise impact assessment

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 M/H - 4 L/M - 4 M/H - 4 M - 44

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Post mitigation L - 1 L/M - 2 L - 2 L/M -2 L - 10 Mitigation measures • The transportation of exploration and mining materials, equipment and machinery should be limited to once or twice a week only, but not every day.

• Noise from project vehicles and equipment on site should be reduced to acceptable levels.

• The exploration and mining times should be set such that, no such activities are carried out during the night or very early in the mornings (to be limited between 8am and 5pm on weekdays).

• Project (exploration and mining) hours should be restricted to between 8am and 5pm to avoid noise generated by project equipment and the movement of vehicles before or after hours.

• When operating the blasting and drilling machinery onsite, workers should be equipped with personal protective equipment (PPE) such as earplugs to reduce noise exposure.

• Target exploration and mining sites that may be found to be within less than 1 km from the residence (farmhouses) should be avoided at all cost. This is done to preserve some tranquillity for the residents.

• If the Proponent does not already have a blasting expert or the experience, an experienced blasting contractor should be hired to carry out exploration activities and mining phases in a professional manner such that noise is kept at minimum as a result of a very good ‘’know-how’’ with the utilized blasting machinery and equipment.

6.4.7 Vehicular Traffic The main road B2 is the main transportation route for all vehicular movement between Karibib and Walvis Bay (and the towns and settlements in between). Project associated heavy vehicles will obtain access to the site from the B2 road that connects the mining claims to exploration and mining activities’ service providers inland (water carting, exploration machinery, equipment, and others).

For exploration, water trucks will be frequenting the area once or twice a week to cart water to exploration sites on the mining claims. This would potentially increases slow moving heavy vehicular traffic along the B2. The impact would not only be felt by the B2 road users but the local road users from the B2 to the farms (via local access gravel and single-track roads). This would add additional pressure on the roads.

The time-to-time transportation of mined dimension stone to processing facilities in Karibib and Walvis and if need be, mining equipment may increase traffic in the area on certain days of the week or month when required. However, only so many times a week or even monthly that the exploration and mining related heavy trucks will be transporting materials and equipment from and to site, respectively, therefore the risk is anticipated to be short- term, not frequent and therefore of medium significance.

Pre-mitigation, the impact can be rated medium and with the implementation of mitigation measures, the significance will be low as assessed in Table 15 below.

Table 15: Vehicular traffic impact assessment

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 M/H - 4 L/M - 4 M/H - 4 M - 44 Post mitigation L/M - 2 L/M - 2 L - 2 L/M - 2 L - 12 Mitigation measures • The transportation of exploration and mining materials, equipment and machinery should be limited to once or twice a week only, but not every day.

• The heavy truck loads should comply with the maximum allowed limit while transporting materials and equipment/machinery on the public and access roads.

• The carted water into the area from Walvis Bay or other source of water supply should be done once or twice a week in container that can supply and store water for most of the week, thus reducing the number of trucks on the road on a daily basis.

• Drivers of all project phases’ vehicles should be in possession of valid and appropriate driving licenses.

• Vehicle drivers should adhere to the road safety rules.

• Drivers should drive slowly (40km/hour or less), and on the lookout for livestock and wildlife.

• The Proponent should ensure that the site access roads are well upgraded and in good condition to cater for vehicles travelling to and from site throughout the project’s life cycle

• Project vehicles should be in a road worthy condition and serviced regularly to avoid accidents because of mechanical faults of vehicles.

• Vehicle drivers should only make use of designated site access roads provided.

• Vehicles drivers should not be allowed to operate vehicles while under the influence of alcohol.

• Sufficient parking area for all project vehicles should be provided for and clearly demarcated on sites.

• The Proponent should make provision for safe materials and equipment offloading and loading areas on sites.

• No heavy trucks or project related vehicles should be parked outside the project site boundary or demarcated areas for such purpose.

• Truck movements, frequency, times, and routes should be carefully planned and scheduled – please refer to the next point.

• To control traffic movement on site, deliveries from and to site should be carefully scheduled. This should optimally be during weekdays and between the hours of 8am and 5pm.

• The site access road(s) should be upgraded to an unacceptable standard to be able to accommodate project related vehicles and access permits obtained from the Roads Authority.

• The site access road(s) should be provided for in such ways that they do not interfere with other traffic movement and/or compromise traffic safety on the host farms.

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6.4.8 Impact on Surrounding Air Pollution (Dust) The project activities and vehicles may potentially generate dust and gas emissions from vehicles (due to unpaved access roads). Dust emanating from site access roads when transporting project equipment and supply (water) to and from site (time-to-time) and blasting done at the pit may compromise the air quality in the area. This is likely because of the bare soils (very little to no vegetation cover) and dry condition of the project area.

According to Resilient Environmental Solutions (2019), dust generated from operating the geological drill rigs could result in the production of respirable dust (particulate matter smaller than 50 µm or even 10 µm in size), which could impact the respiratory health of the drill rig operators/workers. The dust produced might also settle on nearby vegetation and may affect rates of photosynthesis and transpiration. The settled dust on plant leaves may not only affect the vegetation's functionality but livestock that feed on the vegetation (i.e., browsing) too.

Furthermore, the main respiratory diseases related to inhaled mineral dusts include, pneumoconiosis (which includes silicosis, asbestosis, and coal miner’s pneumoconiosis), and cancer (including bronchogenic carcinoma and malignant mesothelioma). It should be noted however that the scale and nature of the operation (i.e., drilling for exploration purposes only) is such that prolonged and continuous exposure to mineral dust (as experienced during a full production mining operation) is not expected. Furthermore, the work environment – i.e., open air, is of such a nature that particulate matter is freely dispersed, as opposed to mineral dust generation within a confined space (Resilient Environmental Solutions, 2019).

Given the scale and nature of the activities (i.e., drilling for exploration purposes only), the impact on the rates of photosynthesis and transpiration of nearby plants are expected to be limited in extent and duration and therefore negligible. Furthermore, no range restricted species plant species are expected within the project area. However, the impact needs to be considered once the project progresses from exploration to mining phase.

The impact can be rated as medium (significance) if no mitigation measures are implemented. However, once this is done, the impact significance can be reduced to low - please refer to the assessment below (Table 16).

Table 16: Air quality impact assessment

Mitigation Status Extent Duration Intensity Probability Significance Pre mitigation M - 3 M/H - 4 M - 6 M - 3 M – 39 Post mitigation L - 1 L - 1 L - 2 L/M - 2 L - 8 Mitigation measures • Drill and excavating/blasting equipment should be regularly maintained to ensure drilling and excavation efficiency and so reduce dust generation.

• Dust masks, eye protective glasses and other respiratory PPE accessories should be provided to the

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

workers on site, specifically the ones exposed to dusty site area and activities.

• The impact mitigation measures should be covered in the relevant farm access agreement as required by law on commercial farms. This should also be considered for resettled farms.

• The Proponent should ensure that the project activities schedules are limited to the given number of days of the week, but not every day. This will keep the vehicle-related dust level minimal in the area.

• Since the project site is in an area where due to little vegetation cover, soils are exposed, it is highly probable that more dust will be generated from excavation and drilling works and heavy vehicle movements on bare dry soils. It is therefore advised that in extremely windy days, a reasonable amount of water should be used to supress the dust that may be emanating from certain exploration and mining areas at the sites. In other words, Dry dust suppression methods such as reasonable amount of water should be employed to minimise dust generation.

• The transportation of exploration and mining materials, equipment and machinery should be limited to certain days of the week only as so to reduce dust generated by heavy vehicles in the area.

6.4.9 Impact of Poor Communication (Proper Liaison): Proponent and Landowners For the exploration phase, a temporary residence of “outsiders” on farmland will be required (campsite) and because of this, some of the project workers may behave contrary to the wishes of the farmers/landowners or occupiers of land. Not only the workers’ potential unacceptable behaviors but other inconveniences to the landowners biophysical and social aspects related to the project activities. If not managed effectively, these have the potential to result in destructive conflicts between the Proponent and the owners of land on which the mining claims and project activities are being undertaken. Without any mitigation measures and their effective implementation (for example an appointment of a project Liaison/Public Relations Officer), this impact is rated as medium significant. However, upon implementation of the provided measures, the significance would be reduced to low. This potential impact is assessed below (Table 17).

Table 17: Impact of poor communication between the Proponent and farm owners or occupies

Mitigation Status Extent Duration Intensity Probability Significance Pre mitigation M - 3 M/H - 4 M - 6 M - 3 M – 39 Post mitigation L - 1 L - 1 L - 2 L/M - 2 L - 8 Mitigation measures • A Public Relation Officer (PRO) should be appointed for the project. They will be responsible for ongoing consultations (liaising) with the affected farmers/landowners as well as handling potential grievances related to the project activities, as and when required. • The PRO should be introduced to the farm/landowners and his or her contact details provided to them prior to undertaking activities for easy communication during the exploration activities and eventual mining. • The Proponent should compile a clear communication procedure/plan which should include a grievance and response mechanism.

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6.4.10 Impact on Farms and Surrounding services Infrastructure (roads, fence, and pipelines) The movement of vehicles such as heavy truck around private and even communal/public farms may lead to the destruction / damaging of buried farm or even public water pipelines and or power supply cables. This is likely to happen; especially during rainy seasons when the buried pipes get compacted or deformed once driven over by heavy vehicles.

Other impacts on farm infrastructure include farm gates being left open and heavy exploration machinery or equipment damaging farm fences if extensive work is done too close to the fences. This impact is assessed as follows in Table 18.

Without any implementation of the mitigation measures provided, the potential impact’ significance will be rated medium. However, upon effective implementation of these measures, the impact significance will be reduced to low.

Table 18: Assessment of impacts on local (farms) infrastructure

Mitigation Status Extent Duration Intensity Probability Significance Pre mitigation M - 3 M - 3 M - 6 M - 3 M – 36 Post mitigation L/M - 2 L/M - 2 L/M - 4 L/M -2 L - 16 Mitigation measures • A Public Relation Officer (PRO) should consult with the farmers to help in locating possible buried cables and pipelines on their properties (farms) to avoid damages to buried services such as water and power supply lines and cables. • If possible, heavy trucks should avoid driving over farm areas that are known to have pipelines or any related infrastructure buried. • The project personnel should be informed not to leave the farms' gates open, but close or lock them as instructed by the farm owners. • Project equipment and machinery should not be left leaning on the farm fences (using the fences as support). • Agreement and continued engagement with landowners / farm owners on use and maintenance of farm infrastructure (roads, fences, gates, boreholes, etc.) should be implemented and maintained.

6.4.11 Health and Safety Project personnel (workers) involved in the exploration and mining activities may be exposed to health and safety risks. These are in terms of accidental injury, owing to either minor (i.e., superficial physical injury) or major (i.e. involving heavy machinery or vehicles) accidents. The site safety of all personnel will be the Proponent’s responsibility and should be adhered to as per the requirements of the Labour Act (No 11 of 2007) and the Public Health Act (No. 36 of 1919). The heavy vehicle, equipment and fuel storage area should be properly secured to prevent any harm or injury to the Proponent’s personnel or local domestic animals.

The use of heavy equipment, especially during blasting and the presence of hydrocarbons on sites may result in accidental fire outbreaks. This could pose a safety risk to the project personnel and equipment and vehicles too.

Environmental Scoping Assessment Report: Exploration and Mining Activities on Mining Claims 71609-71617

If machinery and equipment are not properly stored and packed, the safety risk may not only be a concern for project workers but residents too, especially children, given the fact that the project sites are within farms, where children reside too. This is true because, the local children may try to access the active site areas and play with dangerous materials and equipment.

Another potential health risk stemming from the proposed project is the handling of project hazardous waste on site in relation to the local community. The impact is likely because some of the unsuspecting and uniformed local people may be wandering around and if they see improperly stored or kept empty hazardous containers on site, they may be tempted to take these containers without the site workers or Proponent's knowledge. The locals may then use the containers for domestic use like water and/or food storage without proper container treatment or cleaning. The storage of and eventual consumption of water and/or food from such containers may lead to serious health risks to the locals.

The impact can be rated as medium to slightly high to medium significant if no mitigation measures are implemented, but upon implementation, the impact will be of low significance (as per Table 19 below).

Table 19: Health and Safety impact assessment

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 M - 3 M/H - 8 M/H - 4 M – 56 Post mitigation L/M - 2 M - 3 L - 2 L/M - 3 L - 21 Mitigation measures • The Labour Act’s Health and Safety Regulations should be complied with.

• As part of their induction, the project workers should be provided with an awareness training of the risks of mishandling equipment and materials on site as well as health and safety risk associated with their respective jobs.

• When working on site, employees should be properly equipped with adequate personal protective equipment (PPE) such as coveralls, gloves, safety boots, earplugs, dust masks, safety glasses, etc.

• Heavy vehicle, equipment and fuel storage site should be properly secured, and appropriate warning signage placed where visible.

• Drilled boreholes that will no longer be in use or to be used later after being drilled should be properly marked for visibility and capped/closed off.

• Ensure that after completion of exploration holes, drill cuttings are put back into the hole and the holes filled and levelled.

• An emergency preparedness plan should be compiled, and all personnel appropriately trained.

• Workers should not be allowed to drink alcohol prior to and during working hours as this may lead to mishandling of equipment which results into injuries and other health and safety risks.

• Workers should not be allowed on site if under the influence of alcohol.

• The site to be equipped with "danger" or "cautionary" signs for any potential danger or risk area identified

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on site.

• Temporary enclosed boundaries should be erected around high-risk area sites for the duration of project activities at that specific site area. This is done to control access to the site, in such a way that the public, especially children do not access the site and play with equipment and machinery on days when no work is done.

• A security guard or guards should be part of the team so that they can look after the project equipment and vehicles that would be left on site in weekends or public holidays (when no work is done) to ensure that no unauthorized person enters the area.

• To discourage the unsuspecting and uniformed local community from eyeing the empty hazardous containers, the site workers should if possible, drill holes in these containers while kept on site (before transporting the containers to the waste site).

• All employees and contractors (personnel) to be trained on environmental awareness, the Proponent’s internal Environmental Health and Safety Policy, Environmental Management Plan, and engagement with key stakeholders, specifically the key government ministries and farmers.

• With regards to accidental fire outbreaks, the following should be implemented:

✓ Portable fire extinguishers should be provided on sites (per vehicle and working site). ✓ No open fires should be created by exploration and mining personnel. ✓ Potential flammable areas and structures such as fuel storage tanks should be marked as such with clearly visible signage.

6.4.12 Archaeological impact During exploration and mining activities, historical resources may be impacted through inadvertent destruction or damage. This may include the excavation of subsurface graves or other archaeological objects.

According to the assessment undertaken by Kinahan (2020), the area to be affected by Mining Claims 71609-71617 on the farms Sukses and Hakskeen does not contain any significant archaeological sites that fall directly within the mining claims. On the other hand, it should be stressed that there has not been any information provided about the layout of access tracks, waste rock dumps, field camps or any other infrastructure that may affect the archaeology of the area.

The conclusions drawn from the Archaeological Assessment by the Archaeologist were that the field survey of Mining Claims 71609-71617 on farms Sukses and Hakskeen confirmed the patterns known from the wider area surrounding Arandis in the west of Erongo Region with regards the archaeology of the later pre-colonial period. The survey located evidence of both wild grass seed exploitation and the hunting of migratory antelope by using the strategic advantages of natural gaps in dolerite ridge.

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Whereas these more common indications of late pre-colonial subsistence are sometimes associated with other evidence such as human burials and the occupation of rock shelter sites, no such evidence was found during the present survey.

Of the sites located during the survey a minority fell within the area of the proposed mining claims and these were of low significance. While it is permissible to conclude from the survey that the proposed exploration and mining activities would have little or no archaeological/heritage impact, it must be stressed that no information is available regarding the use of access tracks, stockpiling of waste rock and of stone to be removed for processing. The full footprint of the proposed activities has not been defined and the assessment of Mining Claims 71609-71617 on farms Sukses and Hakskeen is therefore qualified.

To add to the preceding paragraph with regards to access tracks, waste rock dumps, field camps and related infrastructure, the access tracks (roads) cannot be determined before the actual work starts. This is true because for exploration, the target areas are not predetermined as the exploration works to search for and select the suitable and economical and mineable spots on the mining claims will need to be verified before setting up any infrastructure. However, precautions will need to be taken by the Proponent and their project contractors to ensure that archaeological objects or sites that may be encountered on the site paths are undisturbed, reported to the NHC for protection.

Therefore, pre-mitigation measures, this impact can be rated slightly medium. Upon implementation of the necessary measures, the impact significance will be low. The assessment of the impact is shown in Table 20 below.

Table 20: Archaeological impact assessment

Mitigation Status Extent Duration Intensity Probability Significance Pre mitigation M - 3 M - 3 M - 6 M - 3 M – 36 Post mitigation L - 1 L - 1 L - 2 L/M - 2 L - 8 Mitigation measures • Caution should be exercised when carrying out excavations associated with the exploration activities if archaeological/heritage remains are discovered. • Identified of any archaeological significant objects on the site should not be disturbed but are to be reported to the project Environmental/Safety officer or National Heritage Council offices for further instructions and actions. • Workers should be educated to not destroy or throw away but report (to the Environmental/Safety officer) of any unknown object found/discovered on site. • The Operator should familiarise themselves with the National Heritage Council’s Chance Finds Procedure and if uncertain about the procedure should receive training by a suitably qualified archaeologist with respect to the identification of archaeological/heritage remains and the procedures to follow in the event that such remains are discovered throughout the project activities’ duration. The Chance and Finds Procedure is attached to the EMP. • Once finalized and become available, the layout of access tracks (roads), waste rock dumps, field

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camps and other related infrastructure should be submitted to the NHC to verify the possible presence of archaeological objects or sites near these infrastructures.

6.4.13 Waste Generation Exploration and mining activities are associated with generation of waste of all kinds (domestic, hazardous, and general). Improper handling, storage and disposal of wastes may lead to environmental degradation/pollution. If not handled, store and disposed of properly, the waste may scatter around the project site and pollute the immediate project area.

Without any mitigation measures, the impact significance is rated as medium, but implementation of the recommended measures, the significance will be reduced to low. This assessment is presented below (Table 21).

Table 21: Impact assessment of waste generation on the environment

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 M/H - 4 L/M - 4 M/H - 4 M - 44 Post mitigation L/M - 2 L/M- 2 L/M - 4 L/M -2 L - 16 Mitigation measures

• Project workers should be sensitized to dispose of waste in a responsible manner and not to litter. • After each daily works, there should not be waste left scattered on site, but rather be disposed of in allocated site waste containers. • No waste may be buried or burned on site or anywhere else throughout the project lifecycle. • All domestic and general waste produced daily should be contained until such that time it will be transported to designated waste sites on a weekly basis. • The sites should be equipped with separate waste bins for hazardous and general waste/domestic. • Hazardous waste, including emptied chemical containers should be safely stored on site where they cannot be accessed and used by uniformed locals for personal use. These containers can then be transported to the nearby approved hazardous waste sites for safe disposal. No waste should be improperly disposed of on site or in the surroundings, i.e., unapproved waste sites. • As an emphasis on the preceding point, empty hazardous substance containers should not be disposed of anywhere on the project site or its surrounding, but instead they should be kept at a designated storing place on site until such time that they can be safely taken to the nearest approved hazardous waste sites. • A penalty system for irresponsible disposal of waste on site and anywhere in the area should be implemented.

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6.4.14 Social Nuisance: Job seeking and Differing Norms, Culture and Values Like any new development tor project in an area, the proposed project activities may attract a potential influx of people from outside the project area in search of job opportunities. Such influxes during the exploration and eventual mining phase may lead to social annoyance to the local community as well as conflicts. This is generally considered a concern given the current unemployment rate of youth in Namibia, that people from other areas in different regions may hear about the project intentions (especially from the ESA newspaper adverts) and be forced to go look for work opportunities in the project area. Different people may come with different ways of living to the area, which could interfere with the local norms, culture, and values. This could potentially lead to social crashes between the locals and outsiders (out-of-area job seekers).

The influx of people into the project area may also lead to sexual relations between these out-of-area workers and the locals. This would lead to the spreading of sexual transmitted diseases (i.e., HIV/AIDS) when engaging in unprotected sexual intercourse.

Pre-implementation of mitigation measures, the impact is rated as of slightly high to medium significance. However, upon mitigation (post-mitigation) – see mitigation measures below, the significance will change from medium to low rating. The impact is assessed in Table 22 below.

Table 22: Social impact assessment of outsiders’ influx into the area (job seeking related)

Mitigation Status Extent Duration Intensity Probability Significance Pre mitigation M - 3 M - 3 M/H - 8 M/H - 4 M – 56 Post mitigation L/M - 2 L/M - 2 M - 6 L/M - 2 L - 20 Mitigation measures • The Proponent should prioritize the employment of local people, and only if necessary and due to lack of skills in the area, out-of-area people can be given some of the work. This is to avoid the influx of outsiders into the area.

• The locals to be employed during the project phases should be provided with the necessary training of skills required for the project to avoid bringing in many out-of-area employees.

• The workers should be engaged in health talks and training about the dangers of engaging in unprotected sexual relations which results in contracting HIV/AIDS and other sexual related infections.

• Out-of-area workers that may be employed (due to their unique work skills) on site should be sensitized on the importance of respecting the local values and norms, so that they can co-live-in harmony with the local communities during the duration of their employment on site.

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6.4.15 Social Nuisance: Property intrusion and Disturbance or Damage The presence of some out-of-area workers may lead to social annoyance to the local community. This could particularly be a concern when they or some of those workers enter or damage properties of the locals. The locals' private properties could be homes, yards/fences, vegetation, or domestic animals (livestock) or any properties of value to the farm owners or occupiers of the land. The damage or disturbance to properties may not only be private but local public properties. The unpermitted and unauthorized entry to private properties may cause social crashes between the local community (affected property owners) and the Proponent (being responsible for the overall project activities).

Pre-implementation of mitigation measures, the impact is rated as of medium significance. However, upon mitigation (post-mitigation), the significance will change from medium to low rating. The impact is assessed below (Table 23).

Table 23: Social impact assessment of outsiders’ influx into the area (locals’ properties)

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 M - 3 M - 6 M - 3 M – 36 Post mitigation L/M - 2 L/M- 2 L/M - 4 L/M -2 L - 16 Mitigation measures • The Proponent should inform their workers on the importance of respecting the locals' properties by not intruding or damage their homes, fences or snaring and killing their livestock.

• Any workers or site employees that will be found guilty of intruding peoples 'privately owned properties should be called in for disciplinary hearing and/or dealt with as per their employer' (Proponent)’s code of employment conduct

• Site workers should be advised to respect the community and local's private properties, values, and norms.

• No worker should be allowed to wander in people's private yards or fences without permission.

• Site workers are not allowed to kill or in any way disturb local livestock.

• No worker should be allowed to, without permission cut down or damage trees belonging either the farm owner, the neighbouring farms or in the already scarce community vegetation.

6.5 Cumulative Impacts According to the International Finance Corporation (2013), cumulative impacts are defined as “those that result from the successive, incremental, and/or combined effects of an action, project, or activity (collectively referred to in this document as “developments”) when added to other existing, planned, and/or reasonably anticipated future ones”.

The cumulative impacts to which the project would contributes are listed below:

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• Road infrastructure (vehicular traffic): The proposed exploration activities and eventual mining will contribute cumulatively to various activities such as commuting, farming activities, and travelling associated with tourism and existing mining activities in the Erongo Region. The contribution of the proposed project to this cumulative impact is however not considered being very significant given the scale and extent of the proposed project activities itself. Although most road users on the B2 are travelers (in vehicles of all sizes and types), the significance of the impact on the roads is placed mainly on the heavy trucks that are transporting various products for different businesses (commercial) and services deliveries within the Region, from and to different destinations in other regions. The past, current and future use of the road infrastructure by other users and for different operations will be beyond the Proponent’s control. Therefore, to ensure that the Proponent do their part to reduce this impact with regards to their project operations (heavy vehicle loads and frequency on the roads), they will implement the provided management (mitigation) measures and comply with the legal obligations and requirements as set out by the Roads Authority. This will be done through consultations as recommended under the Permitting and Licensing Table in the Draft EMP. • Visual: There are currently visual concerns of active mining sites and the abandoned ones in the Erongo Region. Although minimally (given the natural colour of the targeted site mountains/hills and the dolerite), the proposed project activities will contribute to the impact in the area. Regardless, the Proponent will be required to do their part (not to worsen the visual impact) by implementing the provided mitigation measures. • Water use: As indicated in the Groundwater Assessment Report, the current actual or baseline information on the total groundwater being abstracted from the site area aquifers by both private (households/domestic) and commercial users is unknown (due to the lack of annual records on water abstracted). Therefore, the proposed water abstraction from the borehole in the mining phase would be an add-on to an undocumented and unknown figure. While the contribution of this project will not be significant compared to large-scale mining operations elsewhere in the Region (given the daily use and option of carting water to site), mitigation measures to reduce water consumption are essential. therefore, the provided mitigation measures will be implemented by the Proponent for them to do their part on groundwater management and conservation and improve the status on water abstraction.

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• Soils and Water Pollution: Further cumulative sources of pollution are wet waste/effluent from improperly managed sewage facilities, fertilizers, pesticides, and hydrocarbons from other existing anthropogenic activities in the site area. The past, current and future prolonged duration of no recharge and very little recharge to groundwater aquifers is also a contributing factor to poor water quality. Another significant potential (cumulative) source of pollution in the area is the material from the tailings storage facility (TSF) at Rössing Mine. According to von Oertzen (2015), after this, very little material can be mobilized by wind from this surface. During heavy rainy seasons, these pollutants would be carried by rainwater through surface runoff and infiltrate into the ground, recharge local aquifer systems and pollute them. Regardless, mitigation measures to avoid and or reduce the potential soil and water pollution impact owing to the proposed project have been provided for implementation throughout the project’s life cycle.

6.6 Decommissioning (Cessation of Exploration and Mining Activities) Impacts pertaining to the closure of the mining activities have been identified. The impacts are loss of employment by workers at the project site and contribution to the national economy (revenue and royalties). Another concern that stems from mine closure is the rehabilitation of the site (discussed under section 6.7).

6.6.1 Loss of Employment, Revenue and Royalties Should the mining activities cease, workers that are employed by the mine sites will lose their jobs and source of income. The quality dimension stone mined would eventually run out or become difficult to mine and this would mean that the mining works will end, leading to loss of employment. This will also mean that there will be no more revenue and royalties paid to the government from this project.

This impact can be rated as of medium significance and only so much can be done by the Proponent to assist the workers in this regard. Regarding the national revenue and royalties’ payment, there will be unfortunately nothing that the Proponent would do to mitigate this. The impact significance of unemployment can be reduced from medium to low by implementing mitigation measures. The impact assessed in Table 24 below is that of employment loss only.

Table 24: Impact assessment of project activities closure on employment

Mitigation Extent Duration Intensity Probability Significance Status Pre mitigation M - 3 L/M - 2 M - 6 M/H - 4 M – 44 Post mitigation L/M - 2 L/M - 2 L/M - 4 L/M - 2 L - 16 Mitigation measures • The Proponent should inform the employees/workers on time, of the intentions to cease the project works and the expected date of such closure. This will provide the employees with enough time to search for

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work elsewhere.

• The Proponent should raise awareness of the possibilities for work in a similar or other industrial sector.

• The workers should be fairly laid off with reasonable severance packages to allow them to survive the few fist months of job hunting, and in accordance with the national Labour Law regarding retrenchment.

6.7 Site Rehabilitation One of the main challenges faced by the mining industry, which includes small-to-medium scale miners in Namibia and worldwide, is the rehabilitation of mined-out areas. Rehabilitation of mined out areas provides ecological, economic, and social benefits to the community, and non-rehabilitated disturbed areas deprive communities from benefiting from their land after mining (Ansaah, 2008). For communities to benefit from their land post- mining, it is necessary for miners to rehabilitate the mined-out areas to at least bring them close to their pre-mining states (by backfilling). However, this remains a challenge to many small-to-medium scale miners due to lack of rehabilitation knowledge, money, and necessary equipment to undertake the required site rehabilitation.

It is believed that rehabilitation has not been done on most (if not all) mined out areas in Namibia. This will lead to cumulative environmental impacts that may take long or may not be able to be reversed. To avoid this, it is vital that new rational mitigation measures need to be taken into consideration and effectively implemented by the miners. This could only be achieved through providing awareness training to miners on the environment and progressive rehabilitation of their mined-out areas (Excel Dynamic Solutions, 2019).

6.7.1 Planning for Rehabilitation Each mine will have characteristics that will influence the procedures adopted in the rehabilitation program. These characteristics may be obvious but critical differences are often only identified by careful investigation. The proposed post mining land-use will also influence the procedure and the plant species used for rehabilitation (Minerals Council of Australia, 1998).

The following are the basic rehabilitation practices as summarized after the Minerals Council of Australia (1998), which with appropriate modifications, will apply to most disturbed areas.

1. Making Safe: After planning for rehabilitation, the first step is to clean up and make the area to be rehabilitated, safe. This involves the following:

• Removal of infrastructure and unused or unwanted equipment. No facilities or equipment should remain on site unless with the written approval of the landowner or relevant authority.

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• Removal of rubbish for disposal at approved sites. Care is required with residual toxic or hazardous materials including contaminated packaging and containers

• Removal of all services.

• Removal or burial of concrete slabs, footings, etc.

• Backfilling or securely and permanently covering any shafts, pits, or similar excavations.

• Restricting or preventing public access by removal or closure of access roads and tracks.

2. Landform Design: The re-shaping and grading of a site is an essential aspect of rehabilitation. Unless slopes are stable, the effectiveness of subsequent topsoiling and re-vegetation is greatly reduced, and maintenance may be prolonged. When planning the final landform, the whole of the mine and associated infrastructure needs to be considered. The final landform should be hydrologically and, if possible, visually compatible with the surrounding area. The following factors should be considered in the planning stage:

• Will the final landform be stable? The erosion potential of the material on the site needs to be assessed. A geo-technical engineer’s report may be required.

• The drainage patterns for the overall site must be planned as part of the overall landscaping.

• Open-cut mines with large volumes of overburden will normally require a drainage density higher than existed prior to mining to compensate for the increase in the gradient of slopes and drainage channels.

• Slopes should be designed to reduce the velocity of runoff as the catchment of the slope increases.

• Where site limitations prevent the formation of a stable slope profile, contour benches or similar erosion control methods may be required.

• Drainage can be directed to the surrounding area or directed internally to a final void. Low quality water should not normally be directed to a void.

• Final discharge points for water leaving the new landform are dependent on the location of suitable watercourses in the surrounding land.

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• Ideally, the area of catchment of the watercourse receiving the discharge should not be significantly increased. Where mining results in an increased catchment area for an existing watercourse leading away from the site, additional downstream erosion control structures (e.g., graded banks, rock- lined waterways) may be required or existing structures may need upgrading. Consult the government department responsible for water resources.

• In flat or low-lying areas control of surface elevation is critical for drainage.

• Settlement of backfilled areas may require re-shaping some years after the initial landform is constructed.

3. Erosion Control: Control of erosion is important, both during mining and rehabilitation. The effects of erosion may require remedial works on sites where soil loss has occurred as well as where the material is deposited as drift, dust, or river sediment. Major objective of most rehabilitation programs is to establish an adequate cover of vegetation to stabilize the site and prevent or control erosion to natural levels. Until a vegetation cover has been established, provision to protect against wind and water erosion will be required.

4. Topsoil Management: Although re-vegetation has been achieved on various substrates, topsoil is almost always an essential factor in successful rehabilitation programs, particularly during the period of initial plant growth. Subsoil conditions become of more importance in the longer term. Topsoil (or weathered surface material) provides a good microenvironment for seed germination and generally contains seeds, nutrients and microorganisms that are necessary for plant growth. If these are lost, then the system will generally take a longer time to re-establish.

5. Soil Properties for Plant Growth: Maintaining or improving the ability of the soil (or other plant growth media) to supply nutrients, to store and supply water and support root growth should be a major consideration during rehabilitation.

Conclusion on the impact assessment: it is found that most of the identified potential negative impacts are rated as medium significant. Therefore, to reduce the significance from medium to low, it is recommended that the Proponent effectively implement mitigation measures. Furthermore, to maintain low significance, the implementation of measures will need to be continuously monitored.

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Rehabilitation: On the issue of rehabilitation, successful rehabilitation requires careful consideration of the local ecological context in combination with rehabilitation goals. The most important steps in undertaking a successful rehabilitation are planning and environmental awareness (environmental education) on the importance of progressive rehabilitation (or post-mining rehabilitation) and its importance to the environment. Furthermore, to successfully implement the planned rehabilitation, practically, this will depend on a few factors, namely the rehabilitation program, characteristics of a mine, nature of disturbance, rehabilitation methods, as well as resources availability.

To ensure that they do their best to rehabilitate the disturbed or mined-out site areas, the Proponent intends utilize waste rubble to rock blind exposed rock faces and stockpiled topsoil to partially back fill

7 RECOMMENDATIONS AND CONCLUSIONS The aim of this environmental scoping assessment was to identify the potential impacts associated with the proposed exploration and mining activities on the nine mining claims, assess and recommend practical mitigation measures. The public was consulted as required by the EMA and its 2012 EIA Regulations (Section 21 to 24). The public was informed via the newspapers used for this assessment; site/public notices placed in the project site area, relevant local and regional offices notice boards. A one-on-one interaction (public meeting) was held with the public and virtual meeting done with the national authorities. The interested and affected parties raised their comments and concerns on the proposed project activities. The concerns and comments received from the public and the local community members formed the basis for this report as well as the Draft EMP.

The conclusions reached and recommendations provided are presented below.

7.1 Recommendations It is therefore recommended that an Environmental Clearance Certificate be issued for the proposed exploration and mining activities on mining claims 71609 to 71617, subject to the following recommendations:

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• The Proponent complies with the legal requirements governing this type of project and its associated activities.

• All mitigations provided in this ESA Report and the management action plans in the EMP should be implemented and monitoring conducted as recommended.

• All the necessary environmental and social (occupational health and safety) precautions provided should be adhered to.

• Site areas where exploration and mining activities have ceased should be rehabilitated, as far as practicable, to their original state.

• The monitoring of the implementation of mitigation measures should be conducted, applicable impact’s actions taken, reporting done and recorded as recommended in the Draft EMP.

7.2 Conclusions The potential (positive and negative) impacts stemming from the proposed exploration and mining activities were identified. The two impacts types were described, assessed and mitigation measures where provide (where necessary).

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The findings of this scoping assessment were deemed sufficient and conclude that no further detailed assessments are required.

With that being done, the positive impacts of the project activities as indicated in the Report will be able to overweigh the negatives and ensure socio-economic development.

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Motloung, M. and Ashmole, I. (2008). The Southern African Institute of Mining and Metallurgy. Retrieved from Dimension stone: The latest trends in exploration and production technology.: https://www.saimm.co.za/Conferences/SurfaceMining2008/035- 070_Ashm

Mweemba, M. S. (2014). Small-Scale Mining in Namibia: Theme: “Earth Sciences and Climate Change: Challenges to Development in Africa”: 7th conference of the African Association of Women in Geosciences. Windhoek.

Namibia Statistics Agency. (2011a). Namibia 2011 Population and Housing Census Main Report. Windhoek: Namibia Statistics Agency.

Namibia Statistics Agency. (2011b). 2011 Population and Housing Census: Erongo Regional Profile. Windhoek: Namibia Statistics Agency.

Pallett, J., Irish, J., Aiyambo, D., Eelu, K., Guittar, J., Henschel, J., Kavari, R., Nghiitombo, V., Shikangala, J. and Siteketa, V. (2008). Rössing Biodiversity Assessment. Windhoek: Rossinf Uranium.

Parsons, R. and Wentzel, J. (2007). Groundwater Resource Directed Measures Manual.109pp. Pretoria: Department of Water Affairs and Forestry (South Africa).

Resilient Environmental Solutions. (2019). Environmental Assessment for Exclusive Prospecting License (EPL) 7264 near Talismanis in the Omaheke Region. Windhoek: Resilient Environmental Solutions.

Robins, N. (2020). Introducing Hydrogeology. Edinburgh: Dunedin Academic Press Ltd.

SLR Environmental Namibia. (2012). Scoping Report for the proposed Arandis Thermal Power Generation and Waste Oil Recycling Plants. Windhoek.

Southern African Institute for Environmental Assessment (SAIEA). (2011). Strategic Environmental Assessment for the Central Namib Uranium Rush. Windhoek: Ministry of Mines & Energy.

Strohbach, B. J. (2008). Mapping the Major Catchments of Namibia. Windhoek: Namibia University of Science and Technology.

Van Wyk, A.E., Strub, H. and Struckmeier, W. (2001). Hydrogeological Map of Namibia, Scale 1:000 000 : Vulnerability of Groundwater Resources Map. Windhoek: Ministry of Agriculture, Water and Forestry. von Oertzen, G. (2015). Risk assessment on Rössing Uranium mine's tailings dust. Aachen: Brenk Systemplanung GmbH.

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Winker, F. (2010). Groundwater Model of the Swakop River Basin. Freiburg: University of Freiburg.

World Weather Online. (2020). Arandis - Erongo Region, Namibia Weather. Retrieved April 8, 2020, from World Weather Online: https://www.worldweatheronline.com/arandis- weather-averages/erongo/na.aspx

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APPENDIX G: DESKTOP HYDROGEOLOGICAL (GROUNDWATER) IMPACT ASSESSMENT REPORT

Desktop Groundwater Impact Assessment (DGIA) for the Proposed Exploration and Mining Activities on Mining Claims 71609 – 71617 near Arandis Town in the Erongo Region

Document Version: Final

Proponent: Okonde Mining and Exploration CC

Date: 14 August 2020

Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

DOCUMENT INFORMATION Title: Desktop Groundwater Impact Assessment (DGIA) for the Proposed Exploration and Mining Activities on Mining Claims 71609 – 71617 near Arandis Town in the Erongo Region

Prepared on behalf of Omavi Geotechnical & Geo-Environmental Consultants by:

Author: Fredrika N. Shagama Qualifications: PhD. Student: Civil Engineering (Geotechnics & Hydrogeology), VSB - Technical University of Ostrava, Czech Republic

MSc. Geological Engineering (cum laude) with primary focus in Hydrogeology, VSB - Technical University of Ostrava, Czech Republic

BSc. Geological Engineering, VSB - Technical University of Ostrava, Czech Republic

Professional Affiliations: International Association of Hydrogeologists (IAH) - Full (online) Member, Membership No.139790

Namibian Hydrogeological Association (NHA) – Member

Environmental Assessment Professionals of Namibia (EAPAN) - Ordinary Member Practitioner (Membership No. 183)

Signature:

Date: 14 August 2020

Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

EXECUTIVE SUMMARY Okonde Mining and Exploration CC (hereinafter referred to as Okonde Mining and Exploration or the Proponent) intends to undertake exploration and subsequent mining activities on nine mining claims (MCs) near Arandis Town in the Erongo Region (the project). The mining claims namely 71609, 71610, 71611, 71612, 71613, 71614, 71615, 71616 and 71617 are located about 30 km northeast of the Arandis Town. Although the mining claims are in the same area, they are grouped into two sites. The two groups that are about 6 km apart comprise of MCs 71609, 71610, 71611, 71612, 71613 & 71614 and then MCs 71615, 71616 & 71617. The total (combined) surface area of the nine mining claims is 140 hectares (ha).

The proposed exploration and mining are however among the listed activities in the Environmental Management Act (EMA) No. 7 of 2007 and its 2012 Environmental Impact Assessment (EIA) Regulations that may not be undertaken without getting the environmental clearance certificate (ECC). Consequently, the Okonde Mining and Exploration CC appointed Omavi Geotechnical & Geo-Environmental Consultants CC (hereinafter referred to as Omavi Consultants) to undertake the required EIA process and apply for the project ECC.

To ensure that all the significant environmental components are considered as part of the EIA study, Omavi Consultants subcontracted Ms. Fredrika Shagama (an independent Hydrogeologist) to undertake a desktop impact assessment study for one of the physical environmental components (groundwater), i.e. a geohydrological/hydrogeological assessment for the proposed project.

It is for this reason, that this desktop groundwater impact assessment report was compiled. The aim of the report was to determine the possibility/likelihood and extent of groundwater being impacted by the proposed project activities, assess the potential impacts, and provide the necessary practical measures to manage avoid and or minimize their significance.

RECOMMENDATIONS AND CONCLUSIONS

The aim of this report was to assess the potential impacts of the proposed exploration and mining activities on the groundwater resources. The assessment has been undertaken on a desktop level, i.e. based on information provided by Omavi Geotechnical & Geo-Environmental Consultants (the project Environmental Assessment Practitioner/Consultant) obtained from their own site visit, information provided by the project proponent, author’s professional judgment complemented by experience as well as review of previous relevant studies conducted within proximal distance from the project.

The recommendations provided to the assessment and conclusions made are as follows:

Recommendations

Given the assessment results, to manage and protect the water resources, the following management measures should be implemented:

Groundwater Abstraction and Use Mitigation Measures ii

Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

• The groundwater abstraction and use should be controlled by Regulation, i.e. water abstraction and use permit. As required by the Water Act that all activities that uses water for commercial purposes, the Proponent should apply for and obtain a Water Abstraction and Use Permit from the Department of Water Affairs’ Directorate of Water Resources Management. The Proponent will be required comply with the conditions set in the Permit. With regards to the two project activities, the specifications are as follows:

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• There is a ‘’potential water source’’ (borehole) within the site area (on Farm Hakskeen - located at 21°57'22.23"S 15° 8'49.76"E) that is planned for rehabilitation. The rehabilitation will either entail the removal of pumping equipment from the borehole to re-drill the borehole to a new depth where water can be encountered or re-installation of the pump to lower it down to the new water level that may have dropped below the pump over time. The rehabilitated borehole would then be pump tested by a suitably qualified and experienced hydrogeologist or geologist so that it can supply (some of the) water for the mining activities. However, given the low potential of local aquifers and should it come to light that the rehabilitated old borehole cannot even supply the minimum of water volumes required, then the Proponent may need to have a new borehole sited, drilled and installed in a carefully selected area within the mining claims’ site area.

• As per the preceding point, if it comes to siting a completely new borehole, this borehole should be carefully sited, drilled, installed and their sustainable yields determined during the aquifer test (pumping test) by a qualified and experienced hydrogeologist. The hydrogeologist will then recommend a safe (sustainable) abstraction yield for the site to the Proponent to ensure that the local aquifers are not stressed, i.e. not negatively impacted by this local over abstraction.

o For the exploration activities, 5 000 litres (5 m3) per day or 155 000 litres (155 m3) per month, and o For the mining activities, 232 m3 or 2 232 000 litres per year (6 000 litres x 31 days = 186 000 litres per month or 186 m3 which is 2 232 m3 per year, i.e. 186 m3 x 12 months).

• Like with their previous operations, the Proponent should aim to use water efficiently, recycle and re-use where necessary and possible.

Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

• Putting into consideration the low borehole yields in the project area, the project borehole should be pumped for 0.5 hours in a day (also as backed up by the Hydrogeologist’s pump test recommendations above) during mining to cover at least half of the required volumes of water while considering the minimum hourly yield that a borehole on a dark brown area of the groundwater map (Figure 8) can provide. Therefore, the Proponent would need to pump this water from the borehole on certain days of the week only (not every day) and store the required water in industry standard water tanks on site. This is to avoid abstracting water from the borehole daily (which would stress the aquifers further) and allow the borehole water level some time to recover from the pumping.

• The site borehole water should be used efficiently, i.e. by limiting water use to the intended project activities only. The aim is to ensure that general environmental sustainability is not compromised in terms of water supply to both the natural and social environmental components that depend on this already struggling water resource.

The most important abstraction management plan is a GWAUP (permit/license), which clearly stipulates the amount of water that should be abstracted from an aquifer and outlines all the conditions that need to be complied with during abstraction. It is important that the Proponent strictly adhere to the abstraction volumes given in their water permit and if necessary, use less water than the allocated volume therein.

Groundwater Pollution Mitigation Measures

Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

• Exploration and mining site areas where hydrocarbons will be utilized, the surface should be covered with an impermeable plastic liner (e.g. an HDPE liner), carefully placed so as to minimize risk of puncturing, to prevent any spillages from getting into direct contact with the soils and prevent eventual infiltration into the ground.

• Project machines and equipment should be equipped with drip trays to contain possible oil spills when operated during exploration and mining works.

• Although fuel (diesel) required for exploration equipment will be stored in a tank mounted on a mobile trailer, drip trays must be readily available on this trailer and monitored to ensure timely cleanup of accidental fuel spills along the tank trailer path/route around the exploration sites.

• Spill control preventive measures should be in place on site to management soil contamination, thus preventing and or minimizing the contamination from reaching groundwater bodies. Some of the soil control preventive measures are:

Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

o Maintain a fully provisioned, easily accessed spill kit. Spill kits should be located throughout the active project sites contain the floor dry absorbent material and absorbent booms, pads, mats. These would be suitable for ground surface areas that are covered mainly by hard rocks. o All project employees should be made aware of the impacts of soil pollution and advised to follow appropriate fuel delivery and handling procedures. o Develop and prepare countermeasures to contain, clean up, and mitigate the effects of an oil spill. This includes keeping spill response procedures and a well- stocked cache of supplies easily accessible. o Ensure employees receive basic Spill Prevention, Control, and Countermeasure (SPCC) Plan training and mentor new workers as they get hired in each phase of the project.

Groundwater Monitoring:

The following monitoring exercises are recommended during the mining phase:

• Monthly recording of water levels in the site production and monitoring boreholes(s) as well as surrounding farms; boreholes.

• Groundwater quality monitoring (sampling) is recommended to be undertaken on a quarterly basis (twice a year, preferably in the months of March/April – after the raining season and September/October – prior to the raining season).

• The following sample results after the first one will then be compared against both the baseline water quality and the preceding months’ measurements (concentrations).

• Conducting a quarterly Hydrocensus of the neighbouring farms to monitor the movement of and detect possible pollution from the mining site.

• An annual monitoring report to be prepared and made available to the responsible unit of the Department of Water Affairs as per conditions and instruction stipulated in the water abstraction and use permit.

Conclusions

Water abstraction (use): For exploration activities, the impact on local groundwater resources (abstraction) will be very low to none because the required water will be carted to site from Swakopmund and kept in water tanks on site. During the mining phase, the impact on groundwater will be moderate to low because of the project magnitude (small to medium) and the project activities will not require a large amount of water to operate like a typical mine where significant amount of water would be required daily and or annually. Therefore, the impact on groundwater resources from the exploration and mining activities is minimal, provided that the recommended management measures (plans) are effectively implemented. vii

Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

It should be noted that this report was compiled based on desktop level (no detailed study) and given the limitations on baseline groundwater that are specific to the project area and site, the actual values or parameters could not be provided by this report. However, the following concluding values were estimated from the available insufficient information:

o The expected borehole yield from the project site will range between 1 and 3 m3/hour (based on the groundwater potential and yield map) o The recharge frequency in arid areas of Namibia such as the project area only happens in every 10 years when heavy rains occur leading to floods. However, it should be noted that heavy rainfalls does not equal high recharge, as this is a complex component in the hydrological cycle that depends on certain factors such as soil cover, land use, topography, vegetation cover, last rainfall event, etc. These among others need to be well understood. The actual recharge that infiltrates the soil and eventual reaching the water table requires different hydrological methods used in estimating effective recharge from rainfall (partitioning rainfall into recharge, runoff, and evapotranspiration). This is beyond the scope of this study and report. o The expected stress index as estimated from the available water balance components is 0.0057. Based on the guide for determining the level of stress of the groundwater resource unit the additional abstraction of 6 m3/day for the proposed mining activities in the sub-catchments is classified as status category A (<0.05). Therefore, the aquifer has an unstressed / low level of stress.

Water pollution: As it is common with every new and existing project, ground surface pollution is anticipated from the project operations and related activities. This potential pollution would be from improper disposal of hazardous products such as hydrocarbons (fuel/oils) and effluent from exploration works and eventual mining on site. The geology of the project area would make the groundwater less vulnerable to pollution from the surface due to the type (igneous and metamorphic rocks) and nature (unfractured/faulted) of rocks would inhibit further spreading pollution of potential pollutants in the water. The avoidance of pollution from reaching the ground surface (into groundwater) and effective implementation of pollution management plans will greatly aid in minimizing groundwater pollution. The impact is therefore considered low (minimal) to slightly moderate and according to the Groundwater Resources Vulnerability to pollution Map, the general site area has a rather low and, in some parts, moderate risk of pollution.

Furthermore, for exploration activities, the potential pollution impact is short-term (short lifespan), which means that the impact will be only limited to the duration of these activities. The potential impact is however anticipated to be long-term during the mining phase, but it can be managed by effective implementation and monitoring of the recommended management (action) plans.

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Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

In conclusion, it is unlikely that the proposed project activities will have a high significant impact on groundwater resources in the project area as the impacts have been assessed as low for the exploration activities and low to slightly medium significance for the mining phase/activities. The impact significance has been rated as medium for water quantity during the mining phase because some water is expected to be abstracted from a local nearby borehole. Therefore, it is vital for the Proponent and their contractors (if any) to effectively implement and monitor the recommended management measures to protect both the biophysical and social water environment. All these would be done with the aim of promoting environmental sustainability while ensuring a smooth and harmonious existence and purpose of the project activities in the hosting biophysical and social environment.

To protect groundwater, it is necessary for different water users in societies to recognize that water resources are finite and vulnerable and find ways to reconcile the demands of human activities with the tolerance of nature. The essential first step to making water use sustainable is awareness and knowledge of human impacts on the environment, specifically on water resources. This will not only be applicable to the project proponents but also members of the public who may have been living in the area prior to developments, such as the proposed exploration and mining.

The Proponent will also be required to ensure that all their activities comply with the laws governing their project activities from exploration throughout to mining phase (if the explored areas of the mining claims or parts of the claims will be hosting dimension stone’ deposits that are commercially valuable). In other words, adherence to the water permitting conditions and legislations are essential for the prevention and management of groundwater pollution. The Proponent should take note of their responsibility to acquire the legal authorizations such as borehole drilling and water abstraction and use permits, land/farm access agreements to drill boreholes, etc. and ensure compliance with these specific legal requirements.

Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

TABLE OF CONTENTS DOCUMENT INFORMATION ...... i EXECUTIVE SUMMARY ...... ii TABLE OF CONTENTS ...... x LIST OF FIGURES ...... xi LIST OF TABLES ...... xii LIST OF ABBREVIATIONS ...... xii 1 INTRODUCTION ...... 1 1.1 Brief Project Background and Location ...... 3 2 TERMS OF REFERENCE, SCOPE OF WORKS AND LIMITATIONS ...... 5 2.1 Terms of Reference for the Study ...... 5 2.2 Scope of Works ...... 5 2.3 Limitations of the Study ...... 5 3 APPROACH AND METHODOLOGY ...... 6 3.1 Desktop (Baseline) Study...... 6 3.2 Impact Assessment Methodology ...... 6 3.2.1 General Concept of Impact (Risk) Assessment ...... 6 3.2.2 Impact Assessment Criteria ...... 7 3.2.3 Impact Significance ...... 9 3.3 Reporting ...... 10 4 LEGAL FRAMEWORK FOR WATER RESOURCES MANAGEMENT AND PROTECTION 10 4.1 Applicable National Legal Framework ...... 10 5 DESCRIPTION OF THE (RELEVANT) RECEIVING ENVIRONMENT ...... 12 5.1 Climate and Topography ...... 12 5.2 Soil and Geology ...... 14 5.3 Hydrology and Catchments ...... 17 5.4 Hydrogeology ...... 17 5.4.1 Baseline Groundwater (Borehole) Yields and Levels ...... 18 5.4.2 Groundwater Quality ...... 20 5.4.3 Vulnerability of Groundwater to Over-abstraction ...... 21 5.4.4 Vulnerability of Site Area groundwater resources to Pollution ...... 22 5.5 Vegetation ...... 23 6 PROPOSED GROUNDWATER ABSTRACTION AND USE ...... 24 6.1 Existing Groundwater abstraction and Use ...... 24 x

Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

6.2 Proposed Water abstraction and Use for the Project Activities ...... 25 6.2.1 Water Requirements for Exploration Activities ...... 26 6.2.2 Water Requirements for Mining Activities ...... 26 7 PRELIMINARY GROUNDWATER RESERVE DETERMINATION ...... 27 7.1 Sub-catchment Delineation ...... 27 7.2 Groundwater Recharge ...... 30 7.3 Basic Human need...... 31 7.4 Existing & Proposed Groundwater Abstraction (Reserve Estimation) ...... 32 7.5 Groundwater Contribution to Baseflow ...... 32 7.6 Water Balance Calculations ...... 32 8 GROUNDWATER IMPACTS: DESCRIPTION AND ASSESSMENT ...... 34 8.1 General Concept of Impact (Risk) Assessment ...... 34 8.2 Groundwater Impact Assessment (Over-abstraction) ...... 35 8.2.1 Brief Impact Description – Water Quantity ...... 35 8.2.2 Abstraction (Use) Impact Assessment Based on Calculations under Chapter 7 ...37 8.3 Groundwater Impact Assessment (Pollution) ...... 38 8.3.1 Brief Impact Description – Water Quality ...... 38 8.3.2 Pollution Impact Assessment ...... 39 9 GROUNDWATER MANAGEMENT MEASURES ...... 41 9.1 Groundwater Abstraction Management Plans ...... 41 9.2 Groundwater Pollution Management Plans ...... 44 9.3 Groundwater Monitoring: Abstraction (Water Levels) and Pollution (Quality) ...... 46 9.3.1 Basic Groundwater Level Monitoring During the Mining Phase ...... 46 9.3.2 Basic Groundwater Quality Monitoring ...... 46 10 RECOMMENDATIONS AND CONCLUSIONS ...... 47 10.1 Recommendations ...... 47 10.2 Conclusions ...... 52 11 REFERENCES LIST ...... 54

LIST OF FIGURES Figure 1: Location of the mining claims (project site) near Arandis in the Erongo Region ...... 4 Figure 2: The spatial distribution of potential evaporation in Namibia (after BGR, 2005) ...... 12 Figure 3: The rainfall patterns for the Arandis area (source: World Weather Online, 2020) ....13 Figure 4: The maximum, minimum and average temperature Arandis area (source: World Weather Online, 2020) ...... 13

Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

Figure 5: Topography within the mining claims’ site boundary (photo: Omavi Consultants, 2020) 14 Figure 6: Geological features of the project area as presented with regards to the Omdel Aquifer (edited after Matengu et al, 2019) ...... 15 Figure 7: Approximate geological section (map) and Legends of the project site area extracted from a 1:250 000 geological sheet ...... 16 Figure 8: Hydrogeological map of Namibia with rock bodies groundwater potential with the approximate location of project site indicated by the light green arrow on the map ...... 18 Figure 9: Location of the sampling points for the 2010 Khan-Swakop River Catchment groundwater quality assessment (edited after Kringel et al, 2010)...... 20 Figure 10: Spatial distribution of Electrical Conductivity (EC) at the sampled area (Kringel, 2010) 21 Figure 11: Vulnerability of groundwater resources to Pollution (Van Wyk et.al, 2001)- approximate project site area enclosed by the light green circle ...... 23 Figure 12: Sub-catchment delineation map for the mining claims’ site ...... 29 Figure 13: Recharge zones derived from annual rainfall map (DEA, 2002), after Winker (2010) 30

LIST OF TABLES Table 1: Impact assessment criteria ...... 7 Table 2: Impact significance rating scale ...... 9 Table 3: Identified boreholes around the mining claims’ area ...... 19 Table 4: Sub-catchment information of the mining claims site area ...... 30 Table 5: Water balance or budget for the project site area (Sub-catchment 1 and Sub- catchment 2) ...... 33 Table 6: Assessment of the project impact on water resources abstraction (quantity) ...... 37 Table 7: Guide for determining the level of stress of a groundwater resource unit ...... 37 Table 8: Assessment of the project impact on groundwater resources (quality) ...... 41

LIST OF ABBREVIATIONS °C: Degree Celsius

µS/cm: microsiemens per centimetre

ArcGIS: A geographic information system for working with maps & geographic information

BGR: Bundesanstalt für Geowissenschaften und Rohstoffe (The Federal Institute for Geosciences and Natural Resources of the Republic of Germany)

CC: Close Corporation

DEM: Digital Elevation Model

DGIA: Desktop Geohydrological (Groundwater) Impact Assessment

DWA: Department of Water Affairs

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EC: Electrical Conductivity

EEA: European Environmental Agency

EIA: Environmental Impact Assessment

EMA: Environmental Management Act

EMP: Environmental Management Plan

GWAUP: Groundwater Abstraction and Use Permit

HDPE: High Density Polyethylene km: kilometre km2: square kilometre m: Metres m3: Cubic metre m3/day: cubic metre per day m3/h: cubic metre per hour m3/year: cubic metre per year (annum)

MAWLR: Ministry of Agriculture, Water and Land Reform

MC: Mining Claim mm/a: millimetre per annum (year)

Mm³: Million cubic metres

Mm3/a: Million cubic metres per annum (year) mS/m: Millisiemens per metre

NamWater: Namibia Water Corporation Limited (The National Bulk Water Supplier)

OMDEL/Omdel: Omaruru Delta Aquifer

S-P-R: Source-Pathway-Receptor

SPCC: Spill Prevention, Control, and Countermeasure

TDS: Total Dissolved Solids

TOR: Terms of Reference

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Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

1 INTRODUCTION Mining is the backbone of the Namibian economy constituting about 9.3% contribution to Gross Domestic Product (GDP). About 52.7% of export-earnings from mining were recorded in the Chamber of Mines’ 2013 Annual Report. Other sectors contributing to the GDP include fisheries, agriculture, and tourism (Mweemba, 2014). Minerals extracted in Namibia range from diamonds, uranium, base metals (copper, lead, zinc, etc.), gold, industrial minerals (sand, limestone, and graphite), dimension stones (marble, dolerite) and semi- precious stones/gemstones. Some listed minerals and stones are either mined at a small, medium, or large- scale level, depending on the; ore deposit, specimen size sought after, available resources and geological extent, etc.

The mining activities of these above-mentioned minerals groups (mainly preceded by exploration activities) usually to certain extents require the use of water to fully operate. Like any other type development (activity), exploration and mining activities usually comes with positive impacts such as income generation, employment creation, contribution to local and regional socio-economic development as well as the country’s revenue through taxes and royalties by the project owners (Proponents). However, these activities also associated with some negative (adverse) environmental issues. If these issues (impacts) are not well understood prior to project implementation and enable their timely avoidance or significance reduction, they can potentially harm both the physical and social environment or its components during the project lifecycle. One of the vital environmental physical components that can be potentially impacted by the exploration and mining activities is water resources, particularly groundwater.

Groundwater is one of the most valuable yet vulnerable natural resources for people, animals, and the general environment owing to sudden adverse changes in the water systems. Therefore, affecting water resources systems and overall natural environment functionality. It is, therefore, very crucial to understand the impacts of proposed (new) projects on groundwater, in terms of over-utilization (over-abstraction) and pollution (quality). Groundwater over-abstraction does not only result in aquifer depletion and water-quality degradation, but also impacts the ecological integrity of streams and wetlands, resulting in significant losses of habitat and biodiversity. This impact is felt more in semi-arid and arid areas with high water demand and low rainfall (limited groundwater recharge) compared to humid areas. In other words, although water scarcity often happens in areas with low rainfall, human activities aggravate the problem particularly in areas with high population density, tourist inflow, intensive agriculture and other water demanding industries.

Over abstraction of groundwater leads to water scarcity, whereby there is insufficient water resources to satisfy long-term average requirements. According to the European Environmental Agency (EEA) (2018), water scarcity refers to long-term water imbalances, combining low water availability with a level of water demand exceeding the supply capacity of the natural system. Water scarcity is driven primarily by two factors:

1 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

• Climate, which controls the availability of renewable freshwater resources and seasonality in water supply, and • Water demand, which is largely driven by population and related economic activities

With every new project planned for in the society (natural and social environment), it is vital that all possible impacts on water resources from such developments’ activities are considered, how to prevent them and or minimize their significance (if avoidance is impossible) and come up with practical mitigation measures. All this is done to ensure that the projects and development activities run in an environmentally and socially manner to ensure sustainability, while maximizing the positive impacts (benefits) of the projects.

This document aims to confirm, assess potential impacts on groundwater resources associated with the proposed exploration and mining activities in the Erongo Region, west coastal side of Namibia, and provide mitigation measures to avoid and or minimize the significance of these impacts.

With that in consideration and commitment to continue operating to generate income, positively impact the lives of Namibian citizens (through employment) and economic development to the Erongo Region and Namibian nation, as one of the dimension stone exploration and mining companies in Namibia, Okonde Mining and Exploration CC intends to continue with their line of operations. They intend on doing this by exploring on prospective target areas of the mining claims and eventually mine on economically confirmed parts of these sites.

For Namibia, water resources are protected under Water Act (1956) and the new Water Resources Management Act (2013). Water resources protection and management is also listed under the Environmental Management Act No. 7 of 2007 and its 2012 Environmental Impact Assessment (EIA) Regulations as one of the activities that may not be undertaken without an environmental clearance certificate (ECC). Most importantly for this project, the EMA also made provision for ECC abstraction and use of groundwater for commercial purposes (mining activities to be specific).

To ensure that all the significant environmental components are considered and to satisfy the requirements by both the Proponent and public (public consultation requests), as part of the main EIA study, Omavi Geotechnical & Geo-Environmental Consultants(the project Environmental Consultants) subcontracted Ms. Fredrika Shagama (an independent Hydrogeologist) to undertake a desktop groundwater (hydrogeological) assessment for the proposed project activities.

It is for this reason, that this desktop groundwater impact assessment report was compiled. The aim of the report was to determine the possibility of groundwater being impacted by the proposed exploration and mining activities on the nine mining claims, assess the potential impacts, and provide the necessary management measures to reduce the significance of these impacts.

2 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

1.1 Brief Project Background and Location The Namibian water resources are protected by the old Water Act No. 54 of 1956 and the new unpromulgated Water Resources Management Act No. 11 of 2013, that require that a water abstraction and use permit should be obtained for every commercial water use. The abstraction and use of water resources (groundwater) is also listed under the Environmental Management Act No. 7 of 2007 and its 2012 Environmental Impact Assessment (EIA) Regulations as one of the activities that may not be undertaken without an environmental clearance certificate.

It is for these legal reasons that Okonde Mining and Exploration CC (hereinafter referred to as Okonde Mining and Exploration or the Proponent) appointed Omavi Geotechnical & Geo-Environmental Consultants CC (hereinafter referred to as Omavi Consultants) to undertake the required environmental assessment for their proposed exploration and mining activities on their nine mining claims (MCs) located about 30 km northeast of the Arandis Town in the Erongo Region (the project) - Figure 1. The dimension stone and industrial mineral mining claims covered by the project are 71609, 71610, 71611, 71612, 71613, 71614, 71615, 71616 and 71617. The mining claims are in the same area, bordering each other and have a combined surface area of 140 hectares (ha). Okonde Mining and Exploration intends to mine (quarry) of black dimension stone (dolerite) from these mining claims and supply to the market (consumers).

3 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

Figure 1: Location of the mining claims (project site) near Arandis in the Erongo Region

4 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

2 TERMS OF REFERENCE, SCOPE OF WORKS AND LIMITATIONS

2.1 Terms of Reference for the Study There was no formal Terms of Reference (TOR) provided by Omavi Consultants. However, this document has been prepared as guided by their requirement for the water resources component as part the main project Environmental Impact Assessment (EIA). The water resources impact assessment covered in this report primarily deals with the potential impacts of the proposed exploration and eventual mining operations on groundwater resources on site and in the immediate areas.

2.2 Scope of Works The scope of work for this study is limited to the water resource impact assessment with a cursory look at the project impacts on groundwater in terms of quantity (abstraction) and quality (pollution). The scope of works for this study is presented below:

• Baseline assessment (desktop study) of existing site information as provided by Omavi Consultants and general literature on the broader area in relation to the proposed project site and overall project activities.

• A review and brief presentation of legislation that governs water resources management and protection in Namibia.

• A description of the physical conditions; climatic, pedological (soil), geological, hydrological (surface) and hydrogeological (groundwater) conditions of the project site area.

• The proposed (future) water abstraction for the project activities.

• Determination/estimation of the groundwater rapid (desktop) reserve of the project area and sustainable (abstractable) water volume per day (and year); and

• Identification of the potential impacts from the proposed project activities on groundwater resources, their descriptions, assessment, and recommendations on mitigating these impacts.

2.3 Limitations of the Study The following assumptions apply to this assessment:

• This report has been compiled on a desktop level i.e. no detailed fieldwork/site visit was conducted by the Author for this assessment. The project specific information used in this document is as provided by Omavi Consultants from the Proponent.

• The Author assumes that all the project information and data provided by Omavi Consultants and the Proponent is correct and accurate, and that all necessary information has been disclosed.

• It is also assumed that the relevant information obtained from different literature consulted is accurate; and

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• The report has been compiled on an assumption that there will be no significant changes to the proposed activity or the affected water environment between the time of compiling this report and implementation of the proposed project activities that could substantially influence findings of this document. It is also assumed that there will be no significant changes to the project activities that could substantially influence the mitigation measures given and recommendations made for the management and protection of groundwater resources.

The methodology employed for this study (assessment) is presented under the following chapter.

3 APPROACH AND METHODOLOGY To ensure that the requirements of the study addresses the main issues, the following methods and tasks have been employed to aid in undertaking a concise assessment and to make informed decisions.

3.1 Desktop (Baseline) Study For this study, an analysis of existing project information as presented by Omavi Consultants and Proponent and reviewing of literature and legislation relevant to the study (baseline assessment) were undertaken. This review entails reports containing information on the area geology, soil, climate, and hydrology. Other existing reports of similar or related studies conducted in the area were also reviewed. This also entailed the review of relevant books in the field of hydrogeology that significantly contribute to the study.

3.2 Impact Assessment Methodology The potential impacts of the project activities on the groundwater resources has been described and presented as per criteria presented under section 3.2.1 and section 3.2.2, respectively and in detail under Chapter 8 (impacts’ description and assessment). The mitigation (management) measures to avoid or minimize these potential impacts are provided under Chapter 9.

The methodology used to assess and determine the significance of the potential project impacts on the water resources is as explained below.

3.2.1 General Concept of Impact (Risk) Assessment Generally, an environmental risk occurs when there is a hazard (e.g. process, activity, or substance) that can result in a harmful impact on the surrounding environment. The part of the environment which is, or could be, affected is known as a receptor. Receptors include humans, flora and fauna, the built environment and water resources (controlled waters).

According to SRK (2006), the presence of a hazard alone does not constitute a risk; a risk is only present if there is a means by which the hazard can impact on sensitive receptor(s). The connection between the hazard and receptor is known as a pathway, and all three elements together.

The risk/impact assessment is driven by three factors and these are:

• Source: The cause or source of the contamination.

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• Pathway: The route taken by the source to reach a given receptor; and

• Receptor: A person, animal, plant, eco-system, property, or a controlled water source. If contamination is to cause harm or impact, it must reach a receptor.

A pollutant linkage occurs when a source, pathway and receptor exist together (Booth, 2011). The objective with the mitigation measures is to firstly avoid the risk and if the risk cannot be avoided, mitigation measures to minimize the impact are then recommended. Once the mitigation measures have been applied, the identified risk will be of low significance, provided there is sufficient monitoring of measures’ implementation.

3.2.2 Impact Assessment Criteria The methodology employed for this assessment was adopted from typical environmental assessment reports based on research and analysis of other consultants’ reports on the suitable project assessment methodology.

To enable a scientific approach to the determination of the environmental significance, a numerical value is linked to each rating scale. This methodology ensures uniformity and that potential impacts can be addressed in a standard manner so that a wide range of impacts are comparable.

• Provision of a brief explanation of the impact.

• Assessment of the pre-mitigation significance of the impact; and

• Description of recommended mitigation measures.

Table 1: Impact assessment criteria

Nature Description Rating Extent (Spatial scale) An indication of the physical and Low (1): Impact is localized within the site spatial scale of the impact. boundary: Site only.

Low/Medium (2): Impact is beyond the site boundary: Local.

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Nature Description Rating Medium (3): Impacts felt within adjacent biophysical and social environments: Regional.

Medium/High (4): Impact widespread far beyond site boundary: Regional

High (5): Impact extend National or over international boundaries.

Duration The timeframe, over which the Low (1): Immediate mitigating measures, impact is expected to occur, immediate progress measured in relation to the lifetime Low/Medium (2): Impact is quickly of the project. reversible, short term impacts (0-5 years)

Medium (3): Reversible over time; medium term (5-15 years).

Medium/High (4): Impact is long-term.

High (5): Long term; beyond closure; permanent; irreplaceable or irretrievable commitment of resources

Intensity, Magnitude / The degree or magnitude to which Medium/low (4): Low deterioration, slight Severity (Qualitative the impact alters the functioning of noticeable alteration in habitat and criteria) an element of the environment. The biodiversity. Little loss in species numbers. magnitude of alteration can either be Low (2): Minor deterioration, nuisance or positive or negative irritation, minor change in species / habitat / diversity or resource, no or very little quality deterioration.

Probability of occurrence Probability describes the likelihood Low (1): Improbable; low likelihood; of the impacts occurring. This seldom. No known risk or vulnerability to determination is based on previous natural or induced hazards. experience with similar projects Medium/low (2): Likely to occur from time and/or based on professional to time. Low risk or vulnerability to natural judgment or induced hazards.

Medium (3): Possible, distinct possibility, frequent. Low to medium risk or vulnerability to natural or induced hazards.

Medium/High (4): Probable if mitigating measures are not implemented. Medium risk of vulnerability to natural or induced hazards.

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Nature Description Rating High (5): Definite (regardless of preventative measures), highly likely, continuous. High risk or vulnerability to natural or induced hazards.

3.2.3 Impact Significance This is determined through a synthesis of the above impact characteristics (in Table 1 above). The significance of the impact “without mitigation” is the main determinant of the nature and degree of mitigation required. As stated in the introduction to this chapter, for this assessment, the significance of the impact without prescribed mitigation actions was measured.

Once the above factors (Table 1) have been ranked for each potential impact, the impact significance of each is assessed using the following formula:

SP = (magnitude + duration + scale) x probability

Table 2: Impact significance rating scale

Significance Environmental Significance Points Colour Code

High (positive) >60 H

Medium (positive) 30 to 60 M

Low (positive) <30 L

Neutral 0 N

Low (negative) >-30 L

Medium (negative) -30 to -60 M

High (negative) >-60 H For an impact with a significance rating of high, mitigation measures are recommended to reduce the impact to a low or medium significance rating, provided that the impact with a medium significance rating can be sufficiently controlled with the recommended mitigation measures. To maintain a low or medium significance rating, monitoring is recommended for a period to enable the confirmation of the significance of the impact as low or medium and under control.

The assessment of the project impacts is done for both pre-mitigation (before implementing any mitigation) and post-mitigation (after mitigations are implemented).

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3.3 Reporting All the information obtained from the project Proponent, site knowledge (by Omavi Consultants) and literature review have been analysed and consolidated into this document. The information includes physical settings/conditions of the area, relevant maps, water resources, impact assessment, and recommendations on water resources management and protection. The recommendations made herein will be incorporated into the project Environmental Management Plan (EMP) by Omavi Consultants as the Environmental Assessment Practitioner.

The following chapter presents the national and international legal requirements that are applicable and relevant to this assessment and groundwater resources

4 LEGAL FRAMEWORK FOR WATER RESOURCES MANAGEMENT AND PROTECTION The project’s primary purpose entails the exploration and extraction or mining of dimension stone and this will at some extent require the use of water. The exploration and mining activities, depending on their operational scales and type can potentially have impacts on the water resources, specifically groundwater (in terms of quantity and quality). It is therefore necessary to consider the national legislations and legal requirements governing the water management and protection.

4.1 Applicable National Legal Framework The Namibian legislations that govern the use, management and protection of water resources and related activities are as follows:

• Water Act No. 54 of 1956: To consolidate and amend the laws relating to the control, conservation and use of water for domestic, agricultural, urban and industrial purposes; to make provision for the control, in certain respects, of the use of sea water for certain purposes; for the control of certain activities on or in water in certain areas; for the control of activities which may alter the natural occurrence of certain types of atmospheric precipitation; for the control, in certain respects, of the establishment or the extension of townships in certain areas; and for incidental matters.

• Water Resources Management Act No. 11 of 2013: This Act (Government Gazette 5367) has been passed by Parliament, but it has not yet been brought into force. The Regulations have been passed in December 2016 but have not yet been promulgated. Therefore, the Regulations of the 1956 Water Act still apply. The objectives of this Act are to ensure that the water resources of Namibia are managed, developed, used, conserved, and protected in a manner consistent with, or conducive to, the fundamental principles set out in relevant Sections.

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• Environmental Management Act No. 7 of 2007 and its 2012 Environmental Impact Assessment (EIA) Regulations: The Act aims at promoting sustainable management of the environment and use of natural resources. The Environmental Management Act (EMA) is broad; it regulates land use development through environmental clearance certification and/or Environmental Impact Assessments. The Act provides for the clearance certification for:

o ‘’Regulation 3.1 The construction of facilities for any process or activities which requires a license, right or other forms of authorization, and the renewal of a license, right or other form of authorization, in terms of the Minerals (Prospecting and Mining Acts), 1992 o Regulation 8.1 The abstraction of ground or surface water for industrial or commercial purposes."

• Soil Conservation Act No.76 of 1969: The Act makes provision for the prevention and control of soil erosion and the protection, improvement and conservation of soil, vegetation and water supply sources and resources, through directives declared by the Minister.

• The Water Policy: National Water Policy White Paper, August 2000 (this laid the basis for the new Water Resources Management Act).

The relevant baseline environment of the project site and surrounding broader area interest is presented under the following chapter.

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5 DESCRIPTION OF THE (RELEVANT) RECEIVING ENVIRONMENT The baseline (pre-project site conditions) information of a project area is crucial to one’s understand as it aids in undertaking a concise assessment and make informed conclusions on the proposed project’s impacts on environmental components, such as water resources. The baseline information (conditions) of the site area and broader area that are relevant to this assessment are briefly described below.

5.1 Climate and Topography According to African Planning Forum (2019), Arandis generally experiences all year healthy and bearable climatic conditions where warm days are followed by cool nights. Thus, Arandis can be considered to have a desert climate.

The spatial potential evaporation distribution in Namibia map is presented in Figure 2 with the project area being in the range of 3 200 to 3 400 mm/a. The location of the Arandis area being the nearest town to the mining claims’ site is estimated by the red arrow (between Swakopmund and Usakos) on the western coastal part of Namibia.

Arandis Area

Figure 2: The spatial distribution of potential evaporation in Namibia (after BGR, 2005)

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The only rains fall during the summer months and on average most of this rainfall is experienced from February to April (African Planning Forum, 2019). In the past 10 years, the highest rainfall recorded for Arandis was 51 mm (in February 2011) – Figure 3. African Planning Forum (2019) further states that occasional thunderstorms however do occur turning the small river courses into fast flowing rivulets and flash flood conditions do occur. The average rainfall for the region over the long term is less than 100 mm per year but due to the erratic distribution, much of the area receives less than 50 mm per year.

Figure 3: The rainfall patterns for the Arandis area (source: World Weather Online, 2020)

Figure 4: The maximum, minimum and average temperature Arandis area (source: World Weather Online, 2020)

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With regards to topography, the town of Arandis is located some 581 metres above mean sea level. The area is characterized by undulating hills and sandy valley areas (Africa Planning Forum, 2019). In the Erongo Region, the land rises steadily from sea level to about 1,000 m across the breadth of the Namib. The Namib land surface is mostly flat to undulating gravel plains, punctuated with occasional ridges and isolated ‘inselberg’ hills and mountains (Southern African Institute for Environmental Assessment (SAIEA), 2011). Aurecon Environment and SLR Environmental Consulting (2014) further state that broad geomorphological characteristics include a shore of mixed sand and rock, with gravelly coastal plains in the study area, with the Arandis Mountain (just over 600 m high) further to the east and a narrow dune belt further to the south.

The mining claims’ sites are characterized by hilly mountains (Figure 5) and the Proponent is targeting these mountains for dolerite extraction/mining.

Figure 5: Topography within the mining claims’ site boundary (photo: Omavi Consultants, 2020) 5.2 Soil and Geology According to GCS Water & Environmental Consultants (2017), the soils of Namib Desert are knowns as “syrosems” and calcareous soils. The syrosem soils were formed when solid rock is exposed, mainly broken down by mechanical weathering. Rock fragments and exfoliation chips gather around the outcrops, where they undergo further processes of weathering. The calcareous (from limestone) soils were formed during a pluvial period when a minimum of groundwater was available. The subsoil rises to the surface through capillary action and deposits the dissolved CaCO3 on evaporation, forming the deep soils. The texture of the Namib Desert soil is classified as coarse to moderately coarse. These soils are prone to collapse when disturbed

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The geology of the central region is dominated by the Damara Sequence. This sequence underlies most of central and northern Namibia. The basal arenitic succession of the Nosib Group was laid down between 850 and 700 million years (Ma) ago. There is a large gap in the geological history of the central area after the Damara orogenesis. Sediments of the Karoo Sequence were deposited and largely eroded afterwards, except for some remnants preserved under volcanic rocks. In the early Cretaceous, the continental breaks up of South America and Africa caused widespread volcanic activity. From 180 to 120 Ma ago, basaltic lava erupted from deep-seated fissures and covered large parts of Namibia. Erosion has removed most of these sheet basalts, but their feeder channels are still present in the form of dolerite dykes (dolerite is a coarse-grained basalt). The north-north east striking dykes are found throughout the Namib Desert (Christelis and Struckmeier, 2011). A general geological setting of the project area (enclosed by a light green rectangle) is shown in Figure 6 below.

Figure 6: Geological features of the project area as presented with regards to the Omdel Aquifer (edited after Matengu et al, 2019)

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The geology of the area is also characterized by relatively flat light-brown sand, rocky and gravel plains of the Namib Desert with outcrops of granite and quartzite (GCS Water & Environmental Consultants, 2017). Although windblown sand is found along the foot of the dolerite ridges the topsoil found within the Arandis area generally comprise of gravel plains comprising of surface quartz gravels (Africa Planning Forum, 2019). The general geology map of the project site and surrounding areas is shown in Figure 7.

Figure 7: Approximate geological section (map) and Legends of the project site area extracted from a 1:250 000 geological sheet

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5.3 Hydrology and Catchments The site area does not have significant natural surface bodies such as rivers. According to Africa Planning Forum (2019), the only nearby surface water body is the Khan River, a prominent ephemeral river located south of the Arandis Town. The town therefore falls within the Kahn River catchment area of which in turn is part of the greater Swakop River catchment area. Further north of the town the catchment area of the Omaruru River is found. All these rivers are ephemeral and are dry for most parts of the year.

5.4 Hydrogeology The project site is within the groundwater basin of the Central Namib-Windhoek Area, which according to Christelis and Struckmeier (2011) extends from Windhoek in the east to the Atlantic Ocean in the west. Several towns are situated in the catchment of the Swakop and Khan rivers: Okahandja, Otjimbingwe, Karibib, Usakos and Arandis as well as the Rössing uranium mine.

The Hydrogeological map of Namibia with groundwater potential of rock units is shown in Figure 8 According to this map, the project site area (as shown by the green arrow) is largely found in generally low, locally moderate groundwater potential and in some further areas, very low and limited potential.

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Figure 8: Hydrogeological map of Namibia with rock bodies groundwater potential with the approximate location of project site indicated by the light green arrow on the map

5.4.1 Baseline Groundwater (Borehole) Yields and Levels Moderate yields are also encountered in the marble and schist aquifers around Karibib and the calcrete aquifer in the Kranzberg area at Usakos. But while the marbles supply the much larger town of Otjiwarongo further north, the recharge at Karibib is insufficient to maintain the required yields, and the water supply to thetown and Navachab gold mine is augmented by the Swakoppoort Dam. Other bedrock aquifers in the eastern part of the Namib, e.g. in the former Damaraland, are barely able to supply enough water for stock watering. Many dry boreholes were drilled in this area. The yield potential is generally low, but locally moderate. Yields decrease to very low and limited in the Namib (Christelis and Struckmeier, 2011).

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The groundwater map (in Figure 8) presents a color scheme that subdivides the rock bodies into aquifer (blue, green) and non-aquifers (brown) and further into fractured (green) or porous (blue) ones. Dark blue and dark green illustrate aquifers with high potential and yields generally above 15 m3/h, while the light colors describe aquifers with moderate potential and yields between 3 and 15 m3/h (Winker, 2010). With that said, it can be safely concluded that the light and dark brown colors in the same map represent areas of very low, limited and generally water potential with yield less than 3 m3/h. This is the scenario with the project area (Arandis Town and the mining claims). However, moderate potential and yield areas could be encountered on certain local aquifers (small light green patches around the project area in the map). The probability of encountering such aquifers would be depended on correct siting of boreholes in the area targeting these specific moderate aquifer bodies.

These boreholes do not have specific identification names or numbers, therefore for the purpose of this report they have been named according to their nearest significant features in the area such as farms. The boreholes names, abbreviations and coordinates are presented in Table 1 below and locations shown on the map in Figure 12 (under Chapter 7):

Table 3: Identified boreholes around the mining claims’ area

Borehole Abbreviation Borehole full name GPS Coordinates

HBH Farm Hakskeen Borehole 21°57'22.23"S 15° 8'49.76"E

MHB Maletzky Borehole 22° 0'33.09"S 15°11'35.06"E

MHB2 Maletzky Borehole 2 22° 1'36.82"S 15°12'54.53"E

MMBH Main Maletzky House Borehole 22° 4'11.38"S 15°13'48.96"E

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5.4.2 Groundwater Quality According Christelis and Struckmeier (2011), groundwater in fractured aquifers between the coast and 20-150 km inland is mostly saline. Fractured aquifers with inadequate yields are used at the Spitzkoppe (94) and Tubussis (101) water supply schemes. The Spitzkoppe is a popular tourist attraction in the Erongo Region. The mountain consists of granite intruded into meta-sediments of the Swakop Group. A settlement established at the foot of the mountain depends mainly on tourism and some small stock farming. The water scheme’s boreholes are sited on fractures intersecting the small Spitzkoppe River. Their yields are low, recharge is erratic, and its absence leads to poor water quality of Group C- D. A treatment plant to improve water for domestic consumption has been built.

A local groundwater quality assessment was conducted by BGR for the Khan and Swakop River Catchments in 2010 – Figure 9.

Mining Claims

Arandis

Figure 9: Location of the sampling points for the 2010 Khan-Swakop River Catchment groundwater quality assessment (edited after Kringel et al, 2010)

The spatial distribution of Electrical Conductivity (EC) from groundwater samples from this assessment (study) is shown in Figure 10. According to Kringel et al (2010), generally, the occurrence of low salinity groundwater is restricted to the headwater region of the two rivers. In the downstream region, groundwater is saline. For the Khan River catchment samples with high EC also occur upstream of any discharge point from the Rössing Uranium Mine. Elevated EC is also found upstream of the Langer Heinrich Uranium Mine. Apart from a few exceptions, samples east of 15.35° latitude are in group “excellent” (A) and “acceptable” (B) while to the west of this latitude the groundwater is in group C or lower, making it unsuitable for human consumption. The unsuitability of this poor-quality water could also be explained by complaints received from some farm owners (about salty borehole water in the area) during the project site visit on the 25th to 26th July 2020.

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Mining Claims

Arandis

Figure 10: Spatial distribution of Electrical Conductivity (EC) at the sampled area (Kringel, 2010)

5.4.3 Vulnerability of Groundwater to Over-abstraction The over-abstraction of groundwater in any aquifer in an area does not only affect the surrounding users (humans), but also the general environment (ecosystem) that depends on the same water resource. Over-abstraction would lead to significant lowering of groundwater levels in surrounding boreholes and the eventual gradual depletion of the aquifer. The lowering of the water table also means a decrease in borehole water levels for downstream water users. A decrease in water level in the surrounding (downstream) users' boreholes could increases pumping costs. This is true because advanced pumping equipment would be required to reach the new borehole water levels, thus affecting the rights of pre- existing water users in the area.

Groundwater over-abstraction does not only affect water users and the ecosystem, but also surface water-groundwater interactions which is a crucial component of the hydrologic cycle. Furthermore, over- pumping of groundwater would also induce the intrusion of salt water into the aquifer for aquifers in coastal areas, leading to poor water quality.

The water potential of the project site area, and this part of the Erongo Region is classified as generally low, locally moderate groundwater potential and in some further areas, very low and limited potential. The long-term unmanaged water abstraction from the aquifers with even moderate to good potential would still make the aquifers vulnerable to over-abstraction, therefore it would even be worse for aquifers with low to limited potential. However, the vulnerability of groundwater to over-abstraction would be dependent on the amount of water abstracted from the aquifer and frequency of abstraction.

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With regards to the proposed water use on the project activities (without considering the existing water uses and with the absence of pre-project concerns), the nature and duration of the proposed project activities (specifically exploration being a short-term activity) as well as volume of water required, groundwater vulnerability to over-abstraction owing to the project activities is considered low to slightly moderate. The impact of the proposed project activities on the groundwater resources in the area is describe and assessed under Chapter 8.

5.4.4 Vulnerability of Site Area groundwater resources to Pollution In areas where activities such as extensive agricultural, mining, waste management and industrial activities are practised with poor planning prior to project implementations, groundwater pollution becomes one of the main environmental and social concerns. However, as mentioned in the preceding subsection, poor water quality does not only come from direct pollution from the ground surface, but also from over-abstraction of aquifers, especially the poorly recharged and managed ones. Given the nature, type and scale of the proposed project activities, groundwater vulnerability to pollution owing to the project activities is rather low.

The Groundwater Resources Vulnerability Map of Namibia in Figure 11 shows that the vulnerability of groundwater to pollution in the project area ranges from rather low to moderate. This vulnerability status could be explained by the geology of the site area that is mainly characterized by metamorphic rocks such as granites, dolerite, basalts, marbles, and schists. Groundwater is hosted in both these secondary aquifers (fractured or faulted rocks units) and at some places in unconsolidated sediments in this part of the Namib Desert. These rock units without any fractures/faults or joints are considered aquitards (rock units that restrict water flow or hardly transmit water from one rock unit to the other, which in a way would move pollution in the aquifer system, if present in the water).

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Figure 11: Vulnerability of groundwater resources to Pollution (Van Wyk et.al, 2001)- approximate project site area enclosed by the light green circle

5.5 Vegetation The knowledge and consideration of vegetation cover in an area is crucial as evapotranspiration is one of the important components of the hydrologic cycle, and mostly on groundwater recharge. It is therefore vital to understand the vegetation cover in an area of interest.

Moving westward off the inland plateau and towards the Namib Desert, the vegeation shifts from upland savannas to vegetation more suited to arid conditions. The transition zone between savanna and semi- desert is composed of a great variety of species, many of which are endemic to the Erongo Region (Jacobson et al, 1995). These vegetation species include Euphorbia, Cyphostemma, Moringa, Adenolobus, and Acacia.

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Since the purpose of this report is to assess the impact of the proposed project exploration and mining activities on groundwater, certain factors need to be considered first prior to the actual assessment. Therefore, firstly the volume of water required for the project activities need to be known or at least estimated (Chapter 6). The known or estimated volume of water required for the project activities (preferably worst-case scenario) is needed so that it can be used as an input for reserve estimation/calculations (Chapter 7).

6 PROPOSED GROUNDWATER ABSTRACTION AND USE

6.1 Existing Groundwater abstraction and Use Groundwater in the sub-catchments is used for stock watering, industrial, mining, tourism, and domestic consumption. Water required by commercial water users such as mining and for urban consumption such as towns with the broader catchment is abstracted from the Omaruru Delta Aquifer (Omdel) near Usakos. From here, operated and managed by NamWater, the water is channelled via pipelines to reservoirs for distribution to these different consumers. The catchment includes towns such as Arandis, Usakos, Swakopmund and Henties Bay.

Current water supply sources in Erongo’s coastal region are the Omdel and Kuiseb Aquifers and the desalination plant built and owned by Areva. The Omdel dam, and aquifer recharge scheme was completed in 1994 but its sustainable yield is not fully understood. Based on the water figures in 2000, NamWater calculated that it has a sustainable yield of 9.8 Mm3/a. Water Scarcity Solutions estimated the extractable recharge of Omdel to be about 7.1 Mm3/a (Aurecon Environment and SLR Environmental Consulting, 2014).

According to Aurecon Environment and SLR Environmental Consulting (2014), the domestic demand in the coastal region is estimated to be 12.4 Mm3/a in 2014 and could rise to 14.7 Mm3/a by 2018. The demand in the mining and industrial sectors is predicted to be 5.4 Mm3/a in 2014 and could rise to 13.7 Mm3/a by 2018 with just the certain users, including Rossing Mine. When these demand predictions are balanced with the supply, including being supplied 10 Mm3/a from Areva, there could be a shortfall of about 5 Mm3/a in 2016 which would rise to 8 Mm3/a from 2017 (Aurecon Environment and SLR Environmental Consulting, 2014).

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With regards to the Arandis Town, the terminal reservoir capacity is 60 000 m3 (comprised of three 20 000 m3 reservoirs), and the Rossing Uranium Mine has access to 48 000 m3 or 80% of this stored capacity. The low-level limit is set at 30% of full level, which translates to 6 000 m3 of unusable storage in one reservoir. By adding 2 days of working storage and 2 days of emergency storage for Arandis a further 6 000 m3 of storage is rendered unavailable. This adds to make a total of 12 000 m3 reserved for Arandis, and the remaining 48 000 m3 for the Mine (Aurecon Environment and SLR Environmental Consulting, 2014).

The above water figures have been provided to give a general outlook on the groundwater consumption by major users (towns, industries, and mines) in the Region. This water is however not abstracted from the project site area but from the Omdel aquifer because the project site area’s hydrogeological settings (potential) cannot yield nor cater for such huge volumes of water. The proposed exploration activities will therefore be supplied with water from the same schemes that supply Swakopmund (as mentioned under the next section).

Based on the information gathered on site during the visit conducted on 25 July 2020, on one farm there are four boreholes with depths ranging from 12 to 17 m and they were all dry. The area is drought stricken which according to the consulted farmers led to the deaths of most their livestock (mostly cattle) over the past 2 to 3 years. Some two farmers keep small stock such as goats and sheep.

The water from five of the existing local site boreholes, on Farm Sukses is currently used for stock watering and domestic consumption. Water abstracted from one of the two boreholes on Farm Hakskeen is used for cooking and basic domestic purposes but not for direct drinking (only to make tea and coffee). Water for drinking is abstracted from Farm Black Range borehole and carted onto Farm Hakskeen houses in tanks and stored for use. It should be noted that

With the above said, it can be assumed that the local aquifers around the project site (catchments) are only abstracted by potentially existing small-scale farmers for their stock watering water needs. It should also be noted that due the fact that the water abstracted from these boreholes has not been recorded, there is a lack of baseline information on local water use. Therefore, the total volume of water consumption by local activities depending on these aquifers is unknown.

6.2 Proposed Water abstraction and Use for the Project Activities For both project activities (exploration and mining), the Proponent anticipates the use of water volumes within the range of 3 000 and 6 000 litres of water (i.e. 3 and 6 m3) per day, averaging to a monthly volume of 93 000 and 186 000 litres (93 and 186 m3/month). In case that the exploration activities would be carried out for a year or more, the annual water demand would be 1 116 and 2 232 m3 (1 116 000 and 2 232 000 litres).

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6.2.1 Water Requirements for Exploration Activities A worst-case scenario of the water requirements, a daily volume of 5 000 litres will be used for this report’s considerations and as maximum for the proposed exploration activities. This value would amount to an average of 155 000 litres per month (1 860 m3 or 1 860 000 per year). It is important to note that during this phase, this water will not be abstracted from existing site boreholes but carted from outside the project area (Proponent’s Warehouse water supply line in Swakopmund) as required but not to be transported every day. The water will be stored in industry standard water tanks onsite for project use. Once the feasibility of the target dimension stone is confirmed (by exploration results), the identified dry borehole within the site area to supply water for mining activities will be carefully sited, drilled and installed on or near the mining sites.

The water required for this project will be mainly used for down-the-hole drilling, butterfly cutting during exploration, cleaning, and cooling off drilling/exploration equipment. Water recycling will be prioritized to conserve water.

With this said, there will be no water abstraction from the local aquifers during exploration works.

6.2.2 Water Requirements for Mining Activities A worst-case scenario of the water requirements, a maximum daily volume of 6 000 litres will be used for this report’s considerations and as maximum for the proposed mining activities. This value would amount to an average of 186 000 litres per month (2 232 m3 or 2 232 000 litres per year). The water required for the project will be mainly used for cleaning and cooling off mining equipment. Water recycling will be prioritized to conserve water.

Once the feasibility of the target dimension stone is confirmed (by exploration results), an identified dry borehole within the site area (on Farm Hakskeen) will be rehabilitated to supply water for mining activities. If, upon pump testing and determining the capability of the borehole to yield optimal volumes of water, then it will be pumped for 2 hours on certain days of the week to supplement the required 6 000 litres or less per day. In events that the borehole would only supply a certain amount of water that is even less than the required volumes, for instance 3 000 litres only, then the borehole will be pumped for approximately 0.5 hours to provide half of the water required for mining. However, water will not be pumped from the borehole daily, but only when it is necessary to refill the onsite water storage tanks. These durations are recommended in consideration of the maximum yield (groundwater potential) of 3 m3/h in such an area. However, water will not be pumped from the borehole daily, but only when it is necessary to refill the onsite water storage tanks. These durations are recommended in consideration of the maximum yield (groundwater potential) of 3 m3/h in such an area - as explained under section 5.4.1. Given the poor nature of water potential in the project area (low groundwater potential), the Proponent may need to continue with water augmentation in the mining phase from their Warehouse water supply and stored in industry standard water tanks onsite.

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It is very important to determine or at least estimate the amount of water resource that is available in a certain area, as this helps in setting up management plans for the resource. This is usually done by undertaking a preliminary groundwater reserve estimation for an area to determine the available abstractable (sustainable) water volume. The sustainable water volumes are calculated from the (sub) catchment water balance and then determine the stress index level of the aquifer for the study/project area. Chapter 7 (the next chapter) is a presentation of the preliminary groundwater reserve available for abstraction, which also includes the water balance and groundwater risk assessment (stress index) for the study area. These calculations are only done for the mining phase of the project because it is the only phase of the two where direct water abstraction from site (local) aquifers is anticipated.

7 PRELIMINARY GROUNDWATER RESERVE DETERMINATION A Groundwater Reserve Determination (estimation) was done to enable a fair assessment of the potential impact on groundwater by the proposed exploration and mining activities on the mining claims. To achieve this, a groundwater balance is required to determine the volume of groundwater that can safely be abstracted from the resource (aquifer) in an area. The Groundwater Reserve Determination considers the following parameters:

• Effective recharge from rainfall and specific geological conditions. • Basic human needs for the site. • Groundwater contribution to surface water (baseflow). • Existing and proposed abstraction; and • Surplus reserve.

7.1 Sub-catchment Delineation The project site was delineated by using ArcGIS. The digital elevation model (DEM) was used as an input to enable the delineation of a drainage system and then quantify the characteristics of that system. The tools in the extension allows the user to determine, for any location in a grid, the upslope area contributing to that point and the down slope path that would be followed by the water. This data is usually important during impact assessments.

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According to Robins (2020), groundwater flows on a catchment scale from beneath the higher ground towards the lower ground to discharge as baseflow into the surface waters. The speed of the flow is a function of the hydraulic gradient, or the inclination of the water table, and the permeability or transmissive properties of the rocks. The volume of groundwater in the flow system depends on the effective rainfall, which is the actual rainfall minus evaporation, less any surface water runoff.

With that said, a site sub-catchment delineation map was created for the project site and is shown in Figure 12. The mining claims are found in different catchments and these are labelled in the map as sub-catchment ‘’1’’ (housing Mining Claim 71615, 71616 & 71617) and sub-catchment ‘’2’’ (housing Mining Claim 71609, 71610, 71611, 71612, 71613 & 71614). The two sub-catchments (surface areas) will be used in the calculations to estimate the reserves of the site area. Sub-catchment 1 and 2 have surface areas of 50.26 km2 and 109.34 km2, respectively. Given the two different sub-catchments and the 6 km distance between the two mining claim groups, the groundwater reserve estimation will therefore be done separately for the two groups under the subsequent sections of this chapter. The sub-catchment delineation information for the calculations are given in Table 4.

The boreholes that were identified in the site area (on farms) as described under section 5.4.1 are shown in the catchment delineation map in Figure 12. The boreholes name abbreviations shown in Figure 12 are as follows.

• HBH – Farm Hakskeen Borehole • MHB – Maletzky Borehole • MHB2 - Maletzky Borehole 2 • MMBH – Main Maletzky House Borehole

It should be noted that none of the four boreholes falls under the delineated sub-catchments (‘’1’’ and ‘’2’’), but in the large catchments in the area (Catchment A).

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Figure 12: Sub-catchment delineation map for the mining claims’ site

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Table 4: Sub-catchment information of the mining claims site area

Groundwater Total Area Recharge Rainfall Sub-Catchment contribution (km²) (mm/a) (mm/a) to baseflow (mm/a)

Sub-catchment (‘’1’’) 50.26 3.5 70 0

Sub-catchment (‘’2’’) 109.34 3.5 70 0

7.2 Groundwater Recharge The effective groundwater recharge from rainfall is the portion of rainfall that reaches the groundwater table. The remainder of the rainfall is lost to surface water runoff, evapo-transpiration, and soil moisture. The effective rainfall-recharge is dependent on the rainfall intensity, soil and vegetation characteristics, catchment geology, surface water ponding and the available storage. As a general principle, it can be assumed that an increase in water available in a portion of the catchment (from rain or ponding of surface water) would increase the recharge in the area. Thin soil cover further promotes recharge.

Estimated figures published in literature were utilized to calculate the groundwater recharge in the study area. Usually, groundwater recharge of a site is calculated from a conservative annual recharge derived from annual rainfall. A recharge value for the two sub-catchments was calculated from recharge zones given by Winker (2010) and these are shown in Figure 13 below with the Arandis and the approximate site area indicated as ‘’PS’’.

Figure 13: Recharge zones derived from annual rainfall map (DEA, 2002), after Winker (2010)

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Recharge rates of the catchments which reported by several investigations varied from 0.3 to 10 % of annual rainfall (Winker, 2010). Given low rainfall received in Namibia over the past years, and climatic conditions of the project area, normal or worst-case scenario rainfall will be used to estimate groundwater reserve of the area. A conservative average of 5% of the annual rainfall of 70 mm is used (based on project experience and a value used in literature conducted), which amounts to 3.5 mm/a.

Groundwater recharge (Sub-Catchment ‘’1’’) = Annual Recharge (m/a) x sub-catchment area (m2)

= 0.0035 m/a x 50 260 000 m2

= 17. 59 m3/a

= 48.19 m3/day

Groundwater recharge (Sub-Catchment ‘’2’’) = Annual Recharge (m/a) x sub-catchment area (m2)

= 0.0035 m/a x 109 340 000 m2

= 382 690 m3/a

= 1 048.47 m3/day

7.3 Basic Human need The basic human needs are set by the Water Services Act (Act No. 108 of 1997) at 25 l per person per day. The reserve is calculated by multiplying the number of people living within the confines of a source unit by 25l/day (0.025m3/day). According to the desktop review of the study area, approximately 0.5 people live with a 1 km radius of the sub-catchment (Viles, 2007).

Basic human need (sub-catchment ‘’1’’) = (0.9 people per km2 x 50.26 km2) x 0.025m3/day

= 45.23 x 0.025m3/day

= 1.13 m3/day

Basic human need (sub-catchment ‘’2’’) = (0.9 people per km2 x 109.34 km2) x 0.025m3/day

= 98.41 x 0.025m3/day

= 2.46 m3/day

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7.4 Existing & Proposed Groundwater Abstraction (Reserve Estimation) Groundwater in the sub-catchments is used for stock watering, industrial, mining, tourism, and domestic consumption. Water required by commercial water users such as mining and for urban consumption such as towns with the broader catchment is abstracted from the Omaruru Delta Aquifer (Omdel) near Usakos. From here, operated and managed by NamWater, the water is channelled via pipelines to reservoirs for distribution to these different consumers. The catchment includes towns such as Arandis, Usakos, Swakopmund and Henties Bay.

The estimated value for basic human water consumption in the sub-catchment (not project site specific) has been estimated under section 7.3 but the total volume of water consumption by local activities depending on these aquifers is unknown. Therefore, for the sake of reserve determination, a worst-case scenario guess estimated value will be used to determine the current water abstracted from the local aquifers within the delineated sub-catchments.

As provided under section 6.2.1 and 6.2.2, the exploration and mining activities will require volumes of 5 m3/day and 6 m3/day, respectively. Only the mining activities water volumes or part of it will be sourced from the local aquifers. Exploration activities will be supplied with water from outside the project area through carted water.

7.5 Groundwater Contribution to Baseflow Baseflow is a slightly less visible part of the water balance is seepage or baseflow from the aquifer to streams and rivers where the water table intersects valley bottoms (Robins, 2020). Baseflow is also the low flow in a river during dry or fair-weather conditions, but not necessarily all contributing to groundwater. It includes contributions from delayed interflow and groundwater discharge. Given the low annual rainfall in the area, the baseflow of groundwater into surface water bodies in the study area is considered negligible.

7.6 Water Balance Calculations The water balance, also known as water budget, of an aquifer is defined as a function of inflow/outflow (inputs and outputs to the aquifer system) resulting from head differences between the aquifer and its surroundings. A water budget describes the various components of the hydrologic cycle of the area of interest. The general equation for calculating a water balance of a water system (aquifer) is given below:

Inflow = Outflow ±∆Storage

Whereby,

• ∆S is known to be change in storage.

• Input: precipitation, surface water, groundwater inflow, and recharge; and

• Outputs: evaporation, groundwater outflow, groundwater abstraction.

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According to Michigan Land and Water Management Division (2010), the most difficult part of computing the water budget is locating data that allows accurate estimation of the net surplus or deficit. If the project depends primarily on surface runoff, years with normal, below normal, and above normal rainfall can be identified, and that information can be used to determine the surface runoff under those three climate conditions. Rainfall data are readily available from the National Oceanic and Atmospheric Administration and other agencies. However, if the project area depends on groundwater flow, then ideally one should use groundwater flow data for a range of conditions. However, groundwater flow data, if it exists at all, is usually not available for the period when a permit application is being reviewed.

If the expression on the right-hand side of the equation (result of the calculations) is positive, storage will increase and the water level in the area will rise. A positive change in storage is often termed a surplus, while a decrease in storage is termed a deficit. A water budget is calculated for a specified period. Permanent projects may be evaluated using daily or monthly data, with the resulting net surplus or deficit is expressed as a seasonal or annual value (Michigan Land and Water Management Division, 2010).

The local water balance for the two sub-catchment areas owing to abstracting water for mining activities is presented below (Table 5).

Table 5: Water balance or budget for the project site area (Sub-catchment 1 and Sub-catchment 2)

*The real volume is unknown. Therefore, the value used in this calculation is a worst-case scenario hypothetical (guest estimated from Basic Human Water Need) to represent the volume of existing groundwater abstractions (by domestic, stock watering, small-scale mines, tourism, etc.) from the local aquifers – that according to site visits are not being abstracted due to most boreholes’ dryness. This complication come in when by Law only commercial water users are required to record and submit their water returns (volumes) to the Department of Water Affairs as part of their Water Abstraction and Use Permit conditions. There was no baseline information available on current water abstractions (volumes) from the local aquifers even by local small livestock farmers and small-scale commercial water users. Therefore, it becomes a challenge to present a realistic volume of water abstracted by both commercial and non- commercial users, and eventual a realistic water balance of a catchment.

Sub-catchment ‘’1’’

Parameter Value

Rainfall Recharge (m3/day): +48.19

Basic Human Need (m3/day): -1.13

Groundwater contribution to baseflow (m3/day): 0

Evaporation (m3/day): -9.04

Existing abstractions - estimated from Basic human water needs (m3/day) * -12.30

Other existing abstractions - unaccounted for due to lack of data(m3/day) unknown

Proposed / future abstraction for mining activities only (m3/day) -6.00

Total output from the catchment/aquifers (m3/day) -28.47

Surplus (+) or Deficient (-) Amount: Recharge minus total output (m3/day) +19.72

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Based on the estimated and known (future abstraction) values, the guest estimated water balance of sub-catchment ‘’1’’ indicates an available surplus water volume of 19.72 m3/day or 7 197.80 m3/year.

Sub-catchment ‘’2’’

Parameter Value

Rainfall Recharge (m3/day): +1 048.47

Basic Human Need (m3/day): -2.46

Groundwater contribution to baseflow (m3/day): 0

Evaporation (m3/day): -9.04

Existing abstractions - estimated from Basic human water needs (m3/day) * -98.4

Other existing abstractions - unaccounted for due to lack of data(m3/day) unknown

Proposed / future abstraction for mining activities only (m3/day) -6.00

Total output / losses from the aquifer (m3/day) -115.90

Surplus (+) or Deficient (-) Amount: Recharge minus total output (m3/day) +932.57

The guess estimated water balance of sub-catchment ‘’2’’ indicates an available surplus water volume of 932.57 m3/day or 340 388.05 m3/year. Please note that this value is significantly higher than that of sub-catchment ‘’1’’ owing to the sub-catchment size (area) which was used to estimate groundwater recharge under section 7.2. And again, this result also derived from uncertainties arising from the lack of actual data on the total groundwater abstractions from the catchment and sub-catchment (aquifers).

The following chapter (Chapter 8) covers the potential impacts of the proposed exploration and mining activities on groundwater, with primary focus on possible over-abstraction and pollution. Under the same chapter, these two aspects are described, and assessed (section 8.2 and 8.3).

8 GROUNDWATER IMPACTS: DESCRIPTION AND ASSESSMENT

8.1 General Concept of Impact (Risk) Assessment Generally, an environmental risk occurs when there is a hazard (e.g. process, activity, or substance) that can result in a harmful impact on the surrounding environment. The part of the environment which is, or could be, affected is known as a receptor. Receptors include humans, flora and fauna, the built environment and water resources (controlled waters).

• Source (or hazard): a substance capable of causing pollution or harm.

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• Receptor (or target): something which could be adversely affected by the contaminant.

• Pathway: a route by which contaminants can reach the receptor.

The environmental risk assessment is the process whereby S-P-R linkages are identified and assessed. In the case that any of the three elements are absent, then there is no complete linkage and thus no verifiable unacceptable risk. The magnitude of a risk is a function of the consequences of risk and the likelihood that such rick will occur.

The risk/impact assessment for the three identified potential impacts that may impact the water resources during the duration of the project activities is presented under the subsections below. The subsections provide a brief description to each potential impact (as per the S-P-R system) and then assessed according to the criteria provided (for both the pre-mitigation and post mitigation scenarios) under section 3.2.2 and 3.2.3.

8.2 Groundwater Impact Assessment (Over-abstraction) Groundwater resources is impacted by project developments/activities in two ways, namely through pollution (water quality) or over-abstraction (water quantity) or at times both.

8.2.1 Brief Impact Description – Water Quantity The impact of the project activities on the resources would be dependent on the water volumes required by each project activity (exploration and mining). Commonly exploration activities use a lot of water, mainly in drilling. However, this depends on the type of drilling methods employed (diamond drilling is more consuming compared to drilling methods such as reverse circulation for instance) and the type of mineral being explored for.

The drilling method to be employed for this project’s exploration activities is down-the hole (DTH). According to Jeansson (2014), water is required and used to power the impact mechanism of the hammer at a high frequency rate and bring any cuttings to the surface and clean the borehole. Additionally, the hydrostatic column, which is created above the hammer, helps to keep the hole stable while preventing potential collapse. This also prevents water from being drawn into the borehole, which increases hole stability and prevents potential environmental issues. Using water as a flushing medium also has a secondary effect in terms of borehole cleaning. This is important if the purpose of the borehole is for injection of cement (grouting) for ground improvement. Dust (compressed air + cuttings) clogs cracks, while the water cleans the borehole. This increase both productivity and quality in the grouting process. Water also acts as a lubricant and eliminates the need for any oil. This means that the ground is not polluted and workers or people in the vicinity are not exposed to oil mist or dust caused by the drilling process (Jeansson, 2014).

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In terms of water abstraction and use for mining, the project activities will not use a significant amount of water that would impact the resources in the area as only about 6 000 litres will be required per day. The water will be sourced from a local borehole within the site boundary that will be rehabilitated to a new groundwater level to be able to supply the project. This volume can still be considered reasonable for the project, however, given the potential of local aquifers, the borehole may not be able to supply that amount as needed (even after rehabilitation). Therefore, abstraction from local aquifers may need to be complemented by carted water from areas with good water availability (potential) to ensure that demand pressure is less on the local aquifers, i.e. from areas with little to no water availability issues. Should it come to light that the rehabilitated old borehole cannot not even supply the minimum of water volumes required, then the Proponent may need to have a new borehole sited, drilled and installed in a carefully studied area with the mining claims’ site boundaries.

The assessment of this potential impact on water abstraction from the aquifers is summarized as follows:

• Source: The sources in this aspect will be the over-abstraction of water for the exploration and mining activities, which may affect other water users and the environment. The lowering of the groundwater levels would pose a risk to small-scale water users downstream of the mining claims (to the west, as indicated by the delineated catchments) and to the general biophysical environment.

• Pathway: The pathway is determined by the depth to water table, type of lithology in the area and groundwater flow direction. There is little to no information on groundwater levels in the area. Groundwater within the project area is mostly in the fractured and faulted rock units (granite, basalts, and schists) that are overlain by Namib sediments unconsolidated to semi- consolidated sediments (sand and calcrete). The nature of sediments (unconfined aquifers) would cause rapid a drawdown in boreholes during excessive pumping and leading it to extend over a large area and interfere with nearby borehole yields. However, this impact is minimal because the project site’s groundwater is mainly hosted in the above-mentioned rock units, therefore, rapid drawdown is unlikely.

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• Receptor: The neighbouring farms (boreholes) and other water users (downstream to the west) and surrounding environmental components like vegetation can be considered potential receptors. A hydrocensus would be required to identify all the existing boreholes within a 2 km radius of the project site and include them in a groundwater monitoring network once the project operations start.

Furthermore, based on the impact assessment criteria presented under the Methodology chapter, this impact has been assessed as follows (Table 6).

Table 6: Assessment of the project impact on water resources abstraction (quantity)

Mitigation Extent Duration Intensity Probability Significance Status Pre M - 3 M/H - 4 L/M - 4 M/H - 4 M - 44 mitigation Post L/M - 2 L/M - 2 L - 2 L/M - 2 L - 12 mitigation

8.2.2 Abstraction (Use) Impact Assessment Based on Calculations under Chapter 7 The status of a groundwater resource unit can be assessed in terms of sustainable use, observed ecological impacts or water stress.

• Where demands for water are approaching or exceed the available supply.

• Where water quality problems are imminent or already exist; or

• Where water resource quality is under threat.

To provide a quantitative means of defining water stress, a groundwater stress index was developed by dividing the volume of groundwater abstracted from a groundwater unit by the estimated recharge to that unit (Parsons and Wentzel, 2007).

The groundwater recharge value for sub-catchment ‘’2’’ was used to estimate the stress index of the site area owing to water abstraction for mining activities. This was used to make sure that the assessment on the level of stress to the affected aquifers is close to reality as possible.

Stress Index = Proposed Groundwater Abstraction / Groundwater Recharge

= 6 m3/day / 1 048.47 m3/day

= 0.0057

The stress-index and classes described in Table 7 below, provide a guide for determining the level of stress of a groundwater resource unit, based on abstraction, baseflow and recharge.

Table 7: Guide for determining the level of stress of a groundwater resource unit

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Present Status Category Description Stress Index

A <0.05 Unstressed or low level of stress B 0.05-0.2

C 0.2 – 0.5 Moderate levels of stress D 0.5 – 0.75

E Stressed 0.75 – 0.95

F Critically stressed >0.95

The groundwater risk stress index for the mining claims’ area based on proposed water abstraction of 6 m3 per day is 0.0057. Based on the guide for determining the level of stress of the groundwater resource unit (in Table 7 above), the additional abstraction of 6 m3/day for the proposed mining activities in the sub-catchments is classified as status category A (<0.05). Therefore, the aquifer has an unstressed / low level of stress.

8.3 Groundwater Impact Assessment (Pollution)

8.3.1 Brief Impact Description – Water Quality In areas where activities such as extensive agricultural, mining, waste management and industrial activities are practiced with poor planning prior to project implementations, groundwater pollution becomes one of the main environmental and social concerns. However, as mentioned in the preceding subsection, poor water quality does not only come from direct pollution from the ground surface, but also from over-abstraction of aquifers, especially the poorly recharged and managed ones. Given the nature, type and scale of the proposed project activities, groundwater vulnerability to pollution owing to the project activities is rather low.

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8.3.2 Pollution Impact Assessment The main concern regarding groundwater pollution would be on areas that are underlain by fractured/faulted rock units or partly overlain by the limited sediments. These sediments or fractured rock structures would provide ready passage for pollutants into groundwater, but without faults or fractures, these rock units would behave as aquitards, but not aquifers. If there is a significant point source of pollution, the pollution vulnerability would be bound to fractured/faulted rock units, therefore low (for fractured/faulted rocks) and slightly moderate (for distinctive unconsolidated sediment aquifer areas).

Furthermore, although not significant, measured nor monitored, there could already be an existing pollution from other pre-proposed project (existing) anthropogenic activities undertaken in the site area. These existing activities or some of them could also have been the sources of such pollution. Therefore, it is of great importance to first assess the baseline (water quality) information pre-exploration and mining activities so that future pollution scenarios will not be solely pointed to the proposed project activities, but to also consider the possibility of cumulative occurrence of such an impact (pollution) in the area. Groundwater pollution risk can also arise from localized pollution sources, in combination with the aquifer’s vulnerability to pollution.

The potential impact of pollution arising from the proposed project is described below as per the three elements of risk/impact assessment given under Section 8.1:

• Source: As mentioned above, potential sources of pollution from the project activities would be hydrocarbons (oil) from project (exploration and mining) vehicles, machinery, and equipment as well as potential wastewater/effluent from exploration and mining works.

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Further cumulative sources of pollution are wet waste/effluent from improperly managed sewage facilities, fertilizers, pesticides, and hydrocarbons from other existing anthropogenic activities in the site area. Another significant potential (cumulative) source of pollution in the area is the material from the tailings storage facility (TSF) at Rössing Mine (subject to capping, so that fresh material deposited onto the TSF forms a solid crust after a period of a few months). According to von Oertzen (2015), after this, very little material can be mobilized by wind from this surface. This means that it is the freshly deposited and dried material on the TSF that is most likely to be mobilized by wind. Dust that has been deposited in the plume during the season of east wind tends to have formed a hard crust by the time the next east wind season occurs, and very little further distribution of this material then occurs through wind erosion. Further mobilisation of this material now occurs through water erosion during infrequent rainstorm events, which collect dust from the surface and accumulate the material in gullies. Water erosion therefore collects material which was distributed in a thin layer on the surface and gathers it in small accumulations in lower lying areas. During heavy rainy seasons, these pollutants would be carried by rainwater through surface runoff and infiltrate into the ground, recharge local aquifer systems and pollute them.

• Pathway: Polluted or poor-quality water would travel from the potential sources (points) of pollution downstream of the sites in the project area. In some parts of the site areas that may be underlain by the porous and unconsolidated sediments (aquifers), these aquifers in these parts may be prone to pollution risk. Given the high permeability of such sediments, water can enter the groundwater system easily and rapidly. In events of high pollution on the surface, the nature of these sediments would be expected to cause rapid infiltration of pollutants to groundwater and spreading of pollutants over a large area. In parts of the project areas underlain by the consolidated rocks such as dolerite, basalts, schists and marbles, the pollution transport would not penetrate the aquifers. This could be because of the presence of these host rocks (if not fractured) that act as pollution barriers (aquitards), thus preventing or delaying any possible pollutant transport in groundwater.

• Receptor: The impact could be felt by communities who depend on boreholes, especially those downstream of the site and they would be considered potential receptors of this pollution from sources given above. Surrounding few environmental bio-components like vegetation can also be considered as potential receptors. A sudden worsened groundwater quality downstream during the project’s long-term operations (mining) would at some extent be linked to the project activities. However, a thorough study would need to be undertaken to confirm that the experienced water quality issue has been indeed worsened by the mining activities on the mining claim sites.

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From the above description of the impact, it can be concluded that without implementing any measures to avoid or minimize the impact, the impact significance will moderate and once the mitigation measures have been implemented, the significance will be reduced to low. The assessment is also presented in Table 8 below.

Table 8: Assessment of the project impact on groundwater resources (quality)

Mitigation Extent Duration Intensity Probability Significance Status Pre M - 3 M - 3 L/M - 4 M - 3 M - 30 mitigation Post L/M - 2 L/M - 2 L - 2 L - 1 L - 6 mitigation

After assessing the site area based on the available information, literature and professional judgement, the impact of pollution on the groundwater resources, this impact is considered low. Furthermore, the project impact is short-term, i.e. the potential impact will only exist during the exploration phase and long-term for the mining phase following exploration works.

The next chapter (Chapter 9) presents the groundwater abstraction management plans to ensure groundwater protection against over-abstraction (overexploitation) and potential pollution.

9 GROUNDWATER MANAGEMENT MEASURES The following groundwater management plans are recommended, and they should be effectively implemented and monitored by the project Proponent to mitigate and effectively manage the potential impacts on groundwater resources in the area.

9.1 Groundwater Abstraction Management Plans Over-abstraction of both surface and groundwater resources can have severe impacts on people, animals and surrounding environment supported by the same water resource. Therefore, it is very important to manage water abstraction. If too much groundwater is abstracted, the aquifer may become depleted. The depletion of groundwater has adverse impacts like drying up of shallow water boreholes, deterioration of water quality and a decrease in groundwater levels, which results in increased water pumping costs (GCS Water & Environmental Consultants, 2016). It is therefore important to manage the abstraction from an aquifer.

The following management action plans are recommended to mitigate the impact of groundwater (over) abstraction:

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42 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

• As per the preceding point, if it comes to siting a completely new borehole, this borehole should be carefully sited, drilled, installed and their sustainable yields determined during the aquifer test (pumping test) by a qualified and experienced hydrogeologist. The hydrogeologist will then recommend a safe (sustainable) abstraction yield for the site to the Proponent to ensure that the local aquifers are not stressed, i.e. not negatively impacted by this local over abstraction.

• Like with their previous operations, the Proponent should aim to use water efficiently, recycle and re-use where necessary and possible.

• Putting into consideration the low borehole yields in the project area, the project borehole should be pumped for 0.5 hours in a day (also as backed up by the Hydrogeologist’s pump test recommendations above) during mining to cover at least half of the required volumes of water while considering the minimum hourly yield that a borehole on a dark brown area of the groundwater map (Figure 8) can provide. Therefore, the Proponent would need to pump this water from the borehole on certain days of the week only (not every day) and store the required water in industry standard water tanks on site. This is to avoid abstracting water from the borehole daily (which would stress the aquifers further) and allow the borehole water level some time to recover from the pumping.

43 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

9.2 Groundwater Pollution Management Plans It is important to note that the potential pollution from the project does not constitute the absence of current (cumulative) and future anthropogenic activities that are already or will be contributing to groundwater pollution in the project area. Nevertheless, to avoid and or minimize the potential impact of pollution stemming from the project activities, the following measures are recommended for implementation:

• Project machines and equipment should be equipped with drip trays to contain possible oil spills when operated during exploration and mining works.

44 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

• Although fuel (diesel) required for exploration equipment will be stored in a tank mounted on a mobile trailer, drip trays must be readily available on this trailer and monitored to ensure timely cleanup of accidental fuel spills along the tank trailer path/route around the exploration sites.

o Identification of oil storage and use locations on site and allocate drip trays and polluted soil removal tools suitable for that specific surface (soil or hard rock cover) on the sites. o Maintain equipment and fuel storage tanks to ensure that they are in good condition thus preventing leaks and spills. o The oil storage and use locations should be visually inspected for container or tank condition and spills. o Maintain a fully provisioned, easily accessed spill kit. Spill kits should be located throughout the active project sites contain the floor dry absorbent material and absorbent booms, pads, mats. These would be suitable for ground surface areas that are covered mainly by hard rocks. o All project employees should be made aware of the impacts of soil pollution and advised to follow appropriate fuel delivery and handling procedures. o Develop and prepare countermeasures to contain, clean up, and mitigate the effects of an oil spill. This includes keeping spill response procedures and a well-stocked cache of supplies easily accessible. o Ensure employees receive basic Spill Prevention, Control, and Countermeasure (SPCC) Plan training and mentor new workers as they get hired in each phase of the project.

45 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

9.3 Groundwater Monitoring: Abstraction (Water Levels) and Pollution (Quality) According to Hertsted (2014), sufficient monitoring and reporting demonstrates compliance and enables management to make informed decisions that minimize environmental impacts to groundwater and dependent ecological systems.

9.3.1 Basic Groundwater Level Monitoring During the Mining Phase The lack of a comprehensive groundwater monitoring programme during a project’s operation precludes getting an overall and clear presentation of groundwater data in the area and a groundwater database should be developed as soon monitoring starts. The following are as minimum required for the mining phase:

• Monthly recording of water levels in the site production and monitoring boreholes(s) as well as surrounding farms; boreholes.

Hydrocensus is a survey that involves the gathering information on water features or supply in an area of interest. This includes such as borehole, dams, and river water levels, GPS coordinates and elevations as well as sampling water bodies. This survey is usually conducted within 2 km of the site

radius.

9.3.2 Basic Groundwater Quality Monitoring Conventional groundwater monitoring through sampling of production boreholes is not reliable to detect incipient groundwater pollution before widespread pollution occurs. Thus, vadoze zone monitoring or specially designed monitoring boreholes are needed for this purpose (Lee and Jones-Lee, 2007). A lot of boreholes would be ideal for a big-scale mining operation to capture pollution from different potential sources on such a mine site. However, given the (small to medium) scale of operation for Okonde Mining and Exploration, one or two monitoring boreholes would be sufficient for this task. The monitoring borehole(s) would be drilled at least 50 m downstream of the mining site where actual mining is taking place, machinery/equipment are kept and different hazardous substances like fuels are stored and used on the sites. The borehole(s) location would be determined during siting once exploration works are completed and mining spots (sites) confirmed. The same borehole(s) would also be used to monitor groundwater levels together with surrounding farm boreholes to form a monitoring network.

Monitoring results would be then handled as follows:

• The first monitoring samples’ results would be analysed against the background (baseline) water quality of the study area, if available from the landowners (farmers) and the Department of Water Affairs at the Ministry of Agriculture, Water and Land Reform. Groundwater quality monitoring (sampling) is recommended to be undertaken on a quarterly basis (twice a year, preferably in the months of March/April – after the raining season and September/October – prior to the raining season).

46 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

• The following sample results after the first one will then be compared against both the baseline water quality and the preceding months’ measurements (concentrations).

An annual report will be prepared and made available to the responsible unit of the Department of Water Affairs as per conditions and instruction stipulated in the water permit.

The recommendations and conclusions made for the overall assessment are as presented under Chapter 10 below.

10 RECOMMENDATIONS AND CONCLUSIONS The aim of this report was to assess the potential impacts of the proposed exploration and mining activities on the groundwater resources. The assessment has been undertaken on a desktop level, i.e. based on information provided by Omavi Geotechnical & Geo-Environmental Consultants (the project Environmental Assessment Practitioner/Consultant) obtained from their own site visit, information provided by the project proponent, author’s professional judgment complemented by experience as well as review of previous relevant studies conducted within proximal distance from the project.

The recommendations provided to the assessment and conclusions made are presented under the following sections (10.1 and 10.2):

10.1 Recommendations Given the assessment results, to manage and protect the water resources, the following management measures should be implemented:

Groundwater Abstraction and Use Mitigation Measures

47 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

o Mining: Once the dimension stone deposits are verified and have met the criteria for mining viability, the Proponent will have to apply for the Groundwater Abstraction and Use Permit (GWAUP) prior to commencing with mining activities. This permit must be applied for and obtained from the national Department of Water Affairs (DWA) at the Ministry of Agriculture, Water and Land Reform (MAWLR) to regulate and manage water abstracted from borehole for the project. In the Permit, the Water Regulatory Authority would set objectives (abstraction targets), conditions, annual abstraction threshold, monitoring requirements and enforce compliance by the Proponent.

• As per the preceding point, if it comes to siting a completely new borehole, this borehole should be carefully sited, drilled, installed and their sustainable yields determined during the aquifer test (pumping test) by a qualified and experienced hydrogeologist. The hydrogeologist will then recommend a safe (sustainable) abstraction yield for the site to the Proponent to ensure that the local aquifers are not stressed, i.e. not negatively impacted by this local over abstraction.

48 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

• Like with their previous operations, the Proponent should aim to use water efficiently, recycle and re-use where necessary and possible.

• Putting into consideration the low borehole yields in the project area, the project borehole should be pumped for 0.5 hours in a day (also as backed up by the Hydrogeologist’s pump test recommendations above) during mining to cover at least half of the required volumes of water while considering the minimum hourly yield that a borehole on a dark brown area of the groundwater map (Figure 8) can provide. Therefore, the Proponent would need to pump this water from the borehole on certain days of the week only (not every day) and store the required water in industry standard water tanks on site. This is to avoid abstracting water from the borehole daily (which would stress the aquifers further) and allow the borehole water level some time to recover from the pumping.

49 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

Groundwater Pollution Mitigation Measures

• Project machines and equipment should be equipped with drip trays to contain possible oil spills when operated during exploration and mining works.

• Although fuel (diesel) required for exploration equipment will be stored in a tank mounted on a mobile trailer, drip trays must be readily available on this trailer and monitored to ensure timely cleanup of accidental fuel spills along the tank trailer path/route around the exploration sites.

o Identification of oil storage and use locations on site and allocate drip trays and polluted soil removal tools suitable for that specific surface (soil or hard rock cover) on the sites.

50 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

o Maintain equipment and fuel storage tanks to ensure that they are in good condition thus preventing leaks and spills. o The oil storage and use locations should be visually inspected for container or tank condition and spills. o Maintain a fully provisioned, easily accessed spill kit. Spill kits should be located throughout the active project sites contain the floor dry absorbent material and absorbent booms, pads, mats. These would be suitable for ground surface areas that are covered mainly by hard rocks. o All project employees should be made aware of the impacts of soil pollution and advised to follow appropriate fuel delivery and handling procedures. o Develop and prepare countermeasures to contain, clean up, and mitigate the effects of an oil spill. This includes keeping spill response procedures and a well-stocked cache of supplies easily accessible. o Ensure employees receive basic Spill Prevention, Control, and Countermeasure (SPCC) Plan training and mentor new workers as they get hired in each phase of the project.

Groundwater Monitoring:

The following monitoring exercises are recommended during the mining phase:

• Monthly recording of water levels in the site production and monitoring boreholes(s) as well as surrounding farms; boreholes.

• The following sample results after the first one will then be compared against both the baseline water quality and the preceding months’ measurements (concentrations).

• Conducting a quarterly Hydrocensus of the neighbouring farms to monitor the movement of and detect possible pollution from the mining site.

51 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

10.2 Conclusions Water abstraction (use): For exploration activities, the impact on local groundwater resources (abstraction) will be very low to none because the required water will be carted to site from Swakopmund and kept in water tanks on site. During the mining phase, the impact on groundwater will be moderate to low because of the project magnitude (small to medium) and the project activities will not require a large amount of water to operate like a typical mine where significant amount of water would be required daily and or annually. Therefore, the impact on groundwater resources from the exploration and mining activities is minimal, provided that the recommended management measures (plans) are effectively implemented.

52 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

53 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

11 REFERENCES LIST Africa Planning Forum. (2019). Environmental Scoping Report: Construction and Operation of Arandis Data Center, Arandis Erongo Region. Windhoek: Ministry of Environment, Forestry and Tourism. Retrieved from http://eia.met.gov.na/screening/30_Final%20EMP%20Arandis%20Data%20Center.pdf

Aurecon Environment and SLR Environmental Consulting. (2014). Social and Environmental Impact Assessment for the Proposed Rossing Uranium Desalination Plant near Swakopmund, Namibia. Windhoek: Rossing Uranium .

British Geological Survey. (2020, May 6). Earthwise. Retrieved from Atlas Groundwater Africa: Hydrogeology of Namibia: http://earthwise.bgs.ac.uk/index.php/Hydrogeology_of_Namibia#Groundwater- Surface_Water_Interaction

GCS Water & Environmental Consultants. (2016). Okatji Marble Mine Water Use Permit Application. Windhoek: Unpublished.

GCS Water & Environmental Consultants. (2017). National Environmental Assessment for the MTC Namibia 100% Population Coverage Project: Landscape Specialist Report. Windhoek: MTC Namibia.

GCS Water & Environmental Consultants. (2018, January 18). MTC Namibia. Retrieved from Old MTC Namibia Website - Environment: Downloads: http://www.oldmtcweb.mtc.com.na/pdf/gcs-pdf/Appendix_C_Baseline_Report.pdf

Hertsted, O. (2014). Groundwater Management Plan: Environment. Perth: Fortescue Metals Group.

Christelis, G and Struckmeier, W (eds). (2011). Groundwater in Namibia: An Explanation to the Hydrogeological Map. Windhoek: Department of Water Affairs.

Jacobson, P.J,. Jacobson, K.M and Seely, M.K. (1995). Ephemeral Rivers and their Catchments: Sustaining People and Development in Western Namibia. Windhoek: Desert Research Foundation of Namibia.

Land and Water Management Division. (2010). Michigan State. Retrieved from General Guidelines for Calculating a Water Budget: https://www.michigan.gov/som/

Lee, G. F and Jones-Lee, A. (2007). Focus on Irrigated Agriculture Pollution of Groundwater Excerpt from "Groundwater Quality Protection Issues". Sacramento: G. Fred Lee and Associates.

Matengu, B., Xu, Y and Tordiffe, E. (2019). Hydrogeological characteristics of the Omaruru Delta Aquifer System in Namibia. Springer-Verlag.

54 Groundwater Impact Assessment Okonde Mining and Exploration CC DGIA: Mining Claims 71609–71617

Parsons, R. and Wentzel, J. (2007). Groundwater Resource Directed Measures Manual.109pp. Pretoria: Department of Water Affairs and Forestry (South Africa).

Robins, N. (2020). Introducing Hydrogeology. Edinburgh: Dunedin Academic Press Ltd.

Southern African Institute for Environmental Assessment (SAIEA). (2011). Strategic Environmental Assessment for the Central Namib Uranium Rush. Windhoek: Ministry of Mines & Energy.

SRK. (2006). Preliminary Surface and Ground Water Impact Assessment for the Scoping Supplementation: Assessment for the Proposed New Filling Station in Paul Kruger Street, Secunda. Northlands: SRK.

Strohbach, B. J. (2008). Mapping the Major Catchments of Namibia. Windhoek: Namibia University of Science and Technology.

Van Wyk, A.E., Strub, H. and Struckmeier, W. (2001). Hydrogeological Map of Namibia, Scale 1:000 000 : Vulnerability of Groundwater Resources Map. Windhoek: Ministry of Agriculture, Water and Forestry. von Oertzen, G. (2015). Risk assessment on Rossing Uranium mine's tailings dust. Aachen: Brenk Systemplanung GmbH.

Winker, F. (2010). Groundwater Model of the Swakop River Basin. Freiburg: University of Freiburg.

World Weather Online. (2020). Arandis - Erongo Region, Namibia Weather. Retrieved April 8, 2020, from World Weather Online: https://www.worldweatheronline.com/arandis-weather- averages/erongo/na.aspx

55 Groundwater Impact Assessment APPENDIX J: ARCHAEOLOGICAL ASSESSMENT REPORT FOR MINING CLAIMS 71609-71617 SITE

7 October 2020 OMAVI Geotechnical & Geo-environmental Consultants Windhoek Namibia

For attention: Ms F. Shagama, Environmental Assessment Practitioner

ARCHAEOLOGICAL ASSESSMENT OF PROPOSED MINING LICENCE CLAIMS 71609-71617 LOCATED ON FARMS SUKSES AND HAKSKEEN, AND AN AREA OF INTEREST LOCATED ON FARM TREKOPJE WITHIN EPL 5161, ERONGO REGION, NAMIBIA

John Kinahan, Archaeologist P.O. Box 22407 Windhoek Namibia

DECLARATION

I hereby declare that I do:

(a) have knowledge of and experience in conducting assessments, including knowledge of Namibian legislation, specifically the National Heritage Act (27 of 2004), as well as regulations and guidelines that have relevance to the proposed activity;

(b) perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;

I also declare that I have no interests or involvement in:

(i) the financial or other affairs of either the applicant or his consultant

(ii) the decision-making structures of the National Heritage Council of Namibia.

John Kinahan, Archaeologist

EXECUTIVE SUMMARY

An archaeological field survey was carried out on Mining Claims 71609-71617 on farms Sukses and Hakskeen in the Erongo Region. The field survey located a number of late pre-colonial archaeological sites although none found within the proposed area of exploration and mining were considered to be significant or to require special mitigation measures. It is recommended that the project adopt the attached Chance Finds Procedure devised for mining projects.

Furthermore, a desk study was carried out on a portion of EPL5161 on the farm Trekopje, also in the Erongo Region. Previous archaeological surveys which did not cover the whole of the area of the proposed exploration and mining activities identified a number of sites, including two cemeteries in the near vicinity of Trekopje Siding. It is recommended that the battlefield be designated a No-Go area for the proposed exploration and mining activities and that it should be excised from the prospecting licence area until a detailed survey has been conducted.

TABLE OF CONTENTS

1. Introduction

2. Legal requirements

3. Project description

4. The receiving environment

5. Conclusions & recommendations

6. Bibliography

Appendix 1 Chance finds procedure

1. INTRODUCTION

1.1 Background

Okonde Mining and Exploration cc intends to undertake exploration and subsequent mining activities on nine mining claims located on the farms Sukses and Hakskeen, and Best Cheers Investment Namibia (Pty) Ltd intends similar activities on a portion of EPL 5161 located on the farm Trekopje. All of the exploration and mining properties are located near Arandis, in the western Erongo Region of Namibia. Mining is listed in the Environmental Management Act (2007) as an activity requiring environmental assessment and the issuance of an Environmental Clearance Certificate.

Omavi Consultants has been engaged to carry out an environmental assessment (EA) of the proposed project in terms of the Environmental Management Act (2007). Archaeological remains in Namibia are protected under the National Heritage Act (2004) and National Heritage Regulations (Government Notice 106 of 2005), and projects of this magnitude are also subject to archaeological assessment. Omavi has accordingly appointed the undersigned, J. Kinahan, archaeologist, to carry out this assessment.

1.2 Terms of Reference

The primary task of the archaeological assessment reported here was to identify sensitive archaeological sites that could be affected by the proposed exploration and mining activities. The archaeological assessment forms the basis of recommended management actions to avoid or reduce negative impacts, as part of the environmental assessment. The study is intended to satisfy the requirements of the relevant legislation and regulations, in which the process of review and clearance may require further, or different mitigation measures to be adopted.

Specifically, the archaeological assessment addresses the following primary elements:

1. The identification and assessment of potential impacts on archaeological/heritage resources, including historical sites arising from the proposed exploration and mining activities. 2. The identification and demarcation of highly sensitive archaeological/heritage sites requiring special mitigation measures to eliminate, avoid or compensate for possible destructive impacts. 3. Formulation and motivation of specific mitigation measures for the project to be considered by the authorities for the issuance of clearance certificates. 4. Identify permit requirements as related to the removal and/or destruction of heritage resources.

1.3 Assumptions & Limitations

Archaeological assessment relies on the indicative value of surface finds recorded in the course of field survey. Field survey results are augmented wherever possible by inference from the results of surveys and excavations carried out in the course of previous work in the same general area as the proposed project, as well as other 6

sources such as historical documentation. Based on these data, it is possible to predict the likely occurrence of further archaeological sites with some accuracy, and to present a general statement (see Receiving Environment, below) of the local archaeological site distribution and its sensitivity. However, since the assessment is limited to surface observations and existing survey data, it is necessary to caution the proponent that hidden, or buried archaeological or palaeontological remains might be exposed as the project proceeds

2. LEGAL REQUIREMENTS

The principal instrument of legal protection for archaeological/heritage resources in Namibia is the National Heritage Act (27 of 2004). Part V Section 46 of the Act prohibits removal, damage, alteration or excavation of heritage sites or remains. Section 48 ff sets out the procedure for application and granting of permits such as might be required in the event of damage to a protected site occurring as an inevitable result of development. Section 51 (3) sets out the requirements for impact assessment. Part VI Section 55 Paragraphs 3 and 4 require that any person who discovers an archaeological site should notify the National Heritage Council. Heritage sites or remains are defined in Part 1, Definitions 1, as “any remains of human habitation or occupation that are 50 or more years old found on or beneath the surface”.

It is important to be aware that no specific regulations or operating guidelines have been formulated for the implementation of the National Heritage Act in respect of archaeological assessment. However, archaeological impact assessment of large projects has become accepted practice in Namibia during the last 25 years, especially where project proponents need also to consider international guidelines. In such cases the appropriate international guidelines are those of the World Bank OP/ BP 4.11 in respect of “Physical Cultural Resources” (R2006-0049, revised April 2013). Of these guidelines, those relating to project screening, baseline survey and mitigation are the most relevant.

Archaeological impact assessment in Namibia may also take place under the rubric of the Environmental Management Act (7 of 2007) which specifically includes anthropogenic elements in its definition of environment. The List of activities that may not be undertaken without Environmental Clearance Certificate: Environmental Management Act, 2007 (Govt Notice 29 of 2012), and the Environmental Impact Assessment Regulations: Environmental Management Act, 2007 (Govt Notice 30 of 2012) both apply to the management of impacts on archaeological sites and remains whether these are considered in detail by the environmental assessment or not.

3. PROJECT DESCRIPTION

The proposed exploration and mining activities to be carried out on the farms Sukses, Hakskeen and Trekopje are described in the Environmental Scoping Assessment (ESA) Report for the Proposed Exploration and Mining of Dimension Stone on Mining Claims 71609-71617 in the Erongo Region (MEFT Application 001763 of 28 August 2020) prepared for Okonde Mining and Exploration cc, by Omavi Geotechnical and Geo-environmental 7

Consultants, Windhoek. The proposed activities will include the use and/or construction of access tracks,

Figure 1: The Okonde Mining and Exploration cc Area of Interest, showing the known distribution of archaeological sites in the Erongo Region.

establishment of field camps, earthmoving to expose bedrock, bulk sampling of selected outcrop material, as well as mining and removal of material for processing and possible export. The ESA document does not consider the possible impact of the project on protected archaeological/heritage resources and the consultants were therefore directed by the National Heritage Council to obtain appropriate assistance with this requirement.

In response to a separate Environmental Management Plan (EMP) compiled by Omavi for possible dimension stone exploration and mining in the Trekopje area (EPL 5161), the National Heritage Council (letter dated 24 September 2020) directed the consultants to conduct a heritage impact assessment of the area in which these activities are to take place. The letter directed the consultants to “carry out a heritage assessment to identify and further present an assessment of cumulative impacts…., map out sensitive areas, and provide practical mitigation to avoid or reduce negative impacts, and set out associated long-term monitoring requirements for managing and conserving heritage resources in the project area.”

In consultation with Omavi, the undersigned agreed to conduct a direct field survey of Mining Claims 71609- 71617 on farms Sukses and Hakskeen and this was carried out on 26 and 27 September 2020. Omavi requested the undersigned to carry out a desk assessment of a proposed target area on EPL5161 using the results of previous field surveys which had traversed the lease area. The surveys did not however cover the whole of the proposed target area. This report is therefore based on current observations for the state of archaeological/heritage resources on the farms Sukses and Hakskeen and relies on an earlier (incomplete) survey of the Trekopje area.

4. THE RECEIVING ENVIRONMENT

4.1 Background

Due to its aridity, western Namibia including the vicinity of Arandis and the proposed Okonde project location, presents a marginal environment for human occupation, and in the past, particularly during periods of climatic cooling and hyper-aridity, the region may have been quite inimical to settlement. These conditions are reflected in the available archaeological evidence, which spans the last 0.8 million years with a sequence that is characterized by short periods of relatively intensive occupation, and long periods in which there appears to have been little or no human presence (see Kinahan 2011).

The region surrounding Arandis has been the focus of several archaeological surveys and assessments during the last two decades. These surveys have helped to determine the local archaeological sequence and to establish the relationship between archaeological sites and the particular types of terrain that characterize the area, including gravel outwash fans, granite outcrops and the many dolerite ridges that criss-cross the landscape. However, archaeological surveys for mining and infrastructure projects are highly focussed on the area of a particular project footprint and do not therefore as a rule reflect the wider archaeology of the area. 9

Taken together, the cumulative results of earlier surveys provide an indication of the archaeological importance of this general area, although the intensity of survey varies considerably and large parts of the area are archaeologically unknown. The general sequence and archaeological characteristics of the area under consideration, based on current knowledge, are as follows:

a. Early to mid-Pleistocene (ca. 2my to 0.128my; OIS 6, 7, 19 &c): represented by surface scatters of stone tools and artefact debris, usually transported from original context by fluvial action, and seldom occurring in sealed stratigraphic context. b. Mid- to upper Pleistocene (ca. 0.128my to 0.040my; OIS 3, 4 & 5a-e): represented by dense surface scatters and rare occupation evidence in sealed stratigraphic context, with occasional associated evidence of food remains. c. Late Pleistocene to late Holocene (ca. 0.040my to recent; OIS 1 & 2): represented by increasingly dense and highly diverse evidence of settlement, subsistence practices and ritual art, as well as grave sites and other remains. d. Historical (the last ca. 250 years): represented by remains of crude buildings, livestock enclosures, wagon routes and watering points. Of particular importance in the project area is evidence relating to the 1915 World War I conflict between Allied and colonial German forces, including the Battle of Trekopje which took place on 26th April 1915.

In summary, early to mid-Pleistocene sites are associated with pans, outwash gravels, drainage lines and river gravels, although on the Namib coast some mid-Pleistocene sites are associated with relict beach levels (Corvinus 1983; Deacon & Lancaster 1988). These sites are difficult to detect and because they are easily overlooked in the course of mining or construction work they are often damaged or destroyed in the process. An example of mid-Pleistocene stone artefacts is illustrated in Figure 2. Mid- to upper Pleistocene sites occur in similar contexts to the earlier material, but hill foot-slopes and outcrops of rock suitable for artefact production (e.g. chert, fine-grained quartzites) are also focal points. Late Pleistocene to late Holocene sites occur in almost every terrain setting, with the exception of very steep slopes and mountain tops (Deacon 1972; Kinahan 2011). These sites often exhibit locally integrated distribution patterns which allow some reconstruction of land-use and subsistence. Major Holocene sites include stratified occupation deposits, containing an array of organic and inorganic residues.

Significant changes in human settlement patterns and economic activities occurred during the last 5000 years in the Namib Desert and in the immediate semi-desert hinterland. These include several specialized subsistence technologies, and in the last 2000 years the adoption of livestock keeping which lead to the emergence of a predominantly nomadic pastoral economy. One such development that is directly relevant to the Arandis area is the intensified exploitation, especially during the last 1000 years, of wild grass seed as a major source of human nutrition, and the use of organized communal hunts aimed at migratory antelope, especially oryx. These two activities left clearly recognizable traces on the landscape and have been the subject of intensive research to establish a detailed understanding of late pre-colonial desert subsistence. The archaeological signature traces 10

of both activities are known in sufficient detail that they are clearly visible in the field. The sites are at the same time quite subtle in appearance and their recognition in the field requires considerable experience.

Figure 2: Examples of typical mid-Pleistocene Acheulean handaxes from the Namib Desert in the area to the north of Arandis.

Archaeological evidence related to the exploitation of wild grass seed includes well preserved shallow diggings where caches of grass seed (still known today as sâun in Khoekhoegowab) were extracted from the nests of harvester ants (Messor denticornis). The seed was cleaned and stored in highly characteristic bag-shaped pottery vessels (see Fig. 3). Processing of the seed for cooking was carried out using grinding surfaces on granite outcrops, usually outcrops with cavities where supplies of rainwater collect after summer showers in the desert. These different components of the seed exploitation assemblage are usually found together in localized concentrations, each covering an area of several square kilometres. Sometimes the sites are also associated with the remains of small groups of hut dwellings or natural rock shelters, occasionally containing painted rock art and other archaeological evidence.

The second component of the recent archaeological record that is relevant to the present study, and comprising evidence of communal hunting of migratory antelope, is closely associated with dolerite dyke outcrops which are a characteristic feature of the landscape in the vicinity of Arandis. Dolerite dykes form natural barriers to the movement of migratory antelope and late precolonial hunters exploited these by siting themselves in breaks 11

between the outcrops where antelope were funnelled from one area of grazing to another. The hunters constructed stone shelters, arcuate in shape and approximately 2m in diameter, which they positioned as hiding places close to paths used by the antelope. Some communal hunting sites include more than 50 such structures and suggest that orchestrated communal hunts took place involving several hundred people. Most of the hunting sites are relatively small, however, and suggest groups of no more than ten hunters. It is difficult to reliably date these structures since they do not contain organic remains suitable for radiocarbon dating. Experimental dating of some sites using Optically Stimulated Luminescence (OSL) has produced satisfactory results, as shown in Table 1, below. More OSL dates are needed to establish the age range of these unusual features.

Table 1: Dating of hunting blind structures using Optically Stimulated Luminescence1 (Results from Kinahan 2020).

Site Dose (Gy) Dose rate (Gy/ka) Age (years)

Gorrasis 0.34±0.04 2.40±0.12 140±20 1.14±0.13 3.00±0.15 380±50 Husab 0.28±0.03 4.01±0.38 260±50 0.28±0.03 5.38±0.51 230±60 0.28±0.03 6.05±0.63 240±60

A final component of the local archaeological sequence that is relevant to the present study is the evidence of the 1915 Allied invasion which ended the period of German colonial occupation in Namibia. The invasion formed part of a number of campaigns in different parts of Africa, the Middle East and elsewhere to capture the colonial possessions of Germany. The campaign in Namibia is of both historical and archaeological interest due to the fact that evidence of the conflict is unusually well preserved on the ground, most particularly in the Namib Desert. The area of interest in EPL 5161 includes the whole of the battlefield where Allied and German forces engaged in the Battle of Trekopje in April 1915. Previous archaeological surveys have documented some features

1 Optically Stimulated Luminescence, or OSL, is useful in desert conditions where organic remains are not available for radiocarbon dating. OSL dating measures the residual energy of electrons trapped within the atomic spacing of a mineral grain such as of quartz sand to calculate the period of time elapsed since the sand grain was last exposed to sunlight.

of the battlefield but it is not sufficiently well surveyed as a heritage site and is considered to be especially sensitive.

Figure 3: Examples of typical bag-shaped pottery vessels associated with the exploitation of wild grass seed in the Namib Desert during the last 1000 years.

4.2 Observations

A detailed foot survey of the area surrounding Mining Claims 71609-71617 on the farms Sukses and Hakskeen yielded a number of late pre-colonial archaeological sites related to grass seed exploitation and hunting of migratory antelope. These sites included both seed diggings and grinding sites as described in the previous section as well as a number of stone hunting blinds. However, only a small number of seed digging sites fell within the indicated boundaries of Mining Claims 71609-71617 as shown in Figure 4. These sites do not include any cultural material or other artefacts and are therefore not considered to be significant.

A desk assessment of the area of interest on EPL5161 was carried out on the basis of findings from previous surveys in this area2 as well as published descriptions of the Battle of Trekopje (L’Ange 1991: 233-41) and a contemporary battlefield sketch made by the German commander at the scene of the battle in Aril 19153. The eleven Allied and German servicemen killed at the Battle of Trekopje are buried in a fenced and well maintained cemetery. Outside the cemetery, to the north and east are the remains of entrenchments and earthworks carried out at the time of the battle. These and related remains have not been documented in detail.

On the eastern side of the railway line adjacent to the site of the Trekopje Station is a further cemetery containing ten graves, of which three are those of children. No documentation of this cemetery has been found and none of the graves are marked. It is however possible that they date to the years immediately following World War I in 1918 when the so-called Spanish Flu spread through Namibia, often carried by people travelling by train. Similar cemeteries are found at other railway sidings in remote parts of Namibia where the dead were evidently taken from the trains and buried immediately. This is still to be confirmed in the case of Trekopje.

The map shown in Figure 5 indicates the full extent of EPL5161, although it is understood that the mining and exploration will be confined to the part of EPL5161 that falls within the boundaries of Trekopje farm. The map also shows the distribution of archaeological sites known from previous surveys as well as the extent of the area covered by the Trekopje battlefield site. The contemporary battlefield sketch indicates that the battle took place in the area between the dolerite hills and the railway line and this part of EPL5161 is demarcated in Figure 5 by a polygon in peony pink. This is considered to be the most sensitive part of the area and has yet to be surveyed in detail.

In summary, the area to be affected by Mining Claims 71609-71617 on the farms Sukses and Hakskeen does not contain any significant archaeological sites that fall directly within the mining claims. On the other hand it should be stressed that the client has not provided any information as to the layout of access tracks, waste rock dumps, field camps or any other infrastructure that may affect the archaeology of the area. In the case of EPL5161, the

2 Kinahan, J. 2006. Archaeological assessment of water and power supply routes to the Trekopje licence area. Commissioned by Turgis Consulting (Pty) Ltd. on behalf of UraMin (Pty) Ltd. (Namibia). 3 From the collection of the Sam Cohen Library, Swakopmund. 14

project proponent has declined to commission a survey of the area of interest4 and the detailed characteristics of this area remain largely unknown.

Figure 4: Mining Claims 71609-71617 on farms Sukses and Hakskeen (small polygons) shown in relation to previously known archaeological sites (green squares) and archaeological sites found during the present survey (red squares).

4 Despite the instruction of the National Heritage Council (letter dated 24 September 2020) directing the proponent to conduct a heritage impact assessment of the area in which these activities are to take place. 15

Figure 5: Upper diagram shows EPL 5161 (grey polygon) in relation to known archaeological/heritage sites (green squares), with Trekopje Battlefield enclosed by peony pink polygon. The contemporary battlefield sketch in the lower part of the diagram shows the extent of entrenchments and other features in relation to Trekopje Station. 16

5. CONCLUSIONS & RECOMMENDATIONS

Field survey of Mining Claims 71609-71617 on farms Sukses and Hakskeen confirmed the patterns known from the wider area surrounding Arandis in the west of Erongo Region with regards the archaeology of the later pre-colonial period. The survey located evidence of both wild grass seed exploitation and the hunting of migratory antelope by using the strategic advantages of natural gaps in dolerite ridge. Whereas these more common indications of late pre-colonial subsistence are sometimes associated with other evidence such as human burials and the occupation of rock shelter sites, no such evidence was found during the present survey. Of the sites located during the survey a minority fell within the area of the proposed mining claims and these were of low significance. While it is permissible to conclude from the survey that the proposed exploration and mining activities would have little or no archaeological/heritage impact, it must be stressed that no information is available regarding the use of access tracks, stockpiling of waste rock and of stone to be removed for processing. The full footprint of the proposed activities has not been defined and the assessment of Mining Claims 71609-71617 on farms Sukses and Hakskeen is therefore qualified.

With regards to EPL5161, the desk assessment presented here is based on observations made for an entirely different project where the survey had only a partial overlap with the proposed area of interest on the farm Trekopje. The previous survey recorded the presence of two cemeteries, one related to the Battle of Trekopje in April 1915 and the other tentatively associated with mortalities resulting from the Spanish flu epidemic in 1918. The 1915 servicemen’s graves are protected in terms of the 1967 War Graves Act (South Africa) (not repealed by the National Heritage Act of 2004). The civilian graves on the east side of the railway line are protected by Ordinance 27 of 1966. The grave sites are nonetheless vulnerable to disturbance if exploration involving earthmoving and invasive sampling are permitted in their near vicinity. It is also a matter of concern that the actual battlefield at Trekopje has not been surveyed at all and that historically important remains of the conflict might be destroyed in the course of exploration and mining. It is therefore recommended that the battlefield itself be excluded from the exploration and mining licence area either permanently or until it has been satisfactorily surveyed.

The contemporary sketch map in Figure 5 clearly shows that the battlefield at Trekopje encompassed a large area beyond the site of the servicemen’s cemetery. This area, extending from the railway to the Trekopje farm fence has not been surveyed in detail. In view of the express instruction of the Heritage Council in this regard, this area is to be excluded from exploration and mining on EPL5161 (as indicated in Figure 6) until such time as a comprehensive survey has been carried out as the basis for a decision by the National Heritage Council. Figure 7 shows the parts of the farm Trekopje falling within EPL5161 which are of interest to the proponent.

Figure 6: Proposed temporary Exclusion Area (No-Go Area) on EPL5161 to provide for conservation of archaeological/heritage resources associated with the April 1915 Battle of Trekopje pending detailed field assessment. The exclusion area stretches from the northern to the southern boundaries of EPL5161, and from the B2 trunk road at the turnoff to Areva Mine, to the Areva Mine access road gate (locked) on the Trekopje farm boundary fence.

Figure 7: Parts of the farm Trekopje falling within EPL5161 which are of interest to the proponent.

6. BIBLIOGRAPHY

Deacon, H. 1972. A Review of the post-Pleistocene in South Africa. South African Archaeological Society Goodwin Series 1: 26-45.

Deacon, J. and Lancaster, N. 1988. Late Quaternary palaeoenvironments of southern Africa. Oxford : Oxford University Press.

Kinahan, J. 2011. From the beginning: the archaeological evidence. In Wallace, M. and Kinahan, J. A history of Namibia: from the beginning to 1990. London: Hurst & Co., pp 15-44.

Kinahan, J. 2020. Namib: the Archaeology of an African Desert. Windhoek: University of Namibia Press (in press).

L’ange, G. 1991. Urgent Imperial Service: South African forces in German South West Africa 1914-1915. Ashanti Publishing.

Appendix 1: Chance Finds procedure

Areas of proposed development activity are subject to heritage survey and assessment at the planning stage. These surveys are based on surface indications alone, and it is therefore possible that sites or items of heritage significance will be found in the course of development work. The procedure set out here covers the reporting and management of such finds.

Scope: The “chance finds” procedure covers the actions to be taken from the discovery of a heritage site or item, to its investigation and assessment by a trained archaeologist or other appropriately qualified person. Compliance: The “chance finds” procedure is intended to ensure compliance with relevant provisions of the National Heritage Act (27 of 2004), especially Section 55 (4): “ a person who discovers any archaeological …. object ……must as soon as practicable report the discovery to the Council”. The procedure of reporting set out below must be observed so that heritage remains reported to the NHC are correctly identified in the field.

Responsibility: Operator To exercise due caution if archaeological remains are found

Foreman To secure site and advise management timeously

Superintendent To determine safe working boundary and request inspection

Archaeologist To inspect, identify, advise management, and recover remains

Procedure:

Action by person identifying archaeological or heritage material a) If operating machinery or equipment stop work b) Identify the site with flag tape c) Determine GPS position if possible d) Report findings to foreman

Action by foreman a) Report findings, site location and actions taken to superintendent b) Cease any works in immediate vicinity

Action by superintendent a) Visit site and determine whether work can proceed without damage to findings b) Determine and mark exclusion boundary c) Site location and details to be added to project GIS for field confirmation by archaeologist

Action by archaeologist 20

a) Inspect site and confirm addition to project GIS b) Advise NHC and request written permission to remove findings from work area c) Recovery, packaging and labelling of findings for transfer to National Museum

In the event of discovering human remains a) Actions as above b) Field inspection by archaeologist to confirm that remains are human c) Advise and liaise with NHC and Police d) Recovery of remains and removal to National Museum or National Forensic Laboratory, as directed.