Mining Licence 219 Environmental Impact Assessment Cape Cross, Erongo Region

Home , Cape Cross, Henties Bay, Salt road, Uis

Mining Licence 219 Cape Cross Salt Pan Arandis Electoral Constituency Project Name Erongo Region

BASELINE SCOPING REPORT

Report Status Final

Project Reference APP - 00688 Number Cape Cross Salt (Pty) Ltd Farm 143, Cape Cross P O Box 25021 Prepared For Windhoek Namibia

EKWAO CONSULTING 4350 Lommel Street Ongwediva Prepared By Namibia Cell: 081 418 3125 Fax2Mail: 088645026 Email: [email protected]

Date Prepared November 2019

Contributors Joel Shafashike & Takatu Shafashike

ABBREVIATIONS AND ACRONYMS

AQG Air Quality Guidelines BAT Best Available Technology BID Background Information Document BSR Baseline Scoping Report CCS Cape Cross Salt (Pty) Ltd CGS Chemical Grade Salt CI Cumulative Impacts CO Carbon Monoxide

CO2 Carbon Dioxide DNP Dorob National Park EIA Environmental Impact Assessment EMP Environmental Management Plan ERC Erongo Regional Council FDS Food Grade Salt FOB Free on Board GRN Government of the Republic of Namibia HES Health Environmental and Safety HPP The Harambee Prosperity Plan IAPs Interested and Affected Parties ISO International Organization for Standardization MET Ministry of Environment and Tourism MME Ministry of Mines and Energy NAAQS National Ambient Air Quality Standards NAMPOWER Namibia Power Corporation Pty Ltd NAMWATER Namibia Water Corporation Ltd NHC National Heritage Council

NO2 Nitrogen Dioxide NSI Namibia Standards Institute PM Particulate Matter PPE Personal Protective Equipment PPP Public Participation Process SABS South African Bureau of Standards SHE Safety, Health & Environment SME Small and Medium Enterprises SO2 Sulphur Dioxide TLV Threshold Limit Value

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Executive Summary

1. Introduction

The salt resource at Cape Cross perfectly fits the description of a world class salt deposit; but its location of ±150 km from the port of Walvis Bay and the absence of surfaced roads combined with salt being a low value high volume commodity, have contributed to the resource remaining undeveloped into a major salt production facility in the country. However, the upgrading of key coastal gravel roads to bitumen surfaced road standards - C34 (75 km) between Henties Bay and Swakopmund and MR44 (45 km) between Swakopmund and Walvis Bay, a dual carriageway sited behind the dunes, have improved the commercial viability of developing the salt resource at Cape Cross.

2. The Proponent

Cape Cross Salt Pty Ltd (CCS) - a 100% Namibian owned company, is one of those junior mining companies which had a long history of salt mining at Cape Cross. CCS had mined both Coarse Grade Salt and Natural Rock Salt and constructed infrastructures (workshops, offices, staff housing, hostel accommodation, storerooms, etc) to support its salt operation. Also developed are sixteen Salt Crystallisers with an annual yielding capacity of approximately 80 000 tons. The current asset replacement value has been estimated at over N$20 million. Mining Licence (ML 219) covers approximately 700 ha of the saline pan including all the existing Salt Crystallisers.

3. Proposed Development

The promoter has secured an agreement with an end-user of 0.5 million tons of salt per year, supplied in bulk shipments FOB Walvis Bay Harbour. This will require the construction of Salt Production Crystallisers on ±240 ha and roadways, levees and dykes on approximately ±10 ha - resulting in a project footprint of ±250 ha (±35% of ML 219).

A new Salt Wash Plant capable to wash 300 ton per hour based on working 9 hours a day over 250 days per year is planned to be installed. Harvested salt is washed in brine and stockpiled to dry out before road freighted to the Walvis Bay Harbour. Three public roads are involved in the transport, salt road D2301 (42 km) and the newly tarred roads - C34 and MR 44.

4. Water & Energy Requirements

Potable water is only required for human use and cleaning purposes and will be trucked from the Omdel Water Scheme at Henties Bay. The water required for the operation is not expected to impact negatively on the existing water resource. Electricity will be provided from a combination of generator sets (for the Salt Wash Plant) and solar panels installed on rooftops (to power office equipment, weighbridge and lighting at night).

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5. Pre-Existing Conditions on the Environment

The Cape Cross Salt Pan covers approximately 4 000 ha and is a brownfield area bearing environmental disturbances as a result of human activities spanning over a 100 years. A number of commercial activities were conducted there, ranging from seabird guano harvesting from man-made structures covering 6.8 ha, to processing facilities for whales and Cape Fur Seal culled from the Cape Fur Seal Colony.

Around 1895, the adjacent Cape Cross Bay served as a shipping ‘harbour’ where guano, seal and whale products were exported to the European markets. Guano was railed to the ‘harbour’ on the narrow-gauge railway covering a distance of 21 km - the first railway line constructed in Namibia. The remains of such activities are still evident and scattered over a wide area of the Cape Cross Saltfield.

5.1 Baseline Conditions

5.1.1 Access to ML 219 - The Salt Mine

From Henties Bay, the salt mine is accessed via the district road D2301. Salt will be trucked to the Walvis Bay Harbour over three national roads: D2301, C34 and MR44. D2301 is the only gravel (salt) road and is about 42 km long. C34 and MR44 are now tarred roads. The Roads Authority has identified some sections of D2301 as being too narrow and recommended that those be widened and adequate signage provided when the carting of salt starts.

5.1.2 Climatic Conditions

The project area has a mean annual rainfall of less than 50 mm but can go without receiving a drop of rain for several years. Fog, is a more predicable occurrence in the project area than rain and occurs for about 150 days of the year, usually extending up to 100 km inland hence providing life-supporting moisture to fauna and flora occurring in the arid desert environment.

Wind speeds average approximately 3m/s and occasionally ‘berg wind conditions’ from the east are encountered which raises the temperature to above 30 degrees. Evaporation increases steadily from the coast inland exceeding precipitation – presenting ideal weather conditions for solar salt production.

5.1.3 Site Topography

When viewed from C34, the topographic sight over ML 219 resembles a flat depression with about 1 m below sea level. Significant rocky outcrops occur to the northwest and undulating features resulting from old workings are evident over a great area of ML 219. The construction of new Salt Crystallisers will result is minor changes to the topography but are fully reversible on decommissioning.

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5.1.4 Geological Aspects

The geology of Cape Cross Salt Pan is well documented. The pan is believed to have come into existence when a stretch of sand dune separated from the mainstream ocean resulting in the formation of an island (pan) measuring approximately 4 000 ha. Over the years the water in the pan evaporated leaving behind a thick layer of Halite (Rock Salt) with depths varying between 0.5 m to 4.5 m. To the west, the island is still separated from the open sea by a sand barrier while low hills of the Etendaka Formation surround the periphery of the island from the north, east and south. The evaporated water is continuously being replenished through seepage via the sand barrier and through the occasional tidal overflows.

5.1.5 Land Use, Tenure and Capabilities

The study area is located in the Dorob National Park – a proclaimed national park with the custody vested in the Ministry of Environment & Tourism. Due to the nature of the soil, the sporadic and low rainfall, the Dorob National Park has low capabilities to sustain agricultural activities. Limited commercial activities especially those with low environmental impacts are allowed in the park. The entire ML 219 is located on the saline pan and therefore in close proximity to existing salt operations.

5.1.6 Air Quality

There are no industries in the study area and the C34 coastal road serving the project site is a salt road with relatively low traffic. All current salt operations on the Cape Cross saltfield are relatively small scale operations and not heavily mechanized. The air quality is therefore good and the proposed development is not expected to negate that.

5.1.7 Noise Disturbances

Noise levels in open space areas are generally low. In the context of ML 219 noise is generated by the existing salt operations and the traffic on the coastal road D2301. Sensitive noise receptors are at the Cape Cross Lodge, about 10 km away. Perhaps the noisiest place around the salt mining site is the Seal Colony to the northwest of ML 219 and about 8 km away. On a relatively quiet day noise from the Seal Colony can be heard at the salt work. Noise associated with the operation can be effectively mitigated.

5.1.8 Visual Intrusion

The topographic sight is mostly comprised of salt mining operations in the form of earthmoving machineries and equipment visible at different locations within the saltfield, building structures along the D2301, and disturbed sites. Overall, the saltfield displays a significant desert sense of place, with a wide open vista to the west and pleasant hills to the south, east and north and therefore popular with tourists.

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5.1.9 Archaeological and Cultural Heritage

Various commercial undertakings such as seabird guano harvesting, processing of whales and seals culled from the Cape Fur Seal Colony have been conducted in the Cape Cross area for over 100 years which, archaeologically gives the area a medium to low ranking. On the saline pan itself remains of whale bones, rusted railway line steels, dumps of discarded bottles, porcelain and scrapped machines from yesteryear are still visible over a wide area. There are also reports of graves located on the hills of mountains to the south of saltpan. Guidelines are provided in the EMP on how to deal with items of cultural heritage should such be uncovered during the construction of the salt ponds.

5.1.10 Surface and underground water

Population growth, economic developments and urbanization are factors placing increasing pressure on existing water sources in Namibia. There are no known sources of fresh water in the vicinity of the project site and drilling by exploration companies to locate underground water in the adjacent river streams have yielded water of poor quality and unfit for human consumption.

The processing of salt does not require the use of fresh water, but potable water will be required for human use and for equipment cleaning purposes. This will be sourced from the Omdel Water Scheme where all other operations along the coast source their water requirements. All employees will reside in Henties Bay and bussed to and from work each day hence moderate water will be required.

5.1.11 Wetland

The Lagoon to the southwest is the only area with open standing water and is an important area for marine birds. A 6.8 ha man-made guano platform constructed onsite over 100 years ago is still standing serving a breeding and roosting place for the seabirds. The highest global population of Cormorants is found there. The Lagoon is outside the tenement of ML 219 about 5 km away. Movements of birds from the lagoon to the inland are rare and very uncommon.

5.1.12 Floral Aspects

The entire ML 219 is located on the saline pan which does not support any form of life, however the coastal hummock belt and undulating hills to the southeast but outside the tenement of ML 219 are considered as of high sensitivity.

5.1.13 Faunal Aspects

The brown Hyaenas are often spotted traversing the salt pans en-route to the Seal Colony. No access to contaminated waste water and leftover food should be allowed to jackals and hyaenas. Occasionally, wounded Seal Bulls are encountered on the salt pans. These should not be hunted down.

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5.1.14 Road Safety

To enhance safety and reduce accidents, additional traffic lanes have to be constructed at the Uis turnoff and at the T-junction where the mine access road joints D2301. Among the measures proposed by the Roads Authority are that trucks used in the haulage operation, be fitted and driven with amber flushing lights at the rear and front. Adequate signage along the D2301 road (speed limit, curves ahead, blind crests, no overtaking, etc.) should also be erected.

On its part, the promoter will have each driver tested for alcohol at the beginning of their shift and all movements of vehicles (driving habits, speed limits, stopping duration and overtaking) will be monitored via a satellite linked system by a dedicated staff on a 24/7 basis.

5.2 Social and Economic Impacts

The operation will create over sixty (60) fulltime employment with all employees budgeted to draw approximately N$28 million per year in salaries and wages, hence boasting both the local economy and national coffers through statutory payments (PAYE, royalties, export levies, company tax). Salt will be exported overseas and therefore earning the much needed foreign currency. All employees will reside in the town of Henties Bay and bussed to and from work each day hence improving the town’s income potential through payment for services, water, electricity and rates & taxes.

6. Assessment Criteria

Each impact as identified during the Scoping has been assessed on the basis of its nature, extent, duration, intensity/severity and probability for such an impact actually occurring. A Significant Rating was then determined for each assessment. This essentially means significance for decision to approve the project.

 Impacts with LOW (-ve) Significance Ratings will not affect the decision to approve the project.

 Impacts with MEDIUM (-ve) Significance Rating will affect a decision to approve the project unless such impacts are effectively mitigated.

 Impacts with HIGH (-ve) Significance Ratings would essentially indicate that the impacts will affect the decision irrespective of mitigation measures

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Environmental Impact or Significance Rating Possible Mitigation Concern /Issue WOM WM  Widen narrow road sections Impact on salt road D2301 High (-) Medium (-)  Provide adequate speed limit signage & sharp curve signage  Contract extra traffic lanes Mine access T-junction on  Provide lighting to enhance safety & Medium (-) Low (-) D2301 adequate signage  Test drivers for alcohol  Contract additional lanes Uis Road T-junction on D2301 Medium (-) Low (-)  Install adequate signage  Comply with traffic rules  Install full weighbridge Impact on national roads C34 Medium (-) Low (-)  No overloading and MR44  Monitor driving habits, speeding and overtaking via a satellite linked system  Limit new salt ponds on the saline pan and within the confines of ML 219 Impact on topography Low (-) Low (-)  All internal routes should be well planned and clearly demarcated  Use water sparingly  Ensure any leaks from storage facilities Impact on potable water Low (-) Low (-) are detected early and repaired on time  Maintain a high standard of housekeeping  Use generator sets combined with solar Impact on energy supply panels attached on rooftops Zero Zero (electricity)  Re-fuelling of generators should be done by trained personnel  Pipe to the sea must be buried Impact on bitterns discharge Low (-) Low (-)  Discharge bitterns once or twice per year  Ensure vehicles, plant and equipment are Impact on ambient air quality Low (-) Low (-) well maintained  Train employees on the environment  Main road D2301 and all internal routes are salt roads hence no dust Dust nuisance Zero Zero  Provide PPEs to employees working in areas where dust generated  No noise receptors nearby Noise Impact Low (-) Low (-)  Provide PPE PE to people working in noisy areas  Provide different waste bins  Train employees on all types of waste Impact on solid waste Medium (-) Low (-)  Transport waste to Henties Bay landfill site  Store liquid waste (used oil, filters, etc.) in sealed containers Impact on liquid waste Medium (-) Low (-)  Transport to licensed landfill site (Walvis Bay)  Train employees on waste types

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 Site infrastructures away from sensitive Impact on visual intrusion Low (-) Low (-) and elevated areas  Lights at T-junction should face inwards  Train employees on aspects related to archaeological & cultural heritage Impact on Archaeological & Medium (-) Low (-)  Follow recommendations in the EMP Cultural Heritage  Safeguard earthed items of cultural interests  Store fuel at a designated site with controlled access Fuel storage, Handling and Medium (-) Low (-)  Use an approved diesel bowser for offsite Management refueling  Only trained personnel may handle fuel  Feeding of wild animals (jackals) should be avoided  Food items/wastes should be placed in Impact on faunal aspects Low (-) Low (-) lockable containers  Astray Seal Bulls encountered on salt pans may not be killed  No illegal fishing by the employees ML 219 is on saline pan hence no flora impact Impact on floral aspects Zero Zero is foreseen  Adopt ‘a local first’ policy when recruiting  Enhance benefits through training On employment Creation High (+) High (+)  Former CCS employees to be given preferences  Procure goods and services from local companies  Make all statutory payments due to the On the local economy Medium (+) High (+) State, Social Security, etc.  Join local lobby groups NCCI & Chamber of Mines  Develop a Health and Safety Plan for the salt operation  Develop an Emergency Response Plan Health and Safety Aspects Low (-) Medium (+)  Maintain high standard of housekeeping  Train employees on the provisions of the EMP

The EIA for ML 219 has indicated that with the exception of the coastal road D2301, there are no impacts with HIGH (-ve) Significance Ratings and that all identified impacts can be effectively mitigated. The widening of those cross sections of D2301 as identified in the report carried out by the Roads Authority will be done in conjunction with the Roads Authority.

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7. Public Participation Process

The project was announced through advertisement in local newspapers (two publications). A Background Information Document (BID) which provided information on the project was prepared and circulated to identified stakeholders and Interested and Affected Parties (IAPs). All IAPs were granted an opportunity to provide any inputs to the EIA or to voice any concerns and/or issue which they might have with respect to the project. A date for a Public Information Sharing Meeting was also announced.

Only three IAPs registered for the EIA and were supplied with BID and invited to attend the public meeting at the project site. Two state entities (Roads Authority, and Namport) were specifically engaged by the EIA Consultant because of their direct role to the successful implementation of the project.

All mineral right holders inside and outside of ML 219 both active and inactive were contacted and provided with BID and invited to participate in the EIA process. All correspondences are attached to the PPP section of the EIA.

Concerns were raised by Cape Cross Lodge particularly on the narrow cross section of D2301 salt road which posed safety risks. In a study conducted by the Roads Authority on D2301, those sections of the road which presented safety hazardous have been identified and recommendations provided. A section of 19 km of D2301 will have to be widened possibly incrementally as the salt mine ramps up to full production. Adequate signage has to be provided and road edge markers with yellow reflectors periodically cleaned possibly at the cost of the promoter.

On the problem regarding salt stalls erected along D2301 being a visual nuisance – this matter was outside the scope and assignment of the EIA Constant.

8. Conclusion and Recommendation

ML 219 is located on the saline pan, however the entire Cape Cross Saltfield is in the Dorob National Park which makes it a sensitive location and therefore every effort has to be made by the proponent to ensure that environmental disturbances associated with the project are managed and kept to the minimum.

Compliance monitoring will be needed to ensure that the salt operation fulfills its obligation of complying with the recommendations as outlined in the EMP. In the context of past disturbances, the project has a small footprint and does not appear to present any adverse socio-economic impacts provided that health and safety aspects for the employees are well managed, and the handling, transport and disposal of waste both hazardous and non- hazardous is in compliance with the recommendations of the EMP.

It is the recommendation of the EIA Consultant that an Environmental Clearance Certificate can be granted for ML 219 subject to the proponent committing to complying with all the recommendations for the Environment Management as outlined in the EIA and the EMP.

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TABLE OF CONTENTS

EXECUTIVE SUMMARY

SECTION DESCRIPTION PAGE

1.0 SCOPING ASSESSMENT 1 1.1 Introduction 1 1.2 Background 1 1.3 The Proponent 2 1.4 The Rationale to Revive the Salt Operation 2 1.5 Mining Licence (ML 219) 3 1.6 Objectives of the Environmental Assessment 3 1.7 Terms of Reference 4 1.8 Approach to the EIA Study 4

2.0 PROJECT LOCATION AND DETAILS 7 2.1 Salt operation - Site Context 7 2.2 Land Status - Ownership Context 7 2.3 Salt Operation - Surrounding Context 10 2.4 Project Water Requirements and Supply 11 2.5 Project Energy Requirements and Supply 11

3.0 PROJECT DESCRIPTION IN DETAILS 13 3.1 Introduction 13 3.2 Current Production Process 13 3.3 Solar Salt Production 13 3.4 Comparisons of Specifications between FGS and CGS 15 3.5 Solar Salt Wash process 16 3.6 Ponds Design and Layout 17 3.7 Wash Plant and Equipment Capacity 18 3.8 Human Resource Requirements 20

4.0 NEED AND DESIRABILITY ASSESSMENT 22 4.1 Introduction 22 4.2 Benefits to the Local Economy 22 4.3 Salt Production in Africa 23

5.0 LEGAL AND POLICY FRAMEWORKS 24 5.1 Introduction 24 5.2 The Namibian Constitution 24

6.0 THE BASELINE RECEIVING ENVIRONMENT 6.1 Introduction 27 6.2 Access to Salt Resource 27 6.3 Climatic Conditions 27 6.4 Site Topography 28 6.5 Geological Aspects Waste 28 6.6 Land Use and Capabilities 38 6.7 Hydrology - Surface and Underground Water 29 6.8 Dust Disturbances 30 6.9 Noise Disturbances 30 6.10 Ambient Air Quality 31 6.11 Waste Management 31 6.12 Visual Impacts 31 6.13 Archaeological and Cultural Heritage 32 6.14 The Biological Environmental Aspects Ecosystem 32 6.15 The Socio-Economic Environment 34

7.0 IMPACT ASSESSMENT METHODOLOGY 36 7.1 Introduction 36 7.2 Identification of Impacts 36 7.3 Evaluation and Mitigation of Impacts 37 7.4 Impact Assessment Methodology 37

8.0 IMPACTS ASSESSMENT AND MITIGATION MEASURES 39 8.1 The Physical Environment 39 8.1.1 Access and Traffic Impacts on National Roads 39 8.1.2 Site Topography and Land Use 44 8.1.3 Hydrology (Surface and Underground Water) 45 8.1.4 Ambient Air Quality 46 8.1.5 Noise Disturbance 47 8.1.6 Dust Pollution 47 8.1.7 Waste Generation and Management 48 8.1.8 Visual Intrusion 49 8.1.9 Archaeological and Cultural Heritage 50 8.1.10 Fuel Storage, Refueling & Fuel Management 51 8.2 The Natural (Biological) Environment 51 8.2.1 Fauna 51 8.2.2 Flora 52 8.3 The Human Environment 53 8.3.1 Creation of Employment 53 8.3.2 Boast to the Local Economy 54 8.3.3 Labour and Working Conditions 55 8.3.4 Health and Safety 56

9.0 EVALUATIONS AND CONCLUSIONS 57 9.1 Environmental Economic Criteria 57 9.1.1 The Efficiency Criterion 57 9.1.2 The Equity Criterion 58 9.1.3 The Intergenerational Equity or Sustainability Criteria 58

10.0 CONCLUSION 58

TABLES

TABLE DESCRIPTION PAGE TABLE 1 : Project Location and Details 5 TABLE 2 : Comparisons of Specifications Between FGS and CGS 14 TABLE 3 : Minimum Wash Efficiency to Produce FGS 16 TABLE 4 : Human Capital Requirements for the Project 21 TABLE 5 : Mining Contribution to the National Economy 22 TABLE 6 : Salt Production in Africa 23 TABLE 7 : Salt Production - World vs Africa between 1970 to 2015 23 TABLE 8 : Population Growth - World vs Africa between 1970 to 2015 23

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TABLE 9 : Per Capita Salt Production – World v Africa: 1970 to 2015 23 TABLE 10 : Applicable National Legislations 24 TABLE 11 : National Policies and Related Programme 26 TABLE 12 : Main Employment Sectors in Erongo Region 36 TABLE 13 : Assessment of Impacts 38 TABLE 14 : Impact on Traffic on National Public Roads: D2301, C34 and MR44 44 TABLE 15 : Impacts on Topography and Land Use 45 TABLE 16 : Impacts on Hydrology (Surface and Underground Water) 46 TABLE 17 : Impacts on Ambient Air Quality 46 TABLE 18 : Noise Related Impacts 47 TABLE 19 : Dust Related Impacts 48 TABLE 20 : Impacts on Waste Generation, Handling and Management 49 TABLE 21 : Impacts on Visual Intrusion Aspects 49 TABLE 22 : Impacts on Archaeological and Heritage Cultural Aspects 50 TABLE 23 : Impacts on Fuel Storage, Handing and Management 51 TABLE 24 : Impacts on Fauna Related Aspects 52 TABLE 25 : Impacts on Flora Related Aspects 53 TABLE 26 : Impacts on Employment Creation 54 TABLE 27 : Impacts on the Local Economy 55 TABLE 28 : Impacts on Labour and Working Conditions 56 TABLE 29 : Impacts on Health and Safety Aspects 57

LIST OF FIGURES/PHOTOS

FIGURE 1 : Google Map of the Cape Cross Saltfield & ML 219 6 FIGURE 2 : Mining Licence - ML 219 6 FIGURE 3 : Looking West from D2301 - Access to the Salt Work 8 FIGURE 4 : Looking East from D2301 - two staff housing 8 FIGURE 5 : Looking East from ‘Old’ Wash Plant 8 FIGURE 6 : One of the Sixteen (16) Existing Salt Crystalliser of the Promoter 9 FIGURE 7 : Existing Salt Crystalliser approximately 0.5 ha 9 FIGURE 8 : Internal Routes from the ‘old’ Wash Plant to the Salt Crystallisers 9 FIGURE 9 : Mineral Rights within and around ML 219 12 FIGURE 10 : Location of New Crystallisers & Wash Plant within ML 219 12 FIGURE 11 : Proposed Salt Pond/Crystallisers Layout 18 FIGURE 12 : Salt Harvesting and Hauling Machinery 19 FIGURE 13 : Salt Wash Plant 19 FIGURE 14 : Salt Stockpile 19 FIGURE 15 : Operational Photos taken during the time when CCS operated 20

FIGURE 16 : ML 219 in Relation to Owarab River Drainage/Delta 30 FIGURE 17 : The Cape Cross Seal Colony 33 FIGURE 18 : Marine Birds at the Cape Cross Lagoon 33 FIGURE 19 : A Seagull preying on a Seal Puppy 33 FIGURE 20 : The Stone Cross at Cape Cross 33 FIGURE 21 : A jackal killing a young seal at the Seal Colony 33 FIGURE 22 : The Permit Office to the Seal Colony 33 FIGURE 23 : Photos of the Henties Bat Town 35 FIGURE 24 : Salt Haul Routes to Walvis Bay Harbour 39 FIGURE 25 : Vertical Curves causing blind crests on D2301 40 FIGURE 26 : D2301 too narrow to pass 40 FIGURE 27 : Failure of shoulder of D2301 40 FIGURE 28 : D2301 seen from north towards the sharp Curve 41 FIGURE 29 : Sharp Curve on D2301 seen from south to north 42 FIGURE 30 : Sharp Curve on D2301 from north to south 42 FIGURE 31 : Salt Mine Access Road onto D2301 43 FIGURE 32 : T-junction of Uis Road onto D2301 43

BASELINE SCOPING REPORT

SECTION 1

1.1 Introduction

Ekwao Consulting (hereinafter Ekwao) has been appointed by Cape Cross Salt (hereinafter CCS) to handle its application for an Environmental Clearance Certificate (ECC) with the Ministry of Environment & Tourism (MET).

CCS has applied for a Mining Licence (ML 219) from the Ministry of Mines & Energy (MME) to resume its salt mining operation at the Cape Cross based saltfield, located north of Henties Bay in the Arandis Electoral Constituency of the Erongo Region.

In terms of the provisions of the Environmental Management Act (EMA) (Act 7 of 2007) and its Environmental Impact Assessment (EIA) Regulations of 2012, mining is a listed activity which may not be undertaken without an ECC having been granted by MET.

The baseline environmental aspects which have been assessed for the proposed salt mining operation are:

(a) The Physical Environmental Aspects:

 Access and transport route to the Walvis Bay Harbour  Site topography  Climatic Conditions  Geological Aspects  Land Use and Capabilities  Hydrology (Surface and Underground water)  Ambient Air Quality  Dust Disturbances  Noise Disturbances  Visual Intrusions Aspects  Archaeological, Heritage & Cultural Aspects

(b) The Biological Environmental Aspects:

 Flora, and  Fauna

 Creation of employment  Boast to the local economy  Labour and working conditions  Health and Safety Aspects

1.2 Background

The coastal saltfield at Cape Cross covers a surface area of ±4 000 ha, and is situated about 50 km north of Henties Bay, and 120 km from the town of Swakopmund. Walvis Bay, which accommodates the country‟s deepest port, is 150 km away. Whilst the Cape Cross saltfield perfectly fits the description of a world class salt deposit, it has remained undeveloped into a major salt producing facility primarily due to the following reasons:

 non-availability of grid electricity at the site (Cape Cross)  salt being a low value high volume commodity

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 long haulage distance on often slippery and muddy gravel road between Cape Cross and Swakopmund for rail transport and tarred road connections

 long haulage distance (150 km one-way) to the port and more often with delays caused by traffic congestion between Swakopmund and Walvis Bay

Since the early sixties, a number of role players have, intermittently, attempted to mine salt at Cape Cross, albeit on a relatively small-scale. In recent years, salt mining at the saltfield has concentrated and focused more on the extraction of Natural Rock Salt, sold exclusively as leak supplement to local and regional livestock and game farmers.

1.3 The Proponent

The proponent, Cape Cross Salt is one of those role players which have had a long history of salt mining at Cape Cross dating back to 2000 when the company acquired the assets (plants and equipment) of the former operator, Namsalt. In fact, CCS had mined both Coarse Grade Salt (CGS) and Natural Rock Salt (NRS) and established infrastructures at the saltfield to support its salt mining operation.

1.4 The Rationale to Revive the Operation

CCS has negotiated an agreement with a salt end-user for the supply of 500 000 tons per annum (TPA) of Food Grade Salt (FGS) delivered in bulk shipments on the FOB basis, Walvis Bay.

The rationale to revive the salt operation is also supported and encouraged on the successful implementation of several national capital development projects in the Erongo Region. These infrastructural development projects have made huge positive impacts both at the regional and national levels to such an extent that the prospects of developing the enormous saltfield at Cape Cross look more attractive and possibly, commercially feasible.

The key challenge to develop the Cape Cross Saltfield into a major salt operation has always been the long distance between the saltfield and the port of Walvis Bay.

These developments are:

 the upgrading of the Henties Bay-Swakopmund highway (C34) to bitumen standard

 the construction of the Swakopmund-Walvis Bay highway (MR44) dual carriage (allowing road trucks faster turnaround time to the port)

 the expansion of the Walvis Bay port facilities (allowing efficient handling of both bulk and containerized cargo)

 provision of serviced industrial land in the town of Henties Bay (possibly allowing the promoter to construct a bagging plant to serve the domestic and regional markets who need iodised bagged salt)

 the planned tarring of the Henties-Uis-Khorixas-Kamanjab roads (MR76) will shorten the distance between the coastal towns and the northern regions of Namibian including opening up access to the Angolan markets

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1.5 Mining Licence (ML 219)

ML 219 covers 708 ha of the saltfield at Cape Cross and forms part of the 5 000 ha saltfield previously extensively explored by CCS under EPL 2850. The said EPL was held by the now dormant, Namibia Small Miners Assistance Centre (NSMAC) and CCS was contracted to explore the EPL. The Mining Licence has been applied from MME in terms of the Minerals (Prospecting & Mining) Act, Act 23 of 1992.

The EIA is a process which assesses and evaluates those impacts which the proposed operation might have on the physical, natural and socio-economic environments. Where the salt mining operation poses negative impacts, mitigation measures are proposed to minimise such negative impacts and where the salt operation makes positive impacts, recommendations are made to maximize such benefits to the locals and to the Namibian economy.

By complying with the recommendations as provided for in the Environmental Management Plan (EMP), CCS will ensure that its salt mining operation is conducted in a manner which safeguards and protects the environment and therefore harmonised with national legislations, regulations and policies.

1.6 Objectives of the Environmental Assessment

For development to become sustainable in Namibia, it is imperative to reduce the burden of harmful impacts to the environment. In fact, as resources gradually become limited, the environmental impacts are becoming more complex and more pronounced. Environmental assessment has therefore become a very important tool for development and decision making. This role is formally recognized in the Environmental Management Act (EMA).

„Environmental impact assessment, as a national instrument, shall be undertaken for proposed activities that are likely to have a significant adverse impact on the environment and are subject to a decision of the Environmental Commissioner‟.

Mining is a listed activity which may not be undertaken before an EIA has been conducted. The EIA provides precautionary measures in the form of an Environmental Management Plan (EMP) in which mitigation measures are provided.

The overall objective is therefore to ensure that the proposed salt mining operation is carried out in a manner which makes it technically sound, economically feasible, socially acceptable and environmentally sustainable.

In this regard, the EIA process is expected to provide mechanisms whereby the overall environmental performance of the planned activity (salt mining) is enhanced through:

 listing the policy and legislative framework within which the proposed activity (salt mining and processing) is located and how the activity complies with and responds to the policy and legislative context

 identifying possible alternatives for consideration and assessment in terms of those aspects related to the activity (salt mining and processing), location of the development and technology alternatives

 describing the need and desirability of the proposed development

 undertaking an impact assessment process inclusive of cumulative impacts which focuses on determining the geographical, the bio-physical, social, economic, heritage and cultural sensitivity of the sites and locations in order to determine:

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a) the nature, significance, consequence, extent, duration and probability of the impact occurring and,

b) the degree to which these impacts:  can be reversed  may cause irreplaceable loss to the resources  can be managed, mitigated or avoided

1.7 Terms of References

The general terms of reference for this EIA as agreed between the promoter and Ekwao are:

 a detailed description of the Baseline Environmental Aspects in terms of the environmental legislative and regulatory framework and any other information which might have a bearing to the activity

 description, evaluation and analysis of the foreseeable potential environmental effects of salt mining, generally expressed in terms of the biophysical, natural and socio-economic aspects arising from the activity

 to conduct a comprehensive Public Participation Process during which the views, concerns and inputs of the neighbouring communities towards the salt mining operations are gathered and considered

 to formulate an EMP, proposing the measures to mitigate any adverse impacts on the environment resulting from the salt mining activities

1.8 Approach to the EIA

The approach to the EIA for ML 219 was guided by the provisions of the Environmental Management Act and related EIA Regulations which came into existence in February 2012.

In preparing for the Baseline Scoping, an investigative approach was adopted by Ekwao which took cognizance of the fact that salt mining at the Cape Cross saltfield has been conducted for well over seventy (70) years. There has been no Environmental Impact Assessments conducted for, almost, all the existing operations and therefore, there are no Environmental Management Plans (EMPs) for some of the existing operations, which could serve as a benchmark for the EIA study.

This does not mean that the existing operations are reluctant to conduct EIA; there was simply no law compelling salt miners to obtain an Environmental Clearance Certificate (ECC). EMA and its regulations were only enacted about seven years ago. The assessment for this study was therefore based on:

 on-site observation and physical inspections and surveys

 existing information based on literature review and desk study assessments

 views and attitudes of interested and affected parties

 through discussions with existing salt operators

 existing legislation, policies and regulations

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SECTION 2

2.0 Project Location and Details

Details with regard to the project location and surroundings are listed in the Table below:

Table 1: Project Location And Details Common Name of the Cape Cross Location/Area Region in Namibia Erongo Electoral Constituency Arandis Magisterial District Swakopmund Land Tenure Stateland /Government Land Project Proponent Cape Cross Salt Pty Ltd (Reg. 2000/601) Mining Licence No. 219 Mining Application Area 707 ha Footprint - Current Development 23 ha Footprint - Proposed Development 227 ha Footprint - total Development 250 ha Project Footprint as a Percentage of 35% Total Mining Licence Area ±48 km from Henties Bay Distance from nearest towns ±120 km from Swakopmund ±150 km from Walvis Bay ±8.1 km Cape Cross Lodge ±10.6 km Cape Cross Seal Colony Distance from nearest ±3 km Atlantic Ocean to the west neighbours/features ±12.5 km Guano Platforms ±15 km Mile 72 Camping Site ±17.6 km Fishermans Inn - Henties Bay Vervoer & Soutwerke Adjacent salt works (active and - JD Soutwerke dormant) on the same Cape Cross - Solz Gossow Saltfield - Crystal Salt (ML78B & &ML78C) - Salt Company (ML66A) .

Label Latitude Longitude 1 -21.78709851 13.99570182 2 -21.79110083 14.00215748 Mining Licence Coordinates 3 -21.80816729 14.01773212 4 -21.80167874 14.02547462 5 -21.78179611 14.01405208 6 -21.76669957 13.99999812 7 -21.77701658 13.98796523

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Figure 1: Google Map of the Cape Cross Saltfield (greenish) & Mining Licence 219 (purple)

Figure 2: Mining Licence 219

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2.1 Salt Operation - Site Context

This section should be read in consultation with Table 1 and Figures 1 & 2. The saltfield at Cape Cross is very big and has been estimated at ±4000 ha (40 km2). Previous exploration work has estimated the salt resource at 7.7 million tons (Gevers and Westhyzen, 1932) down to a depth of 450 mm.

The last recorded exploration work conducted by Linning (1965) has estimated the salt resource in the Cape Cross Salt Pan as being 350 million tons down to depth of 3800 mm (3.8 m). The Pan is separated from open sea by a sand bar of approximately 300 mm wide.

The proponent, Cape Cross Salt has constructed support infrastructures and accessories at the site as listed here below:

 machine repair workshop  administrative office  two staff housing to the south of C34  spare parts and tools storeroom  accommodation facilities (prefabricated) for employees  fuel tank storage  two x 40ft Containers (housing gensets)  a Wash Plant (ramp & civil structure still intact)  a scrapyard (out of sight of C34)  water storage facilities  sewerage drainage system  a stockpile area  sixteen (16) Salt Crystallisers capable of yielding 80 000 tons of salt per year

Estimate current replacement value for all the above is at least N$20 million (twenty million Namibia Dollars).

2.2 Land Status - Ownership Context

The Cape Cross Salt Pan is located on land proclaimed as the Dorob National Park (DNP), a protected area under the Nature Conservancy Ordinance No. 4 of 1975. The DNP was gazetted as a national park on 1 December 2010 and extends from the Kuiseb Delta (south of Walvis Bay) running along the Atlantic coast up to the north of the Ugab River. The park extends for about 50 km inland from the Atlantic Ocean and is home to one of the oldest uranium mines in the world – the Rossing Uranium Mine which has been in operation since 1976.

Over the last fifteen (15) years, the DNP has seen an upsurge in uranium exploration activities triggered by increased energy demand in the world. Currently three uranium mines are in operation within the DNP while the fourth uranium mine is under care and maintenance after completing a large scale and successful trial period. Two other uranium projects are at the stage of project finance negotiations. Additionally, low level but intensive prospecting activities are underway at several identified uranium deposits within the DNP.

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Figure 3: Looking West from D2301 - Access to salt works with office (right) and workshop (left )

Figure 4: Looking East from D2301 - two staff houses (right for Manager and left for Workshop Foreman)

Figure 5: Looking East from Wash Plant area - left is Admin office & right is Workshop. Foreground are rusted containers which housed generators

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Figure 6: One of sixteen exsisting Salt Crystalliser measuring ±0.60 ha, filled with brine

Figire 7: Another Salt Crystalliser of about 0.5 ha. Note harvested salt on the left handsides

Figure 8: Internal Route from the Wash Plant to the Crystallisers. Note the Saline Pan in background which constitutes ML 219

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2.3 Salt Operation - Surrounding Context

This section should be read in conjunction with Table 1 and figures (????) above. The entire area covered by Mining Licence (ML 219) is on the saline pan.

North and Northwest of ML 219: Taking the administrative office of CCS as a reference point, the Cape Fur Seal Colony and the Cape Cross Lodge are, by road distance, 10 km and 8 km respectively.

In January 1486, a Portuguese explorer and navigator, Diogo Cão erected a huge stone cross at the site, which ultimately led to the area being referred to as „Cape Cross‟. Today, the landmark feature and the Cape Fur Seal Colony have become household names, visited by hundreds of tourists each year making Cape Cross a popular tourist destination in the country.

A landing strip for small aircrafts is located on the edge of the Cape Cross Pan and is used predominantly by guests, visiting both the Cape Fur Seal Colony and the landmark stone cross.

Bordering ML 219 to the north is the salt operation conducted by Henties Vervoere & Soutwerke extracting mostly Natural Rock Salt. The company has since developed crystallisers and is now producing Coarse Grade Salt.

West and Southwest of ML 219: The Atlantic Ocean is to the west and approximately 2.5 km from the application area whilst a Guano Platform is about 12.5 km, by road, from the administrative office of CCS. The guano reserve was discovered in the area in 1895 and platforms to provide a safe haven for breeding and roosting were constructed over an area of 6.8 ha (68 000 m2).

Further south of ML 219, is Mile 72, a Camping Site managed by the Namibia Wildlife Resorts. There is also a landing strip serving the Camping Site. It was not possible to establish if the landing strip was still being used.

South of ML 219: ML 11 held by Salt Company is to the south but distant from ML 219. ML 11 overlaps several mineral rights for Guano production and harvesting. A Wash Plant operated by Oranje Soutwerke, a subsidiary of the Blaaw Transport Group of Walvis Bay has been erected within ML 11.

East of ML 219: Abutting the mining area to the east is the salt gravel road (D2301) which links the town of Henties Bay to Terrace Bay. D2301 provides a vital link to all human activities, be they commercial (salt mining, guano production) or leisure (tourism, fishing, etc.) conducted along the coastal strip. The salt processed from the saltfield at Cape Cross Pan is also transported on the very same road.

Mineral Rights within ML 219: To the northwest but within ML 219 are three Mining Licenses all secured under the Ordinance 20 of 1968 - the Act which preceded the Minerals (Prospecting and Mining) Act. ML 82A and ML 82B are held by Rolf Gossow Holdings Pty Ltd and covered surface areas of 32 ha and 25.3 ha respectively. Rolf Gossow Holdings is one of the pioneers who started salt mining at the Cape Cross saltfield way back in the fifties. The third license is ML 78B held by Crystal Salt and covers a surface area of 37.2 ha.

Towards the northwest corner of ML 219 are three licenses – all three secured under Ordinance 20 of 1968. ML 82C is 13.2ha and is held by Gossow Rolf Wolfgang. Crystal Salt has 78C which measures 15.1 ha while Salt Company is the beneficiary for ML 66A which measures 38.8 ha. Salt Company is the second biggest salt producer in Namibia and has its operations based in Swakopmund.

According to mineral registry at MME, all six minerals rights overlapped by ML 219 were due to expire on 31 March 2019; and their statuses are reflected as pending renewal. Ekwao has not been able to establish whether renewal applications have been submitted for any of the six Mining Licenses.

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2.4 Project Water Requirements and Supply

Water is a scarce commodity in Namibia and Region of Erongo has the highest demand for water as a result of the number of mines operating in the region. However, the salt washing process does not require the use of potable water but a mixture of brine and seawater.

Potable water required for the operation is for human consumption and machine use only. Daily water requirement is projected at 15 m3 which is equivalent to 15 000 liters per day. This will translate into an annual requirement of ±4 500 m3 (4.5 million liters) based on 300 working days per year. According to the World Health Organization (WHO), between 50 and 100 litres of water are needed to ensure that most basic needs of a person are met and few health concerns arise. The water needs of the project will be sourced from the Omdel Water Scheme using a water tanker.

Since all employees of the company will be accommodated in Henties Bay, there was no consideration given to assess alternative water supply such as laying a water pipeline from Henties Bay to the salt mine or to drill boreholes to locate underground water sources in the surrounding areas.

2.5 Project Energy Requirements (Power) and Supply

The bulk of energy required in the production of salt is sourced from the sun – which evaporates the water from the brine solution hence solar salt production. Approximately 51% of the sun energy is absorbed by the land and the oceans and about 23% of this energy is carried back to the atmosphere by latent heat in the form of water vapour. Solar evaporation has therefore a conversion efficiency of 45%. (Salt Partner).

Electrical energy is only required for the wash plant, the stacking conveyors, weighbridge, administrative office, workshop applications and for lighting purposes at night. The maximum power demand for the operation is therefore estimated at 300 kW and this will be met from diesel powered generators.

Solar panels fixed of building rooftops could be used to supplement the energy requirements for the project. Energy generated in this way could be used to power office equipment (laptops, fax machine, copy machines, coffee kettles, etc), weighbridge and lighting for security at night. This will reduce the diesel used to power the generators and associated carbon footprints.

Alternative energy supply such as photovoltaic, wind energy or to construct a 22 kV power line from MR76 have not been considered. These options will be considered should CCS wish to increase salt production in future perhaps combined with the development of a private salt loading jetty in the adjacent Cape Cross Bay. In the long term this option could prove to be a cost effective alternative to transporting the salt by road to Walvis Bay.

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Figure 9: Mineral Rights within and Around ML 219

Figure 10: Proposed New Crystallisers (yellow) & Wash Plant

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SECTION 3

3.0 Project Description in Details

In this section a detailed description of the project is presented from the perspective of salt production using saturated brine as starting material. The volume of salt planned for production, current production, product specifications, planned salt volume and design parameters for crystallisers are also outlined. The activities involved during the Construction and Operational Phases are also discussed.

3.1 Introduction

Cape Cross Salt has secured an agreement with a salt end-user who requires 500 000 metric tons per year of Food Grade Salt (FGS) supplied in bulk shipments from the port of Walvis Bay. To meet this requirement, CCS has to increase the salt production capacity of its existing crystallisers of approximately 80 000 tons per year by ±545 000 tons of FGS per year. This tonnage includes salt losses of 15% at the Wash Plant and 5% through the following multiple handling stages:

 loading from the stockpile at salt mine  hauling to the port - 165 km away  offloading at port stockpile  loading into bulk carriers at the port

3.2 Current Production Process

CCS produces salt by utilizing saturated subterraneous brine that upon evaporation produces a new layer of salt. Fresh saturated brine continuously seeps into the pond as the volume of brine is reduced through evaporation thereby ensuring a constant brine level within the pond. With time, this salt layer increases in depth and after about eight (8) months the salt layer has reached a depth of approximately 270 mm. At this stage the salt layer has reached the surface of the brine and the pond is virtually dry.

Harvesting the 270 mm layer of salt is performed by utilizing a bottom dump scraper. As the layer of salt is removed new saturated brine begins to seep immediately into the pond and harvesting equipment is forced to harvest salt that is submerged in brine.

The harvested salt is washed in a Wash Plant using a mixture of seawater and brine to form salt slurry that through the scouring action of the screw conveyors releases dust, sand and gypsum from the salt. The slurry is de-watered in a continuous centrifuge and the product stockpiled for further drying. The wash effluent is diverted into the brine aquifer.

3.3 Solar Salt Production

For the purpose of this EIA, the solar salt production process is described in terms of salt quality specifications for Food Grade Salt (FGS) against salt quality specifications for Chemical Grade Salt (CGS). There are three good reasons for the proponent, Cape Cross Salt to support this approach:

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 firstly, the supply contract secured by CCS is primarily for FGS and not CGS and therefore CCS has to focus its attention and apply its resources towards achieving that

 secondary, it is imperative to highlight the importance of strategic alignment of solar salt production and processing to meet export requirements for FGS, and

 thirdly, to ensure CCS obtains a long term sustainable competitive advantage in the FGS markets of its contracted client

The strategic alignment is imperative because the process to produce FGS and CGS lie on two ends of the same scale. Salt begins to crystallize at a specific gravity of 1,218 g/cm3 of brine (maiden brine) or once approximately 90% of fresh water has been evaporated from seawater for the solar operations that use seawater as starting material.

In the case of CCS, the brine is already at the salting point, in other words, the concentration of NaCl (Sodium Chloride) is approximately 22, 0%. From this point onward the process requirement to produce FGS and CGS will differ remarkably as shown in Table 2 which indicates the difference in terms of the specifications for FGS and CGS requirements.

TABLE 2: COMPARISONS OF SPECIFICATIONS BETWEEN FGS AND CGS Description FGS CGS Assay (%m/m) 98,0 99,5

H2O (%m/m) 3,0 4,0 Insoluble Matter (%m/m) 0,1 0,1 Calcium Ion (ppm) 1000 500 Magnesium Ion (ppm) 1000 250 Sulphate Ion (%m/m) 0,3 0,15

3.4 Comparisons of Specifications between FGS and CGS

Amongst the specifications considered in order to achieve an efficient solar salt production facility at Cape Cross Salt are the Calcium, Magnesium, Control of Mass Balance and impurities.

(a) Calcium Content

From the Table above, the Calcium still present in maiden brine is an important impurity in the production of FGS; hence no stringent brine control measures are required compared to the production of CGS. Calcium is not considered as a critical contaminant in the production of FGS and the Calcium content in the final product (i.e. FGS) will not exceed the maximum allowable concentrations specified by world quality monitoring agencies. Similarly the point of bittern discharge (spent maiden brine) will differ between the two processes.

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(b) Magnesium Content:

At 250 ppm, the Magnesium content for the CGS is so low such that to ensure the salt meets the required specifications, bittern is discharged at a maximum Magnesium concentration of about 3,0%. The discharge point for FGS is not based on the Magnesium concentration but rather on optimum salt recovery which suites the operational circumstances of CCS. For the production of CGS, the recovery from maiden brine has to be at 76.6%, whereas for FGS the recovery is about 80% depending on optimum evaporation rates against Magnesium concentration.

Of particular importance to the CCS salt production is the control of the mass balance especially that of Magnesium, Potassium, Bromine and Sulphate salts. These salts are highly soluble and will gradually increase in the concentration of the maiden brine, if bittern is not removed from the immediate vicinity of the crystallization ponds. The net effect of allowing the aforesaid salts to increase in the concentration of the maiden brine is a decrease in the evaporation rate of the brine therefore decreasing the overall production capacity of the system as well as ever increasing concentrations of these salts in the final product.

Very high Magnesium, Potassium and Bromine salt contamination in the final product (besides not meeting the UNICEF requirements for FGS) will result in a bitter taste of the salt.

(d) Solar Salt Quality

The rule of thumb to be applied for the production of a high quality FGS is to ensure the use of high quality raw material with the subsequent application of stringent process control parameters. Once high quality brines have been used to produce unwashed salt, the harvesting process and subsequent wash process will convert the raw product into final FGS effectively and efficiently. Avoiding contamination of final product can be achieved by establishing efficient procedures for storage, transportation and handling that will ensure product preservation.

(e) Insoluble Matter Content

The insoluble matter content of salt is dependent on at least three factors. The most important is to maintain a permanent pavement and to plan the depth of the pavement in such a way that the harvesting equipment is prevented from fracturing the pavement. A fractured pavement will lead to a mud pumping action occurring. Mud pumping is especially significant in soft silt or clay substrates. These soils do not occur at the CCS saltfield that consist of rock salt and gypsum layers over granite bedrock.

Wind borne sand or Aeolian sand deposition is another source of insoluble matter contamination, but this is not a significant factor at the CCS saltfield. A preventive action that could be implemented to avoid such contamination is to construct a buffer trench or fence to trap windblown sand before it can enter the crystalliser

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ponds. Again there is a distinct absence of fine to medium grain sand around the CCS saltfield.

An estimated average insoluble content of 0,06 %m/m can be expected for unwashed product and 0,02 %m/m insoluble matter for final product salt from the crystallisers of CCS can be achieved.

(f) Sulphate

As a result of the ratio in which Calcium, Magnesium and Sulphate occurs naturally in seawater, the ratio of these elements will remain approximately similar in salt. The control point for Sulphate is therefore the Calcium content of maiden brine. Controlling this parameter will ensure a Sulphate content of unwashed FGS of approximately 0,90 %m/m.

(g) Moisture Content

Of particular importance is the moisture content of the final product. Customers for FGS will use coarse salt and refine it so that the final moisture content of refined salt is 0,5%. Therefore the higher the coarse salt moisture content, the higher the conversion costs incurred by the FGS customers. In addition moisture contributes to increasing transportation cost and therefore lowers customer value. All effort must be made to ensure that final moisture content of the salt is <2,5%m/m.

3.5 Solar Salt Wash Process

There are several laws that govern the operation of conventional wash processes and these are:  poor quality unwashed salt produces poor quality washed salt;  the higher the unwashed salt quality the less expensive the wash process that will be required;  solid impurities such as gypsum and insoluble matter is removed by crystal fracturing, scouring, elutriation, hydro-cyclone and screening;  dissolved impurities are removed by crystal fracturing, residence time, diffusion and de-watering;  high concentration of dissolved impurities in unwashed salt will lead to higher dissolution losses;  high concentrations of solid impurities will lead to higher losses of solid salt

In order to convert food grade unwashed salt to food grade washed salt Table 3 below illustrates the minimum wash efficiencies required for non-series flow crystalliser operations.

TABLE 3: MINIMUM WASH EFFICIENCY TO PRODUCE FGS Un-washed Product Washed Product Wash Efficiency

H2O 8,0 %m/m 3,0 %m/m 63 % Insoluble 0,05 %m/m 0,02 %m/m 60 % Calcium 0,18 %m/m 0,100%m/m 44 % Magnesium 0,350 %m/m 0,100 %m/m 72 % Sulphate 0,900 %m/m 0,300 %m/m 67 %

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During the time of this EIA, the wash plant requirements for CCS were being determined through experimentation by two equipment suppliers. However, if historical results from the previous wash plant are to be relied upon, have there is no need for a more complex wash process.

3.6 Pond Design and Layout

The central theme when designing a solar salt production facility is to aim to achieve the highest salt production with salt of highest quality at the lowest production cost. Lower production costs and salt of the highest qualities are key elements required to aggressively compete successfully in a brutal salt market.

The intention of CCS is to aim at achieving highest salt productivity and salt of the highest quality from its solar salt operation through effective management of the brine used in the operation and its Crystallisers. The design and positioning of Crystallisers are critical to achieving high salt productivity and salt of the highest quality.

At the time of conducting this EIA, the precise layout for the entire crystalliser system was being designed taking into account the physical and geological topographic form of the saline pan. A precise layout will form a vital part of the expansion, as a sub-optimal layout design will result in higher operating costs that cannot be rectified afterwards. An effective layout is one in which the areas of highest activities are identified and the distances between such areas minimised. Hence the harvesting, washing, stockpiling and loading centres must be as close as possible to one another.

Converting salt production rate at CCS of approximately 2,000 ton/ha per annum to crystallization area required for the production of 500,000 ton results in a total crystallization area of approximately 240 ha at zero down time. The most economical method of harvesting salt is to allow for the formation of a 150 mm to 200 mm salt layer. This is to ensure optimal mechanical wear conditions during the harvesting and therefore to prevent high maintenance and downtime for harvesting equipment.

Each pond will be harvested twice per annum assuming zero down time or bi- annually. In order to determine the number and size of crystallization ponds required, consideration needs to be given to salt demand per shipment, harvesting rate per pond, pond design and crystallizer downtime.

Pending the outcome of the aquifer recharge rate and conditions, salt crystallisers will have zero down time due to readily available saturated brine. Thus 240 ha of crystalliser ponds will suffice to produce approximately 625 000 tons unwashed salt per annum with provision for salt wash and handling losses of 20%. The actual pond layout and size will depend on the topography.

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Figure 11: Proposed Crystallizer Pond Layout

Well Points Bittern Discharge to Sea Mirror Ponds

Maiden Brine Supply 200m * 500m Crystallizer Pond

3.7 Salt Wash Plant and Equipment Capacities

The global standard used to optimise asset utilization is to plan the capacity of plant and equipment on the following formula:

Demand Capacity = Plant instantaneous Capacity * 250 tons per hour @ 300 days/annum

A wash plant with an output of 250 tons per hour working 10 hours per day gives a production of 2 500 tons per day which equates to 750 000 tons over 300 days per year. Such a wash plant gives the flexibility to achieve the target production by operating only one shift, working eight effective hours per day, five days a week. It also gives the flexibility to increase production to one million tons by working two shifts of eight effective hours.

It is also advisable to build some safety margin into the design capacity so as to cope with queuing inefficiencies, irregular demand, large breakdowns and other unforeseen events. The other advantages with a wash plant of that size is that it allows huge volumes of salt to be processed and stockpiled over a longer period of time up to four months thereby giving the salt enough time dry out to reach acceptable moisture levels of under 3%.

Within this capacity there are many choices of wash and harvesting plant and equipment and each alternative has to be evaluated based on a multiple criteria assessment analysis in order to select a system that will produce the lowest operating cost per ton for the operation.

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Figure 12: A salt harvesting machine & dump truck

Figure 13: Salt Wash Plant

Figure 14: Salt stockpile ML 219 - Baseline Scoping Assessment Page 19

Figure 15: Photos taken when CCS last operated: Top left: Salt packed in ton bulk bags and stuffed into containers, Top right: Salt packed in 50 kg and stuffed into container for shipping, middle left: Salt packed in 1 ton bulk bags at the loading quay, middle left: iodised salt packed in 20 kg bags ready for shipping as break bulk, bottom left and right: salt on stockpile and wash plant (visual intrusion) 3.8 Human Resource Requirements

In the table below the human resource requirements for the salt operation are listed. All vacancies will be filled by suitably qualified Namibians in full compliance of the Labour Act:

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TABLE 4: HUMAN CAPITAL REQUIREMENTS Position Compliment Minimum Skills Required Qualification General Manager 1 Management with a minimum 10 years’ experience Degree/Diploma Operations Manager 1 Management with a minimum 6 years’ experience Degree/Diploma Maintenance Manager 1 Engineering with a minimum of 5 years’ experience Degree/Diploma Financial Manager 1 Finance with a minimum of 5 years’ experience Degree/Diploma Logistics Manager 1 Logistics with a minimum 5 years’ experience Degree/Diploma Environmental Officer 1 Environment with a minimum of 4 years’ experience Degree/Diploma Lab Technicians 2 Chemistry with a minimum of 3 years’ experience Degree/Diploma Mechanic with a minimum of 6 years’ suitable Workshop Foreman 1 Trade Qualification experience Mechanics 4 Must have a minimum of 5 years’ experience Trade Diploma Workshop Assistants 4 3 years Trade Qualification Supervisor - Harvesting 1 2 years Trade Qualification Supervisor - Wash Plant 1 2 years Trade Qualification Bookkeepers 2 2 years Degree/Diploma Administrative Officers 4 2 years Degree/Diploma Machine Operators 8 5 years Trade Qualifications Plant Operators 6 2 years Trade Qualifications 5 years’ experience, mature individuals not young Long Haul Drivers 16 Literate & Grade 10 than 40 years old Handymen/Cleaners 3 1 year Literate & Grade 10 Security/Guards 6 2 years Literate & Grade 10 64

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SECTION 4

4.0 Need and Desirability Assessment

4.1 Introduction

Namibia has a long mining history dating back to the end of the 19th century when copper was discovered at Tsumeb. In 1904, a milestone in the development of the country was achieved when the railway line between Tsumeb and Swakopmund was completed to transport copper concentrates to the coast for export to the European smelters.

Namibia‟s economy is therefore heavily depended on the mining and processing of minerals for export. In 2018, mining contributed about 14% to the GDP and provided more than 50% of the country‟s foreign exchange earnings. According to the annual report of the Chamber of Mines of Namibia for the year 2018, contributions to the domestic economy by the mining industry are as follow:

TABLE 5: MINING CONTRIBUTION TO THE NATIONAL ECONOMY Total Revenue NAD 33.545 billion Salaries and wages NAD 6.090 billion Royalties paid NAD 2.06 billion Export levies NAD 214.6 million Exploration spending NAD 573.3 million Corporate tax paid NAD 1.708 billion Total taxes paid NAD 3.986 billion Spending on skills development NAD 147.8 million Corporate social responsibility NAD 73.1 million Employment - permanent individuals 9 042 Employment - temporary employees 498 Employment - contractors 6 681 Source : Chamber of Mines of Namibia Annual Report

The development of the salt project will therefore contribute to the local, regional and national economy during its construction phase of seven (7) months and operational phase which will last for an identity period as long as there is demand for the end-product. It is important to remember that salt is one of those resources which are renewable.

All employees of the company will stay in the town of Henties Bay contributing to the socio-economic development of the local authority through payment for rates and taxes. The employees will also procure their basic needs such as groceries from local shops hence supporting and improving the status of the local economics.

At full production of 500 000 PTY, Central Government will receive a minimum royalty of at least N$4.5 million per year. All the salt produced is destined for export which will improve the foreign exchange earnings of the country and the export levy account.

4.2 Benefits to the Local Economy

The company will procure most of its services and products (fuel, oil, grease, spare parts, stationeries, office equipment, machinery, plants, etc) from local businesses hence improving the revenue generated by such businesses.

Unlike uranium which is a hazardous product and is extracted by at least three mines in the Region of Erongo, salt is not a harmful product to the human and the environment. Spilling of salt will not have a major impact on the environment.

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4.3 Salt Production in Africa

According to a presentation made by the President of Salt Partners, Mr Vladimir Sedivy at the Salt Symposium held in Park City, Utah in the USA in 2018, Namibia was the third biggest salt producer in Africa after Tunisia (2nd) and Egypt (1st) in 2015. In Table 6 below, the salt production by the six top African salt producers is shown for the periods as indicated. Walvis Bay Salt Refiners have in the meantime increased their salt production to about 850 000 tons per year (Chamber of Mines).

The 500 000 TPY targeted by CCS will place Namibia in the second spot as the second biggest salt producer on the continent after Egypt. This is something good to aspire to.

In terms of the projections of Salt partners, who are without doubt global salt experts, demand for salt in Africa is growing stronger and will continue to grow for many years into the future. This is also clearly demonstrated by the last three Tables.

TABLE 6: SALT PRODUCTION IN AFRICA Country 1970 1985 2000 2015 o Egypt 420 000 923 000 1 200 000 2 200 000 o Tunisia 330 000 405 000 662 000 700 000 o Namibia 110 000 154 000 523 000 650 000 o Botswana 1 000 1 000 185 000 525 000 o South Africa 370 000 723 000 346 000 500 000 o Morocco 45 000 105 000 203 000 425 000 o Other 883 000 1 118 000 924 000 1 186 000 Total 2 159 000 3 429 000 4 043 000 6 186 000 Source: Salt Partners (Presentation at the Salt Symposium 2018, USA)

TABLE 7: SALT PRODUCTION - WORLD v AFRICA : 1970 AND 2015 World Salt 1970 1985 2000 2015 World Total 146 600 000 176 400 000 216 600 00 294 900 900 Africa Total 2 159 000 3 429 000 4 043 000 6 186 000 World Growth 100% 120.3% 147.7% 201.2% Africa Growth 100% 158.8% 187.3% 286.5% Source: Salt Partners

TABLE 8: POPULATION GROWTH - WORLD v AFRICA : 1970 AND 2015 Population 1970 1985 2000 2015 World Total 3 700 578 000 4 873 781 000 6 145 007 000 7 383 009 000 Africa Total 366 459 000 552 800 000 817 566 000 1 194 370 000 World Growth 100% 132% 166% 200% Africa Growth 100% 157% 223% 326% Source: Salt Partners Ministries of Mines, Geological Departm TABLE 9: PER CAPITA SALT PRODUCTION- WORLD v AFRICA :1970 AND 2015 Per Capita Salt 1970 1985 2000 2015 Production World Production 109 99 97 109 Africa Production 16.1 17.0 13.5 14.2 In grams per person per day Source: Salt Partners

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SECTION 5

5.0 LEGAL AND POLICY FRAMEWORKS

5.1 Introduction

To protect the environment and achieve sustainable development, all projects, programs and policies deemed to have adverse impacts on the environment are required to have an EIA conducted in accordance with EMA. The following legislations govern the EIA process in Namibia, pertaining to the salt mining operation proposed by CCS.

5.2 The Namibian Constitution

The Constitution of the Republic of Namibia as adopted in 1990 has a clear relevance to environmental management associated with the proposed salt mining operations as outlined in Article 95:

Promotion of the Welfare of the People. The State shall actively promote and maintain the welfare of the people by adopting policies aimed at the maintenance of ecosystems, essential ecological processes and biological diversity of Namibia and utilization of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future.

The key most important Act of Parliament governing the proposed Salt Mining and Process as proposed by CCS is the Minerals (Prospecting and Mining) Act, 1992. The Act provides for the reconnaissance, prospecting and mining for, and disposal of, and the exercise of control over minerals in Namibia; and to provide for matters incidental thereto.

This article recommends that a relatively high level of environmental protection is called for in respect of pollution control and waste management. Other important legislative instruments which have a bearing on the construction, operation and decommissioning of the salt works are as shown in the Table 7 below:

The following legislations are applicable to the development contemplated by the promoter.

TABLE 10: APPLICABLE NATIONAL LEGISLATIONS The Environmental Management Act, Act No. 7 of 2007: Environmental Impact Assessments are regulated in terms of the Environmental Management Act, (Act No. 7 of 2007). This Act was gazetted in December 2007 (Government Gazette No. 3966) and the Environmental Impact Assessment Regulations: Environmental Management Act, 2007 (Government Gazette No. 4878) were promulgated in February 2012. The chief custodian of the Environmental Management Act is the Environmental Commissioner in the Ministry of Environment and Tourism custodian Minerals (Prospecting and Mining) Act, act 33 of 1992 The Act provides for reconnaissance, prospecting and mining, and disposal of, and the exercise of control over minerals in Namibia, and all matters incidental thereto.

Mining Licence: means a Mining Licence issued under Section 98 of the Minerals Act and includes the renewal of any such license.

Mining Area: means the area of land to which a Mining Licence relates.

Mining Operations: means any operations carried on in connection with mining Mine: when used as noun means any place where mining operations are or have been carried on, including any excavations or accessory works, which is or are necessary for, or incidental to such mining operations Mine: when used as a verb means any operations calculated to win any mineral or group of

ML 219 - Baseline Scoping Assessment Page 24 minerals, from a mine or from any ore won from a mine and includes any operations which are necessary for or incidental to such any operation. Water Resource Management Act (Act No. 11 of 2013) The line ministry is the Ministry of Agriculture, Water and Forestry. This Act provides for the management, protection, development, use and conservation of water resources; to provide for the regulation and monitoring of water services and to provide for incidental matters. The Road Administration Act (Act No. 18 of 1999 as Amended Regulates traffic and use of public roads in Namibia including aspects related to road safety, vehicle licensing, roadworthiness, Mass Distance Charges, abnormal loads, etc. Atmospheric Pollution Prevention Act (Act No. 45 of 1965) This Act was enacted in 1965 is still being applied in independent Namibia today and resorts under the Ministry of Health and Social Services. The Act attempts to guard against the pollution of the atmosphere. A number of sections of this Act relate to ‘Air Pollution Control Certification’, dust control, etc. At present, the Ministry does not grant any certificates as no procedures or guidelines exist. The best practice would be to notify the Ministry of the anticipated emissions. National Heritage Council Act (Act No. 27 of 2004) As Amended The line ministry is Ministry of Youth, Sport and Culture. The National Heritage Council Act provides for the protection and conservation of places and objects of heritage significance and the registration of such places and objects. It also makes provision for archaeological ‘impact assessments’. Part V: Permits, paragraphs 51 and 52). If applicable, the relevant permits must be obtained before disturbing or destroying a heritage site as set out in the Act. Atomic Energy and radiation Protection Act (Act No. 5 of 2005) The Hazardous Substance Ordinance No. 14 of 1974 was repealed and amended by the Atomic Energy and Radiation Protection Act. The Act provides for the control of substances which may cause injury or ill-health or death of human beings by reason of their toxic, corrosive, irritant, strongly sensitising or flammable nature. Whilst the environmental aspects are not really explicitly stated, the Act provides guidelines with respect to importing, handling and storage, etc. of hazardous substances. The line ministry is the Ministry of Police, Safety and Security (the Drag Law Enforcement Unit). The Regional Council Act (Act No. 23 of 1992) The Act resorts under the Ministry of Urban and Rural Development and was enacted to promote the planning and coordination of policies at the regional level. Under Article 28, the powers, duties, functions, rights and obligations of regional councils include overseeing the general implementation of regional development activities. The Labour Reform Act (Act No. 11 of 2007) To consolidate and amend the labour law; to establish a comprehensive labour law for all employers and employees; to entrench fundamental labour rights and protections; to regulate basic terms and conditions of employment; to ensure the health, safety and welfare of employees; to protect employees from unfair labour practices; to regulate the registration of trade unions and employers’ organisations; to regulate collective labour relations; to provide for the systematic prevention and resolution of labour disputes; to establish the Labour Advisory Council, the Labour Court, the Wages Commission and the labour inspectorate; to provide for the appointment of the Labour Commissioner and the Deputy Labour Commissioner; and to provide for incidental matters The Petroleum Products & Energy Act (Act No.13 of 1990) As Amended The Act provides measures for saving of petroleum products and an economy in the cost of the distribution thereof, and for the maintenance of a price therefore, for control of the furnishing of certain information regarding petroleum products, and for the rendering of services of a particular kind or services of a particular standards, in connection with motor vehicles, for the establishment of the National Energy Fund and for the utilization thereof, for the establishment of the National Energy Council and the functions thereof, for the imposition of levies on energy sources, and to provide for matters incidental thereto.

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TABLE 11: NATIONAL POLICIES & RELATED PROGRAMME The Environmental Policy of Namibia

The Environmental Assessment Policy requires that all projects initiated by both the government and private sector that have a detrimental effect on the environment must be accompanied by an EIA. It further provides a guideline list of all activities that require an impact assessment. The proposed activity is listed as an operation requiring an impact assessment. Vision 2030 and National Development Plans (NDPs)

Vision 2030 states that: “The nation shall develop its natural capital for the benefit of its social, economic and ecological well-being by adopting strategies that: promote the sustainable, equitable and efficient use of natural resources; maximize Namibia’s comparative advantages; and reduce all inappropriate use of resources. However, natural resources alone cannot sustain Namibia’s long-term development, and the nation must diversify its economy and livelihood strategies. The Harambee Prosperity plan (HPP)

The HPP was launched by President Geingob in March 2015 as a targeted Action Plan to accelerate development in key defined priority areas, which lay the basis for attaining prosperity for all in Namibia. The Plan does not replace, but complements the long-term goal of the National Development Plans [NDPs] and Vision 2030. HPP introduces an element of flexibility in the Namibian planning system by fast tracking development in areas where progress is insufficient. It also incorporates new development opportunities and aims to address challenges that have emerged after the formulation of NDPs.

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SECTION 6

6.0 The Baseline Receiving Environment

6.1 Introduction

This section provides an overview on those aspects of the natural environment that are considered as opportunities or constraints upon the proposed development of ML 219 or those aspects of the natural environment that may be impacted by the development of ML 219.

The impacts were gathered through sources such as:

 visual investigation and survey of the site  discussions with the proponent  desk study  observation of the current environmental status

Only those elements of the environment that have a direct bearing on the impact assessment process of the salt works are discussed. The severity of the potential impacts is largely determined by the state of the receiving environment.

6.2 Access to the Salt Resource

From Henties Bay, access to the saltfield is provided via salt road D2301 over a distance of 42 km. D2301 is linking vital areas along the coast up Terrace Bay.

6.3 Climatic Conditions

The climatic conditions along the coastal area of the Namib Desert are ideal for salt production. These are: low rainfalls, high evaporation rates (up to 1500 mmm per year), strong winds and high humidity.

Rainfall: The average rainfall per year in the project area ranges from a minimum of 20 mm to a maximum of 50 mm. It is not uncommon for the area to go for years without a single drop of rain. In general, the rainfall pattern can be described as is extremely variable, patchy and unpredictable. However, the coastal line of Namibia receives considerable amounts of moisture from fog or dew. This fog is believed to support several types of plant species found in the Namib Desert (Christian, 2006). The project area is a saline pan and therefore devoid of any plants.

Temperature: The temperature in the Namib Desert is moderated by proximity to the sea, i.e. as the distance from the coast increases, temperature become more intense. The hottest month is February when the temperature could push the mercury bar towards the 40 0C mark. The average maximum temperature is normally between 25 0C and 30 0C. The coldest month is August when temperature ranges between 6 0C and 12 0C, again depending on the distance from the coast.

Wind: Prevailing strong winds are normally from southerly direction, but westerly to south westerly winds are also encountered. Generally, the wind speed will decrease as the distance from the coast to the interior increases (Christian, 2006). Warm easterly winds from the interior could typically blow for several days. These „berg winds‟ are hot dry winds caused by air descending from inland. As the air descends from the interior, it is compressed causing a rapid increase in temperature. These winds could cause seriously sand storms especially during winter and spring.

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6.4 Site Topography

The topography within ML 219 is generally flat with about one (1) meter below sea level right across its entire width of over 2.5 km. To the northwest of ML 219, there are rocky outcrop. To the west and quite distant from ML 219 is the sand barrier which separates the saltfield or the Cape Cross Salt Pan (saline pan) from the Atlantic Ocean.

The section of ML 219 to the east and trending along the D2301 salt road is marginal elevated and depressions above sea level by about 1.2 m. Undulating features resulting from old workings are evident as seen in the photos below.

6.5 Geological Aspects

The geology of the Cape Cross Saltfield is well documented. The Cape Cross Salt Pan as it is commonly referred to, today, came into existence hundreds of years ago, when a stretch of sand dune with an average width of 450 m separated from the seawater constituting a small island.

The sand dune acted as a barrier preventing the seawater in the pan from mixing with the waters from the open sea. The lagoon so created measures approximately 45 km2 in extent (±16 km in length and averaging ±2.8 km in width). (Linnig 1964)

Overtime, the water held in the lagoon evaporated, leaving behind a layer of Halite (Rock Salt). The width or thickness of the Rock Salt varies between 4.5 m and 0.5 m. The total Rock Salt in the Cape Cross Salt Pan has been estimated at over 320 million tons (Lenning 1964). Below the thick layers of Halite is saturated subterraneous brine. When the saturated brine is pumped into a well-constructed Crystalliser (Pond), it starts to produce new layers of salt almost immediately.

This saturated brine is used as the raw materials in the production (mining) of Food Grade Salt at Cape Cross. Tests conducted have confirmed that the brine in the aquifer is continuously being replenished by seawater seeping through the sand barrier which separates the lagoon from the main open sea. The pan has therefore unlimited brine (at saturation point), to sustain a solar salt operation producing over a million tons of salt per year basically for an indefinite period

The lagoon is bordered on its southern, eastern and northern periphery by low hills of gently dipping Etendeka Formation mixed with igneous rocks of the Cape Cross Complex. To the west is the Atlantic Ocean which is separated from the Salt Pan by the sand dune mentioned above. Marine terraces are encountered on the eastern margin of the pan as well as alluvial fans caused by occasional floods from inland.

Along the coastline where the salt pan floor lies between the low and high-water marks, distinctive lagoons have formed parallel to the coast line. Fossil rock salt is well developed in the eastern half of the pan but tends to thin out toward the coastline alternating with sand and layers of clayish materials. The rock salt is thicker to the east of the pan providing a good base for the construction of Salt Crystallisers (Ponds).

6.6 Land Use, Tenure and Capabilities

The status of the land has been described in section 2.2 and only the land capabilities are dealt with here. The land covered by ML 219 is about 18% of the approximate land size of Cape Cross Salt Pan (±4000 ha). Salt has been mined from the Cape Cross Salt Pan for over sixty years. ML 219 is confined to the saline pan – an area already disturbed by past salt mining activities. In proclaiming the Dorob National Park, MET has adopted a synergy approach which enhances and encourages development within the park based on a three pillar sustainable multiple-land use, targeting and promoting:

 conservation

 eco-tourism, and

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 other economic opportunities with low levels of environmental impacts (salt mining, aqua-culture, Guano harvesting, etc)

According to the proponent, several tourists travelling on the D2301 have often stopped at the salt works and asked questions. Many tourists were fascinated to view and observe the salt operation.

As mentioned in section 2.2, uranium and diamonds are amongst the mineral commodities mined extensively in the Namib Desert. These minerals are finite and not renewable resources. Salt is a renewable resource and mining of salt will continue for hundreds of years into the future long after uranium and diamond mining operations have ceased.

6.7 Hydrology - Surface and Underground Water

The Cape Cross area is actually split into two sections namely: the Lagoon and the Salt Pan or Saltfield. The Lagoon is the area alongside the beach where puddles of standing water are observed especially towards the southwestern part of the saltfield (See figure 15). The Lagoon is not directly connected to the Ocean and the standing water is perhaps as result of tidal inflows. The Lagoon has been given the status of an Important Bird Area‟ accommodating a huge number of marine birds.

The Saltfield is the saline pan which lies west of D3201 and east of the lagoon. The whole of ML 219 is on the saline pan, but some of the accessory works are outside the saline pan. These are the:

 access road from D2301 to the premises  administrative offices  workshop & storeroom for spare parts  the workers‟ accommodation, and  the two staff housing

Surface Water: Other than the brine in the crystallisers and the bitterns (spent brine) there are no other sources of open surface water within ML 219. However, the southeastern end of ML 219 is abutting sections of the flood plain (delta) of the Owarab River – one of several ephemeral rivers flowing from the interior to the Atlantic Ocean.

Whilst there are no recent records of the flow of the Owarab River having reached the Cape Cross saltfield, there is a likelihood that sporadic flooding incidents of this river could pose a potential threat to salt production infrastructures. It is therefore recommended that any salt crystallisers constructed on the southeast section of ML 219 be raised to a height of at least 1.2 m to mitigate against any flooding incidents of the Owarab River. The flow of the Owarab River is indicated on figure

Washing of harvested salt is done with brine and not potable water. Potable water required for the operation will be for human consumption and cleaning purposes only (washing of machinery and equipment) and will be sourced from Henties Bay as is the case with all other operations in the area. The water requirement for the salt operation is not expected to impact negatively on the available water resources at Henties Bay.

Underground Water: Drilling conducted in the Owarab River flood plain has indicated that the underground was saline and classified as Category D and therefore not fit for human consumption. The yield was also relatively poor.

The promoter did not consider alternative water supply to the project such as lying a pipeline from Omdel Water Scheme to Cape cross Saltfield.

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Figure 16: ML 219 in Relation to the drainage channels of the Owarab River

6.8 Dust Disturbances

During the Construction Phase, dry products will be handled (sand, gypsum, etc. to seal off the floors of the crystallisers) which are likely to generate some dust. Little dust is expected during the Operation Phase – this is due to the high moisture content of the soil and the salt nature of all internal routes on the salt mine.

Perhaps the biggest source of dust pollution encountered all along the coastal areas of Namibia is the occasional „berg wind conditions‟ which often result in elevated content of airborne particulate matters from the dry interior.

6.9 Noise Disturbances

Within the context of ML 219 existing sources of noise are the three neighbouring salt mining works, the traffic using the public road D2301 and the occasional use of the landing strip north of ML219. Perhaps the noisiest place is the Cape Fur Seal Colony. On a quiet and calm day, the noise from the Seal Colony is laudable at the salt works.

Generally, some noise is expected from machinery and equipment to be used in both (Construction and Operation) phases of the salt operation: During the Construction Phase, the machinery and equipment in use will include: bulldozers, graders, compactors, wheeled loaders, tipper trucks, water tanks and LDV (light duty vehicle, i.e. bakkies). These machineries are expected to generate noise which is likely to impact the ambient noise level in the area.

During the Operational Phase noise will be generated by machinery used in these activities: pumping, harvesting, hauling and washing of salt. The generator sets producing power will also generate some noise. The transport of salt to Walvis Bay with tipper trucks will also generate some noise but the road is shared with other vehicles also generating some noise.

There are no sensitive noise receptors in the area and noise impacts can be effectively mitigated and kept within acceptable thresholds. Some of the measures which could be used with respect to reducing noise impacts from machinery and equipment are provided in the Environmental Management Plan.

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6.10 Ambient Air Quality

The public road D2301 is used by relatively little traffic each day which emit gaseous emissions into the atmosphere. The three existing salt operations on the saltfield are also relatively mechanized and use diesel powered machinery and equipment (loaders, hydraulic saws, cutters, generators, etc.) which releases gaseous emissions and therefore impacting on the ambient air quality in the area.

All internal routes on the mine are „salt roads‟ and vehicles using such roads do not generate dust. The machinery and equipment mentioned in the preceding section (5.7) are diesel powered and are expected to release emissions within the mining area and the surrounding areas. Such impacts can be mitigated if the proponent complies with the provisions of the EMP.

6.11 Waste Management

Waste, especially solid waste is a general problem in Namibia which poses a significant threat to human and the environmental health. Widespread littering of cans, bottles and plastics has become a visual nuisance along major roads in the country and D2301 and the surrounding areas are no exception.

Types of wastes which will be mostly associated with Construction Phase are:

 rock salt waste from the construction of Salt Crystallisers  cement bags  paint containers  steel scraps  broken metals  unused concrete  building rubble

Types of wastes which will be associated with the Operational Phase are:

 hazardous or industrial waste: - waste oil, used lubricants, old batteries, oil filters, scrap metals, scrapped machines, old earthmoving vehicle tyres, paints, conveyor rubber belts, hose pipes, etc.

 household or domestic waste: these are items such as empty bottles, broken glasses, plastics, carry bags, old overalls, old safety shoes, redundant PPEs, etc.

 office waste: the wastes in this category will be empty cartons, newspapers, magazines, papers, ink cartridges, obsolete office machines, old files, maps, pens, etc.

MET has a launched a National Solid Waste Management Strategy (NSWM) which sets plans and initiatives to address this national problem. This has resulted in the banning of use of plastics in all national parks.

Guidelines on how CCS should deal with wastes generated by its salt operation at Cape Cross are provided in the EMP.

6.12 Visual Intrusion

To a large extent, visual intrusions are dependent on the characteristics of the existing landscape, topography and the sensitivity of receptors. With specific reference to the envisaged activity, sensitive receptors are the tourists using the coastal road D2391 to visit the Cape Fur Seal Colony and the Cape Cross Lodge. The salt operation is however too far and invisible to guests visiting these facilities (seal colony and lodge).

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6.13 Archaeological & Cultural Heritages

From an archaeological and cultural heritage perspective, the area of Cape Cross has both historical and biological interests of great significance to the country. The Cape Cross Seal Reserve is a popular tourist attraction receiving the highest number of local and international visitors each year, second only to the Etosha National Park.

In 1486, exactly 533 years ago, a Portuguese speaking navigator named, Diego Cão, was the first European who landed at Cape Cross and planted a stone cross 2 m high and weighing about 360 kg to mark his journey. A replica of the cross is still standing there today and the site has been given the status of the National Heritage Site.

It is reported that in 1895, thousand tons of guano was discovered at Cape Cross. Guano is the waste left by fish-eating sea birds and is used as a fertilizer and it is Inca word for a mixture of eggshell, feathers, decayed corpses of birds and bird droppings that became so valuable and was called “white gold”. Guano platforms were constructed on site and the products shipped to European markets from a private jetty constructed in the adjacent Cape Cross Bay.

The demand for Guano led to the construction of the first railway line in Namibia of 21 km over the Cape Cross Salt Pan to the ships in the Cape Cross Bay. Large volumes of Guano and seal skins were shipped during that period. A small community consisting of some 100 workers lived and worked at Cape Cross. A police station, customs office and post office were other facilities established at the Cape Cross Settlement during that period. (Source: MET, Cape Cross Seal Reserve)

Other than the stone cross, there are no other items of cultural heritages known in the area. In the event that such items are unearthed during the construction of crystallisers, the procedures outlined in the EMP section of the EIA should be followed.

In the event that future salt production from Cape Cross exceeds 500 000 tons per year, the proponent is advised to assess the costs involved in the construction of a salt loading jetty in the Cape Cross Bay.

6.14 The Biological Environmental Aspects

Flora: In terms of the widely used classification of the Namibian vegetation, the Cape Cross saltfield falls into the Central Namib Vegetation Zone (Giess, 1998). This zone consists of two sections – the first section is a narrow coastal strip of hummock dunes. This is followed by a second section which is parallel to the first comprising the littoral zone which represents the first line of vegetation above the high water mark.

The entire ML 219 is located on the saline pan which is devoid of any kind of vegetation. Two areas in close proximity of ML 219 that support the existence of vegetation are the lagoon (wetland) portion described in the section 5.6 and the delta of the Owarab River located on the southeastern periphery of ML 219.

Fauna: The Cape Cross Lagoon as described in section 5.6 is directly ±2 km from the southern border of ML 219. The Lagoon supports high numbers of marine birds. The construction of 6.8 ha of guano platforms over hundred years ago has provided a safe haven for breeding and roosting to the cormorants and other bird species.

Various reptiles and insects are also encountered in the halophytic vegetation along the Lagoon margins. An aerial survey estimated carried out in 1974 has

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estimated the number of cormorants at 900 000 birds. About 28 bird species are recorded.

The Cape Seal Colony northwest of and about 5 km from ML 219 provides fertile feeding grounds for brown hyenas and seagulls. The brown hyenas live in the mountain hills to the east of Cape Cross and commute to the Seal Colony during the day and night. The construction of salt ponds on ML 219 is likely to impede the movements of such brown hyenas.

Fig 17: The Cape Cross Seal Colony Fig 18: Cormorants in the Cape Cross Lagoon Lagoon

Fig 19: Seagull feasting on a seal puppy Fig 20: The stone cross at Cape Cross

Fig 21: A jackal killing a seal puppy at Seal Colony Fig 22: Permit Office to Cape Cross Seal Colony

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6.15 The Socio-Economic Environment (Human Environment)

According to the Population and Housing Census (HPC) of 2011, the Erongo Region had a population of 150 809 with 87.4% living in its six urban areas with Walvis Bay and Swakopmund accounting for majority of the urban population.

The recent survey by the Namibia Statistic Agency titled „Namibia Housing Income and Expenditure Survey‟ for 2015/2016 has estimated the population of Erongo at 175 752 with the coastal towns of Walvis Bay and Swakopmund having respectively recorded growth rates of 5.3% and 5% from the PHC of 2011.

Interesting statistics regarding the main employment sectors within the region were reflected in NHP of 2011 as in the table below:

TABLE 12: MAIN EMPLOYMENT SECTORS IN ERONGO REGION Economic Sector % Employment Mining 11.7% Manufacturing 11.5% Fishing and Agriculture 11.5% Construction 9% Vehicle Repairs 9% Support Services 8%

Henties Bay Town All employees of CCS will reside in the town of Henties Bay with the company providing free transport to and from work. A brief description of the population and the services available are as follow:

Population: The town of Henties Bay has a population of about ±14 000 as permanent residents of the town. As is the case with all towns at the coast, Henties Bay has two residential sections – Omdel is the section formerly reserved for black residents or non-whites while Henties Bay proper is the section formerly reserved for whites residents (for the Europeans only).

Most houses in the town are owned by non-permanent residents who often come to Henties Bay during the holidays and festive season. During the festive period the population could swell to about 30 000 people. According to NSA, Afrikaans is the most widely spoken language in Henties Bay – 85% of the residents are conversant in Afrikaans followed by Damara and Oshiwambo.

Housing: Henties Bay is reportedly having an oversupply of serviced residential erven but targeted mainly for middle and high income earners. Affordable housing for low income earners is in short supply with demand for low cost housing projected at 800 units. Unlike Swakopmund and Walvis Bay, Henties Bay has not benefited from the Mass Housing Project of Government.

Education: Henties Bay has one government school providing primary education from Grade 0 to Grade 10. After grade 10, learners have a choice of secondary schools in Swakopmund, Walvis Bay or Uis. The school is reported to have a high number of learners than it was designed to cater for.

Henties Bay has also a satellite campus of the University of Namibia (Sam Nujoma Campus) which is multidisciplinary research centre mandated to promote and coordinate research and development in the areas of marine science and coastal management. The campus is situated along the ocean and has beautiful buildings.

Health: There is a State clinic at Henties Bay manned by about five professional nursing staff. There is no permanent medical doctor assigned to the clinic yet, but ML 219 - Baseline Scoping Assessment Page 34

a doctor will normally visit the facility three or four times a week – depending on the workload and arrangements made by the nursing staff. There is no ambulance assigned to the clinic and patients in need of ambulance transport needing will have to wait for an ambulance to be arranged from Swakopmund.

For those people with medical insurance, there are a number of doctors with private practices the majority of whom are who are retired doctors and therefore well experienced. There is also a medical centre, two or three pharmacies and a frail care centre.

Local Economy: The Henties Bay local economy is comprised of formal business and informal business. Formal businesses found in town include grocery shops, a line fish processing factory, seal factory, sand-brick-making enterprises, car repairs, fuel retail service stations, hotels, real estate agencies, a hardware store, etc. and a machine The town is quite compact and within walking distance of all houses in the town. An 8-hole golf course is planned for the town and will offer private residential houses.

Crime level is quite low in Henties Bay compared to other coastal towns.

Figure 23: Top: Serviced residential erven in Henties Bottom: Henties Bay during the festive season

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SECTION 7

7.0 Impact Assessment Methodology

7.1 Introduction

This section provides an introduction to the assessment of potential impacts which follow in the next section of this EIA document. The criteria used in making each assessment are also explained.

Firstly, in line with international practice in EIAs, a broad definition of „Environment‟ is adopted, which incorporates bio-physical and socio-economic components. The Environmental Management Act (EMA) of Namibia also seeks to achieve a balance between negative and positive impacts and between bio-physical impacts and social and economic gains to society.

Therefore, both positive and negative impacts to the environment are considered. To the extent that it is practically possible, the report has recommended measures to mitigate identified negative impacts to the environment and where positive impacts have been identified, measures to optimize such positive impacts have also been recommended.

The assessment includes all activities to be undertaken within the boundaries of ML 219. These are the construction of salt crystallisers over 250 ha of the saline pan, salt works internal routes, water and electricity requirements for the operation, the transport of salt to the port of Walvis Bay and all matters incidental thereto. The findings are then presented to MET as the competent authority to make an informed decision on whether the salt expansion operation as proposed by CCS should be:

 cleared and authorized to resume  authorized to continue with conditions, and/ or  rejected and refused

7.2 Identification of Impacts

The identification of potential impacts associated with this salt operation on the environment had included only those impacts which could occur during the Construction and Operational Phases. While the salt operation has an indefinite lifespan, a conceptual decommissioning plan has been provided for any possible pre-mature operation closure, i.e. as a result of project failure, insolvency on the part of the promoters or due to economic factors such as recession.

Included in the process of identification and assessment of impacts are inter alia, the following:

 determination of current environmental conditions in sufficient detail so that there is a baseline against which impacts are identified and measured

 understanding of the salt operation in great details so as to understand all consequences associated with its activities

 identification of significant impacts that are likely to occur if the salt works ceases operation in an unplanned and non-coordinated fashion

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7.3 Evaluation and Mitigation of Impacts

Once impacts have been identified and/or predicted for a particular activity, appropriate mitigation measures are proposed. Mitigation measures are the modification of certain activities in such a way so as to reduce the impacts on the environment. The objectives of mitigation measures are amongst others to:

 find more environmentally sound ways of doing things  enhance the environmental benefits of the proposed activity  avoid, minimize or remedy negative impacts  ensure that residual negative impacts are within acceptable levels

When mitigation measures are considered for certain impacts, such measures are organized in a hierarchy of actions, namely:

 avoid negative impacts as far as possible through the use of preventatives  minimize or reduce negative impacts to „as low as practicable‟ level, and  remedy or compensate for negative residual impacts that are unavoidable and cannot be reduced further

7.4 Impact Assessment Methodology

It is important to point out here that this assessment is made on the basis of the current proposal by CCS to produce, process and transport to the port of Walvis Bay 500 000 tons per annum. Should these parameters change in any materials way, i.e. should CCS wish to increase production to 700 000 tons per annum, and to export the product either through the port of Walvis Bay or via a private loading jetty in the adjacent Cape Cross Bay, then this assessment will have to be reconsidered and amended.

In the next section, for each activity with the potential for environmental impact, a brief discussion of the impact is presented. Where practically possible, the discussion is followed by a table that summarises all assessment parameters according to specific criteria as presented in the table here below.

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TABLE 13: ASSESSMENT OF IMPACTS This is an appraisal of the type of effect that the proposed activity will have on the receiving environment and is classified as Nature of POSITIVE IMPACT: a benefit to the receiving environment Impact NEUTRAL IMPACT: no cost or benefit to the receiving environment NEGATIVE IMPACT: a cost to the receiving environment These are measures which could be applied to reduce negative impacts or to Mitigation enhance positive impacts The geographical extent of the impact applied on the scale of: LOW: impact is site specific or confined within the project boundaries Extent MEDIUM: impact extends beyond the boundaries of the project HIGH: impact extends beyond the boundaries and have a widespread effect VERY HIGH: impact extends beyond regional and national boundaries The length of time that impact persists: SHORT TERM: 0 - 5 years Duration MEDIUM TERM: 5 - 15 years LONG TERM: Lifespan of the project PERMANENT : beyond the lifespan of the project LOW: natural, social and cultural functions are not significantly affected Intensity or MEDIUM: natural, social and cultural functions continue but are modified Magnitude of HIGH: natural, social and functions become altered to the extent that they Impacts become dysfunctional The probability of the impact actually occurring: IMPROBABLE: a low probability that the impact will occur Probability PROBABLE: a distinct probability that the impact will occur HIGHLY PROBABLE: it is most likely that the impact will occur DEFINITE: the impact will occur regardless of any mitigation measures The level of confidence that can be placed on this assessment: LOW: There is a high degree of uncertainty associated with the impact predicted, as certain key information was unavailable at the time of the prediction MEDIUM: Although the majority of the information was available, there is Confidence some uncertainty associated with the impact HIGH: The prediction was based on virtually all necessary information being available, with the exception of significant information that will not materially affect the outcome of the. In other words, the impact is well understood DEFINITE: No uncertainty is associated with the prediction of the impact and all necessary information was available. The Significance of the impact is equal to the: CONSEQUENCE x PROBABILITY LOW SIGNIFICANCE: implies that the impact would not have an effect on the decision to approve the project Significance MEDIUM SIGNIFICANCE: implies that the assessed impact should have an effect on the decision unless it is effectively mitigated HIGH SIGNIFICANCE: implies that the decision will be influenced regardless of mitigation Further A recommendation for further investigation (prior to the commencement of Investigation or the activity) or monitoring (prior to commencement and/or during operations Monitoring or even post closure.

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SECTION 8

8.0 Impact Assessments and Mitigation Measures

In the section below, all possible impacts associated with the salt expansion works as proposed by CCS are assessed and a SIGNIFICANCE RATING for each impact determined.

8.1 The Physical Environment

8.1.1 Access and Traffic Impacts on National Roads

From the Walvis Bay Harbour where the salt is exported from, access to the Cape Cross saltfield is provided via three national public roads and the total distance involved is approximately 165 km. Starting from the Cape Cross saltfield, the three roads are D2301, C34 and MR44 as depicted in figure (??).

These roads are described here and the potential impacts that the hauling of salt will have on them:

Figure 24: Salt Haul Routes – from Cape Cross to WVB Port (a) District Road D2301 - Between Cape Cross Salt and Henties Bay

This coastal road links Henties Bay and the Cape Cross saltfield and proceeds further up to Terrace Bay. The section of D2301 between ML 219 (salt works) and MR76 (the turnoff to Uis) is approximately 42 km. This is the only gravel (salt) road involved in the transport of the salt to the port.

In an audit report carried out by the Roads Authority on this section of D2301, the road cross section was found to vary along the road subsection and should be widened to a constant roadway width of 9 m inclusive of shoulders over a stretch of approximately 19 km.

Currently the road cross section is only 7 m with shoulders of 0.5 m on either side. Without road markings this is too narrow to allow two heavy trucks driving in ML 219 - Baseline Scoping Assessment Page 39

opposite directions to pass each other safely. The shoulder tends to fail when a heavy vehicle drives over it. In Figure (?) the presence of vertical curves can be seen on D2301 road. This is a result of the salt road having been built to follow the contours and has safety risks. However, the risks can be managed by way of signage. The effect of mist and fog has also to be catered for by means of warning signs and road delineators.

Figure 25: Vertical curves causing blind spots on D2301 salt road

Figure 26: D2301 is too narrow -7m excluding Figure 27: Shoulder of D2301 tend to fail shoulders of 0.5 cm on either side

Between Fisherman Inn and the access road into ML 219, D2301 is intersected by about three access roads leading to and from:

 Mile 72 Camping Site & an aircraft landing strip  Salt Washing Plant operated by a Walvis Bay based company, and  the guano platforms

The intersection of the access road from Mile 72 is located on a straight flat section of D2301 and the sight distances to the north and south are long and unimpeded. This is also the case with the access road from the guano platforms. The sight distance from each side is clear and adequate as can be seen in Figure 27 below. There were no road signs erected along D2301 to warn the traffic and no stop sign for the traffic entering D2301.

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Figure 28: D2301 seen from north towards the curve. Access road from the Guano Platform is to the right

The intersection of the access road from the salt wash plant operated by Blaaws Transport is outside a very sharp curve which does not impede the horizontal site distance. From the north the road (D2301) shows a slight crest curve which does not appear to hide approaching traffic. However, the curve itself is too sharp and is likely to pose safety risks especially when two heavy vehicles travelling in opposite directions approach each other in the curve at night or when foggy conditions prevail.

The safety risk posed by the sharp curve can be mitigated by way of erecting adequate road signs to warn heavy duty vehicles when approaching the curve under conditions in which visibility is reduced and or when the road is slippery.

Some of the measures which can be implemented to improve safety on this section of D2301 are:

Poles painted white with yellow reflective strips as elected on the road periphery should be maintained at standard spacing of say 100 m. The poles or edge markers should be regularly cleaned to serve their purposes.

„No passing signs‟ in conjunction with „warning sign‟ must be installed where blind crest or rise occur

Signs of „no road markings‟ should be prominently installed at all intersections and junctions along D2301.

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Fgure 29: Sharp curve on D2301 seen from north to south

Figure 30: Sharp curve on D2301 seen from south to north

(i) Intersection of the Salt Mine Access Road with D2301

The current intersection of the mine access road with D2301 is slightly raised and the horizontal sight distance to the north is not impeded. From the vehicle, the view to the north is very clear for a considerable distance. However, the horizontal sight distance to the south is impeded with slight undulations in the vertical alignment. From the vehicle the view to the south shows a slight crest curve that hides approaching vehicles. The current location is therefore reasonably unsafe when a heavy fleet of heavy vehicles.

The intersection therefore represents a potential hazard to other road users as slow-moving heavy trucks loaded with salt enter a road that currently has low volumes of traffic. The position of the intersection should be carefully chosen to avoid proximity to existing bends in the road. It is recommended that turning lanes be added to both sides of the road (D2301) to facilitate smooth merging of traffic onto D2301.

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Fgure 31: Access road from CCS salt works onto D2301. No stop sign & warning signs from north to south

It is further recommended that good and adequate signage be installed to warn other road users of heavy vehicles entering and turning off the road. These measures will require consultation with and approval of the Roads Authority.

(ii) Intersection of the Uis Road (MR76) with D2301

At present MR76 - the road linking Henties Bay to Uis is a gravel road and has little traffic on it. Upgrading of this road to bitumen standard is earmarked to start during 2021 Government financial year with completion planned for 2024. This road joins coastal areas with the settlements of Uis, Khorixas, Fransfontein and Kamanjab and its upgrade to bitumen will reduce travelling time and costs to the northern regions. Traffic is therefore expected to increase on this highway once it is tarred.

Fgure 32: T-junction of Uis Road onto D2301 – well provided with signages

The existing intersection is provided in terms of warning and direction signage. The width of the junction is adequate for the current use, given the traffic to and from Uis is very low. With the projected traffic increase on the D2301, the cross section at this intersection is likely to be inadequate to provide a lane for vehicles turning right waiting to cross the opposite traffic.

As a mitigation measure it is recommended for the intersection area to be widened through normal maintenance actions to provide an area where three lanes of traffic can be accommodated.

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(b) Public Road C34: Between Henties Bay and Swakopmund

Henties Bay and Swakopmund are connected to each other by this road and if the turnoff to Uis (M76) is taken as a reference point, the distance involved is approximately 79 km. C34 has been recently upgraded to bitumen standard up to the Uis turnoff. Practical completion is expected during the first quarter of 2020.

Swakopmund and Walvis Bay are linked by MR44 which runs behind the dunes and is currently being upgraded to a dual carriageway. MR44 is being constructed to ease and reduce the traffic congestion on B2 – a single carriageway which runs along the coast. Practical completion is expected during the second half of 2020. Total distance from the Swakopmund interchange to the port at Walvis Bay is approximately 45 km.

TABLE 14: TRAFFIC IMPACTS ON NATIONAL ROADS: D2301, C34 and MR44 Possible Impacts:  Overloading - hence causing undue wear and tear on national roads  Collisions - failure to stop at traffic stop signs  Over speeding  Operating unlicensed and non-road worthy vehicles  Incidents/ Accidents as a result of non-adherence to road regulations Possible Mitigation Measures All potential impacts as listed above can be effectively mitigated if the provisions of the EMP are complied with. A weighbridge should be installed and all trucks loading salt must pass over a weighbridge.

All trucks used on public roads must be licensed, roadworthy and operated by drivers who are in possession of valid licenses and public permits.

Adequate lighting and traffic signs at the intersection of the access road and D2301 should be provided to warn other road users. To enhance safety, trucks hauling salt to the port should have amber hazard lights affixed at the front and rear. Such lights should be switched on at all times in addition to main headlights. The light housing should be cleaned before each trip. Nature of Impact Negative Extent of the Impacts Medium to High – salt transport over 165 km Duration Long term Intensity Low Probability Highly Probable Confidence High Significance Low Further Remarks Comply with the EMP

8.1.2 Site Topography and Land Use

The expansion involves the construction of salt crystallisers on land measuring approximately 240 ha and roadways, dykes and levees on land measuring approximately 10 ha. The total land involved is therefore 250 ha and is relatively flat; however there are some rocky outcrops encountered on the northwestern side of ML 219. The project footprint is approximately 35% of the total land covered by ML 219.

As a result of the high salt content, there is no vegetation on ML 219.

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In terms of land use - the Cape Cross saltfield is in the Dorob National Park a proclaimed national park. Limited commercial activities with low impact levels on the environment are however allowed. Amongst the activities currently being pursued within the Park are: water desalination, exploration mostly for nuclear energy, guano production, solar salt mining, aggregate quarrying, lead & zinc mining, ecotourism, hospitality establishments and recreational fishing, etc.

In general, the Cape Cross saltfield is a brownfield area which has been at the receiving end of human activities for over 100 years. Harvesting of the Cape Fur Seals and guano production have been conducted there since 1895 with the first railway line of 21 km in Namibia constructed over the saltfield during that time. Salt mining has been conducted there since the early fifties.

TABLE 15: IMPACTS ON SITE TOPOGRAPHY AND LAND USE Possible Impacts :  Possible loss of habitat for saline adapted micro-life organisms  Land surface disturbances through excavations Possible Mitigation Measures The Cape Cross saltfield is a brownfield area which has been impacted by human activities for over 100 years. However, the impacts associated with topography and land use can be effectively mitigated if the proponent complies with the EMP. Nature of Impact Negative Extent of the Impacts Low – confined within boundaries of ML 219 Duration Long term Intensity Medium Probability Highly Probable Confidence Highly Significance High Further Remarks Comply with the EMP

8.1.3 Hydrology (Surface & Underground Water)

The project is located in a hyper-arid western coast area of Namibia. Permanent surface water in the area is confined to the Lagoon – the area closest to the beach and is approximately 3 km from and to the southwest of ML 219.

Potable water is required for human use and for cleaning purposes and will be sourced from Omdel Water Scheme at Henties Bay as is the case with existing salt mining operations in the area and other establishments.

The project area receives less than 50 mm of rain per year which is good for solar salt production. Fog and misty conditions are experienced over 100 days of year.

There are no known boreholes or underground water sources near the salt operation.

The spent brine from the crystallisers will be pumped into a specific pond for bitterns with a sealed floor and diluted with some seawater prior to pumping the solution to the sea for discharge. The pipe through which the bitterns is pumped will be buried and not visible to the public.

With respect to Hydrology, the project does not have any impact on the environment, but the environmental aspects related to hydrology could impact negatively on the project.

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TABLE 16: IMPACTS ON HYDROLOGY (SURFACE AND UNDERGROUND WATER) Possible Impacts :  Flooding of crystallisers by the small ephemeral Owarab River  Flooding of crystallisers due to tidal overflow Possible Mitigation Measures  Bitterns from crystallisers should be pumped into a separate common pond and mixed with some seawater prior to discharging into the sea.  Water is a scare resource and should be used sparingly  Maintain a high standard of housekeeping which includes regular inspections of surface water installations and storage facilities (tanks and containers) on the mine  Try to recycle water used for cleaning purposes for watering of plants around the administrative offices of the salt works  Crystallisers developed on the southeast section of ML 219 adjacent to the Owarab River flood plain should be raised to mitigate against intermittent flooding of the river  The pipe through which the bitterns is discharged to the sea should be buried.  Comply with the EMP Nature of Impact Neutral to Negative Extent of the Impacts Mostly localized expect the bitterns discharge pipe Duration Long term Intensity Low Probability Probable Confidence High Significance Low Further Remarks The bitterns is about 20% of the original brine solution

8.1.4 Ambient Air Quality

Gaseous emissions released by earthmoving machinery, heavy duty trucks hauling the product to the port and other equipment used in the salt operation are expected to impact negatively on the ambient air quality. All other salt operations in the area are relatively small operations using one or two machines.

Unlike the towns of Walvis Bay and Swakopmund, there are no heavy industries in the Cape Cross area and the district road D2301 is used by relatively few traffic. The high moisture content of soils and the fact that D2301 is a salt road, also help to reduce the potential of wind-blown dust.

The biggest threat to air quality all along the coastal areas of Namibia is naturally, the occasional „berg winds‟ conditions which results in elevated content of airborne particulate including dust.

TABLE 17: IMPACTS ON AMBIENT AIR QUALITY Possible Impacts :  Noxious emissions from earthmoving machines, trucks and equipment used in the salt operation  Wind-blown dust from ‘berg-wind conditions’  Possible dust released during the construction of crystallisers (handling of gypsum, sand, cement, etc.)  Health hazard  Noxious emissions from traffic using D2301 and other salt works Possible Mitigation Measures Most of the impacts above can be effectively mitigated by complying with the provisions of the EMP on Air Quality.

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Nature of Impact Negative Extent of the Impacts Localised Duration Medium to long term Intensity Low Probability Probable Confidence High Significance Low Further Remarks Comply with the EMP

8.1.5 Noise Disturbances

All salt operational activities carried out on the Cape Cross saltfield are relatively mechanized to different levels of sophistication. Machinery and equipment used are generating some noise as a result operational use, idling, revving and hooting. These are expected to impact on the ambient noise levels in the area.

Some noise is also generated from the traffic using D2301. Generally, the noisiest places around the Cape Cross saltfield are the Cape Fur Seal Colony and the lagoon where thousands of marine birds occur. On a quiet day, noise from the Seal Colony can be heard around the premises of CCS.

TABLE 18: NOISE RELATED IMPACTS Possible Impacts : Hearing irritations, Hearing impairments, Health hazard and Amenity nuisance Possible Mitigation Measures By complying with the EMP impacts related to noise can be handled effectively

Nature of Impact Negative Extent of the Impacts Localised Duration Long term Intensity Low Probability Probable Confidence High Significance Low Further Remarks Comply with the EMP

8.1.6 Dust Pollution

Due to the high moisture content of the soils, there is no dust in the area. The D2301 road linking ML 219 to Henties Bay is a salt road and therefore no dust is generated by the traffic such a road. All internal routes are also salt routes and hence no dust is generated. Generally, the only time when some dust is experienced in the area is during the „berg-winds‟ episodes when air borne dust blows over the area.

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TABLE 19: DUST RELATED IMPACTS Possible Impacts :  Eye and noise irritations  Health hazard  Harmful airborne dust particles Possible Mitigation Measures  Provide suitable PPE to employees exposed to dust (sand blasting, etc)  Enforce wearing of PPEs to employees working in dusty areas  When using materials which generate dust, ensure dust levels are kept within allowed standards Nature of Impact Neutral to negative Extent of the Impacts Localised and confined to ML 219 Duration Long term Intensity Low Probability Probable Confidence High Significance Low Further Remarks Comply with the EMP

8.1.7 Waste Generation and Management

Various types of waste are expected to be generated during the Construction and Operational Phases of the salt mining operation. It is important to note that waste is best managed according to the waste management hierarchy of prevention, reduction, re-use, recycling and disposal.

CCS is expected to develop an in-house waste management policy which details how the company intends to deal with all types of waste generated by its salt operation. The waste management policy has to include the management of both solid and liquid wastes generated by the salt operation.

Suitable waste skips have to be procured and provided at all sectional areas of the operation, i.e. workshop, wash plant, office, etc. in which different types of wastes are stored.

Solid and household waste should be disposed of at the waste dump site of the Henties Bay Municipality while wastes of hazardous nature i.e. used oil, used oil filters, old batteries, redundant tyres, etc. should be stored in closed containers and disposed of at the Walvis Bay landfill sites.

Ensure that litter blown from the project site may not accumulate in the surrounding areas resulting in visual nuisance

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TABLE 20: IMPACT ON WASTE GENERATION AND MANAGEMENT Possible Impacts :  Visual nuisance  Odour nuisance  Health hazard  Amenity nuisance Possible Mitigation Measures  Develop an in-house waste handling policy and enforce compliance thereof  Separate wastes generated and store in separate containers  Remove recyclable waste materials & offer to recycling companies  Burn papers and small quantities of plastic wastes at a designed site within the confines of ML 219 or accessory work area  Determine annual quantities of liquid wastes, store in sealed containers and transport once or twice annually to a suitable waste landfill at Walvis Bay  Provide training to employees on waste identification and waste handling.  Maintain a high standard of housekeeping  Comply with the EMP. Nature of Impact Negative Extent of the Impacts Localised Duration Long term, project lifelong Intensity Low Probability Probable Confidence High Significance Low Further Remarks Comply with the EMP

8.1.8 Visual Intrusion

The salt works is visible to the traffic using D2301, but not to the guests at the Seal Colony or the adjacent Cape Cross Lodge.

In general, the project is located in a relatively topographically flat area with a few outcrops towards the northwest. The line of sight distances are quite far except when fog and misty limit visibility.

Man-made structures within the project area are mostly encountered in the form of salt wash plants, machineries working in various parts of the saltfield, buildings, salt stockpiles, etc.

TABLE 21: IMPACT ON VISUAL ASPECTS Possible Impacts :  Salt mine infrastructures (buildings, product stockpiles, etc.)  Light pollution (at night)  Waste pollution (papers & plastics)  Airborne dust particles Possible Mitigation Measures  Locate infrastructures away from sensitive and elevated areas  Ensure that security light at D2301 intersection does not offend road users.  Pick up wind-blown papers and plastics around the salt premises to avoid visual nuisance  Buildings on the operational site should be well maintained and regularly painted to avoid visual decay  Maintain a high standard of housekeeping

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Nature of Impact Negative Extent of the Impacts Localised Duration Medium to long term Intensity Low Probability Probable Confidence High Significance Low Further Remarks Comply with the EMP

8.1.9 Archaeological & Cultural Heritage

The Cape Cross area is a brownfield and a number of activities have been conducted there over the last 100 years. Amongst the activities conducted include processing of whales, harvesting of seals, production of guano from man- made structures, development of the first railway line of 21 km in the country and shipping operations from the adjacent Cape Cross Bay.

The area is therefore endowed with items of archaeological and cultural heritage interests.

TABLE 22: IMPACT ON ARCHAEOLOGICAL AND CULTURAL HERIATGE ASPECTS Possible Impacts :  ‘Chance find’  Unearthing of human bones or graves of dead people during excavation  Damage to an archaeological items  Unearthing of bones, items of artefacts, etc.  Buried guns, weapons, coins, ornaments, railway steel, etc. Possible Mitigation Measures  Provide training to employees on items of archaeological and cultural heritage importance for them to appreciate such items when encountered during the development of crystallisers  Officials of the National Heritage Council are to be contacted on all items/objects suspected to be of Cultural Heritage  Both the National Heritage Council in Windhoek and the local nearest police station are to notified when items suspected of being ‘human remains’ are uncovered during the development of salt ponds  Work in the vicinity where items of historical backgrounds are uncovered, is to be stopped immediately and the site secured by strapping white masking tapes around it while officials from NHC are being consulted.  No items suspected to be of cultural heritage may be removed from site until permission is granted by officials from the NHC on what to do  Follow the steps recommended in the EMP. Nature of Impact Negative Extent of the Impacts Localised Duration Short term – during the construction period only Intensity Low Probability Probable Confidence High Significance Low Further Remarks

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8.1.10 Fuel Storage, Refuelling and Management

Large quantities of fuel (diesel) will be procured for the operation and stored in a surface mounted tank to be erected on the salt mine premises. The erection of the fuel storage and operation thereof must be carried out in terms of the provisions of the Petroleum Products and Energy Acts (Act No. 13 of 1990).

Oil and lubricants are procured in reasonable quantities basically on a need-to- need basis and stored in sealed containers in the workshop.

TABLE 23: IMPACT ON FUEL STORAGE, HANDLING AND MANAGEMENT Possible Impacts :  Leakage could lead to ground contamination  Fire hazard  Toxic emissions  Health hazard  Air pollution Possible Mitigation Measures  Fuel may only be stored in a designated area as provided for by the Petroleum Products Act  The area where fuel is stored should be fenced in, kept under lock and access strictly controlled  Refueling of heavy earthmoving machinery working on the saltfield (such as excavators, bulldozers, harvester, etc.) should be done using a double skinned diesel bowser  Make use of drip trays when refueling plants in the saltfield  No open fire may be used in close proximity of fuel storage devices  No explosive devices including welding gas may be stored in close proximity of fuel storage devices  Clear warning signs should be displayed of ‘No Smoking’, ‘Danger’ ‘Flammable Product’ should be displayed  When a fuel leakage into the soil surface has been detected, follow the recommendations in the EMP  Only well trained employees may handle fuel related activities Nature of Impact Negative Extent of the Impacts Localised Duration Long term Intensity Low Probability Probable Confidence High Significance Low, if the EMP is followed Further Remarks Comply with the EMP and Petroleum Products and Energy Act

8.2 The Natural (Biological) Environment

8.2.1 Faunal Aspects

ML 219 is located on the saline pan of the Cape Cross saltfield, which, by its physical nature does not support the majority of life forms. Outside of and to the southeast of ML 219 is a Lagoon which has been given the status of an „Important Bird Area‟. The Lagoon supports a high number of marine bird species and guano platforms erected around this wetland over one hundred (100) years ago, are still intact and providing breeding and roosting shelter to the birds.

The Lagoon is reported to have the highest number of Cape Cormorants. Bird movements around this habitat and from this habitat to the inland are therefore common.

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A Seal Colony to the northwest of ML 219 is home to over 200 000 Cape Fur Seals. During the breeding season, bulls will normally engage in fights resulting in a high number of mortalities amongst the seal puppies which attract seagulls and brown jackals to the colony.

More often jackals are seen crisscrossing the salt pan. Seal bulls, often wounded during fighting are also occasionally encountered wondering around on the salt pan several kilometers away from the Colony.

Large antelopes (mostly Oryx) are occasionally spotted inland on the delta section of the Owarab River.

TABLE 24: IMPACT ON FAUNAL RELATED ASPECTS Possible Impacts :  Loss of established routes to the sea and seal colony  Loss of habitat  Road kills  Illegal fishing by employees  Illegal killing of seals  Illegal hunting of wildlife (Oryx) Possible Mitigation Measures  An environmental induction specifically dealing with faunal species found in the vicinity of the salt works should be presented to all employees. Occasionally astray seal bulls have been encountered on salt works – no killing of such animals should be allowed and any astray seal bull seen should be reported to the Seal Colony personnel whose contact number should be displayed on the notice board at the salt works of CCS  All employees operating trucks and earthmoving vehicles should undergo an environmental induction training course stressing the importance to comply with speed limits, to respect all forms of wildlife (jackals, reptiles, birds, etc.) and where possible to prevent accidental road kills of fauna  No hunting of astray seals or wildlife is allowed.  No illegal fishing Nature of Impact Negative Extent of the Impacts Site specific Duration Possibly during construction phase Intensity Low Probability Probable Confidence High Significance Low Further Remarks Comply with the EMP

8.2.2 Flora (Plant Species)

All development pertaining to ML 219 will be carried out on the saline pan which is devoid of any vegetation or any form of plant life. Vegetation is however observed in the vicinity of ML 219 especially in the delta part of the Owarab River which flows towards the Cape Cross Salt Pan.

The salt operation will have no direct impact on the vegetation outside of ML 219.

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TABLE 25: IMPACT ON FLORAL RELATED ASPECTS Possible Impacts :  Possibly loss of habitat for saline adapted creatures  Possible displacement of flora Possible Mitigation Measures  Keep the footprint of disturbed areas to the minimum  Limit the construction of crystallisers on clearly demarcated areas  Provide training to all employees on matters related to floral species Nature of Impact Neutral to negative Extent of the Impacts Site specific Duration Short term - during the construction phase only Intensity Low Probability Probable Confidence High Significance Low Further Remarks Comply with the EMP

8.3 The Human Environment (Social-economic Environment)

With regard to the human social-economic environmental aspects, the development is expected to deliver positive impacts in at least four areas:

 Creation of employment  Boast to the local economy  Labour and working conditions  Health and safety aspects

8.3.1 Creation of Employment

Unemployment is a serious problem in Namibia particularly amongst the youth and it is more rampant in the rural areas of the country where economic opportunities are rather limited. Lack of employment opportunities in the rural area has resulted in the migration of people from the rural to urban areas in the hope of finding jobs and better living conditions.

The salt works promoted by CCS will create and provide employment opportunities to over sixty (60) people who will reside in the town of Henties Bay. Taking a multiplier factor of one employee supporting five other individuals, the benefits accruing from implementation of CCS salt operation will have a positive impact on the lives of at least 300 people.

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TABLE 26: IMPACT ON EMPLOYMENT CREATION Possible Impacts :  Earning of an income /salary  Support to family/relatives  Improved standard of living  Living a dignified life Possible Mitigation Measures  Adopt a ‘local first policy’ when hiring workers for non-skilled and semi-skilled positions for the salt operation.  Hire employees from the local communities without discrimination on the basis of gender, race, background, religious or political affiliations  People from marginalized communities should also be considered and offered employment  People with disabilities should likewise be considered for suitable employment opportunities.  Guard employees against social ills such as drug abuse, excessive alcohol consumption and indulging in unsafe sex practices which lead to HIV/AIDS and other sexual transmitted diseases.  Provide and offer on-the-job training opportunities for employees to improve their skills levels Nature of Impact Positive Extent of the Impacts High – impact at regional and national levels Duration Long term Intensity Probability Probable Confidence High Significance High and it is positive Further Remarks Comply with the EMP

8.3.2 Boast to the Local Economy

The development as promoted by CCS is expected to cost millions of Namibia Dollars in capital expenditure to procure items needed both for the Construction and Operational Phases of the project. Payments have to be made for the earthmoving machinery, salt wash plant, road trucks which will transport the salt from the mine to port equipment and to the contractor who will develop the 250 ha crystallisers and accessory works. Such funds will be spent to local suppliers of goods and services hence boasting the local economy.

On the other hand, all employees who will be hired for the CCS development will reside in the town of Henties Bay and will be spending their disposal incomes in the town through payment of rates and services (water, electricity, refuse removal, etc. to the local municipality), school fees, medical costs and procurement of groceries and other basic human needs from the local service providers.

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TABLE 27: IMPACT ON THE LOCAL ECONOMY Possible Impacts :  Creation of employment  Increased local spending  Injection of income in the local community of Henties Bay & Swakopmund  Product exported hence earning of foreign currency  Community support through corporate social responsibility Possible Mitigation Measures  Procure and source goods and services for the salt operation from local businesses (spare parts, water, fuel, oil, lubricants, PPEs, stationeries, etc.)  Hire and employee people from the local communities  Pay royalties, export levies, VAT, PAYE and income taxes due to the State  Comply with all applicable rules and regulations  Join local organizations and lobby groupings such as the Chamber of Mines and Namibia Chamber of Commerce and Industries (NCCI)  Offer and provide training to employees to improve their skills level and knowledge base Nature of Impact Positive Extent of the Impacts High – regional and national Duration Long term Intensity Probability Probable Confidence High Significance High and it is positive Further Remarks Comply with the EMP

8.3.3 Labour and Working Conditions

Employees should be provided with training opportunities to improve and enhance their skills and knowledge. Given Namibia‟s past poor labour relationship history, it is important to allow employees to join a labour union of their choice and to have the right to be represented by a representative of their choice at any disciplinary hearings.

Respect and accommodate employees with different cultures and traditions. When CCS operated the salt mines, the employees were staying on the mine in single sex accommodation facilities. Water had to be transported to the mine from Henties Bay which is 42 km away.

It is proposed for all employees of CCS to reside in Henties Bay with free transport to and from work provided by the company. Henties Bay has suitable accommodation including affordable housing built by the Henties Bay Municipality. There are also schools, health facilities, both public and private and shops

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TABLE 28: IMPACT ON LABOUR AND WORKING CONDITIONS Possible Impacts :  Poor labour relations  Industrial actions (strikes)  Bad corporate image  High labour turnover  Undefined roles & responsibilities  Unsafe working practices  Poor standard of hygiene & cleanliness Possible Mitigation Measures  Develop working standards and conditions for the salt works in line with industry practices  Train all employees on working standards and conditions for the salt works  Enforce compliance of the working standards and conditions once training has been successfully provided  Allow employees to exercise their rights to join and belong to a trade union of their choice  Allow each employee charged with a misconduct the right to be represented during a disciplinary hearing  Enforce traffic road safety conditions on and off the salt operation  All employees to be given an induction training course on all environmental aspects associated with the salt operation especially the EMP  Where appropriate the training on the environment should be conducted in the language understood by the employees alternatively translation should be provided Nature of Impact Positive Extent of the Impacts Regional and national Duration Long term Intensity Probability Probable Confidence High Significance High and it is positive Further Remarks

8.3.4 Health and Safety Impacts

The salt operation should strive to create a good and safe working environment which is free of accidents, free of health hazards and associated impediments.

Safety is of paramount importance in the execution of the salt operation and applicable industry safety standards have therefore to be implemented and complied with by CCS Management as neglect to do so could lead to incidents and accidents which are undesirable and often associated with costly consequences.

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TABLE 29: IMPACT ON HEALTH AND SAFETY ASPECTS Possible Impacts :  Unwanted Incidents and possibly accidents  Injuries  Loss of life  Loss of assets/properties  Unhygienic conditions Possible Mitigation Measures  Develop a Health and Safety Plan for the salt operation and train employees on such a safety  Develop an Emergency Response Plan for the salt operation  Develop an Accident Procedure Framework for the salt operation and train employees on such plans  Ensure employees are provided with suitable PPE and wearing thereof is enforced  Limit speed to 20 km/hour on internal routes  Enforce good housekeeping and ensure proper handling of all waste products.  Ensure adherence to the relevant health and safety legislation  Comply with the EMP Nature of Impact Neutral Extent of the Impacts Medium to High – Salt transport to port Duration Long term Intensity High to Low Probability Probable Confidence High Significance Low Further Remarks Apply industry standards

SECTION 9

9.0 Evaluations & Conclusions

9.1 Environmental Economic Criteria

A qualitative assessment is considered in terms of the criteria used in the field of Environmental Economics. These criteria are explained by Stauth (1983), namely:

 the efficiency criterion,  the equity Criterion, and  the intergenerational equity criterion

9.1.1 The Efficiency Criterion

A project is considered to be efficient if it brings about a net benefit to society. If some people are made better off without anyone else being made worse off, then a project is considered efficient in terms of the environmental economics.

The salt operation to be revived by CCS will bring significant benefits to the country in terms of employment, support to secondary industries (earthmoving machinery, plant & equipment suppliers and commercial opportunities to various sectors of the local economy.

Payment to Government in the form of royalties, income taxes, VAT, export levies and PAYE will benefit the country as whole while export of salt will further earn the much needed foreign exchange for Namibia. ML 219 - Baseline Scoping Assessment Page 57

The efficiency of this project is further enhanced through the use of renewable resource, solar energy to evaporate the water with little use of fossil generated energy. . 9.1.2 Equity Criterion

The equity criterion deals with the distribution of costs and benefits in the affected society. If a project brings about a situation in which the distribution of social wellbeing is improved then the project is considered to have met the equity criteria.

This project will benefit the local Namibia people through the creation of employment of over sixty people without disadvantaging any one. ML 219 is located on a saline pan of the Cape Cross saltfield and the implementation of the project will not result in people being displaced from their land or to any person to be subjected to adverse health conditions.

The salt operation will further support local industries and create commercial opportunities through the procurement of goods and services.

9.1.3 The Intergenerational Equity (or Sustainability) Criterion

This criterion considers the economic impacts on future generations – i.e. it extends the considerations of equity to future generations. Thus a project should be able to make the present generation better off without making future generations worse off. It should be able to provide benefits to future generations without degrading the resource base that the society depends on for its wellbeing.

This criteria is met by this project in that salt is a renewable resource which will be mined for an indefinite period as long as there is demand for the product, hence benefiting future generations. By comparisons, uranium is a finite mineral. Currently uranium is being mined from three mines in Namibia and there are two mines on care and maintenance. Three other uranium projects are at funding negotiation stages awaiting the recovery of uranium prices.

10.0 CONCLUSIONS AND RECOMMENDATION

Overall the economic benefits that will accrue from the implementation of this project by far outweigh the limited negative impacts. The salt operation is expected to perform positively in relation to the efficiency, equity and sustainability criteria if it complies with the provisions as recommended in the EMP document.

It is recommended that an Environmental Clearance Certificate (ECC) be granted for Mining Licence 219 to allow the implementation of the project.

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REFERENCES:

 Linning K, Economic Geology Series. Open File Report EG 070, Geological Report on the Cape Cross Salt Pan, 1965, Geological Survey of Namibia, Ministry of Mines and Energy

 Adshead, Samuel AM : Salt and Civilisation, MacMillan, 1992

 Lac Business Group Inc. Salt Technology & Engineering, RR 3-79 Marple Road, Dalton http://www.lacsolarsalt.com/Brochure-08.pdf   Namibia’s 5th National Development Plan (NDP 5) 2017/18 - 2021/22

 NDP 5 - GRN Portal – Erongo Regional Council

 National Planning Commission (NPC) 2011: Population and Housing Census Erongo Region, Windhoek, Government Press

 Chamber of Mines of Namibia, Annual Reports for 2016, 2017 & 2018

 Vladimir Sedivy, Salt Partners Ltd, Zurich, Switzerland, EuSalt Salzburg, 2015 PowerPoint Presentation

 Vladimir Sedivy, Salt Partners Ltd, Upgradeability of Solar, Rock and Vacuum Evaporated Salt, 10th World Salt Symposium, 2018, Park City, Utah, USA

 Vladimir Sedivy, Salt Partners Ltd: Salt Business in Africa, Trends and Opportunities, Salt Symposium, 2018, Park City, Utah, USA

 BERRY HH 1975. History of the Guano Platform on Bird Rock, Walvis Bay, South West Africa. Bokmakierie 27: 60-64.

 CRAWFORD RJM, COOPER J, SHELTON PA 1981. The Bredding Population of White Pelicans Pelecanus Onocrotalus at Bird Rock Platform in Walvis Bay, 1947-1978. Fisheries Bulletin of South Africa

 Boorman M (2011) Unpublished data of ephemeral wetland counts in 2011.

 Coastal Environment Trust of Namibia (CETN) (2012) Unpublished data of Walvis Bay counts in 2011.

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 Simmons R 1992. The status of coastal wetlands in Namibia. Matiza T, Chabwela HN (eds) Wetlands conservation conference for southern Africa. Gland: IUCN: 125-132.

 Underhill LG, Whitelaw DA 1977. An ornithological expedition to the Namib coast. Cape Town: Western Cape Wader Study Group: 1-106.

 Williams AJ 1991. Numbers and conservation importance of coastal birds at the Cape Cross lagoons, Namibia. Madoqua

 Stauth, R. (1983) Environmental Economics in Fuggle, R.F. and Rabie M.A. (1983)

 Mendelsohn J, Jarvis A, Roberts C and Robertson T (2002) Atlas of Namibia. Published for the Ministry of Environment & Tourism by David Philip.

 Kinahan, J. (2012) Archaeological Guidelines for Exploration & Mining in the Namib Desert.  AREVA Resources. Retrieved from www.areva.com Bitter A (2010) Ground Water Specialist Report to the EIA: Improved water supply to the Langer Heinrich Mine

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