For the Proposed Amendment to the Husab Mine Activities and Infrastructure - 12 Mw Solar Pv Power Plant

SCOPING REPORT (INCLUDING IMPACT ASSESSMENT) FOR THE PROPOSED AMENDMENT TO THE HUSAB MINE ACTIVITIES AND INFRASTRUCTURE - 12 MW SOLAR PV POWER PLANT

Husab Mine, Namibia

Prepared for: Swakop Uranium (Pty) Ltd

SLR Project No: 733.03107.00001 Revision No: 1 Month/Year: July 2019 Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

DOCUMENT INFORMATION

Title Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine activities and infrastructure - 12 MW Solar PV Power Plant Project Manager Marvin Sanzila and Werner Petrick Project Manager e-mail [email protected] Author Marvin Sanzila and Werner Petrick Reviewer Stuart Heather-Clark Keywords Swakop Uranium, Husab Mine, Amendment, 12 MW Solar PV Plant Status Draft for I&AP review SLR Project No 733.03107.00001

DOCUMENT REVISION RECORD

Rev No. Issue Date Description Issued By

1 May 2019 First draft issued for internal (SLR) comment MS/WP

2 May 2019 Draft for client review WP

3 June 2019 Draft for I&AP review MS

4 July 2019 Final to MET for review and decision WP & MS

BASIS OF REPORT

This document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescales and resources devoted to it by agreement with Swakop Uranium (Pty) Ltd part or all of the services it has been appointed by the Client to carry out. It is subject to the terms and conditions of that appointment. SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or collateral warranty. Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid. SLR disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the work.

The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this report remain vested in SLR unless the terms of appointment state otherwise. This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which may be unclear to it. Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents referenced explicitly herein and should then only be used within the context of the appointment.

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

EXECUTIVE SUMMARY

1. General Introduction and Project Motivation

Swakop Uranium holds the mining licence (ML) 171 and Environmental Clearance Certificates (ECCs) for the Husab Uranium Mine (and associated activities / infrastructure) and for its associated linear infrastructure. The mine and processing plant is situated in the northern most part of the Namib Naukluft National Park, about 12 km south-east of Arandis. Mining started in March 2014 and the commissioning of the processing plant commenced in December 2016, with the first drum of U3O8 produced.

Power is currently supplied to the Husab Mine via a 132 kV NamPower transmission line. This overhead powerline feeds into the Husab Mine substation, located within the processing plant complex. Swakop Uranium also installed two generators with 2 MVA capacity each and four smaller generators with 500 kVa capacity each, for back-up power to the Husab Mine, processing plant and associated activities.

Swakop Uranium identified the need for additional power supply infrastructure to the Husab Mine to augment the current power demand. This would provide cost savings to Swakop Uranium, compared to the current NamPower tariff. In addition to the cost saving, the overall electricity demand, as was previously determined and assessed (as part of the original, approved, EIA processes) has increased.

Swakop Uranium has therefore partnered with CGN Energy International Holdings CO. Limited (CGNEI), a sister Company of Swakop Uranium, to construct and operate a Solar Photovoltaic (PV) Power Plant with a capacity of 12 megawatt (MW) at the Husab Mine to supply power to the processing plant, mining area and associated activities.

Prior to the commencement of the proposed project, an ECC (amendment) is required from the Ministry of Environment and Tourism (MET): Directorate Environmental Affairs (DEA) in terms of the Environmental Management Act, 2007 (No. 7 of 2007) and the associated EIA Regulations.

SLR Environmental Consulting (Namibia) (Pty) Ltd (SLR) has been appointed by Swakop Uranium and CGNEI as the independent Environmental Assessment Practitioner to undertake the EIA process.

2. Project Description

The proposed PV power plant site will have a development footprint of approximately 16.4 hectares (ha) and will be located adjacent to the processing plant on an area previously used for the temporary construction accommodation, used during the construction phase of the Husab Project.

The PV power plant will be connected via a 33 kV powerline (transmission) line to the Husab Mine’s substation, which is located approximately 1.2 km from the proposed site, within the processing plant complex (refer to Figure 1).

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

Figure 1: Proposed PV power plant and associated INFRASTRUCTURE location ADJACENT to the PROCESSING Plant

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

CGNEI propose to use bifacial monocrystalline silicon technology for the PV power plant. It is anticipated that each module would have dimensions in the order of 2,000 mm (length) x 992 mm (width) (i.e. ±1.98 m2), with a 380 W (peak) high efficiency. The maximum height of the panels would be ± 2.8 m.

The PV modules would be arranged to face the north, at an angle of 23° to capture solar radiation through the monocrystalline silicon PV cells and emit the direct current (DC) into inverters that will convert the current into alternating current (AC). The AC is then fed into a transformer and further into the Husab Mine’s substation. 570 solar arrays are proposed, each consisting of 2 strings of 26 modules each, resulting in a total of 29,640 modules.

The proposed site is currently fenced off and consists of the following infrastructure:

 Temporary housing, ablution facilities and related infrastructure, i.e. underground domestic water and sewage pipelines;  Overhead power lines and a cable tray that feeds to Husab Mine substation;

Each photovoltaic sub-array unit will access to a 2.5 MW box-transformer with a voltage ratio of 33/0.8 kV. All transformers access to a collecting line. It is proposed that the 33 kV line coming from the output of the transformer station (i.e. PV power plant switch station) will be connected to the Husab Mine electricity network through a powerline running over a distance of approximately 1.2 km. With reference to Figure 1, the yellow line represents a section of the powerline that will be buried, while the blue line represents a section of the powerline that will be placed on the existing cable tray to the Husab Mine substation. No new main electrical substation and transformers would therefore be required. Various operations and maintenance buildings would be constructed to support the PV power plant, these will include:

 Main building (± 200 m2) formalized by pre-fabricate container, which would be shared by control and security staff;  70 inverter structures in between arrays (each 1 500 m2);  6 box transformer structures (each ± 15 m2);  1 switching station (± 24 m2);  2 equipment and control rooms (± 28 m2); and  1 energy storage equipment (±18 m2).

A pack of phosphate based lithium-iron batteries will be installed in prefabricated containers.

The water during both construction and operational phases of the proposed projects will be supplied from the Husab Mine water supply, sourced from a location in the processing plant which is ± 500 meters from the PV power plant site.

The water requirements are as follows:

 Water requirements during the construction phase would be approximate 500 m3. The main water requirement during construction would be for concrete mixing.  The water requirements during the operation and maintenance period mainly includes domestic water and PV module cleaning water. The yearly water consumption for module cleaning is approximately 1,000 m3.

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

During construction approximately 100 people (peak) would work on site over a period of ± 8 months. It is envisaged that approximately 4 people would be permanently employed during the operational phase of the project.

3. Identification of environmental aspects and potential impacts

The potential impacts were identified during the scoping process, in consultation with authorities, I&APs and the project team. For context, the description of the potential impact should be read with the corresponding descriptions of the current environment in Section 6 of this report. Furthermore, it must be noted that the PV plant and powerline would be constructed adjacent to the Husab Mine Processing Plant infrastructure, within an already disturbed area and potential impacts are considered cumulatively (taking existing activities into consideration).

The following issues were identified as requiring assessment.

 Physical impacts and general disturbance to avifauna as a result of the following: o Collisions of birds with photovoltaic (PV) panels and associated infrastructure o Attraction of novel species to the area by the artificial provision of otherwise scarce resources  Visual impacts due to the new PV power plant infrastructure.  Groundwater and surface water quality impacts and pollution of soil due to: o Possible hydrocarbon spillages from earth moving equipment and spillage of paint, concrete and other hazardous substances during the construction phase.  Air quality impacts (dust).  Socio-economic impacts, including: o Positive impacts relating to employment and skills development o Negative impacts including inward migration and social/security issues.

4. Environmental impact assessment findings

This section describes and assesses the significance of the potential impacts related to the proposed project, taking the adjacent Husab Mine processing plant and the overall infrastructure and associated activities into consideration. In this regard, the assessments have been conducted by referring extensively to previous EIAs conducted for the Husab Mine and associated infrastructure and further specialist input undertaken specific for the proposed PV power project. The assessments also take cognisance of the fact that the proposed activities and infrastructure will be located within the same Husab Mine project footprint area (adjacent to the processing plant).

The management and mitigation measures to address the identified impacts are included in the EMP in Section 9 of the report.

Issue: Collisions of birds with photovoltaic (PV) panels and associated infrastructure

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

power plants, with collision trauma with PV panels, perhaps associated with polarised light pollution and/or with waterbirds mistaking large arrays of PV panels as wetlands – the so-called "lake effect", emerging as a significant impact factor at one site where mortality monitoring is on-going.

Indirect impacts resulting from such collisions, and/or entrapment in surrounding fences, could include predation if the bird is unable to fly or take off.

Artificial lighting may impact on night-flying or migrant birds, especially in terms of causing disorientation and/or collisions on structures. Flamingos usually fly at night, and fall into this group. New forms of lighting in areas that were previously unlit may exacerbate the problem of collisions, and also change movement patterns and corridors. It must however be noted that the proposed PV project site is adjacent to the processing plant, which have lighting installed.

It has been found that nocturnally migrating birds (small passerines, in this case) may become attracted to an isolated pool of diffused light (e.g. at an illuminated waterhole) – but only when there is no moon at all, plus fog/mist at ground level; this does not seem to happen when there is moonlight (of any phase). Although speculative, this would appear to indicate that when there is no moon, plus low fog, the birds could also become attracted to an illuminated, reflective array of solar panels; perhaps becoming disorientated because they are used to following visual clues such as the moon.

The significance of this potential impact is medium in the unmitigated scenario and low for the mitigated scenario.

Issue: Attraction of novel species to the area by the artificial provision of otherwise scarce resources

Other possible impacts of solar PV developments include the attraction of novel species to an area by the artificial provision of otherwise scarce resources – for example perches, nest sites and shade. Potentially positive impacts of solar energy projects on birds include the use of the various raised structural components of these developments as artificial nesting and roosting sites by a suite of otherwise tree-nesting species.

The ultimate impact of this phenomenon – in terms of the effect of inflated numbers of some species on the overall species composition in the vicinity of the development area, and the possible need for management or removal of these nests by the developer – remains unclear at this stage.

In terms of the present study, the provision of large areas of shade in this arid habitat could prove to be attractive to species such as the near-endemic Rüppell's Korhaan. Increased water run-off and resultant vegetation flush could also attract Gray's Lark, another near-endemic. This impact is potentially positive, but could also have negative indirect impacts, e.g. entrapment in fences; predation.

The significance of this potential impact is low to medium (potentially positive) and no mitigation is required unless indicated by monitoring.

Issue: Visual impacts due to the new PV power plant infrastructure

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

sense of place, aesthetic value, sensitivity of the visual resource and sensitive views. In this regard, the area in which Husab is situated is considered to have a significant visual landscape.

When considering the potential change to the visual landscape the key issues are: visual exposure, visual intrusion, and sensitivity of receptors. Each of these issues are discussed below.

Visual exposure is the extent to which mine infrastructure and activities will appear in the various views. It follows that the closer the infrastructure and activities, the greater the visual exposure. Most tourist related views will be from more than 7 km away from the proposed project infrastructure. Visual intrusion is the extent to which the infrastructure and activities will contrast with the visual landscape and can/cannot be absorbed by the landscape. The proposed PV project plant site is located on a previously developed (i.e. contractor’s camp) site and is adjacent to the processing plant, the visual aspects of which were assessed in the original (approved) EIAs.

‘Replacing’ the existing infrastructure (i.e. housing, etc.) on this site with the proposed PV power plant, will have very little effect on the current visual exposure and the intrusion. Also, due to the fact that the panels will face to the north, any possible glare will be away from the Welwitschia Drive and the big tourist Welwitschia. Sensitivity of receptors relates to the way in which people will view the visual intrusion. In this regard, it is anticipated that tourist receptors will be sensitive to the visual intrusion of the overall Husab Mine itself, which is significantly bigger and more visually intrusive than the solar PV plant. Taking the comments received from stakeholders into account, it is unlikely that tourists will be more sensitive to the visual intrusion as a result of the proposed solar PV plant.

Therefore, the proposed PV power project will not significantly change the severity of the cumulative impact of the current infrastructure and activities at the Husab Mine. The significance of the visual impacts associated with the PV power plant (alone) is therefore low in both the unmitigated and mitigated scenarios.

Issue: Possible hydrocarbon spillages from earth moving equipment and spillage of paint, concrete and other hazardous substances during the construction phase

The project area is flat with no significant natural drainage channels being present on the site. The site is located near a catchment divide, within a relatively small catchment area, when compared to the much bigger ‘Husab Catchment’. Minor drainage lines have already been impacted by the process plant and associated infrastructure, within this catchment area. There is however a relatively small drainage line located south-west of the site, flowing in a south-westerly direction, towards the Khan River. Storm water flowing from the north of the site is diverted around the site. Therefore, only storm water falling on the site will therefore flow into the existing storm water drainage channel, south of the site. In the unmitigated scenario, flood water may collect and mobilize contaminants (hydrocarbons, and other contaminants) from numerous sources on site and transport it downstream, towards the above mentioned drainage line. However, with reference to the above, rain water (with possible contaminants), will naturally flow along the ground surface, into the existing storm water drainage system/ channel, which Swakop Uranium has previously blocked. This should prevent potentially contaminated surface water from being released into the environment. Also, as a result of the magnitude of the project activities during the construction process, the likelihood of significant spillage is relatively small. In the unmitigated scenario, small volumes of hydrocarbon substances, in particular fuels and oil, waste water and sludge, sewerage, paint, concrete sludge, etc. could seep into groundwater. However, with reference to the

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

previous EIAs, the pollution plume is mostly pulled into the open pits there will be no off site pollution impact on any groundwater resources which means that no third parties will be exposed to the pollution. With mitigation, this could be further limited through proper engineering design and controls. Topsoil from the site was previously stripped - prior the implementation of the contractors’ camp.

In both the unmitigated and mitigated scenarios, the significance of this potential impact is low.

Issue: Air quality impacts (dust)

The site has already been cleared and only limited landscaping within the footprint of the site will be required, resulting in limited dust generation.

It is also not anticipated that the various other construction activities would result in higher off-site impacts

(including health impacts associated with the finer, i.e. PM10, dust particles) than the Husab Mine operational phase activities. Dust fallout from the construction phase of the PV power plant is expected to be limited to an area relative close to the site.

The gaseous emissions, in comparison to the particulates, are small with low impact significance.

It must also be taken into consideration that the activities will be conducted adjacent to the existing Husab Mine processing plant and near the mining activities. The current (approved) mining activities generate dust and monitoring and mitigation measures are already existent.

The significance of this potential impact is low in both the unmitigated and mitigated scenarios. By implementing the actions and management and mitigation measures presented in the EMP (Section 9 of the Scoping Report), this issue can be further minimized.

Issue: Positive impacts relating to employment and skills development

The proposed PV power project will contribute to the economy in the following positive ways: • Direct benefits: Direct number of persons employed and their wages and salaries, taxes paid and profits earned. Skills developed through training.

• Indirect benefits: The provision of products and services to the project, as well more employment opportunities will be created due to the multiplier effects of the (cumulatively) large industry in the region.

The permanent job opportunities are relatively small, when compared to the number of permanent employees at the existing Husab Mine operations.

The significance of this potential impact is medium positive.

Issue: Negative impacts including inward migration and social/security issues

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

children), unprotected sex and the spread of HIV/AIDS. The influx of job seekers may increase over-crowding which increases the spread of TB.

Inward migration has already started at the central coastal towns of Namibia.

The relatively small workforce requirements and short construction period of the proposed project is, however, unlikely to stimulate a considerable influx of more job-seekers to the region.

The presence of construction workers on the site increases the potential risk of poaching and security issues, taking cognisance of the fact that the mine is located within the NNNP. Swakop Uranium, however, has strict requirements for any new recruits, construction workers and visitors to the mine relating to the protection of biodiversity, etc.

In the unmitigated scenario, the significance is medium. In the mitigated scenario, the significance of this potential impact is reduced to low. 5. Environmental Impact statement and conclusion

The assessment found that the proposed project present the potential for minimal additional risks and related impacts in the mitigated scenario.

Therefore, the overall contribution from the proposed project to the potential cumulative impacts associated with the existing Husab Mine operations is such that the original assessment findings remain largely unchanged albeit that management and mitigation measures are required and have been detailed in the EMP (Section 9 of this report).

SLR believes that a thorough assessment of the proposed PV power plant and associated activities have been achieved and that an environmental clearance certificate could be issued.

6. Way Forward

The way forward is as follows:

 MET review the Scoping Report and EMP and provide record of decision.

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

CONTENTS

EXECUTIVE SUMMARY ...... 2

1. INTRODUCTION ...... 1

PURPOSE OF THE REPORT ...... 1

INTRODUCTION TO THE PROPOSED PROJECT ...... 1

MOTIVATION (NEED AND DESIRABILITY) ...... 5

THE NEED FOR RENEWABLE ENERGY IN NAMIBIA ...... 5

FIT WITH POLICY AND PLANNING ...... 6

NATIONAL EMISSION TARGETS ...... 6

EIA PROCESS ...... 7

INTRODUCTION TO THE PROPOSED EIA (AMENDMENT) PROCESS ...... 7

EIAS COMPLETED AND APPROVED FOR THE HUSAB MINE AND ASSOCIATED LINEAR INFRASTRUCTURE ...... 8

EIA PROCESS FOR THE PROPOSED PV POWER PROJECT ...... 9

EIA TEAM ...... 11

OPPORTUNITY TO COMMENT ...... 13

SCOPING (INCLUDING IMPACT ASSESSMENT) METHODOLOGY ...... 13

INFORMATION COLLECTION ...... 13

SCOPING REPORT (INCLUDING ASSESSMENT OF IMPACTS) ...... 13

PUBLIC PARTICIPATION PROCESS ...... 15

SWAKOP URANIUM’S I&APS ...... 15

STEPS IN THE CONSULTATION PROCESS ...... 17

SUMMARY OF COMMENTS SUBMITTED / ISSUES RAISED ...... 19

LEGAL FRAMEWORK ...... 20

SUMMARY OF APPLICABLE ACTS AND POLICIES ...... 20

PROJECT DESCRIPTION ...... 24

INTRODUCTION ...... 24

CURRENT (APPROVED) HUSAB MINE POWER SUPPLY INFRASTRUCTURE ...... 24

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

PROPOSED CHANGES TO THE POWER SUPPLY TO THE HUSAB MINE ...... 24

PHOTOVOLTAIC POWER GENERATION...... 24

MODULES AND SOLAR ARRAYS ...... 25

PV POWER PLANT LOCATION ...... 26

ASSOCIATED INFRASTRUCTURE AND SERVICES ...... 28

PROJECT PHASES ...... 34

PROJECT ALTERNATIVES ...... 36

PV POWER PLANT LOCATION (I.E. SITE) ALTERNATIVES ...... 36

LAYOUT AND SOLAR ARRAY ALTERNATIVES ...... 36

POWERLINE ROUTE OPTIONS ...... 36

TECHNOLOGY ALTERNATIVES ...... 37

MODULES, INVERTORS, TRANSFORMERS AND SWITCHGEARS ...... 37

MOUNTING SYSTEM ...... 37

NO-GO OPTION ...... 38

DESCRIPTION OF THE CURRENT ENVIRONMENT ...... 39

CLIMATE...... 39

TEMPERATURE ...... 40

SOLAR RADIATION ...... 40

PRECIPITATION AND FOG ...... 41

SURFACE WIND FIELD ...... 42

TOPOGRAPHY ...... 44

GROUNDWATER ...... 45

SURFACE WATER...... 46

REGIONAL HYDROLOGY ...... 46

LOCAL HYDROLOGY ...... 46

SOIL ...... 46

BIODIVERSITY ...... 46

BIODIVERSITY IN AND AROUND THE PROPOSED PV POWER PLANT SITE ...... 46

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

AVIFAUNAL ENVIRONMENT ...... 47

AIR QUALITY ...... 51

ARCHAEOLOGY ...... 51

VISUAL ...... 51

SOCIAL ...... 51

IDENTIFICATION AND DESCRIPTION OF POTENTIAL ENVIRONMENTAL IMPACTS THAT ARE LIKELY TO CHANGE AS A RESULT OF THE PROPOSED AMENDMENTS ...... 53

ASPECT AND IMPACT IDENTIFICATION ...... 53

ENVIRONMENTAL IMPACT ASSESSMENT ...... 64

BIODIVERSITY - AVIFAUNA ...... 66

ISSUE: COLLISIONS OF BIRDS WITH PHOTOVOLTAIC (PV) PANELS AND ASSOCIATED INFRASTRUCTURE AND GENERAL DISTURBANCE OF BIRDS ...... 66

ASSESSMENT OF IMPACT: ATTRACTION OF NOVEL SPECIES TO THE AREA BY THE ARTIFICIAL PROVISION OF OTHERWISE SCARCE RESOURCES ...... 67

CUMULATIVE IMPACTS ...... 69

VISUAL ...... 69

ISSUE: VISUAL IMPACTS AND SENSE OF PLACE ...... 69

GROUNDWATER & SURFACE WATER AND SOIL...... 71

ISSUE: GROUNDWATER & SURFACE WATER QUALITY AND SOIL POLLUTION ...... 71

AIR QUALITY ...... 72

ISSUE: AIR POLLUTION (DUST) ...... 72

SOCIO-ECONOMIC ...... 74

ISSUE: EMPLOYMENT AND SKILLS DEVELOPMENT ...... 74

ISSUE: INWARD MIGRATION AND SOCIAL/SECURITY ISSUES ...... 75

ENVIRONMENTAL MANAGEMENT PLAN ...... 77

AIMS ...... 77

ENVIRONMENTAL OBJECTIVES ...... 77

MANAGEMENT AND MITIGATION MEASURES (ACTION PLANS) TO ACHIEVE OBJECTIVES ...... 78

RESPONSIBILITIES ...... 104

iii

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

SU PROJECT MANAGER ...... 104

SWAKOP URANIUM ENVIRONMENTAL SECTION ...... 104

CGNEI PROJECT / CONSTRUCTION MANAGER ...... 104

OWNER ENGINEER...... 105

SUB-CONTRACTOR(S) ...... 105

HSE REPRESENTATIVE ...... 106

INTERNAL REVIEW AND AUDITING ...... 106

ENVIRONMENTAL AWARENESS TRAINING ...... 107

PERMITS ...... 107

MONITORING ...... 108

AVIFAUNA ...... 108

DECOMMISSIONING AND CLOSURE ...... 108

WAY FORWARD ...... 109

WAY FORWARD FOR THE SCOPING REPORT ...... 109

ENVIRONMENTAL IMPACT STATEMENT AND CONCLUSION ...... 109

REFERENCES ...... 110

APPENDICES

APPENDIX 1: CVs APPENDIX 2: Information Sharing Record APPENDIX 3: IAP database APPENDIX 4: Comments Received APPENDIX 5: Avifauna specialist study APPENDIX 6: Comments and Response Report

LIST OF TABLES

TABLE 1-1: SUMMARY OF APPROVALS (ECCS) FOR THE VARIOUS EIAS CONDUCTED ...... 8 TABLE 1-2: EIA PROCESS ...... 9 TABLE 1-3: THE ENVIRONMENTAL PROJECT TEAM ...... 12 TABLE 2-1: SCOPING REPORT REQUIREMENTS STIPULATED IN THE EIA REGULATIONS ...... 14 TABLE 2-2: SWAKOP URANIUM STAKEHOLDERS ...... 15 TABLE 2-3: CONSULTATION PROCESS WITH I&APS AND AUTHORITIES ...... 17 TABLE 3-1: RELEVANT LEGISLATION, POLICIES, CONVENTIONS AND MANAGEMENT PLANS ETC...... 22 TABLE 4-1 WASTE MANAGEMENT FOR CONSTRUCTION PHASE ...... 32

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

TABLE 6-1: KEY ENVIRONMENTAL ASPECTS TO BE TAKEN INTO CONSIDERATION DURING THE PROJECT DEVELOPMENT PHASES ...... 39 TABLE 6-2 ARANDIS SOLAR RESOURCE ASSESSMENT (NAMENERGY, 2019) ...... 41 TABLE 6-3: CHECKLIST OF PRIORITY BIRD SPECIES RECORDED WITHIN THE HUSAB MINE AREA, IN TERMS OF THE PROPOSED PV POWER PROJECT (SEE BELOW FOR KEY) ...... 50 TABLE 7-1: ENVIRONMENTAL ASPECTS AND POTENTIAL IMPACTS ASSOCIATED WITH CONSTRUCTION PHASE OF THE 12 MW PV POWER PROJECT ...... 54 TABLE 7-2: ENVIRONMENTAL ASPECTS AND POTENTIAL IMPACTS ASSOCIATED WITH OPERATIONS PHASE OF THE PV POWER PROJECT ...... 59 TABLE 8-1: CRITERIA FOR ASSESSING IMPACTS...... 65

LIST OF FIGURES

FIGURE 1-1: HUSAB MINE LOCALITY MAP INCLUDING THE MINING LICENCE BOUNDARY ...... 3 FIGURE 1-2 LOCALITY MAP TO THE PROPOSED HUSAB MINE 12 MW SOLAR PV POWER PLANT ...... 4 FIGURE 1-3 – THE EIA PROCESS ...... 11 FIGURE 4-1: A TYPICAL SOLAR PV ILLUSTRATION (JCM, 2019) ...... 25 FIGURE 4-2: PROPOSED PV POWER PLANT AND ASSOCIATED INFRASTRUCTURE LOCATION ADJACENT TO THE PROCESSING PLANT ...... 27 FIGURE 4-3: EXISTING STORM WATER INFRASTRUCTURE AROUND THE PROPOSED PV POWER PLANT SITE ..... 30 FIGURE 4-4: EXISTING HUSAB MINE CABLE TRAY...... 31 FIGURE 6-1: MONTHLY AVERAGE TEMPERATURES AT ALL HUSAB STATIONS (AIRSHED, 2017) ...... 40 FIGURE 6-2: AVERAGE ANNUAL RAINFALL FOR NAMIBIA, INCLUDING HUSAB MINE (0-50 MM/A) ...... 42 FIGURE 6-3: PERIOD, DAY- AND NIGHT-TIME WIND ROSES (MARBLE RIDGE WEATHER STATION DATA, 2014 - 2016) ...... 43 FIGURE 6-4: SEASONAL WIND ROSES (MARBLE RIDGE WEATHER STATION DATA, 2014 - 2016) ...... 44 FIGURE 6-5: DEM DATA FOR THE GENERAL AREA SURROUNDING THE INVESTIGATION SITE (WHITE INDICATES THE HIGHEST SECTIONS AND BLUE THE LOWEST) (TERRA SOIL, 2018) ...... 45 FIGURE 6-6: THE PROPOSED SITE FOR THE SOLAR PV DEVELOPMENT ON THE HUSAB MINE, LOOKING NORTH- EASTWARDS; NOTE THE PREVIOUSLY DISTURBED, OPEN HABITAT (ACS, 2019) ...... 47

Swakop Uranium (Pty) Ltd Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine 733.03107.00001 activities and infrastructure - 12 MW Solar PV Power Plant July 2019

ACRONYMS AND ABBREVIATIONS

Acronym / Abbreviation Definition BID Background Information Document CGNEI CGN Energy International Holdings CO. Limited CO Carbon Monoxide

CO2 Carbon Dioxide DEA Directorate of Environmental Affairs DEM Digital Elevation Model DWNP Directorate Wildlife and National Parks HSE Health, Safety and Environmental EAP Environmental Assessment Practitioner EAPAN Environmental Assessment Professionals Association of Namibia ECC Environmental Clearance Certificate EIA Environmental Impact Assessment EMP Environmental Management Plan EPL Exclusive Prospecting License ha Hectares I&AP Interested and Affected Party LOM Life of Mine MET Ministry of Environment and Tourism ML Mining Licence MME Ministry of Mines and Energy MSDS Material Safety Data Sheet NAMREP Namibian Renewable Energy Programme NIRP National Integrated Resource Plan NNNP Namib Naukluft National Park PM Particulate Matter PPE Person protective equipment PPP Public Participation Process PV Photovoltaic REEE Regulatory Framework for Renewable Energy and Energy Efficiency SLR SLR Environmental Consulting (Namibia) (Pty) Ltd STP Sewerage Treatment Plant SU Swakop Uranium (Pty) Ltd TSF Tailings Storage Facility

1. INTRODUCTION

PURPOSE OF THE REPORT

This Scoping (including impact assessment) and Environmental Management Plan (EMP) Report summarises the Environmental Impact Assessment (EIA) process being followed for the proposed 12 MW solar photovoltaic (PV) power plant to be constructed on Swakop Uranium’s Husab Mine, located in the northern most part of the Namib Naukluft National Park (NNNP). It includes an assessment of the environmental impacts that the proposed project is likely to have. The proposed management and mitigation measures relating to the proposed project are documented in an Environmental Management Plan (EMP), see Section 9.

Registered Interested and Affected Parties (I&APs) are being provided with the opportunity to comment on this Scoping (including impact assessment) Report (see Section 1.5). Once the comment period closes, the Scoping Report and EMP will be updated to a final report with due consideration of the comments received, and will be submitted to the Ministry of Environment and Tourism (MET) for decision-making.

INTRODUCTION TO THE PROPOSED PROJECT

Swakop Uranium holds the mining licence (ML) 171 and Environmental Clearance Certificates (ECCs) for the Husab Uranium Mine (and associated activities / infrastructure) and for its associated linear infrastructure. The mine and processing plant is situated in the northern most part of the Namib Naukluft National Park, about 12 km south-east of Arandis (refer to Figure 1-1). Mining started in March 2014 and the commissioning of the processing plant commenced in December 2016, with the first drum of U3O8 produced.

Power is currently supplied to the Husab Mine via a 132 kV NamPower transmission line. This overhead powerline feeds into the Husab Mine substation, located within the processing plant complex.

Swakop Uranium identified the need for additional power supply infrastructure to the Husab Mine to augment the current power demand.

Prior to the commencement of the proposed project, an Environmental Clearance Certificate (ECC) (amendment) is required from the Ministry of Environment and Tourism (MET): Directorate Environmental Affairs (DEA) in terms of the Environmental Management Act, 2007 (No. 7 of 2007) and the associated EIA Regulations.

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SLR Environmental Consulting (Namibia) (Pty) Ltd (SLR) has been appointed by Swakop Uranium and CGNEI as the independent Environmental Assessment Practitioner to undertake the EIA process.

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FIGURE 1-1: HUSAB MINE LOCALITY MAP INCLUDING THE MINING LICENCE BOUNDARY

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Legend:

Solar PV Plant boundaries 33 kV switch station SU Substation Proposed powerline route

SU Processing Plant

TSF

3 km

Solar PV Plant and Power line Locality Map

FIGURE 1-2 LOCALITY MAP TO THE PROPOSED HUSAB MINE 12 MW SOLAR PV POWER PLANT

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MOTIVATION (NEED AND DESIRABILITY)

Swakop Uranium (with CGNEI) proposes to construct and operate a 12 MW PV power plant at the Husab Mine to provide electricity for the mine, processing plant and associated activities. This would provide cost savings to Swakop Uranium, compared to the current NamPower tariff. In addition to the cost saving, the overall electricity demand, as was previously determined and assessed (as part of the original, approved, EIA processes) has increased. Swakop Uranium therefore identified the need for additional supply to enable the Husab Mine to operate efficiently with uninterrupted power and meeting the increased power demand.

Swakop Uranium has identified an area within the mine foot print for the development of the proposed PV power plant infrastructure. The area is already disturbed and was used for the temporary construction camp during the construction phase. This site is located relatively close to the supporting infrastructure i.e. Husab Mine substation. The footprint of the proposed PV power plant will therefore not require additional area to be cleared and will be integrated into the existing infrastructure.

The energy demand in Namibia increases each year due to economic and population growth, as well as social development and upliftment. While fossil fuels have, historically, long been the preferred energy source, it has become apparent that more sustainable resources must be utilised in order to avoid energy crisis. The worldwide awareness of environmental degradation and subsequent climate change also forces the energy industry to find alternative sources of energy that would have less detrimental effect on the environment.

The high level of solar radiation experienced in Namibia renders it suitable for energy generation through solar technology.

The proposed development would provide clean energy from an unlimited and sustainable resource, which would cause minimal environmental impact. It would produce minimal waste and avoid CO2 emissions, and therefore reduce further global warming. The project would therefore make a contribution to improving the sustainability of development in Namibia.

The concept of “need and desirability” can essentially be equated to the wise, sustainable use of land. The Sections below consider the context within which the “need and desirability” of the proposed project should be considered.

The need for renewable energy in Namibia

Energy is critical to virtually every aspect of the economic and social development of Namibia. The Namibian electricity sector relies heavily on electricity imports from external sources (i.e. South Africa). There is a need to address the potential capacity deficit, to contribute to Namibia’s ability to generate electricity from its own sources, thus reducing its dependency on external suppliers and to take advantage of the good solar resource in Namibia. As a result, NamPower continues to negotiate Power Purchase Agreements (PPAs) and Transmission Connection Agreements with Independent Power Producers (IPPs).

Namibia has one of the best solar regimes in the world with an average high direct insolation of 2 200 kilowatt hours per square meter per annum (kWh/m2/a) and minimum cloud cover (www.reeep.org/namibia-2014).

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Fit with policy and planning

The relevant policies pertaining to the energy sector indicate that renewable energy (including solar) and the establishment of PV plants are supported at a national level. A summary is provided below.

1.3.2.1 Vision 2030

In 2004, Namibia adopted Vision 2030, which outlines the country's development programmes and strategies to achieve its national objectives. One of the objectives of Vision 2030 is to “ensure the development of Namibia’s ‘natural capital’ and its sustainable utilisation, for the benefit of the country’s social, economic and ecological well-being”.

1.3.2.2 White Paper on Energy Policy of 1998

The current energy policy is articulated in the White Paper on Energy Policy of 1998 (WPE). It contains specific policies with regard to renewable energy that have guided initiatives by the Ministry of Mines and Energy (MME) over the last few years. Between 2007 and 2010, the Namibian Renewable Energy Programme (NAMREP) was developed to increase affordability and access to renewable energy services and accelerate market development for renewable energy technologies by reducing existing barriers to solar energy, including human capacity, financial, technical, awareness and other market limitations.

1.3.2.3 Regulatory Framework for Renewable Energy and Energy Efficiency

The development of a Regulatory Framework for Renewable Energy and Energy Efficiency within the Electricity Sector (“REEE Regulatory Framework”) is one of several projects implemented by NAMREP. Two strategic objectives underlie the recommendations of the REEE Regulatory Framework and should be at the centre of Namibia’s long-term energy policy and vision for sustainable development. These are:

 Supporting environmentally sustainable technologies; and  Attaining greater energy security through a steady increase of electricity production in Namibia using fuels or energy sources that are available in Namibia, e.g. solar, biomass and wind.

1.3.2.4 National Integrated Resource Plan (NIRP)

The goal of the NIRP is to identify the mix of resources for meeting short- and long-term consumer energy needs in Namibia in an efficient and reliable manner, at the lowest reasonable cost. The NIRP focuses on electricity supply, but also takes into account the impact of developing other energy sources and demand management measures capable of reducing electricity demand in the country. One of the objective of the NIRP is to increase the diversification, security, reliability and efficiency of electricity supply, including the substitution of electricity by other energy sources such as oil, gas, biofuels and solar in order to improve efficiency.

National Emission Targets

Depending on the way electricity is produced, transported and used, it can contribute to both local environmental degradation, such as air pollution, and global environmental problems, principally climate change.

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Namibia is signatory to numerous Conventions and is striving to maintain climate change as a priority within its development framework (e.g. Vison 2030 and NDP4). The National Policy on Climate Change for Namibia was produced in 2011 to better translate the government’s will and commitment to tackle climate change. Furthermore, a National Climate Change Strategy and Action Plan has also been developed, which outlines the strategic options to be adopted for coping with climate change challenges while contributing to the international agenda to meet decisions taken.

Namibia, as a Non-Annex I Party to the United Nations Framework Convention on Climate Change (UNFCCC), does not have commitments under the Convention. However, Namibia takes climate change issues seriously and the preparation of the Intended Nationally Determined Contributions (INDC) report (September 2015) is a testimony that the country is committed to fight climate change. To this end, Namibia has put in place policies and strategies to deal with the adverse impacts of climate change, which is seen as a major threat to the economic development and the general welfare of the Namibian society.

Namibia aims at a reduction of about 89% of its Greenhouse Gas (GHG) emissions compared to the business-as- usual scenario at the 2030 time horizon. One of the proposed measures to achieve this relates to a shift from fossil fuels to renewable energy sources, improve energy efficiency and reduce fossil fuel consumption through a series of measures in the road transportation sector. Key proposals include, inter alia:

 Increasing the percentage of renewable energy (hydro, solar, wind and biomass) in electricity production from 33% in 2010 to 70% in 2030; and  Implementing an energy efficiency programme to reduce consumption by about 10% in 2030.

EIA PROCESS

Introduction to the proposed EIA (amendment) process

EIA (and amendment) Applications are regulated by the Ministry of Environment and Tourism (MET) in terms of the Environmental Management Act, 7 of 2007. This Act was gazetted on 27 December 2007 (Government Gazette No. 3966). The Environmental Impact Assessment Regulations: Environmental Management Act, 2007 (Government Gazette No. 4878) were promulgated on 6 February 2012. An environmental clearance (amendment) is required based on an application, prior to the commencement of the proposed changes and additions.

The overall objectives of the assessment process are to:

 Provide an independent assessment of the potential environmental impacts associated with the proposed power supply infrastructure at the Husab Mine, taking the existing infrastructure and activities into consideration;  Develop relevant management and mitigation measures for identified potential impacts where necessary.

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EIAs completed and approved for the Husab Mine and associated linear infrastructure

Swakop Uranium undertook an EIA for the Husab Mine and related site infrastructure in 2009/2010. Another EIA was conducted in 2010/2011 for the linear infrastructure. In 2012/2013 Swakop Uranium undertook an EIA Amendment for the proposed changes to the Husab Mine, primarily relating to the mineralised waste facilities. In 2013/2014 an EIA amendment was conducted for a proposed change to the permanent water pipeline alignment (and associated transmission line) and a further amendment to the linear infrastructure was applied for in 2017, for a proposed new 33 kV overhead powerline at Husab Mine ‘B2 Vehicle Staging area’. In 2018, Swakop Uranium proposed changes to the Waste Rock Dump design and facility and changes to the onsite waste management (i.e. a proposed new waste incinerator) that also followed an amendment application process (still being reviewed by MET); as well as an amendment to the linear infrastructure (i.e. installation of mobile communication antenna poles), approved by MET in April 2019.

The MET: Department of Environmental Affairs (DEA) has issued the following Environmental Clearance Certificates (ECCs) to Swakop Uranium after review and acceptance of the relevant EIAs:

TABLE 1-1: SUMMARY OF APPROVALS (ECCS) FOR THE VARIOUS EIAS CONDUCTED

Date EIA and related approval  January 2011  ECC for the Husab Mine EIA was issued  2013  Renewal of above ECC  June 2011  ECC for the Linear Infrastructure EIA  2013  Renewal of above ECC (after the EIA amendment)  September 2013  ECC for the Husab Mine EIA Amendment (relating to the TSF amendment, amongst others)  September 2016  Renewal of above ECC  March 2014  ECC for the Amendment to the Husab Mine Linear Infrastructure associated with the Water Supply Pipeline and northern associated powerline  March 2014  ECC for the Emulsion Manufacturing plant  September 2017  Renewal of above ECC  July 2014  ECC was issued for an increase in Height of the Base Transmitter Mast from the current 30 Meters to 60 Meters Situated at the Husab Mine.  September 2017  Renewal of above ECC  September 2016  ECC for the amendment to the Husab Mine Linear Infrastructure, associated with the new 33 kV overhead powerline  February 2017  ECC for the second Telecommunication Tower at the Husab Mine  April 2019  ECC for the installation of Mobile Communication Antenna Poles

A combined environmental management plan (EMP) for the Husab Mine (and associated site activities / infrastructure) and its associate linear infrastructure was compiled and approved in 2013.

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EIA process for the proposed PV power project

Prior to the commencement of the proposed additional power supply infrastructure (i.e. PV power plant and associated infrastructure) described in this document, an (Amendment) Application was submitted to the MET: DEA to advise that an EIA process was to be conducted in terms of the Environmental Management Act, 7 of 2007. This process includes: an internal screening phase and a scoping phase, which includes an impact assessment and an EMP specific to the PV power project.

This report is the Scoping Report, the main purpose of which is to provide information relating to the proposed additions to the current power supply infrastructure on-site and to indicate which environmental aspects and potential impacts have been identified during the internal screening and scoping phases. During the internal screening exercise, SLR identified the need for an Avifauna Specialist Study, due to the potential impacts of the PV panels on primarily Red Data bird species (including those with migrant status) and/or endemic species.

Existing information from the previous EIAs conducted (refer to Section 1.4.2) were also used in this report and have been further augmented by site visits by the EIA team to the Husab Mine, as well as an additional specialist study and input from comments gathered as a result of stakeholder consultation. The potential cumulative impacts of the activities associated with the proposed PV power plant and activities could therefore be assessed.

It is thought that this Scoping Report (including impact assessment) and EMP will provide sufficient information for MET: DEA to make an informed decision regarding the proposed project, and whether an environmental clearance certificate for the activities associated with the proposed PV power plant can be issued or not.

More detailed information on the Scoping Report is provided in Section 2.2.

The EIA process and corresponding activities which have been undertaken for this project are outlined in Table 1-2 below. The process that was followed was in accordance with the requirements outlined in the EIA Regulations of 2012.

TABLE 1-2: EIA PROCESS

Objectives Corresponding activities Project initiation and Screening phase (March 2019)  Identify environmental aspects  Notify the MET: DEA of the proposed application and EIA and potential impacts associated process (an Application was submitted to MET for the proposed with the proposed project changes to the Husab Mine Infrastructure and associated  Notify the decision making activities). authority of the proposed project  Project initiation meetings and site visit with the Swakop  Initiate the EIA Scoping process. Uranium Environmental team to discuss the proposed project.  Early identification of environmental aspects and potential impacts that might change as a result of the proposed project and determine additional legal requirements.  Decision on EIA process to be followed and specialist to be used in the process.  Identify key stakeholders (update existing Husab Mine interested and affected party (IAP) database).

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Scoping (including assessment) phase (April – July 2019)  Involve I&APs in the scoping  Online registration of the project onto MET’s (new) online process through information system. sharing.  Notify government authorities and I&APs of the proposed  Identify further potential amendment and EIA process (telephone calls, e-mails, environmental issues associated newspaper advertisements and site notices). with the proposed amendments.  Interested and affected party (IAP) registration and initial  Determine the terms of comments. reference for additional  Key stakeholder (focus group) meetings and Include IAP issues assessment work. and concerns in the studies and assessments.  Consider alternatives.  Conduct specialist study (Avifauna).  Identify any fatal flaws.  Compilation of Scoping Report (including impact assessment)  Provide further details associated and EMP. with the potentially affected  Distribute Scoping Report and EMP to relevant authorities and environment. I&APs for review (including a public meeting).  Assessment of potential  Forward finalised Scoping Report with EMP and I&APs environmental impacts comments to MET for decision making. associated with the proposed project.  Develop management and mitigation measures.  Receive feedback on application

The above mentioned EIA process is explained diagrammatically in Figure 1-3 below.

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Project initiation / Screening phase

Public participation Scoping & (introducing scope of EIA project, assessment phase identify issues & inviting comments

Scoping Report & updateEMP EMP Prepare draft Scoping Report (including assessment of impacts) & updatedEMP EMP

Review by IAPs

Submission of Final Reports to MET

Implementation of EIA Not approved Review by MET Approved mitigation through EMP

FIGURE 1-3 – THE EIA PROCESS

EIA Team

SLR is an independent Namibia registered firm of consultants who was appointed to undertake the EIA processes.

Werner Petrick, the EIA Project Manager has more than twenty years of relevant experience in environmental management, conducting/managing EIAs, compiling EMPs and implementing EMPs and Environmental Management Systems. Werner is certified as a Lead Environmental Practitioner and Reviewer under the Environmental Assessment Professional Association of Namibia (EAPAN).

Marvin Sanzila, the EIA Project Assistant has more than eight years of experience in the environmental management discipline with five years’ experience in the mining industry dealing with environmental management systems implementation (ISO 14001), coordination and implementation of EMPs, legal compliance and over three years with EIAs. Marvin is certified as an Environmental Practitioner under the EAPAN.

The relevant curriculum vitae documentation is attached in Appendices A. The environmental project team is outlined in Table 1-3 below.

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TABLE 1-3: THE ENVIRONMENTAL PROJECT TEAM

Team Name Designation Tasks and roles Company

Project & Planning: Jordan Dengeinge Head of Department Swakop Uranium Swakop project team Environmental Uranium Carlene Binneman Responsible for Superintendent technical input and implementation of CGN Energy Li Gang Technical Expert CGNEI the EMP International commitments Holdings CO. Limited (CGNEI) Xue Lijiong Technical Expert CGNEI Technical Team

Report compilation, management of the Werner Petrick Project Manager process, team members and other stakeholders EIA Project Project SLR Namibia management administration, Marvin Sanzila Project Assistance compilation of reports and arrange Public Participatory Process.

Stuart Heather- Clark Reviewer Report review

African Specialist Mike and Ann Scott Avifauna Specialists Avifauna Assessment Conservation investigations Services cc

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OPPORTUNITY TO COMMENT

This EIA Scoping Report (including impact assessment) and EMP were distributed for a 21 day review period in order to provide I&APs with an opportunity to comment on any aspect of the proposed changes and the findings of the EIA process. A hard copy of the full report was made available at the Swakopmund Public Library. An electronic copy of the report was available on request to SLR. For comments to be included in the Final Scoping Report, they had to reach SLR by 8 July 2019.

SLR Environmental Consulting (Namibia) (Pty) Ltd Attention: Marvin Sanzila

PO Box 86386, Windhoek Tel: +264 61 231 287 Fax: +264 61 231 289 E-mail: [email protected]

SCOPING (INCLUDING IMPACT ASSESSMENT) METHODOLOGY

This chapter outlines the Scoping (including impact assessment) methodology and I&AP consultation process followed in the EIA (amendment) process.

INFORMATION COLLECTION

SLR Namibia used various information sources to identify and assess the issues associated with the proposed changes. These include:

 Review of previous EIAs and other studies done in the project area  Site visit by SLR Namibia  Consultation with the Project Technical Team (Swakop Uranium and CGNEI)  Consultation with relevant regulating authorities  Consultation with I&APs; and  Further specialist studies (Avifauna), including a site visit.

SCOPING REPORT (INCLUDING ASSESSMENT OF IMPACTS)

Table 2-1 outlines the Scoping Report requirements as set out in Section 8 of the Environmental Impact Assessment Regulations that were promulgated in February 2012 in terms of the Environmental Management Act, 7 of 2007.

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TABLE 2-1: SCOPING REPORT REQUIREMENTS STIPULATED IN THE EIA REGULATIONS

Requirements for a Scoping Report in terms of the February 2012 Reference in Report Regulations

(a) the curriculum vitae of the EAPs who prepared the report; Section 1.4.4 and Appendix 1 (b) a description of the proposed activity; Section 4 (c) a description of the site on which the activity is to be undertaken Sections 4 & 6 and the location of the activity on the site; (d) a description of the environment that may be affected by the proposed activity and the manner in which the geographical, physical, Sections 6, 7 and 8 biological, social, economic and cultural aspects of the environment may be affected by the proposed listed activity; (e) an identification of laws and guidelines that have been considered Section 3 in the preparation of the Scoping Report; (f) details of the public consultation process conducted in terms of regulation 7(1) in connection with the application, including - (i) the steps that were taken to notify potentially interested and affected parties of the proposed application; (ii) proof that notice boards, advertisements and notices notifying potentially interested and affected parties of the proposed application Sections 2.3 have been displayed, placed or given; (iii) a list of all persons, organisations and organs of state that were registered in terms of regulation 22 as interested and affected parties in relation to the application; and (iv) a summary of the issues raised by interested and affected parties, the date of receipt of and the response of the EAP to those issues; (g) a description of the need and desirability of the proposed listed activity and any identified alternatives to the proposed activity that are feasible and reasonable, including the advantages and Sections 1.3 and 5 disadvantages that the proposed activity or alternatives have on the environment and on the community that may be affected by the activity; (h) a description and assessment of the significance of any significant effects, including cumulative effects, that may occur as a result of the undertaking of the activity or identified alternatives or as a result of Sections 7 and 8 any construction, erection or decommissioning associated with the undertaking of the proposed listed activity; Section 7 & 8 (However, not applicable due to the fact that this is the final report, (i) terms of reference for the detailed assessment; and which includes an assessment and specialist input. No further assessment is required).

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Requirements for a Scoping Report in terms of the February 2012 Reference in Report Regulations

(j) a management plan, which includes - (i) information on any proposed management, mitigation, protection or remedial measures to be undertaken to address the effects on the environment that have been identified including objectives in respect of the rehabilitation of the environment and closure; (ii) as far as is reasonably practicable, measures to rehabilitate the environment affected by the undertaking of the activity or specified Appendix 11 activity to its natural or predetermined state or to a land use which conforms to the generally accepted principle of sustainable development; and (iii) a description of the manner in which the applicant intends to modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation remedy the cause of pollution or degradation and migration of pollutants.

PUBLIC PARTICIPATION PROCESS

The public participation process for the proposed amendment is conducted to ensure that all persons and/or organisations that may be affected by, or interested in, the proposed changes, were informed of the project and could register their views and concerns. By consulting with relevant authorities and I&APs, the range of environmental issues to be considered in the Scoping Report (including the assessment of impacts) has been given specific context and focus.

Included below is a summary of the I&APs consulted, the process that was followed, and the issues that were identified.

Swakop Uranium’s I&APs

Table 2-2 provides a broad list of persons, group of persons or organisations that were informed about the amendments and were requested to register as I&APs should they be interested and/or affected.

TABLE 2-2: SWAKOP URANIUM STAKEHOLDERS

IAP Grouping Organisation

Local and regional government – Erongo Regional Council, Walvis Bay and Swakopmund Town councillors and key officers Councils Government Ministries . Ministry of Environment and Tourism (MET);  Department of Environmental Affairs (DEA);  Directorate of Wildlife and National Parks (DWNP); . Ministry of Mines and Energy (MME); . Ministry of Health and Social Service;

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IAP Grouping Organisation

. Erongo Regional Council . Swakopmund Town Council; . Swakopmund Municipality; . Arandis Town Council; . Ministry of Health and Social Services; . Walvis Bay Municipality; . Ministry of Education; . Ministry of Trade and Industry . Ministry of Agriculture Water and Forestry; . Ministry of Labour and Social Welfare; and . Ministry of Works, Transport and Communications. Government Parastatals NamPower and Erongo Red; Neighbouring Mines / Zhonghe Resources; Rössing Uranium; Areva Resources (ORANO); Exploration companies and North River Resources (Namib Lead); Arandis Airport (Pty) Ltd; others. Langer Heinrich Uranium; Valencia; Novachab Mine and Reptile Uranium. Environmental Foundations and Namibian Uranium Association; Namibia Uranium Institute; NGOs Namibian Coast Conservation and Management Project (NACOMA); Southern Africa Institute for Environmental Assessment (SAIEA); Earthlife Namibia; Coastal and Tourism Association (CTAN); and Coastal & Environmental Trust of Namibia (CETN). National Chambers Chamber of Mines of Namibia; National Chamber of Commerce and Industry; and National Chamber of Environment. Local Businesses Various in Arandis, Swakopmund and Walvis Bay. Media Newspaper adverts: Die Republikein, Allgemeine Zeitung and The Namibian Sun newspaper. Information was also shared with other media forums (i.e. newspapers) Other interested and affected Any other people with an interest in the proposed project or who parties may be affected by the proposed project.

The full stakeholder database for the EIA amendment process is included in Appendix 3 of the report.

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Steps in the consultation process

Table 2-3 sets out the steps that were followed as part of the consultation process:

TABLE 2-3: CONSULTATION PROCESS WITH I&APS AND AUTHORITIES

TASK DESCRIPTION DATE

Notification - regulatory authorities and I&APs

SLR submitted the Application form (Form 2) to MET. A copy Notification to of the Background Information Document (BID) was also sent April 2019 MET to MET. Online registration of the project onto MET’s (new) online system. The Swakop Uranium stakeholder database was updated to include relevant I&APs and will be updated during the EIA (amendment) process as required. IAP identification April 2019 All parties who registered or showed an interest in this EIA (amendment) process, together with relevant Local, Regional and Governmental Ministries are included in Appendix 3. Copies of the BID were distributed via email to all authorities and I&APs on the project stakeholder database and were available at the Focus Group meetings. Copies of the BID were made available on request to SLR. Distribution of background The purpose of the BID was to inform I&APs and authorities April –May 219 information about the proposed project, the EIA process, possible document (BID) environmental impacts and means of providing input into the EIA process. Attached to the BID was a registration and response form, which provided I&APs with an opportunity to submit their names, contact details and comments on the project. A copy if the BID is attached in Appendix 2. One site notice was placed at the B2 entrance to the mine and Site notices another at the main site security reception. Refer to Appendix April 2019 2 for photos of the site notices. Block advertisements were placed as follows:

 Die Republikein (8 and 15 April 2019);

 Allgemeine Zeitung (8 and 15 April 2019); Newspaper  Namibian Sun newspaper (8 and 15 April 2019). April 2019 Advertisements Refer to Appendix 2.

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TASK DESCRIPTION DATE

Public meeting and Focus Group meetings and submission of comments

The following focus group meetings were held:  Coastal Tourism Association of Namibia (CTAN) representative on the 16th of April 2019. Focus Group  MET: Directorate of Wildlife and National Parks April - June 2019 Meetings (DWNP) (NNNP Chief Park Warden) on the 7th of June 2019.  MME (Deputy Director of Energy) on the 7th of June 2019. Minutes of the meetings and all comments received during Comments and the process, by email are attached in Appendix 4. A Summary

Responses of comments received (with responses) is provided in Section 2.3.3 and Appendix 6.

Review of draft Scoping Report

The Scoping Report (including impact assessment and EMP) (Main Report) was sent via email to all parties who registered or showed an interest in this amendment process, as well as relevant Local, Regional and Governmental Ministries. I&APs and Electronic copies of the full report (including appendices) will authorities be made available on request to SLR (on a CD). (excluding MET) June – July 2019 review of Scoping Hard copies of this report will be available at the Report and Swakopmund Public Library. An electronic copy of the EIA updated EMP Report can be provided on request to SLR.

Authorities and I&APs had 3 weeks to review the Scoping Report and submit comments in writing to SLR. The closing date for comments was 8 July 2019. The availability of the Scoping Report for review by I&APs, as well as the information about the public meeting (see below) was advertised as follows: Newspaper  Die Republikein (20 June 2019); 20 June 2019 advertisement  Allgemeine Zeitung (20 June 2019);

 Namibian Sun newspaper (20 June 2019).

Refer to Appendix 2. A public (feedback) meeting was held during the review Public meeting period of the Scoping Report (including impact assessment 26 June 2019 and EMP). Minutes of the meeting and all comments by I&APs

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TASK DESCRIPTION DATE

during the meeting (with responses) are provided in Appendix 6. MET review of A copy of the final Scoping Report, including authority and IAP Scoping Report review comments, will be delivered to MET on completion of July 2019 and EMP the public review process for their review and decision.

Summary of comments submitted / issues raised

Few comments were submitted by I&APs throughout the EIA process. The comments received from I&APs relate to, amongst others, the following:

 Positive comments relating to the proposal to implement a PV power project.  The location of the proposed plant and the associated shape of the project area.  A few I&APs sent e-mails, requesting to be added to the database and also to obtain further information relating to relevant services they could provide during the construction phase.  Possibility of supplying power to the grid when the full capacity from the PV power plant is not utilised by the Husab Mine and associated infrastructure, also after closure of the Husab Mine.  Waste management issues.  Methods for cleaning of the panels.  Impacts on birds.

A Comments and Response Report, summarising all comments / issues received by I&APs throughout the process (including during meetings), is attached as Appendix 6.

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LEGAL FRAMEWORK

The original EIAs and previous EIA amendments presented the key Namibian legislative requirements and International Conventions applicable to the Husab Mine and the associated infrastructure. These key legislative requirements remain applicable and are summarised in this chapter.

The Republic of Namibia has five tiers of law and a number of policies relevant to environmental assessment and protection, which includes:

 The Constitution  Statutory law  Common law  Customary law  International law

Relevant policies currently in force include:

 The EIA Policy (1995).  Namibia’s Environmental Assessment Policy for Sustainable Development and Environmental Conservation (1994).  The National Climate Change Policy of Namibia (September 2010).  Minerals Policy of Namibia (2004).  Policy for the Conservation of Biotic Diversity and Habitat Protection (1994).  Policy for Prospecting and Mining in Protected Areas and National Monuments (1999).

As the main source of legislation, the Constitution of the Republic of Namibia (1990) makes provision for the creation and enforcement of applicable legislation. In this context and in accordance with its constitution, Namibia has passed numerous laws intended to protect the natural environment and mitigate against adverse environmental impacts.

The management and regulation of mining activities and the proposed Solar PV project falls within the jurisdiction of the Ministry of Mines and Energy (MME) (i.e. a power generation licence is required), with environmental regulations guided and implemented by the DEA within the MET.

The Section below summarises the various applicable laws and policies.

SUMMARY OF APPLICABLE ACTS AND POLICIES

ML 171 falls within an officially protected area, proclaimed under the above Namibian Nature Conservation Ordinance of 1975. However, the mine does not fall within a specific zone within the Park to be excluded from prospecting and mining, in terms of the recent National Policy on Prospecting and Mining in Protected Areas, compiled by the Ministry of Environment and Tourism and Ministry of Mines and Energy (Anon. 2018).

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On an international level, Namibia is a signatory to the international Convention on Biological Diversity, a legally binding instrument for the global conservation and sustainable use of biological diversity.

The Convention on Migratory Species has developed an inter-governmental treaty known as the African-Eurasian Migratory Waterbird Agreement (AEWA). Namibia is classed as a range state but, although guided by the principles of AEWA, is not yet a contracting party to this international agreement.

The study area falls within an Important Bird Area (IBA). Several other IBAs have been identified in the greater study area. IBAs are sites regarded as being of international significance for the conservation of birds at the Global, Regional (Continental) or Sub-regional (southern African) level, selected according to stringent criteria. However, not all IBAs have official protection.

In the context of the Husab Mine and associated linear infrastructure, also taking the proposed PV power project into consideration, there are several Namibian laws and policies currently applicable, summarised in Table 3-1.

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Swakop Uranium (Pty) Ltd 733.03107.00001 733.03107.00001 Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine activities and infrastructure - 12 July 2019 MW Solar PV Power Plant July 2019

TABLE 3-1: RELEVANT LEGISLATION, POLICIES, CONVENTIONS AND MANAGEMENT PLANS ETC.

YEAR NAME

economic

Other

Visual

hazardous &

hazardous Vibrations

Emissions to air air to Emissions

Safety & Health

Socio

(energy & water)

Emissions to land land to Emissions

(non

Emissions to water to Emissions

Impact on Land Land on use Impact

Noise (remote only) Noise

Emergency situations

Natural Resource Use Resource Natural

Impact on on Archeology Impact

Impact on biodiversity on Impact

(industrial & domestic) (industrial

(fumes, dust & odours) dust (fumes, 1990 The Constitution of the Republic of X X X X X X X X X X X X X Namibia of 1990 1997 Namibian Water Corporation Act, 12 of X X 1997 2007 Electricity Act, 2007 (No. 4 of X 2007) 2001 The Forestry Act 12 of 2001 X X X 2013 Water Resources Management Act 11 of X X X 2013 2004 National Heritage Act 27 of 2004 X X 2007 Environmental Management, Act 7 of X X X X X X X X X X X X 2007 2012 Regulations promulgated in terms of the X X X X X X X X X X X X X X Environmental Management, Act 7 of 2007 1969 Soil Conservation Act, 1969 (No. 76 of X X 1969) 1975 Nature Conservation Ordinance 14 of X X X X 1975

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YEAR NAME

economic

Other

Visual

hazardous &

hazardous Vibrations

Emissions to air air to Emissions

Safety & Health

Socio

(energy & water)

Emissions to land land to Emissions

(non

Emissions to water to Emissions

Impact on Land Land on use Impact

Noise (remote only) Noise

Emergency situations

Natural Resource Use Resource Natural

Impact on on Archeology Impact

Impact on biodiversity on Impact

(industrial & domestic) (industrial

(fumes, dust & odours) dust (fumes, 1976 Atmospheric Pollution Prevention X Ordinance 11 of 1976 1995 Namibia's Environmental Assessment X X X X X X X X X X X X Policy for Sustainable Development and Environmental Conservation 2004 Pollution Control and Waste X X X X Management Bill (3rd Draft September 2003) 1990 Petroleum Products and Energy Act, No. X X X X X X 13 of 1990

1992 Labour Act, 1992: Regulations for the X Health and Safety of Employees at Work

1974 Hazardous Substance Ordinance, No. 14 X X X X of 1974

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PROJECT DESCRIPTION

This Section provides a description of the proposed PV power project. Refer to Section 5 of this report for a comparative assessment of project alternatives relating to the proposed PV power plant and powerline.

INTRODUCTION

Current (approved) Husab Mine Power Supply Infrastructure

Power is currently supplied to the Husab Mine via a 132 kV NamPower above ground transmission line. This powerline feeds into the Husab Mine substation, located within the processing plant complex. Swakop Uranium also installed two generators with 2 MVA capacity each and four smaller generators with 500 kVa capacity each, for back-up power to the Husab Mine, processing plant and associated activities.

The “original” EIAs undertaken in 2010 /2011 for the Husab Mine and associated activities and infrastructure assessed the infrastructure and activities associated with the current (approved) power supply to the mine.

PROPOSED CHANGES TO THE POWER SUPPLY TO THE HUSAB MINE

Swakop Uranium (with CGNEI) proposes to augment the existing Husab Mine power supply infrastructure, as follows:

 The construction of a 12 MW Solar Photovoltaic (PV) arrays and modules.  The construction of associated infrastructure and services including a transmission line, operation and maintenance buildings, battery storage system and water supply infrastructure.

PHOTOVOLTAIC POWER GENERATION

Photovoltaics is a method of generating electrical power by converting solar radiation into direct current electricity using semiconductors that exhibit the photovoltaic effect. The photovoltaic effect is the process of converting light (photons) to electricity (voltage). Photovoltaic power generation uses solar panels composed of a number of solar cells connected in series containing a photovoltaic material. (Refer to Figure 4-1 for an illustration of a typical solar PV power plant).

When sunlight hits the solar cells, electrons inside gain more energy and create an electrical current. Inverters then convert the direct current (i.e. the unidirectional flow of electrons) into the alternating current (i.e. flow of electrons that periodically reverses direction), which is the form in which electric power would be delivered.

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FIGURE 4-1: A TYPICAL SOLAR PV ILLUSTRATION (JCM, 2019)

MODULES AND SOLAR ARRAYS

Due to the growing demand for renewable energy sources, the manufacturing of solar cells and photovoltaic modules has advanced considerably in recent years. There are a number of photovoltaic panel technologies, including (https://energypedia.info/index.php/Solar_Cells_and_Modules):

 Crystalline The most common material for solar cells is crystalline silicon, which is separated into multiple categories according to crystallinity and crystal size in the resulting ingot, ribbon or wafer. o Monocrystalline silicon PV cells are made from silicon wafers that are cut from cylindrical single- crystal silicon ingots. Monocrystalline silicon shows predictable and uniform behaviour, but is also the most expensive type of silicon. Modules consisting of monocrystalline silicon cells reach commercial efficiencies between 15% and 18%. o Polycrystalline or multicrystalline silicon PV cells are made from cast square ingots, which are large blocks of molten silicon, carefully cooled and solidified. They are less expensive to produce than monocrystalline silicon cells, but are marginally less efficient, with module conversion efficiencies between 13% and 16%.  Thin film

Thin-film technologies reduce the amount of light absorbing material required in creating a solar cell. Thin film cells are constructed by depositing extremely thin layers of photovoltaic semi-conductor materials onto a backing material such as glass, stainless steel or plastic. Thin film materials commercially used are amorphous silicon, cadmium telluride and copper-indium-(gallium)-diselenide. Although thin film cells are

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potentially cheaper to manufacture than crystalline cells, the majority have lower energy conversion efficiencies (an average 6% to 12% module efficiency).

PV POWER PLANT LOCATION

The proposed PV power plant will be located within ML 171, adjacent to (i.e. west) the Husab Mine processing plant (within the Husab Mine infrastructure). The proposed site was previously cleared and used as a temporary contractor’s camp site. The site currently is fenced off and consists of the following infrastructure:

The PV power plant will encompass an area of approximately 16.4 hectares (ha) (refer to Figure 1-2 and Figure 4-2) for the locality and infrastructure map). Only a portion of the camp site will however be used and some of the existing infrastructure will be dismantled and removed prior to constructing the proposed PV power plant and associated infrastructure.

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FIGURE 4-2: PROPOSED PV POWER PLANT AND ASSOCIATED INFRASTRUCTURE LOCATION ADJACENT TO THE PROCESSING PLANT

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ASSOCIATED INFRASTRUCTURE AND SERVICES

4.2.4.1 Powerline

Each photovoltaic sub-array unit will access to a 2.5 MW box-transformer with a voltage ratio of 33/0.8 kV. All transformers access to a collecting line. It is proposed that the 33 kV line coming from the output of the transformer station (i.e. PV power plant switch station) will be connected to the Husab Mine electricity network through a powerline running over a distance of approximately 1.2 km. With reference to Figure 1-2 and Figure 4-3, the yellow line represents a section of the powerline that will be buried, while the blue line represents a section of the powerline that will be placed on the existing cable tray (refer to Figure 4-4) to the Husab Mine substation.

4.2.4.2 Buildings

Various operations and maintenance buildings would be constructed to support the PV power plant, these will include:

No new main electrical substation and transformers would be required, as the proposed project would link directly into the existing Husab Mine substation.

4.2.4.3 Battery Storage

A pack of phosphate based lithium-iron batteries will be installed in prefabricated containers. The battery storage system will mainly be used to smooth the power generation curve, but could also function as short time standby power supply.

The batteries and management system will be installed in prefabricated containers.

4.2.4.4 Water supply requirements and storm water management

Water consumption during construction phase for this project consists of building construction water and domestic water.

The solar panels will be exposed to several external agents (dust, sand, pollution, etc.), which would cause a gradual degradation of the modules and affect their productivity. For this reason, cleaning of the modules is essential to ensure optimum efficiency. A high efficiency cleaning system that uses water is the preferred method to be used to clean the panels. A water tanker (truck) will be utilised to supply water for the cleaning of the panels.

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Swakop Uranium constructed storm water channels to the north and north-east of the site, collecting and diverting (clean) storm water around the processing plant and the site where the PV power plant is proposed (previously the construction camp), into a natural drainage channel, which flows towards the Khan River. Another storm water channel, to the east of the proposed PV power plant site, divert potentially contaminated water from the Husab Mine Salvage Yard to the process pond. Refer to Figure 4-3 for the location of these channels.

The storm water from the proposed PV power plant site naturally flows unto the ground surface and further flows into the existing storm water drainage channel, south of the site (see Figure 4-3). This channel flows in a south-western direction, towards a small (natural) drainage channel (see Section 6.4). However, Swakop Uranium has previously blocked this storm water channel due to previous contamination from the process ponds, to avoid contaminated water entering the surrounding environment. Storm water directed to this channel will therefore be blocked from flowing further south-west and will evaporate (see Figure 4-3).

The water requirements are as follows:

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Storm water channel – routing potentially contaminated storm Storm water channels constructed water from the Salvage Yard to by Swakop Uranium to divert the process pond (clean) storm water around the site

Construction camp (Proposed PV power plant site)

Proposed PV power plant Stormsite water (Construction channel (blocked) camp)

Natural drainage channel

FIGURE 4-3: EXISTING STORM WATER INFRASTRUCTURE AROUND THE PROPOSED PV POWER PLANT SITE

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FIGURE 4-4: EXISTING HUSAB MINE CABLE TRAY

4.2.4.5 Access Roads

No new access roads will be constructed. All project activities will follow the existing Husab Mine access routes.

4.2.4.6 Fencing and Lighting

The proposed project location at the temporary construction camp is already fenced off and includes existing lighting infrastructure, previously approved as part of the Husab Mine infrastructure. However, additional lighting will be provided (i.e. hanging lamps at the switch station).

4.2.4.7 Electricity Supply

Electricity for back-up energy for the security system and lighting at night would be obtained from the existing Husab Mine power supply.

4.2.4.8 Ablution Facilities

The existing ablution facilities within the temporary construction camp will be used during construction and operations of the proposed PV power project. Where required, these will be upgraded.

4.2.4.9 Automated Fire Alarm Design

The fire protection design of this project implements the design principle of "giving priority to prevention and combining prevention with elimination".

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The electrical equipment of this project is fire-proof (no oil equipment, fire-resistant cable). Attention will be given to fire-proof cable facilities. The spacing of buildings will meet the fire safety requirements. Evacuation passages, accident lighting and evacuation signs will be installed in the buildings. Mobile fire extinguishers will be installed according to the relevant regulations. There will be a fire engine access of ± 6 m wide in the plant area.

The power supply of the fire detection and alarm system will be connected by uninterrupted power supply, and a communication network will be installed at critical locations.

4.2.4.10 Waste Management

Construction Waste

As part of the Husab Mine’s Waste Management Strategy, the construction contractor will be responsible for the frequent removal of general and recyclable waste from the PV power plant area and implement the approved Husab Mine Waste Management Plan and relevant procedures. Hazardous (including hydrocarbon) waste will be stored and removed/disposed of, as per the approved Husab Mine Waste Management Plan and relevant procedures.

Waste will be separated at source, stored in a manner that there can be no discharge of contamination to the environment and either recycled or reused where possible. The remainder will be transported off site to appropriate recycling or disposal facilities (in Swakopmund and/or Walvis Bay).

Table 4-1 presents the waste management specification that has been developed for the proposed PV power project and outlines the waste management for all waste types. In summary, the types of waste expected to be generated during the construction phase include:

 General waste and recyclable waste (domestic waste and other non-hazardous waste);  Industrial waste;  Hazardous waste (likely very small quantities).

TABLE 4-1 WASTE MANAGEMENT FOR CONSTRUCTION PHASE

WASTE WASTE SPECIFICS STORAGE FACILITY END USE TYPE (EXAMPLE OF WASTE TYPES) NON- Pallets and wooden Skips and/or wheelie bins in Waste will be sorted and HAZARDOUS crates, cable drums, relevant work areas will be recyclable waste will be sent to a WASTE scrap metal, general provided for different waste reputable recycling company. domestic waste such types. The remainder of the waste will as food, PPE and be transported by a waste packaging. Plastic management contractor to a packaging. permitted general landfill facility as part of the Husab Mine Waste Management Plan. Building rubble and Designated rubble collection The waste management waste concrete points will be determined to contractor will regularly remove the waste from the designated

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WASTE WASTE SPECIFICS STORAGE FACILITY END USE TYPE (EXAMPLE OF WASTE TYPES) which contractors will take collection points for disposal, in rubble and concrete. line with the approved Husab Mine Waste Management Plan. HAZARDOUS Hydrocarbon Hazardous waste will be Hazardous waste will be SOLID WASTE contaminated waste, separated at source and disposed of at the permitted treated timber crates, stored in designated hazardous disposal site in Walvis printer cartridges, containers in dedicated Bay by the waste management batteries, fluorescent bunded storage areas and/or contractor, in line with the bulbs, paint, solvents, in dedicated wheelie approved Husab Mine Waste empty hazardous bins/skips. Management Plan. Grease will material containers, be removed to a permitted PPE, etc. disposal site in Walvis Bay by the waste management contractor, in line with the approved Husab Mine Waste Management Plan. Hydrocarbons (oils, Used oil and grease will be Used oil will be sent to a grease) stored in drums in dedicated reputable recycling company for bunded areas. The bunds will recycling and as part of the be able to accommodate Husab Mine’s Hazardous Waste 110 % of the container Management Plan. contents and include a sump and oil trap. The storage area will include a concrete slab, proper bunding and an oil sump. Sewerage Either chemical ablution Chemical ablution facilities: facilities will be used, that will Sewage will be collected by a be regularly cleaned and waste contractor for disposal off removed off site, or the site at a licence facility, existing ablution accordingly with the Husab Mine infrastructure will be used Waste Management Plan. that feeds into the main Existing ablution infrastructure: sewerage system and end Discharged into the Husab STP. point is the sewerage treatment plant (STP). MEDICAL Medical waste such Medical waste will be stored Medical waste will be WASTE as material with in sealed containers at the transported by the waste blood stains, first aid station/on-site management contractor to a bandages, etc. medical facility. permitted incineration facility according to the Husab Mine Waste Management Plan.

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Operational Waste

The likely waste to be generated during maintenance of the PV power plant include:

 Waste cables; and  damaged PV modules

The occurrence of such waste is a random event, and the quantities per annum is generally very small (if any).

The waste generated by the daily activities of labor at site during operations and maintenance work will be handled and disposed of in line with the existing, approved, Husab Mine Waste Management Plan and relevant procedures, including, amongst others suitable storage, recycling wherever possible and disposal by a local waste management contractor.

PROJECT PHASES

4.2.5.1 Construction Phase

In broad terms, construction activities would include:

 Establishing site access in line with the current Husab Mine access system;  Site preparation involving limited landscaping within the footprint of the site, 16.4 hectares. The entire site is already disturbed;  Establishment of working areas, stores and construction staff amenities (existing ablution facilities will be used during the construction phase);  Materials delivery and laydown / storage;  Materials handling and civil construction works;  General building activities (i.e. painting, grinding, welding, concrete mixing, etc.)  Power and water use; and  Waste generation and management.

During construction approximately 100 people (peak) would work on site over a period of ± 8 months. The construction workers would be sourced, as far as possible, from the local labour force in and around Swakopmund, Arandis and Walvis Bay.

The appointed contractor would transport their workers to and back on a daily basis.

4.2.5.2 Operational Phase

In broad terms, operational activities would include:

 Electricity generation;  Module cleaning;  Maintenance and repair;  Delivery and storage of operational consumables;  Power and water use; and  Waste generation and management.

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It is envisaged that approximately 4 people would be permanently employed during the operational phase of the project. It is proposed that local labour from Swakopmund, Arandis and Walvis Bay would be employed as far as possible. For maintenance (i.e. scheduled maintenance period), an additional 3 people would be required on a contract basis.

Cleaning of the PV modules would be undertaken depending on exposure to dust which can cause a decrease in the performance. For this reason, cleaning of the modules is essential to ensure their efficiency. Module cleaning would be carried out by using water as detailed in Section 4.2.4.4. A water bowser and chemical fire retarding agents would be available on site for fire-fighting purposes.

4.2.5.3 Decommissioning and Closure

A generation licence is valid for a period of 25 years after which the licence would be renewed or the power plant decommissioned and the site rehabilitated. In broad terms, decommissioning activities would include:

 Disconnection from the Husab Mine Substation;  Dismantling and removal of PV modules and associated infrastructure (inverters, transformers, powerline, etc.);  Demolition and removal of buildings (including septic tank) and concrete structures;  Removal of waste and decommissioned components; and  Rehabilitation of disturbed areas.

The proposed PV power plant and associated infrastructure will be incorporated into the overall Husab Mine Closure Plan.

4.2.5.4 Project Schedule

The implementation of the project is dependent on the approval of the EIA amendment (ECC) by MET as well as the issuing of a Generation Licence by the Ministry of Mines and Energy (MME). Provided the necessary authorisations have been obtained, construction of the proposed project is planned to commence during the 4th Quarter of 2019.

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PROJECT ALTERNATIVES

This Section describes the various alternatives, with advantages and disadvantages, which were considered during the process to determine the preferred project plan, being assessed in more detail in Sections 8 and 9.

Project alternatives that have been considered during the EIA are described in the Sections below.

PV POWER PLANT LOCATION (I.E. SITE) ALTERNATIVES

The selection of the site was based on a number of factors, including: proximity to the Husab Mine processing plant; site access; and land availability.

With reference to Section 4.2.3, the proposed PV power plant will be located adjacent to the Husab Mine processing plant. The proposed site was previously used as a temporary contractor’s camp site, with relevant infrastructure in place, suitable for the proposed PV power project – i.e. fencing, ablutions facilities, storm water control, etc.

By utilising an already disturbed area (within the Husab Mine infrastructure) would minimize cumulative environmental impacts.

Furthermore, with the site being near the existing Husab Mine substation, ensures that the powerline will be relatively short, saving on costs and further reducing cumulative environmental impacts.

Other site locations were therefore not deemed feasible.

LAYOUT AND SOLAR ARRAY ALTERNATIVES

CGNEI has analysed several possible layout options for the PV plant, among others:

 Fixed mounted structure versus 1-axis tracking  Various types of modules (crystalline, thin-film)  Various types of inverter technology (central versus string technology)  Row distance between the trackers

The preferred system is the fixed-axis system with bifacial monocrystalline modules, string inverter technology is most suitable for the proposed PV project at the proposed site.

POWERLINE ROUTE OPTIONS

The powerline is required to connect to the Husab Mine Substation. The option of constructing the line above ground vs below ground was also considered. The preferred option is to connect the 33 kV line coming from the output of the transformer station (i.e. PV power plant switch station) to the Husab Mine electricity network through a powerline running over a distance of approximately 1.2 km. With reference to Section 4.2.4.1 and Figure 1-2 and Figure 4-3, the yellow line represents a section of the powerline that will be buried, while the blue line represents a section of the powerline that will be placed on the existing cable tray to the Husab Mine substation.

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The powerline route is constrained due to existing infrastructure associated with the Husab Mine processing plant and associated infrastructure and the remaining portion of the temporary contractor’s camp. By installing the line underground and on the existing cable tray minimises potential cumulative environmental impacts.

Another option would be an above ground powerline structure, i.e. using pole structures. This option would be more costly and potentially contribute to cumulative impacts on birds (i.e. collisions and electrocutions).

TECHNOLOGY ALTERNATIVES

Modules, invertors, transformers and switchgears

With reference to Section 4.2.2, there are a few different photovoltaic panel technologies, including: monocrystalline silicon PV cells, polycrystalline silicon PV cells and thin film. The commercial efficiencies of these different technologies range between 6-12% (thin film) and 15-18% (monocrystalline). The preferred option is to use monocrystalline silicon PV cells technology. However, there would be no additional environmental impacts or differences in impact significance relating to the other module technologies.

Mounting system

Two mounting system alternatives were considered, namely:

 Fixed frame: This is typically a rack mounted system of modules on frames and installed at a fixed angle. Fixed racks hold modules stationary as the sun moves across the sky; and  Single-axis horizontal trackers: Trackers follow the movement of the sun and tilt or rotate the modules to ensure maximum exposure to sunlight.

The preferred option is the “fixed frame technology”. The PV modules would be arranged to face the north, at an angle of 23° to capture solar radiation. A tracking system would be more complex and would have a potentially high failure rate.

Other than a slight difference in height above the ground (with the trackers potentially being slightly higher), it is not anticipated that there would be any additional impacts or differences in impact significance relating to the choice of mounting system.

Mounting supports for frames or trackers include the following alternatives:

 Pile mounts, which utilise a metal pile that is driven into the soil on which the main structural beam is mounted;  Foundation mounts, such as concrete slabs or poured footings; and  Ballasted footing mounts, such as concrete or steel bases that use weight to secure the solar module system in position and do not require ground penetration.

The preferred option is to use piled foundations. This option would reduce the actual development footprint slightly compared to the foundation and ballasted footing mounts.

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NO-GO OPTION

The No-Go alternative relates to the option of not developing the proposed 12 MW PV power plant, powerline and supporting infrastructure. In this case, the residual impacts (i.e. impacts after implementation of mitigation measures) of the proposed activities would not occur (refer to Section 7). The specific proposed project area (i.e. already disturbed area, previously the temporary contractor’s camp) would either be rehabilitated, utilised for other future development, or a portion of the current infrastructure left as it is until future rehabilitation.

The implications of not going ahead with the proposed project are listed as follows:

 Husab Mine will not have any cost savings on power supply;  The job creation anticipated during construction phase i.e. Engineering, Procurement and Construction (Labour recruitment) and poverty alleviation that would have occurred due to the development, would not take place;  In addition to the above, the renewable energy industry in Namibia will not benefit from jobs related to this PV project and the transfer of skills to the locals;  Without the implementation of this development, Renewable Energy options for future power supply would be compromised and fossil-fuel-based energy would possibly be used to supply for the growing demand. This could have potential (cumulative) negative environmental and social impacts, elsewhere;  There would be a lost opportunity to generate a ”cleaner” energy especially for the mining industry in the Erongo Region which could have significant benefits for the region and Namibia as a whole;  The Namibian electricity sector would continue to mainly rely on electricity imports from other sources (i.e. South Africa);  There would also be a lost opportunity to improve energy security and diversify the country’s energy mix.

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DESCRIPTION OF THE CURRENT ENVIRONMENT

This chapter provides a general overview of the current baseline conditions associated with the construction, operation and maintenance of the proposed amendment to the Husab Mine infrastructure, i.e. the 12 MW PV power plant project. The detailed baseline description of the environment (prior to the construction of the mine) were provided in the previous EIA Reports and will not be repeated here.

The Section was compiled utilising the following sources of information:

 Previous EIAs conducted for the Husab Mine (refer to Section 1.4.2);  Visual observations during site visit by SLR and the relevant specialist;  Atlas of Namibia;  Literature review;  Google Earth; and  Specialist report relating to the proposed PV power project: o Avifauna specialists input (Appendix 5).

Table 6-1 provides the key environmental aspects to be taken into consideration for the proposed project activities and infrastructure during the different project development phases (refer to Section 7 for more details relating to the identification of environmental aspects and potential impacts).

TABLE 6-1: KEY ENVIRONMENTAL ASPECTS TO BE TAKEN INTO CONSIDERATION DURING THE PROJECT DEVELOPMENT PHASES

Environmental aspect Construction Operation and Decommissioning maintenance Climate Yes Yes No Topography Yes Yes No Biodiversity Yes Yes Yes Surface Water Yes Yes Yes Ground Water Yes Yes Yes Air Quality Yes No Yes Visual Yes Yes No Archaeology Not Applicable Not applicable Not applicable

CLIMATE

The information presented in this Section has been sourced from the previous EIAs conducted for the Husab Mine and Linear Infrastructure and the Air Quality Specialists Report (Airshed, 2018).

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Temperature

Swakop Uranium’s Husab Mine has its own on-site meteorological weather station. There are three weather stations to the Husab Mine. Two are Davies (Installed October 2008 at Husab and Ida Camp Sites) and Campbell Scientific installed in May 2012 at Marble Ridge. The Marble Ridge Campbell weather station is a sophisticated weather station and produces quality data with good data availability. This weather station measures wind speed and wind direction 10 m above ground level whereas the Davies stations measure wind speed at 2 m above ground level.

Temperature data from the Marble Ridge, Ida Camp and Husab weather stations are presented in Figure 6-1. Site data indicates a temperature range from just over 30 to 40 degrees in summer months to lows of less than 15 to 5 degrees in winter months.

FIGURE 6-1: MONTHLY AVERAGE TEMPERATURES AT ALL HUSAB STATIONS (AIRSHED, 2017)

Solar Radiation

Husab Mine is located 12 km south-east of Arandis. According to baseline information sourced from (NamEnergy, 2019), Arandis is located in a 4.98 kWh/m2/d solar radiation zone with the highest radiation zone amounting to more than 6.2 kWh/m2/d in the north east of Namibia.

Table 6-2 provides a summary of the Arandis Solar Resource Assessment.

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TABLE 6-2 ARANDIS SOLAR RESOURCE ASSESSMENT (NAMENERGY, 2019)

Precipitation and fog

The Husab Mine is situated within a rainfall belt of less than 100 mm/year. As is typical of arid areas, rainfall can vary considerably and can be of great intensity and depth when it occurs.

The Department of Water Affairs operated a rainfall station at Tinkas (just south east of Langer Heinrich Mine, approximately 50 km south east of Husab Mine) from June 1983 until June 2007 (when the instrument was removed). The Tinkas rainfall data has a mean annual precipitation of 29.7 mm and the maximum daily rainfall recorded was 33.3 mm on the 30th of January 1990.

Regular fog from condensation occurs on site and is an important water source for biodiversity in the desert. Swakop Uranium started monitoring fog at three weather stations from 2018. These monitoring results are not yet available.

Swakop Uranium has a network of rain gauges across the ML & EPL area, which record rainfall and three weather stations that record rainfall and produce intensity data. From the available data it can be seen that there have

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Swakop Uranium (Pty) Ltd 733.03107.00001 733.03107.00001 Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine July 2019 activities and infrastructure - 12 MW Solar PV Power Plant July 2019 been six months in the past 6 years where rainfall has been exceeding 20 mm and the maximum 1-hour intensity has been recorded at 24.8 mm.

The mean annual rainfall for the Husab Mine is indicated in Figure 6-2 below.

FIGURE 6-2: AVERAGE ANNUAL RAINFALL FOR NAMIBIA, INCLUDING HUSAB MINE (0-50 MM/A)

Surface Wind Field

The horizontal dispersion of pollution is largely a function of the wind field. The wind speed determines both the distance of downwind transport and the rate of dilution of pollutants. The generation of mechanical turbulence is similarly a function of the wind speed, in combination with the surface roughness.

Period, day- and night-time wind roses from the Marble Ridge weather station for the period January 2014 to December 2016 are shown in Figure 6-3. Seasonal variations in the wind field are shown in Figure 6-4. The wind roses comprise of 16 spokes, which represent the directions from which winds blew during a specific period. The colours used in the wind roses below, reflect the different categories of wind speeds; the yellow area, for example, representing wind speeds between 4 and 5 m/s. The dotted circles provide information regarding the frequency of occurrence of wind speed and direction categories. The frequency with which calms occurred, i.e. periods during which the wind speed was below 1 m/s are also indicated.

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From the Marble Ridge weather data (2014 to 2016), the wind field was dominated by winds from the southwest, west and northeast with less frequent, but strong winds from the northwest and very little from the southeast. An average wind speed of 3.3 m/s was measured over the period. Day-time wind field was similar to the periodic wind field with less frequent north-easterly flow, but with stronger winds from this direction. Night-time wind rose reflected an increase in easterly winds and a decrease in airflow from the west. The night-time airflow was characterised by lower wind speeds. The expected difference between day and night due to the land-sea interaction is demonstrated in this data set.

During summer, the prevalent winds occur from the west, west-northwest, west-southwest, northwest and southwest. The prevailing wind field during autumn occurs from the southwest and northeast, with less frequent winds from the west-southwest and western wind field. During winter season, the prevailing wind field also occurs from the southwest and a much stronger northeast component. The strongest winds occur from the northeast during this season, representing the so-called “Berg- or east-wind” conditions. An increase in the west- southwest and western wind field is observed during spring, with the prevalent wind from the southwest.

Period

Day-time Night-time

Figure 1: Period, day- and night-time wind roses (Marble Ridge weather station data, 2014 - 2016) FIGURE 6-3: PERIOD, DAY- AND NIGHT-TIME WIND ROSES (MARBLE RIDGE WEATHER STATION DATA, 2014 - 2016)

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FIGURE 6-4: SEASONAL WIND ROSES (MARBLE RIDGE WEATHER STATION DATA, 2014 - 2016)

TOPOGRAPHY

The study area is around 500 m above msl, although the Rössing Mountain to the west reaches 650 m.

The original EIAs (Metago 2010, SLR 2013) described the general topography as follows:

“The Husab mine is located on a gently sloping plain that is distantly surrounded by hills and koppies. The Khan and Swakop River valleys occur to the north, northwest, south and southwest of the site. Water currently flows across the site from the north and northeast to the south and southwest in a series of shallow surface washes”.

The local topography has however changed since the mining and construction activities commenced.

Elevation data for the site was obtained from the United States Geological Survey (USGS) (https://earthexplorer.usgs.gov/) in the form of the global SRTM 30m digital elevation model (DEM) and this data is provided in Figure 6-5.

The site where the PV power plant will be constructed is relatively flat, gently sloping from north to south.

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FIGURE 6-5: DEM DATA FOR THE GENERAL AREA SURROUNDING THE INVESTIGATION SITE (WHITE INDICATES THE HIGHEST SECTIONS AND BLUE THE LOWEST) (TERRA SOIL, 2018)

The Swakop River, with its main tributary the Khan River and their smaller tributaries are a major topographical feature in the area.

GROUNDWATER

The information presented in this Section has been sourced from the EIA Amendment Groundwater and Surface Water Specialist Report (SLR, 2018).

Due to the generally high salinity of water in this desert environment, the Namibian National Water Quality Standards (“NWQS”) are not suitable to be used as a reference and therefore upper and lower limits (furthermore described as “baseline”) were established (in consultation with SU staff) for individual boreholes from available historic data (SLR, 2017 Quarterly groundwater monitoring). The aquifer system around the Husab Mine project is referred to as saturated alluvium. Borehole yields and storage for the saturated alluvium associated with the Husab plain and the bedrock aquifers are generally low, with yields from the bedrock aquifers generally below 1 L/s and yields in the saturated Husab plain alluvium dependent on recharge from surface run- off/rainfall which is generally low.

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Water levels in the shallower alluvial aquifers range from near surface to 20 m below surface. Water levels in the bedrock aquifers (not associated with the proposed Project site) range in depth below surface from 56 to 130 m.

SURFACE WATER

Regional Hydrology

ML 171 encompasses an area that lies between the Swakop and Khan Rivers. The catchment area up-stream of the Husab Mine site is approximately 34 500 ha or 345 km2. A catchment divide splits the area so that part of the mining site drains towards the Khan River and the major part drains via a number of small natural water channels towards the Swakop River.

Local Hydrology

The site for the proposed PV power plant is located near a catchment divide, within a relatively small catchment area, when compared to the much bigger ‘Husab Catchment’. Minor drainage lines have already been impacted by the process plant and associated infrastructure, within this catchment area. There are no drainage lines flowing through the site, however a relatively small drainage line is located south-west of the site. This drainage line flows in a south-westerly direction, towards the Khan River, and is home to amongst others a few Welwitschias, Camel Thorn Trees (Acacia erioloba), etc. (refer to Section 6.5 for more details on biodiversity).

With reference to section 4.2.4.4, storm water flowing from the north of the site is diverted around the site through existing storm water channels, previously constructed by Swakop Uranium (refer to Figure 4-3).

Soil

The dominant soils in the region is Petric Gypsisols and Petric Calcisols (Mendelsohn et al. 2002).

The proposed PV power plant site has already been previously disturbed (for the construction of the temporary contractor’s camp). The topsoil has therefore already been removed, mostly in 2013, from this area to the nearest topsoil stockpile north of the construction camp.

BIODIVERSITY

Biodiversity in and around the proposed PV power plant site

The Husab Mine is situated within the Namib Naukluft National Park (NNNP) and adjacent to the ≠Gainqu Communal Conservancy. The area falls within the Namib Desert Biome. The vegetation type is classified as Central Desert; dominant structured sparse shrubs and grasses; and dominant landscape mainly Central-western Plains (Mendelsohn et al. 2002).

The proposed PV power project site is located within a previously disturbed area (i.e. the Husab Mine temporary contractor’s camp site) adjacent to the processing plant. Therefore, the local environment is exposed and harsh with almost no vegetation remaining on site (refer to Figure 6-6).

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Swakop Uranium’s Environmental Section did however establish a small area inside the contractors’ camp site where some important (protected) vegetation species were transplanted during construction, prior to specific areas for the development of the mine and processing plant were cleared. This area (and vegetation) will not be impacted by the proposed PV power development.

FIGURE 6-6: THE PROPOSED SITE FOR THE SOLAR PV DEVELOPMENT ON THE HUSAB MINE, LOOKING NORTH- EASTWARDS; NOTE THE PREVIOUSLY DISTURBED, OPEN HABITAT (ACS, 2019)

The area surrounding the site contain some vegetation species, i.e. Pencil Bush and Dollar Bush, as well as Welwitschias (Welwitschia mirabilis) growing in the downstream drainage line and on the plain south and southwest of the site and Camel Thorn Trees (Acacia erioloba), also growing in the drainage line. The latter two species are both protected.

Avifaunal environment

The information presented in this Section has been sourced from the Avifauna specialists study (ACS, 2019) (Appendix 5).

The NNNP is an Important Bird Area, and forms a group together with several other IBAs on the coast (around 40 km away), namely Mile 4 Saltworks and the 30 km Beach: Walvis Bay-Swakopmund, with the extensive Walvis Bay wetlands to the south.

With its narrow linear aquifer and concentrations of large trees and bushes, the Khan River (close to the mine) forms a habitat that is attractive to birds; it also serves as an important flight corridor for their movements between the coast and inland. Occasional flooding conditions on the river are likely to bring an influx of food for birds, and to attract nomadic species including waterbirds. The presence of artificial water bodies/irrigation schemes in an otherwise arid environment is an additional attraction to wildlife.

Although the location of the study site within a formally Protected Area and Important Bird Area (as described above) would imply a class of high avifaunal sensitivity, the mine habitat is already developed/disturbed, and in

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Swakop Uranium (Pty) Ltd 733.03107.00001 733.03107.00001 Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine July 2019 activities and infrastructure - 12 MW Solar PV Power Plant July 2019 close proximity to very high levels of disturbance from mining activities, all of which would decrease the avifaunal sensitivity to some extent.

Due to the potential sensitivity of waterbirds to solar PV developments, existing open-water structures in the area were also considered during the assessment, as they have the potential to attract aquatic birds to the area. The proximity of such water bodies may increase the risk of impacts, as the birds are already accustomed to using such habitats in the area. These bodies include a run-off dam east of the study site, a larger process pond with relatively fresher water (where waterbirds such as Three-banded Plover were observed), and several other process ponds further to the east. Other waterbirds have also been recorded in these habitats, mainly at the pond with fresher water, including grebes and teal, and one Lesser Flamingo.

A large Tailings Storage Facility (TSF) of around 400 ha to the south of the site was also investigated. A large group of around 30 Lesser Flamingos was reported to have landed at the TSF in February 2019. Prior to this, groups of up to 30 Great White Pelicans and 2-10 flamingos have been recorded at the TSF, usually arriving at night and leaving towards the middle of the next day. These records indicate the attraction of any open water body to these waterbirds in an arid environment, despite the quality of the water, and including as an overnight roosting site during flight movements.

6.5.3.1 Sensitivities in terms of bird species

The sensitivities of the bird species in the study area are discussed below, according to relevant criteria. Due to the number of species involved, the focus is on priority species, defined as those that are biologically important (Red Data [including migrants] and endemic species), and including waterbirds, and raptors and other species that are collision-sensitive. The 19 priority species are summarised in the Avifauna specialists report (Appendix 5).

6.5.2.1.1 Bird Diversity

A total of 170 bird species was recorded for the overall study area. This represents 25% of the 676 species currently recorded in Namibia, a diversity that is regarded as relatively low. Only a few species were observed during the site visit; these included a Rock Kestrel perched near the dam with fresher water.

6.5.2.1.2 Red Data status

Fourteen (8%) of the species within the study area are currently classed as Threatened in Namibia (Brown et al. 2017), of which seven (4% of the total) are also Globally Threatened. One further Red Data waterbird, Cape Cormorant (Endangered and also Globally Endangered), has been recorded in the area once, but is considered as a vagrant and unlikely to occur on a regular basis, being a marine species.

6.5.2.1.3 Endemism

Within the study area, six species (3% of the total) are classed as near-endemic to Namibia, with >90% of their populations in this country. This level of endemism (19% of the 16 endemic or near-endemic bird species in Namibia) is relatively low-moderate. Having a restricted distribution renders a species more vulnerable to impacts such as habitat destruction, disturbance and displacement.

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6.5.2.1.4 Residency/ migrant status

Nomadic/migrant habits result in high mobility and consequently increase the risk of impacts such as collisions. It should be emphasised that both short-term, local movements and longer-distance movements are possible. This is particularly true under the changing conditions associated with a relatively arid climate and an ephemeral river system such as the Swakop/Khan system. Nomadic and/or migrant species of concern, however, other non- Red Listed, non-endemic nomadic/migrant species may also be at risk to these impacts.

6.5.2.1.5 Determination of the avifaunal sensitivity of the study area and species at risk

The quantity and quality of baseline data required to inform the assessment process at the proposed solar PV site is based on the size of the site and the predicted impacts of the solar technology in question, namely PV; the anticipated sensitivity of the local avifauna (for example, the diversity and relative abundance of priority species present, proximity to important flyways, wetlands or other focal sites); and the amount of existing data available for the area.

For the purposes of the present study, the size of the proposed 15 ha development was classed as small (<30 ha). The location of the site within a formally protected area and Important Bird Area (namely the Namib Naukluft National Park), and its proximity to the ephemeral Swakop/Khan River system (an important bird habitat and corridor), would imply a class of high avifaunal sensitivity but, given that the study area is in a previously developed/disturbed habitat, in close proximity to very high levels of disturbance from mining activities, the avifaunal sensitivity was classed as medium.

The above classification results in a Regime 1 approach to the assessment, where the design of a site-specific survey and monitoring project is thus not deemed necessary as yet; however, monitoring is essential, the results of which would be taken into account for an adaptive approach should any further mitigation be required.

Due to the number of species involved in the present study, risk assessment and mitigation efforts are directed towards those that have a high biological significance, i.e. primarily Red Data species (including those with migrant status) and/or endemic species.

The 19 (priority) species considered at potential risk are summarised in

TABLE 6-3 (refer to Appendix 5 for more details regarding these species). All of these species are at risk to potential collisions with solar PV structures, although to varying degrees (depending on factors such as habitat requirements, adaptation to or avoidance of human disturbance, etc.).

Of the priority species, five Red-listed waterbird species are of particular concern with regard to potential collisions with solar PV structures, including two that are intra-African migrants; however, there are many more waterbirds (at least 38 species in total) that could occur in the study area and be placed at similar risk.

At least 21 raptor species have been recorded in the study area, six of which are Red-listed. Although these species have the potential to become involved in collisions with solar PV structures, the likelihood in the present context is considered very low; however, monitoring is essential as a precautionary measure.

Six of the priority species are near-endemic to Namibia, including at least two with the potential to be attracted to the new habitats created by the solar PV development.

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No priority species have been reported to breed in the proposed development site; however, a juvenile Rock Kestrel was recorded at one of the dams in the mine area; and at least one resident pair of Verreauxs' Eagles is found in the adjacent Khan River Valley area.

TABLE 6-3: CHECKLIST OF PRIORITY BIRD SPECIES RECORDED WITHIN THE HUSAB MINE AREA, IN TERMS OF THE PROPOSED PV POWER PROJECT (SEE BELOW FOR KEY)

Species name Group Habitat Impact Probability

A. High priority species with the potential to be impacted by the proposed development

Flamingo, Lesser W Aquatic CS L-M Flamingo, Greater W Aquatic CS L-M Pelican, Great White W Aquatic CS L-M Grebe, Black-necked W Aquatic CS L-M Duck, Maccoa W Aquatic CS L

Korhaan, Rüppell's LTB Gravel plains, watercourses CS L-M N

Lark, Gray's O Gravel plains, watercourses CS L N B. Priority species less likely to be impacted by the proposed development

Babbler, Bare-cheeked O Thickets, dry watercourses All have the potential to be Chat, Herero O Arid inselbergs, sparse woodlands involved in collisions with solar PV structures (CS); Bustard, Kori LTB Open savanna - woodland however, the probability is Bustard, Ludwig's LTB Gravel plains, shrublands very low/ unlikely Eagle, Martial R Savanna, semi-desert Eagle, Verreauxs R Cliffs, mountains Eagle-Owl, Cape R Cliffs, gorges, mountains Falcon, Peregrine R Cliffs, savanna Parrot, Rüppell's O Wooded, savanna Tit, Carp's O Woodlands, hillsides Vulture, Lappet-faced R Semi-arid woodland, plains Vulture, White-backed R Semi-arid woodland, plains

Key: Group: R = raptor; W = waterbird; LTB = large terrestrial bird; O = other Impact: CS = collision (solar PV structure); N = attracted to new habitats on/under solar structure (a potentially positive impact)

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Probability: Probability: H = high; M = moderate; L = low; VL = very low; N = not probable

AIR QUALITY

The project area is on an already disturbed area with barren soils and no vegetation cover. This exposes the soils to winds and generating a relatively dusty environment during construction activities and machinery movement. Furthermore, there are few gravel routes in the surrounding area and any traffic will generate dust. The current (approved) operational activities generate dust, however Swakop Uranium implements monitoring and mitigation measures to minimise the dust impacts.

ARCHAEOLOGY

The site has already been disturbed and contain no archaeological artefacts of importance. Furthermore, the original EIAs for the Husab Mine did not identify any archaeological sites within, or adjacent to, the site boundaries.

VISUAL

The visual landscape is determined by considering: landscape character, sense of place, aesthetic value, sensitivity of the visual resource and sensitive views. In this regard, the original EIAs (prior to the mine being developed) considered the study area to be a significant visual resource.

The greater landscape character is defined by flat rolling topography, sloping toward the south. The overall background in the context of Husab Mine project location includes hills, koppies, river canyons, natural vegetation, washes (i.e. drainage lines) and mountains.

The sense of place results from the combined influence of the landscape on all of the viewers’ subjective senses. When viewed from the perspective of a tourist, the original natural landscape (as assessed prior to the mine development) is associated with a serene and tranquil sense of place. The tourist attractions and guest/farm houses further afield evoke excitement and anticipation. The exploration and mining activities are associated with a sense of disenchantment, particularly to people not involved with the mines in question. The mining and processing infrastructure and activities have already influenced the original visual environment and sense of place.

The proposed PV project site, which was previously developed (i.e. contractor’s camp), is adjacent to the processing plant and was included in the original (approved) EIAs. The visual impact associated with this site and infrastructure, forming part of the overall Husab Mine development, was cumulatively assessed in these EIAs, with all other activities, facilities and infrastructure.

SOCIAL

The social (and economic) baseline of the region was described in detail in the original (approved) EIAs for the Husab Mine and associated infrastructure and will not be repeated here.

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It must however be recognised that the construction of the Husab Mine, together with other mining developments, as well as other expected mining developments (i.e. the so called “Uranium Rush” - when the Uranium price was much higher than the current situation); the upgrading of the Walvis Bay Port; and developments in other sectors in the Erongo Region, caused inward migration to the central coastal towns of Namibia during the last couple of years. This inward migration is the cause of various social impacts.

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IDENTIFICATION AND DESCRIPTION OF POTENTIAL ENVIRONMENTAL IMPACTS THAT ARE LIKELY TO CHANGE AS A RESULT OF THE PROPOSED AMENDMENTS

This chapter outlines the environmental aspects and potential impacts that could change as a result of the proposed projects (i.e. amendment to the existing Husab Mine activities and infrastructure), taking the approved Husab Mine EIAs into consideration. It identifies, with reasons, which environmental aspects need further assessment (Section 8) to compare the assessment findings of potential cumulative impacts with that previously assessed.

ASPECT AND IMPACT IDENTIFICATION

Table 7-1 and Table 7-2 below provides a summary of the activities associated with the construction and operational phase of the proposed PV power plant (including the powerline infrastructure) and the associated environmental aspects and potential impacts on the environment.

The decommissioning phase of the project will be part of the overall Husab Mine Rehabilitation, Restoration and Closure Plan. Activities will at a conceptual level be similar to those described for the construction phase.

The relevance of the potential impacts (“screening”) are also presented in the tables below to determine if certain aspects need to be assessed in further detail (Section 8 of this report). Because of the existing baseline information obtained from the Husab Mine and associated EIAs and the Avifauna specialist study to this project, as well as an additional site visit by the Environmental team, potential impacts can be assessed and the relevant management and mitigation measures to minimise or prevent the potential impacts, will be provided in Section 8.

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TABLE 7-1: ENVIRONMENTAL ASPECTS AND POTENTIAL IMPACTS ASSOCIATED WITH CONSTRUCTION PHASE OF THE 12 MW PV POWER PROJECT

ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTAL CONSTRUCTION IMPACT PHASE

1. Site preparation, earthworks, laydown areas and establish work areas  Site preparation  Clearing of Potential impact on PV Power Plant and powerline infrastructure and earthworks; vegetation biodiversity The footprint area of the proposed project is limited to 15 ha. The proposed project (physical impacts  Establishing of and soil site at the temporary contractor’s camp is already a disturbed site with little to no and general working areas and stripping vegetation cover and topsoil was already removed (refer to Section 6.5 and Figure 6-6). disturbance) stores, waste  Using of Limited site preparation and earthworks is therefore required. management earthmoving facilities and equipment Swakop Uranium would need to dismantle / remove the existing infrastructure construction staff and (associated with the contractor’s camp), prior to the establishment of the PV plant amenities; machinery infrastructure. Most of this material would be sold / recycled, donated or re-used elsewhere on the mine.  Drilling activity for  Waste installation of generation Existing access roads to the site will be used to deliver material and workers. The site Solar Panel is already fenced off and no activities will be conducted outside the footprint of the R01 structures site (i.e. workers will be restricted to the site boundaries), therefore no impact to the (Modules). natural vegetation outside the site boundaries could occur.  Trenches for Trenching for ground cable laying and installations will also be conducted along a route ground cable that has been previously disturbed. laying. Taking the above mentioned into consideration, potential impacts on biodiversity by  Materials delivery the construction activities associated with the PV power plant and powerline and laydown / infrastructure is unlikely. However relevant measures are stipulated in the EMP storage. (Section 9) to ensure the workers and activities are carefully managed in line with the approved Husab Mine (and associated infrastructure) EMP, policies and procedures, and NNNP Park Rules.

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ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTAL CONSTRUCTION IMPACT PHASE

Potential impact on The potential impacts on archaeological sites as part of the Husab Mine infrastructure archaeological has already been assessed in the original (approved) EIAs for the Husab Mine resources infrastructure and associated activities. With reference to Section 6.7, The site has already been disturbed and contain no archaeological artefacts of importance and this R02 issue will not be further assessed.

A chance find procedure has however been included in the EMP and relevant procedures are in place.

Interruption of Activities related to the overall construction of the proposed Solar PV Project i.e. drainage and stripping, trenching are similar to that already assessed in the initial EIA for the Husab interference with Mine infrastructure and approved design plan. water flow. With reference to Section 6.4, minor drainage lines have already been impacted by the Increased storm process plant and associated infrastructure (including the contractor’s camp site), water flows, within the catchment area of the site and there are no drainage lines flowing through reduced infiltration the site. Also, the proposed project site at the temporary contractor’s camp is already and increased risk a disturbed site with little to no vegetation cover and topsoil was already removed. of erosion. With reference to Section 4.2.4, storm water flowing from the north of the site is R03 diverted around the site. Therefore, only storm water falling on the site and future PV panels will therefore naturally flow unto the ground surface and further flows into the existing storm water drainage channel, south of the site. The storm water management will therefore not change as a result of the proposed PV project development (i.e. the existing rainwater flow will not change significantly as a result of the proposed PV power project).

The interruption of draining and interference with surface water flow; as well as the risk of erosion is therefore regarded as insignificant and will not be assessed further in this report.

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ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTAL CONSTRUCTION IMPACT PHASE

Noise Increase in There are various construction activities (particularly the movement of vehicles) generation disturbing noise relating to the proposed project that would generate noise on site. It must however from levels (nuisance) be taken into consideration that the activities will be conducted adjacent to the earthmoving existing Husab Mine processing plant. equipment and R04 machinery The initial and approved EIA already assessed the overall noise impacts related to the overall Husab Mine infrastructure and the contribution of proposed PV power project activities is regarded minimal and will not be further assessed.

Dust and Increase in dust There are various activities or sources (particularly dust generating sources due to an gaseous levels (nuisance & already cleared site and movement of vehicles) relating to the proposed project that emissions from health impacts) can pollute the air and cause resultant potential impacts (i.e. nuisance impacts and / earthmoving or health) on humans and the surrounding environment. The gaseous emissions, in equipment and comparison to the particulates, are small with much lower impact significance. machinery It must also be taken into consideration that the activities will be conducted adjacent R05 to the existing Husab Mine processing plant and near the mining activities. The current (approved) mining activities generate dust and monitoring and mitigation measures are already existent.

The increase in ambient dust levels will however be qualitatively assessed in Section 8.

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ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTAL CONSTRUCTION IMPACT PHASE

Possible Contamination of Construction activities could result in the contamination of soil, surface water hydrocarbon surface water and resources and groundwater. Potential sources of contamination include the leakage of spillages from groundwater oils and fuels, accidental spills, maintenance activities, wear and tear of hazardous earth moving resources and containers stored in the sun and the disposal of waste and wastewater. equipment and pollution of soil Pollution to the groundwater quality is less likely due to the magnitude of the project during R06 activities activity during the construction process. The project design and implementation associated with should aim to prevent pollution of groundwater. hazardous These potential impacts are assessed in Section 8. substances management

2. PV plant and underground powerline construction Installing panels, Construction Potential impact on Refer to R01. (No further assessment required). inverters, tracking activities biodiversity system, powerline, disturbing/ (physical impacts R07 etc. destroying and general biodiversity disturbance)

Interruption of Refer to R03. (No further assessment required). drainage and interference with water flow

Possible Contamination of Refer to R06 and Section 8 for the assessment of the potential impacts on surface hydrocarbon surface water and water, groundwater resources and pollution of soil.

spillages from groundwater earth moving resources and R08 equipment pollution of soil

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ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTAL CONSTRUCTION IMPACT PHASE

General building Spillage of Impact on surface Refer to R03 and R06 above. activities (i.e. paint, water and painting, grinding, concrete, etc. groundwater water Some of the construction activities (i.e. painting, mixing of concrete, etc.) could R09 welding, concrete quality result in the contamination of the surface water resources and groundwater. These mixing, etc.) potential impacts are qualitatively assessed in Section 8.

3. General Waste management Waste Emissions to land. Activities relating to the above mentioned will generate waste that needs to be management Land degradation managed. The packaging material covering the PV panels will, amongst others and disposal and impact on the contribute to a relatively significance waste source, once the panels get installed. The NNNP and existing contractor’s camp ablution facilities will be used where required, however the biodiversity. option of mobile toilet facilities where required is not omitted. Nuisance (visual) impacts to tourists. Waste generation is likely to be limited on site. This material will be stored properly until safe disposal off-site, in line with the approved Husab Mine Waste Management R10 Plan and relevant procedures. Swakop Uranium (with CGNEI) however need to investigate means of minimising the usage of plastic/Styrofoam packaging, through the procurement of the PV infrastructure, taking into consideration the project site is in the NNNP. Through the effective implementation of the management and mitigation measures, as described in the EMP the potential impacts relating to waste management can be avoided/mitigated. No further assessment is required.

Refuelling of Hydrocarbon Emission to land, Refuelling activities could cause hydrocarbon spillages which could result in the equipment spillages pollution of surface contamination of the surface water resources and groundwater. Refer to R06 and and groundwater Section 8 for the assessment of the potential impacts on surface water, groundwater resources and pollution of soil. R11

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ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTAL CONSTRUCTION IMPACT PHASE

4. Socio-economic Temporary employ Socio- Employment and The proposed development would create a number of temporary local employment contractors and economic skills development and business opportunities during the construction phase as described in Section labourers 4.2.5. The new recruits will have to undergo various inductions and risk assessment training i.e. Safety and Emergency Preparedness Response, environmental training, etc. as per required by the existing Husab Mine EMP, policies and procedures. Site R12 access grants will also follow that of the existing Husab Mine Access Management System.

Potential impacts associated with employment and skills development is qualitatively assessed in Section 8.

Inward migration The establishment of the proposed project could attract job seekers to the area during and community the construction phase, which could increase the associated (cumulative) impacts to R13 health the surrounding communities (i.e. Swakopmund, Arandis, etc.). These potential impacts are qualitatively assessed in Section 8.

TABLE 7-2: ENVIRONMENTAL ASPECTS AND POTENTIAL IMPACTS ASSOCIATED WITH OPERATIONS PHASE OF THE PV POWER PROJECT

ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTA OPERATIONS PHASE L IMPACT

1. Operating the PV Power Plant and Powerline PV power plant PV power plant Visual impacts The sense of place results from the combined influence of the landscape on all of the infrastructure infrastructure viewers subjective senses (receptors). When viewed from the perspective of a tourist, R14 contributing to the natural landscape surrounding the greater area surrounding the Husab Mine is

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ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTA OPERATIONS PHASE L IMPACT

the overall associated with a serene sense of place. However the interaction between tourists and visual impacts mine’s infrastructure is minimal due to access restrictions to the existing mine and tourist destinations / routes relatively far from the activities. The proposed Solar PV could (cumulatively) add to visual impact associated with the Husab Mine infrastructure.

These potential impacts are qualitatively assessed in Section 8.

New PV power Collisions of birds Reflective surfaces may act as attractants for approaching birds. These surfaces may be project with photovoltaic confused for large water bodies and cause disorientation of flying birds, resulting in infrastructure (PV) panels and injury and / or death. R16 impact on associated Potential impacts on birds are assessed in Section 8. avifauna infrastructure

Attraction of Other possible impacts of PV power plant include the attraction of novel species to an novel species to area by the artificial provision of otherwise scarce resources – for example perches, nest the area by the sites and shade. artificial provision R17 These potential impacts on birds are assessed in Section 8. of otherwise scarce resources

No impacts in terms of bird collisions or electrocutions on powerline structures are New powerline Collisions and/or electrocutions of anticipated, should the power supply follow the proposed combination of birds on underground burial and cable tray routing. R18 powerline structures

Cleaning the solar Water supply Impact on water In addition to the discussion in R03 and R06, the following: panels resources With reference to Section 4.2.4, the water during both construction and operational R19 phases of the proposed projects will be supplied from the Husab Mine water supply.  Water consumption during construction period is ±500 m3.

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ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTA OPERATIONS PHASE L IMPACT

 The annual water consumption during the operation phase is ±1,000 m3/year. The approved Husab Mine annual water consumption is 8 Mm3 per annum. At present the total water consumption is ± 5,47 Mm3 per annum.. Water to the mine is supplied through a permanent pipeline from NamWater’s Swakopmund reservoir.

The water requirements for the PV power project is therefore insignificant when compared to the volumes of water used by Husab Mine. Furthermore, water that was previously used in the contractor’s accommodation camp will now end. This issue will therefore not be assessed in further detail. Wash water Contaminated Clean water will be used for the washing of the PV panels. Furthermore, with reference flow to water impacting to R03 and Section 4.2.4.4, storm water run-off (including cleaning water) would be downstream downstream collected in the existing (blocked) storm water drainage system / channel, from where vegetation vegetation health it will evaporate. Also, storm water flowing from the north of the site is diverted around (i.e. Welwitschias, the site. Therefore, only storm water falling on the site and future PV panels will Camel Thorn therefore naturally flow into the existing storm water drainage channel, south of the trees, etc.) site.

This issue will therefore not be assessed in further detail.

R20

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ACTIVITY/FACILITY ASPECT POTENTIAL RELEVANCE (SCREENING) OF POTENTIAL IMPACT Ref RELATING TO ENVIRONMENTA OPERATIONS PHASE L IMPACT

2. General Waste management Waste disposal Emissions to land Refer to R10. Waste generation is likely to be limited on site and will primarily be domestic and Nuisance impacts recyclable waste. This material will be stored properly until safe disposal off-site. R21 Through the effective implementation of the management and mitigation measures, as described in the EMP (Section 8) the potential impacts relating to waste management can be avoided/mitigated. This issue will therefore not be assessed in further detail. 3. Socio-economic Operating the PV Generation of Air quality – The establishment of a clean, renewable energy facility would reduce, albeit minimally, power plant and clean, positive impact Namibia’s reliance on energy imports and the generation of carbon emissions into the supply electricity to renewable atmosphere. Due to the fact that the proposed PV power project will be constructed to the Husab Mine. energy (primarily) supply electricity to Husab Mine, the potential positive impacts to Namibia’s R22 overall energy supply would be very minimal. This potential impact is not further assessed.

Reflection of Impact on civil The potential impacts on civil aviation are related to the reflection of sunlight during the sunlight during aviation day from the module / solar array surface, which can present a hazard during critical the day phases of flight, especially approach and landing. Due to the fact that no airports are located in closest proximity to the proposed PV power project except for the Arandis R23 Airstrip that is located ±14,5 km from the project site in Arandis and that the PV power project additionally adds to the overall infrastructure of the already approved Husab Mine, this is not regarded an issue and the impact on aviation is not further assessed.

Permanent Socio- Employment and Refer to R12. employment economic skill development R24

Inward migration Refer to R13. R25

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With reference to Tables 7 and 8 above, the following issues were identified as requiring assessment.

Refer to Section 8 of this Scoping Report for an assessment of the above mentioned issues.

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ENVIRONMENTAL IMPACT ASSESSMENT

This chapter describes and assess / re-assesses the significance of potential cumulative impacts associated with the proposed PV Power Project, incorporated into the bigger Husab Mine and associated infrastructure.

The environmental aspects that require further assessment (as identified in Section 7 of this Scoping Report) relate to biodiversity - birds; visual impacts; groundwater and surface water quality and soil pollution; air quality (dust); and socio-economic impacts (both positive and negative).

This chapter describes and assesses the significance of these potential impacts related to the proposed project development phases, as well as the cumulative impact, taking the adjacent Husab Mine processing plant and the overall infrastructure and associated activities into consideration. In this regard, the assessments below have been conducted by referring extensively to previous EIAs conducted and further specialist input undertaken specific for the proposed PV power project. The assessments also take cognisance of the fact that the proposed activities and infrastructure will be located within the same Husab Mine project footprint area (adjacent to the processing plant).

The management and mitigation measures to address the identified impacts are included in the EMP in Section 9.

Both the criteria used to assess the impacts and the method of determining the significance of the impacts are outlined in Table 8-1.

This method complies with the Environmental Impact Assessment Regulations: Environmental Management Act, 2007 (Government Gazette No. 4878) EIA regulations. Part A provides the approach for determining impact consequence (combining severity, spatial scale and duration) and impact significance (the overall rating of the impact). Impact consequence and significance are determined from Part B and C. The interpretation of the impact significance is given in Part D. Both mitigated and unmitigated scenarios are considered for each impact.

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TABLE 8-1: CRITERIA FOR ASSESSING IMPACTS PART A: DEFINITION AND CRITERIA Definition of SIGNIFICANCE Significance = consequence x probability Definition of CONSEQUENCE Consequence is a function of severity, spatial extent and duration Criteria for ranking of the H Substantial deterioration (death, illness or injury). Recommended level will often SEVERITY/NATURE of be violated. Vigorous community action. Irreplaceable loss of resources. environmental impacts M Moderate/ measurable deterioration (discomfort). Recommended level will occasionally be violated. Widespread complaints. Noticeable loss of resources. L Minor deterioration (nuisance or minor deterioration). Change not measurable/ will remain in the current range. Recommended level will never be violated. Sporadic complaints. Limited loss of resources. L+ Minor improvement. Change not measurable/ will remain in the current range. Recommended level will never be violated. Sporadic complaints. M+ Moderate improvement. Will be within or better than the recommended level. No observed reaction. H+ Substantial improvement. Will be within or better than the recommended level. Favourable publicity. Criteria for ranking the L Quickly reversible. Less than the project life. Short term DURATION of impacts M Reversible over time. Life of the project. Medium term H Permanent. Beyond closure. Long term. Criteria for ranking the L Localised - Within the site boundary. SPATIAL SCALE of impacts M Fairly widespread – Beyond the site boundary. Local H Widespread – Far beyond site boundary. Regional/ national

PART B: DETERMINING CONSEQUENCE SEVERITY = L DURATION Long term H Medium Medium Medium Medium term M Low Low Medium Short term L Low Low Medium SEVERITY = M DURATION Long term H Medium High High Medium term M Medium Medium High Short term L Low Medium Medium SEVERITY = H DURATION Long term H High High High Medium term M Medium Medium High Short term L Medium Medium High L M H Localised Fairly widespread Widespread Within site Beyond site Far beyond site boundary boundary boundary Site Local Regional/ national SPATIAL SCALE

PART C: DETERMINING SIGNIFICANCE PROBABILITY Definite/ Continuous H Medium Medium High (of exposure to Possible/ frequent M Medium Medium High impacts) Unlikely/ seldom L Low Low Medium L M H CONSEQUENCE

PART D: INTERPRETATION OF SIGNIFICANCE Significance Decision guideline High It would influence the decision regardless of any possible mitigation. Medium It should have an influence on the decision unless it is mitigated. Low It will not have an influence on the decision.

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BIODIVERSITY - AVIFAUNA

With reference to Table 7-1 and the baseline information detailed in Section 6.5 the proposed project site is already a disturbed site with little to no vegetation cover. Existing access roads to the site will be used to deliver material and workers. The site is already fenced off and no activities will be conducted outside the footprint of the site (i.e. workers will be restricted to the site boundaries), therefore no impact to the natural vegetation outside the site boundaries could occur.

However the potential impacts of the PV power project on Avifauna were identified as requiring further assessment. In this regard, the discussion relates to avifauna only.

This Section therefore assesses the physical impacts and general disturbance on avifauna, associated with the proposed PV power project. The impact assessment and detailed baseline description of the Avifauna specialist report (ACS, 2019) was used as a basis for this assessment together with site observations by SLR.

Issue: Collisions of birds with photovoltaic (PV) panels and associated infrastructure and general disturbance of birds

8.1.1.1 Introduction

Due to the number of species likely to be found in the proposed project location encompassing the Husab Mine, the assessment is directed towards avifauna that have a high biological significance, i.e. primarily Red Data species (including those with migrant status) and/or endemic species. Due to the potential sensitivity of waterbirds to solar PV developments, existing open-water structures in the area were also considered during the assessment (see Section 6.5.2), as they have the potential to attract aquatic birds to the area. Raptors were also considered as a potentially sensitive group.

8.1.1.2 Assessment of impact

Severity

Birds may be injured or killed by colliding with PV panels. According to the specialist study (Appendix 5), recent findings at facilities in North America suggest that collision mortality impacts may be underestimated at PV power plants, with collision trauma with PV panels, perhaps associated with polarised light pollution and/or with waterbirds mistaking large arrays of PV panels as wetlands – the so-called "lake effect", emerging as a significant impact factor at one site where mortality monitoring is on-going.

Indirect impacts resulting from such collisions, and/or entrapment in surrounding fences, could include predation if the bird is unable to fly or take off.

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Taking the above mentioned into consideration, the (cumulative) unmitigated severity is medium which may reduce to low with the successful implementation of the mitigation measures.

Duration

The duration of impact is medium in both unmitigated and mitigated scenarios.

Spatial scale

The impact will be confined to a localised project area within the Husab Mine the spatial scale of impacts is therefore low in both the unmitigated and mitigated scenarios.

Consequence

In the unmitigated scenario, the consequence of the potential impact is medium and this reduces to low with mitigation.

Probability

Without any mitigation the probability associated with the impacts is possible. With mitigation, the probability of impacts (cumulatively) will be reduced to low.

Significance

The significance of this potential impact is medium in the unmitigated scenario and low for the mitigated scenario. Refer to Section 9 (EMP) for the management and mitigation measures.

Tabulated summary of the assessed impact – bird collisions on solar photovoltaic panels and associated infrastructure and general disturbance of birds

Mitigation Severity Duration Spatial Consequence Probability of Significance Scale Occurrence Unmitigated M M L M M M Mitigated L M L L L L

Assessment of impact: Attraction of novel species to the area by the artificial provision of otherwise scarce resources

8.1.2.1 Introduction

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Swakop Uranium (Pty) Ltd 733.03107.00001 733.03107.00001 Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine July 2019 activities and infrastructure - 12 MW Solar PV Power Plant July 2019 of solar energy projects on birds include the use of the various raised structural components of these developments as artificial nesting and roosting sites by a suite of otherwise tree-nesting species.

8.1.2.2 Assessment of impact

Severity

The severity of the attraction of novel species into the area is therefore rated as low (potentially positive) in both the unmitigated and mitigated scenarios.

Duration

The duration of impact is medium in both unmitigated and mitigated scenarios.

Spatial scale

The impact will be confined and localised to the site boundary. The spatial scale of impacts is therefore low in both the unmitigated and mitigated scenarios.

Consequence

In the unmitigated and mitigated scenario, the consequence of the potential impact Low

Probability

The probability without mitigation is low to medium.

Significance

The significance of this potential impact is low to medium (potentially positive) and no mitigation is required unless indicated by monitoring.

Tabulated summary of the assessed impact – Attraction of novel species to the area by the artificial provision of otherwise scarce resources

Mitigation Severity Duration Spatial Consequence Probability of Significance Scale Occurrence Unmitigated L M L L L-M L-M (potentially +) Mitigated L M L L L-M L-M ((potentially +)

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Cumulative impacts

Together with existing threats both in the area and at other migrant destinations, the above impacts have the potential to act cumulatively, e.g. on avian food sources, feeding and roosting, breeding and survival.

The clustering of existing infrastructure in the area, including the road network, communication masts, powerlines and other infrastructure, as well as associated human presence and noise, would increase the cumulative effect of any impacts associated with the present development.

Although recorded mortalities may be in low numbers, the cumulative impacts of such negative interactions over the entire lifespan of the development are an important consideration.

Sensitive species that are already under threat, including Red Data and endemic species, raptors, waterbirds and other migrants/nomadic species are at particular risk to such cumulative effects.

Taking the proposed powerline design (combination of underground and above-ground cable tray) into consideration, no additional impacts in terms of collisions and electrocutions on powerline structures are foreseen.

VISUAL

Issue: Visual impacts and sense of place

8.2.1.1 Introduction

With reference to Table 7-2 the proposed development could (cumulatively) add to visual impact associated with the Husab Mine infrastructure.

The maximum height of the panels would be ± 2.8 m. The total area required for the 12 MW PV power plant would be ± 16.4 ha. Various operations and maintenance buildings would be constructed to support the PV power plant (refer to Section 4).

With reference to Section 6.8, the mining and processing infrastructure and activities have already influenced the original visual environment and sense of place.

8.2.1.2 Assessment of impact

Severity:

The severity of visual impacts is determined by assessing the change to the visual landscape as a result of mine related infrastructure and activities. The visual landscape is determined by considering: landscape character, sense of place, aesthetic value, sensitivity of the visual resource and sensitive views. In this regard, the area in which Husab is situated is considered to have a significant visual landscape (refer to Section 6.8).

When considering the potential change to the visual landscape the key issues are: visual exposure, visual intrusion, and sensitivity of receptors. Each of these issues are discussed below.

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Therefore, the proposed PV power project will not significantly change the severity of the cumulative impact of the current infrastructure and activities at the Husab Mine. Taking all of the above mentioned into consideration, the severity of the PV power project (on its own) is regarded low in the unmitigated and mitigated scenarios.

Duration:

The duration of the impact, associated with the PV project is expected to be medium term for all project phases in the unmitigated and mitigated scenarios because the impacts should be limited to the life of the project.

Spatial scale:

The PV infrastructure might be visible from beyond the site boundary, therefore medium spatial scale.

Consequence:

Based on the above assessment the determining consequence is low in the unmitigated and mitigated scenarios.

Probability:

With reference to the above, the PV power plant would ‘replace’ existing infrastructure on this site and the current visual impacts from this specific site would not change, therefore the probability of the potential impact is low.

Significance:

The significance of the visual impacts associated with the PV power plant (alone) is low in both the unmitigated and mitigated scenarios.

Tabulated summary of the visual impacts

Mitigation Severity Duration Spatial Consequence Probability of Significance Occurrence Scale

Unmitigated L M M L L L

Mitigated L M M L L L

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Cumulative impacts

The proposed PV power project will not increase the footprint of the overall Husab Mine infrastructure, and would also not change the cumulative visual impact significance rating of the Husab Mine activities and infrastructure. The significance of the cumulative impact therefore remains high in the unmitigated and mitigated scenarios (similar to the original EIAs). With reference to the original EIAs (and EMP), management and mitigation may reduce this significance to medium – high.

GROUNDWATER & SURFACE WATER AND SOIL

Issue: Groundwater & surface water quality and soil pollution

8.3.1.1 Introduction

With reference to Table 7-1 there are a number of activities during specifically the construction phase that have the potential to pollute surface water, groundwater and soil. These potential pollution sources would be temporary in nature, at most for a few weeks to a few months. Although these sources are temporary in nature, the related potential pollution can be long term.

8.3.1.2 Assessment of impact

Severity

With reference to Section 6, the project area is flat with no significant natural drainage channels being present on the site. The site is located near a catchment divide, within a relatively small catchment area, when compared to the much bigger ‘Husab Catchment’. Minor drainage lines have already been impacted by the process plant and associated infrastructure, within this catchment area. There is however a relatively small drainage line located south-west of the site, flowing in a south-westerly direction, towards the Khan River. With reference to Section 4.2.4, storm water flowing from the north of the site is diverted around the site. Therefore, only storm water falling on the site will therefore flow into the existing storm water drainage channel, south of the site. In the unmitigated scenario, flood water may collect and mobilize contaminants (hydrocarbons, and other contaminants) from numerous sources on site and transport it downstream, towards the above mentioned drainage line. However, with reference to the above (and section 4.2.4.2), rain water (with possible contaminants), will naturally flow along the ground surface, into the existing storm water drainage system/ channel, which Swakop Uranium has previously blocked. This should prevent potentially contaminated surface water from being released into the environment. Also, as a result of the magnitude of the project activities during the construction process, the likelihood of significant spillage is relatively small. In the unmitigated scenario, small volumes of hydrocarbon substances, in particular fuels and oil, waste water and sludge, sewerage, paint, concrete sludge, etc. could seep into groundwater. However, with reference to the previous EIAs (SLR, 2010), the pollution plume is mostly pulled into the open pits there will be no off site pollution impact on any groundwater resources which means that no third parties will be exposed to the pollution. With mitigation, this could be further limited through proper engineering design and controls. Topsoil from the site was previously stripped - prior the implementation of the contractors’ camp (refer to Section 6.4.3).

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Taking the above mentioned into consideration, the severity is therefore low in the unmitigated scenario and low in the mitigated scenario.

Duration

Impacts are likely to occur only during the construction phase. The impact could be for the life of the project and therefore medium in the unmitigated and mitigated scenarios.

Spatial scale

As mentioned above, contamination of surface water and soil beyond the site boundary is unlikely. Groundwater contamination could potentially migrate beyond the site boundary. However, with reference to the previous EIAs (SLR, 2010), the spatial scale of the potential impact is directly related to the spatial scale of the dispersion of any ground water pollution that in turn has the potential to impact on human health. Given that the pollution plume is mostly pulled into the open pits, and taking the nature and scale of the activities into consideration (i.e. the potential for large spills seeping into the groundwater being unlikely), the spatial scale is localised.

Consequence

Based on the above assessment the determining consequence is low in the unmitigated and in the mitigated scenarios.

Probability

Contamination of surface water and soil beyond the site boundary is unlikely. The probability of their being any groundwater pollution impact on third parties is low because of the nature and scale of the activities and the extremely limited extent of the plume.

Significance

In both the unmitigated and mitigated scenarios, the significance of this potential impact is low.

Tabulated summary of the assessed cumulative impact – surface water & groundwater quality and soil pollution

Mitigation Severity Duration Spatial Consequence Probability of Significance Occurrence Scale

Unmitigated L M L L L L

Mitigated L M L L L L

AIR QUALITY

ISSUE: Air Pollution (dust)

8.4.1.1 Introduction

There are various construction activities (particularly the movement of vehicles) relating to the proposed project that would generate dust on site. Considering the nature and scale of the project (construction) as well as the location, a qualitative air quality assessment is done below.

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8.4.1.2 Assessment of impact

Severity

The site has already been cleared and only limited landscaping within the footprint of the site will be required, resulting in limited dust generation.

It is also not anticipated that the various other construction activities (refer to Section 4.2.5.1) would result in higher off-site impacts (including health impacts associated with the finer, i.e. PM10, dust particles) than the Husab Mine operational phase activities. Dust fallout from the construction phase of the PV power plant is expected to be limited to an area relative close to the site.

The gaseous emissions, in comparison to the particulates, are small with low impact significance.

Based on the above, the dust impact severity is regarded low in the unmitigated scenario and low with mitigation and would not change the cumulative dust impact rating of the existing Husab Mine infrastructure.

Duration

In the context of this assessment, the construction activities, and specifically the activities that would generate dust will last for a relatively short period (only a few months). Health impacts could however be experienced over a longer period. The impact duration would therefore be medium.

Spatial scale

The thoracic dust (smaller particles, i.e. PM10) would travel further than the dust fall out (i.e. nuisance dust) and would be beyond the site boundary in the unmitigated scenario, therefore a medium spatial scale.

With mitigation, dust generation would be minimised, reducing the spatial scale to low.

Consequence

The consequence is low in the unmitigated and mitigated scenarios.

Probability

The likelihood of causing increased dust impacts to third parties as a result of the PV plant construction activities is low. This is due to the relatively small scale of activities.

Significance

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Tabulated summary of the assessed impact – air pollution (dust) Mitigation Severity Duration Spatial Scale Consequence Probability of Significance Occurrence Unmitigated L M M L L L Mitigated L M L L L L

SOCIO-ECONOMIC

Issue: Employment and skills development

8.5.1.1 Introduction

The proposed development would create a number of temporary local employment and business opportunities during the construction phase (±100 people (peak) over an 8 month period) as well as a small number (approximately 4) permanent jobs during the operational phase.

8.5.1.2 Assessment of impact

Severity

The permanent job opportunities are relatively small, when compared to the number of permanent employees at the existing Husab Mine operations.

The severity is there considered to be low positive.

Duration

In the normal course, the direct positive economic impacts associated with the project will occur for the life of operations.

Spatial scale

The impact will be experienced in the region and in other ‘economic centres’ of Namibia such as Arandis, Swakopmund, etc. The spatial scale is therefore beyond the project site and is classified as medium.

Consequence

Based on the above assessment the determining consequence is low.

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Probability

In the normal course of economic activity, the net positive impacts will definitely occur.

Significance

The significance of this potential impact is medium positive.

Tabulated summary of the assessed cumulative impact – employment and skills development

Mitigation Severity Duration Spatial Consequence Probability of Significance Occurrence Scale

Unmitigated L+ M M L H M+

Mitigated L+ M M L H M+

Cumulative Impacts

Issue: Inward migration and social/security issues

8.5.2.1 Introduction

The proposed development would create a number of temporary local employment and business opportunities during the construction phase as well as a small number of permanent jobs during the operational phase.

8.5.2.2 Assessment of impact

Severity

Inward migration usually leads to an increased incidence of social ills including alcoholism, drug abuse, prostitution, gambling and criminality. Alcohol abuse is part of the accepted social norm in Namibia and is often stimulated by cash earnings which increase the likelihood of domestic violence (usually against women and children), unprotected sex and the spread of HIV/AIDS. The influx of job seekers may increase over-crowding which increases the spread of TB.

With reference to Section 6.9, inward migration has already started at the central coastal towns of Namibia.

The relatively small workforce requirements and short construction period of the proposed project is, however, unlikely to stimulate a considerable influx of more job-seekers to the region.

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Taking the above mentioned into consideration, the severity in the unmitigated scenario (specifically relating to social/security issues) is considered to be low to medium in the unmitigated scenario and low in the mitigated scenario.

Duration

The social issues is expected to relate specifically to the construction phase, which is only ±8 months, therefore short term.

Spatial scale

The impacts would be beyond the site boundary. Inward migration impacts would be felt in Arandis and the central coastal towns. The spatial scale is therefore medium in the unmitigated scenario and low in the mitigated scenario.

Consequence

Based on the above assessment the determining consequence is medium.

Probability:

In the unmitigated scenario, the possibility of social/security issues is possible. With mitigation, this can be prevented.

Significance:

In the unmitigated scenario, the significance is medium. In the mitigated scenario, the significance of this potential impact is reduced to low.

Tabulated summary of the assessed cumulative impact – inward migration and social/security

Mitigation Severity Duration Spatial Consequence Probability of Significance Occurrence Scale

Unmitigated L-M L M L-M M M

Mitigated L L L L L L

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ENVIRONMENTAL MANAGEMENT PLAN

AIMS

The aim of the Environmental Management Plan (EMP) is to detail the actions required to effectively implement mitigation and management measures. These actions are required to minimise or avoid negative impacts associated with the proposed PV power plant activities and the associated infrastructure.

In addition to the above, the EMP identifies parties at an early stage of project development to implement management and mitigation measures through all phases of the project from design to operational phase. It is also important to note that Swakop Uranium has an approved EMP for the Husab Mine (and associated activities) and infrastructure, which his being implemented though an Environmental Management System.

This EMP therefore provides additional/specific management and mitigation measures, specifically relating to the PV power project, however the relevant management and mitigation measures associated with the Husab Mine EMP needs to be complied with.

This EMP should therefore be read with the existing overarching EMP for the Husab Mine.

ENVIRONMENTAL OBJECTIVES

The following overall social and environmental objectives are applicable:

 To ensure compliance with relevant national legislation and standards, corporate environmental policies and objectives as well as this EMP.  To investigate and exploit measures to reduce resource and energy consumption.  To minimise, as far as is possible, the unacceptable loss of biodiversity and related functionality through physical destruction and disturbance.  To monitor the impacts of bird strikes and interactions with the PV plant infrastructure and determiner additional suitable management and/or mitigation measures as and where required.  Minimise disturbing dust and noise impacts (specifically during the construction phase) on third parties.  To limit contaminated effluent discharge into the environment, and to protect soils and surface and groundwater resources through the implementation of measures for spill prevention and clean-up.  To avoid additional negative visual impacts.  To enhance positive socio-economic impacts.  To avoid social/security issues from occurring.  To ensure the appropriate management and disposal of general, recyclable and hazardous waste.

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 To prevent and minimise pollution.  To develop, implement and manage environmental monitoring systems for biodiversity (i.e. avifauna).  To support and encourage environmental awareness and responsibility amongst all employees and service providers.  To provide appropriate environmental education and training for all employees and service providers.

MANAGEMENT AND MITIGATION MEASURES (ACTION PLANS) TO ACHIEVE OBJECTIVES

The management and mitigation measures (or action plans) to achieve the above-mentioned objectives, relating to the various environmental issues are listed in the Sections below.

Swakop Uranium (Pty) Ltd, who owns the ML on which the PV power plant will be constructed will have overall accountability for ensuring the EMP gets implemented, through contracts with CGNEI. However, all members of the project team as well as their Contractors are expected to understand the EMP requirements and implement them.

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TABLE 9-1: BIODIVERSITY

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Infrastructure/activities Environmental issue Management and Mitigation Measures

CONSTRUCTION AND OPERATIONS PHASES

 - The construction activities should be limited to the 16.4 ha footprint for Site preparation and earth works; Potential impact on biodiversity the overall design plan.  Establishing of working areas and (physical impacts and general - The design plan should have a clear and specific infrastructure layout of all stores, waste management disturbance) facilities and construction / facilities before construction. All activities related to the PV power plant operational staff amenities; should be limited to the fenced project area except where the trenching  Drilling activity for installation of for powerline cable or further surface water controls are required. Solar Panel structures (Modules). - Before construction activities are undertaken. The Project Team and their  Trenches for ground cable laying. contractor should ensure that all the existing infrastructure relating to the temporary construction camp is identified and dismantled / removed,  Materials delivery and laydown / where required, in liaison with SU. Where possible leave infrastructure, storage. i.e. existing ablution facilities that can be utilised for the PV power project. However it must be noted that the infrastructure has to be upgraded as the design was for a temporary installation. - Ensure that all removed infrastructure is either sold / recycled or re-used elsewhere on the mine; or disposed of appropriately as per waste management measures or kept at the Husab Mine temporary storage area for reusable material. - CGNEI, SU and the Contractors to agree on the way forward prior to the start of construction. - Where necessary, construct permanent pipeline facilities for the existing ablution facilities, connecting it with the existing SU Sewerage Treatment Plant. - Implement a high efficiency system for cleaning of the PV panels. Prevent erosion from water flowing off the panels.

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- Backfill all open trenches with the same soil removed. No topsoil to be used from existing stockpiles. Where required use additional soil from the current open pit mining environment after obtaining the appropriate permission from the Husab Mine Mining Department and Environment Section. - Control the growth of alien invasive plant species (monitor and remove these species). - The Contractor shall not deface, paint, damage or mark any natural features outside the site. Any features affected by the Contractor in contravention of this clause shall be restored / rehabilitated to the satisfaction of Swakop Uranium. - The removal, damage or disturbance of flora, fauna or avifauna is forbidden outside the site. - Prevent trapping and hunting. - Although no formal faunal search and rescue is considered necessary, every effort is to be made to relocate faunal species that cannot flee on their own accord to a suitable area immediately adjacent to the proposed footprint. - The Contractor shall ensure that no hunting, trapping, shooting, poisoning or otherwise disturbance of any fauna takes place. The feeding of any wild animals is prohibited. No domestic pets or livestock are permitted on site. - Prevent the spread of waste in, and beyond, the construction area. An integrated waste management approach shall be used, based on the principles of waste minimisation, reduction, reuse and recycling of materials. Refer to Table 9-7: Waste Management for further management and mitigation measures relating to waste management.

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 - Due to the limited certainty of predicting the impacts of solar PV Solar PV panels Structures Collisions of birds on solar PV panels developments, and of the species likely to be impacted, monitoring of and associated infrastructure any potentially negative impacts is considered essential; recommendations for monitoring are provided below. Should the results show that such impacts, including injuries and/or mortalities of birds are taking place, mitigation measures would need to be investigated, if necessary on a species-specific basis. - These mitigations could include minor modifications of the panel design, in order to reduce the illusory characteristics of these structures. - The solar PV area should be fenced with predator-proof fencing, to reduce indirect predation of any bird collision species (if injured and still alive), attraction for the creation of dens, and also to prevent the removal of any carcass material before it is recorded. - Security lighting should be kept to the minimum and directed downward and away from the PV panels if possible. - The PV panels themselves should not be directly illuminated. - If numerous bird carcasses are found around the modules/solar arrays, investigate and implement relevant management and mitigation measures to avoid/reduce further impacts. - In addition to formal carcass searches, staff should report incidental bird mortalities through the formal SU reporting system.

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- Any movement of hitherto unrecorded species onto or beneath the Attraction of novel species to an area solar panel structures should be monitored. by the artificial provision of otherwise - Should any negative impacts result (e.g. entrapment of korhaans in scarce resources fences; predation), these should be addressed. - Bird nesting activities should be discouraged early in the cycle, before any eggs are laid; the Ministry of Environment and Tourism should be contacted for specific guidelines, should this become a problem.

- No mitigation is recommended for these interactions, should the Collisions and/or electrocution of birds power supply follow the proposed combination of underground burial on powerline structures and cable tray routing, as no impacts on birds are anticipated. - However, should the powerline (or any components) be constructed above-ground, using pole structures, this aspect would need to be reassessed as the above potential impacts would then apply.

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TABLE 9-2: NOISE

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Infrastructure/activities Environmental issue Management and Mitigation Measures

CONSTRUCTION PHASE

 - The Contractor shall be familiar with and adhere to Husab Mine policies and Site preparation and earthworks; Increase in disturbing noise levels procedures regarding working hours.  Establishing of working areas and (nuisance) stores, waste management - The Contractor shall avoid construction activities outside of “normal working facilities and construction staff hours”. amenities; - Maintain machinery, vehicles and equipment in good condition to prevent  Materials delivery and laydown / unnecessary noise outputs. storage - The contractor shall ensure that workers do not create unnecessary noise such as hooting or shouting. - Work shall be restricted to the daylight hours.

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TABLE 9-3: AIR QUALITY (DUST)

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Infrastructure/activities Environmental issue Management and Mitigation Measures

CONSTRUCTION AND OPERATIONS PHASES

 - The Contractor shall ensure that the generation of dust is minimized and Site preparation and earthworks; Increase in Dust levels (nuisance and shall implement a dust control programme, with reference to the measures  Establishing of working areas and health impacts) stores, waste management provided below, to maintain a safe working environment and minimise dust facilities and nuisance. construction/operational staff - CGNEI and their contractors shall ensure that areas (i.e. access routes within amenities; the project area), where movement of vehicles and machinery is adequately  Materials delivery and laydown / water sprayed to minimize excess dust. storage - In this regard, SU to determine though the existing dust monitoring programme whether there is any increase in dust levels as a result of the

construction phase of the PV power project.  Windblown dust from - Construction vehicles shall comply with the Husab Mine speed limits at all exposed/cleared surfaces during times. operations

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TABLE 9-4: SURFACE WATER, GROUNDWATER AND SOIL RESOURCES

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Infrastructure/activities Environmental issue Management and Mitigation Measures

DESIGN AND CONSTRUCTION PHASE

 - Engineered containment (contained areas with impermeable floors) of Earth moving equipment and Contamination of surface water and process areas, sewerage facilities, wastewater, waste storage areas, machinery: Possible hydrocarbon groundwater resources and pollution spills concrete works, painting areas and hydrocarbon storage areas. of soil  Storage and handling of other - Prevent pollution through education and training of workers (permanent hazardous substances (i.e. paint) and temporary). - Prevent pollution of the drainage line located south-west of the site. - Cement and concrete mixing directly on the ground shall not be allowed and shall take place on impermeable surfaces. - Used cement bags shall be stored in weatherproof containers to prevent windblown and disposed appropriately. - The Contractor shall submit a “Mini EMP” with a Method Statement/Procedure detailing cement storage, concrete batching areas and methods, method of transport of cement and concrete, storage and disposal of used cement bags, etc. for each concrete batching operation. The SU Environmental Section to sign off on the approved documentation. - All excess concrete shall be removed from site on completion of concrete works and disposed of in line with the SU Waste Management Plan and relevant procedures. Washing of the excess concrete into the ground is prohibited. - All hydrocarbon (e.g. fuel, oils and contaminated soil / materials) and other hazardous waste (e.g. paint, bitumen, tar, etc.) resulting from spills, shall be disposed of at a licensed hazardous waste site or, where possible, sold to an approved used-oil recycling company. The Managing Contractor shall keep records of disposal certificates on site.

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- In the event of a hydrocarbon spill, the source of the spillage shall be isolated and the spillage contained. - Any hydrocarbon and other hazardous substance spills will be cleaned up immediately. - Reporting of spills to occur immediately to the Project Manager and Environmental Section. - Spill kits or adsorbent materials will be kept on hand to clean up spills. Once used, this material will be treated as hazardous waste and disposed of accordingly. - No repairs and maintenance to machinery, vehicles and equipment shall be allowed on the PV project site. This shall be undertaken at the approved SU workshop – in liaison with SU. - Dispensing of petroleum products to take place over a drip tray or within a lined and bunded area. - All hazardous substances to be stored in lined and bunded areas (110% of volume). The floor and wall of the bund area shall be impervious to prevent infiltration of any spilled / leaked fuel, oil or hazardous substance into the soil. - The relevant Material Safety Data Sheets (MSDS) for all hazardous chemical substances (as defined in the Regulations for Hazardous Chemical Substances) shall be submitted to the CGNEI Project Manager. The Contractor shall have a copy of the Material Safety Data Sheets readily available and ensure that he / she or his / her employees who are required to use such substances are fully conversant with the safe handling precautions, protective equipment to be used and storage precautions to be taken. - Maintain all vehicles free of leaks (oil, hydraulic fluid etc.). Daily Inspections and regular planned maintenance programmes to be enforced. - Refueling to take place over a drip tray or within a lined and bunded area.

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- Ensure good housekeeping and proper sanitation and treatment of wastewater during construction and operations. - Ensure that the existing storm water drainage channel is adequate to

capture all infiltrated water from potential spillage, cleaning the panels and in events of flood. - The Contractor shall ensure suitable sanitary facilities are available – in  Toilet facilities (if required) Contamination of surface water and liaison with SU. There should be one toilet for every 15 workers on site. groundwater resources and pollution Toilets must be easily accessible. of soil - The Contractor shall be responsible for ensuring that all ablution facilities are maintained in a clean and sanitary condition. The emptying of toilets will be conducted in line with the contract agreement with Swakop Uranium (and the existing Husab Mine EMP and relevant Procedures). - The Sub-contractor shall ensure that there is no spillage when the chemical toilets are cleaned and that the contents are properly removed from site, to a registered Municipality facility in either Swakopmund or Walvis Bay. - Safety certificates/records to be provided of the disposal. - The Contractor shall be responsible for enforcing the use of these facilities. Performing ablutions outside of established toilet facilities is strictly prohibited.  Water supply for construction - Only use the allocated volumes of water and ensure this covers for dust Impact on water resources suppression. - Minimise water consumption by every practical means, including recycling, selection of equipment and appliances, and tar/gravel access and services road surfaces.

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DESIGN AND OPERATIONS PHASE

 Establish PV power infrastructure  Interruption of drainage and - CGNEI shall protect areas susceptible to erosion by installing necessary interference with water flow. temporary and permanent drainage works and by taking measures  Increased stormwater runoff from necessary to prevent surface water from being concentrated in streams and modules / solar array surfaces and from scouring slopes, banks or other areas. roads, could result in the - Ensure that clean storm water is directed around the site. concentration of stormwater flows, reduced infiltration and increased risk of erosion.  Cleaning the solar panels - Ensure that the water volumes required for cleaning is adequately Impact on water resources accounted for and where additional water is required this must be communicated and arranged with the Swakop Uranium Environmental Section.

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TABLE 9-5: VISUAL

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Infrastructure/activities Environmental issue Management and Mitigation Measures

CONSTRUCTION AND OPERATIONS PHASES

 PV power plant infrastructure - The construction activities should be limited to the 15 ha footprint for the Visual impacts and buildings overall design plan.  Specifically lighting - Manage all dust plume sources with dust suppressants to limit visual intrusion by dust, in the event of excessive dust generation. - The use of night light will be kept to a minimum and will illuminate only that which is required. The use of standard high pole flood lights will be avoided. - Yellow lighting is recommended and/or light emitting diode (LED) lighting is reported to be unattractive to insects and should be used where possible. - Lights should be directed downwards where possible. - Painting infrastructure with colours that blend in with the surrounding environment where possible (similar to the adjacent SU process plant infrastructure). - Prevent littering.

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TABLE 9-6: ARCHEOLOGICAL RESOURCES

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Infrastructure/activities Environmental issue Management and Mitigation Measures

CONSTRUCTION AND OPERATIONS PHASES

 - In the unlikely event that archaeological resources are discovered during Site preparation and earthworks; Potential impact on archaeological construction, a chance find emergency procedure will be implemented  Establishing of working areas and resources stores, waste management which includes the following: facilities and construction /  All work at the find will be stopped to prevent damage; operational staff amenities;  An appropriate heritage specialist will be appointed to assess the find  Materials delivery and laydown / and related impacts; and storage  Permitting applications will be made to the necessary authorities, if required.

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TABLE 9-7: WASTE MANAGEMENT

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Infrastructure/activities Environmental issue Management and Mitigation Measures

CONSTRUCTION AND OPERATIONS PHASES

 General construction and  Emissions to land - All hydrocarbon (e.g. fuel, oils and contaminated soil / materials) and other operational activities – workforce  Nuisance impacts hazardous waste (e.g. paints, bitumen, tar, etc.) resulting from spills, refueling (waste management):  Groundwater and Surface water and maintenance activities shall be disposed of at a licensed hazardous waste  Hydrocarbon and pollution site or, where possible, sold to an approved used-oil recycling company. Hazardous Waste Hydrocarbon contaminated soil can also be treated at a dedicated Management bioremediation treatment area on site. This shall be done in liaison with the SU Environmental Section. - When the soil is clean (after treatment), the location for disposal of material to be agreed with the SU Environmental Section. - No hydrocarbon and hazardous waste shall be burnt or buried on site. The spoiling or burial of tar or bituminous products shall not be allowed on site.  General construction and  Emissions to land - Solid waste includes all construction waste (rubble, cement bags, old cement, operational activities – workforce  Nuisance impacts tags, wrapping materials, timber, cans, wire, nails, PPE, etc.), recyclables and (waste management): domestic waste (surplus food, food packaging, organic waste, etc.).

 Non-Hydrocarbon Waste - CGNEI to investigate means of minimising the usage of plastic/Styrofoam Management packaging, through the procurement of the PV infrastructure.

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- The Contractor liaise with the SU Environmental Section to ensure the solid waste control and removal system is in line with the current Husab Mine Waste Management Plan and relevant Procedure. In this regard, Waste Management Contractor on the mine site supplies the necessary facilities to be used. - Prevent the spread of waste in, and beyond, the construction area. An integrated waste management approach shall be used, based on the principles of waste minimisation, reduction, reuse and recycling of materials. Containers for glass, paper, metals and plastics shall be provided. The Contractor shall remove all construction waste to the waste transition yard and/or arrange with the Waste Management Contractor for the removal of waste from the site. - The “Mini EMP” shall include procedures relating to the management of waste, in line with the SU Waste Management Plan and procedures for sign off by the SU Environmental Section, prior to the start of construction. - The Contractor shall provide bins (with lids) of sufficient number and capacity to store office waste produced on a daily basis. The lids shall be kept firmly on the bins at all times. - Arrange with the Waste Management Contractor to provide the wheelie bins and skips. These shall be located at eating areas and construction areas where there will be a concentration of labour. Bins shall be emptied on a weekly basis or more frequently as required. The general cleanliness of the site shall form part of the site management, HSE Representative and SU inspections.

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- All solid waste may be temporarily stored on site in a demarcated area, which meets the satisfaction of the CGNEI Project Manager and the SU Environmental Section. No waste shall be stored outside the site, except on approval by the SU Environmental Section. All solid waste shall be disposed of offsite at a licensed landfill site, via the Waste Management Contractor. The stockpiling of construction rubble or other material shall only be permitted in areas approved by the CGNEI Project Manager. No waste material or litter shall be burnt or buried on site. - Adhere to the NNNP Park Rules relating to waste management. - The use of Styrofoam food packaging, etc., danger tape and snow netting shall not be allowed on site.

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TABLE 9-8: SOCIO-ECONOMIC ASPECTS

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Infrastructure/activities Environmental issue Management and Mitigation Measures

CONSTRUCTION AND OPERATIONS PHASES

 Temporary contractors and  General third party safety and - No construction workers to be housed on site. workforce and permanent security (i.e. stock theft, poaching, - Provide appropriate fencing, security access control and warning signs (in employees. etc.). appropriate languages with danger pictures) at the PV power plant access point and around the entire PV power plant site, at appropriate intervals.

- Contractor to remain within the PV project working area during working hours. - Employment and skill - The recruitment process, job opportunities, contact details, etc. to be made development (Enhancement of available to the local people in the area. positive economic impacts) - In this regard, the abovementioned information needs to be displayed at appropriate places in Arandis and at least Swakopmund and Walvis Bay (i.e. relevant shopping centre’s notice boards, etc.). - Recruitment of Namibian nationals, in particular local people. With priority in Arandis, Swakopmund and Walvis Bay. - Promote small and medium enterprises (SME) development wherever possible. - Use small-scale contractors wherever possible. - Tender selection criteria will include suppliers of goods and services which use local suppliers down the supply chain. - Competitive salaries and wages should be paid to employees. - Local procurement whenever possible and encourage employees and the community to do the same.

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- Development and implementation of socio-economic management policy which will promote positive impacts where possible must be looked at. - Training / skill development of local and regional contractors, before the project commences to be included in the above policy and implemented. - Technical training and skills development will form part of the training programme. - Training of local employees should continue throughout the life of the operation. - Support employees to continue learning and developing skills so they too benefit from being able to offer labour flexibility and productivity. - The government policy of improving gender equality and the empowerment of women will be supported where possible. - Develop and implement an emergency response plan for accidental injury to Emergency third parties or animals. - Report all emergency situations to the Namib Naukluft National Park Warden, through the SU Environmental Section.  Transport of material  Material falling from trucks - The Contractor (and suppliers) shall ensure that all materials are appropriately impacting third party road users secured to ensure safe passage between destinations. Loads including, but not limited to sand, stone chip, refuse, and cement, shall have appropriate tarpaulins or covers to prevent them spilling and transfer of dust debris from the vehicle during transit. The Contractor shall be responsible for any clean-up resulting from the failure by his employees or suppliers to properly secure transported materials. The Contractor shall ensure that delivery drivers are supervised during offloading.

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RESPONSIBILITIES

This Section describes the roles and responsibilities for implementing the different parts of the Environmental Management Plan (EMP). The implementation of the EMP will involve the following parties including their scope of responsibility.

SU Project Manager

The SU Project Manager shall ensure compliance to this EMP. The EMP will be part of the contract with all contractors working on the project. The SU Project Manager shall also ensure that CGNEI and their contractors have a copy of the Husab Mine EMP and relevant site documentation to familiarise themselves with other relevant management and mitigation measures. Ensure that a clause is inserted in the contract document that a retention amount will be withheld until an environmental close out audit is satisfactory completed and the Environmental Completion Certificate is issued to the contractor.

Swakop Uranium Environmental Section

The SU Environmental Section has overall responsibility for all environmental related matters on the ML. The Section will assist the SU Project Manager for ensuring CGNEI and their contractors comply with all the management and mitigations measures stipulated in this EMP as well as conditions listed in the Environmental Authorisation (Environmental Clearance Certificate) should the project be approved.

The SU Environment Section shall perform random site inspections to check compliance with the EMP. A site close out audit shall also be conducted at the end of the project phase and an Environmental Completion Certificate issued if environmental performance and closure is found satisfactory.

CGNEI Project / Construction Manager

CGNEI is ultimately responsible for the implementation of the EMP (and be familiar with the relevant Sections of the Husab Mine EMP) and the financial cost of all environmental control measures. CGNEI must ensure that any person acting on their behalf complies with the conditions / specifications contained in this EMP. CGNEI is also responsible for the appointment of an “Owner Engineering Company” as well as the relevant sub-contractor(s) and Health, Safety and Environmental (HSE) Representative (either themselves or through the Owner Engineer).

CGNEI shall address any site problems pertaining to the environment at the request of Husab Mine’s Environmental Section and/or SU Project Manager.

The CGNEI Project Manager shall also be responsible for issuing penalties for contravention of the EMP.

It is the responsibility of the Project Manager to ensure an effective environmental close out audit is conducted at the end of the construction phase. Engagement for close out should be relayed 30 days in advance of close out of the construction site.

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Owner Engineer

The “Owner Engineer” shall oversee the planning, design and construction phases of the project and report to the CGNEI Project Manager.

The Owner Engineer shall address any site problems pertaining to the environment at the request of the HSE Representative.

The Owner Engineer shall act as the CGNEI ‘on-site implementing agent’ and has the responsibility to ensure that responsibilities are executed in compliance with the EMP. Any on-site decisions regarding environmental management are ultimately the responsibility of the Owner Engineer. The Owner Engineer shall assist the HSE Representative where necessary and shall have the following responsibilities in terms of the implementation of this EMP:

 Reviewing and approving the sub-contractor(s)’ Mini EMP and/or Method Statements/Procedures with input from the HSE Representative where necessary.  Monitoring and verifying that the EMP and Mini EMP and/or Method Statements/Procedures are adhered to at all times and taking action if specifications are not followed.  Keeping a photographic record of construction activities on site.  Assisting the sub-contractor(s) in finding environmentally responsible solutions to problems with input from the HSE Representative and the SU Environmental Section where necessary.  Ordering the removal of person(s) and/or equipment not complying with the EMP specifications.  Issuing penalties for transgressions of commitments raised in this EMP.  Delaying any construction activity if he/she believes the environment has been or is likely to be seriously harmed / impacted.  Communicating environmental issues to the HSE Representative.

Sub-Contractor(s)

The sub-contractor(s) shall have the following responsibilities:

 To implement all provisions of the EMP. If the sub-contractor(s) encounters difficulties with specifications, he / she must discuss alternative approaches with the Owner Engineer and/or the HSE Representative prior to proceeding.  To ensure that all staff are familiar with the EMP.  To make personnel aware of environmental issues and to ensure they show adequate consideration of the environmental aspects of the project.  To prepare required Mini EMP and/or Method Statements/Procedures indicating how the requirements of the EMP will be implemented.  To report any incidents of non-compliance with the EMP to the Owner Engineer and/or the HSE Representative and to correct them.

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 To rehabilitate any sensitive environments damaged due to the sub-contractor(s)’ negligence. This shall be done in accordance with the HSE Representative specifications, in liaison with the SU Environmental Section.

Failure to comply with the EMP may result in fines through legal persecution and reported non-compliance may result in the suspension of work or termination of the contract by the Engineer if not rectified or monitored to ensure no future adhesive impacts may arise.

HSE Representative

An HSE Representative will either be appointed by the CGNEI Project Team or the Owner Engineering Company. The HSE Representative’s duties shall include, inter alia, the following:

 Reviewing Mini EMP and/or Method Statements/Procedures.  Advising the CGNEI Project Manager and / or the Owner Engineering (and sub-contractors) on environmental issues within defined construction areas.  Undertaking regular (at least daily) site visits to ensure compliance with the EMP, Mini EMP and/or Method Statements/Procedures and verifying that environmental impacts are kept to a minimum throughout the contract.  Completing environmental checklists during site visits.  Monitoring and verifying that the EMP, Mini EMP and/or Method Statements/Procedures are adhered to at all times and taking action if specifications are not followed.  Monitoring and verifying that environmental impacts are kept to a minimum.  Keeping a photographic record of progress on site from an environmental perspective.  Assisting the Owner Engineering (and sub-contractors) in finding environmentally acceptable solutions to construction problems.  Recommending additional environmental protection measures should this is necessary.  Giving a report back on any environmental issues at site meetings and during monthly reports.  Reporting any incidents that may or have caused damage to the environment or breaches of the EMP to the SU Environmental Section.  Prepare an environmental audit report at the conclusion of the construction phase.  Provide training to personal/contractors staffs.

The HSE Representative shall communicate directly with the CGNEI Project Manager or the Owner Engineer and the SU Environmental Section. Should problems arise on site that cannot be resolved between the HSE Representative and the Owner Engineer, the HSE Representative shall take the matter up with the CGNEI Project Manager or the SU Environmental Section.

INTERNAL REVIEW AND AUDITING

An internal review process and procedure shall be established by CGNEI / Owner Engineer to monitor the progress and implementation of the EMP. Where and when necessary, method statements / procedures that

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Swakop Uranium (Pty) Ltd 733.03107.00001 733.03107.00001 Scoping Report (including impact assessment) for the Proposed amendment to the Husab Mine July 2019 activities and infrastructure - 12 MW Solar PV Power Plant July 2019 require modification shall be changed to improve the efficiency of the EMP, Different forums will be used for the ongoing training/awareness. As a minimum, training/awareness shall include in liaison with the SU Environmental Section. Swakop Uranium will conduct regular inspections and audits, throughout the various PV project phases.

ENVIRONMENTAL AWARENESS TRAINING

Before the commencement of any work on site, CGNEI, the Owner Engineer and all sub-contractors staff shall attend an environmental awareness-training course, presented by SU. The Owner Engineer shall liaise with the courses Project Manager and arrange inductions with the onsite security services.

Different forums will be used for the ongoing training/awareness by the HSE Representative. As a minimum, training/awareness shall include:

 Explanation of the importance of the work being conducted within the NNNP and within the Husab Mine ML with an approved EMP;  Explanation of the importance of complying with the EMP, Mini EMP and/or Method Statements/Procedures;  Discussion of the potential environmental impacts of construction activities;  Explanation of the management structure of individuals responsible for matters pertaining to the EMP.  Employees’ roles and responsibilities;  Explanation of the mitigation measures that must be implemented when carrying out their activities; and  Explanation of the specifics of the EMP, Mini EMP and/or Method Statements/Procedures and its specification.  Explain the NNNP park rules.

The Owner Engineer shall keep records of all environmental training sessions and SU inductions, including names of attendees, dates of their attendance and the information presented to them. Records of environmental training sessions shall be submitted to the HSE Representative.

PERMITS

CGNEI shall ensure that all contractors and employees have the required permits to enter the NNNP.

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MONITORING

Avifauna

An avifaunal monitoring programme shall be implemented throughout the construction and operational phases of the project in order to contribute to the research database. This will form part of the responsibilities of the SU Environmental Section. The monitoring programme shall be undertaken as part of routine maintenance activities. The following shall be recorded:

 Number of bird carcasses encountered around the modules / solar arrays;  Incidence of nests and nesting attempts; and  Increase in bird activity and unusual bird aggregations.

Any observations by CGNEI and their Contractors shall be sent to the SU Environmental Section.

DECOMMISSIONING AND CLOSURE

SU shall ensure that the proposed PV power plant and associated infrastructure will be incorporated into the overall Husab Mine Rehabilitation, Restoration and Closure Plan.

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WAY FORWARD

WAY FORWARD FOR THE SCOPING REPORT

The way forward is as follows:

 MET review the Scoping Report and EMP and provide record of decision.

ENVIRONMENTAL IMPACT STATEMENT AND CONCLUSION

It is SLR’s opinion that the environmental aspects and potential impacts relating to the proposed PV power plant, adjacent to the existing Husab Mine processing plant (on an already disturbed site), have been successfully identified. The following environmental aspects and their potential impacts associated with project development, as well as the cumulative impacts, (i.e. taking the current/approved facilities/activities and the proposed project into consideration) have been assessed:

 Physical impacts and general disturbance to avifauna as a result of the following: o Collisions of birds with photovoltaic (PV) panels and associated infrastructure o Attraction of novel species to the area by the artificial provision of otherwise scarce resources  Visual impacts due to the new PV power plant infrastructure.  Groundwater and surface water quality impacts and pollution of soil due to: o Possible hydrocarbon spillages from earth moving equipment and spillage of paint, concrete, etc. during the construction phase.  Air quality impacts (dust).  Socio-economic impacts, including: o Positive impacts relating to employment and skills development o Negative impacts including inward migration and social/security issues.

The assessment found that the proposed project present the potential for minimal additional risks and related impacts in the mitigated scenario.

SLR believes that a thorough assessment of the proposed PV power plant and associated activities have been achieved and that an environmental clearance certificate could be issued.

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REFERENCES

African Conservation Services cc (ACS). 2019. EIA amendment to the Husab Mine: proposed on-site 12 MW solar PV plant - Avifaunal baseline/scoping and assessment study.

JCM. 2019. 50MW Solar PV Power Plant Project, Global Environment Centre Foundation (http://gec.jp/jcm/projects/15pro_ban_03/).

SLR. 2010. EIA Report for the Proposed Husab Mine.

SLR. 2011. EIA Report for the Husab Mine linear infrastructure.

SLR. 2013. EIA Report amendment for the proposed changes to the Husab Mine (TSF amendment).

SLR. 2018. Scoping Report (including assessment) for the proposed changes to the Husab Mine (WRD amendment and on-site waste Incinerate).

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APPENDIX 1: CVS

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APPENDIX 2: INFORMATION SHARING RECORD

2.1 BID

2.2 NEWSPAPER ADVERTS

2.3 SITE NOTICES

2.4 E-MAIL CORRESPONDENCE TO I&APS

2.5 MEETINGS

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APPENDIX 3: IAP DATABASE

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APPENDIX 4: COMMENTS RECEIVED

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APPENDIX 5: AVIFAUNA SPECIALIST STUDY

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APPENDIX 6: COMMENTS AND RESPONSE REPORT

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