Environmental Scoping Report (Esr)

ENVIRONMENTAL SCOPING REPORT (ESR)

FOR THE PROPOSED SUBMARINE TELECOMMUNICATIONS CABLE (ACE CABLE SYSTEM) TO BE LANDED AT SWAKOPMUND, NAMIBIA, ERONGO REGION

Ebenos Technology Solution (Pty) Ltd (2019/0479)

12 September 2019

DOCUMENT INFORMATION AND APPROVAL

Environmental Scoping Report (ESR) For The Proposed Title Submarine Telecommunications Cable (ACE Cable) To Be Landed At Swakopmund, Namibia, Erongo Region ECC Application Reference number Activity 10.1 (g) communication networks including towers, telecommunication and marine telecommunication lines and cables; West coast of Swakopmund Location Namibia

Proponent Ebenos Technology Solution (Pty) Ltd (2019/0479) P.O. Box 21555, Windhoek 47 Nelson Mandela Avenue Windhoek, Namibia

Represented by: Mr. Tshuutheni Emvula

Author: Signature Date 12 September 2019 Mr. Ipeinge Mundjulu (EAP)1

Reviewer: 12 September 2019 Mr. Jonas Heita (EAP)

Copy Right:

“This document is the intellectual property of TEC and may only be used for the intended purpose. Unauthorized use, duplication, plagiarism or copying without referencing is prohibited”

1 EAP – Environmental Assessment Practitioner

TABLE OF CONTENTS Executive Summary ...... 1 1. Introduction ...... 4 1.1. Background ...... 4 1.2. A brief history of submarine cables ...... 5 1.3. Regulatory Requirements...... 7 1.3.1. Additional permits required for the project ...... 7 1.4. The Need and desirability of the Project...... 8 1.5. Terms of Reference ...... 8 1.6. Scope of study ...... 9 2. Project Description...... 9 2.1. Location ...... 9 2.2. Overview of project Components and Systems ...... 10 2.2.1. Submarine Cable ...... 10 2.3. Offshore ...... 14 2.3.1. Pre-Installation Phase...... 14 2.3.2. Installation Phase ...... 15 2.4. Onshore ...... 17 2.4.1. Beach Manhole ...... 17 2.4.2. Landing Location ...... 17 2.5. Project Schedule...... 19 2.5.1. Operation Phase ...... 19 2.5.2. Decommissioning Phase ...... 19 3. Description of the Affected Environment ...... 20 3.1. Land Use and Ownership ...... 20 3.2. Bio-Physical Environment ...... 20 3.2.1. Climate ...... 20 3.2.2. State of the Marine Environment ...... 21 3.2.3. The Coastal and Terrestrial Environment ...... 28 3.3. Socio Economic and Cultural Environment ...... 29 3.3.1. Population Demographics ...... 29 3.3.2. Economy, Livelihood and Employment ...... 30 3.3.3. Social Services and Infrastructures ...... 33 3.3.4. Cultural Heritage Sites ...... 33

4. Project Alternatives ...... 34 4.1. Analysis of alternatives ...... 34 4.1.1. No-go (No Project) ...... 34 4.1.2. Technical alternatives ...... 34 4.1.3. Technology ...... 35 4.1.4. Site ...... 35 5. Policy, Legal and Administrative Framework ...... 36 6. Public Consultation ...... 42 6.1. Newspaper Adverts ...... 42 6.2. Local Authority Consultation ...... 42 6.3. Public Meeting ...... 42 7. Impact Identification and Risk Assessment ...... 45 7.1. Pre-Construction Phase ...... 48 7.2. Construction Phase...... 53 7.3. Operational Phase ...... 60 7.4. Decommissioning Phase ...... 61 7.5. Cumulative Impacts ...... 62 8. Conclusions and Recommendations ...... 63 8.1. Conclusion ...... 63 8.2. Recommendations ...... 63 9. References ...... 64 10. Appendixes ...... 66 Appendix 1. Beach Man Hole Technical Description ...... 66 Appendix 2. Background Information Document...... 67 Appendix 3. Newspaper Adverts ...... 68 Appendix 4. Proof of Public Meeting ...... 69 Appendix 5. Environmental Management Plan (EMP) ...... 70 Appendix 6. CV for Environmental Assessment Practitioner – Author ...... 71 Appendix 7. CV for Environmental Assessment Practitioner – Reviewer ...... 72

List of Figures

Figure 1. The routing of the African Coast Europe submarine cable ...... 4 Figure 2. History of Africa Undersea Cables (Source: https://manypossibilities.net/african- undersea-cables/ retrieved on 25 August 2019)...... 5 Figure 3. Undersea Cables for the Sub-Saharan Africa (Source: https://manypossibilities.net/african-undersea-cables/ retrieved on 25 August 2019) ...... 6 Figure 4. The Scope of the EIA Process in Namibia ...... 9 Figure 5. Elements of the Submarine Cable System (Source: U.K. Cable Protection Committee & Alcatel Submarine Networks) ...... 10 Figure 6. Armored Fibre Optic Cable (Source: The David Ross Group Inc) ...... 11 Figure 7. Cable Armouring (DA, SA, LWP, LW) (Source: Axiom) ...... 12 Figure 8. Repeaters plan (Source: NEC) ...... 13 Figure 9. Branching Unit (Source NEC) ...... 13 Figure 10. Survey for the Cable route (Source NIWA) ...... 14 Figure 11. A plough burying the cable into the seabed (Alcatel Submarine Networks) ...... 15 Figure 12. Submarine Cable Lying Sea Plough (Source: Alcatel Submarine Networks)...... 16 Figure 13. Cable being guided by to the shore by divers (Source: Alcatel-Lucent) ...... 17 Figure 14. The Landing site for in Swakopmund at Ocean View...... 18 Figure 15. The BCLME and some of its major physical dynamics illustrating the complexity of this system ...... 22 Figure 16. Coastal configuration and continental shelf bathymetry of Namibia (Source: Bianchi et al, 1999) ...... 24

List of Tables

Table 1. Listed activity trigger by the proposed installation of the Submarine Cable ...... 7 Table 2. Cable armour characteristics for guidance only ...... 11 Table 3. Population Demography of Erongo Region, 2011 and 2001 (Namibia 2011 population and housing census main report) ...... 30 Table 4. Policy, Legal and Administrative Framework ...... 36 Table 5. The impacts assessment criteria ...... 45

ACRONYMS

ACE Africa Coast to Europe BID Background Information Document BMH Beach Man Hole BU Branching Unit CLS Cable Landing Station CS Cable Station DEA Department of Environmental Affairs DSR Draft Scoping Report EA Environmental Assessment EAP Environmental Assessment Practitioner ECC Environmental Clearance Certificate ECO Environmental Compliance Officer EEZ Exclusive Economic Zone EIA Environmental Impact Assessment EMA Environmental Management Act (No. 7 of 2007) EMP Environmental Management Plan FO Fibre Optic HDPE High-density polyethylene I&APs Interested and Affected Parties MET Ministry of Environment and Tourism MPAs Marine Protected Areas Nm Nautical Miles PLGR Pre-Lay Grapnel Run PPE Personal Protective Equipment RS Route Survey SM Site Manager TEC Tortoise Environmental Consultancy TW Territorial Waters UNCLOS United Nations Convention on the Laws of the Sea WACS West Africa Cable System

MFMR Ministry of Fisheries and Marine Resources

Executive Summary

Introduction

Telecommunication is the most important aspect of today’s technology. However, such communication must be effectives, fast and reliable. Submarine cables provides fast, cost effective and fast telecommunication around the world. Today, submarine cables are further used for transmission of power to secluded areas such as islands. Vision 2030 for Namibia aims for the country to be industrialized in year 2030. The main catalyst of this industrialization is the infrastructural development and advancement of information communication technology. Hence, Namibia is among other African countries investing in submarine cables for telecommunication.

Project Description

Submarine cables consist of Fibre Optic Cable which transmit data via beams of laser- generated light that are internally reflected within the optical fibres. The cable consists of an inner fibres surrounded by high density polyethylene plastic insulator or a fiberglass core that ensures fibre separation and provide strength, protection and insulation. A comprehensive technical description of the project is provided in chapter 2.

Policy, Legal and Administrative Framework

The protection of the environment is enshrined in the Namibian constitution under article 95. Further, the Environmental Management Act (No 7 of 2007) has listed activities that may not be under taken without an Environmental Clearance Certificate. Against this, the project falls under the listed activity, hence it is required that an environmental impact assessment is done for the project’s approval. There are various national and international legal instrument that the project must adhere to. The summary of the policy, legal and administrative framework is given under chapter 5.

The Need and Desirability of the Project

Submarine telecommunication is essential for effective communication as the transport about 100% of transoceanic internet traffic in the world. Namibia telecommunication is currently reliant to one submarine cable WACS, which may cause internet shutdown during maintenance or damage to the cable. Further, being a gate away to many landlocked neighbors, Namibia is well position to export internet to neighboring countries.

Description of the affected environment

Namibia has one of the most productive fishing grounds in the world oceans due to an upwelling ecosystem called Benguela upwelling; renowned as the Benguela Current Large Marine Ecosystem (BCLME). The seabed area between Cape Cross and Walvis is made up of mud, and relatively rocky on the inshore. Various literature has indicated that, submarine cables are not detrimental to the environment, given that due consideration is undertaken during their installation. To ensure that sensitive marine areas are avoided, a non-evasive marine geophysical survey is conducted to map the seabed and to determine cable route. A comprehensive description of the environment is given chapter 3

Potential Impact and Mitigation Measures

A comprehensive desktop scoping study was done with the aim to identify the need of specialist studies. All identified impacts were properly studied and mitigation measures proposed. None of the impact were deemed significant. A detailed impact assessment is provided in chapter 7.

Project alternative and analysis of alternatives

Submarine telecommunication is an advance field of technology whose activities are constructed and installed by specialized ships and equipment’s. The main trunk of the ACE cable is already installed, the area proposed of the landing site is already serviced with provision of the municipal bulk services and the beach man hole is less than half a kilometer to the landing station, which is ideal in reducing the trenching distance. Description of alternatives is given in chapter 4. 2

Conclusions and Recommendations

The study recommends to the approving authority for the approval of the project subject to the condition of undertaking the route determination survey before the pre-installation and installation of the cable.

1. Introduction

1.1. Background

The world has become a global village and telecommunication has fast become an integral part of human activities. Unlike in the past where communications satellites were mostly used, the

20th century telecommunication require high speed data, internet, voice & video communication such as video conferencing. The high speed telecommunication has been achieved through the submarine cables. To ensure global competitiveness, African countries are fast investing in submarine cables for communication.

Namibia is envisioned to become an industrialized country by 2030. To achieve this, infrastructure development, especially in Information, Communication and Technology (ICT) are high priority in the country’s development plan (NDP 5).

Together with other African countries, Namibia, through Ebenos Technology Solution (Pty) Ltd, is investing in the African Coast to Europe (ACE) submarine communications cable system that run along the west coast of Africa between France and South Africa (Fig 1).

Figure 1. The routing of the African Coast Europe submarine cable

1.2. A brief history of submarine cables

The first type of submarine cable were the power cables installed in Germany in 1811 (International Cable Protection Committee Ltd). While the first telecommunication cables were coaxial telephone cables used from 1950s to the late 80s. They have copper wires to carrying analogue electrical signals and range from 40 to 100 mm. They are protected by coatings of steel components and plastics (polyethylene). While the modern telecommunication cables are fibre optic cables which were introduced in the 1980´s (Dr Karin Meißner et al 2006). A fibre optic cable sends information (including sounds converted to digital signals) by shooting pulses of light through thin transparent fibers usually made of glass or plastics. The history of the AUC for Africa is shown in figure 2.

Figure 2. History of Africa Undersea Cables (Source: https://manypossibilities.net/african- undersea-cables/ retrieved on 25 August 2019). 5

An overview of the current and future Sub-Saharan Africa sub-marine cables are shown in figure 3.

Figure 3. Undersea Cables for the Sub-Saharan Africa (Source: https://manypossibilities.net/african-undersea-cables/ retrieved on 25 August 2019)

1.3. Regulatory Requirements

The Environmental Management Act (also referred to as the EMA), stipulates that for each developmental project, which is listed under the EIA regulations, an Environmental Impact Assessment (EIA) should be conducted.

The aim of the EIA is to identify, assess and ascertain potential environmental impacts that may arise from the proposed activity. According to the EMA, an EIA is a process of identifying, predicting, interpreting and communicating potential impacts to interested and affected parties (I&APs).

The proposed installation and operation of the Submarine Cable triggers some listed activities in terms of the Environmental Management Act no. 7 of 2007 and the Environmental Impact Assessment Regulations of 6 February 2012 that may not be undertaken without an environmental clearance certificate (ECC). The triggered activities are shown in table 1below.

Table 1. Listed activity trigger by the proposed installation of the Submarine Cable

Activity Description of the Activity Operation of the Activity 10. 1 (e) any structure The installation of the This activity is only triggered below the high water mark of Submarine Cable shall take during construction and /or the sea; place at sea, which is below decommissioning phase of the the high water mark project. 10.1 (g) communication The project entails the The Marine Cable would provide networks including towers, construction of the high speed internet to Namibia. telecommunication and marine Submarine telecommunication lines and Telecommunication Mable cables;

1.3.1. Additional permits required for the project

The operations of maritime activities are regulated by the Ministry of Work and Transport under the Department of Maritime Affairs. Necessary permits to operate in the Namibian Economic Exclusive Zone shall be required. Furthermore, the landing station shall be stationed in the local authority of Swakopmund Municipality, hence the operation shall be subjected to the local authority bi-laws and obtain all necessary permits and approval especially the construction of the landing site and beach manhole.

1.4. The Need and desirability of the Project

This project is line with the country’s National Development Goal (NDP 5), Vision 2030 and Harambee Prosperity plan in steering the country towards becoming a developed nation. High- speed telecommunication is essential for effective communication by reducing the cost of travel and indirectly reducing carbon footprints. Namibia telecommunication is currently reliant to one WACS marine cable, which may cause internet shutdown during maintenance or damage to the cable. Lastly, Namibia is strategically located to supply internet to its landlocked countries, which shall boost the country economy and an additional internet supplier would be mean better competition which shall be advantageous to consumer.

1.5. Terms of Reference

The Terms of Reference (TORs) for this Environmental Impact Assessment study is in accordance to the Environmental Management Act 2007 and its Regulation Section 9 (a-b). The overall aim is to obtain an Environmental Clearance Certificate (ECC) in order for the project to be implemented. It considers all other relevant local, national and international laws. These guidelines are aimed to focus on issues of greater environmental concerns and to develop mitigation measures to ensure effective environmental management. The TORs of this project includes, but not limited to the following;

• Provide a comprehensive description of the proposed Project; • Identify relevant legislation and guidelines for the project; • Identify potential environmental (physical, biological and social) conditions of the project location and conduct risk assessment; • Inform Interested and Affected Parties (I&APs) and relevant authorities about the proposed project to enable their participation and contribution; • Develop an Environmental Management (EMP) that would be a legal guideline for the environmental protection by the project

1.6. Scope of study

An EIA is a process that evaluates the likely environmental and social effects of a proposed project or development, which identifies suitable mitigation for to avoid or minimize the predicted impacts. The envisioned EIA process will be undertaken in a holistic approach encompassing different elements as shown in figure 4.

Figure 4. The Scope of the EIA Process in Namibia

2. Project Description

This Environmental Impact Assessment (EIA) for the project shall be undertaken in two components; the marine and the land component. This chapter describes the infrastructure and operational aspects of the ACE Cable System.

2.1. Location

The main trunk The main cable trunk is located 354km off the coast of Swakopmund. Hence the branching unit submarine cable system would include an installation of about 400 km of subsea cable towards Swakopmund (figure 1). A beach manhole is located at 9

Ocean View beach (22°37'51.93"S, 14°31'28.06"E) less than a kilometer to the proposed landing station.

2.2. Overview of project Components and Systems

2.2.1. Submarine Cable

The submarine cable system consists of Fibre Optic Cable, Repeater and a Branching Unit. The land unit consist of supporting units including the power feed equipment and undersea network management system Figure 5.

Figure 5. Elements of the Submarine Cable System (Source: U.K. Cable Protection Committee & Alcatel Submarine Networks)

Fibre Optic Cable

Fibre optic cables transmit data via beams of laser-generated light that are internally reflected within the optical fibres. The cable consists of an inner fibre surrounded by high density polyethylene insulator or a fiberglass core that ensures fibre separation and provide strength and insulation. The diameter of the subsea cables varies between 17 and 20 mm for sections without protective armor while armored cables can be as large as 50 mm in diameter (Figure 6).

Figure 6. Armored Fibre Optic Cable (Source: The David Ross Group Inc)

Deep sea cable does not often require armored protection because of minimal anthropogenic threat, while shallow cable at depth less than 2000m requires some level of protection which increases towards shallower depths (Table 2 and Figure 7). The diameters of the marine optic fibre cables range in size from 17 mm diameter (cables installed at a water depth of between 7,000 – 1,500 m) to 37.5 mm diameter (rock armoured cable which is installed in shallow water depths (< 200 m)).

Table 2. Cable armour characteristics for guidance only

Cable Type Characteristics Water Depth

Light weight (LW) Deep water cable for areas where no < 2 500 m significant hazards exist Light weight protected Light weight cable with an abrasion resistant < 2 500 m (LWP) covering. Suitable for areas where rugged topography is crossed, such as the mid Indian ridge Single Armor Light (SAL) A relatively light weight cable for use in 1 500 ‐ 2 500 m areas where good burial is possible, and external threat risk is relatively low Single Armor (SA) Usually used in areas where only limited 100 ‐ 1 500 burial is possible Double Armor (DA) A well-protected cable for use in areas where little or no burial is anticipated and 0 ‐ 100 for shore ends

Similar to double armour but with improved < 200 Rock Armor (RA) impact resistance and more flexible, hence better able to conform to an undulating rock seabed

Figure 7. Cable Armouring (DA, SA, LWP, LW) (Source: Axiom)

Repeaters

The strength of the light signal reduces with distance. To provide periodic optical amplification an electrical powered amplifier “commonly referred to as repeaters” are installed in the marine cable at intervals of 80km. The repeater receives electrical power via the cable’s copper conductor (Figure 8).

Figure 8. Repeaters plan (Source: NEC)

Branching Units

Branching Units (BU) is branch of submarine telecommunications cable systems network from the main route (often called trunk route) which allow the cable to split in order to serve more than one destination of landing network (Figure 9). All consortium member countries shall be connected to the main ACE cable via a BU.

Figure 9. Branching Unit (Source NEC)

2.3. Offshore

2.3.1. Pre-Installation Phase

a) Cable Route Survey

Before the installation of the cable, a marine geophysical survey must be undertaken to determine best route for the cable (Figure 10). The cable routes cable routes are carefully surveyed and selected to minimize environmental impacts and maximize cable protection.

Figure 10. Survey for the Cable route (Source NIWA) At shallow water, the survey is determined by divers with aid of equipment’s such as side-scan sonar and seabed bottom profiles. Prior to the installation of the cable, a Pre Lay Graphel Run (PLGR) which involve dragging a grapnel along the survey route in necessary to ensure that the cable route is free of any obstacle such as fishing wires, nets and any debris.

For the purpose of this assessment, a route determining survey must be a condition for environmental clearance for the commencement of the cable installation.

2.3.2. Installation Phase

a) Cable Burial

The main cable trunk is located 354km off the coast of Swakopmund. A specialized Cable Laying Ship will install the Branching Unit of the cable consistent with the industry practice as indicated in figure 11 to the shore of Swakopmund along the pre-installation cable route. Some countries have regulatory requirement on the minimum depth for laying the cable, in the absence of minimum depths, the burial depth depends on various factors such, the types of threats present, habitat, sediment the depth of water. In deep water, (depths >1500m) the cable shall rest on the seabed and shall eventually sink into the seabed, at this depth the risks of damage by activities such as fishing or vessel anchoring are minimal.

Figure 11. A plough burying the cable into the seabed (Alcatel Submarine Networks)

In shallow depths, (depth <1500) the cable shall be buried about 1-1.5m below the seabed to ensure its protection from fishing and maritime activates. The burial is done by feeding the purpose build sea plough submerged onto the seabed with the cable from the ship (Figure 12).

Figure 12. Submarine Cable Lying Sea Plough (Source: Alcatel Submarine Networks)

A plough towed by the cable ship opens a gulley in the seabed of about 0.75 m wide. The cable passes through the plough and exist at the lower end of the plough. The cable is laid in the gulley as the plough moves forward.

Where burial is not impossible due to rocky seabed, or when there is a high risk of cable damage the cable may require some form of protection. Protection may be applied in form of a rock- mattress cover, cast iron shells, cable anchoring, ducting or rock dumping or cover cables with reinforced concrete slabs or steel plates. The impact on the seabed by the sea plough is known be minimal, the footprint in form of skid marks is expected affect an area of 5m in width, an insignificant area.

At shallow depths, the cable shall be suspended by floats and guided into position by small boats and divers as determined by the survey route (Figure 13). The cable shall be pulled via a winch into a pre-constructed beach man hole (BMH). After securing the cable in the BMH, the divers would follow the cable back in the water with handheld water jetting machine to bury the cable to a depth of about 1m.

Figure 13. Cable being guided by to the shore by divers (Source: Alcatel-Lucent)

2.4. Onshore

2.4.1. Beach Manhole

The marine cable is connected to the land cable via the beach manhole (BMH) located at 22°37'51.93"S, 14°31'28.06"E. The BMH is a constructed chamber, above the high tide level where the marine cable is connected to the land cable, the technical description of the BMH is given in appendix 1. The marine cables are pulled in the BMH with winches of which may cause short term and localized disturbances to beach goers. The beach is seldom used, mostly by resident taking a walk, but not as a public recreational place.

2.4.2. Landing Location

The landing station is less than half a kilometer from the BMH and located at 22°37'48.33"S 14°31'43.58"E (figure 14). The land cable shall be installed in trenches from the BMH to the landing station in accordance with laws and town planning pf Swakopmund Municipality. It is recommended that the cable is installed below all existing ground installation and future installation. The building plans for the landing station shall be subjected to the laws of Swakopmund Municipality.

Figure 14. The Landing site for in Swakopmund at Ocean View

2.5. Project Schedule

As soon as the project is approved, a route survey shall be undertaken. The result of the route survey shall be shared with Department of Environmental Affairs for the amendment of the Environmental Clearance Certificate. After the approval of the amendment, all necessary permits shall be obtained and cable installation shall commerce. The route determining survey is expected to start in the first quarter of 2020 while the Deep and shallow water cable lying is planned to start between March and April 2020. The cable has a lifespan of 25 years; hence its decommissioning is expected in 2045.

2.5.1. Operation Phase

a) Operation and Maintenance

The installation of the submarine cables is known to be safe and one that hardly requires frequent maintenance. In an unfortunate event of damage to the cable, the damaged segment shall be retrieved and repaired.

2.5.2. Decommissioning Phase

The lifespan of the cable is 25 years. At the end of its lifespan, the cable may be removed from the seabed for replacement.

3. Description of the Affected Environment

This chapter describes the physical, biological, social and economic environmental setting of the area in which the project is located. In general, Swakopmund is the second biggest coastal town in Namibia. It is renewed as a tourism attracting town. Offshore, it is a cold Atlantic Ocean driven by a productive Benguela upwelling well known for its support of abundance marine resources. The landing station is located in town, in an area that is already with provisions of municipality.

3.1. Land Use and Ownership

Namibia land ownership is in the form of freehold title. Every land that does not have a title deed, belongs to the state and is subjected to government laws. While land in local authorities are subjected to local authority act and the bylaws of the town council. At sea, the area from the high water mark to the international water line, (200 Nm) belongs to the state. The Erf 365 Ext 1 in Swakopmund was offered to Messrs Namibia Desert Giant Group (Pty) Ltd, Ebenos Technology Solution PTY Ltd will buy the site after EIA is approved, the offer for the purchase has been accepted and can only be executed after the EIA certificate compliant. All activities shall be subjected to the national and international law of the sea.

3.2. Bio-Physical Environment

3.2.1. Climate

Swakopmund is a coastal town whose weather conditions is influenced by the cold Benguela Current of the Atlantic Ocean and a hot dry Namib Desert. Like any other coastal town of Namibia, there is little to no rain, lower temperatures, less radiation and sunshine, strong eastern winds, high humidity and frequent fog. The average maximum temperature is 24ºC in March and 19ºC in September while the average minimum temperature is 16ºC in Feb and 9ºC in August. The wind blows southerly, westerly and south-westerly. The area receives an annual average rainfall of 8 mm. Desert ecology in the arid Namib desert is supported by fog that is carried by wind.

3.2.2. State of the Marine Environment

Namibia, situated on the west coast of Africa between Angola and South has a huge area of the South Atlantic Ocean. The country’s Exclusive Economic Zone (EEZ) is about 530,000 square kilometers, which is about two thirds of the total land area. Being a signatory to the United Nation Law of the Sea Convention, the country has declared Territorial Water of 12 nautical mile (Nm) and an EEZ of 200 Nm.

a) The Benguela Upwelling

The country has one of the most productive fishing grounds in the world oceans due to an upwelling ecosystem called Benguela upwelling; renowned as the Benguela Current Large Marine Ecosystem (BCLME), because it extends from Cape of Good Hope to 27°E longitude, approximately Port Elizabeth of South Africa through Namibia to Angola northern border of Angola (Cabinda) (Figure 15).

Figure 15. The BCLME and some of its major physical dynamics illustrating the complexity of this system In these ecosystems, because of the interaction between wind movement and the rotation of the earth, surface waters are pushed offshore causing deeper, colder, nutrient-rich waters to rise towards the surface to replace them, hence being called upwelling; which is a process that leads to high primary productivity that in turn supports large populations of marine organisms including fish, marine mammals and seabirds.

The Benguela Current Large Marine Ecosystem current, but naturally sub-divided into three parts; the cold Benguela which originate from Lüderitz Namibia, and the two warm water current from South Africa and Angolan’ coast (O’Toole et al 2001, Shannon et al 2004, Wolfgang Fennel 1999). The most productive ground is found in the area of Lüderitz. There are about 20 fish species in the Namibian waters (EEZ 200nm). The most important commercial fishery includes; Hake Merluccius capensis and M. paradoxus, Horse mackerel Trachurus capensis, Monk Lophius vomerinus Red Crab Rock Lobster, Orange Roughy and Pilchard Sardinops ocellatus. Fishing

activities are mainly industrialized which are divided into two categories, pelagic and demersal fishery.

b) The Coast and Shelf Topography

The Namibia coastline stretches some 1500 km from Orange River to Kunene river mouth. The coastal area is characterized by arid desert condition. According to Bianchi et al, 1999, the shelf area from the shore to a depth of 200 m is approximately 110 000 km2, and about double as much to 1 000 m. The shelf is widest off the Orange River and off Walvis Bay, and narrowest off Kunene River to Cape Frio. The depth of the shelf edge varies, averaging about 350 m. Two pronounced double shelf breaks occur at depths of 140 and 400 m in the Walvis Bay region (Figure 16).

Figure 16. Coastal configuration and continental shelf bathymetry of Namibia (Source: Bianchi et al, 1999)

The bottom sediments are known to form textural zones parallel to the coast and becoming finer towards offshore. This pattern is altered inshore by the presence of rivers and biological deposition. Hence there is a significant presence of a mud belt in the midshelf, between Cape Frio and Conception Bay, about 500 km long. The mud belt area includes the west coast of Swakopmund where the project is located, hence it is advantageous because the cable lying shall be easily achieved with ease in the mud.

a) Marine Ecology

Namibians water contains high abundance of fish and relatively low diversity. It contains, Cetaceans (Whales and Dolphins) Marine Mammals (Seals), Sharks, Skates and Rays, Turtles, Birds, Fish (Demersal and Pelagic Fish species), Sea Birds and Shellfish. For a comprehensive species abundances and location in the Namibian water, A Field Guide to the Living Marine Resource of Namibia is recommended as an attachment to this document.

Cetaceans (Whales and Dolphins)

The order Cetacea is subdivided into 2 groups: the Mysticeti (baleen whales) and the Odontoceti (toothed whales, dolphins, and porpoises). The suborder Mysticeti comprises 4 families and 11 species, 8 of which can be found in Namibian waters. The suborder Odontoceti comprises 9 families and about 65 species, 23 of which have been recorded in Namibian waters.

Stranded cetaceans have been used by Khoikhoi people along the Namibian coast for millennia. They provided these nomadic groups with food and even building materials as the bones of large whales were used to build huts on this treeless desert coast. After the arrival of Europeans, the first attempts to catch cetaceans were made. Whaling developed quickly during the second half of the

18th century with the arrival of American and European whalers in search of right whales. By the middle of the 19th century, the southern right whale was driven to virtual extinction in the area and whalers turned their attention to the humpback whale whose populations also soon began to decline. The end of the 19th century marks the beginning of modern industrial whaling using steam boats and cannon harpoons. The intensive exploitation of all species of large whales throughout

their range began, and Namibian waters were no exception. During the first 30 years of this century sperm whales, humpback whales, fin whales, blue whales, and other species were caught and processed at whaling stations along the Namibian coast. The local populations soon declined dramatically and shore-based whaling was abandoned in favor of large whale factory ships. Today, most species once exploited in Namibian waters are still very rare and all cetaceans are fully protected in the area (Bianchi et al, 1999).

Marine Mammals (Seals)

The Order Pinnipedia (seals) is represented in the area by members of 2 families: the Otariidae which include fur seals and sea lions, and the Phocidae which include true seals (including elephant seals). Only 1 seal, the South African fur seal Arctocephalus pusillus pusillus breeds on the Namibian coast. The subantarctic fur seal Arctocephalus tropicalis is a very rare vagrant and not included in the guide. The southern elephant seal Mirounga leonina is also a rare vagrant but occurs more regularly and is included in this guide. In addition, the skull of a leopard seal was discovered in the sand at Sandwich Harbour.

In the world, Cape fur seal are only found in Namibia, Angola and South Africa. Namibia has about 60% of the population on twenty-six colonies along the coastline (MFMR Annual Report 2014). Cape fur seal harvesting is one of the oldest fisheries in Namibia. Harvesting took place indiscriminately between the 17th and 19th centuries which consequently lead to the reduction of seals population to very low levels by the beginning of the 20th century. The resource recovered towards the end of the 20th century (Bianchi et al, 1999).

Sharks

Based mostly on the work of Compagno (1984, 1985, 1989, and 1991), about 46 species in 15 families of sharks are reported from Namibia (Bianchi et al, 1999).

Skates and Rays

Mostly from the work of Compagno and collaborators (1989 and 1991) and our collections, we count 28 species in 7 families and 3 orders of batoid fishes from Namibia. A checklist of batoid fishes is included in the Appendix in order to serve as an aid to a more accurate assessment of the batoid resources of Namibia. Although not actively fished, they are consistently caught in the bottom trawls of the hake fishery and constitute a substantial biomass in the demersal community (Bianchi et al, 1999).

Turtles

Of the 8 species of sea turtles worldwide, 5 occur in Namibia. Most sea turtle species are considered endangered and are protected under an international agreement. All turtles receive total protection in Namibia. In the past they were incidentally exploited for their fresh meat, their eggs, for ornamental crafts made from their shell, and for leather from their skin. Today they are inadvertently caught in some fisheries. This guide is intended as an aid for conservationists in the management of this endangered group (Bianchi et al, 1999).

Bony Fish Species

There are around 410 species in 137 families of bony fishes that occur in marine waters of Namibia. These include the species of primary commercial importance, such as hakes, pilchard, and horse mackerel, Kingklip, Monk and Orange Roughy and many other species that are exploited as bycatch in the bottom trawl and purse-seine fisheries (Bianchi et al, 1999).

Sea Birds

Approximately 62 species of seabirds have been recorded in Namibian waters, 20 of which are only rare vagrants. Twelve species of seabirds breed along the Namibian coast. These are: the jackass penguin, Spheniscus demersus; the white pelican, Pelecanus onocrotalus; the Cape gannet,

Morus capensis; the white-breasted cormorant, Phalacrocorax carbo; the Cape cormorant, P. capensis; the bank cormorant, P. neglectus; the crowned cormorant, P. coronatus; the kelp gull, Larus dominicanus; hartlaub’s gull, L. hartlaubii; the greyheaded gull, L. cirrocephalus; the swift tern, Sterna bergii; and the damara tern, S. balaenarum. The first 7 of these are significant guano producers and included in this guide. Also included here are 11 species of pelagic seabirds commonly encountered by fishermen at sea (Bianchi et al, 1999).

Shellfish

b) Marine Protected Areas

Due to the fast depleting fish stock in the world, mainly as a result of over-fishing, unsustainable harvesting practices and unregulated anthropogenic activities such as seabed mining, the world has adopted a holistic conservation approach called Marine Protected Area as a tool to promote sustainable marine resource use and marine biodiversity conservation. The importance of MPA is well established in various literature and regional and international conventions. In Namibia, all island and areas surrounding them are Marine Protect Area (Heidi Currie et al, 2008). Further protection is given in terms of Bathymetry, where trawling is not allowed beyond the 200m isobaths in order to protect spawning areas and juvenile fish. There project area does not have an MPA (Bianchi et al, 1999).

3.2.3. The Coastal and Terrestrial Environment

The proposed landing station is within the town of Swakopmund at Ocean View Suburb Erf 365. The beach man hole is located on an area that is not a recreational site, hence it is less frequented, unless by people taking a walk on the beach. Trenching shall follow the municipality existing services. In instance where the cable has to transverse in area with potential of habitat destruction, a comprehensive on land impact assessment should be undertaken. The BMH is less than half a kilometer to the landing station. The area is serviced with bulk municipal services, hence no habitat destruction is envisioned buy the project.

3.3. Socio Economic and Cultural Environment

3.3.1. Population Demographics

The overall Namibian population has grown steadily since 1921 rising from under one quarter of a million in 1921 to 1.8 million in 2001 and 2.1 million in 2011. About 900 000 people, which account for 42% of the population lives in urban areas. The population is relatively young, with 37% of the whole population being less than 15 years of age. The median age for the overall population is 21 years, which makes half of the Namibian population to be under the age of 21. Close to 52% of the population is female.

Swakopmund is second largest coastal town in Erongo region after Walvis Bay and, the fourth largest town in Namibia with a population 44 725. Erongo region has a population of 150 809 people and a growth rate of 1.3%. The region has an area of 63 579 m2 with an average of 2.4 people per km2. The population demography of the Erongo region is shown in table 4 below.

Table 3. Population Demography of Erongo Region, 2011 and 2001 (Namibia 2011 population and housing census main report)

The population if Swakopmund has more than doubled over a decade mostly due to the construction and operation of several Uranium mines in the region.

3.3.2. Economy, Livelihood and Employment

Namibia has one the highest inequality wealth distribution in the world. The country’s unemployment stands at the staggering 38% which is worse among the youth. Namibia’s human

development index is rated low, at 0.61 which is ranked 128th out of 186 countries. This inequality is brought by the colonialism and apartheid regimes that excluded natives in the main stream economy. As a result, 90% of the country’s economy is controlled by less than 10% of the minority white population. Contrastingly, the World Bank classified Namibia as an upper middle-income country, with a Gross Domestic Product (GDP) per capita of around US$5700. The reliance of this classification on GDP-derived indicators masks the unambiguous past inequalities that defines the Namibian society because it overlooks the vulnerability of the majority of the population with high rates of poverty (30% of the total population) and a Gini coefficient of 0.59. Thus the quality of life is not in unison with the country’s macro indicators.

Erongo region has a relatively low rates of unemployment at 30% compared to the national unemployment of 38%. According to the National Statistic Agency (NSA) report of 2014, The main sectors of employment in the region includes, manufacturing (11.5%), mining (11.7%), fishing and agriculture (11.5%), construction (9%), repair of motor vehicles (9%) and administrative / support services (8%). Erongo region is faced with the challenge of high rate of HIV/Aids.

a) Fishing

Namibia has one of the biggest fishing industry in Africa. The fishery sector is administered by the Ministry of Fisheries and Marine Resources (MFMR). It contributes an average of 3.5 percent to the real GDP and is regarded as an important sector because (i) it is the fourth-largest foreign currency earner (as of 2012); (ii) it is a big employer, especially in the Erongo region, employing about 25,000 people in 2012; and (iii) it has potential to contribute to the country’s food security and livelihood diversification. Nearly half the harvested fish is exported to the SADC region, and domestic consumption is about 10 percent of the harvest.

The fishing operation includes catching and processing. Catching is done through various forms, from traps for crabs and rock lobster, line fishing, purse seining and demersal and pelagic trawling. Other fishing activities which are regarded as small scale include daily operated ski boat, while hook and line is mostly used for subsistence.

b) Tourism

Tourism is one of the fastest growing industry in world and Namibia is not exception. The direct contribution of the tourism sector in 2015 is estimated at N$5.2 billion of value added and more than 44,700 jobs country wide. Swakopmund is Namibian’s favorite tourist destination town in Namibia, both for local and international tourism.

c) Transport and Logistics

The port of Walvis Bay in an international gateway from Namibia’s landlocked neighboring countries. This makes Namibia, Erongo region in particular to be a transport and logistic hub in Namibia.

d) Offshore Mining and Exploration

Namibian is renowned with the mining offshore diamonds. There are several explorations of hydrocarbons and other minerals at sea. The Ace cable shall pass through an inactive Exclusive Prospecting Licence; hence no direct impacts is expected. The submarine cables are legally protected by international laws and provision is made to create a buffer zone for their protection. Future activities shall be prohibited in this buffers zone.

e) Terrestrial Mining

Terrestrial mining in Erongo is known for Uranium. It has several Uranium mines and the fourth largest Uranium mine in the word. Other mining includes, stone quarrying.

f) Submarine Cables

The proposed ACE submarine cable is not the first to land in Namibia and in Swakopmund in particular. Telecom Namibia, the country’s biggest telecommunication company operates a West Africa Cable System (WACS) submarine cables. The entry point or the beach man hole for the WACS cable is 5km south of the proposed ACE Cable. During a public meeting, Telecom Namibia 32

welcomed the proposed ACE, commenting that it will increase Namibians competiveness in ICT and may act a backup in instance where the WACS cable fail.

3.3.3. Social Services and Infrastructures

According to the Road Authority, Namibia tops the list of African countries in road infrastructure development. The main roads include the Trans-Kalahari, which connects Namibia to the eastern part of the country and to neighboring countries, Zambia, Zimbabwe and Democratic Republic of Congo and there is a major Trans-Kalahari highways which connect South African to the rest of Namibia.

The Swakopmund Town Council provides for the upgrade, and construction of bulk services, such as, road, electricity, water, and sanitation to the town. There are government and private hospitals. Like many towns in Namibia, provision of decent housing is challenge.

3.3.4. Cultural Heritage Sites

Swakopmund town has a dark colonial history and as a result, there are various cultural and heritage sites. These site include, the railway bridge, which was built by forced labour, light house, German Lutheran Church, Old station building, Kaserne, the Hohenzoller building, Marine Monument, Martin Luther Steam Engine. While Erongo region has other sites such as the Cape Cross monument and the white lady at Brandberg and Spitzkoppe.

4. Project Alternatives

The identification and analysis of alternatives is an integral component of the ESIA process. Its purpose is to provide the approving authority with a broad range of information in which it demonstrates and compare the environmental implications of various feasible project alternatives options available to execute the project, while minimizing the impact on the environment. Project alternative are considered during the design stage of the project to prevent the implementation of expensive mitigation measures at the later state of the project. The alternatives consider no-go, site, technological and equipment (technical) alternatives.

4.1. Analysis of alternatives

4.1.1. No-go (No Project)

This alternative considers a no project option. This alternative is detrimental to the development of country, and would severely deprive the country’s opportunity for economic growth. Telecommunication are important for business, reduce travel cost and are effective in enhancing decision making. Hence this alternative is not ideal to be considered.

4.1.2. Technical alternatives

The sub-marine telecommunication cables are installed by specialized vessels made only for the installation. A sea plough is made with a blade that buries the cable to the desirable depth, with a foot print of less than 5m. There is minimal disturbance to the seabed, which is expected to be temporally. The water jets used for trenching and burying the cable in shallow water is environmental friendly. Due to the specialization of operation, the is no other know environmental friendly technical procedures that may be adopted. Cable protection measures, such as concrete mart, of pipes at hard surface shall in the long term become marine habitats for the marine organisms.

4.1.3. Technology

Telecommunication submarine cable are all made of fibre-optics. They are durable, can last for 25 years, and does not pose danger to the environment.

4.1.4. Site

The ACE cable is already installed off the Namibian coast. There is also an existing WACS cable in Swakopmund. Further, there is little activities, in terms of fishing, transportation happening of the coast of Swakopmund. Lastly, it is recommended that Submarine cable are closely aligned, toward one entry point. The BMH point is selected, because there shall be no disturbances to the local environment, and that it is less than half a kilometer to the landing station, hence the trenching for the cable to the main landing station is short. The landing station is situated in the serviced area with the provision of bulk facilities by Swakopmund municipality.

5. Policy, Legal and Administrative Framework

The construction and operation of the ACE submarine cable shall be affected by the legal framework as shown in Table 4. The operators of the ACE must ensure that its operation is in accordance to the relevant national and international law, especially in safeguarding the environmental and ensuring health and safety to employees. Table 4. Policy, Legal and Administrative Framework

Legislation Summary The Namibian Constitution The Namibian constitution is the supreme law of the country which is committed to sustainable development. Article 95(1) of the Constitution of Namibia states that:- “The State shall actively promote and maintain the welfare of the people by adopting policies aimed at… The maintenance of ecosystems, essential ecological processes and biological diversity of Namibia and utilization of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future”. The Environmental Management Act The Environmental Management Act No 7 of 2007 aims to promote the sustainable management of the No 7 of 2007 environment and the use of natural resources and to provides for a process of assessment and control of activities which may have significant effects on the environment; and to provide for incidental matters. The acts provide a list of activities that may not be undertake without an environmental clearance certificate. Further, the Act ensures that; (a) Potential threats are considered timeously (b) A comprehensive stakeholder’s consultations is conducted and all Interested and affected parties are given an opportunity to comment on the project (c) Decision are robust by taking into account the above mentioned activities

Legislation Summary Draft Pollution Control and Waste This Bill serves to regulate and prevent the discharge of pollutants to air and water as well as providing Management Bill for general waste management. The Bill will repeal the Atmospheric Pollution Prevention Ordinance (11 of 1976) when it comes into force. The Bill also provides for noise, dust or odor control that may be considered a nuisance. Further, the Bill advocates for duty of care with respect to waste management affecting humans and the environment and calls for a waste management licence for any activity relating to waste or hazardous waste management. Marine Resource Act (Act No. 27 of Provide for the conservation of the marine ecosystem and the responsible utilization, conservation, 2000) protection and promotion of marine resources on a sustainable basis; for that purpose to provide for the exercise of control over marine resources; and to provide for matters connected therewith. Namibian Ports Authority Act 2 of To provide for the establishment of the Namibian Ports Authority to undertake the management and 1994 control of ports and lighthouses in Namibia and the provision of facilities and services related thereto; and to provide for matters incidental thereto. Marine Traffic Act, No. 2 of 1981 as To amend the Marine Traffic Act, 1981, in order to adjust its provisions in view of the independence of amended by the Marine Traffic Namibia; and to provide for incidental matters. Amendment Act 15 of 1991. Prevention and Combating of To provide for the prevention and combating of pollution of the sea by oil; to determine liability in certain Pollution of the Sea by Oil Act No 6 respects for loss or damage caused by the discharge of oil from ships, tankers or offshore installations; of 1981 (as amended by Act 24 of 1991). and to provide for matters connected therewith. Dumping at Sea Control Act 73 of To control the dumping of substance in the sea 1980. Environmental Policy framework This policy subjects all developments and project to environmental assessment and provides guideline for (1995) the Environmental Assessment. Its provision mandate that Environmental Assessment take due consideration of all possible impacts and incorporate them in the development or planning stages.

Legislation Summary Regulations Relating to the Health and sets out the duties of the employer, welfare and facilities at the workplace, safety of machinery, hazardous Safety of Employees at Work. Reg substances, physical hazards, medical provisions, construction safety and electrical safety. No. 156 Labour Act No. 11 of 2007 This Act outlines the labour laws which encompass protection and safety of employees at work.

Public Health Environmental Act No. To promote public health and wellbeing as well as prevent diseases, injures and disabilities. Protect 1 of 2015 individuals and communities from public health risks. Water Resources Management Act This Act provides a framework for managing water resources based on the principles of integrated water (2013) resources management. It provides for the management, development, protection, conservation, and use of water resources. Furthermore, any watercourse on/or in close proximity to the site and associated ecosystems should be protected in alignment with the listed principles. Water Act No, 54 of 1956 This act states that, all water resources belongs to the State. It prevents pollution and promotes the

sustainable utilization of the resource. To protect this resources, this act requires that permits are obtained when activities involve the following; (a) Discharge of contaminated into water sources such as pipe, sewer, canal, sea outfall and (b) Disposal of water in a manner that may cause detrimental impact on the water resources Petroleum Product and Energy Act This Act provides a framework for handling and distribution of petroleum products which may include No, 13 of 1990 purchase, sale, supply, acquisition, possession, disposal, storage or transportation thereof.

Labour Act No. 6 of 1992 This Act aims to regulate labour in general and includes the protection of the health, safety and welfare

of employees.

Legislation Summary Regional Council Act, 1992 (Act No. The Regional Councils Act legislates the establishment of Regional Councils that are responsible for the 22 of 1992) planning and coordination of regional policies and development. The main objective of this Act is to

initiate, supervise, manage and evaluate development at regional level. National Heritage Act 27 of 2004 To provide for the protection and conservation of places and objects of heritage significance and the registration of such places and objects; to establish a National Heritage Council; to establish a National Heritage Register; and to provide for incidental matters Nature Conservation Ordinance 14 of To consolidate and amend the laws relating to the conservation of nature; the establishment of game parks 1975 and nature reserves; the control of problem animals; and to provide for matters incidental thereto.

Atmospheric Pollution Prevention To provide for the prevention of the pollution of the atmosphere, and for matters incidental thereto Ordinance 11 of 1976 Hazardous Substances Ordinance 14 To provide for the control of substances which may cause injury or ill-health to or death of human beings of 1974; by reason of their toxic, corrosive, irritant, strongly sensitizing or flammable nature or the generation of pressure thereby in certain circumstances Marine Traffic Act 2 of 1981 (as To regulate marine traffic in Namibia and to provide for matters connected therewith. amended by the Marine Traffic Amendment Act 15 of 1991); Territorial Sea and Exclusive To determine and define the territorial sea, internal waters, contiguous zone, exclusive economic zone and Economic Zone of Namibia Act 3 of continental shelf of Namibia; and to provide for matters incidental thereto 1990; Wreck and Salvage Act 4 of 2004 To provide for the salvage of ships, aircraft and life and the protection of the marine environment; to provide for the amendment or repeal of certain provisions of the Merchant Shipping Act, 1951; and to provide for matters connected therewith.

Legislation Summary INTERNATIONAL CONVENTION AND TREATIES The International Convention for the Provide for the protection of submarine cable by establishing that the breaking or injury of a submarine Protection of Submarine Cables cable, done willfully or through culpable negligence, and resulting in the total or partial interruption or (1884) embarrassment of telegraphic communications, shall be a punishable offence, but the punishment inflicted shall be no bar to a civil action for damages Geneva Convention on the High Seas This convention give provision that the High Seas as being open to all nations; no State may validly (1958) purport to subject any part of them to its sovereignty. Freedom of the High Seas is exercised in accordance with other rules of international law, where coastal and non-coastal States shall have freedom of navigation, fishing, lay submarine cables and pipelines and fly over. United Nations Convention on the Namibian is a signatory to UNCLOS which gives provision to claims rights within a 12 nautical mile Law of the Sea (UNCLOS) (1982) territorial water and a 200 nautical mile Exclusive Economic Zone (EEZ). Under this, Namibia is entitled

to lay submarine cables and pipelines on her continental shelf. Namibia reserves the rights to establish conditions for cables or pipelines entering its territory or territorial sea, or its jurisdiction over cables and pipelines constructed or used in connection with the exploration of its continental shelf or exploitation of its resources or the operations of artificial islands, installations and structures under its jurisdiction. However, when laying submarine cables or pipelines, States shall have due regard to cables or pipelines already in position. In particular, possibilities of repairing existing cables or pipelines shall not be prejudiced International Convention for the The is the main international convention covering prevention of pollution of the marine environment Prevention of Pollution from Ships by ships from operational or accidental causes. (MARPOL) London, 1973

Other international treaties and conventions that could potentially be applicable to the Project are presented below:

Convention on Biological Diversity, 1996 International Convention on the Control of Harmful Anti-fouling Systems on Ships, October 2001 The International convention for the control and management of ships’ ballast water and sediments, 2004 Convention on the International Regulations for Preventing Collisions at Sea, (COLREGs)1972 Convention on the Prevention of Marine Pollution by Dumping of Wastes and other Matter, 1972

6. Public Consultation

Public consultation is a requirement by law (EMA No 7 of 2007) to be incorporated into an EIA process, hence it is a fundamental part of the EIA. Public consultation ensures robust decision making by involving Interested and Affected Parties (I&APs). The PPP has therefore been structured to provide I&APs an opportunity to gain more information on the proposed project and for them to provide inputs through the review of documents/reports, and to flag any issue of concern during the PPP process.

6.1. Newspaper Adverts

Newspaper advertisement were place into two local newspapers The Namibian and the Namib times (Appendix) as required by the EMA. A coastal town newspaper was deliberately chosen because the project is located at the coast in order to ensure good coverage of the coastal community. The adverts were place as follows;

• The Namibian 17th $ 22nd July 2019

• The Namib Times 12th & 19th July 2019

6.2. Local Authority Consultation

The Swakopmund Municipality was consulted during proposed location of the Beach Man Hole. The Municipality shall further be consulted during the construction of the landing station for purposes of approving building plans, and trenching.

6.3. Public Meeting

A public meeting was held at Swakopmund Platza Hotel on 19th 2019. A presentation for project description was given. In attendance, was representative from Telecom Namibia, Swakopmund

Municipality, Project Proponent and Interested parties who all welcomed the project. The comment and response for the meeting is presented in table below.

Name Institution Comment / Concern Response Mr. Laban Hiwilepo Telecom Telecom welcomes the second submarine The comment is well noted Namibia cable and advices proponents of ACE cable to consult with the Swakopmund Municipality on issues that were raised to avoid unnecessary project delays. These issues include, trenching and construction of the beach man hole. Kluivert Municipality of The landing site is at the side of the TEC: Alternatives are considered to Mwanangombe Swakopmund residential area, has there been other site reduce the potential effect on the but attending in alternative considered? environment. There were no raised flags his private for the chosen site, and advantageous, it capacity is less than a kilometer from the landing station. If red flags were raised, an alternative site would have been considered.

Kluivert Municipality of The proposed are is already serviced with Telecom Namibia: The existing WACS Mwanangombe Swakopmund provision of Municipal bulk services, why cable for telecom was also installed in but attending in can it not be moved to a place where there town with the provision of Municipal

Name Institution Comment / Concern Response his private are not municipal services? Can the cable bulk services. What needs to happen is capacity exist with future services or maintenance of that, the trenches shall be deep enough to services? Will the maintenance of bulk be below the bulk municipal service. service, such as fixing broken pipes damage Hence the cable can co-exist with other the cable? infrastructures. Mike Spencer Manica Group What is your estimated time to implement Ebenos Technology: The funds are the project available; we shall only wait for the project approval in terms of environmental clearance then the project shall be implemented. We anticipate construction to start in the first quarter of 2020. Mike Spencer Manica Group Thank you for the good, informative and TEC: We appreciate that comprehensive presentation.

7. Impact Identification and Risk Assessment

Under this section, environment and social impacts relating to the project were identified, evaluated and practical mitigation measures proposed. The Department of Environmental Affairs (DEA) had set out criteria for impact assessment as indicated in Table 5.

Table 5. The impacts assessment criteria

Risk Event Rating Description Impact type 0 No Impact +VE Positive -VE Negative Probability The likelihood that an impact may occur under the following analysis 1 Improbable (Low likelihood) 2 Low probability 3 Probable (Likely to occur) 4 Highly Probable (Most likely)

5 Definite (Impact will occur regardless of the applied mitigation measure) Confidence The confidence level of occurrence, based on available knowledge level L Low M Medium H High Significance 0 None (Based on the available information, the potential impact (Without is found to not have a significant impact) Mitigation) L Low (The presence of the impact’s magnitude is expected to be temporal or localized, that may not require alteration to the operation of the project M Medium (The impact is expected to be of short term moderate and normally regionally. Often, such impacts require alteration to the or alternative method of mitigation is implemented

H High (The impact is definite, can be regional or national and in long term. The impact could have a no go implication unless the project is re-designed or proper mitigation can practically be applied Mitigation The applied measure / alternative to reduce / avoid an impact

Significance 0 None (Based on the available information, the potential impact (With is found to not have a significant impact) Mitigation) L Low (The impact’s magnitude is expected to be temporal or localized, that may not require alteration to the operation of the project M Medium (The impact is expected to be of short term moderate and normally regionally. Often, such impacts require that the projects be altered to mitigate the impact or alternative method of mitigation is implemented H High (The impact is definite, can be, local, regional or national and in long term. The impact could have a NO go implication unless the project is re-designed or proper mitigation can practically be applied Duration Time duration of the impacts 1 Immediate 2 Short-term (0-5 years) 3 Medium-term (5-15 years) 4 Long-term (more than 15 years 5 Permanent Scale The geographical scale of the impact 1 Site specific 2 Local 3 Regional 4 National 5 International

During scoping, literature review was used to determine the study plan and needs of specialist studies. The scoping study revealed rich secondary data information is available on fishing activities and sea bed characteristic which adequately describe the area and activities presents. The installation of the cable on the sea bed with a specialized sea plough is not expected to cause disturbance to the seabed, such as creating plumes. Contrariwise, the area shall become an indirect biodiversity conservation area after the creation of the buffer zone for cable protection. In accordance to the identified impact, no specialist study that required primary data was recommended.

The marine fauna of Namibian is extensively studied and excellent literature are available that shows their distribution and identification as well as their conservation status (Bianchi et al 1999). Spatial catch statistics are available from the various survey reports from Ministry of Fisheries and Marine Resources. A route determining survey is not treated as a specialist study because it is a standard requirement for cable laying aimed to minimize potential impact, especially in mapping sensitive areas. Overall, no primary data was collected for purposes of impact analysis. On land, the only impacts would be trenching, however the landing station is located at the serviced municipal land, hence these shall be no impact on terrestrial flora and fauna.

7.1. Pre-Construction Phase

PRE-CONSTRUCTION PHASE Potential Environmental / Social Impact Mitigation Measures Significance of the Impact Human Safety 1. The vessels must pass all safety Type -Ve requirement after inspection by the Safety at sea is number one priority. There is risk of Department of Maritime Affairs, Severity High falling in water, tripping on board that may result in 2. Ensure that, firefighting equipment are severe injury, risk of fire, vessel collision, grounding functional and inspected before sailing, Scale / Extend On board etc. The provision of maritime safety is regulated 3. Ensure adequate life boats and other safety the vessel under the Marine and Maritime Act. measures are on board, Probability Probable 4. All employees onboard the vessel must Confidence High possess a health certificate level 5. All employees must have safety induction Without High certificate (In Namibia to be obtained from Mitigation Namibia Fishing Institute (NAMFI). With Medium Mitigation

PRE-CONSTRUCTION PHASE Potential Environmental / Social Impact Mitigation Measures Significance of the Impact 6. All employees must be provided with adequate Personal Protective Equipment (PPE) 7. All employees must go through a health and safety induction before sailing, 8. A compulsory drill must be undertaken few hours after sailing 9. No employee must be allowed to be at work station without adequate PPE 10. There must be a first aid kid with adequate medicine

Human Health 1. The vessels must have first aid kid with Type -Ve relevant medicine to stabilize sickness Severity High The working environmental is an isolated 2. The sleeping environmental must be Scale / Extend On board environment that need to cater for all health conducive the vessel emergencies for the employees. Employees may get 3. Ablution facilities must conducive and Probability Probable serious injured during operation all fall imminently ill clean all the time while kilometer away offshore Confidence High level

PRE-CONSTRUCTION PHASE Potential Environmental / Social Impact Mitigation Measures Significance of the Impact 4. There must be a balanced diet with Without High adequate provision of bottled water Mitigation 5. Work shift must adhere to the labour act With Low Mitigation

Marine Traffic 1. The Captain and all officer for the vessel Type -Ve must be certified to operate in the Namibian Severity Low Marine traffic includes fishing, mineral exploration, waters Scale / Extend Offshore tourist and cargo vessels. There is risk of collision. 2. The vessels must be equipped with all Probability Probable necessary radio communication tools, radar Confidence High etc. level 3. Warm nearby vessel about ongoing Without High activities Mitigation 4. Adhere to the Marine Traffic Amendment With Low Act 15 of 1991. Mitigation

Impact on Marine Mammals 1. Keep a watch on the movement of marine Type -Ve mammals around the vessels Severity Low

PRE-CONSTRUCTION PHASE Potential Environmental / Social Impact Mitigation Measures Significance of the Impact There is potential of collision of marine mammals 2. Always give right of way to the marine Scale / Extend Along the with the vessels There is limited understanding of the mammals cable Noise and vibration impacts to the marine fauna. The route operation is not similar to the seismic surveys for Probability Probably hydrocarbons which are known to have significant Confidence High impacts on the vocalizations of marine mammals. level Hence noise emission related to submarine cable Without Low installation is not regarded as serious problem. Mitigation With Low Mitigation

Waste Generation 1. Waste must be segregated on board the In terms of waste generation, the vessels can be seen vessels and stored properly as an island. All types of waste is generated on 2. Wasted dumping at sea is strictly onboard the vessels, from general household waste, prohibited and illegal lubricants etc. 3. Waste can only be disposed of at appropriate and approved site on land Pre-lay grapnel run 1. Ensure that the grapnel run follows a pre- Type -Ve determined survey route, Severity Low

PRE-CONSTRUCTION PHASE Potential Environmental / Social Impact Mitigation Measures Significance of the Impact Before cable lying, a pre-lay grapnel run is 2. Ensure that the area must be cleared of any Scale / Extend Cable undertaken to ensure that the cable route is free of any fishing activities such as long lining, route debris. Minimal disturbances for benthic organisms is trawling and purse seining, Probability Definite expected such as turbidity, but in a short term and 3. All recovered debris must not be discarded Confidence High even lower than that of bottom trawling. Other overboard, but onshore to appropriate and level impacts may arise in the form of injury or mortality approved sites Without Low to slow moving or non-mobile organisms such as 4. To reduce turbidity, minimised the duration Mitigation bivalves. The grapnel is not expected to make a of physical disturbance of the seabed. With Low permanent footprint on seabed due to expected rapid Mitigation natural reinstatement of the seabed and consequently recolonization hence, no permanent impacts are anticipated. Bottom fish such as Monk that buries themselves in the mud are not expected to be disturbed because the can easily move away from the grapnel.

7.2. Construction Phase

CONSTRUCTION PHASE Potential Environmental /Social Impact Mitigation Measures Significance of impact Cable laying / burial 1. Cable laying must follow the survey Type -Ve route Severity Low The submarine cable shall follow a pre-determined cable 2. On shore, trenching must first be route. It shall be towed behind the cable laying vessel approved by Swakopmund Scale / Extend Offshore and and buried in the seabed by the sea plough 1-1.5 m deep. Municipality Onshore The cable plough covers an area of 0.75 m wide and 3. All trenches must be well rehabilitated project sit buries the cable at very slow speed. This is expected to to place’s original state Probability Definite disturb bottom and benthic organisms in short period 4. To reduce turbidity, minimised the through increase turbidity which is lees in comparison duration of physical disturbance of the Confidence High to bottom trawling. The change in sedimentation is seabed. level expected to be short term. The long term impacts of the Without Medium marine telecommunications cable on the benthic Mitigation environment (both fauna and flora) is expected to be With Low positive because the buffer zone would provide some Mitigation protection from bottom trawling activities, mineral

CONSTRUCTION PHASE Potential Environmental /Social Impact Mitigation Measures Significance of impact exploration and the anchoring of vessels in a radius of 500m on both side of the cable. Hence, the long term direct benefits to the marine environment is expected to outweigh the short term negative impacts associated with the laying and burial of the marine cable. At rocky are areas where cable laying is not possible, standard practices of cable lying shall be followed such as rock or split pipes. Traffic, Health and Safety The mitigation measure are same as Same as during Pre-Construction during the Pre-Construction Near shore cable laying 1. The captain of the vessels must Type -Ve maintain safe navigation depths Severity Low At shallow depths, the vessels are at risk of grounding. 2. Only use qualified and licensed diver Scale / Extend Near shore Divers shall be used to place the cable in position, hence to lay the cable near shore Probability Possibly there is risk associated with diving. 3. Divers must have all necessary gears Confidence High level Without Medium Mitigation With Low Mitigation

CONSTRUCTION PHASE Potential Environmental /Social Impact Mitigation Measures Significance of impact Construction of Beach Man Hole 1. All building structure including the Type -Ve BMH must be approved by the Severity Low The construction of the BMH shall take place on land, Municipality Scale / Extend Site Specific its design is subject to approval by the Swakopmund 2. Building rubbles must be taken to the Probability Definite municipality. During construction, including trenching municipal waste disposal site Confidence High for the cable to the landing station, access to the BMH 3. Fence of the site with a red tape and level shall be restricted, which may impact on beach goer. The put up appropriate signs Without Medium area is not a public recreational area hence the Mitigation disturbance is expected to be minimal. With Low The is safety risk with operation of winches and Mitigation trenching equipment.

Aesthetics 1. Ensure good house keeping Type -Ve Onshore, the digging and trenching may create an eye 2. Piles of excavated sand must be well Severity Low shore to beach goers, but this is expected to be stored Scale / Extend Site Specific temporally. 3. Rehabilitate the excavated area back Probability Definite to its natural state Confidence High 4. Do not burry waste on site level Without Medium Mitigation

CONSTRUCTION PHASE Potential Environmental /Social Impact Mitigation Measures Significance of impact With Low Mitigation

Air Quality 1. The vessel must be well service and Type -Ve functional to prevent gaseous Severity Low Sea freight accounts for 90% of the world merchants. emissions. Scale / Extend Site Specific The vessels are believed to contribute to Carbon Dioxide Probability Definite and other noxious gases. Confidence High level Without Low Mitigation With Low Mitigation

Dust 1. Avoid digging during heavy winds Type -Ve 2. Apply dust suppression measures Severity Low During digging and excavating, there is potential for such as water sprays Scale / Extend Site Specific generation of some fugitive dust. This is expected to be 3. Provide employees with adequate Probability Definite short term. Personal Protective Equipment Confidence High level

CONSTRUCTION PHASE Potential Environmental /Social Impact Mitigation Measures Significance of impact Without Medium Mitigation With Low Mitigation

Noise and Vibration 1. Don’t hooter unnecessarily Type -Ve 2. Maintain low speed Severity Low The local resident may be impacted the noise of heavy 3. Vehicle and machinery must be well Scale / Extend Site Specific vehicles during digging and excavating, but the serviced Probability Definite movement of such vehicle and machine is temporally in 4. Work must only start at 7:00am – Confidence High the area. 5:00pm, do not work in evening level 5. Provide PPE such as ear muffs to the Without Medium employees Mitigation 6. Stationary vehicles and machines With Low must be switched off at time Mitigation

Ballast water management 1. Adhere to the International Type -Ve The ship carried ballast water in their ballast tanks to Convention for the Control and Severity Low improve stability, balance and trim. This waste is taken Management of Ships' Ballast Water Scale / Extend Offshore and from where the vessels is departing or anywhere at sea, and Sediments. ports

CONSTRUCTION PHASE Potential Environmental /Social Impact Mitigation Measures Significance of impact when a ship needs extra stability in poor weather and can Probability Definite be discharged anywhere. This waster has the potential to Confidence High introduce invasive alien species that has the potential to level wipe out local population or change the ecological Without High setting. Mitigation With Low Mitigation

Fishing 1. The disturbance to fisheries shall be Type -Ve temporally and negligible Severity Low

The installation of cable has the potential to disturb 2. Watch out for deployed longline Scale / Extend Cable site fishing. The cable protection zone, which is a 500m on fishing both side of the cable shall be a no go area for fishing, Probability Definite which in return shall become some sort of conservation Confidence High area. This area not significant, compared to the remain level entire EZZ. Additionally, during laying of cable, the Without Medium vessel must watch out for deployed longlining to avoid Mitigation destruction With Low Mitigation

CONSTRUCTION PHASE Potential Environmental /Social Impact Mitigation Measures Significance of impact Socio-Economics Type +VE Severity Low With high rates of poverty and unemployment, every job 1. Unskilled labour must all be Scale / Extend Local opportunity created in Namibia is significant. The reserved for local Probability Definite project is expected to create temporally jobs for the 2. Only employ foreigners where Confidence High locals during the construction of the BMH, trenching skills and expertise in not in level and the construction of the landing site. Most of the Namibia Without Medium skilled workers will be imported to undertake the 3. Abide by the labour act Mitigation installation of the telecommunications cable, it is 4. Provide contract to employees With Low encouraged that under studies are employed to ensure Mitigation skill transfer.

7.3. Operational Phase

OPERATIONAL PHASE Potential Environmental / Social Impact Mitigation Measures Significance of Impact Electromagnetic Fields The Impact is The Impact is considered considered low and low and negligible. Electromagnetic fields are generated by operational transmission cables due negligible. to voltage passing through it. Some fish, marine turtles and marine mammals are known to possess a natural sensitivity to electromagnetic fields (EMFs) which may disturb their ability to sense prey. Because Terrestrial organisms are exposed to the geomagnetic field, so as marine animals are also exposed to natural electric fields caused by sea currents moving through the geomagnetic field. Hence this impact is considered low.

7.4. Decommissioning Phase

DECOMMISSIONING PHASE Potential Environmental / Social Impact Mitigation Measures Significance of Impact Decommissioning 1. Inform the authority about the The impact is expected to be negligible decommissioning plan Submarine Cables are made to have a life-span of 2. All affected parties, internet users 25 years. Decommissioning of the ACE Cable must be informed well in advance to System in the near future is unlikely. At time of make appropriated alternatives decommissioning, all activities must follow all 3. A decommissioning plan must be relevant procedures. It is unlikely that the project developed for approval by the shall be decommissioned due to increase in demand competed authority. of telecommunications. The industry practice shall be to leave the cable in its place, since by then it became part of the ecosystem. Hence no impact is expected.

7.5. Cumulative Impacts

Cumulative Impact are possible environmental and social impacts on the receptor caused by the combination effects of more than one project/development. Cumulative impact assessment aims to identify the environmental threats of the proposed project in combination with the existing similar project in the area.

The submarine marine cable a protected with a 500m buffer zone on each site. A total amount of 1km2 of area surrounding the cable shall not be used for deep sea trawling or anchoring of long lines. Having the WACS cable already installed, the cumulative impact shall be minimal loss of fishing ground. Analysis of the fishing activities showed that, deep sea fishing, which is mainly for hake occurs in South at areas surrounding Lüderitz. Hence the creation of the buffer zone in this proposed area shall not cause significant impact to fishing. Continuous monitoring of the catch correlation and start of operation for the ACE cable is recommended for environmental audit as fishing companies are allocated a fishing quota. The continued fulfillment of the fishing quota would mean that, the fishing operation is not impacted by the installation of the ACE cable. Additionally, band width and data connectivity is essential for economic growth and is not known to harm the marine environmental. The coexistence of these economic benefits means that, more economic growth shall be realized.

8. Conclusions and Recommendations

8.1. Conclusion

The study concluded that, the potential impact of the project is limited to the pre-installation and installation of the cable. The impact from operational and decommissioning phase is expected to be negligible. All impacts were found to be low, short term, site specific while some are negligible. Although a desktop study was done to assess the area, a pre-survey route must be undertaken to determine the survey route. Various literature has confirmed that the project activities are not expected to have adverse impacts on the environment especially offshore. Further, with the implementation of the environmental management plan and adherence to the national and international legal framework, all potential impact shall be reduced to insignificant levels.

8.2. Recommendations

It is recommended to the approving authority that; this project is approved but subjected to following conditions;

• A route determining survey must be undertaken before pre-construction and construction of the submarine cable • A route determining survey report must be submitted to the competent authority for approval and subsequent amendment to the EMP must be made. • Strict implementation of the Environmental Management Plan and adherence to the legal framework pertaining the project is highly recommended.

9. References

1. ACER (Africa) Environmental Consultants 2017: Environmental impact assessment report for marine telecommunications system (ace cable system) to be landed at Van Riebeeckstrand on the West Coast of South Africa, EIA reference no. 14/12/16/3/3/2/988 2. ACER (Africa) Environmental Consultants., (2017) Proposed Marine Telecommunications System (Ace Cable System) To Be Landed At Van Riebeeckstrand On The West Coast Of South Africa. EIA Reference 14/12/16/3/3/2/988 3. Africa Development Bank 2010: Multinational Seychelles submarine cable project environmental and social impact assessment - Project reference no: P-SC-GB0-002 4. Alcatel – Lucent 2010: Submarine terminal stations design & building guidelines 5. Alcatel – Lucent 2015; Ace Segment 4 system description 6. Alcatel – Lucent; Land conduit route - civil work recommendation from station to BMH for Submarine Cable System 7. BCLME State of the Marine Environment Report., (2014-18) 8. Bianchi G et al., (1999), Field Guide To The Living Marine Resources Of Namibia 9. Heidi Currie et al., (2003), Namibian Islands’ Marine Protected Area. WWF South Africa Report Series – 2008/Marine/003

10. IXSURVEY, 2010: Environment and Social Impact Assessment Study Report, Tanzania, Project ref no: BIO/T1831_0.1_ESIAS 11. IXSURVEY, 2010: Environment and Social Impact Assessment Study Report, Seychelles, Project ref no: BIO/T1831_0.1_ESIAS 12. Karim M et al 2006., Impacts of submarine cables on the marine environment, A literature review 13. Lynne J. Shannon et al., (2004), Simulating anchovy–sardine regime shifts in the southern Benguela ecosystem; Ecological Modelling 172 pp 269–281 14. Namibian Statically Agency., (2011) Namibia Population and Housing Census Main Report. 15. OSPAR, 2009: Assessment of the environmental impacts of cables. – Publication Number: 437/2009, 19 p. 16. OSPAR, 2009: Guidelines on Best Environmental Practice (BEP) in Cable Laying and Operation

17. Reinett Mogotshi et al 2019., Environmental Impact Assessment process for the Installation and Operation of the METISS Subsea Cable System to be Landed in Amanzimtoti, South Africa 18. The David Ross Group Inc., (2008), Undersea Cable System: Technical Overview & Cost Considerations 19. The ecosystem approach to fisheries., (2003), FAO Technical Guidelines for Responsible Fisheries. No. 4, Suppl. 2. Rome, FAO. 112 p. 20. Wolfgang Fennel 1999 Theory of the Benguela Upwelling System Journal of physical oceanography Vol. 29

10. Appendixes

Appendix 1. Beach Man Hole Technical Description

Appendix 2. Background Information Document

Appendix 3. Newspaper Adverts

Appendix 4. Proof of Public Meeting

Appendix 5. Environmental Management Plan (EMP)

Appendix 6. CV for Environmental Assessment Practitioner – Author

Appendix 7. CV for Environmental Assessment Practitioner – Reviewer