App No: 00886

APP NO: 00886

ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED EXPLORATION ACTIVITIES ON EXCLUSIVE PROSPECTING LICENCE NUMBER 5232 AT OTAVI AREA, OTJOZONDJUPA REGION

(Photo Credit: Kodo Drilling) 06 January 2020

CONSULTANT: PROPONENT Mr. Ipeinge Mundjulu (BSC, MSc) Huab Energy Red-Dune Consulting CC P O Box 87100 P O Box 27623 Windhoek Eros Cell: +264 81 147 7889 Windhoek

DOCUMENT INFORMATION

DOCUMENT STATUS Final APPLICATION NO: APP 00886 PROJECT TITLE Environmental Impact Assessment For The Proposed Exploration Activities On Exclusive Prospecting Licence Number 5232 CLIENT Huab Energy Pty Ltd PROJECT CONSULTANT Mr. Ipeinge Mundjulu LOCATION Otavi Areas, Otjozondjupa Region

Table of Contents Executive Summary ...... ii 1. Introduction ...... 1 1.1. Regulatory Requirements ...... 1 1.2. The Need and Desirability of the Project ...... 2 1.3. Terms of Reference ...... 2 1.4. Scope of the EIA ...... 3 2. Project Description...... 4 2.1. Location ...... 4 2.2. Project Activities ...... 6 2.2.1. Phase 1. Non-Invasive Exploration...... 7 2.2.2. Phase 2. Evasive Exploration ...... 8 2.3. Equipment ...... 9 2.3.1. Vehicles...... 9 2.3.2. Drilling ...... 10 2.3.3. Airborne Geophysical survey ...... 11 3. Description of the Affected Environment ...... 11 3.1. Environmental Parameters ...... 11 3.1.1. Climate ...... 11 3.1.2. Geomorphology ...... 12 3.1.3. Ecology ...... 13 3.1.4. Ecological Impact Assessment ...... 16 3.1.5. Socio-Economic Environment ...... 17 3.1.6. Land Use ...... 17 3.1.7. Archaeology ...... 17 3.1.8. Population Demography ...... 17 4. Project Alternatives ...... 19 5. Policy and Legal Framework ...... 21 6. Public Consultation ...... 24 6.1. Newspaper Adverts ...... 24 6.2. Public Meeting ...... 24 6.2.1. Introduction ...... 24

6.2.2. Environmental Impact Assessment (EIA) process ...... 26 6.2.3. Commencement of the Exploration Activities ...... 27 6.2.4. Huab Energy (Pty) Ltd ...... 27 6.2.5. Comment / Question and Response ...... 28 7. Impact Identification and Risk Assessment ...... 29 7.1. Impact Identification ...... 29 7.2. Impact Risk Assessment Procedure ...... 31 7.3. Identified Impacts ...... 31 7.3.1. Potential Negative Impacts ...... 31 7.3.2. Potential Positive Impact of the project ...... 32 8. Risks Assessment ...... 32 8.1. Planning Phase ...... 32 8.2. Operational Phase ...... 33 8.2.1. Socio-Economic Impacts ...... 33 8.2.2. Bio-Physical Impacts ...... 38 9. Decommissioning and Rehabilitation ...... 41 10. Conclusions and Recommendations ...... 41 10.1. Conclusions ...... 41 10.2. Recommendations ...... 41 11. Reference ...... 42

List of Figures

Figure 1 The EIA Process in Namibia ...... 3 Figure 2. EPL 5232 Location ...... 5 Figure 3. Exploration vehicles ...... 9 Figure 4. An illustration of a hand dug trench ...... 10 Figure 5. A truck mounted RC drill rig and a skid mounted drill rig ...... 10 Figure 6. An illustration of a fixed wing Cessna ...... 11 Figure 7. Locality map showing the Otavi Mountain Land (J.E. Misiewicz 1988)...... 13 Figure 8. Dominant species that were observed during site assessment ...... 16 Figure 9. Public meeting at Otavi Farmers association hall ...... 25 Figure 10. Matrix used for the impact assessment ...... 31

List of Tables

Table 1. Identified listed activities concerning the proposed project...... 1 Table 2. GPS Coordinates for EPL 5232 ...... 6 Table 3. Population Demography of Otjozondjupa Region (Namibia Population and Census Report of 2011)...... 18 Table 4. Project alternatives ...... 19 Table 5. Newspaper Adverts ...... 24 Table 6. Criteria for impact assessment ...... 29

ACRONYMS

DEA Department of Environmental Affairs EA Environmental Assessment EAP Environmental Assessment Practitioner EC Environmental Commissioner ECC Environmental Clearance Certificate ECO Environmental Compliance Officer EIA Environmental Impact Assessment EMA Environmental Management Act (No. 7 of 2007) EMP Environmental Management Plan EPL Exclusive Prospecting License I&APs Interested and Affected Parties MET Ministry of Environment and Tourism OML Otavi Mountain Range PPE Personal Protective Equipment RC Reverse Circulation RD Red-Dune Consulting CC TORs Terms of Reference

Executive Summary

Mineral exploration existed for many centuries. With improving technology, mineral exploration has become environmental friendly, in a way that it more non-evasive, with negligible impact on the bio-physical environment. The proponent, Huab Energy (Pty) Ltd intent to carry out exploration activities of Base, Rare, Precious Metals and Dimension stone and Non-nuclear fuels on the Exclusive Prospecting Licence (EPL) 5232. The EPL is located at Otavi area toward the eastern direction. It measures 29 301.47 hectares (ha) and cover various commercial farms.

The proposed exploration activities shall comprise of non-invasive methods such as geological field mapping and geophysical ground mapping to generate target point where geochemical soil sampling would take place. Generated targets shall be sampled using traditional methods of shallow pitting and trenching, while deeper targets would be sampled through Reverse Circulation drilling. All drilled holes shall be covered completely after sampling, unless otherwise the farm owners indicate interest in the drilled hole (i.e water borehole), a casing shall be left.

In conclusion, exploration activities are not known to cause harm to the environment. In Namibia, farms are heavily encroached with think bushes, hence access roads to generated targets are in a way advantageous to the farmers as long as the line cutting avoids mature and protected trees. Should this exploration yield into the potential of establishing a mine, a comprehensive EIA must be undertaken which shall include all necessary specialist studies. Thus it is recommended to the approving authority that this project is approved and be issued with an Environmental Clearance Certificate.

1. Introduction

The proponent, Huab Energy (Pty) Ltd, owns the Exclusive Prospecting License (EPL) Number 5232, as per the Mineral Act 1992 (Appendix 1). The company intends to undertake exploration activities for, Base, Rare metals & Precious metal on the EPL. The exploration activities shall include, Reconnaissance field mapping, Geochemical soil sampling, Geophysical ground surveys (magnetics, electromagnetics, gravity) for target generation and Pitting and Trenching as well as Reverse Circulation Drilling (RC) for geochemical sampling.

1.1. Regulatory Requirements

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” Section 27 (2) of EMA and the annexure of Environmental Impact Assessment regulation has listed activities that may not be under taken without an Environmental Clearance Certificate (ECC) (Table 1).

Table 1. Identified listed activities concerning the proposed project.

Activity Applicability 3.1 The construction of facilities for any process or The projects shall include the activities which requires a license, right or other form of prospecting of Mineral authorization, and the renewal of a license, right or other form of authorization, in terms of the Minerals (Prospecting and Mining Act), 1992. 3.2 Other forms of mining or extraction of any natural Mining activities shall involve, resources whether regulated by law or not. drilling and digging to extract natural resource. 3.3 Resource extraction, manipulation, conservation and The project shall extract resource related activities. sample for manipulations / analysis.

1.2. The Need and Desirability of the Project

Developing countries, especially Africans states economies largely depends on mineral extraction industries. The extraction of these resources are mostly exploited by wealthy multinational companies. These extraction industries are important in contributing to countries’ economies and provide much needed employment. Mining processes are preceded by exploration activities, which aims to map the mineralization of the minerals in order to establish a mining area. The discovery of economical deposit from exploration activities yield into mining activities which is the main driver for the Namibia Economy. Hence this project is important to the socio-economic needs of the country.

1.3. Terms of Reference

The Terms of Reference (TORs) for this Environmental Impact Assessment (EIA) is in accordance with the Environmental Management Act 2007 and its Regulation Section 9 (a-b). It considers other relevant local, national and international laws. These guidelines are aimed to focus on issues of greater environmental concerns and to develop mitigation measures for effective environmental management. Eventually, this EIA is aimed at obtaining the Environmental Clearance Certificate for the project and to ensure environmental sustainability. 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

1.4. Scope of the EIA

The scope of this project is guided by the Environmental Regulations 2012, which follows the process as shown in figure 1. The scope aims at identifying possible impacts, assessing the impact and formulate the optimum, practical mitigation measure to minimize the impacts.

Red-Dune (RD) believes that the developed Environmental Management Plan (EMP) provided practical mitigation measure which shall ensure environmental sustainability. Further, RD believes that, the information provided is adequate and sufficient to enable the Environmental Commissioner (EC) to make an informed decision and issue the Environmental Clearance Certificate for the project.

APPOINTMENT OF THE ENVIRONMENTAL PRACTITIONER BY THE PROPONENT

Public Participation PHASE 1. Scoping

Newspaper Advert Determine the Scope of the EIA Site Notices Background Information Document PHASE 2. Environmental and Social Assessment Public Feedback Analyse Impacts Determine mitigation measures (Conduct Specialist, if necessary) PHASE 3. Submission of EIA to Competent Authority

PHASE 4. Competent Authority makes comment and forward application to MET

Appeal to Minister Project Project Not of Environment and Approved Approved Tourism

Implementation of Project

Figure 1 The EIA Process in Namibia

2. Project Description

2.1. Location

The EPL is located at Otavi area toward eastern direction in Otjozondjupa Region Figure 2 and table 2 shows the EPL coordinates points. It measures 29 301.47 hectares (ha) and covers farms Vindsval 582, Achalm 583, Skoll 552, Ibi Patria 551, Rentes 783, Elephantenberg Wes 792, Elephantenberg 584, Achalm 583, Omagonde 501, Ondjondjo 505, Eisenberg 509, Hohentweil 506, Neuwerk 507.

Figure 2. EPL 5232 Location

Table 2. GPS Coordinates for EPL 5232

2.2. Project Activities

The proposed exploration would adopt various prospecting methods for base rare and precious metals as follows;

 Reconnaissance field mapping  Geochemical soil sampling and target generation  Geophysical ground surveys (magnetics, electromagnetics, gravity)  Diamond/RC Drilling of geophysical target

The above proposed activities would be undertaken in phases as explained below.

2.2.1. Phase 1. Non-Invasive Exploration

The initial phase of mineral prospecting and exploration involves non-invasive work. These activities do not cause physical damage to the environment. These activities include geological studies and field mapping where analysis of historical data, geological maps and their interpretations take place. Analysis of these data would generate geophysical targets where evasive exploration would take place. The non-invasive exploration activities are explained below;

Geological studies and field mapping, during this stage, various geological data for the area were collected from different sources to analyses and study available information of the area. Information are derived from aerial photo. These geological photos were studied to generate target point where geochemical soil sampling were taken.

Soil surveys Soil survey was the process used to classify soil types and other soil properties in target area which is used for geo-encoding. The collection of information of the substrata, by air or ground, through sensors such as radar, magnetic and electromagnetic to detect any mineralization in the area. This is a non-evasive process that does not have impact on the environment. Soil sampling traverses to be conducted on foot within the farming areas shall be collected from soil sampling pits, which would be around 30x30x30cm (hand- held shovel width and depth) and are to be backfilled immediately after sampling.

Geophysical surveys, Geophysical ground surveys used various method to gather geological information such as magnetic and electromagnetics. Magnetic surveying measure local magnetic field characteristic of the generated targets from geological mapping. This activity was used to detect minerals that respond to magnetic field. It provided information of a subsurface area without physically opening the ground and is able to detect metal ore in the ground. The activity was done from air and on ground. On ground, a Magnetometer was carried by a person on the surveyed areas to collect samples. While in aerial magnetic data was collected using a helicopter where the Magnetometer is mounted and this was used on difficult terrain and on large terrains. This activity does not pose significant impact to the environment

2.2.2. Phase 2. Evasive Exploration

The second phase of exploration includes sampling for geochemical samples from targets sites. During this phase collection of geochemical samples from hole of less than 1m and drilling shall take place. The target sites maybe un-accessible with existing roads, hence new access road shall be established. Generally, the many farms are heavily encroached by bushes, hence to some extent, the clearing of certain areas may be of good advantage to the farmers. Nonetheless, protected tree species must be protected. The recommendation of the vegetation study carried out for the area must be implemented to ensure sustainable conservation.

Drilling is done at the final stage of exploration to evaluate the prospect of minerals and determine the feasibility of mining. Drill rods are used to collect geological samples from the earth’s subsurface. The drill targets shall be generated from the mapping and sampling programmes. The targets grid patterns shall range from 200X50m grid spacing to grids of 100m by 50m and in some instances on a 50m by 20m grid spacing during detailed sampling. Exploration activities mainly use two types of drilling; Reverse Circulation (RC) and Diamond Core drilling. Reverse circulation gained prominence due to its effectives and conservative when it comes to water use.

Reverse Circulation drilling often referred to as ‘RC’ drilling uses rods (shafts) with inner and outer tubes with drill bit attached to an air-filled interchanging piston known as a hammer. The hammer produces drill cuttings that are returned to the surface inside the rods. RC drill are carried on drill rigs, which are mostly powerful heavy truck. RC drilling is the most preferred method because it is less costly and produces liable materials that are free from contamination. In an arid place like Namibia, RC Drilling would be advantageous because it does not require water for rock drilling unlike Diamond core drilling that requires water for lubrication. Once the proposed exploration has been concluded, the impacted sites will be rehabilitated as provided for by the Environmental Management Plan.

When necessary, a base camp for accommodation shall be set up or use of existing farms houses or camping sites. In an event where a base camp is set up, waste management provisions must be implemented which include; A garbage dump and pit toilet must be established where no hazardous waste shall be dumped in a garbage dump, an impermeable skip container must be on site for collecting hazardous waste. At the end of exploration, toilet pits and garbage dump shall be dump filled before leaving the site. To ensure environmental protection from oil, fuel, and lubricants, servicing of vehicles and equipment must take place at designated area at the camp site.

2.3. Equipment

2.3.1. Vehicles

About four 4x4 pickup trucks shall be used during the exploration (Figure 3). All excavations during trenching and soil sampling programmes shall be done manually (Figure 4). Water shall be supplied by a water trucks. Night driving, reckless driving and speeding are prohibited within the license area. A bulldozer may be used for the access road.

Figure 3. Exploration vehicles

Figure 4. An illustration of a hand dug trench

2.3.2. Drilling

A 4X4, 5-10 Ton Lorries and skid mounted drill rig shall be used to carry the drill on target sites.

Figure 5. A truck mounted RC drill rig and a skid mounted drill rig

2.3.3. Airborne Geophysical survey

Arial photo shall be taken with a fixed wing Cessna plane (Figure 6).

Figure 6. An illustration of a fixed wing Cessna

3. Description of the Affected Environment

3.1. Environmental Parameters

3.1.1. Climate

According to the Atlas of Namibia, Otavi areas is relatively cold during winter with minimum average temperature between 6-8oC and gets very hot during summer with maximum temperature ranging between 32-34oC. The area receives an above average rainfall compared to many places in Namibia with average rainfall of 500-550 mm a year. The rainfall pattern increases toward the eastern party of Kavango and Zambezi region which receives the highest rainfall in the country.

3.1.2. Geomorphology

a. Geology

Otavi area fall under what is called the Otavi Mountain Land (OML). The OML is widely studied due to its mineral rich occurrences. According to literatures, the area is formed up of Dolomites and Limestones which were folded and faulted during the Damara Orogen. The Damara Orogen forms a fold belt which extend across northern Namibia. According to the theory of plate tectonics, “the crust, which represents the uppermost layer of the Earth’s inner structure, consists of thick lithospheric plates “swimming” on the liquid mantle. If two plates - together with the continents riding on them - move away from each other, molten rock from the interior erupts onto the surface, while sediments from the erosion of continents accumulate in the resulting rift; if the movement is reversed, plates collide and the sediments deposited in the rifts or grabens are deformed into mighty mountain ranges under enormous temperatures and pressures. At the same time rocks within the tortured crust are being molten and the resultant liquid magma ascends to be emplaced again at higher levels as granitic intrusions. In this dramatic manner the Damara Orogen originated - a process which from the early rifting stage up to continental collision lasted about 300 million years (~850 to 550 m. y.).” The interaction between sediments, magma and hydrothermal solution yielded in the development of a mineralised zone during the orogenic processes. This mineralization yielded in the deposit of rich base metal of the Otavi Mountain such as Copper, Zinc and Lead (Namibia Geological Survey 1998).

Figure 7. Locality map showing the Otavi Mountain Land (J.E. Misiewicz 1988)

b. Topography and Hydrology

The area of Otavi receives an above average rainfall of 550-550mm compared to most part of the country with the good recharge capability of the subsurface water. The hydrology is characterized by Grootfontein Karst Aquifers (GKA). The GKA comprise of the famous Kombat, Brandwag and the Abenab aquifers. The area is known to have more Ground Water Rivers and aquifers than surface water body. The water table ranges from 60m which is the main source of water supply used for crop irrigation and cattle farming.

3.1.3. Ecology

a. Flora

The general vegetation type of Otavi area could be described as Karstveld which is dominated by Acacia trees and shrub savanna which is characterized by a scattered distribution of tall trees and low shrubs. The EPL, which is the study area is vast and many habitats are expected to occur in the respective landscapes.

The soil is sandy, ranging in color from pale brown and grey with broken calcrete and limestone pieces in it, to fine red sand. The stunt vegetation on hills suggest that the soil is not deep which can be attributed to the presence of calcrete or shale layer that inhibits root establishment.

The EPL spread over a few farms with various farming activities as the land-use. Within the study area, the land-use on the foothills is limited to grazing while the plains are used for mixed use including cultivation of crops.

A site visit was undertaken during November 2019 to establish the vegetation in the study area for this EIA (Figure 8). The area had received some rain and some plants had recovered from the dry season but not yet fruiting. Pictures of the dominant plants are presented in the subsequent table with their conservation status. A relatively low plant diversity is observed in the study perhaps due to heavy bush encroachment on plains and on mountain outcrops vegetation.

Vegetation that is growing along a stream Euclea pseudebenus (Wild ebony) branches hence the thickness and is dominated by with fruits Euclea pseudebenus Protection Status: non-protected

Branches of A. mellifera Acacia mellifera (Black-thorn) Protection Status: non-protected

Peltophorum africanum branches with fruits

Peltophorum africanum (African wattle) Protection Status: Protected in Namibia under the Preservation of trees and forests Ordinance of 1952 Figure 8. Dominant species that were observed during site assessment

b. Fauna

The EPL cover the whole Otavi town and several commercial farms with mixed farming of cattle and crops. During site assessment, Warthog (Phacochoerus africanus), Kudu (Tragelaphus strepsiceros), were observed. However, farms owner confirmed that there several wild animals which includes which includes, Dik-dik (Madoqua damarensis), Cheetah (Acynonyx jubatus), Steenbok (Raphicerus campestris), Gemsbok (Oryx gazelle) and Springbok (Antidorcas marsupialis). Several birds and reptiles also do occur in the study area.

3.1.4. Ecological Impact Assessment

The proposed exploration activities in the study area are not expected to include vegetation removal or habitat destruction. It is however important to put mechanisms in place to ensure that unintentional disturbance is prevented.

Impact on vegetation: The impact on vegetation shall be minimal. However, should the exploration yield feasible data for mining operation, it shall be inevitable for some tree to be affected. A comprehensive vegetation study should be conducted by then.

3.1.5. Socio-Economic Environment

Exploration activities do not involve significant employment. Hence the effect on socio-economic is deemed minimal. However, in cases where significant ore deposit is found that yields to the establishment of a mine, there shall be great benefit to the socio-economic of the surrounding people and towns. The project is not expected to negatively impact the operation of farmers. All operation shall be within the confines of an agreement between Huab Energy Pty and farms

3.1.6. Land Use

Otavi areas is part of the well-known, “Maize Triangle” due to high production of maize in the area. Some farmers practice mixed farming while some farms operate tourism activities such as game drives, bird watching and hunting.

3.1.7. Archaeology

During site assessment, there were no heritage or archaeological sites found, neither known on the EPL. If found, detailed mitigation measures are given in environmental management plan.

3.1.8. Population Demography

Otavi has a population of about 4000 people. It is in Otjozondjupa region with the population of 144 000 people. The unemployed rate in the region is estimated to be at 37% which is relatively low compared to many regions in the country that have over 50%. This could be attributed by the number of mines and high yield farms in the region which create employment opportunities. Some of the biggest mines such B2 Gold mine are found in Otjozondjupa region. This is a clear indication

that, in addition to agriculture, mining is one of major economic activity in the region which will uplift the local economy of both the region and towns.

Table 3. Population Demography of Otjozondjupa Region (Namibia Population and Census Report of 2011).

4. Project Alternatives

The provision of EMA requires an EIA to explore various project alternative which aims to ensure that a chosen project component does not have significant impact to the environment. Project alternative ranges from not implementing the project (No go alternative), when the environmental impacts are severe, or there is high degree of uncertainty. Other alternative considers the project site, technology and equipment to be used. The description of alternative is given in the table 5 below.

Table 4. Project alternatives

Alternative Description Advantages Disadvantage Chosen Option No Project This alternative There would be NO environmental The following benefits would NO would keep a threats such as; be lost if the project does go status qou  Waste Generation with potential ahead. Surface and Ground Water Pollution  Prospective of new mining  Habitat destruction / Land project that culminate into degradation by Construction / loss of income upgrading of access roads  Compromise on  Drilling of holes government development  Social effect on Human Health and goals of manufacturing and Safety Risk industrialization

Alternative Description Advantages Disadvantage Chosen Option  Increase in poverty reduction through loss of employment opportunity Project Site Exploration activity follow mineralization of mineral. Hence there is no specific site. However, activities shall by all mean avoid protected sites. Implement This entails the  Enhance development The natural environment may Yes project implementation  Enhance skill and capacity building be disturbed, but with adequate and operation  Improved technology transfer implementation of the of the project Increase chances of establishing of a Environmental Management new mine Plan, environmental sustainability shall be achieved. Drilling Type: Cost effective  RC drilling: This type of drilling is No significant disadvantage to RC Drilling  RC vs Does not ideal as it does not require water for the environment Diamond require water lubrication and cooling, hence it for lubrication conserve water compared to diamond compared to drilling Diamond drilling

5. Policy and Legal Framework

Legislation Summary Applicability to Assessment

The Namibian The State shall actively promote and maintain the welfare of the Protection of the environment and biodiversity. Constitution people by adopting policies aimed at … The maintenance of Ensures that these principles are enshrined in ecosystems, essential ecological processes and biological the EIA documentation diversity of Namibia and utilization of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future Environmental To promote sustainable management of the environment and the The Act provides a list of activities that may not Management Act No. 7 of use of natural resources and to provides for a process of be undertake without an environmental 2007 assessment and control of activities which may have significant clearance certificate to prevent environmental effects on the environment; and to provide for incidental matters damages. Mineral Resource Act, Prospecting and Mining of Mineral in Namibia and Issuance of Issuance of Mining permits Act 1992. all Permits. Draft Pollution Control This Bill serves to regulate and prevent the discharge of pollutants To protect the Environment from possible and Waste Management to air and water as well as providing for general waste hydrocarbons and oil leaks from the machinery, Bill management. trucks and vehicles. Environmental Policy This policy subjects all developments and project to Consideration of all possible impacts and framework (1995) environmental assessment and provides guideline for the incorporate them in the development stages Environmental Assessment.

Legislation Summary Applicability to Assessment

Regulations Related to Promotes the Safety and Health of employees at the work place To ensure employees health and safety at work the Health and Safety of Employees at Work. Reg No. 156 Public Health Act No. 36 To Protect the public from nuisance and states that no person shall To ensure that the project is not a nuisance to of 1919 cause a nuisance or shall suffer to exist on any land or premises land owners and the public at large owned or occupied by him or of which he is in charge any nuisance or other condition liable to be injurious or dangerous to health. Labour Act No. 11 of This Act outlines the labour laws which encompass protection and Fair labour practises to be observed with regard 2007 safety of employees at work. to this act

Water Act No, 54 of 1956 All water resources belong to the State. It prevents pollution and Prevention of discharging contaminated water promotes the sustainable utilization of the resource at unauthorised places Soil Conservation Act To promotes the conservation and compacting of soil erosion Uncontrolled movement of heavy vehicles and No. 76 of 1969 truck at areas surrounding the site may cause land degradation Water Resource The Act stipulates the prevention of pollution for Surface and Oil spillage coming from machinery requires Management Act No.11 Ground water sources. proper monitoring. of 2011

Legislation Summary Applicability to Assessment

Public Health Act no. 36 The Act gives provision for the protection for the health of all The noise and dust level emanating from the of 1919 people. project could affect the surrounding community and vegetation in the vicinity. National Heritage Act The Act gives provision of the protection and conservation of The chance find of Human Remains due to No.27 of 2004 places and objects with heritage significance. colonial history or crime, Artefacts, and or heritage materials within the EPL

Minerals (Prospecting Section 50 (i) requires “an environmental impact assessment The proposed activity is prospecting for and Mining) Act No 33 of indicating the extent of any pollution of the environment before minerals, hence it requires an EIA to be carried 1992 any prospecting operations or mining operations are being carried out and adhere to the act’s provisions. out and an estimate of any pollution, if any, likely to be caused by such prospecting operations or mining operations”

6. Public Consultation

The provision of the EMA requires an EIA process to follows a robust and comprehensive public consultation. This is an important process, because it gives members of the public, especially the Interested and Affected Parties to comment or raise concerns that may affect the socio-economic or general environment as a result of the project. Further, it solicits crucial local knowledge that the Environmental Assessment Practitioner may not have.

6.1. Newspaper Adverts

The EMA requires that, the project must be advertised into two (2) daily newspapers that are widely circulated in the country (Table 6). The project was advertised for two consecutive weeks in the NewEra newspaper and Confidente Newspaper (Appendix 1).

Table 5. Newspaper Adverts

Newspaper Date advertised NewEra 14th & 20th November 2019 Confidente 14th & 20th November 2019

6.2. Public Meeting

6.2.1. Introduction

A public meeting was held at Otavi “Boerevereniging” (Farmers Association) on 28th November 2019. The meeting was jointly organized by Huab Energy (Pty) Ltd and Red-Dunes Consulting CC. (Figure 8). It is worth to note that, the initial proposed public meeting date was changed due to the farmer’s commitment to an auction that was held on the 22nd November 2019. This arrangement was done together with the chairperson of the Otavi farmers association.

Figure 9. Public meeting at Otavi Farmers association hall

Red-Dune Consulting explained to the meeting in layman terms that exploration is “looking for minerals, with the aim of investing and opening up a mine”.

It was further explained that major part of exploration process is non-invasive, meaning the proponent does not engage into physical activities or excavation. These activities do not cause harm to the environment, but instead various prospecting methods are used such as geophysical ground surveys (using helicopters mounted with electromagnets), Geochemical soil sampling and aerial mapping amongst others.

The only evasive process is whereby after the geological targets are identified, the proponents then comes in with equipment to drill at a specific site to obtain geochemical samples for assessment. The farmers were assured that the project is at the exploration level and no mining will be taking place at this stage. However, given the proponents finds minerals feasible to establish a mine, a comprehensive EIA shall be undertaken and farmers shall be presented with comprehensive contractual agreement detailing their benefits.

6.2.2. Environmental Impact Assessment (EIA) process

Red-Dune gave an overview of the environmental impact assessment process is the provision of the Environmental Management Act 2007, (Act No 7 of 2007). The farmers were informed of their importance to in participating in the EIA to ensure critical environmental issues are considered. For example, if farm A has tourism activities, which requires bird siting and the proponent is flying over simultaneously, this may disturb the birds/game at that specific time. Therefore, information to guide flying time may come from the farmers to be included in the EMP. Another example given was that, if a specific site has a social value (i.e. cemetery) and the farmer doesn’t want it to be accessed/disturbed, the farmer has the right to refuse the proponent from entering that site. Once the EMP is approved by the Ministry of Environment and Tourism (MET), then it becomes a legal guiding tool for the proponent to undertake the exploration process. The proponent is required to rehabilitate any physical exploration done on an area, if failure to do so, the farmer has the right to report them to MET.

To enlighten the farmers, a list of the potential environmental threats identified were given;

Soil and Ground Water pollution: Fuel, Oil, and Lubricants spillages Drilling activities: Dust creation, noise and wild life disturbances and spill of Hydraulic Fluids,

Biodiversity Loss: clearing of vegetation to make way for vehicles, camping sites and drilling. Human Health & Safety Risk: Dust from drilling, accidents and Sanitation Human Wildlife conflict and Poaching Land Degradation: Off-road driving Pollution: Solid waste generated by workers, ablution facilities.

6.2.3. Commencement of the Exploration Activities

The exploration activities will only take place once an Environmental Clearance Certificate is granted by the Ministry of Environment and Tourism. Farmers were encouraged to email their comment so that they are included into the EMP.

6.2.4. Huab Energy (Pty) Ltd

Mr. Crispen Mutizwa from Huab Energy briefly explained to the meeting that they are exploring for copper and gold, and that a compensation fee of N$5000p/m will be paid to the farmer to access their farms.

6.2.5. Comment / Question and Response

The farmers indicated that they are familiar with Exploration activities and few comments and question were raised in relation to their previous experience with other explorations.

Name Comment / Question Response Mr. de Jager If you drill and find water, are we allowed to make Huab Energy: We shall be happy to leave the casing for use/keep the borehole? you Mr, de Jager When are u planning on starting with the exploration? Huab Energy: Sometime next year, we need to renew EPL

Mr. Falk Please just make arrangements in advance, we do not Huab Energy: We will communicate to you prior and want you just showing up that same day. agree on convenient dates.

7. Impact Identification and Risk Assessment

7.1. Impact Identification

During literature review and site assessment, possible impacts were listed. The criteria used to assess the impacts and the method of determining their significance is outlined in Table 7. This process conforms with the Environmental Impact Assessment Regulations of Environmental Management Act, 2007 (Government Gazette No. 4878) EIA regulations. The approach for determining and analyzing impacts is undertaken into two steps.

 Impact Determination; during this step, the impact is assessed based on severity, spatial scale and its duration.  Impact Significance; various rating exists to determine the overall rating of the impact

Impact significance is determined under two mitigation scenarios; without mitigation and with mitigation. The confidence of impact mitigation depends on the level of certainty based on available information to assess the impact. Impacts whose level of uncertainties are high, a specialist study maybe commissioned to understand and develop the mitigation measures. If after a specialist studies there are still further uncertainties pertaining the impact, a precaution measure is applied to allow for more studies to be undertaken.

Table 6. Criteria for impact assessment

Risk Event Rating Description of the risk that may lead to an Impact Impact type 0 No Impact +VE Positive -VE Negative Probability The probability 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 irrespective of the applied mitigation measure)

Confidence The confidence level of occurrence in the prediction, based on available knowledge level L Low M Medium H High Significance 0 None (Based on the available information, the potential impact is found (Without 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 (This is when the impact is expected to be of short term moderate and normally regionally. In most cases, such impacts require that the projects is altered to mitigate the impact 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 is found (With to not have a significant impact) Mitigation) L Low (The presence of the impact’s magnitude is expected to be temporal or localised, that may not require alteration to the operation of the project

M Medium (This is when the impact is expected to be of short term moderate and normally regionally. In most cases, such impacts require that the projects is altered to mitigate the impact 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 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

7.2. Impact Risk Assessment Procedure

An illustration of an impact analysis is shown in Figure 9.

Figure 10. Matrix used for the impact assessment

7.3. Identified Impacts

The following negative and positive impacts were identified. An EIA is a living document, impacts that could not be identified for this scoping report and identified later should be taken into account and adequate mitigation measures be applied.

7.3.1. Potential Negative Impacts

 Noise pollution from heavy machinery and drilling  Soil disturbance  Loss of habitat and biodiversity from site preparations and occupation  Air pollution from vehicle emission and dust emission from drilling activities

 Health and Safety risk  Risk of pollution from generated domestic solid wastes  Risk of contamination of ground water from oil, grease and lubricants from heavy vehicles, and drilling activities.

7.3.2. Potential Positive Impact of the project

 Direct and indirect creation of employment opportunities  Knowledge and technology transfer.  Increased economic activities  Increase in National economy through payments of taxes.

8. Risks Assessment

8.1. Planning Phase

To ensure that the project is accepted by the public and avoid possible conflicts, the project was advertised in local newspaper and a public meeting was held with farm owners. Access to farms is done under a signed agreement between farmers and Huab Energy Pty Ltd.

8.2. Operational Phase

8.2.1. Socio-Economic Impacts

Potential Environmental / Social Mitigation Measures Significance of the Impact Impact Employment 1. Ensure that all general work is Type +VE reserved for local people unless in Severity Medium It is not anticipated that a significant circumstances where specialized Scale / Extend Local number of employment shall be created skills are required. Probability Definite during the operation of the project. 2. Fair compensation and labour Confidence level High

practise as per Namibian Labour Without Mitigation Medium Laws must be followed With Mitigation Low 3. Ensure skill transfer to the locals

HIV/AIDS, Alcohol and Drug abuse 1. Provide awareness to the employees / Type -VE recyclers on danger of alcohol and drug Severity High Namibia has high prevalence of abuse Scale / Extend Local HIV/AIDS and it is important to ensure 2. Provide Condoms at site Definite that employees are sensitized about the Probability pandemic. Confidence level High Without Mitigation Medium, With Mitigation Low

Potential Environmental / Social Mitigation Measures Significance of the Impact Impact Health and Safety Health; Type -VE

1. Abide by the Occupational Health and The Regulations Relating to the Health Severity High Safety and Labour Act of Namibia and and Safety of Employees at Work, made Scale / Extend Local other statutory requirement such as under Labour Act of 1992 (Act No. 6 of Probability Definite International Labour Practise (ILO) 1992) place legal duty on employers to 2. Ensure adequate first aid kid at every Confidence level High provide a health and safe working station Without Mitigation High environment to the employees and any 3. Supervisors must undergo an With Mitigation Low person other than the employees who occupational health and first aid might be affected by their operations. course; Operation of specialized drilling 4. Train employees on the possible health equipment may increase safety risk if not hazards to avoid potential risks executed correctly 5. Provide appropriate Personal

Protective Equipment (PPE)

6. Provide insect repellent, mosquito nets and immunization to prevent fatal diseases such as Malaria 7. Implement compulsory medical examination for workers with regard to

Potential Environmental / Social Mitigation Measures Significance of the Impact Impact communicable / airborne diseases (i.e. TB) 8. Employees must NOT be exposed to noise levels above the required -85dB (A) limit over a period of 8 hours. 9. Adhere to the Labour act, non-toxic human dust exposure levels may not exceed 5mg/m3 for respiratory dust and 15mg/m3 for total dust. 10. Supply clean drinking water to the site;

Safety 11. Develop a safety plan 12. Ensure that every employee goes through an induction course about safety; 13. Employees must be equipped with all necessary Personal Protective Equipment (PPE). These includes,

Potential Environmental / Social Mitigation Measures Significance of the Impact Impact Helmet, Overall, Safety Shoes, Safety Glasses, Gloves, Earmuff etc; 14. During operation, minor accidents are eminent, hence there must be a first aid kit; 15. Only qualified and licenced personnel must be allowed to operate machinery and vehicles; 16. Adequate safety signs must be displayed on site; Archaeology 1. Employee must be trained on the Type -VE

possible find of archaeological Severity Medium There are no known of possible heritage material in the area; Scale / Extend Local or archaeology materials on site 2. Implement a chance find and steps to Probability Definite be taken when archaeological material finding (Heritage (rock Confidence level High

painting and drawings), human Without Mitigation Medium, remains or artefacts) are unearthed With Mitigation Low Stopping the activity immediately

i. Informing the operational

Potential Environmental / Social Mitigation Measures Significance of the Impact Impact manager or supervisor ii. Cordoned of the area with a danger tape and manager to take appropriated pictures. iii. Manager/supervisor must report the finding to the National Museum (+264 61 276800) or the National Forensic Laboratory (+264 61 240461).

8.2.2. Bio-Physical Impacts

Potential Environmental / Social Impact Mitigation Measures Significance of the Impact Flora 1. Implement recommendation from the Type -VE vegetation study Severity Medium The target areas for drilling and trenching may 2. Ensure that access roads are rehabilitated Scale / Extend Site Specific require the clearing of vegetation. The farms after use Probability Definite are heavily encroached, and farmers indicated Confidence level High that, they shall be happy if the encroacher bush Without Mitigation Medium is removed. Unless totally unavoidable, mature With Mitigation Low trees must not be cut down. Fauna 1. Do not kill animal, unless such animals Type -VE

pose eminent danger to humans Severity Medium There are domestic and wild animals on farms. 2. There must be ZERO tolerance to Scale / Extend Site Specific These animals are accustomed to human poaching to ensure this, no weapon and Probability Probable activities; hence human presence shall not traps are allowed on site; Confidence level High impact them severely. However, employees Without Mitigation Medium must be cautioned against poaching. Highly With Mitigation Low protected animals such as Rhinos are not With Mitigation Medium present in the area. Surface and Ground Water Pollution 1. Fuelling of heavy vehicle on site must be Type -VE well coordinated at designated places Severity Medium

Potential Environmental / Social Impact Mitigation Measures Significance of the Impact Heavy vehicle and machinery may pollute 2. Stationary vehicles must be provided Scale / Extend Site Specific water sources from leakages of oils, hydraulic with drip tray to capture oil, lubricants Probability Definite fluids, lubricants and greases. These pollutants and hydraulic fluids leakages Confidence level High may reach underground water through 3. All vehicle and machinery must be well Without Mitigation Medium seepage. Further surface water may be polluted service to avoid leakages With Mitigation Low from surface run off soils that is polluted. 4. Provide and train on oil spill emergency response 5. Servicing of vehicles and machinery must take place at designated sites Land Degradation 1. Movement of heavy vehicles must be Type -VE coordinated and restricted to be on Severity Medium The uncontrolled movement of heavy access roads Scale / Extend Site Specific machinery at the project site as well as on Probability Definite access loads may cause land degradation. Confidence level High Without Mitigation Medium With Mitigation Low Waste Generation 1. Provide Skip bins to collect waste Type -VE General household waste management and be disposed of at an approved Severity Medium measures must be put in place. disposal site Scale / Extend Site Specific 2. Do not burry waste on site Probability Definite

Potential Environmental / Social Impact Mitigation Measures Significance of the Impact 3. Excavate a small biodegradable Confidence level High waste site that would be dump filled Without Mitigation Medium at the end of the project With Mitigation Low 4. Used oil, grease and lubricants cans must be collected in appropriate drums and disposed of at a approved site.

9. Decommissioning and Rehabilitation

The exploration activities do not necessarily yield into a decommissioning phase, but rather a rehabilitation phase. The rehabilitation shall include all footprints that were created as a result of exploration mainly, access roads, trenches and drilled holes. Waste dumps with biodegradable materials must be backfilled as well as pit latrine toiled if any. In the end, the rehabilitation must satisfy the farm owners.

10. Conclusions and Recommendations

10.1. Conclusions

Normally, exploration phase does not yield high level bio-physical environmental damage. Negligible footprint from access roads, and drilling are not expected to cause irreversible harm to the environment. Trenches, drilled holes and access roads are normally fully rehabilitated and always re-vegetated after rainfall season. Henceforth, the proposed exploration activities are expected to be undertaken in an environmental sustainable manner. In events where this exploration yield into a feasibility mining operation, a comprehensive environmental impact assessment must be undertaken.

10.2. Recommendations

It is recommended to the approving authority for an issuance of the Environmental Clearance Certificate for the proposed Exploration activities on EPL 5232.

11. Reference

A.L.E. Simmonds and T.J. Smalley 2000., Kalahari aquifers in the Gam area of north-eastern Namibia, Communs geol. Surv. Namibia, 12 (2000), 469-474 Department of Water Affairs., Demarcation of Water Basins on National Level, Namibia Dr. Martin Pickford and Dr Brigitte Denut 2010., Memoir 21 Karst Geology and Palaeobiology of Northern Namibia, Ministry of Mines and Energy Geological Survey of Namibia Enviro Dynamics 2014., Environmental Assessment for the exploration of base metals on exclusive prospecting licenses 5606, 4934, 5712 & 5713), Kavango East Region, Namibia. Greg Christelis and Wilhelm Struckmeier 2011., Groundwater in Namibia; An Explanation to the Hydrogeological Map, Ministry of Agriculture Water and Forestry J.E. Misiewicz 1988., The Geology and Metallogeny of the Otavi Mountain land, Damara Orogen, Swa/Namibia, with particular reference to the Berg Aukas zn·pb-v Deposit - A Model of Ore Genesis Mannheimer, C.A, & Curtis, B.A. (eds) 2009. Le Roux and Muller’s Field Guidebto the Trees and Shrubs of Namibia. Windhoek: Macmillan Education Namibia. Maria Boni et al 2016., Genesis of Vanadium Ores in the Otavi Mountainland, Namibia, Society of Economic Geologists, Inc. Economic Geology, v. 102, pp. 441–469 Mendelsohn, J., Jarvis, A., Roberts, C. & Robertson, T., 2009. Atlas of Namibia. 3rd ed. Cape Town: Sunbird Publishers. Ministry of Agriculture Water and Forestry 2000 ., Strategic Water Resources Assessment: Theme Report Okitsu, S. (2005). Factors controlling geographical distribution in savanna vegetation in Namibia. African Study Monographs, Suppl. 30(March), 135–151. Population Demography for the Otjozondjupa Region for 2001 and 2011 (Namibia Population and Census Report of (2011). S Hapugoda and J R Manuel., A Comparison of Drilling and Sampling Techniques as They Relate to Base and Precious Metal Exploration in the Mt Isa Inlier of North West Queensland and the Southern Lachlan Fold Belt in New South Wales.