Summer Desertification Program 17

November 2013 - February 2014

Water sources, Wastewater and Solid Waste Management in the Greater Sossusvlei Landscape,

1

Water sources, Wastewater and Solid Waste Management in the Greater Sossusvlei Namib Landscape, Namibia

By

Vistorina Amputu, Brunah N Ekandjo, Ebba Iilende, Kaoti Jackson, Lysias Kapiye, Kennedy JD Kariseb, Sinvula M Lukubwe, Tanaka D Nyatoro, Emma Shidolo, Ruben Ulbrich, Martha N Uugwanga

Summer Desertification Program 17

November 2013 - February 2014

Edited by

Robert Logan, Mary Seely, Kathryn Vincent 2

Acknowledgements

The authors and editors of this report extend their gratitude to those who supported them and made the study possible:

The Namibia Protected Landscape Conservation Areas Initiative (NamPlace) and Environmental Investment Fund of Namibia (EIF) for providing the funding for the course.

The Directorate of the Ministry of Environment and Tourism (MET), namely Mr Sem Shikongo for lectures and advice during the time in Gobabeb.

Family Sturm as well as Mr Karl-Heinz Oosthuizen for hosting the course during the fieldwork and the workshop. Special regards to Mr Quintin and Mrs Vanessa Hartung for the accommodation and assistance in Toekoms.

All the stakeholders and their staff members of the GSNL who took their time to be interviewed and their patience to show us around on their properties as well as sharing their knowledge and experience.

The team wants to give a special thanks to all guest speakers from various institutes who voluntarily gave an introductory overview of the GSNL and provided basic research techniques for the fieldwork during the first week in Windhoek. The guest speakers are listed below in alphabetical order: Rodney Amster, Dudley Biggs, Jonas Heita, Ivondia Karumendu, Gunter Lempert, Gys Louw, Tobias Mannel, Eugene Marais, Willem Odendaal, Wolfgang Schenk, John Siloiso, Friedolf Sturm and Roger Swart.

The Desert Research Foundation of Namibia staff members for facilitating the course, namely in alphabetical order Ronald Kanguti, Viviane Kinyaga (director), Christerline Ndeleki and Epfania Lepaleni.

Dr Gillian Maggs-Kölling and her staff members from Gobabeb Research and Training Centre for hosting the team during field preparation and data analysis. Thanks goes to Robert Logan and Kathryn Vincent for driving, assisting and discussing back and forth with the team.

The SDP participants want to express deepest gratitude to Dr Mary Seely for her advice, assistance and fruitful discussions during the whole duration of the program. 3

Abstract SDP 17 conducted a study on water, wastewater and solid waste management in the Greater Sossusvlei Namib Landscape. Observations, water quality tests, GPS coordinates and interviews were conducted on 21 stakeholders and their establishments.

The major findings of the research as per the four aspects namely water, wastewater, solid waste management and legal aspects of the study were as follows. All stakeholders have several boreholes on their establishments and use groundwater as the main water source. However, little is known about the aquifers’ recharge or the groundwater in the area. Other studies have emphasised that staff members have major control of water usage. Most of the small establishments use French drains and septic tanks for handling their wastewater. Few, especially medium and large establishments, are using more advanced systems like reed beds, biological wastewater systems or evaporation ponds.

The majority of interviewed stakeholders sort their solid waste before the disposal and, half of the interviewed stakeholders have onsite dump sites. Others take their waste to Windhoek recycling plants and the Maltahohe dump site. The majority of stakeholders rejected the idea of a group collection centre for different valid reasons. Most of the interviewed stakeholders are not aware of required permits or licences for disposal of wastewater, solid waste or drilling boreholes nor are in possession of such permits or licences.

Based on the findings of the study the following recommendations were made and further discussed in a workshop with the stakeholders with the aim of obtaining further input from them. The group identified the need for stakeholders to intensify and promote environmental awareness and training for the staff but also tourists. Further discussion of the group collection centre and a study on groundwater aquifers in the area is recommended. Moreover stakeholders need to prioritize and include water, wastewater and solid waste management as a significant part of their overall business plan. 4

List of Acronyms

Acronym Meaning

DRFN Desert Research Foundation of Namibia DWAF Department of Water Affairs and Forestry EIF Environmental Investment Fund

GIS Geographic Information System GPS Global Positioning System GRTC Gobabeb Research and Training Centre Greater Sossusvlei Namib Landscape GSNL Hospitality Association of Namibia HAN Ministry of Environment and Tourism MET Namibia Protected Landscape Conservation Areas NamPlace Initiative NamWater Namibia Water Cooperation NWR Namibia Wildlife Resorts SDP Summer Desertification Program WW Wastewater WWS Wastewater systems WWTS Wastewater treatment systems 5

List of Figures Figure 1: Study site and interviewed establishments (Source: SDP17)...... 12

Figure 2: Catchments and rivers in GSNL (Source: NamPlace, Atlas of Namibia, Google Earth, SDP17)...... 13

Figure 3: Number of boreholes at various depth categories in the GSNL, 2013 (n = 48)...... 19

Borehole Depth and Location...... 19

Figure 7: Relationship between elevation and known borehole depth in the GSNL (n = 49).20

Figure 5: Recorded boreholes with SDP ID and depth related to the elevation in the northern part of the GSNL, 2013 ...... 21

Figure 6: Recorded boreholes with SDP ID and depth related in the elevation of the southern GSNL, 2013...... 22

Figure 8: Major catchment areas and recorded boreholes in the GSNL, 2013...... 23

Figure 9: Different types of energy sources used to pump water in the GSNL, 2013, n = 58. It is worth noting that most establishments make use more than one energy source ...... 24

Figure 10: Recorded boreholes with SDP ID and energy sources in the northern GSNL, 2013 ...... 25

Figure 11: Boreholes with SDP ID and energy sources in the southern GSNL, 2013 ...... 25

Figure 12: Average depth of boreholes using various energy sources to derive water in the GSNL, 2013, n = 46 ...... 26

Figure 13: Different toilet systems used in various establishments in GSNL ...... 27

Figure 14: The number of establishments that generate identified types of wastewater in the GSNL, 2013...... 28

Figure 15: The number & size of establishments making use of the different WWS at the 21 establishments visited in GSNL, 2013 ...... 29

Figure 16: The number and size of establishments that have kitchen fat traps ...... 33

Figure 19: Maltahohe dumpsite, SDP 17 (2014) ...... 43

Figure 20: Off-site facilities where 14 of the 21 establishments in the GSNL take their recyclable solid waste...... 44

Figure 22: Comparison of the financial costs between solar pumps and diesel pump over a long term (DRFN, 2008) ...... 50 6

Figure 23: Students making paper fire bricks at NaDEET (Source: NaDEET, 2013) ...... 68

Figure 24: A - Garden on one of the private establishments that compost. B - A piggery on a private establishment, SDP 17 (2013) ...... 69 7

List of Tables Table 2: Position of interview respondents from different establishments...... 18

Table 3: Number of recorded boreholes in different catchment areas in the GSNL and their distance from rivers ...... 23

Table 4: Possible water usage for both the tourists and staff members at a tourist establishment ...... 26

Table 5: Frequency of establishments using different types of showers in the GSNL, 2013..27

Table 6: The effectiveness of WWS at the different establishments in the GSNL, 2013...... 30

Table 7: Maintenance frequency of WWS at the different establishments in the GSNL, 2013 ...... 31

Table 8: Number of establishments using various individual WWS components in the GSNL, 2013 ...... 31

Table 8: The cleaning frequency and disposal of kitchen fat trap waste by the different establishments...... 34

Table 9: Change from a previous WWS or addition of components to existing WWS in the GSNL, 2013...... 35

Table 11: The proximity of wastewater handling systems to freshwater sources at establishments in the GSNL, 2013 ...... 38

Table 12: Source of supply for the establishment within the GSNL, 2013. (WHK = Windhoek, MAR = Mariental, MAL = Maltahohe, SWK = , W/B = ) ...... 40

Table 13: Uses of organic waste at establishments in the GSNL, 2013 ...... 42

Table 14: Individual onsite dump sites for private and public establishments in the GSNL, 2013 ...... 42

Table 16: Awareness and possession of permits/licences relating to water sources, waste water and/or solid waste management in the GSNL, 2013 ...... 46

Table 16: The advantages and possible disadvantages of the various WWS components used in the GSNL, 2013...... 58

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TABLE OF CONTENTS

Table of Contents 1 Introduction...... 10 1.1 General Introduction...... 10 1.2 Problem Statement...... 10 2 Methodology and Materials...... 11 2.1 Study Site...... 11 2.3 Data Collection Methods...... 13 2.4 Data Analysis Methods...... 15 2.5 Geographic Information System (GIS)...... 15 2.5.1 GIS Mapping...... 15 2.5.2 3D Modelling...... 15 2.6 Water Testing...... 16 2.7 Workshop ...... 16 3 Results...... 18 3.1 General Information...... 18 3.2 Water Sources...... 19 3.2.1 Borehole Characteristics ...... 19 3.2.2 Boreholes and Location to Rivers...... 22 3.2.3 Boreholes and Energy Sources for Pumping ...... 24 3.2.4 Water Usage and Sanitation ...... 26 3.2.5 Water Quality and Testing ...... 27 3.3 Wastewater in the GSNL ...... 28 3.3.1 Wastewater Sources in the GSNL...... 28 3.3.2 Wastewater Systems used for Handling Wastewater in the GSNL ...... 29 3.3.3 The Effectiveness of Wastewater Systems used by the Establishments...... 29 3.3.5 Establishments with Kitchen Fat Traps ...... 33 3.3.6 Change of Wastewater systems on Establishments since Operation of current Establishment ...... 34 3.3.7 Final Disposal of Wastewater and its Accessibility to Animals and Humans ...... 36 3.4 Solid Waste Management in the GSNL ...... 39 3.4.1 Source of Solid Waste ...... 39 3.4.2 Types of Solid Waste generated...... 41 3.4.4 Onsite Handling of Solid Waste in the GSNL ...... 41 3.4.5 Off‐Site Handling of Solid Waste in the GSNL ...... 43 3.4.7 Group Collection Centre ...... 44 3.5 Legal Aspects ...... 46 4 Discussions ...... 48 4.1 Water Sources...... 48 9

4.1.1 Introduction ...... 48 4.1.2 Boreholes and Depth ...... 48 4.1.3 Source of Energy ...... 49 4.1.4 Water Use ...... 51 4.1.5 Water Quality...... 52 4.1.6 Water Sources Recommendations...... 53 4.2 Wastewater ...... 56 4.2.1 Introduction ...... 56 4.2.2 Wastewater Sources ...... 56 4.2.3 Wastewater Systems and Components ...... 56 4.2.4 Final Disposal ...... 59 4.2.5 Wastewater Summary ...... 61 4.2.6 Wastewater Recommendations...... 61 4.3.1 Introduction ...... 66 4.3.2 Source of Solid Waste ...... 66 4.3.3 Types of Solid Waste generated...... 66 4.3.4 Handling of Solid Waste...... 67 4.3.5 Sorting...... 67 4.3.6 Recycling and Reuse of Solid Waste...... 67 4.3.7 Recycling and Reuse of Organic Waste ...... 68 4.3.8 Individual Dump Sites for Establishments in the GSNL ...... 69 4.3.9 Offsite Handling of Recyclables...... 69 4.3.10 Training and Awareness...... 70 4.3.11 Group Collection Centre ...... 70 4.3.12 Solid Waste Recommendations ...... 71 4.4 Legislative and Regulatory Framework...... 74 4.4.1 General Aspects ...... 74 4.4.2 Water Sources...... 74 4.4.3 Wastewater...... 79 4.4.4 Solid Waste ...... 81 4.4.5 Key Legal and Social Issues...... 82 4.4.6 Law Aspects Recommendations ...... 84 References...... 86

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1 Introduction

1.1 General Introduction The number of tourists to Namibia in 2005/6 to 2011 increased enormously from about 600 000 to over a million (www.travelnamibianews.com, 2013). Of these, 18 % tour to the Greater Sossusvlei Namib Landscape (GSNL) and the percentage of tourists visiting the landscape is expected to increase following the recent inscription of the Namib Sand Sea as a UNESCO World Heritage Site (Marais, 2013). This increase in tourist traffic is likely to significantly increase water demand and waste generation. For this reason, it is important to assess the management of water sources as well as both solid waste and wastewater within the landscape. Given its high economic importance and the severity of its need, management of solid and liquid waste has become a concern for both the public and private tourism sectors in Namibia. For this reason, local authorities such as the GSNL committee are increasing efforts to manage waste across the landscape. To ensure environmental sustainability and economic vitality of lodges in the area, a full assessment of the current state of waste management in the landscape is needed. This report is a contribution to this assessment. In the view of sustainable development, the following elements are considered as being of essence in the developmental approaches: application of policies and legal frameworks, stakeholder involvement as well as attention to all relevant principles (Hasheela, 2009 and EMA, 2007). Such elements involve actions needed to reduce the most serious problems, for example the handling of waste collectively in the landscape. They also contribute to strategies required to promote healthy and safe environments, as well as dealing with specific environmental aspects of concern. It is important to note that the environmental problems resulting from specific establishments not only impact those establishments individually, but can also affect other areas at different levels, for example at the local, regional and national levels.

1.2 Problem Statement Water, wastewater, and solid waste management are serious concerns in the GSNL. Water is a limited resource in the landscape; therefore it requires consideration on usage and consumption. Wastewater can be a serious threat to humans, animals and the environment 11 due to inefficient systems. As part of environmental management in Namibia, waste management should be regarded as a priority in order to reduce negative environmental impacts. However, capacity to manage waste and to control pollution is limited (Hasheela, 2009).

Apart from the management capacity, financial constraints are some of the limiting factors to effective waste management across the country. Namibia is an arid country, with variable rainfall and has limited water sources; mainly ground with limited surface water. These sources are at risk of contamination as a result of uncontrolled pollution and poor waste management practices in the GSNL. At the local level, the environment is threatened by unsafe waste disposal, which can be harmful to the environment and can cause health hazards. Not only health and environmental damage can result, unattended waste can present poor aesthetic views, causing the environment to be less visually appealing despite the fact that Namibia is a tourist destination. Furthermore, poor waste management is a threat to sustainable development and can have long-term impacts if no improvement is made.

2 Methodology and Materials

2.1 Study Site The Greater Sossusvlei Namib Landscape (GSNL) is located in the southern part of the Namib Desert encompassing a major part of the Namib-Naukluft Park and a number of bordering tourism and farming establishments (Figure 1). 12

Figure 1: Study site and interviewed establishments (Source: SDP17)

Much of the land in the focal GSNL was previously used for livestock farming but aridity and unpredictable rainfall posed a difficulty for many farmers. For this reason, the land could not sustain large numbers of livestock and most farms were converted to tourist lodges, which can generate a higher and steadier income (Pallet, 1997 and NDP 4, 2013). Because of its aridity, the GSNL has no permanent surface freshwater bodies and human water use is entirely dependent on groundwater extracted via boreholes using various energy sources such as solar, diesel and windmills. About 30 establishments are found in the GSNL with 60 establishments focusing on the Sossusvlei as the main tourist attraction. The SDP participants interviewed 21 of these establishments for this study. Seventeen are tourist lodges and campsites (two publicly owned and the remainder privately owned); three are management establishments to oversee the local environment (one government owned) and one is an active private livestock farm. The GSNL occurs within several endorheic drainage basins (i.e. there are no outflows from the ) of the ephemeral Tsondab, and Tsaris Rivers. The GSNL is characterised by a collection of similar natural features between the two rivers Koichab (in the south) and Kuiseb (in the north) extending for about 32 000 km2 (NamPlace, 2012). 13

Figure 2: Catchments and rivers in GSNL (Source: NamPlace, Atlas of Namibia, Google Earth, SDP17)

White silt beds (vleis) such as Sossusvlei and Tsondabvlei are found at the end of the endorheic, ephemeral rivers amongst the pinkish-red that are famous land features of the GSNL.

2.3 Data Collection Methods A total of eleven Summer Desertification Programme (SDP) 2013 participants and three Desert Research Foundation of Namibia (DRFN) and Gobabeb Research and Training Centre (GRTC) researchers conducted interviews with respondents from 21 establishments in the Landscape over a two week period in December 2013 using questionnaires (see Appendix 2) which were developed beforehand by the group. The questionnaires consisted of 91 questions, which were a combination of open and closed-ended questions meant to obtain information about, inter alia, an establishment’s size, history of land use, tourists, water sources, water use, wastewater treatment and management, solid waste management, general challenges, and future plans for growth. 14

The interviews lasted for an average of 90 minutes. One interviewer led the discussion with the interviewee and two participants recorded answers, while one participant was taking pictures and collecting further information materials (e.g. GPS coordinates). Each group consisted of at least one DRFN researcher and four SDP participants.

Visits were taken to relevant water and waste infrastructure points on the property for observations and photographs. Photographs of water, wastewater and solid waste infrastructure and management approaches were taken from the establishments after receiving the permission from the interviewee. Additional information such as water quality analysis records, records of the water metres, rainfall records, waste management plans, and other information materials were obtained wherever possible from the establishments. 15

2.4 Data Analysis Methods Data was analysed using Microsoft Excel 2010 from where tables and graphs were produced. Data from the GPS devices were analysed using ArcGIS 10.1 and used to create maps that ranged, e.g. from distances from boreholes to waste water, boreholes to rivers, elevation to catchment areas. Water samples were collected using plastic bottles from 16 establishments at different locations (such as kitchen (tap), borehole, animal water hole and reservoirs).

2.5 Geographic Information System (GIS)

2.5.1 GIS Mapping Each group used a Garmin GPS device and obtained GPS coordinates from most of the following locations: main building and locations of the establishment, water sources (boreholes - used/unused, dams, fountains, rainwater collection), wastewater disposal sites (backwash discharges, biological wastewater treatments, evaporation ponds, French drains, reed beds, Septic tanks), solid waste disposal sites (burning sites, composts, current/old dump sites, solid waste separation/storages places), and further places of interest (diesel reservoirs, fat traps, garden, oil tank, pools, water reservoirs, water tanks, waterholes). The recordings were stored in a table by providing a waypoint number (ident), GPS device, latitude, longitude, altitude in feet and meter, time/date, number in the project (sdp_id), farm/establishment name, location on the establishment, type/kind of establishment, close and broad pictures, comments, borehole depth in metres, energy source as well as groundwater depth in metres.

2.5.2 3D Modelling The borehole depth, the energy source to abstract water and the groundwater table received from the GPS recordings and information of the interviews was visualized in a 3D model. Unknown groundwater tables were estimated to be over 10 m above the borehole depth to simulate the situation in the GSNL. In addition, elevation data was obtained from U.S. Geological Survey (http://hydrosheds.cr.usgs.gov/index.php, accessed 27 January 2014) in a resolution of 3 sec (approximately 90 m x 90 m per grid at the equator). 16

An example was a borehole at 2x4 Sossusvlei parking lot with a depth of 240 m and an estimated groundwater table of 400 m to visualize the situation of the dry drilled borehole without knowing the exact groundwater level. ArcScene© 10.1 (part of the ArcGIS 3D Analyst Extension) was used to model the elevation, groundwater level and borehole depth. A Google Earth satellite image was used in this regard. Different colours were used to highlight the energy source of each borehole (green - solar, yellow – solar hybrid, red - diesel, blue - windmill, black - power line, grey - unknown) (see Appendix 4). The groundwater layer was created with polygons for each borehole containing the depth of the groundwater table as z-value. Groundwater level and borehole depth were multiplied by 10, which was made to ensure the visibility of that information in the model. A short animation clip was created to visualize the situation from different angles and perspectives for the stakeholders at the workshop held at Sossusvlei Lodge on January 17, 2014. The video clip, table of GPS points and the shape files are available from SDP17 upon request.

2.6 Water Testing A water sample was collected at each establishment and labelled with the name of the establishment and date of collection. Upon collecting the samples, the plastic bottle and the lid were rinsed three to five times with the water from the source in order to reduce contamination before filling it up. The samples were analysed as soon as possible. Ammonia, nitrite, nitrate, free chlorine, total chlorine, total hardness, total alkalinity and pH were tested using HACH water quality test strips. The strips were used according to the manufacturer’s instructions as labelled on each container in the test kit. The colours of the strips changed depending on the concentration of the parameter and were compared with the matching colour labels on the container; readings were taken in parts per million (ppm).

2.7 Workshop On the 17 January 2014, eleven SDP participants and nine GSNL stakeholders attended a workshop held at Sossusvlei Lodge. A two and a half hour long presentation and discussion on the proposed water and waste draft management plan took place between the SDP participants and the stakeholders. The aim of the workshop was to share our recommendations based on the results obtained, but vitally to gain additional input from 17 stakeholders. During the discussions the stakeholders expressed the need for more specific information and for the raw data collected, however the SDP participants did not have this at the time. This was because the intended idea was to present recommendations rather than the report. Stakeholders were then presented with recommendation handouts on prioritisation of water and waste management from the SDP participants. The outcome of the workshop, attended by NamPlace but not the primary funder EIF, shifted the intended outcome of the project from a draft management plan to a detailed report. This report will then contain identifiable information on specific situations at different establishments in the GSNL (see Appendix 5), which will help the GSNL committee and NamPlace to draft their own management plan for the landscape. 18

3 Results

3.1 General Information We interviewed a total of 26 respondents (20 male, 6 female) from 21 establishments in the Landscape. Seventeen establishments are tourist lodges and campsites, three are management establishments to monitor the local environment and one is an active livestock farm. The total occupancy of establishments (total number of beds for visitors and staff) varied from zero (no accommodation) to over 100. The establishments were categorized according to the maximum occupancy (small - zero to 30; medium - 31 to 99; large - 100 and above). Seven establishments are independent and the remaining thirteen are part of larger groups such as the state-owned enterprise NWR and the independent syndicates such as Namib Rand Nature Reserve, the Gondwana Collection, Drifters, Taleni Africa and &Beyond. Most respondents were either managers or owners (Table 2).

Table 2: Position of interview respondents from different establishments

Management Number of Establishments Manager 8 Owner/Founder 6 Maintenance worker 3 Warden 2 Ranger 1 Tour guide 1

Establishments in the Landscape receive mainly international visitors (countries such as Germany, Australia, France, United Kingdom, South Africa, Switzerland, United States, and the Netherlands with a vast majority coming from Germany) and only a limited number of Namibians. To date, four establishments have received ratings from ECOAWARDS, and one establishment has ratings from Global Ecosphere Retreats and Classical Safari of Southern Africa. Ten establishments were affiliated with NamPlace, seven had representation on the GSNL Committee, and seven were members of the Hospitality Association of Namibia 19

(HAN). All but three respondents were aware of the recent inscription of the Namib Sand Sea World Heritage Site.

3.2 Water Sources

3.2.1 Borehole Characteristics All interviewed establishments make use of groundwater, which is accessed either through boreholes, or in one case, from an artesian spring. A total of 58 boreholes were recorded, 30 of which were mapped; information concerning 27 boreholes of NamibRand Nature Reserve were provided by Quintin Hartung and Peter Woolfe. One dry borehole was reported to have been drilled to 240 m near the 2x4 parking lot near Sossusvlei late in 2013.

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15

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5 Number of boreholes of boreholes Number 0

Borehole depth

Figure 3: Number of boreholes at various depth categories in the GSNL, 2013 (n = 48)

Borehole Depth and Location Most of the boreholes are in the depth range of 20 m to 160 m and at an elevation of 901 m - 1100 m. Although there was no overall trend of deeper boreholes at lower elevations (Figure 7), all of the deepest boreholes are found in the plains (Nr. 100, + 101, see enlargement in Figure 5) and to the west in Sossusvlei (Nr. 343) while boreholes in the eastern Mountains tended to have shallower boreholes. Only three boreholes have a depth of more than 200 m, all of them can be found at the NamibRand Nature Reserve on the plains.

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Borehole depth in relation to altitude 300

250

200 y = -0.025x + 121.58 R² = 0.00471 150

100 Borehole depth Borehole Boreholes 50

0 0 200 400 600 800 1000 1200 1400 Altitude (m) Figure 7: Relationship between elevation and known borehole depth in the GSNL (n = 49)

Three respondents reported problems with water availability. One borehole that dried up was recorded in 1995 and another one at an unknown date. The farm Wêreldend records dropping of 6 m in the groundwater level during the past years.

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Figure 5: Recorded boreholes with SDP ID and depth related to the elevation in the northern part of the GSNL, 2013

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Figure 6: Recorded boreholes with SDP ID and depth related in the elevation of the southern GSNL, 2013

3.2.2 Boreholes and Location to Rivers None of the observed boreholes seem to be obtaining water from alluvial aquifers. Many of the boreholes (24) are found more than 2.5 km away from known river channels with only 21 out of the 58 boreholes found less than 500 m to known river channels. 23

Table 3: Number of recorded boreholes in different catchment areas in the GSNL and their distance from rivers

Near Medium Far Catchment Total (0 - 500 m) (500 - 2500 m) (+2500 m)

Tsondab 1 3 3 7 Tsauchab 5 1 2 8 Tsaris 7 6 9 22 Fish 2 2 0 4 Outside known 6 1 10 17 catchments Total 21 13 24 58

Figure 8: Major catchment areas and recorded boreholes in the GSNL, 2013 24

3.2.3 Boreholes and Energy Sources for Pumping Most establishments in the Greater Sossusvlei Namib Landscape mainly make use of solar driven water pumps for water abstraction. The 24 boreholes running on solar energy are almost double the number of boreholes using diesel or windmills. The latter both form the second largest energy source. Although several interviewees expressed doubts about the capacity for solar powered pumps to obtain deep water, solar-diesel hybrid pumps were used on the deepest observed boreholes.

Energy sources for pumping 25

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5 Number of boreholes of boreholes Number 0 Solar Diesel Windmill Electricity Unknown Solar hybrid Energy source Figure 9: Different types of energy sources used to pump water in the GSNL, 2013, n = 58. It is worth noting that most establishments make use more than one energy source

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Figure 10: Recorded boreholes with SDP ID and energy sources in the northern GSNL, 2013

Figure 11: Boreholes with SDP ID and energy sources in the southern GSNL, 2013

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300 250 200 150 100 50 0

Average depth of boreholes (m) depth of boreholes Average Solar hybrid Diesel Solar Electricity Windmill Energy source

Figure 12: Average depth of boreholes using various energy sources to derive water in the GSNL, 2013, n = 46

3.2.4 Water Usage and Sanitation Because both tourists and staff must use water for personal use but staff members must also perform activities like maintenance, cleaning, laundry, and cooking; staff use water for more purposes than do individual tourists (Table 4).

Table 4: Possible water usage for both the tourists and staff members at a tourist establishment

Staff Member Tourist

Drinking Drinking

Bathing Bathing

Toilet Toilet

Swimming Swimming

Cooking Jacuzzi

Laundry

Gardening

Cleaning

Filling Up Game Waterholes

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16 14 12 10 8 6 Frequency Frequency 4 2 0 single flush only dual+single dry+single dry+dual dual flush only Toilet systems

Figure 13: Different toilet systems used in various establishments in GSNL

Most establishments do not invest in water saving infrastructure measures. Most interviewed establishments make use of only single flush toilet systems (Figure 13) and only four out of 22 establishments use water saving showerheads (Table 5).

Table 5: Frequency of establishments using different types of showers in the GSNL, 2013

Types of showers Number of Establishments

Regular flow only 18 Low flow only 1 Regular and Low flow 1 Bucket 1 Bucket and Regular flow 1

3.2.5 Water Quality and Testing Water tests were conducted for 19 establishments (see Appendix 7) and all samples indicated drinking water quality for the parameters tested. However, five sites did have relatively high levels of nitrate (>20 ppm) although this still falls well within 50 ppm allowed by Namibian drinking water standards. 28

3.3 Wastewater in the GSNL

3.3.1 Wastewater Sources in the GSNL Every establishment visited in the GSNL has toilets, showers and kitchens that produce wastewater. In addition to that, some establishments generate wastewater from laundries, swimming pools or Jacuzzi backwash, car washing or from wine production (Figure 14). Seven establishments separated their grey water, especially from the showers, from the general wastewater for directly watering trees. None had separate infrastructure for black and grey wastewater.

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5 Number of establishments Number 0 Kitchen & Shower & Laundry Swimming Car wash Jacuzzi Winery Cleaning Toilet pool Wastewater sources

Figure 14: The number of establishments that generate identified types of wastewater in the GSNL, 2013 29

3.3.2 Wastewater Systems used for Handling Wastewater in the GSNL Currently the most widely used WWS in the GSNL is comprised of simple septic tanks linked to French drains. This combination is mainly used by small establishments. Some of the large establishments have an additional component such as a reed beds, biological WWS and evaporation ponds to the septic tank-French drain system.

11 Legend 10 Bio-WWS- Biological WWS 9 CP- Covered pit EP- Evaporation pond Large 8 FD- French drain Medium 7 MCGWR- Mesh covered grey water reservoir Small 6 RB- Reed bed 5 SF- Sand filter ST- Septic tank 4 3

Number of establishments Number 2 1 0

Type of WWS

Figure 15: The number & size of establishments making use of the different WWS at the 21 establishments visited in GSNL, 2013

3.3.3 The Effectiveness of Wastewater Systems used by the Establishments Most of the establishments visited experience blockages and overflows in their WWS. A few of the establishments have more advanced WWS that are more effective (Table 6). 30

Table 6: The effectiveness of WWS at the different establishments in the GSNL, 2013

Establishment & size Type of WWS WWS Effectiveness Small Medium Large

Six experience blockages ST & FD 8 1 1 and overflows.

Both are public ST - 1 1 establishments and have blockages and overflows

1 - experiences blockages FD - 1 1 and overflows

Blockages; saturation of surrounding soils at ST, FD & RB - - 1 French drains at one facility

ST, FD & Bio-WWS - - 1 Effective

ST, Bio- WWS, - - 1 Effective MCGWR & SF ST, FD & EP - - 1 Effective

ST & RB - 1 - Blockages and overflows

ST & CP 1 - - Blockages and overflows

ST, FD & CP 1 - - Blockages and overflows

Most establishments only check their water and wastewater systems when there are problems and only six check them with any regular frequency (Table 7). All establishments that check their systems at least once every six months, however, report no leaks, overflows, or blockages suggesting that regular maintenance has a real impact on reducing problems. Most frequently requiring attention are the wastewater pipes that frequently clog or break. Yet another element of the wastewater system that requires careful attention is the positioning of the French drains. The geology of some areas may not allow for adequate soak- away of wastewater, which may then accumulate on the surface. In this case, odours from the wastewater negatively affect the atmosphere of the lodge facilities. At least three 31 establishments do not seem to pay adequate attention to their wastewater infrastructure, as they do with the renovations to improve the outlook of their establishments to attract tourists.

Table 7: Maintenance frequency of WWS at the different establishments in the GSNL, 2013

Maintenance frequency of WWS Number of establishments

Only on Ad hoc 12 Daily 2 Weekly 2 Yearly 1 Twice a year 1 Not necessary yet since renovations 3

3.3.4 Wastewater Infrastructure Components used in the GSNL As shown in Table 8 below, the most commonly used components of WWS in the study area are septic tanks and French drains. The least commonly used WWS are reed beds, biological WWS, covered pits, an evaporation pond, a mesh covered grey water reservoir and a sand filter.

Table 8: Number of establishments using various individual WWS components in the GSNL, 2013

WWS components in GSNL Number of establishments

Septic tank (ST) 19 French drain (FD) 15 Reed bed (RB) 2 Biological WWTS (Bio-WWTS) 2 Covered pit (CP) 2 Evaporation pond (EP) 1 Mesh covered grey water reservoir (MCGWR) 1 Sand filter (SF) 1

32

A B

A: Septic tank (Sossus Lodge) B: Septic tank & French drain (Wolwedans)

C D

C: Reed bed (Namib Naukluft Lodge) D : Evaporation F ponds (Sossusvlei Lodge)

E F

E: Covered pit (Tok Tokkie) F: Mesh-covered grey water reservoir (Namib Desert Lodge)

33

G H

G: Sand filter (encircled) (Namib Desert H: Biological WWS (Namib Desert Lodge) Lodge)

3.3.5 Establishments with Kitchen Fat Traps Fat in wastewater systems can cause problems such as clogging, killing of bacteria in septic tanks and reduction of potential for water reuse. More than half of the establishments visited have kitchen fat traps, and most of these were at medium and large establishments (Table 8). Only a few of the small establishments have kitchen fat traps.

12 11 10 9 8 7 6 Large 5 4 Medium 3 Small

Number of establishments Number 2 1 0 Yes No Unknown Kitchen fat trap

Figure 16: The number and size of establishments that have kitchen fat traps

34

I

Image I: A functional kitchen fat trap at Namib Naukluft Lodge

Table 8: The cleaning frequency and disposal of kitchen fat trap waste by the different establishments Disposal of fat trap Establishment Size Cleaning frequency waste Agama River Small Ad hoc Dump site Lodge Desert Homestead Medium Daily Unknown and Horse Trails Keerweder Small Unknown Unknown Le Mirage Desert Large Weekly Unknown Lodge NaDEET Small Weekly Onto tree Namib Desert Large Twice a week Unknown Lodge Namib Naukluft Large Weekly Unknown Lodge Sossus Dune Medium Weekly Unknown Lodge Sossusvlei Lodge Large Weekly Unknown Sossusvlei Desert Medium Every 2-3 days Compost Lodge Tok Tokkie Medium Ad hoc Incinerate

3.3.6 Change of Wastewater systems on Establishments since Operation of current Establishment According to the interviewees, most of the establishments have been using the same wastewater systems (WWS) that were in use by previous owners. In many cases these systems 35 were expanded to accommodate the new establishments’ developments. Four privately owned establishments, mainly large tourism establishments, have added new components to the existing WWS. Only establishment Wolwedans has extensively changed to a new WWS (Table 9).

Table 9: Change from a previous WWS or addition of components to existing WWS in the GSNL, 2013

Previous Size of Establishment Current WWS Reasons for change WWS establishment Septic tank Replaced septic tank Small • To increase & French with 2 chambered capacity of WWS. Aandster drain plastic septic tank • To increase efficiency. Septic tank Added Bio filtering Large • To obtain higher Namib Desert WWS, mesh covered EcoAwards rating. Lodge grey water reservoir and a sand filter Septic tank Added reed bed to Large • To remove toxins & French WWS from WW Namib Naukluft drain • To increase Lodge capacity for WW disposal Septic tank Added evaporation Large • Added the cutter to & French ponds and a solid reduce blockages drain waste cutter before & overflows. septic tank. • Advised by MET Sossusvlei official to use Lodge evaporation ponds which are overseen by DWAF regulations. Septic tank Replaced reed bed Large • High labour cost of & reed bed with French drain Wolwedans reed bed and Biological WWS maintenance.

36

Wastewater infrastructure was usually said to be expensive by interviewees who also pointed out that this would have to be brought from Windhoek or other distant places. Generally, most interviewees are not planning on changing their current WWS; however Desert Homestead and Horse Trails, Le Mirage Desert Lodge, Sesriem Campsite, Sossus Dune Lodge and Sossusvlei Lodge establishments expressed intentions of changing to modern WWS to increase the reuse capabilities of their WW.

3.3.7 Final Disposal of Wastewater and its Accessibility to Animals and Humans Wastewater is mainly discharged first into septic tanks and then finally disposed into French drains where it soaks into the ground. Grey water is sometimes reused for watering plants especially by the small establishments (Figure 17 and Table 10). Discharge of wastewater into the environment is being practised by Sesriem Camp and Wolwedans, both large tourism establishments (Image J). Two establishments dispose their WW either into fenced-off reed beds and evaporation ponds respectively, as shown by images K and L below.

J

J: Unfenced disposal site of WW after going through septic tanks only into the environment (free run) at Namibia Wildlife Resorts camp site; Note wide distribution of the animal droppings.

K L

TableK: Fe 1nced0: Different reed bed WW at final Namib disposal Naukluft methods in the GSNL,L: Fenced 2013 evaporation ponds at Lodge Sossusvlei Lodge

37

Wastewater disposal method No. of Establishments

French Drain 14 Watering plants 10 Free run 2 Covered pits 2 Reed bed 1 Evaporation ponds 1 Septic tank 1

Final WW disposal sites that could be accessible to people and/or animals are reed beds, evaporation ponds and free run. Establishments that practise free run do not have their final WW disposal sites fenced off, whereas those with reed beds and evaporation ponds are fenced-off. DWAF stipulates that wastewater handling systems should be more than 500-800 m away from freshwater sources. Anything out of this range is considered as safe distance for possible contamination. Generally, most of the wastewater handling systems are at a safe distance from freshwater sources. Establishments Agama River Lodge and Nubib have all their wastewater systems closer than the recommended distance to their freshwater sources (Table 11). 38

Table 11: The proximity of wastewater handling systems to freshwater sources at establishments in the GSNL, 2013 Name Proximity of wastewater handling site to freshwater sources

Aandster Safe distance Desert Homestead Safe distance and Horse Trails Namib Naukluft Safe distance Lodge Sossus Dune Safe distance Lodge Sossusvlei Desert Safe distance Lodge Wêreldend Safe distance Agama River All boreholes close to wastewater sites Lodge Nubib All boreholes and river channel close to septic tank Keerweder Most freshwater sources close to wastewater sites Sesriem Camp Most boreholes close to plastic septic tank Wolwedans Two boreholes close to septic tanks Drifters Borehole close to plastic septic tank Le Mirage Desert Borehole close to plastic septic tanks Lodge NaDEET Borehole close to wastewater systems Tok Tokkie Borehole close to wastewater systems Zais Borehole close to septic tanks

Actual distances can be found in Appendix 9

39

3.4 Solid Waste Management in the GSNL Solid waste, in addition to wastewater, may cause water pollution and may affect the aesthetics of tourism in the arid GSNL area. A variety of approaches to solid waste management were observed in the area, both currently established and as hold-overs from previous land use practices in the area.

3.4.1 Source of Solid Waste Sources of materials constituting solid waste (i.e. groceries) are varied and include materials from tourists and support staff. Establishments in the GSNL purchase their goods by either driving into towns or via delivery from companies such as Meatco, Hartlief, African market, and Namibian breweries (Table 12). Smaller establishments are far more varied in their sources and get most of their supplies from various towns. Medium sized and large lodges however have one consistent source of supply and most of them buy directly in Windhoek or through delivery companies (Table 12). 40

Table 12: Source of supply for the establishment within the GSNL, 2013. (WHK = Windhoek, MAR = Mariental, MAL = Maltahohe, SWK = Swakopmund, W/B = Walvis Bay) Establishments Beta WHK Delivery MAR MAL Solitaire SWK W/B Total farm Small Neuras  1

Aandster   2 NamibRand Family   2 Hideout Keerweder   2

Wêreldend    3

Nubib   2

Agama River Lodge  1

Zais      5

Total 5 3 3 3 1 1 1 1 18 Medium NaDEET  1

Tok Tokkie  1

Desert Homestead  1

Drifters  1

Sossus Dune Lodge  1

Sossusvlei Desert Lodge  1

Total 2 3 1 6 Large Namib Naukluft Lodge  1

Wolwedans  1

Le Mirage  1

Sossusvlei Lodge  1

Namib Desert Lodge  1

Sesriem Camp  1

A Little Sossus Lodge  1

Total 6 1 7

Sum 13 7 4 3 1 1 1 1 31 41

3.4.2 Types of Solid Waste generated In addition to the currently generated solid waste, old materials are scattered across the GSNL. All this solid waste can be categorized into different types namely: domestic waste, process waste, industrial waste, hazardous waste, and agricultural waste. Domestic waste (i.e. paper, plastic, box/cartons, organic, glass, tin and food cans) is the most common type of solid waste generated by the establishments within the GSNL. Several establishments generated industrial waste in the form of car batteries, tyres, and old building materials but we were unable to reliably quantify this since many respondents weren’t involved in the processes that generate this waste.

3.4.4 Onsite Handling of Solid Waste in the GSNL 3.4.4.1 Sorting (Handling of Recyclable Waste) Waste management practices differ between private and public establishments, small and big establishments and between group and independent establishments. Fifteen of the twenty one establishments interviewed in the GSNL sort their solid waste. To make the practice feasible, labelled dustbins were often placed in locations such as kitchens, bars, dining areas, braai areas, campsites, and shops where most solid waste is generated. Sesriem Camp, Sossus Dune Lodge and Zais burn their sorted waste. Burning is the most common disposal method for solid waste. Unfortunately, several establishments may use labelled bins to separate their waste at the first step of the waste collection process only to combine them after separation. We were unable to tell the exact magnitude of this.

3.4.4.2 Recycling/Reuse of Organic Waste Organic waste, also known as food left-overs, is generated in all 21 establishments. Of these, two private establishments re-use their organic waste as animal feed and six recycle it in the form of compost (Table 13). 42

Table 13: Uses of organic waste at establishments in the GSNL, 2013

Individual/part of a Size of establishments group Number of establishments Part of a Small Medium Large Individual group

Composting 6 2 3 1 1 5

Animal feed 2 1 0 1 1 1

Total 8 8 8

The establishments that re-use and recycle organic waste varies in size (Table 13) and only five of all these establishments belong to a group such as NamibRand Nature Reserve, Drifters, and & Beyond. Moreover, all establishments that have gardens compost and both that have domestic animals (such as chickens and pigs) feed organic waste to the animals.

3.4.4.3 Individual Dump Sites for Establishments in the GSNL Of the 21 establishments that were interviewed, twelve establishments have dumpsites onsite. These dump sites are mostly used for burnable and non-recyclables and the rest of the waste is either re-used or taken to Windhoek for recycling. However, several dumpsites included recyclables. These establishments have labelled bins for different types of solid waste that are commonly generated in a typical residential establishment but it is all mixed in the end and taken to the dumpsites.

Table 14: Individual onsite dump sites for private and public establishments in the GSNL, 2013

Ownership

Private Public Total Number of establishments 9 0 9 without onsite dump site Establishments with fenced 6 0 6 dump sites Establishments with 3 3 6 unfenced dump sites 43

Total 18 3 21

A total of six fenced dumpsites (Table 14) belong to privately owned establishments. Three public establishments (Sesriem Camp, Sossus Dune Lodge and Zais) have unfenced dumpsites. However, none of the fenced dumpsites had the warning “Danger” sign as stipulated in the conditions for the licence for dumpsites (EMA, 2007).

3.4.5 Off­Site Handling of Solid Waste in the GSNL Although 13 establishments purchase goods in Windhoek, only ten of these establishments take their waste back to recycling plants in Windhoek (Figure 20). Besides the Windhoek recycling plant, establishment A Little Sossus Lodge and Campsite, Desert Homestead and Horse Trails, and Drifters sort and separate their waste onsite and disposed of it at the Maltahohe dump site that does however not practice recycling.

Figure 19: Maltahohe dumpsite, SDP 17 (2014)

It was observed that the Maltahohe dumpsite is actually a big unfenced, unsupervised dumping area that allows access for everyone (Figure 19). This area is not far from the residential area in the northern part of Maltahohe and the lightweight waste can be seen in the vicinity of the settlement. There are heaps of all types of solid waste dumped at this so-called dumpsite. Amongst the visible waste were broken bottles, paper, plastic, construction waste, tins, and cans.

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10 9 8 7 6 5 Independent 4 Group 3 2 1 0 Windhoek recycling plant Maltahohe dumpsite Unknown

Figure 20: Off-site facilities where 14 of the 21 establishments in the GSNL take their recyclable solid waste.

As shown in Figure 20, establishments that are part of a group collect their waste together and take it to recycling plants in Windhoek, while most of the independent establishments take their recyclables to the Maltahohe dump site.

3.4.7 Group Collection Centre Schenk, (at DRFN Windhoek, 2013), recommended a group collection centre as a tool of handling solid waste in the Great Sossusvlei Namib Landscape. The idea of a group collection centre was integrated into the research conducted, and the stakeholders were asked to give their views on the idea of the group collection centre. Findings revealed that only nine of the 21 establishments interviewed are in support of the group collection centre idea while twelve establishments were against it.

Establishments that support the idea of a group collection centre all have different ideas of the suitable location for the centre. Establishment NaDEET, Sossusvlei Desert Lodge and Zais suggested Sesriem, while Agama River Lodge, Drifters, Le Mirage Desert Lodge Namib Naukluft Lodge, NamibRand Family Hideout and Tok Tokkie suggested Solitaire; Wolwedans, Toekoms, Sossusvlei, T-Junction near Le Mirage Lodge and any best location respectively.

45

Take their waste to Windhoek Give their waste Hard to manage a to guests to take when they go for shopping, group collection along (Nubib) centre (Sossus laundry, and staff Dune Lodge) shifts (Sossusvlei Lodge, Wêreldend, & Wolwedans)

Own dumpsites, (A Little Sossus Lodge and Part of Campsite, NamibRand Agama River Nature Reserve Lodge, Desert that collects at Homestead and Wolwedans Horse Trails, & (Aandster & Neuras) Keerweder) Figure 21: Reasons why twelve of the 21 interviewed establishments did not support the idea of a group collection centre for the GSNL occupants, 2013

Among the twelve establishments that declined the idea of a group collection centre, four were those that have individual dump sites. In addition to these, three were establishments that go to Windhoek for shopping, other services such as laundry and during staff shifts. Two of the establishments that belong to the NamibRand Nature Reserve collect their waste together at Wolwedans Lodge (Figure 21) which brings the solid waste to the recycling plant in Windhoek.

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3.5 Legal Aspects During the data collection process with owners and managers of 21 establishments in the GSNL, questions were asked concerning their awareness of and/or possession of legal instruments related to their operations connected to water and waste.

Table 16: Awareness and possession of permits/licences relating to water sources, waste water and/or solid waste management in the GSNL, 2013

Possession of Legal Aware of Legal Instruments Instruments (Permits/Licences, (Permits/Licences, Clearance Clearance Certificates) Certificates) Private Public Private Public

Yes 10 2 3 1

No 7 0 6 0

Unknown 1 1 9 2

Grand Total 21 21

Recent research amongst the GSNL stakeholders reveals a normative gap of differences between the awareness about permits/licences on the one hand and, on the other, the factual possession of those permits and/or licences. Out of the 21 establishments interviewed, twelve are aware of some legal instruments required of them, however only four possessed these instruments, be it in the form of a permit, licence or clearance certificate. In contrast nine establishments are not aware of the permits/licences and a vast majority, tallying 17 establishments either did not possess any permit/licence or refused to reveal such possession. Although relatively only a few of the stakeholders in the landscape possess permits/licences and/or other legal instruments, in terms of the information gathered from the interviews, as can be seen from Table 16, a large number of the establishments are conscious of the permits/licences and/or legal instruments required of them, even though they do not possess them. In this regard there seems to be a conflicting position, which raises multifaceted questions for scrutiny. Equally, the status of legal compliance is not clearly assessable, as the position of eleven establishments with regards to their possession of permits or licences is 47 unknown. There are divergent reasons for this situation, but what is clear is that this state of affairs may engulf some legal and to a lesser extent socio-economic implications. Although not a major disparity, the private-state owned dichotomy reveals that the state owned establishments are less likely to comply with the legal obligations imposed on them. In the GSNL more specifically, only one out of the four establishments which possessed legal instruments i.e. permits, licences, clearance certificate, was a state owned enterprise; whilst the remaining three establishments were privately owned. One private establishment showed that they do not possess or are even aware of any governmental permit that is needed. Overall, as can be seen from Table 16 above, legal compliance remains a challenge in the GSNL.

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4 Discussions

4.1 Water Sources

4.1.1 Introduction Aridity is a permanent natural climate condition of low rainfall and high evaporation rates (Pallett, 1997). In arid and semi-arid regions groundwater is often the only natural source of water supply. On average the Greater Sossusvlei Namib Landscape receives about 100 mm of rain annually. Generally in Namibia 83 % of the rain water evaporates, 14 % infiltrates into the ground for natural vegetation, 2 % of the rainfall becomes runoff water and only 1 % of the rainfall eventually goes into the groundwater (Pallett, 1997). Recharge of the groundwater in the Landscape is unknown, however due to the low and highly unpredictable rainfall and high evaporation rates, if there is any recharge it would be very little to recharge the groundwater. For this reason one would assume that the aquifers in the landscape are recharged very slowly or by water originating from elsewhere.

4.1.2 Boreholes and Depth The geology of an area plays a huge role in the distribution and nature of aquifers. The lithology with its physical structure, which includes mineral composition, grain size and grain packaging of the sediments or rock, determines the groundwater systems (Swart, December 2013, Pers. Comm.). Structural features such as fractures, folds and faults also have an influence on the recharge of groundwater (Freeze and Cherry, 1979). The geology of the GSNL consists of granitic rock deposited in the Cretaceous period, Damara sequence (mainly sediments) that overlies the granitic rocks, followed by the Klinghardt intrusions where volcanic rocks intruded the land surface and the recent unconsolidated Kalahari group-pan sediment (sandstone, shale, calcrete, limestone, gravel and some granitic rocks) (Geological Survey of Namibia, 2013). The geological history of the Namib Desert could give an idea of how the groundwater system was formed. Although the age of groundwater in the GSNL is not known, it takes geological time to create substantial amounts of groundwater enough to withstand abstraction for decades without going dry. One could explain this situation that perhaps that aquifer(s) in the landscape were formed about the same time, however due to the continuous movement of the earths crust, the aquifer(s) got split into smaller aquifers. Because the bedrock have been uplifted in some 49 parts during shifting, establishments that are located in areas such as the mountain valley are likely to have their water table much shallower than those at the edge of the mountain range. Furthermore run-off water from the mountains (catchment) collects in the valleys, which means more recharge for aquifers in the valley, that brings up the water table and therefore shallow borehole depth, as might be the case of boreholes on establishment Aandster where borehole depths range between 61-80 m. However run-off water at the edge of the mountain, whereby the mountain is bordered by gravel (25-40 %), sand (25-50 %) and sandstone (5-30 %) with moderate porosity (Davis, 1969 cited in Freeze and Cherry (1979), Geological survey of Namibia, retrieved 2013), water would infiltrate deeper and therefore the aquifer would be deeper. This could be the case for the three deepest boreholes in the landscape found on farm Keerweder. Fractures of the Great Escarpment bordered by the Naukluft Mountain consist of karstified dolomites and limestone (Christelis and Struckmeier, 2011). Fractures of this kind are associated with confined aquifers which are characterized by pressurized water. This is caused by expanding and contracting of cracks (temperature variation) as well as the change of atmospheric pressure, which therefore allows water to come up to the surface (Freeze and Cherry, 1979). Perhaps because of this, Neuras has shallow borehole depths of 40-45 m and is the only place surveyed that has springs. Springs are formed when a fracture is at lower elevation to the water table. Four out of six springs at Neuras have dried up, this could be that the four springs are at higher elevation compared to the other two and maybe an increasing abstraction of water has caused a drop in the water table/water pressure in the speculated confined aquifer. The two running springs are located right next to the river channel (lower elevation), which could mean that they are still much lower than the water table. Similarly, elevation and increasing abstraction of water could have caused drying of a borehole at Wêreldend.

4.1.3 Source of Energy Most boreholes with a depth of 100-150 m are run on diesel powered water pumps (Figure 9). This is because most of these establishments’ owners are under the impression that the water abstraction from deeper boreholes can not be done on solar powered water pumps. This is not entirely true, two of the deepest boreholes in the landscape found on Keerweder are run on solar hybrid water pumps, perhaps it is the issue of investment (cost) or potential theft of solar panels that is the problem. 50

Figure 22: Comparison of the financial costs between solar pumps and diesel pump over a long term (DRFN, 2008)

According to Figure 22, the purchase cost of solar pumps is higher when compared to the diesel pumps however considering replacement, maintenance and operation costs (fuel), diesel pumps are more expensive to have in the long term. Annual operation, maintenance and replacement (fixing) price for diesel pumps has drastically increased from a about N$50 000 to N$ 600 000 over 20 years which is one of the reasons that makes diesel pumps expensive. The cost of solar pumps has only gone from N$100 000 to N$150 000 over the same period, therefore making them much cheaper as mentioned earlier. Other establishment owners mentioned that they have tried using solar powered pumps but later their solar panels were stolen and therefore they resorted back to using diesel pumps, which is easier to manage in term of safety. It is important to note at the time of study (2008) diesel was at the cost of about N$ 8.00/L compared to now (Jan 2014) at a cost of N$ 11.42/L. 51

Nonetheless most of the boreholes in the GSNL are using solar pumps according to the findings of the survey (Figure 9). Only a few of establishments have diesel or windmills. All the windmills that were recorded are found on establishments that are not used for tourist accommodation such as Aandster, Agama River Lodge, Neuras and Wêreldend. Perhaps this is because the water demand is not as severe and they could rely on prevailing winds. Most tourist accommodation establishments have solar pumps, this could possibly be an indication that advocacy for sustainable tourism is slowly but surely being incorporated into the tourism industry. This means making use of the resources for tourism purposes, without compromising the future generation from using the same resource to meet their needs. Eco- Awards and Global Ecosphere Retreats are some of the organizations supporting and advocating sustainable tourism.

4.1.4 Water Use Due to advocacy, tourists seem to be evolving from just being interested in natural landscape beauty and are now more conscious about the environment, therefore they tend to go to establishments that are more environmentally friendly. According to a study on water demand in tourist establishments in Namibia, tourist use about 20 % of the water in an establishment (personal use) (Schachtschneider, 2000), This means that the 80 % of the water is in the hands of the staff members, using it both for personal requirements and service provision activities to the tourists on the establishment. According to a workshop that was held between the survey team and several stakeholders, it has been noted that perhaps the 20:80 percentage ratio has changed over the years, however most believed that staff members still use most of the water. Perchance, it is the inadequate water demand management implementation that has led to the high water usage amongst the staff members. Other explanations could be the lack and insufficient training on water saving to the staff, lack and poor understand of the importance of saving water, lack of incentives, and inadequate continuous reminding to save water as well as the type of infrastructure in the lodges and staff houses. The management of some tourist establishments is experiencing tremendous difficulty in having and influencing and reducing the amount of water in their guests use. This is partly because they feel that their guests have paid so much money and therefore they are entitled to use as much water as they want. Maybe the only way to make people understand the scarcity 52 of water in an arid area is to make them pay for the amount of water that they use (Schachtschneider and Nashipili, 2000) which requires installation of water meters. Though it is not new news that the Namib Desert is an arid region, generally most people do not understand to how this is related to the groundwater, which appears to be in abundance to most of the establishment owners. Thus it is important that staff members are educated on the environmental aspect of the areas they are working in, on water saving as well as maintenance of infrastructure related to water systems. It is also very important that the benefits of such actions are pointed out. When the amount of water abstracted is less or equal to the amount of water that recharges the aquifer, the water table remains the same (Freeze and Cherry, 1979), this means that no further costs are spent to deepen the borehole. It is also means the borehole will not dry up and therefore no extra cost to drill a new borehole. So not only will the owners of the establishment have the benefit of using the same borehole for many years to come, but also save some money that could be spent on other expenses. All this is achieved by making water demand management as a priority. Improving infrastructure throughout the whole establishment could also have a huge impact in reducing water usage. Staff members stay at establishments all year round, unlike the tourist that spends an average of 1.5 nights (MET, 2010) in an establishment. This means that installing dual/low flush toilets and low flow/ bucket showers in tourist rooms will only save a small percentage of the 20 %. However, if the same is done for the staff members that use about 80 % of the water, more water would be saved.

4.1.5 Water Quality Generally, groundwater is of excellent to good quality according to the estimates from water tests done and the view of the establishment occupants. All of the parameters that were tested fell within acceptable concentration ranges (Appendix 10 and 11). This could be that possible sources of contamination are not next to the borehole or that contaminants have not infiltrated and reached the groundwater. The concentration of nitrate in the various boreholes in the landscape varied; this could be influenced by the direction of groundwater flow, the slope and the rate of water flow between the pores. However, with the increasing tourist pressure, pollutants could become a threat. If water demand management is not carried out effectively and the amount of water required keeps increasing, the amount of wastewater will also increase. This will then require lodge 53 owners to invest further in their waste water system. Otherwise failure of these systems would lead to huge volumes of wastewater overflow. If these volumes are large enough, knowing the geology of the landscape (moderate porosity), contamination of groundwater could be a possibility. Similarly this can apply to the infiltration of run-off water from the dumpsites. Contamination of groundwater would mean that tourist establishments would have to transport their water from other places e.g. Windhoek, without calculations one can already image that it would be expensive and impossible for most establishments. Therefore it is important that full water quality analysis is done at a laboratory e.g. NamWater laboratory at least at a three-year interval, to allow the monitoring of the chemical composition in the landscape. This will allow relevant stakeholders to address contamination problems early on.

4.1.6 Water Sources Recommendations Situation Analysis Recommendations Groundwater is the main source of water • Due to dependency on groundwater, in the Greater Sossusvlei Namib individual establishments need to consider Landscape (GSNL), though a few springs water monitoring and keeping of long term occur as well. data, this includes: installation of water meters, measuring of groundwater table and doing regular recording of measurements, at least every month. • A group effort to store/collect rainwater and groundwater level data comparable with the rainfall data collection in the NRNR would help to monitor rainfall and groundwater level and increase reliable data of the area. Additionally many lodge owners • The GSNL committee could emphasise and mentioned that they have rich aquifers request a complete study on aquifers to therefore they can draw as much water as determine how many are in the area, the rate they want. There is very little knowledge of recharge and the rock type aquifer(s) about the aquifer system in the GSNL. occur on. • A regular water quality testing at least once in three years will help to monitor changes 54

in the water quality. Lodges/farms use various sources of • Solar power driven water pumps are cheaper energy to abstract water from boreholes, to use on a long term basis compared to such as solar, diesel, windmill and diesel power driven water pumps, electricity. considering initial investment, maintenance, The deepest boreholes in the GSNL are replacements and operational costs (price of driven by solar and solar hybrid systems diesel). Stakeholders are suggested to install and use solar pumps where applicable in the landscape. • A rethinking of security security for installed solar panels on establishments is needed to avoid theft. A problem of porcupines chewing pipes • Pipes can be buried with stones or under soil was experienced at some lodges/farms, to avoid this problem; in addition exposed this is mainly because they are exposed pipes can reduce the lifespan of plastic pipes and these animals are attracted by small by up to seven years (Schachtschneider and leakages in pipes. Nashipili, 2000). Most establishments use enclosed plastic • The use of plastic tanks is encouraged since tanks and open reservoirs to store their it prevents algae bloom and reduces water. evaporation. • The closing of open reservoirs is preferable to avoid water loss through transpiration, to prevent small animals falling in and drowning, as well as for keeping the water clean. A few establishments had water meters • To improve the monitoring of water use or that were mainly at boreholes to measure loss through leakages the installation of how much they extract. water meters at extraction points, distribution points and before the waste water system is recommended. • Water meters can be a helpful tool to raise awareness of water use and to figure out where most of the water is been used (or 55

lost). Water is used for toilets, showers, • For new lodges, dual flush toilets are laundry, pool, kitchen and a single flush recommended because they use different toilet is used by most establishments. water levels for flushing and can reduce the amount water used by approx. 3 litres per flush. • Judiciously placing a filled water bottle or a clean rock in the cistern can also reduce the amount of water used for each flush. • Bucket showers are the most efficient showers for water saving. Guests at Etendeka and Spitzkoppe camps indicate that tourists feel adventurous using them. • Therefore, the installation of a few additional bucket showers at the lodge or at the campsites is suggested to let tourists choose their preferred method of showering in the desert. Pools are a constant point of water • For lodges that do not receive frequent evaporation in the desert. visitors or where possible, we recommend to cover pools when there are no visitors around to reduce the evaporation of water. Two establishments collect rainwater and • Consider extending the central collection of use it for gardening. rainfall data which is already done by the Several establishments monitor the NRNR to the complete GSNL under the rainfall but do not store those records for supervision of the committee and future reference. additionally the central storing of groundwater levels as well.

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4.2 Wastewater

4.2.1 Introduction The current wastewater situation in the GSNL indicates that all establishments interviewed have a way of handling the wastewater that they generate and these systems have varying levels of effectiveness. This depends on the wastewater systems that they have in place and how they prioritise wastewater handling in their financial budgeting and planning. Some establishments are still using inherited wastewater systems from previous land owners, whilst others have modified and/or expanded these and some have completely changed over to more advanced wastewater treatment systems. However, with each wastewater system there are challenges that need to be addressed with the prospect of an increase in the number of tourists visiting the recently inscribed WHS, the Namib Sand Sea.

4.2.2 Wastewater Sources Most of the wastewater generated at the establishments visited is of domestic origin. With the black water coming from the toilets and kitchen (depending on the cleaning detergents used) and the grey water coming from the showers, laundry, pool/ Jacuzzi backwash, car wash and in one case the winery. The amount of wastewater produced at an establishment directly depends on the amount of freshwater used (Pers. Comm., Dr Gunter Lempert at DRFN Windhoek, Nov., 2013). This has an implication on the water demand management that each establishment has in place. Most interviewees mentioned that the effort to reduce the amount of wastewater produced by regulating the amount of freshwater used has been affected by the hardness of the water in the area. For example some establishments had invested in water- saving shower heads that easily get clogged with the high calcium carbonate (calc) content in the water and this requires high maintenance.

4.2.3 Wastewater Systems and Components As shown in Figure 14 & Table 6, currently most of the small establishments make use of septic tanks linked to French drains, which could be because they can generally handle the amount of wastewater generated by the few people on the establishment. However, the anaerobic condition in septic tanks does not allow the ammonia nitrogen to be converted to nitrate and nitrite, which makes the final effluent toxic to vegetation (DWAF, 2008) and can hence not be reused for watering plants. The semi-treated effluent is then disposed into a 57

French drain, from where it infiltrates into the ground (DWAF, 2008). In the French drain nitrifying bacteria convert the ammonia nitrogen into nitrites and then to nitrates which can then be used by plants to make proteins or it leaches into the ground (www.bcac.bc.ca, page accessed on 25 January 2014) On the other hand according to Table 9, some large establishments (e.g. Namib Naukluft Lodge, Sossusvlei Lodge, Wolwedans) which have a high capacity to host a large number of people have added components to the septic tank-French drain systems such as evaporation ponds that allow oxidation of effluent for the conversion of ammonia nitrogen. As another way to increase wastewater handling capacity Namib Naukluft Lodge has added a reed bed that acts as a natural bio filtering system to remove toxins from the final effluent. A cutter pump was added before the septic tank at Sossusvlei lodge which cuts the sewage flowing through the pump to prevent blockages caused by unsuitable objects (e.g. condoms, sanitary tampons and pads) by reducing their size as well as increasing the surface area of organic matter for digestion in the septic tank. Two large privately owned establishments (Namib Desert Lodge and Wolwedans) use more advanced wastewater bio filtering systems, which make use of bacteria that digest organic matter. The challenge faced with this system at Namib Desert Lodge however is that during the high season when there is a high influx of tourists and an increased water demand, the bacteria is not given enough time to carry out digestion, and this causes the final effluent to have a bad odour limiting its reuse capabilities (Pers. Comm., Mr Udo Kubli at Namib Desert Lodge, Dec., 2013). The quality of the final effluent provides more opportunities for reuse such as gardening and is safe for discharge into the environment to recharge groundwater (SAIEA, 2013). This could explain why Wolwedans discharges their relatively safe final effluent into the environment. Other ways to improve the quality of the final effluent is by having a double piping wastewater system, whereby the black water is separated from the grey water before being mixed into the septic tank (Pers. Comm., Dr Gunter Lempert at DRFN Windhoek, Nov., 2013). The other alternative is by simply having a pipe with the black water (from the toilet) discharge it directly into the septic tank. Then have another pipe dedicated to the grey water joining the one from the septic tank so that it is finally disposes the effluent into the French drain as illustrated by Ballam-Waterslot (PTY) LTD (www.ballamwaterslot.co.za, page accessed on the 25/01/2014). This will enable separation of black water and grey water to increase wastewater reuse capabilities. These are suggestions that the GSNL committee can further pursue. 58

The various wastewater system components used in the GSNL have advantages and disadvantages as shown in Table 16 below.

Table 16: The advantages and possible disadvantages of the various WWS components used in the GSNL, 2013 WWS Advantage(s) Disadvantage(s) components • Underground • Overflows • Separation of sewage into scum, • Bad odours sludge & effluent (DWAF, Vol., • Difficulty in locating them for Septic tanks 1, 2008). maintenance purposes if inspection pipe • Sewage decomposition (DWAF, is covered with sand (DWAF, Vol., 1, 2008). 2008). • Allows for grey water infiltration • Blockages & overflows (DWAF, Vol., 1, 2008). • Bad odours French drains • Possible groundwater contamination if close to freshwater source(s) (SAIEA, 2013). • Absorbs toxins from the pre- • Labour cost for maintenance every one Reed bed treated effluent. or two years • Looks “unnatural” in a desert area. • Uses commercially available • High residence time for complete bacteria (EM1) for organic effluent treatment (optimal 28 days). Biological matter digestion. • Cost of bacteria (EM1) WWTS • Better quality grey water for • Bad smell of final effluent if digestion reuse process is not completed. • Easy to construct • Less desirable method of WW disposal Covered pit as it may contaminate groundwater. • Allow for WW to evaporate • Labour cost for removal of sludge reducing contamination of (DWAF, Vol., 2, 2008). groundwater. • Labour cost for regular removal of Evaporation • Allow for oxidation of ammonia surrounding overgrown vegetation ponds nitrogen to nitrate and nitrite, (MAWF: permit). making final effluent less toxic • Potential habitat for waterborne disease to plants, if reused (DWAF, vectors Vol., 2, 2008). 59

Mesh • Storage of treated grey water for • Potential habitat for waterborne disease covered grey reuse vectors water reservoir Sand filter • Filters particulates through sand • Cost of filter replacement

With all these different wastewater systems, blockages and overflows were found to be the main issue contributing to their ineffectiveness. This could be attributed to the lack of regular check-ups, supervision and maintenance as most establishments only attend to their wastewater systems when they experience problems (Table 16). For some establishments the current wastewater systems are no longer capable of handling the increased amount of wastewater generated, hence there is need to re-evaluate the systems.

4.2.4 Final Disposal Most establishments use French drains as the final wastewater disposal sites of the effluent where it seeps into the ground (Figure 16 & Table 10). At some establishments the French drains are constructed in unsuitable areas that have underlying calcrete rock that leads to rapid saturation causing overflows. Nearly all of the French drains visited in the field were not fenced off, because normally wastewater is not supposed to accumulate on the surface. This challenge can be addressed by fencing off these sites in case of overflows to prevent accessibility to humans and/or animals, as it could be an environmental and health risk. At a publicly run Sossus Dune Lodge the septic tanks are not ideally located such that predominant winds (south-westerly) in the area blow the bad odours towards the buildings. This unpleasant smell has a negative impact on the reputation of the establishment and possibly tourism in the GSNL. The grey water produced at most small establishments is used for watering plants around the establishment (Image M); this is a good practice as it relieves pressure from the limited freshwater sources. One of the privately owned Wolwedans discharges their final wastewater into the environment after it has been treated by an advanced bio filtering wastewater system. This improves the quality of the final effluent making it less harmful to the environment. In contrast, the public Sesriem Camp directly discharges untreated effluent from the septic tanks into the environment (Image J); this is a bad practise as it is harmful to the environment and animals. Furthermore, these sites are not fenced off as evidenced from the animal droppings (Image J). This gives a negative image of the aesthetics of the GSNL environment. 60

It was not asked during the interviews how the handling of septic tank waste removal is done at the different establishments. However, in a study done at Sossus Dune Lodge by Karita (2013) it is said that a lorry sucks up the content of the six septic tanks with a capacity of 5000 L each and then churns the content to let the paper and other solids disintegrate and disposes the effluent a kilometre away west of the establishment in a river bed. Regulations by DWAF on the proper disposal of sludge from septic tanks state that it should be buried half a meter deep at suitable sites that do not cause health hazards, nuisance or cause secondary pollution of groundwater. The stipulated distance between a freshwater source and wastewater system is 500-800 m (DWAF). However, some establishments have their wastewater systems within the 100 m radius around the water source as was found on the NamibRand Nature Reserve. This could be because of poor planning and not knowing the regulations since most of the establishments do not have the relevant wastewater and effluent disposal permits. This poses a problem for the possible contamination of groundwater and associated health risks. From Table 11, the four establishments that have their wastewater systems within the 100 m radius the owners say they make use of plastic septic tanks that prevent possible groundwater contamination (Pers. Comm., Odendaal at DRFN Windhoek, Nov., 2013) although we are unsure how this works because there must still be a draining process for the tanks at some step. However the wastewater systems at these establishments may still pose a threat of groundwater contamination, for example at Sesriem Camp has plastic tanks but still pump out and dispose the wastewater into the environment. Those establishments (Drifters and Nubib) that have French drains after the septic tanks have plants growing above them that help remove the toxins from the wastewater. A possible threat of groundwater contamination could be from Agama River Camp, Keerweder, NaDEET and Tok Tokkie that have several of their wastewater sites (e.g. concrete septic tanks that are susceptible to cracks and leakages) close to their freshwater sources. Most medium and large tourism establishments (Figure 15) that cater for their guests have kitchen fat traps, which are vital for the protection of bacteria inside septic tanks and ensure that grease does not prevent soil from absorbing final effluent (DWAF, 2008). The kitchen fat traps are mostly cleaned out weekly as stipulated in the regulations by DWAF (2008), although some of the establishments are not following this (Table 8). This could be due to the low number of guests being catered for at a time, with an increase in cleaning frequency in the high season. Many of the interviewees did not know where the waste from the fat trap is finally deposited; this could be because they are not directly in charge of the kitchen fat trap 61 cleaning. The other establishments took the fat trap waste to the dumpsite, incinerated it, or disposed onto a tree or on the compost. The small establishments do not have a kitchen fat trap which can be attributed to the few people that they can accommodate.

4.2.5 Wastewater Summary The establishments visited in the GSNL all mainly generate domestic wastewater that they handle in various ways. There is a need for all establishments to prioritise wastewater handling during financial budgeting and planning to prevent possible groundwater contamination as that will have a negative impact on the tourism industry. Inefficient wastewater handling facilities that are not properly designed, located and constructed are costly. The commonly used wastewater systems are septic tanks linked to French drains, where some large establishments have added various components to increase handling capacity of their wastewater. Blockages and overflows are the main challenges experienced in the GSNL. The final wastewater is mainly disposed into the soil from French drains, and some establishments reuse this for watering plants. Directly discharging the untreated effluent straight from the septic tank into the environment poses risks to the environment and animals. Most of the tourism establishments that cater for their guests have kitchen fat traps that they clean out weekly.

4.2.6 Wastewater Recommendations Challenges/Situation Recommendations • Regular inspections by a suitably experienced employee to ensure the maintenance and satisfactory functioning of the system at all times (MAWF). This is the first and most important recommendation for enhancing wastewater systems at all establishments. Blockages & Overflows • When there is saturation of soil at the French drain that leads to overflows, reconstruct the French drain (DWAF, 2008) at a suitable location. • Consider installation of a cutter before the septic tank to reduce the size of solid matter in the effluent, as done at Sossusvlei Lodge. Bad smell at septic tanks & French • Consider the prevailing wind direction for the location of drains septic tanks and French drains, to prevent bad odours 62

blowing towards the establishment. • Add rotten meat, liver or yoghurt to the septic tank to aid digestion of organic matter, by inoculating the septic tank with bacteria and reducing emission of hydrogen sulphide that causes the bad smell. • Use bitter bush (Pechuel-Loeschea leubuitziae) to suppress bad odours at septic tanks & French drains as done at Le Mirage Desert Lodge. • Fence off surface wastewater to exclude people and animals. • WW treatment system should be located in an accessible area for pumping out sludge and maintenance (DWAF, Accessibility of WW disposal site 2008). • WW treatment system should be located downhill of a freshwater source at a distance of 500-800 m (DWAF, 2008). Lack of awareness about objects • Put notices in the toilets, showers and kitchen to alert thrown down the drain that cause people not to throw objects such as sanitary tampon, pads, blockages. diapers and condoms down the drain. • Need to separate grey water from black water, to enable reuse for watering trees and/or lawns and flushing toilets. This will reduce cost of freshwater extraction, and Grey water reuse infrastructure maintenance. • For health reasons, recycled grey water taps should be labelled and locked to prevent accidental consumption (Schachtschneider and Nashipili, 2000). • Add advanced treatment systems to septic tank and/or French drain systems, such as lined evaporation ponds, sand filters as done at Namib Desert Lodge and Sossusvlei Lodge respectively and reed beds as done at Namib Naukluft Lodge. This enhances the wastewater handling Use of ineffective WW systems capacity. • Need to use modern and effective WW treatment systems that facilitate recycling and reuse of WW, e.g. Biological WW filter systems with commercially available digesting bacteria as done at Namib Desert Lodge and Wolwedans. 63

• No free running wastewater should be allowed. • WW should be discharged into fenced off, lined Free running of WW into evaporation ponds or reed beds (DWAF, 2008). environment • Reuse pool backwash for watering plants depending on the amount produced by the filtering system used.

4.2.7 Case Study: Sanitation and Waste Management at Sossusvlei 2x4 Parking Lot

Sossusvlei is a unique, exotic destination in a hyper-arid desert of exceptional beauty, unforgiving harshness and spiritual grandeur. It is one of the key iconic attractions exemplifying elements of the stunning Namib Desert landscape encompassed in the recently inscribed Namib Sand Sea, a World Heritage Site. Sculpted by eons of geological, geomorphic and climatological forces, it now attracts thousands of visitors each year. Every day of the year tens to hundreds of tourists drive the 60 km paved road west from Sesriem along the Tsauchab river deep into the dunes to Sossusvlei. The Sesriem administration headquarters and the Namibian Wildlife Resorts Camp Site or Lodge provide water for sale and are the main sanitation facilities within the boundary of the Namib-Naukluft Park. Provision of sanitation and solid waste facilities near Sossusvlei itself has been a challenge for the Ministry of Environment and Tourism for decades and no water is available.

Although the multitudes of tourists only make a day visits to Sossusvlei, they do require sanitation facilities to prevent desecration of the magnificent scenery. Currently one small facility has been installed at the 2x4 parking lot near the current end point of the Tsauchab River where sedan cars remain while tourists walk or are transported by 4x4 vehicles toward Sossusvlei itself and the photogenic Deadvlei, one of many former end points of the Tsauchab River

Currently a semi-permanent sanitation solution has been established at the 2x4 parking lot near SossusVlei, the area to which tourists can drive with an ordinary sedan car. This involves a portable caravan-like facility with six single flush toilets, three for men and three for women, and three urinals. Two 5000 L tanks provide water for the facility and four septic tanks in sequence receive the wastewater. The septic tanks are not fenced, are accessible to the public and animals such as jackals while the tops are only wired on. 64

Although not viewed, it appears that the wastewater dissipates into the sandy soil directly from the septic tanks. Although less than on year old, both pipes leading from the toilets to the septic tanks are on the surface, are partially destroyed and the flushing water is visible No hand-washing facilities are provided. According to the drivers stationed at the 2x4 parking lot, water is trucked in as required by the Ministry of Environment and Tourism. A recent attempt to drill a borehole near the 2x4 parking lot proved to be dry to a depth of 240 m. Alternative sources of water for a wet sanitation facility would require more frequent trucking in of water or drilling a borehole further upstream on the Tsauchab and installing a 40km pipe. When this facility was first erected in 2013 it attracted several swarms of bees as the only source of water in the vicinity; these left of their own accord. Unfortunately the facilities are currently not clean or in a good state of repair which condition limits their use by visitors to the area (See the images below).

For solid waste, 200 L drums, open at the top, are located around all the parking facilities near SossusVlei. These are not emptied regularly and attract jackals and similar scavengers. The drums are said to be emptied by Namibia Wildlife Resorts drivers on an intermittent basis as required and the solid waste taken to the disposal sites of NWR at Sesriem.

In addition, along the drive from the entrance gate to Sossusvlei, two dry sanitation facilities are available to tourists as well as open drums for rubbish; tourists are observed using these facilities regularly.

2x4 Parking lot toilet facility Three urinals in the men’s toilet

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Unclean toilets and broken down cistern

An alternative approach at the 4x4 parking lot would be to create a ‘sanitation lager’ where several alternative facilities are established and considered part of an experiment in the arid environment experience. The tourists could be invited to assist with the experiment and to comment on the options provided. This experiment would require regular and thorough maintenance and cleaning and a proper reward system for those who are involved in this aspect should be set up.

Recommendations for the 2x4 Parking Lot GSNL Committee should look into who should handle the different responsibilities. • Retain the existing sanitation facility with close attention to daily cleaning and ongoing, weekly infrastructure maintenance. • Repair the pipes and other aspects of the infrastructure now broken, leaking or otherwise dysfunctional. • Clean up around the current facility and remove rubbish and other materials stored in the vicinity. • Add two hand-washing facilities to the inside of the facility. • Add hand-washing facilities to each of these new facilities. • Construct four additional ‘appropriate technology facilities’ in the vicinity based on four different types of dry sanitation. • Carefully name and clearly advertise the different types of facilities. • Develop a brochure describing the rationale for the different types of facilities. • In the brochure, after a brief description of the world heritage site, start by briefly describing the arid landscape, lack of water and similar resource restrictions. 66

4.3 Solid Waste

4.3.1 Introduction The universal waste management hierarchy of the three R’s Reduce, Reuse and Recycle plays a major role in solid waste management in the GSNL. This hierarchy can be called upon at any stage starting with where one buys supplies, at the point of waste generation, and throughout to the point of disposal thus reducing the volume of waste for final disposal.

4.3.2 Source of Solid Waste All the medium and large establishments only purchase their goods in one town each, with A Little Sossus Lodge and Campsite, Namib Desert Lodge, Namib Naukluft Lodge, Le Mirage Desert Lodge, Sossusvlei Lodge and Wolwedans of the seven large establishments shopping in Windhoek only. This could be attributed to the fact that some establishments do their laundry in Windhoek or have their main office there. Agama River Lodge, NaDEET, NamibRand Family Hideout, Nubib, Sesriem Camp, Sossus Dune Lodge and Tok Tokkie get their goods delivered to them which saves money on fuel and reduces the frequency of shopping trips. However, it is not known whether delivery comes cheaper than having establishments picking up goods themselves, whether is it simply more time efficient or for other reasons unknown. Looking at the bigger picture, this reduces the impacts of carbon emission on the environment because instead of having everyone drive to town, a truck delivers to several establishments. Conversely, the small establishments have more than one source of supply apparently because the small towns meet their basic needs. Overall the size of the establishments seems to have a role in where these establishments get their goods and services and hence the types of solid waste generated.

4.3.3 Types of Solid Waste generated The type of solid waste generated determines the waste handling methods to be implemented. Like in any other residential establishment, but in this case used for tourism purposes, common types of domestic waste are generated in all 21 establishments. During the interviews it came clear that establishments in the GSNL do not quantify the amount of solid waste generated. Therefore it makes it hard for one to determine the impacts and the severity of such impacts on the environment, human health, and the tourism industry, as well as to 67 identify alternatives for solid waste handling. The only quantitative information available was that provided by Karita from the Sesriem Campsite (Karita, 2013).

4.3.4 Handling of Solid Waste Besides the types of solid waste being dealt with, the availability of resources (i.e. money), transport, size of the establishments and limited awareness also play a part in the solid waste management methods implemented by these establishments.

4.3.5 Sorting Sorting is one of the handling techniques applied by 15 establishments (A Little Sossus Lodge, Aandster, Desert Homestead and Horse Trails, Drifters, Keerweder, NaDEET, Namib Naukluft Lodge, NamibRand Family Hideout, Nubib, Sossusvlei Lodge, Sossusvlei Desert Lodge, Tok Tokkie, and Wolwedans, private, and two public, Sesriem Camp and Sossus Dune Lodge) within the GSNL, separating burnable, recyclables, and organic waste. Regardless of whether publicly or privately owned, most of the establishments in the GSNL sort their waste onsite. The separation of organic waste from the rest of the waste eliminates the bad odour especially in establishments where waste is only disposed of once a week or is kept onsite for a long period. Mixed waste (including organic waste) produces a bad odour that attracts flies and rodents. Unfortunately, although drums for different solid waste are provided by A Little Sossus Lodge and Campsite, Desert Homestead and Horse Trails, Drifters and Sesriem Camp, for tourists to sort their rubbish, at the end all the waste is mixed together either at an individual dump site before burning them or at an offsite dump site (i.e. Maltahohe dump site)

4.3.6 Recycling and Reuse of Solid Waste NaDEET is an educational centre, which promotes reduce, reuse, and recycling of waste. The establishment helps develop student capacity from different regions country wide on how to add value to waste. This centre makes paper fire bricks out of paper waste as shown in Figure 23 and reuses tins/cans, and empty yoghurt containers for decoration and storage respectively.

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Figure 23: Students making paper fire bricks at NaDEET (Source: NaDEET, 2013)

Recycling paper to make paper fire bricks reduces the need to use fire wood thus preserving the environment and in a way preventing deforestation (Shigwedha, 2012). It also reduces the amount of paper waste that is taken to the dump site.

4.3.7 Recycling and Reuse of Organic Waste Agama River Lodge, Drifters, NamibRand Family Hideout and Wolwedans privately owned establishment’s compost organic waste to fertilise their gardens. Composting saves money on fertilisers and it also reduces groundwater contamination, and air pollution that could result from the use of fertilisers. Furthermore, Sossusvlei Lodge and Wolwedans, both private, established small piggeries to use their organic waste. This therefore reduces the quantity of organic waste taken to the dump site.

A B

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Figure 24: A - Garden on one of the private establishments that compost. B - A piggery on a private establishment, SDP 17 (2013)

4.3.8 Individual Dump Sites for Establishments in the GSNL Twelve establishments out of 21 interviewed establishments were found to have their own dump sites onsite. These dump sites are mostly used for the disposal of burnable and non- recyclable waste. However, car batteries that are considered to be hazardous waste which can potentially contaminate groundwater were found in dump sites for Sesriem Camp and Zeis. The conditions of these dumpsites strongly indicate limited maintenance mechanisms to ensure that the individual dump sites are of an acceptable standard. Among the twelve establishments that have individual dumpsites, Agama River Lodge, Desert Homestead and Horse Trails, Keerweder, Le Mirage Desert Lodge, Namib Naukluft Lodge, and Neuras, have fenced dump sites whilst A Little Sossus Lodge and Campsite, Sesriem Camp, Sossus Dune Lodge, Sossusvlei Desert Lodge, Wolwedans, and Zais have unfenced dumpsites but all twelve do burn their waste. Of all establishments that burn, Zais has a different approach whereby waste is burnt at individual homes and only ash and burnt materials are taken to the dumpsite. All the recorded fenced dumpsites belong to private establishments, with mostly small establishments (three of the four that had dump sites) that are fenced. Both burning and fencing prevents light weight waste from being blown away by the wind, which can be visually unappealing and be ingested by livestock and wildlife. Two instances were also recorded at Nubib during interviews where two cows had died from plastic ingestion. Despite the land-use having changed from farming to tourism in the GSNL, there are still livestock farms in this area and also in the vicinity. Thus this could put the lives of livestock and wildlife in danger. On the other hand, the smoke from burning has negative impacts on the environment and it alters the air quality that can result in respiratory infections (Kaseva and Moirana, 2009).

4.3.9 Offsite Handling of Recyclables It was observed that after sorting, different establishments handle their waste differently. The source of goods supply, having a dumpsite onsite, and whether the establishment is a part of a group that collects their waste together are some of the factors that determine what happens to the sorted solid waste. 70

Aandster, Keerweder, NaDEET, Namib Naukluft Lodge, NamibRand Family Hideout, Sossusvlei Lodge, Tok Tokkie, Wêreldend, Namib Desert Lodge, and Wolwedans that frequently go to Windhoek take their recyclables to the recycling companies in Windhoek. Whilst A Little Sossus Lodge and Campsite, Drifters, and Le Mirage Desert Lodge take their waste to the Maltahohe dumpsite when they go for shopping in Maltahohe and Mariental. Maltahohe has no fenced or managed waste site but different establishments take their mixed waste there for several reasons such as the distance, shopping, and availability of resources while ignoring the environmental implications. It was observed that light weight waste was scattered in the vicinity of the nearby settlement in the northern part of Maltahohe town. This also discourages people from sorting as it is a waste of their effort to sort and locate bins for different types of waste when in the end they then mix everything at this site. Additionally, the open site attracts animals to the site and becomes a breeding site for rodents. This was observed at Sesriem Camp where baboons were found onsite.

4.3.10 Training and Awareness Environmental training that focuses on waste management provides awareness on effective waste management practices and helps people understand the significance of such practices on the environment (Eco Award, 2005). Results indicated that Keerweder, NaDEET, Namib Naukluft Lodge, Sesriem Camp and Sossus Dune Lodge, all have some sort of relationships with MET and offer environmental training to their staff members. However little is known about these establishments’ relationship to MET or what is covered in the environmental training offered. Sesriem Camp and Sossus Dune Lodge are part of Namibia Wildlife Resorts (NWR), a parastatal reporting to MET whilst Keerweder and Namib Naukluft Lodge are part of the GSNL committee.

4.3.11 Group Collection Centre A group collection centre is not just a fancy term and it does not refer to a dumpsite but should be viewed as a source of job opportunity, and a better way to manage solid waste for the entire GSNL. A group collection centre should have an incinerator where burnable waste can be burnt, and facilities for accommodating the non-recyclables. This will therefore eliminate the individual dump sites hence reduces the emission of harmful substances from 71 smoke after burning. With all the benefit the group collection centre would bring to the GSNL, stakeholders however had different views and opinions. Nearby Sesriem is the best possible location for the group collection centre, as it was suggested by three establishments, and other suggested locations were Solitaire, Wolwedans, Toekoms, T-junction at Le Mirage, Sossusvlei/Sesriem, and any suitable location. The “suitable” locations suggested were in consideration of the distance, and accessibility. Conversely the effectiveness of a group collection centre requires team effort, dedication, and commitment. Thus, the involvement of the stakeholders in the GSNL would be significant in achieving a well-maintained collection centre, as proposed by some stakeholders.

4.3.12 Solid Waste Recommendations Situation Recommendations • The GSNL committee needs to further discuss and consider encouraging Interconnection GSNL occupants to work together towards solid waste management to conserve the environment and preserve tourism. • Establishments should continue sorting and separation of waste and owners and managers should encourage guests and staff to sort by having well labelled (with images & words) dustbins onsite. Establishments like N are therefore encouraged to not combine all sorted waste but treat each category Sorting in an appropriate manner. • Compacting can be a good way of storing waste before taking it to its final destination for it reduces volume of the waste. Then there is a need to investigate how much one will save if they have to compact their waste. • Establishments with gardens and domestic animals should continue using their organic waste for compost or/and animal feed to reduce the volume of waste taken to the dumpsite. • The establishments may also donate organic waste to those that compost or feed domestic animals Reuse and • Establishments should purchase reusable shopping bags to reduce the plastic recycling of waste, while paper can be donated to NaDEET for paper fire bricks if need waste be and NaDEET is willing to pick the paper from a location agreed by both parties. • Establishments (e.g. NamibRand Family Hideout and Nubib) with water heater “donkeys” can use paper fire bricks for their donkey, to warm up their water reducing the use of wood and saving trees. 72

• Establishments can invest in reusing waste for decoration, or make hand- crafted products for example using tyres as plant/ flower pots. • Establishments can also look into the reuse of old building materials. If they can use irregular rocks from the surrounding to build their campsite and lodges, then using old irregular building materials can be a good possible option. • Establishments’ management should ensure the dump sites are fenced, and are located away from possible water sources. • Strong fencing materials such as strong mesh wire should be used to ensure the wildlife do not break into dump sites and the minimum height should at least be 2 m. • The dumpsites should also have strong lockable gates to prevent access of unauthorised persons and animals pushing and forcing their way into the Individual dump dump site. sites • These dump sites should not be used for organic waste, because they cause bad smells and attract wildlife such as baboons. • An incinerator would be the best approach for burning burnable and organic waste rather than burning in the open. • The prevailing wind should be considered when constructing a dumpsite. The dumpsite should not be established in a location that causes the prevailing wind to blow the bad smell from the dump site to the direction of the lodge/campsite or any nearby establishments. • The GSNL committee and NamPlace should urgently engage relevant stakeholders (Town Council, MRLGHRD) to look into upgrading the Maltahohe dump site and decide on the best possible waste management methods that can be implemented. Maltahohe • Alternatively, establishments should refrain from using this dump site and dumpsite take their waste to Mariental dump site rather than leaving it in Maltahohe when they go for shopping or can collect together as group where one can take it to a dumpsite that recycles. (although we were unable to examine the Mariental dump site to see whether it is a valid waste disposal site. • Establishments’ management should incorporate the aspects of effective solid Training and waste management methods as part of the environmental on-the-job training. awareness • Establishments should provide awareness on proper solid waste management practices in the form of posters and stickers. Group collection • GSNL committee together with NamPlace should further look into possible 73 centre alternative solid waste management practices such as: • Rethink the idea of a solid waste group collection centre at a location that best fits everyone e.g. near Sesriem that was suggested by majority • Make arrangements with a recycling company to pick up recyclable waste from GSNL. • A group collection centre can own two vehicles that can collect or pick up waste from establishments. One that collects from the northern establishments and the other from the southern establishments.

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4.4 Legislative and Regulatory Framework

4.4.1 General Aspects Legislative and regulatory frameworks are a pre-condition for any sustainable management of the environment. This is particularly true for the proper management of water use, wastewater and solid waste management. Without a legal basis, the conservation and control of these resources could be hammered. Research in the GSNL displays a general reluctance of social compliance with the applicable legislative and regulatory framework. The reasons for such reluctance on the side of the stakeholders may vary. Such reluctance may unfold some legal consequences and ultimately the degradation of the environment if no drastic measures are taken. Namibian law is predominantly a prisoner to its history (Mapaure et al; 2013; Amoo, 2008). Hence, the legislative and the regulatory framework dealing with the environment remains stranded in South African statutes because of the mechanical linkages in the political history between the two countries. On this note, most of the laws dealing with water use, wastewater and solid waste management are pre-independent statutes. Water use, wastewater and solid waste management’s legislative and regulatory framework displays a fragmented wide range of statutes each with its own requirements and sanctions. Although showing commitment on the side of government, this fragmentation and overlap of statutes, as will be discussed below is central or perhaps the root cause of the current weak compliance by stakeholders. This section firstly outlines the main legislation and regulations dealing with waster use, wastewater and solid waste management nationally and attempts to link these to the situation in the GSNL. Secondly, some of the key social and legal issues encountered during the research period amongst the GSNL establishments will be highlighted and supplemented with the data gathered and lastly recommendations to the GSNL Committee will be made.

4.4.2 Water Sources The GSNL is largely private land with the exception of some State owned establishments and the State administered Namib Naukluft Park. Owing to this fact, the water resources within the GSNL are privately managed although the State has sovereign ownership of all natural resources within the country by virtue of Article 100 of the Namibian Constitution.

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The Namibian Constitution, Article 100: Sovereign Ownership of Natural Resources: Land, water and natural resources below and above the surface of the land and in the continental shelf and within the territorial waters and the exclusive economic zone of Namibia shall belong to the State if they are not otherwise lawfully owned.

This private ownership of the establishments within the area has legal consequences. For one, establishment owners are granted abstraction rights for any water sources found on their establishments. Hence, any ground water located on an establishment within the GSNL is by virtue of ownership of the land de facto private water of the establishment owner(s). Water use in Namibia is predominantly regulated by the Water Act No. 54 of 1956 (hereafter referred to as Water Act, 1956).1 In terms of section 5 of the said Water Act, 1956 the ‘sole and exclusive use and enjoyment of private water vests in the owner of the land on which it is found.’ Rights of water abstraction and use is based on the riparian rights principle, derived from the Roman Law (DWAF, 2000); which means that the right to water usage is underlined by the location of the water resources in relation to the land. However, this position will be altered with the promulgation of the Water Resources Management Act, 2004 and its regulations. The extent of ground water use for selling within the GSNL is not known. What can cautiously be presumed is that a relatively low number of the tourism establishments are making use of ground water for such purpose. Of the 21 establishments interviewed in the GSNL only one; that is lodge J used private water abstracted from the ground for selling. The general position, in light of section 30 (1) of the Water Act, 1956 is that no permit or any regulatory compliance is required of the GSNL establishments before abstracting subterranean water underneath their land.

However, regulation 1278 of the Water Act, 1956 stipulates that an authorisation permit be obtained from the Department of Water Affairs (DWAF) before any of the ground water abstracted can be sold or disposed or transported beyond the borders of the land where it was abstracted or where any construction of any water work which stores more than 20 000 m3 of water takes place. Whether the establishments who sell their water comply with this

1 This statute, although a pre-independence work, was made applicable to the territory of South West Africa (present day Namibia) in terms of the Executive Powers Transfer Proclamation (AG 3/1977) dated 28 September 1977. 76 regulation cannot be confirmed as such information was not explicitly requested from the stakeholders during the data collection process.

The Environmental Management Act No. 7 of 2007 (hereafter referred to as Environmental Management Act, 2007) and the Water Resources Management Act No. 24 of 2004 (hereafter referred to as Water Resources Management Act, 2004), although the latter Act is still not operational, are to introduce major changes which could have legal implications for establishments in the GSNL.

The Environmental Management Act, 2007 gives effect to Article 95 (l) of the Namibian Constitution and therefore remains the overarching law concerning matters relating to the environment in Namibia.

The Namibian Constitution, Article 95 (l): Principles of State Policy: The State shall actively promote and maintain the welfare of the people by adopting, inter alia, policies aimed at the following: ...(l) maintenance of ecosystems, essential ecological processes and biological diversity of Namibia and utilisation of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future; in particular, the Government shall provide measures against dumping or recycling of foreign nuclear and toxic waste on Namibian territory.

Under the Environmental Management Act, 2007, an environmental clearance certificate is required from the office of the environmental commissioner for any activity that may have an impact on the environment. This is in line with the Environmental Impact Assessment Policy adopted in 1994. However, this does not have a retrospective requirement. In terms of this policy, any activity, inter alia, involving water use (including the construction or installation of infrastructure relating to water use) and disposal, waste and sewage disposal and chemical treatment requires an environmental clearance certificate. An owner of an establishment may make an application for an exemption in terms of section 28 of the Environmental Management Act, 2007 from obtaining such environmental clearance certificate.

The Environmental Management Act No. 7 of 2007, Section 3 (2): Principles of Environmental Management: 77

(a) renewable resources must be used on a sustainable basis for the benefit of present and future generations; (b) community involvement in natural resources management and the sharing of benefits arising from the use of the resources, must be promoted and facilitated; (c) the participation of all interested and affected parties must be promoted and decisions must take into account the interest, needs and values of interested and affected parties; (d) equitable access to environmental resources must be promoted and the functional integrity of ecological systems must be taken into account to ensure the sustainability of the systems and to prevent harmful effects; (e) assessments must be undertaken for activities which may have a significant effects on the environment or the use of natural resources; (f) sustainable development must be promoted in all aspects relating to the environment; (g) Namibia’s cultural and natural heritage including, its biological diversity, must be protected and respected for the benefit of present and future generations; (h) the option that provides the most benefit or causes the least damage to the environment as a whole, at a cost acceptable to society, in the long term as well as in the short term must be adopted to reduce the generation of waste and polluting substances at source; (i) the reduction, re-use and recycling of waste must be promoted; (j) a person who causes damage to the environment must pay the costs associated with rehabilitation of damage to the environment and to human health caused by pollution, including costs for measures as are reasonably required to be implemented to prevent further environmental damage; (k) where there is sufficient evidence which establishes that there are threats of serious or irreversible damage to the environment, lack of full scientific certainty may not be used as a reason for postponing cost-effective measures to prevent environmental degradation; and (l) damage to the environment must be prevented and activities which cause such damage must be reduced, limited or controlled.

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The Environmental Management Act, 2007 further makes provision for an enforcement mechanism; that is by providing for the appointment of environmental officers who will enforce the provisions of the Act. No regulations yet, however.

The Water Resources Management Act, 2004, although currently not operational as a law will birth substantial changes relating to water use in the country. Once operational as a law the said Act will repeal the whole of the 1956 Water Act and declare the entire territory of Namibia a water control area, such as currently in the area of Stampriet and Tsumeb and Otjiwarongo areas, including the commercial farms in these areas. Ground water usage will therefore be controlled by the State be it on public or private land. A permit will be required to drill, construct, enlarge or alter boreholes or to engage in borehole drilling programme (section 46) as well as a renewable licence will be required for the abstraction or use of underground water (section 32). 79

4.4.3 Wastewater The legal regime relating to wastewater is predominantly embedded in the Water Act, 1956 and the Public Health Act No. 36 of 1919 (hereafter referred to as the Public Health Act, 1919) (including the Public Health Regulations GN 121 of 1969).2

The Water Act, 1956 and its supplementary regulations set out requirements in terms of water supplies for drinking water, wastewater treatment and discharge into the environment. For human consumption, the law stipulates that such abstracted water comply with the General Guidelines for the Evaluation of drinking water quality for human consumption with regard to chemical, physical and bacteriological quality as determined by the Department of Water Affairs (DWAF) in terms of the Water Act, 1956 regulations.

Where effluents are intended to be purified for any reuse i.e., as a means to reduce water usage, individuals should comply with the General Standard Quality Restrictions as laid out in Government Gazette R 553 of 1962 and section 21 (2) of the Water Act, 1956, which stipulates that this purified effluent be returned as close as possible to the point of abstraction of the original water. With regard to the discharge or rather disposal of wastewater into the environment a discharge permit is required in accordance with section 21 (5) and 22 (2) of the Water Act, 1956. This permit is granted subject to conditions (where necessary) by the Permanent Secretary of the Ministry of Agriculture, Water and Forestry (See permit conditions/stipulations below focusing on septic tanks). These conditions are largely outlined in the Code of Practice General Guidelines introduced by the Department of Water Affairs in 2008. These Guidelines mainly set out septic tank systems, pond systems and biological treatment activated sludge processes.

2 The latter Act was extended to the territory of South West Africa in 1920 in accordance with the South African Public Health Proclamation No. 36 of 1920. 80

Department of Water Affairs Conditions for Wastewater and Effluent Disposal Exemption Permits for Septic Tanks (2011):

2.2 The septic tanks and disposal of sludge and effluent shall be operated in such a manner that no health hazard, nuisance or pollution of surface or underground water occurs.

2.3 No intractable or toxic waste shall be allowed to find its way into septic tanks.

2.4 No boreholes, dwelling or occupied building shall be allowed within 500m of the nearest wastewater and sludge disposal site.

2.5 All septic tank facilities must be constructed in accordance with the recommendations of National Building Research Institute as laid down in their information sheet X/BOU 214.

2.6 Septic tanks may be constructed of any suitable non-corrosive material in order to provide an average retention time of 24 hours.

2.7 Septic tank construction shall incorporate a vertical baffle to enhance the removal of sludge and floating material, and a manhole to facilitate desludging.

2.8 The septic tank shall not be washed or disinfected after pumping nor shall it ever be emptied into storm drains or its contents discharged directly into streams or a watercourse.

2.9 Satisfactory methods shall be used for the removal and disposal of grit, screening, floating debris and sludge from the periodic cleaning of the septic tank. None of this shall be made available to any person for any purpose.

Besides the orientation of the wastewater legal framework around the above stated legislation, some inroads are made by the Environmental Management Act, 2007 and the Draft Pollution Control and Waste Management Bill of 2003.

In so far as the Environmental Management Act, 2007 is concerned, any activity involving wastewater and sewage disposal (including chemical treatment thereof) is subject to an environmental impact assessment for the determination whether an environmental clearance certificate can be issued. Equally, the Draft Pollution Control and Waste Management Bill, 2003, although not an operational legal work will upon promulgation prohibit the discharge of effluent and into watercourses without a water discharge licence. The licence will be issued by a Pollution Control and Waste Management Agency which will be a statutory body established by the same Act. 81

The Public Health Act, 1919 especially the supplementary regulations thereof, largely affect wastewater systems by stipulating regulations dealing with septic tanks and requirements regarding sanitary accommodation.

4.4.4 Solid Waste Solid waste management has not as yet received comprehensive legislative thought. In 2010 the Ministry of Health and Social Services (MoHSS) tabled the National Solid Waste Management Policy. This policy, although a national effort in curbing the current solid waste pollution situation in the country, has no legal enforceable effect. During the data collection process it was not asked from those interviewed whether they had a disposal permit. It is however, clear that the Environmental Management Act, 2007 makes provision for waste site licences. Whether the establishments in the GSNL comply with this provision cannot be confirmed as most of the stakeholders interviewed were very sceptical in revealing matters concerning the law.

The Environmental Management Act, 2007 however embraces provisions relating to solid waste management in general. Waste disposal sites are subject to an environmental impact assessment, and therefore require certification with a clearance certificate. But there are no enforceable regulations yet.

In 1999 the Ministry of Environment and Tourism (MET) first drafted a Pollution Control and Waste Management Bill, which by 2003 was in its third drafting stage. The Draft Bill prescribes some key areas in so far as solid waste management (and waste management as a whole) is concerned. These are, inter alia, any collection, transportation, storage, treatment, recovery or disposal of waste or hazardous waste are subject to a waste management licence by virtue of section 58 (1) of the Bill. Every person who owns a waste site will, in accordance with section 59 (1) of the Bill, be obligated to hold and comply with a waste site licence.

Pollution Control and Waste Management Bill (2003), Section 55 (1)-(3): Waste Management General Prohibition and Duty of Care: 82

(1) No person may produce, collect, transport, sort, recover, treat, store, dispose of or otherwise manage waste in a manner that results in or creates a significant risk of harm to human health or the environment. (2) Every person who produces, collects, transports, sorts, recovers, treats, stores, disposes of or otherwise manages waste shall take all reasonable measures to prevent any other person contravening sub-section (1) in relation to that waste. (3) A person who contravenes this section commits an offence and shall be liable on conviction to a fine not exceeding N$ 100 000,00 or to a period of imprisonment not exceeding ten years or to both.

The Bill further intends to control air pollution by stipulating in section 9 (1) that ‘no person shall discharge or cause to be discharged any pollutant to the air from a process except under and in accordance with the provisions of an air pollution licence...’

4.4.5 Key Legal and Social Issues Social compliance with the regulatory and legislative framework governing water use, wastewater and solid waste management remains a key challenge in the GSNL. The reason for this reluctance varies. Owing largely to the fact that the establishments within the GSNL were commercial farms dating back to the pre-independent era, they are by large not bound by post independent legislation, in the absence of an explicit provision making the specific statute retrospectively applicable. In the absence of current legislation expressly providing for these statutes to have a retrospective effect, most of the establishments, especially those started in post independent Namibia would not be affected. However, those who continue to construct new infrastructure on their farms and establishments are subject to conduct environmental impact assessments. Contributing to non-compliance are the State’s weak enforcement mechanisms that are currently in place. Firstly, the State as the sovereign custodian has many times not complied with the very laws they introduce. To take a standard example, in the GSNL, only one out of the four establishments which openly revealed possession of legal instruments i.e. permits, licences, clearance certificate, was a State owned establishment; whilst the remaining three establishments were privately owned. The State has therefore failed to be an effective mentoring institute. Instead the privately owned enterprises demonstrate a fairly moderate mode of legal compliance. 83

The sole and exclusive use of underground water as a private commodity for establishments on private land may pose a challenge for water demand management. Currently, the GSNL stakeholders are not legally bound to keep records of the amount of ground water abstracted. Since these are private establishments they are by virtue of the Water Act, 1956 allowed to draw as much water as their domestic needs may require provided that the water abstracted is used on the land where it was drawn. Equally no permit is required for borehole drilling in terms of the current Water Act, 1956, although this will change with the promulgation of the Water Resources Management Act, 2004 and its regulations.

Environmental laws are not consolidated in their current form. This is largely a shortcoming of the Environmental Management Act, 2007. Hence, there is an overlap of statutes and at times conflict of laws. This fragmentation of legislation may partly be the root cause of ensuring compliance as the various statutes are overseen by different line-ministries.

This conflict of laws or rather overlap of laws may be a solid reason for the weak law enforcement, which is the current status quo. The statutes currently in place, especially those dealing with water use and wastewater management are ancient with the exception of the Environmental Management Act, 2007 and the Water Act, 2004; in that they do not reflect the contemporary practicalities concerning water use and wastewater. For example, the Public Health Act (including its supplementary regulations) was passed in 1919, and made applicable to Namibia in 1920. This legislation is to date still operational. The public health situation in Namibia has drastically changed. The Public Health Act regulates septic tank infrastructure, which by the 1920’s was the then main sewage disposal system. Today, although most establishments still make use of septic tanks, French drains seem to be the main component in the sewage systems or a combination of the two. This is particular true in the GSNL, but the Public Health Act Regulations, 1919 make no mention of French drains.

Public participation in matters concerning conservation and environmental management is a matter of national concern in Namibia generally. More closely in the GSNL, although there is cooperation between GSNL and MET, there is need for closer ties and mentoring interchangeably between the two entities. For law enforcement to be effective such closer ties will be vital especially when one has regard to the fact that our law does not embrace public interest litigation. The issue of locus standi, that is the ability to have legal standing to 84 approach a court for environmental litigation, may negatively affect environmental protection in the GSNL. Therefore, cooperation between the GSNL stakeholders and the State, more closely the office of the Ombudsman is important as the latter office has been constitutionally entrusted with the protection of the environment.

It is only logical to argue that the GSNL stakeholders should prioritise legal-socio compliance concerning environmental matters. A change in attitude and private-state mentoring would be essential in this prioritisation process. For this reason Ruppel (2013) argues “the holistic fulfilment of the Constitution’s environmental principles regarding State policy requires even more political will and public participation at different levels.”

4.4.6 Law Aspects Recommendations • Social Compliance It is strongly recommended that the GSNL Committee advocates amongst its members to comply with the legal requirements imposed on them. This will require incentives on the side of the committee to encourage its members. Mentorship between the State owned enterprises and privately owned establishments can also be used to strengthen ties between stakeholders and encourage social compliance

• Advocacy There is a great need for the GSNL committee to create awareness amongst its members (public and private) about the permits/licences and clearance certificates required of them. This will require the GSNL Committee to also advocate for the promulgation of some of the key legislation needed to conserve the environment, especially the Pollution Control and Waste Management Bill and the Wildlife Management and Protection of Protected Areas Bill. This process of advocacy can serve as a mechanism of public participation in decision making and policy concerning the environment. The Committee can also advocate for the consolidation of the current statutes dealing with water use, wastewater and waste management to address overlapping and conflicting provisions in law.

• Law Enforcement There is a need to ensure that the laws and the obligations passed are complied with. 85

The GSNL Committee can therefore engage the office of the Ombudsman in seeking redress for enforcement. Generally, it is recommended that the GSNL Committee start a network with the office of the Ombudsman in order to investigate shortcomings from its members and help the Ombudsman in environmental related issues concerning the GSNL.

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