Sandpiper Project
Proposed recovery of phosphate enriched sediments from the Marine Mining Licence Area No. 170 off Walvis Bay, Namibia.
Environmental Scoping Report for the Terrestrial Component
March 2012
COPYRIGHT: ENVIRO DYNAMICS cc
Project Name Sandpiper Phosphate Project
Stage of Report Final Scoping Report submit at the DEA
Client Namibian Marine Phosphate (NMP)
Enviro Dynamics cc Lead Consultant
Date of Release April 2012
Stephanie van Zyl, Norman van Zyl, Carla Saayman, Sheldon Husselmann, Eddy Kuliwoye, Pat Morant, Dr Mark Zunckel, Dr John Kinahan, Dr John Irvin, Contributors to the Report Justine Braby, Japie van Blerk, Brett Williams, Pierre Botha, Dr. Andrea Pulfrich, Andre Theron, Dr. Hardus Diedericks, Theo Potgieter, Gert Maritz
Reviewer Patrick Morant
Stephanie van Zyl Contact E-mail: [email protected] Tel: +264 (61) 223 336
i
EXECUTIVE SUMMARY
Namibian Marine Phosphate (Pty) Ltd (NMP) is developing the Sandpiper Marine Phosphate Project in Namibia. The project resource area lies approximately 160 km south of Walvis Bay. The resource area includes a major part of the regionally mapped zone of phosphate mineralisation that occurs on the continental shelf south of Walvis Bay.
The intention is to mine these deposits using proven deep water dredging techniques. The material will be transferred to shore at Walvis Bay where minimal beneficiation is required to separate the phosphate sands from other marine sediments.
Locality of the marine phosphate deposit off the Namibian coast.
The Environmental Impact Assessment (EIA) which is required for this project in terms of Namibia’s Environmental Management Act (2007) and Minerals Act (2002) for the marine and land-based activities are currently underway. NMP appointed Jeremy Midgley and Associates and Enviro Dynamics cc as the lead consultants of these studies. The Final EIA Report for the marine activities is currently being compiled while the land-based EIA is concluding its scoping phase with this Draft Scoping Report.
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The purpose of the scoping process was to identify the key issues to be investigated and to refine the Terms of Reference for the specialist studies. The document includes the following:
a project description; a summary of the environment regulatory framework of the project; an overview of the socio-economic and bio-physical environment of the project; an account of the public consultation and disclosure process undertaken in Windhoek and Walvis Bay; and a list of the key issues identified and the way forward.
The studies that will follow as an output of this scoping phase are as follows:
Theme / Study area Specialist Terms of Reference
Marine ecology Dr Andrea Pulfrich Focus on the intertidal and shallow subtidal Pisces Environmental marine communities by studying changes in Services the: invertebrate macro-faunal community, nursery habitat, biodiversity and movement of marine fish (including larvae inchore and migratory patterns), migration corridors and calving areas of the Southern Right whales.
Focus on the marine and aeolian sediment Sediment Dynamics Andre Theron, dynamics by studying changes in the: Dr Gerhardus Diedericks CSIR sediment movement in the surf zone, beach and dunes due to the pipelines and other infrastructure and facilities, sediment movement in the surf zone due to the return of fines and shell to the sea Consider the effects of sealevel rise on the project activities.
Focus on the terrestrial biodiversity by studying Terrestrial ecology Dr John Irish changes in the Inner (coastal) Namib due to: Biodata change in the ratio of endemic, range- restricted endemic and potentially threatened species, cumulative and related effects of change that the project may have on the ecology.
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Theme / Study area Specialist Terms of Reference
Focus on the avian interaction by studying Birds Dr Justine Braby changes in the: environment in the flight paths between wetlands, along the coast and to new manmade wetlands, feeding, roosting and breeding activities of bird dependant on the project area, bird distribution due to changed habitats and new artificial habitats, interaction of the birds with infrastructure, facilities and activities of the project and the consequences.
Focus on the water and groundwater by Water Quality Pierre Botha studying changes in the: (groundwater, Geo Pollution surface water on Technologies groundwater quality and movement land and at sea) due to the infrastructure, facilities and activities of the project as well as in the surface water that periodically occurs in the project area, sea water quality due to the return of used seawater and process water to the sea. Semi purified water at the bird sanctuary due to the extraction and possible return of process water.
Focus on air quality by studying changes in the: Air quality Dr Mark Zunckel uMOYA-NILU receiving environment by identifying potentially sensitive receptors, process emissions as well as baseline conditions at all infrastructure, facilities as well as the transport/export route, modelling the downwind air conditions created by the project infrastructure, facilities and activities.
Focus on noise by studying changes in the: Noise Brett Williams Safetech receiving environment by identifying potentially sensitive receptors, process emissions as well as baseline conditions, modelling the noise conditions created by the construction and operation of the project infrastructure, facilities.
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Theme / Study area Specialist Terms of Reference
Focus on visual changes in the: Visual change Norman van Zyl Enviro Dynamics receiving environment by identifying potentially sensitive receptors and visual sources generated by the project infrastructure, facilities and activities, generating a visual inventory to determine the value of the views from the various visual receptors, model the visibility of the project infrastructure, facilities and activities from significant views.
Focus on the socio-economic environment by Socio-economic, Carla Saayman studying changes in the: including tourism Enviro Dynamics various forms of land use, including the traditional land use patterns of the Topnaars; fishing, tourism, conservation, traditional livelihood industries, social and economic movement.
Focus on the impact of traffic alternatives by: Traffic Theo Potgieter Burmeister & Partners reviewing the data of the Transport Study against existing information assess the changes in the environments in which the various transport options operates.
Focus on the archaeological landscape of the Archaeology Dr John Kinahan Kuiseb Delta and the surroundings by: QRS Namibia conducting an overview of the project area to identify sensitive areas to avoid (completed to guide the planning process). detailed survey of the pipeline route to ensure that individual sites are avoided
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Theme / Study area Specialist Terms of Reference
Conduct a carbon emissions study according to Carbon emissions Brett Cohen the Greenhouse Gas Protocol, to help delineate The Green House direct and indirect emission sources of the
project, and improve transparency of the calculations as follows: Scope 1: Direct GHG emissions from sources that are owned or controlled by the company. For example, this would include emissions from company owned vehicles Scope 2: Electricity indirect GHG emissions from the generation of purchased electricity consumed by the operations. These emissions occur at the power station. Scope 3: Other indirect GHG emissions include those emissions that occur as “a consequence of the activities of the company, but occur from sources not owned or controlled by the company”. These might include production of purchased materials, transport of materials or products by an outside firm or emissions during the use of the products sold.
Radioactivity Japie van Blerk Conduct a radiation impact study of the AquiSim Consulting (Pty) future impacts during the operation and Ltd closure of the land based process including the transport of product to the port and the loading thereof into vessels for export. This study should take account of sensitive areas such as the salt works, personnel exposed to the process, adjoining residential areas, and issues raised during scoping. The cumulative impact over time due to the build-up of radioactive material in the various stages of the process must be described. The minimum outputs of the study should include a qualitative radiological impact assessment, a radiation protection plan to be included in the overall EHS plan for the operation and closure of the land based process and the design of a radiation monitoring plan to be included in the EMP including post operations phase.
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Objectives
The objectives of this report , have been successfully met.
Assumptions and limitations
It is assumed that the water resource identified to supply the processing plant will be sufficient and sustainable. The semi-purified water from the municipal sewage treatment works will not fulfil the fresh water demand of the processing plant as originally envisaged. The project proponent is therefore responsible for identifying and securing an alternative water resource which is sufficient and sustainable. It is acknowledged that there are major constraints to the project in terms of transport, water and power supply, land availability and export logistics. These aspects are still being investigated by the project technical team. As soon as these have been resolved, stakeholders will be advised and given opportunity to comment and raise issues and concerns, which will be addressed by the appropriate specialists. Even though the specialist studies have been commissioned and will progress concurrently with the Definitive Feasibility Study Process, the final output of the latter study is required for the Draft Environmental Impact Report to be completed. The scope of this EIA excludes further local beneficiation and the power line route which are not included in the project description.
The Way Forward
This Draft Scoping Report will be circulated to the authorities and the public for comment. These comments will be a) incorporated into the report and b) carried forward for consideration in the remaining phases of the EIA process. The Draft Scoping Report will be submitted to the Directorate of Environmental Affairs (DEA) within the Ministry of Environment and Tourism (MET). The specialist studies have been commissioned, as outlined in Section 6 (this is the full investigation phase). These specialist studies will form the basis for the Draft Environmental Impact Report and will inform the environmental considerations of the Definitive Feasibility Study Process.
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CONTENTS
EXECUTIVE SUMMARY ...... i
OBJECTIVES ...... vi
ASSUMPTIONS AND LIMITATIONS ...... vi
THE WAY FORWARD ...... vi
1 INTRODUCTION ...... 1
1.1 BACKGROUND...... 1
1.2 ENVIRONMENTAL MANAGEMENT REQUIREMENTS ...... 2
1.3 EIA TEAM AND TEAM LEADER ...... 2
1.4 REPORT OBJECTIVES ...... 4
1.5 TERMS OF REFERENCE ...... 4
1.5.1 SCOPING ...... 5
1.5.2 SPECIALIST STUDIES ...... 5
1.5.3 ASSESSMENT OF IMPACTS ...... 5
2 PROJECT DESCRIPTION ...... 6
2.1 INTRODUCTION ...... 6
2.2 PROCESS OVERVIEW ...... 7
2.3 ORIGIN AND COMPOSITION OF THE ORE BODY ...... 8
2.4 USES OF PHOSPHATE ORE ...... 9
2.5 LOCALITY OF THE LAND BASED ACTIVITIES ...... 10
2.5.1 SITE ALTERNATIVES ...... 10
2.6 PRODUCTION ESTIMATES ...... 13
2.7 PROCESS DESCRIPTION ...... 13
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2.7.1 TRANSFER OF ORE TO SHORE ...... 13
2.7.2 LAND BASED ACTIVITIES ...... 14
2.8 INFRASTRUCTURE REQUIREMENTS ...... 22
2.8.1 ROADS ...... 22
2.8.2 POWER ...... 22
2.8.3 WATER ...... 23
2.8.4 WASTE WATER AND SEWERAGE ...... 23
2.9 MANPOWER ESTIMATES ...... 23
2.10 DEVELOPMENT SCHEDULE ...... 24
2.11 LATEST CHANGES TO THE PROJECT ...... 24
2.11.1 PIPELINE ROUTE AND PROCESSING PLANT SITE LOCALITY ...... 24
2.11.2 TRANSPORT ROUTES ...... 26
2.11.3 FRESHWATER SOURCE...... 26
3 THE LEGAL ENVIRONMENT ...... 28
4 PUBLIC CONSULTATION AND DISCLOSURE ...... 43
4.1 POLICY AND LEGAL FRAMEWORK ...... 43
4.2 THE STAKEHOLDERS ...... 49
4.3 METHODOLOGY ...... 51
4.4 THE MEETINGS TO DATE ...... 53
4.5 PUBLIC FEEDBACK ...... 56
4.6 ISSUES IDENTIFIED ...... 56
5 BIOPHYSICAL AND SOCIO-ECONOMIC OVERVIEW OF THE RECEIVING ENVIRONMENT .. 62
5.1 OVERVIEW OF THE WALVIS BAY ENVIRONMENT ...... 62
5.2 BIO-PHYSICAL ENVIRONMENT ...... 65
5.2.1 SEDIMENT DYNAMICS ...... 65
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5.2.2 TERRESTRIAL AEOLIAN TRANSPORT...... 65
5.2.3 COASTAL TRANSPORT ...... 65
5.2.4 INTERTIDAL AND SHALLOW SUBTIDAL MARINE COMMUNITIES ...... 67
5.2.5 INTERTIDAL COMMUNITIES ...... 67
5.2.6 SUBTIDAL COMMUNITIES ...... 67
5.2.7 PELAGIC COMMUNITIES ...... 68
5.2.8 GROUNDWATER ...... 68
5.2.9 TERRESTRIAL BIODIVERSITY ...... 72
5.2.10 DIVERSITY ...... 73
5.2.11 ENDEMISM ...... 73
5.2.12 CONSERVATION STATUS ...... 73
5.2.13 LEGAL STATUS ...... 73
5.2.14 BIOGEOGRAPHY ...... 73
5.2.15 BIRDS ...... 75
5.2.16 AIR QUALITY ...... 76
5.2.17 NOISE ...... 78
5.2.18 RADIO-ACTIVITY ...... 78
5.2.19 ARCHAEOLOGY ...... 80
5.3 SOCIO-ECONOMIC ENVIRONMENT ...... 82
5.3.1 DEMOGRAPHY OF WALVIS BAY ...... 82
5.3.2 TRAFFIC ...... 86
5.3.3 VISUAL RESOURCES ...... 87
6 IDENTIFICATION OF KEY ISSUES ...... 92
6.1 SCREENING OF ISSUES ...... 92
6.2 KEY ISSUES AND ASSOCIATED STUDIES ...... 108
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6.3 ALTERNATIVES ...... 112
6.3.1 SITE ALTERNATIVES: ...... 112
6.3.2 ALTERNATIVE TECHNOLOGIES FOR: ...... 112
6.4 IMPACT ASSESSMENT METHODOLOGY ...... 113
6.4.1 DESCRIPTION OF IMPACT – ...... 113
7 THE WAY FORWARD ...... 116
7.1 OBJECTIVES: ...... 116
7.1.1 ASSUMPTIONS AND LIMITATIONS: ...... 116
7.1.2 THE WAY FORWARD ...... 116
8 WORKS CITED ...... 117
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TABLES AND FIGURES
Table 2:1: Site alternatives considered for the discharge of slurry to shore, the pipelines and coastal buffer ponds and ancillary works...... 10
Table 2:2: Criteria for Selection of Site for the Processing Plant ...... 11
Table 2:3: Sandpiper Phosphate Production Estimates...... 13
Table 2:4: Generalised Mass Balance for Land Based Activities ...... 16
Table 2:5: Sea Water Management at the Buffer Pond ...... 17
Table 2:6: Fresh Water Requirement at the Plant Site ...... 21
Table 2:7: Manpower Estimates ...... 24
Table 3:1: Summary of Relevant Environmental and Social Legislation...... 29
Table 4:1: Summary of relevant Namibian legislation...... 44
Table 4:2: IFC Guidelines and Performance Standards ...... 47
Table 4:3: Summary of stakeholders ...... 50
Table 4:4: Announcements over the NBC Radio Service ...... 51
Table 4:5: Notifications placed in the press ...... 52
Table 4:6: Summary of meetings conducted ...... 53
Table 4:7: Summary of the objectives and methodology used arranging each meeting, as well as the main issues raised ...... 54
Table 4:8: Summary of themes resulting from the Public Participation process ...... 57
Table 5:1: Sensitivities related to sediment dynamics...... 66
Table 5:2: Sensitivities related to marine ecology ...... 68
Table 5:3: Sensitivities and potential impacts related to hydrogeology ...... 72
Table 5:4: Summary of taxon characteristics for area (Irish, 2012) ...... 72
Table 5:5: Decreasing size of bioclimatic envelopes with proximity to coast in western Namibia. Source: Irish, 2010-2011, four different studies, locational details withheld for client confidentiality since some projects unfinished...... 74
Table 5:6: Sensitivities and potential impacts related to vegetation ...... 74
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Table 5:7: Sensitivities related to birds...... 76
Table 5:8: Sensitivities and potential impacts related to air quality ...... 77
Table 5:9: Sensitivities and potential impacts related to Noise Impacts ...... 78
Table 5:10: Sensitivities and potential impacts related to radiation ...... 80
Table 5:11: Archaeological sensitivity in the project area ...... 82
Table 5:12: Sensitivities and potential impacts related to the socio-economic environment...... 84
Table 5:13: Sensitivities and potential impacts related to Transport ...... 87
Table 5:14: Visual Receptor Catalogue ...... 88
Table 5:15: Sensitive visual resources in the project area ...... 91
Table 6:1: Identification of key impacts ...... 93
Table 6:2: Key issues to be investigated, specialists assigned and their main Terms of Reference ...... 108
Table 6:3: Impact criteria for determination of significance ...... 114
Table 6:4: Significance descriptions ...... 114
Figure 1:1: Locality of the marine phosphate deposit off the Namibian coast...... 1
Figure 2:1: Sandpiper ore sample (as received at Mintek). Left image: ore as it is recovered from the sea floor. Right image: Shell material as screened out at the buffer pond.) ...... 8
Figure 2:2: Sandpiper -1.0/+0.1m Concentrate (Spherical black particles are the phosphate mineral and the lighter material is shell fragments. The clear material is silica.) Photo by SGA of Germany...... 9
Figure 2:3: Google Image of Walvis Bay and proposed location of buffer ponds and processing plant ...... 12
Figure 2:4: The Mining Development Concept ...... 14
Figure 2:5: The On-Shore Processing Concept ...... 14
Figure 2:6: Flow Diagram of Land Based Processes ...... 15
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Figure 2:7: Buffer Pond Layout(Source: Lithon Engineering) ...... 18
Figure 2:8: Process Plant Layout (Source: Lithon Engineering) ...... 20
Figure 2:9: Pipeline route alternatives being investigated...... 25
Figure 2:10: Transport route alternatives being investigated...... 27
Figure 4:1: Surrounding Land Uses to the proposed project ...... 49
Figure 4:2: Some of the meetings conducted...... 53
Figure 5:1: Overleaf is a photographic illustration of the Walvis Bay environment. Photos sourced from the Walvis Bay Municipality website and supplied by Enviro Dynamics...... 64
Figure 5:2: Intertidal and subtidal communities of the central Benguela region...... 67
Figure 5:3: Hydrogeology map - Locality...... 70
Figure 5:4: Hydrogeology map ...... 71
Figure 5:5: Archaeologically sensitive area located at the proposed pipeline route...... 81
Figure 5:6: Road and Rail routes from the processing plant to the harbour...... 86
Figure 5:7: Visual resource and sensitive receptor distribution...... 90
Figure 6:1: Screening process to determine key issues ...... 92
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APPENDICES
Appendix 1 Public Consultation and Disclosure Plan
Appendix 2 Issues and Responses Trail
Appendix 3 Stakeholders list
Appendix 4 Newspaper notices
Appendix 5 Newspaper articles
Appendix 6 Meeting proceedings
Appendix 7 Curriculum Vitae of team leader (Ms Stephanie van Zyl)
Appendix 8 Internal Review Report
Appendix 9 Comments and Response Trail
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ABBREVIATIONS AND ACRONYMS
BCLME Benguela Current Large Marine Ecosystem
BID Background Information Document
CBD Central Business District
CETN Coastal Environment Trust of Namibia
CSIR Council for Scientific and Industrial Research (South Africa)
DAPR Direct Application Phosphate Rock dwt Dead weight tonnage
DEA Directorate of Environmental Affairs
EA Environmental Assessment
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
EMA Environmental Management Act
EMP Environmental Management Plan
EPL Exclusive Prospecting Licence
HDPE High Density Polyethylene
I&AP Interested and Affected Party
IBA Important Bird Area
ICRP International Commission on Radiological Protection
IFC International Finance Corporation
IUCN International Union for Conservation of Nature
KDDP Kuiseb Delta Development Project kV kilo Volt
MAWF Ministry of Agriculture, Water and Forestry
MARPOL International Convention of the Prevention of Pollution From Ships
MET Ministry of Environment and Tourism
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MVA Megavolt ampere
MFMR Ministry of Fisheries and Marine Resources
MLR Ministry of Lands and Resettlement
MME Ministry of Mines and Energy
MR Main Road
MTI Ministry of Trade and Industry
MW Megawatts
MWTC Ministry of Works Transport and Communication
NDP3 National Development Plan 3
NACOMA Namibian Coast Conservation and Management
NGO Non-Governmental Organisation
NMP Namibian Marine Phosphate
PCDP Public Consultation and Disclosure Plan
PPP Public Participation Process
RA Roads Authority
Ramsar The Convention on Wetlands of International Importance
RED Regional Electricity Distributor
TOR Terms Of Reference
SANS South African National Standards
SEA Strategic Environmental Assessment
TSF Tailings Storage Facility
SSP Single Super Phosphate
TB Tuberculosis
UN United Nations
UNFCCC United Nations Framework Convention on Climate Change
UNCLOS UN Convention on the Law of the Sea
WBLA21 Walvis Bay Local Agenda 21
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WBM Walvis Bay Municipality
WBSR Walvis Bay Salt Refiners
WHO World Health Organisation
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1 INTRODUCTION
1.1 BACKGROUND
Namibian Marine Phosphate (Pty) Ltd (NMP) is developing the Sandpiper Project in Namibia. The project resource area lies approximately 160 km south of Walvis Bay and comprises a 2,233 km Mining Licence (ML170) and six Exclusive Prospecting Licences ( EPLs) covering 4,767 km2 that are held by NMP Figure 1:1. The project resource area includes a major part of the regionally mapped zone of phosphate mineralisation that occurs on the continental shelf south of Walvis Bay. The area incorporates a core zone of high phosphate concentration that occurs at water depths of 180-300m.
Figure 1:1: Locality of the marine phosphate deposit off the Namibian coast.
The intention is to mine these deposits using proven deep water dredging techniques. The material will be transferred to shore at Walvis Bay where minimal beneficiation is required to separate the phosphate sands from other marine sediments. The processed product is exportable in a particulate form as “phosphate rock” concentrate.
Notwithstanding the overall Sandpiper Project, its mining and beneficiation processes are distinct from one another, each following a different statuary process and with different roll-outs; the mining process to be implemented at sea, and the beneficiation process on land.
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1.2 ENVIRONMENTAL MANAGEMENT REQUIREMENTS
This EIA addresses activities related to the terrestrial component of the Project (i.e. the industrial beneficiation of the mineralised sediments recovered from the Mining Licence Area). These activities are listed as requiring EIA in terms of the Environmental Management Act (2007) and its Regulations (2012).
A separate EIA addresses the marine component of the Project, i.e. the activities to take place within the Mining Licence Area (the recovery of mineralised sediments), according to the requirements of the Minerals (Prospecting and Mining) Act, No 33 of 1992, which requires that an environmental contract be entered into with the Ministry of Environment and Tourism for such Mining Licence Area.
Accordingly two EIA processes have been registered separately with the Ministry of Environment and Tourism1. These EIAs will be submitted separately to the authorities for approval. However, in order to address the overall impacts of the Sandpiper Project, a Project Summary Report, including an assessment of the combined impacts of the project, will be included as part of the Terrestrial EIA. The terrestrial EIA will also include an overall socio-economic assessment of the project.
The marine EIA process is being managed by Jeremy Midgley and Associates. NMP appointed Enviro Dynamics cc to conduct the EIA for the land-based component of the project.
The environmental scoping phase for the land-based operations of the project has now been completed. The findings of which are contained in this report.
1.3 EIA TEAM AND TEAM LEADER
The EIA team consists of the following members:
Company/team member Area of expertise
Enviro Dynamics cc Environmental Assessment Practitioner Stephanie van Zyl Norman van Zyl
Enviro Dynamics cc Public participation, social & visual impact assessment Carla Saayman
Council for Scientific and Industrial Research EIA Review Consultant (CSIR) Patrick Morant
1Marine component registered 7th December 2010 and terrestrial component registered 24th November 2011.
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Company/team member Area of expertise
Council for Scientific and Industrial Research Sediment dynamics impact assessment (CSIR)
Andre Theron Dr. Hardus Diedericks
Moya-NILU Consulting (Pty) Ltd Air quality impact assessment Dr Mark Zunckel Atham Raghunandan
Quaternary Research Services (QRS) Archaeological impact assessment Dr John Kinahan
Biodata Consultancy cc Biodiversity impact assessment Dr. John Irish
Dr. Justine Braby Bird impact assessment
Geo Pollution Technologies Geohydrological impact assessment Pierre Botha
Pisces Environmental Services (Pty) Ltd Marine ecological assessment Dr. Andrea Pulfrich
Safetech Noise impact assessment Brett Williams
AquiSim Consulting (Pty) Ltd Radiation impact assessment Japie van Blerk
Burmeister & Partners (Pty) Ltd Transport impact assessment Theo Potgieter Adriaan van der Merwe Gert Maritz
The Green House Carbon emissions assessment Brett Cohen
The Curriculum Vitae of the team leader, Ms Stephanie van Zyl, is attached as Appendix 7.
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1.4 REPORT OBJECTIVES
This Scoping Report provides the following information:
A brief introduction to the project, its EIA requirements, and the Terms of Reference (TOR) for this EIA process (Chapter 1); A project overview, with particular emphasis on the planned land–based operations (Chapter 2); A legal review including the key regulatory requirements which affect environmental and social performance (Chapter 3); The findings of the public consultation and disclosure process followed so far (Chapter 4); An overview of the environment in which this project will be implemented, focusing on sensitivities (Chapter 5); and Key issues and the way forward for the EIA process (Chapter 6).
1.5 TERMS OF REFERENCE
The EIA is based on the Namibian Environmental Management Act (Act. No. 7 of 2007), and its Regulations (January 2012), as well as supporting policies and guidelines. Further compliance requirements include the Equator Principles as well as the International Finance Corporation (IFC) Standards. These international criteria prescribe social and environmental compliance requirements for consideration by the Corporation to consider financing a project.
The EIA for the entire project is being undertaken in two separate, yet integrated phases. The EIA process remains the same for both the marine and terrestrial investigations but the content and scope of these investigations are different. The common process comprises three phases, namely scoping, specialist studies and assessment of impacts.
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1.5.1 Scoping
Identify Interested and Affected Parties (I&APs); Announce the EIA process / registration of I&APs; Distribution of the Background Information Document (BID); Public and stakeholder consultation through electronic means, and public and focal meetings; Prepare a draft Scoping Report; Public review of the draft Scoping Report; and Prepare final Scoping Report and submit to the MET.
1.5.2 Specialist Studies
Conduct specialist studies to address issues identified during the scoping phase.
1.5.3 Assessment of Impacts
Establish the environmental risk of the overall project, its alternatives and various components; Establish mitigation protocols; Prepare the draft EIA Report and Environmental Management Plan; Public review of draft EIA and EMP; Prepare the final EIA and EMP and submit to MET; Await decision of the authorities; and Communicate the decision to I&APs and NMP
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2 PROJECT DESCRIPTION
2.1 INTRODUCTION
An extensive submarine deposit of calcium phosphate (francolite) has accumulated over geological time on the ocean floor about 60 km off the coast of Namibia between Walvis Bay in the north and Luderitz in the south. This deposit was first explored in the 1970s, subsequently the proponent took out seven Exclusive Prospecting Licences – EPL (each of 1000 km2) over core high grade areas of the deposit. Subsequently, EPL 3414 & portions of EPLs 3323 and 3415 of these were upgraded to a mining licence in 2011 The mining licence requires that an EIA and EMPR is prepared and an Environmental Contract is established with MET.
NMP has performed extensive sampling of these deposits which identified extensive resources. Metallurgical test-work has been performed on core samples from the deposit. Once a preliminary process had been developed, Pilot Plant work was carried out at Mintek in South Africa on a 260 tonne bulk sample recovered from the prospecting area to verify the viability of the process on a commercial scale. The results from the Pilot Plant have been used by the client for the design of a simple process for the commercial production of a phosphate concentrate containing 27.5 % P₂O₅.
Samples of the concentrate produced are being used to test the suitability of the product in the market. Tests are also being carried out to determine the suitability for the production of downstream products, namely, single super phosphate, phosphoric acid and fertilizer.
The key elements of the recovery and beneficiation:
The recovery of phosphate enriched marine sediments by means of a trailing arm suction hopper dredge. The transfer of the recovered sediments to a buffer pond on shore; The reclamation of the ore from the buffer pond by means of a utility dredge. The screening of the plus 1mm shell fragments from the ore at the buffer pond. The pumping of the -1mm slurry from the buffer pond to the treatment plant. The concentration of the incoming ore from an average grade of between 19% P₂O₅ and 20% P₂O₅ to a final concentrate containing 27.5% P₂O₅. The transfer of final product from the plant to the port for export initially by truck and ultimately by train or a conveyor system.
The first component of the project, the dredging, of phosphate ore from the offshore mining licence (ML170), was covered by the Marin EIA and the land based activities described above are covered in this assessment.
Initially, the concentrate is to be sold to the agricultural industry for direct application as well as to third party single super phosphate, phosphoric acid and fertilizer manufacturers. As Namibia’s infrastructure develops, the client intends to develop plants for the production of the beneficiated products within
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Namibia (i.e. single super phosphate fertilizer, phosphoric acid and complex fertilisers). Any such activity will preceded by a separate EIA.
The land based processes are described in more detail in the process overview and descriptions below.
2.2 PROCESS OVERVIEW
Once the dredger has filled the hoppers it returns to the buffer pond discharge site where it anchors and picks up the flexible discharge pipeline that is fixed to an anchored buoy. The material in the hopper is then re-suspended as a dilute slurry and pumped by means of the on board ships pumps to the buffer pond. Ore is reclaimed as slurry from the buffer pond by dredging, and the plus one millimetre shell grit is screened out before the ore is pumped via a 27 km pipeline to the processing plant located east of Walvis Bay. The particle size of the ore slurry is less than 1mm in diameter. The screened shell grit either could be stockpiled at the buffer pond, or be deposited at the low tide mark in thin layers to be returned to the ocean by natural wave action if this alternative is proven to be environmentally sustainable. At the processing plant the ore slurry is de-slimed and the fine clay particles separated from the slurry by hydro cyclones. The de-slimed material is then passed over separation spirals where the fine shell material is removed. The resulting concentrate is then polished in attritioners and once again de-slimed. The resulting concentrate is filtered, washed, dried and stockpiled in a covered stockpile. Slimes and gravity tails are thickened, and discharged into a tailings dam on the plant site. Clean fresh water is required to wash the last vestige of salt water from the filtered concentrate. This water will be obtained from the discharge of the municipal sewage system as well as from a desalination plant that could be installed by the client. Excess from the fresh water system can either be discharged into the salt water circuit or to the bird sanctuary, should salinity levels permit. The product will be transported, either by road, train, or by a conveyor which will follow the railway tracks, to the Port at Walvis Bay. At the Walvis Bay port the product will be stored in silos prior to export to international markets.
It is planned to increase the production of concentrate from 1 million tonnes per year in Year 1, to 2 million and 3 million tonnes per year in years 2 and 3 respectively. The deposit has a resource which will last about 100 years at that rate, although the current plan is for a 20 year mine-life in line with the issued Mining Licence.
NMP’s investment to date on exploration and testing is approximately US$4.1 million. According to the Economic Scoping Study completed in late 2010 the shore facilities including process plant are expected to cost around US$140 million. Operating costs are expected to be approximately US$330 million per year. The plant will employ 300 to 400 workers during the construction phase and is expected to employ some 139 people on a permanent basis.
The operation will make use of local suppliers and contractors, pay port charges, and corporate taxes, thereby bringing significant benefits to the community of Walvis Bay and to Namibia as a whole.
NMP is well aware of its environmental obligations with respect to both the marine and land aspects of the project. It is NMP’s policy and aim, in all of the activities in which it engages, to achieve high
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international standards for environmental protection and also for the health and safety of its employees and other stakeholders.
2.3 ORIGIN AND COMPOSITION OF THE ORE BODY
The Sandpiper deposit is thought to have originated from the rapid precipitation of apatite in the phosphate enriched upwelled oceanic bottom water of the Benguela Current that became trapped in subtropical coastal lagoons or estuaries at a time when the sea level was much lower than at present. Reworking of the sediment in numerous subsequent sea level fluctuations washed away the finer material leaving the coarser pelletal phosphate enriched sediments. The concentrate layer varies up to several metres thick in places and occurs on the seafloor at depths of 180 – 300m. The upper layer of the phosphate deposit contains significant amounts of shelly material, while the lower layer, generally deeper than about 0.50 metres, is much less shelly. The phosphate deposits generally lie on a clayey base layer (footwall) (See Figure 2:1).
Figure 2:1: Sandpiper ore sample (as received at Mintek). Left image: ore as it is recovered from the sea floor. Right image: Shell material as screened out at the buffer pond.)
The average phosphate content of the Sandpiper deposit is 18 – 20 % phosphate (P2O5). The world
market requirements for fertilizer are in the order of 27 – 30 % P2O5. Therefore the material needs
to be processed on shore at Walvis Bay to increase the concentration of P2O5 . The great majority of the phosphate-bearing particles occur in the minus 1 mm to 0.1 mm size range, allowing
concentration to around 28 % P2O5 without expensive grinding or chemical treatment.
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Figure 2:2: Sandpiper -1.0/+0.1m Concentrate (Spherical black particles are the phosphate mineral and the lighter material is shell fragments. The clear material is silica.) Photo by SGA of
Germany. Figure 2:2 above shows a magnified photograph of the small black pellets of phosphate, mixed with shell and a little silica sand. This material has already had the plus 1mm shell grit and the minus 0.1mm slimes washed out.
2.4 USES OF PHOSPHATE ORE
Phosphate ore is primarily used in various forms as fertilizer. Some phosphate rock, including the Sandpiper concentrate, is sufficiently reactive that it can be applied directly to the soil to assist the plants to grow. This is known as Direct Application Phosphate Rock (DAPR). The market for this material is growing rapidly as remote (tropical) areas of the world become growers of biofuel crops.
A higher value fertilizer is Single Super Phosphate (SSP) which is produced by mixing the phosphate concentrate with concentrated sulphuric acid to make a granulated paste.
Even higher value downstream processing involves dissolving the phosphate in sulphuric acid at high temperature to produce phosphoric acid which is then concentrated by evaporation. The phosphoric acid is treated with ammonium to produce ammonium phosphate fertilizers or purified to produce food grade phosphoric acid which is used as a preservative in the food industry.
Initially Sandpiper ore will be sold as rock phosphate concentrate for various applications. However, it is planned that downstream processing of the concentrate into a refined range of fertilizers and phosphoric acid will be added. This further development depends upon infrastructure development such as the development of Walvis Bay’s port facility and electrical power supply, and falls outside of the scope of this EIA.
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2.5 LOCALITY OF THE LAND BASED ACTIVITIES
2.5.1 Site alternatives
A number of sites were considered for the discharge of the dredged slurry to shore, the pipeline and coastal buffer pond and ancillary works. The site selection process was done in conjunction and with guidance of the Walvis Bay Municipality. These are presented inTable 2:1 below.
Table 2:1: Site alternatives considered for the discharge of slurry to shore, the pipelines and coastal buffer ponds and ancillary works.
Site Opportunities Constraints
North of Walvis Bay Port Close to the harbour for Draught of loaded vessel export (15.15m) and shoaling sea bottom, vessel between 1.5 & 2 km offshore Town urban ribbon development along coastline to Langstrand Apparently insufficient area for buffer pond Perceived visual impact
South of the town of Available space Buffer pond cannot be on the Walvis Bay, east of the salt works mining Accessible to vessel same site due to ore pumping constraints. licence area Removed from urban
development Access to dredging vessel Length of pipe line to buffer pond, to traverse salt works area. Road access to the area Archaeological and anthropological sensitivities on the pipeline route to the buffer pond south of the salt works. On top of/close to Kuiseb River Mouth
South of the town of Available space Length of services access route. Walvis Bay, south of salt works mining licence Accessible to vessel Limited access area (likely to be the Removed from urban Access to Sandwich Harbour position of the buffer pond only) development should be ensured. In the Namib Naukluft National Park
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The preferred site for ore transfer to land and for the holding pond is just south of the mining licence of the Walvis Bay Salt Works since it is expected to have the least environmental and technical constraints. The site must however still be positioned according to local environmental sensitivities identified during the EIA process.
With regards to the processing plant, the site east of the municipal sewage works has provisionally been selected in consultation with the Walvis Bay Municipality (see Table 2:2). The exact location of the site may be moved so that nuisances to neighbouring activities and the bird sanctuary are minimized. Notwithstanding the provisional support of the site by the Walvis Bay Municipality, the final position will be guided by the EIA process.
Table 2:2: Criteria for Selection of Site for the Processing Plant
Site Opportunities Constraints
East of Dune 7 Removed from Travel distance to the port residential areas Pipeline distance from buffer pond Insufficient space for plant tailings Treatment water pumping distance Product transport infrastructure crossing existing arterial routes Visual Impact – Dune 7 a tourism attraction
West of Dune 7 Insufficient space for plant tailings Travel distance to the port Pipeline distance from buffer pond Treatment water pumping distance Product transport infrastructure crossing existing arterial routes Adjacent to residential areas
South of Municipal Close to water Dust / odours / smells and proximity to waste water resource residential areas treatment plant Difficult to access.
East of Municipal Close to one of the Next to proposed eco-tourism site and bird waste water water sources sanctuary treatment plant Available space Land ownership is split between State and Zoned light industrial Municipality (According to Transport access to the port problematic via Municipality) existing arterial routes. Site selected in Pipeline distance from buffer pond. consultation with Shallow groundwater limits the carrying capacity Walvis Bay authority of the soils and is sensitive to pollution. No other sensitivities in terms of archaeology, habitat.
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Kuiseb River Delta
Figure 2:3: Google Image of Walvis Bay and proposed location of buffer ponds and processing plant
Figure 2:3 is a locality map and a more detailed Google image of the Walvis Bay area showing the approximate intended sites for the buffer pond (south of the salt works) and the processing plant near Walvis Bay.
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2.6 PRODUCTION ESTIMATES
The key production target figures are as presented in Table 2:3 below. The plant is designed to produce
3.0 million tonnes of concentrate (28 % P2O5) per year. The production will be stepped up as shown to meet the projected marketing plan.
Table 2:3: Sandpiper Phosphate Production Estimates
Year 1 Year 2 Year 3 - 20
Concentrate Production (million tonnes/ year) 1.0 2.0 3.0
Dredge Utilization (weeks/year) 11 to12 22 to 24 33 to 36
Pumping Utilization (hours/day) 8 16 24
Process Utilization (hours/day) 8 16 24
Tonnes of Shell Grit/day (approx) 500 1,000 1,500
Tonnes of Slimes to Tails Pond/day (approx) 850 1,700 2,500
Tonnes of Phosphate Product/day 3,800 7,600 11,400
2.7 PROCESS DESCRIPTION
2.7.1 Transfer of ore to shore
The dredger sails to shore, anchoring at least 1 km off the beach south of the salt works in the vicinity of the Namib Naukluft National Park border. Once anchored on station the ship picks up the summerged flexible pipeline that is connected to an anchored buoy. The 70 000 tonnes of material in the ship’s hoppers are then fluidised by means of sea water sucked into the ship by on board pumps. The ore is pumped ashore to the buffer pond in the form of dilute slurry (10% solids). The buffer pond is situated in the hummock dunes south of the present day Kuiseb River Delta (Figure 2:3). The solids settle in the buffer pond and the excess water will be pumped back to the sea or will be allowed to flow across the beach into the intertidal zone.
Once the discharge process has been completed the ship will return to the mining area to start the next dredging cycle. Each complete cycle is expected to take 95 hours.
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2.7.2 Land based activities
a) General The complete system is depicted in Figure 2:4 and the land based system is shown in Figure 2:5 and Figure 2:6 below.
Dredge the deposit 5.5Mt Transport the slurry Transfer the slurry to shore dredged PA 125,500t solids per campaign 1 Transfer every 3 days week
Retain in holding pond Pump Station- Pipeline Processing & stockpiling Capacity 1,590,000m3 Transfer Process flow approx 12,500t / Foot print 360,00m2 day
Transporting final product Bulk loading & export 3 Mt shipped PA
Figure 2:4: The Mining Development Concept
Figure 2:5: The On-Shore Processing Concept
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Figure 2:6: Flow Diagram of Land Based Processes
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The mass balance associated with the processing components shown in Figure 2:6 above is shown in Table 2:4 below.
Table 2:4: Generalised Mass Balance for Land Based Activities
Material Flow in Tons per Day
Concentrate Production 1 million tpa 2 million tpa 3 million tpa
Run of Mine Ore recovered from buffer pond tons per 5 150 10,300 15 400
Shell fragments to be discarded at buffer pond 500 1,000 1,500
Material pumped to plant site 4,650 9,300 13,900
Slimes and tailings discard 850 1 700 2,500
Concentrate Produced 3,800 7,600 1, 400
b) Shore Buffer Pond
The Shore Buffer Pond will receive the dredged ore from the dredger a pipeline into the ponds. The buffer pond has a threefold role, namely;
the storage of solids as the mining rate of the ore is much higher than the processing rate; the separation of solids from the excess water during the dredger discharge; and the storage of sea water for the use by the plant between dredger campaigns.
To fulfil the above purposes the buffer pond is designed to store up to 1.6 million tonnes of solids and 900 000 cubic metres of sea water. It is designed to contain about one million tonnes of ore.
The ore is reclaimed from the Buffer Pond by means of a floating, diesel powered utility dredger.
Excess water from the buffer pond will return to the sea (either across the beach or via the dredge submerged pipeline). The water balance for the buffer pond is shown in Table 2:5 below.
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Table 2:5: Sea Water Management at the Buffer Pond
Water Management at the Buffer Pond
Production tonnes concentrate per annum 1,000,000 2,000,000 3,000,000
Weeks required for dredging operation 11 23 34
Hours available for discharge to sea per week 130 130 130
Water Storage Requirement m³ 696,377 729,338 599,659
Water to be discharged during Dredging m³ 3,170,070 7, 167,261 10,795,971
Water to be discharged during Dredging m³/week 276,937 313,066 285,302
Water to be discharged during Dredging m³/hr 2,130 2,408 2,418
The shore buffer pond site will also house a screening plant to remove the +1mm shell detritus and a slurry pump station which will then transfer the screened ore to the processing plant via a 27km Pipeline. The power requirement at the buffer pond will be 6MW which will be supplied by NamPower by means of a 132 kV 15MVA overhead power line from the nearest substation. A layout of the shore buffer pond is given in Figure 2:7 below.
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Figure 2:7: Buffer Pond Layout(Source: Lithon Engineering)
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c) Screening and shell disposal
Slurry from the buffer pond is pumped to two vibrating screen decks where the shell grit (larger than 1 mm) falls onto a conveyor belt for stacking in an intermediate stockpile. The slurry which passes through the screen falls into a hopper for pumping to the processing plant. In order to handle the planned tonnage, two screen decks will operate side-by-side.
An ongoing study is investigating potential markets for the shell grit which is very high in calcium carbonate (CaCO3), which for example, is the feedstock for lime and cement-making.
The shell material will be stacked in a permanent stockpile with an approximate height of 3m, covering an area of up to 150 ha. This stockpile will increase by of 3,000 tonnes a day and will require six trucks to deposit screened shell on the stockpile.
The stockpile is positioned immediately to the west of the buffer pond, in the southernmost part of the Kuiseb Delta seasonal floodplain.
The spreading of the shells in thin layers on the shore-line for the waves to return them to the sea will be investigated as an alternative to dispose of the shell. d) Pumping
A set of three piston diaphragm pumps running in parallel will transfer slurry at a 1,000 m3/hr up a 300mm pipeline. The pipeline is constructed from 9 mm carbon steel lined with polyurethane to protect it against wear from the slurry particles. The pumping operation uses 5.0 megawatts (MW) of electrical power.
The pipeline route runs inland from the coast to the south of the Kuiseb Delta and travels 27km from the buffer pond south of the salt works to the processing plant to the east of Walvis Bay (see map above). The pipeline will be supported above ground so that regular maintenance inspections can easily be made and so that wind-blown sand can pass underneath. e) Process Plant
A flowsheet of the process plant is given in Figure 2:6 and the layout in
Figure 2:8, below. The plant consists of the following sections:
Concentation and Drying; and Tailings Handling and Storage.
These sections are described below.
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Figure 2:8: Process Plant Layout (Source: Lithon Engineering)
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i) Concentration and Drying
The slurry is pumped into a distributor box at the processing plant and then into a cluster of hydro- cyclones where the minus 0.1 mm slimes are separated. The cyclone underflow is passed over several banks of gravity spirals to remove as much remaining shell grit as possible. The concentrate from the gravity spirals is transferred to an attrition cell where the action of a high shear agitator breaks down any remaining shell and polishes any remaining clay from the phosphate particles. The attrition cell discharge is pumped to a second cluster of hydrocyclones to remove the slimes generated.
The cleaned concentrate is transferred to two side-by-side horizontal vacuum belt filters where vacuum pumps remove most of the sea water. Clean freshwater is sprayed on the end of the filter to wash out the last of the salty water. The fresh water requirement for this process is given in Table 2:6 below.
Table 2:6: Fresh Water Requirement at the Plant Site
Fresh Water Requirement at the Plant Site
Production tons of Concentrate per Annum 1,000,000 2,000,000 3,000,000
Plant Operating Hours per Day 8 16 24
Fresh Water Requirement Cubic Metres per Hour 320 320 320
Fresh Water Requirement Cubic Metres per Day 2,560 5,120 7,680
Fresh Water Requirement Cubic Metres per Month 77,824 155,648 233,472
The fresh water once used will be incorporated into the plant salt water circuit. Should this water be of a suitable maximum salinity level in it could be discharged to the immediate environment (Bird Sanctuary).
The excess process water from the plant (mainly salt water) will be returned to the buffer pond where it will be reused in the screening and pumping circuit.
The clean filter cake is conveyed to an intermediate stockpile. It is reclaimed from the stockpile and conveyed into a dryer (either a rotary dryer or a flash dryer) and dried to about 3 % moisture content. Heat for the dryer is produced by burning diesel or heavy fuel oil depending on suitability and availability.
ii) Tailings
The slimes and shell grit from the gravity spirals are pumped to a thickener. A flocculant is added to help the slimes to settle into thick slurry. The clear sea water is returned to the concentrator for re-use.
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Excess water is pumped down an HDPE pipeline following the same route as the slurry pipeline, back to the Buffer Pond for re-use.
The thickened slurry is pumped to a tailings pond located at the plant site (Figure 2:8). There the slurry consolidates and any clear water is returned to the concentrator.
A Tailings Storage Facility (TSF) will be designed which is suitable for the initial life of mine of 20 years. The TSF will hold both the grit (coarse) and slimes (fines). The TSF will be lined should the geohydrological and geotechnical investigations so determine.
Two construction methods are being considered for the TSF, namely the downstream and upstream methods. The final method will be selected once more details of the tailings material are known. The construction method will also determine the design geometry of the TSF. h) Transport to the harbour
The finished product will be stored on a covered stockpile at the processing plant and will be transported to a buffer storage facility in the port as needed by the shipping schedule. In the initial period, during which 1million tons are being produced, road trucks will be used for the purpose. This will involve 126 truck-loads per week day. To accommodate increased production the use of 21 truck freight trains or a conveyor system are being investigated. The use of rail is a viable alternative and will involve the erection of a Road over Rail Bridge so that a siding can be constructed from the existing rail line, under the airport road to the plant. In addition NMP will have to purchase 30 wagons and two locomotives. The conveyor system could follow the existing rail reserve from the plant site to the Port. This will involve complex engineering as the conveyor will have to pass under the intersections where there are currently level crossings. These alternatives are currently being evaluated in detail by Lithon.
2.8 INFRASTRUCTURE REQUIREMENTS
2.8.1 Roads
A hard-surfaced dirt road will built along the pipeline route for access to the pipeline and to carry men and materials to the Buffer Pond site. At present the only access is by 4 x 4 vehicles along the beach which is inappropriate to move men and materials. The road will be routinely maintained by water binding and grading.
2.8.2 Power
Eight megawatts of electrical energy are required at the buffer pond site. This will be supplied by an overhead 132kV 15MVA power line. Negotiations with NamPower are in an advanced stage for the supply of this power. A further 5 megawatts of electrical energy is required at the processing plant which will be supplied by a branch from the above power line.
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2.8.3 Water
A small quantity of potable water for drinking and showering will be drawn from the water line which supplies fresh water to Walvis Bay. This existing line runs very close to the processing plant.
The first stages of processing use sea water delivered with the slurry via the ore pipeline. Excess sea water is pumped via a separate HDPE pipeline back to the buffer pond.
Fresh water is required to wash the salt from the filtered product. The washing imparts a slight salinity to the water; therefore the water is re-used several times in the washing cycle. It could either be returned to the sewage plant wetlands provided the salinity is less than 10ppt or added to the excess water being returned to the buffer pond. This washing process requires 320 cubic metres of fresh non- potable water per hour (see Table 2:7). The fresh water will be obtained from various sources (including the effluent from the sewage treatment plant) and will be stored on the site, prior to its use, in a 23 000 cubic metre reservoir.
Semi-purified fresh wash water is available from the Walvis Bay sewage treatment facility. The suitability and the sustainable use of this water are being studied by the client. Other alternatives for the supply of fresh water are being investigated. These are:
a dedicated desalination plant; pumping from existing mines; and use of existing desalination plants.
2.8.4 Waste water and sewerage
All wastewater from the concentration process can be grouped into two streams namely:
clean excess sea water that will be returned to the buffer pond, and concentrated slurry of slimes and thickener. The tailings consist of clays and flocculants (thickener) which will be stored in a tailings pond.
The domestic waste generated in the washrooms and showers at the Buffer Pond will be discharged into septic wells. Alternatively a small, self-contained plant will treat the sewage and discharge treated water into soak wells. The processing plant will be connected to the municipal sewerage system.
2.9 MANPOWER ESTIMATES
The estimate for manpower takes into account that there will be people working at the buffer pond and at the processing plant respectively (Table 2:7). Dock workers are not included in this number, nor are the dredging contractors. The administration office will be located at the processing plant.
The manpower estimate includes maintenance tradesmen on shift; however, no on-site workshop has been included. It is envisaged that major repairs and shut-downs will be contracted to local independent maintenance contractors.
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The estimate also takes into account that during the first couple of years the plant will be running intermittently. Full production is envisaged in year 3.
Table 2:7: Manpower Estimates
Year 1 Year 2 Year 3 - 20
Number of Shifts/Day 1 x 8 hrs 2 x 8 hrs 3 x 8 hrs
Management 7 7 7
Operators 21 35 56
Technicians 6 9 12
Labourers 20 35 60
Total 54 86 135
2.10 DEVELOPMENT SCHEDULE
NMP has a team of dedicated specialist consultants from Namibia and around the world working to finalize a definitive Feasibility Study (DFS) by the end of the first quarter of 2012. Providing the project proves to be financially viable, and providing environmental and operating permits are in place, the purchasing of major items will commence in 2012, followed by construction in 2013, with commissioning taking place in early 2014.
2.11 LATEST CHANGES TO THE PROJECT
Since the presentation of this project to the public in November 2011 and final consideration of the issues by the specialists at a workshop held in January 2012, there have been a number of critical changes to the project. These changes are presented here, with a view to inform the reader that they are being incorporated into the EIA process, by changing the appropriate specialists’ Terms of Reference (TOR) where required.
2.11.1 Pipeline route and processing plant site locality
The former western route is costly to build therefore an eastern alternative is also being investigated. The additional route will be investigated by the specialists where appropriate. Furthermore, the exact position of the processing plant site is still to be determined. Even though alternative site locations will be considered in the following phase of the EIA, the current site location needs to be optimised to ensure compatibility with surrounding land uses. Town planning matters also need to be considered in the final layout and locality of the site, such as access, land ownership and statutory processes required. The final site location is likely to be approximately south of the original terrain allocated as shown in .
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Figure 2:9: Pipeline route alternatives being investigated.
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2.11.2 Transport routes
The transport routes being investigated to convey the product from the processing plant to the harbour are depicted in Figure 2:10 below.
2.11.3 Freshwater source
The freshwater requirements have increased significantly from the original estimates. The latest estimated fresh water requirement is provided in Pa 2.8.3.
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Figure 2:10: Transport route alternatives being investigated.
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3 THE LEGAL ENVIRONMENT
A summary of all pertinent international and national standards, guidelines, policies and laws that are of relevance to the NMP Project is presented in Table 3:1 below. The column furthest to the right in the table provides an indication of the relevance of each legal instrument to this project. These instruments will be studied in greater depth for specific relevance during the full investigation phase of the EIA.
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Table 3:1: Summary of Relevant Environmental and Social Legislation.
Theme Instrument and contents Application to the NMP project
International Legislation, Treaties, standards and guidelines
International IFCs overall policy on Environmental and Social Sustainability with the following If NMP is to apply for funding Finance Corporation specific Performance Standards: (IFC) internationally, then these standards Social and Environmental Assessment and Management Systems need to be adhered to. Labour and Working Conditions Pollution Prevention and Abatement Community Health, Safety and Security Biodiversity Conservation and Sustainable Natural Resource Management Cultural Heritage
Equator Principles The Equator Principles require that an environmental and social impact If international funding is sought, then assessment addresses key social and sustainable environmental requirements. NMP will have to demonstrate its adherence to these requirements.
Convention on Details the preservation of rare and endemic species, Namibia is a signatory to this Sites which are likely to affect biological Biological Diversity convention. Ratified by Namibia in 1997. Article 14 requires that EIAs are carried Rio de Janeiro diversity to be identified and assessed (1992) out for projects that are likely to adversely affect biological diversity, avoid or and the impacts avoided or minimized. minimize such effects, and where appropriate, allow for public participation.
Maritime Law UN Convention on the Law of the Sea, 1982 (UNCLOS) All potential activities which could result Part XII, Article 192: ‘States have an obligation to protect and preserve in pollution of the marine environment the marine environment’. need to be identified, and potential pollution impacts assessed and avoided Article 194(2) requires States to take necessary measures to ensure that or mitigated as necessary. activities under their jurisdiction or control do not “cause damage by
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Theme Instrument and contents Application to the NMP project
pollution to other States and their environment” and to take measures to Include all necessary precautions in the minimise “the release of toxic, harmful or noxious substances, especially EMP. those that are persistent, from land based sources, from or through the atmosphere, or by dumping” (Article 194(3)(a)), as well as “pollution from vessels, installations and devices used in exploration or exploitation of the natural resources of the seabed and subsoil” and “pollution from other installations and devices operating in the marine environment” (Article 194(3)(b)). Article 196 requires states to take necessary measures to “prevent, reduce and control pollution of the marine environment resulting from the use of technologies under their jurisdiction or control, or the intentional or accidental introduction of species, alien or new, to a particular area of the marine environment, which may cause significant and harmful changes thereto”.
Climate Change United Nations Framework Convention on Climate Change (UNFCCC) (1994) Consider how this project could Sets an overall framework for intergovernmental efforts to tackle the potentially affect and be affected by challenge posed by climate change. It recognizes that the climate system Climate Change. is a shared resource whose stability can be affected by industrial and other emissions of carbon dioxide and other greenhouse gases. Under the Convention, governments: gather and share information on greenhouse gas emissions, national policies and best practices launch national strategies for addressing greenhouse gas emissions and adapting to expected impacts, including the provision of financial and technological support to developing countries cooperate in preparing for adaptation to the impacts of climate change.
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Theme Instrument and contents Application to the NMP project
Namibia is a signatory to this convention
Marine pollution Convention on the Prevention of Marine Pollution by Dumping of Wastes and Potential pollution sources to sea to be Other Matter (London Convention 1972) identified and prevented as part of the Controls and prevents marine pollution. Dumping is identified as “the deliberate EIA and the necessary precautions disposal at sea of wastes or other matter from vessels, aircraft, platforms or other included in the EMP. manmade structures.” United National Law of the Sea Convention (1982) Part XII deals with marine pollution. Article 192 states that “states have an obligation to protect and preserve the marine environment.” Article 194 requires states to take the necessary measures to ensure that activities under their jurisdiction or control do not “cause damage by pollution to other States and their environment; to take measures to minimise “the release of toxic, harmful or noxious substances, especially those that are persistent, from land based sources,….”and “pollution from other installations and devices operating in the marine environment.” International Convention of the Prevention of pollution from Ships (MARPOL 73/78) Although Namibia is not a signatory of MARPOL, its guidelines are applied by Namport as in internal policy. Annex 1 of MARPOL provides regulations for the prevention of pollution by oil, Annex 1V deals with prevention of pollution by sewerage from ships and Annex V with the prevention of pollution by garbage from Ships. Convention on the Prevention of Marine Pollution by Dumping Wastes
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Theme Instrument and contents Application to the NMP project
and Other Matter (London Convention, 1972) Contributes to the international control and prevention of marine pollution. In 1986, a special set of guidelines for dredged material was adopted as part of the Convention. These, now known as the Dredged Material Assessment Framework (DMAF), provide a clear set of guidelines for dredging and disposal operations to ensure that these are carried out to limit environmental damage. It includes land based disposal and treatment options (not part of the original convention). Although a Signatory, Namibian has not yet ratified the agreement.
Standards for International Atomic Energy Agency The radiation specialist will consider radiation protection International Commission on Radiological Protection these standards where applicable in World Health Organization conjunction with local standards for conducting the specialist radiation study.
The necessary management actions need to be included in the EMP.
Noise standards SANS (South African National Standards) 10103:2008 Version 6 -The measurement In the absence of local legislation with and rating of environmental noise with respect to annoyance and to speech respect to noise, the specialist will use communication. the SANS and other standards for his SANS 10328, Methods for environmental noise impact assessments. assessment. SANS 10357, The calculation of sound propagation by the Concawe method. The necessary management actions need World Bank Guidelines on Pollution Prevention to be included in the EMP. International Finance Corporation – 2007 General EHS Guidelines: Environmental Noise.
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Theme Instrument and contents Application to the NMP project
Air quality World Health Organisation ambient air quality guidelines. In the absence of Namibian standards for guidelines air quality, the WHO guidelines will be used by the specialist.
The necessary management actions need to be included in the EMP.
Water quality The Department of Water Affairs uses a Draft set of water quality standards for A set of water quality objectives need to guidelines effluent to be discharged or disposed of in areas with potential for drinking water be compiled for this project which would source contamination; international rivers and dams and in water management best protect the receiving environment. and other areas. These are used as their standard under the Water Resources The necessary management actions need Management Act. South Africa is the only African country with an official set of to be included in the EMP. water quality guidelines for land based and coastal marine waters. These guidelines provide such guidelines, but they are not exhaustive and need to be supported by best available international guidelines, such as those developed by the Benguela Current Large Marine Ecosystem (BCLME) (see below). Water and Sediment Quality Guidelines for the coastal zone of the BCLME A set of recommended water and sediment quality guidelines for a range of biogeochemical and microbiological quality variables, in order to sustain natural ecosystem functioning, as well as to support designated beneficial uses, in coastal areas of the BCLME region.
Namibian National Legislation
Namibian General human rights – eliminates discrimination of any kind. Ensure these principles are enshrined in the Constitution The right to a safe and healthy environment. Documentation of the NMP Project. Affords protection to biodiversity.
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Theme Instrument and contents Application to the NMP project
General Environmental Management Act (2007), Regulations (February 2012): Conduct public participation as part of Environmental and Social Protection Requires that projects with significant environmental impact are subject the EA process as described in the act and Social and to an environmental assessment process. and regulations. Environmental Requires for adequate public participation during the environmental Conduct an EIA which covers all the Assessment and Management assessmentt process for interested and affected parties to voice their components of the project which are Systems opinions about a project. listed in Schedule 5 of the EMA (2007) According to Schedule 5th the manufacturing and processing and and the Regulations (2012)., as well as associated activities, including waste sites, public roads,, structures below the under Section 50 of the Minerals the high water mark of the sea, conveyors, and abstractor of water for (Proespecting and Mining) Act no 33 of commercial purposes trigger the requirement for EIA. 1992. Minerals (Prospecting and Mining) Act No 33 of 1992 Section 50(i) “an environmental impact assessment indicating the extent of any pollution of the environment before any prospecting operations or mining operations are being carried out and an estimate of any pollution, if any, likely to be caused by such prospecting operations or mining operations” Even though these are the precessing activities of the operation, accessory works are mentioned under definitions of the Act.
Waste Management Hazardous Substances Ordinance 14 of 1974: Consider waste management options for legislation Control of substances which may cause injury or ill-health or death of the NMP Project. human beings because of their toxic, corrosive, irritant, strongly Identify hazardous substances disposed sensitizing or flammable nature. of during construction and operation and Pollution Control and Waste Management Bill: identify practical handling and disposal Aims to prevent and regulate the discharge of pollutants to air, water, options. land, and will regulate noise, dust and odour pollution. Further aims are Waste management options are to be to establish a system of waste planning and management, and to enable considered and included in the EMP.
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Theme Instrument and contents Application to the NMP project
Namibia to comply with its obligations under international law.
Biodiversity Article 95 of the Constitution of the Republic of Namibia: Identify the existence of any protected instruments “maintenance of ecosystems, essential ecological processes and biological diversity of plants and habitats of conservation Namibia and utilization of living natural resources on a sustainable basis for the benefit concern to be addressed in the EIA. of all Namibians, both present and future”. List applicable biodiversity compliance Forest Act 12 of 2001: issues in the EMP. Provision for the protection of various plant species. Section 22(1): It is unlawful for any person to “cut, destroy or remove any living tree, bush or shrub growing within 100 metres from a river, stream or watercourse on land that is not part of a surveyed erf or a local authority area without a licence. Nature Conservation Ordinance 4 of 1975: Protects inter alia nature reserves, conservancies, the hunting and protection of wild animals, and the protection of indigenous plants. Prohibits disturbance or destruction of the eggs of huntable game birds or protected birds without a permit. Requires a permit for picking (the definition of “picking” includes damage or destroy) protected plants without a permit. Preservation of Trees and Forests Ordinance: Protection to tree species. Protects geological, archaeological, historical and other objects of scientific interest in a National Park.
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Theme Instrument and contents Application to the NMP project
Heritage National Heritage Act (2004): Identify areas with archaeological All heritage resources to be identified and either protected or removed/mitigated with potential. Conduct further a permit from the National Monuments Council, before any development may take archaeological assessment if required. place. Heritage assessments undertaken as part of the environmental assessment process. Even though this is the key instrument protecting heritage, the Nature Conservation Ordinnance (1975) also affords protection to archaeological material in National Parks.
Labour, Working Labour Act (1992): Include health and safety regulations in Conditions and Employment Health and Safety Regulations. the EMP. Minimum wages and working conditions including health and safety Ensure that minimum wage and working measures. conditions are stipulated in the contract.
Affirmative Action (Employment) Act 29 0f 1998. Article 9 of the Namibian Constitution.
Public Health and Public Health Act 36 of 1919: Identify sites where potential pollution radiation protection Provides for the prevention of pollution of public water supplies. may occur, introduce mitigation Atomic Energy and Radiation Protection Act (Act No. 5 of 2005), measures where needed. Regulations for Protection Against Ionizing Radiation and Safety of The acts and standards pertaining to Radiation Sources (Ministry of Health and Social Services, 2008) radiation will be used by the radiation specialist to consider whether the set Regulations for the Safety and Secure Management of Radioactive Waste limits are exceeded, in which case the (Ministry of Health and Social Services, 2008) required studies and procedures will be put in place for protection of the public and the workforce. The necessary compliance measures are
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Theme Instrument and contents Application to the NMP project
to be included in the EMP.
Civil Aviation Annex 14 to the Convention on International Civil Aviation. The Civil Aviation Authority of Namibia Chapter 4: Obstacle restrictions and removal needs to be consulted to establish the Chapter 6: Visual aids and identification of obstacles need for further civil aviation assessment.
Water Resource The Water Resources Management Act (2004) is presently without regulations; Obligation not to pollute surface water Management therefore the Water Act No 54 of 1956 is still in force. bodies. A permit application in terms of Sections 21(1) and 21(2) of the Water Act The following permits are required in is required for the disposal of industrial or domestic waste water and terms of the Water Act: effluent. water abstraction permits; Section 23 (1): Prohibits the pollution of underground and surface water domestic effluent discharge permits (site bodies. offices, construction camp); Section 23 (2): Liability of clean up costs after closure/ abandonment of industrial effluent discharge permits; an activity. water use for dust suppression; and Protection from surface and underground water pollution. water reticulation permits (pipelines).
Marine Resources The Marine Resources Act 27 of 2000 The act is administered by the Ministry of Fisheries and Marine Resources (MFMR). The MFMR administers this act and is responsible for regulating all activities below the high water mark that may affect the marine ecological environment. Provides for the conservation of the marine ecosystem; for the responsible utilization, conservation, protection and promotion of marine resources on a sustainable basis. Section 52 states: “Any person who discharges in or allows to enter or
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Theme Instrument and contents Application to the NMP project
permits to be discharged in Namibian waters anything which is or may be injurious to marine resources or which may disturb or change the ecological balance in – any area of the sea, or which may detrimentally affect the marketability of marine resources, or may hinder their harvesting, shall be guilty of an offence and liable on conviction to a fine not exceeding N$500 000.” Section 52 (3) (f) states: “Any person who kills or disables any marine animal by means of any explosive, poison or noxious substance, or by means of a firearm except as may be prescribed, shall be guilty of an offence and liable on conviction to a fine not exceeding N$ 500 000.” National Shellfish Sanitation Programme (to be gazetted) To regulate the harvest and sale of shellfish to safeguard the public health from the consumption of contaminated shellfish.
Port Control Namibian Ports Authority Act 2 of 1994 Include the activities at the port in the Gives Namport the responsibility of protecting the environment within EIA, identify ways of preventing and the port limits. Namport, has implemented a pollution tariff applicable to managing pollution at the port. soil, water and air pollution. The pollution tariff was implemented with Include the necessary management effect from 2003. actions in the EMP.
Parks Management The Nature Conservation Ordinance (1975) as amended through the Nature Application to be made to the Parks Conservation Amendment Act of 1996. authority for the establishment of the Controls development and activities within Namibia’s National Parks. NMP facilities in Dorob and Namib Permission from the Parks Authority is required for the erection of any Naukluft National Park. industries and associated facilities in the Dorob and Namib Naukluft Relevant Regulations to be included in National Parks. the EMP. EIA to be conducted for all such proposed activities.
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Theme Instrument and contents Application to the NMP project
Various rules will apply for initiating this project in the Namib Naukluft and Dorob National Parks.
Planning legislation Town Planning Ordinance 18 of 1954; and the Townships and Division of Land The Developer will have to follow the Ordinance 11 of 1963 various regulations of these acts in terms Land subdivisions and establishment of town planning scheme and zoning of obtaining approval for the purchase, are regulated in terms of these acts. subdivision and zoning of the land for the sites in question.
Traditional Traditional Authorities Act, 25 of 2000 The role and powers of the traditional Authorities Provides for the establishment of traditional authorities and defines their authorities (in this case, Topnaar powers, duties and obligations. authority) in the decision-making process of this project needs to be considered.
The Topnaar community needs to be consulted throughout.
The potential impact of the project on this community needs to be investigated.
Wetlands The Convention on Wetlands of International Importance (Ramsar Convention) Potential impacts on the Walvis Bay The Walvis Bay Lagoon area is a declared Ramsar site, making it a Lagoon need to be identified and wetland of international importance for the protection of this habitat. assessed as part of the EIA process.
National, Regional and Local Planning Framework
National Planning Vision 2030
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Theme Instrument and contents Application to the NMP project
To be a prosperous industrialised country by 2030, developed by our Ensure that the project outcome people, and enjoying peace, harmony and political stability. supports these objectives and that any negative influences on it are addressed in National Development Plan 3 (NDP3) 2007/2008 – 2011/2012 the EIA. Based on the Vision 2030, and provides the long term development
framework for the country to achieve it. The main vehicle to translate the Vision 2030 into action. Includes policy directions and is based on eight key result areas, each corresponding to the main eight objectives of Vision 2030, under the themes Competitive economy, Infrastructure, Productive utilisation of natural resources and environmental sustainability, productive and competitive human resources and institutions, knowledge based economy and technology, quality of life, equality and social welfare, peace, security and political stability and regional and international stability and integration.
Strategic Erongo Strategic Environmental Assessment The proposed project should be Environmental Assessment (SEA) Requires that EIA with careful mitigation be in place for projects with considered against the development for the coast, region potential significant impact. Elements of the project which would cause guidelines and recommendations of the and related significant impacts which cannot be avoided are to be re-designed. Erongo SEA, to ensure they are heeded. industry. Sensitive areas in the Erongo which are relevant include the Kuiseb River Valley, and the Walvis Bay Lagoon. These are to be protected from high impact development. Two other important issues in the document are guidelines for water resource use and rehabilitation of project upon closure. Uranium Rush SEA Even though this SEA is aimed at a Provides strategic recommendations for the development of the uranium sustainable uranium industry, many of industry in the areas of water, infrastructure, employment and skills the guidelines are applicable to all mining
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Theme Instrument and contents Application to the NMP project
development, social amenities and services, environment and heritage and processing developments in general and governance. and should be considered in this EIA. Coastline Strategic Environmental Assessment (SEA) Commissioned by Walvis Bay Municipality for the coastline between Walvis Bay and Swakopmund to provide a balanced protection of the coastline environment. Currently the SEA report guides the Municipal Council in decision making, integrates environmental issues into urban planning and development; and promotes sustainable development and awareness.
Walvis Bay Structure Development guidelines and statutory land use rights for the area of Walvis Bay. The holding pond, pipeline and Plan and Town The Walvis Bay Structure Plan is in the process of being updated. Planning Scheme. processing plant site largely fall outside this area of jurisdiction, but the transport of the material to the harbour and the harbour itself fall within the area. The statutory requirements and vision for the land affected are to be incorporated into the project. Consider how these developments on the outskirts of Walvis Bay would affect its urban development.
Walvis Bay Walvis Bay Municipality (WBM) Integrated Environmental Policy The project should honour the WBM Environmental Policy and Action Drafted under the auspices of the Walvis Bay Local Agenda 21 (WBLA21) Integrated Environmental Policy and be Plans Project. Clearly states the directions WBM and stakeholders will move aligned with the goals set in the Strategy towards in the period to 2008-2-15 to fulfil their joint responsibilities to and Action Plan. manage its natural and human-made environment for the benefit of all residents and visitors. It commits the municipality to certain principles,
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Theme Instrument and contents Application to the NMP project
policy directions and tools. It serves as a framework for a series of sectoral strategies and action plans, these inspired by visions of a better environmental future. Environmental Strategy and Action Plan for Walvis Bay – is a sectoral Strategy of the WBM Integrated Environmental Policy and has the following goals: To maintain the health, productivity and diversity of the various habitats making up the Coastal Area ecosystem. To prevent, control and minimise the impact of polluting activities on the Coastal Area.
To safeguard the Coastal Area shoreline within the jurisdiction of WBM.
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4 PUBLIC CONSULTATION AND DISCLOSURE
Public participation forms an important component of an environmental impact assessment (EIA). It has been defined in the Regulations of the Environmental Management Act (2007), as a ‘process in which potential interested and affected parties (I&APs) are given an opportunity to comment on, or raise issues relevant to, specific matters’.
For this purpose, a Public Consultation and Disclosure Plan (PCDP) was formulated indicating how the consultant set out to consult with I&APs, providing them a platform whereby they can convey their concerns (see Appendix 1). This section of the document reports on what was done, and what the results were. The final section of the report demonstrates where and how the public and stakeholder input is being considered during the EIA process.
At the outset of public consultation for the EIA focusing on the terrestrial component of the proposed project, meetings were held with the authorities and public in Walvis Bay and Windhoek. Even though the marine and terrestrial issues will be dealt with in separate EIAs, there are some overlaps. Thus the information presented provided a brief overview of both components, with special focus on the terrestrial issues and potential impacts.
A summary of all issues and concerns that were raised during public consultation is provided in the Issues and Responses Trail (see Appendix 2). The latter also assisted in developing the parameters of the study in terms of issues to be explored in the specialist study and assessment of the impacts phases.
4.1 POLICY AND LEGAL FRAMEWORK
The Public Participation Process (PPP) is governed by or is guided by certain national and international legislation. The legislation and policies applicable to the PPP for this project are outlined in Table 4:1. In addition, guidelines and performance standards provided by the International Finance Corporation (IFC), for those wanting to qualify for financial assistance, are also presented in the Table 4:2 below
.
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Table 4:1: Summary of relevant Namibian legislation.
Legislation/ Applicable Clause/ Policy Comments Guideline/ Policy Environmental Environmental “The person conducting a public participation process must give notice to all potential interested and affected Management Act (2007) Assessment Regulations: parties of the application which is subjected to public participation by giving written notice to – Section 21: Public the owners and occupiers of land adjacent to the site where the activity is or is to be undertaken or to any Participation Process alternative site; the local authority council and regional council in which the site or alternative site is situated; and any other organ of state having jurisdiction in respect of any aspect of the activity” Environmental Environmental “…advertise the application once a week for two consecutive weeks in at least two newspapers circulated Management Act (2007) Assessment Regulations widely in Namibia” Section 21: Public Participation Process Environmental Environmental “When complying with this regulation, the person conducting the public participation process must ensure Management Act (2007) Assessment Regulations that – Section 21: Public information containing all relevant facts in respect of the application is made available to potential interested Participation Process and affected parties; and participation by potential interested and affected parties is facilitated in such a manner that all potential interested and affected parties are provided with a reasonable opportunity to comment on the application.” Environmental Environmental “An applicant or EAP responsible for an application must open and maintain a register which contains the Management Act (2007) Assessment Regulations: names and addresses of – Section 22: Register of all persons who, as a consequence of the public participation process conducted in respect of that application, interested and affected have submitted written comments or attended meetings with the applicant or EAP; parties all persons who, after completion of the public participation process referred to in paragraph (a), have requested the applicant or the EAP responsible for the application, in writing, for their names to be placed on the register; and
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Legislation/ Applicable Clause/ Policy Comments Guideline/ Policy all organs of state which have jurisdiction in respect of the activity to which the application relates. (2) An applicant or EAP responsible for an application must give access to the register to any person who submits a request for access to the register in writing.” Environmental Environmental “Before the EAP responsible for the application, submits a report compiled in terms of these regulations to the Management Act (2007) Assessment Regulations: competent authority, the EAP must give registered interested and affected parties access to, and an Section 22: Register of opportunity to comment in writing on the report.” interested and affected parties
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The information presented in the table above, based on the Environmental Management Act (2007), is congruent with the guidelines and performance standards of the IFC.
The IFC holds the consultant responsible for compiling a PCDP (Appendix 1). This plan should ensure that all interested and affected parties are consulted with throughout the project, while documenting the communication throughout this process. The IFC has listed some requirements for the PCDP, which includes stakeholder identification, community engagement and the disclosure of information, which are discussed below presented in Table 4:2 below.
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Table 4:2: IFC Guidelines and Performance Standards
Legislation/ Applicable Clause/ Comments Guideline/ Policy Policy International Finance Section G15 Stakeholder identification broadly involves the determination of the various individuals or groups who may have Corporation Guidelines an interest in the project or who may affect or be affected by the project. The process of stakeholder identification includes distinct steps, including: (i) identifying individuals, groups or local communities that may be affected by the project, positively or negatively, and directly or indirectly, making special effort to identify those who are directly affected, including those who are disadvantaged or vulnerable; (ii) identifying broader stakeholders who may be able to influence the outcome of the project because of their knowledge about the affected communities or political influence over them; (iii) identifying legitimate stakeholder representatives, including elected officials, non-elected community leaders, leaders of informal or traditional community institutions, and elders within the affected community; and (iv) mapping the impact zones by placing the affected groups and communities within a geographic area, which will help the client define or refine the project’s area of influence. International Finance Section G45:19 Community engagement is an on-going process involving the client’s disclosure of information. The purpose of Corporation Guidelines community engagement is to build and maintain over time a constructive relationship with the local and affected communities. The nature and frequency of community engagement will reflect the project’s risks to and adverse impacts on the affected communities. Community engagement will be free of external manipulation, interference, or coercion, and intimidation, and conducted on the basis of timely, relevant, understandable and accessible information. International Finance Section G45:20 Disclosure of relevant project information helps affected communities understand the risks, impacts and Corporation Guidelines opportunities arising from the proposed project. Where the client has undertaken a process of Social and Environmental Assessment, the client will publicly disclose the Assessment document. If communities may be affected by risks or adverse impacts from the project, the client will provide such communities with access to information on the purpose, nature and scale of the project, the duration of proposed project activities, and any risks to and potential impacts on such communities. For projects with adverse social or environmental impacts, disclosure should occur early in the Social and Environmental Assessment process and in any event before the
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project construction commences, and on an ongoing basis. International Finance Section G45:21 Effective consultation: Corporation Guidelines should be based on the prior disclosure of relevant and adequate information, including draft documents and plans; should begin early in the Social and Environmental Assessment process; will focus on the social and environmental risks and adverse impacts, and the proposed measures and actions to address these; and will be carried out on an ongoing basis as risks and impacts arise; will be undertaken in a manner that is inclusive and culturally appropriate. The client will tailor its consultation process to the language preferences of the affected communities, their decision-making process, and the needs of disadvantaged or vulnerable groups.
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4.2 THE STAKEHOLDERS
An interested and affected party can be defined as ‘(a) any person, group of persons or organization interested in or affected by an activity; and (b) any organ of state that may have jurisdiction over any aspect of the activity’ (MET, 2010).
The interested and affected parties for this project were identified using the Enviro Dynamics existing stakeholder database. Also, the surrounding land uses to the proposed project area were mapped in order to visually present potential impact zones. This further assisted in identifying potentially affected parties such as the tourism industry, the Topnaar community, MET and MFMR and NACOMA (see Figure 4:1)
Figure 4:1: Surrounding Land Uses to the proposed project
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Notices were also placed in various newspapers inviting the public to register as interested and affected parties (I&APs). Organizations were also selected whom the consultant considered would have an interest in, or be affected by, this particular project. Also, those who have registered as I&APs for the EIA focusing on the marine component were automatically added to the stakeholders list for this terrestrial EIA.
Key stakeholders have been identified at national, regional and local level. In the case of this project, the local level refers to Walvis Bay and the coastal community. A summary of these stakeholder groups are presented in (Table 4:3) the complete stakeholders list can be viewed in Appendix 3.
Members of the Public receive the opportunity to register as stakeholders and are added to the stakeholder list as they come on board.
Table 4:3: Summary of stakeholders
Description
Item Level Ministry of Mines and Energy (MME) Ministry of Environment and Tourism (MET) Ministry of Agriculture, Water and Forestry (MAWF) Ministry of Trade and Industry (MTI) Ministry of Fisheries and Marine Resources (MFMR) Ministry of Works Transport and Communication (MWTC) Ministry of Lands and Resettlement (MLR)
National Planning Commission
Benguela Current Commission
Namwater
Media (radio and papers) National Ministry of Fisheries and Marine Resources Ministry of Environment and Tourism Ministry of Works Transport and Communication
Erongo Regional Council
Marine Neighbours to EPLs
Chamber of Mines Erongo Regional Electricity Distributor (RED)
Namwater
Walvis Bay Salt Works
Media
StakeholderDatabase Regional
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Description
Item Level Walvis Bay Municipality Swakopmund Municipality
NamPort TransNamib Fishing Associations and Industry Tourism Operators Walvis Bay Chamber of Commerce
Non Governmental Organisations (NGOs) Specialists
Other Consultancies
ocal Media (Radio) L
4.3 METHODOLOGY
The public was informed about this project in various ways. Notices were placed in the press in three different newspapers covering the coastal and national areas over a period of two consecutive weeks. The notices briefly explained the project and its location while also inviting people to register as I&APs, clearly indicating their interest in the project (see Table 4:5) below. These newspaper notices are attached as Appendix 4.
A Background Information Document (BID) was circulated to all I&APs along with an invitation to attend one of the three meetings (see Table 4:6) below via e-mails or fax. This included invitations being sent to private fishing companies as well as to the fishing associations, the latter assisting the team by further informing people in the fishing industry about the meetings.
The Honourable Councillor J. Nangolo for the Walvis Bay Rural Constituency aided the team by putting up posters further informing the community about the public meeting scheduled in Kuisebmond, Walvis Bay. This meeting was also announced over the NBC radio in both the Afrikaans and National services (see Table 4:4).
Table 4:4: Announcements over the NBC Radio Service
Date NBC radio Time
28 Nov 2011 Afrikaans and National services 06h30 & 19h00
29 Nov 2011 Afrikaans and National services 06h30
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A number of articles were also published in both national and international newspapers on the proposed project (see Appendix 5). Even though these articles were not formally released by the project team, they assisted in further raising awareness and it is noted that the press do have a role to play in the public consultation phases of a project. Hence, they were also invited to the public meetings.
Table 4:5: Notifications placed in the press
Date National Newspaper Circulation
15-11-2011 Republikein Afrikaans Newspaper, National 22-11-2011 The Namibian English Newspaper, National
The meetings were conducted in both Windhoek and Walvis Bay. In respect of the meeting in Windhoek, both the authorities and public were invited to the same meeting whereas separate meetings were conducted for the public and authorities in Walvis Bay. The rationale for this is that there are fewer potential I&APs from the public in Windhoek than in Walvis Bay.
A focus group meeting was undertaken separately with the Walvis Bay Municipality and Namibian Coast Conservation and Management (NACOMA) regarding the proposed location of the project for its land- based activities. A separate meeting was also conducted with the Kuiseb Delta Development Project (KDDP) representatives regarding their proposed tourism activities near the proposed project location. Besides the above mentioned meetings, venues known and accessible to the I&APs were identified for both the Windhoek and Walvis Bay, meetings namely the NamPower Convention Centre, the Pelican Bay Hotel and the Immanuel Ruiters School Hall in Kuisebmond respectively. The latter venue was in a lower-income area of Walvis Bay to ensure accessibility to those without good transport.
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Table 4:6: Summary of meetings conducted
Date Meeting Venue 08-11-2011 Walvis Bay Municipality and NACOMA Walvis Bay Municipality 29-11-2011 Walvis Bay Authorities Pelican Bay Hotel, Walvis Bay 29-11-2011 Walvis Bay Public Immanuel Ruiters School Hall, Kuisebmond, Walvis Bay 01-12-2011 Windhoek Authorities and Public NamPower Convention Centre, Windhoek 13-12-2011 Kuiseb Delta Development Project Enviro Dynamics Offices, Windhoek
4.4 THE MEETINGS TO DATE
All the public and authorities meetings were facilitated by Norman van Zyl from Enviro Dynamics whom also explained the EIA process as well as potential environmental impacts relating to the project. David Wellbeloved from NMP presented an overview of the proposed project. No interpreter was requested r at any of the meetings, thus it was undertaken in English, the Namibian National Language. The information presented introduced both the marine and terrestrial components of the project, in order for people to understand the project holistically. However, since this EIA focuses on the terrestrial component of the project, more technical and in-depth information was shared on this component at the meetings.
The minutes of all the meetings, including the meetings with WBM, NACOMA and KDDP can be viewed in Appendix 6.
A summary of the objectives and methodology employed for each meeting, as well as the main issues raised are presented in Table 4:7 overleaf.
Figure 4:2: Some of the meetings conducted.
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Table 4:7: Summary of the objectives and methodology used arranging each meeting, as well as the main issues raised
Objectives The Meetings Main Issues Raised Methodology
Walvis Bay Municipality (WBM) and NACOMA
The main objective of this meeting was to The meeting took place at the Walvis The main issues raised as this meeting were The meeting was arranged via e-mails. discuss potential site alternatives for the Bay Municipality offices on 8 related to site alternatives, socio-economic project. November 2011. It was attended by impacts, tourism and transport to the representatives from Enviro Dynamics, harbour. Issues regarding the existing WBM and NACOMA. pipeline route and holding pond site were also raised. The importance of the Uranium Rush SEA and Walvis Bay Structure Plan was also mentioned.
Kuiseb Delta Development Project (KDDP)
The main objective of this meeting was for The meeting took place in Windhoek at The main issues raised at this meeting where The meeting was arranged telephonically. KDDP to inform the consultant on this project the offices of Enviro Dynamics. It was the potential impacts associated with a loss in about its locality and future plans. This will a one-on-one meeting between revenue from tourism, impacts on the assist the team to better understand Norman van Zyl (consultant) and livelihood of the Toppenaars and destruction potential impacts on this project and Ambrosius Swartbooi, the of historical and archaeological sites. Toppenaar community representative of the KDDP.
Consultation with Authorities
In order to consult with the organs of state Walvis Bay: This meeting took place The key concerns raised by the attendees can The authorities were invited to the meeting via fax which have jurisdiction over the areas where on 29 November 2011 and had eleven be summarized as changes in water quality and e-mail. The authorities meeting in Windhoek the proposed project is planned to be attendees, excluding the project team also impacting on the salt works activities, the was also advertised in the newspapers, inviting the implemented, meetings were conducted with and client. They represented the effluent discharge, constraints at the harbour Windhoek public to attend this meeting. the relevant authorities in Walvis Bay and Walvis Bay Municipality, Walvis Bay and associated transport routes, sediment
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Objectives The Meetings Main Issues Raised Methodology
Windhoek. Since aspects of the proposed Salt Works, MFMR and the Fishing transport, leakage and technical details of the At the meeting in Windhoek, the attendees were project will be implemented at both sea and Industry. buffer pond as well as the flooding of the handed cards on which they could record issues on land, the concerns and ideas of the marine Windhoek: This meeting took place on Kuiseb River. Potential impacts on birds, air and concerns. These were then grouped according and terrestrial authorities were solicited. In 01 December 2011 and had eleven quality, the Toppenaar community and to specific themes. addition, it was hoped that possible solutions attendees, excluding the project team Narraville was also raised. to challenges faced with regards to the and client. Amongst them were Another key issue raised at the Windhoek proposed project could also be provided. representatives from the Polytechnic meeting was that the process is currently Take note that the public was also invited to of Namibia, the Deputy Minister of underway for the Namib Desert to be the authorities meeting in Windhoek. Ministry of Environment and Tourism proclaimed as a World Heritage Site hence and MET staff, NACOMA, MFMR, MME concern was express about the plan to locate and MWAF. the buffer in the Namib Naukluft Park.
Public Consultation
The main objective of consulting with the Walvis Bay: Members of the public, Issues related to health and safety, impacts An invitation to the public meetings was circulated public was to create a platform whereby the from the Swakopmund and Walvis Bay on terrestrial and marine ecology, fresh water via e-mail and fax to the I&APs. In addition, the concerns of individuals, groups or local communities, attended this public and sea water quality, waste and shells meetings were announced in the various communities could be conveyed and the meeting on 29 November 2011 at the disposal, site selection, governance and newspapers, over the radio and the use of posters parameters for the study in terms of issues to Immanuel Ruiters Primary School in cumulative impacts were raised. Also, in order to inform the public about the meeting. explore can be developed. Kuisebmond. impacts on noise, traffic and air quality as At the meeting in Walvis Bay, the attendees were In addition, these meetings facilitate well as archaeology and livelihood strategies handed cards on which they could record issues transparency with the public which aids in were mentioned. Impacts on sediment and concerns. These were then grouped according building good rapport, while identifying dynamics was also noted as a key concern. to specific themes. potential challenges brought about by the proposed project, along with possible solutions.
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4.5 PUBLIC FEEDBACK
Continuous public input and feedback is an important component of the PCDP, as it also assists in transparency and building good relations. A commentary period was allowed from 23 November to 10 December 2011, providing I&APs the chance to submit any questions or comments on the BID as well as information presented at the meetings.
The Draft Environmental Scoping Report which also includes a summary of the public participation process and an Issues and Responses Trail, will be made available on the Enviro Dynamics website for the perusal of all registered I&APs. Again, the link will be e-mailed to them with an invitation to provide comments on this document. Hard copies of this document will also be placed at the Windhoek and Walvis Bay libraries.
All comments received during this round of consultation will be collated into a Comments and Responses Trail which will include statements of how the comments were considered and incorporated into the Environmental Assessment Report.
An independent reviewer, Mr Patrick Morant from the Council for Scientific and Industrial Research (CSIR), is also on the EIA team to oversee the entire process and to review the draft documents before they are submitted to the DEA for consideration. This is seen as best practice, given the extent and complexity of the project. Once external review input has also been incorporated into the document, the report will be submitted to the DEA for approval.
4.6 ISSUES IDENTIFIED
The issues that were raised in the consultation forums, as well as in writing, have all been collated in the Issues and Responses Trail (see Appendix 2). These issues will further be considered in the full impact assessment phase which will be a separate document. The key concerns and issues raised by the I&APs are summarised in the Table 4:8 below.
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SUMMARY OF ISSUES Public Consultation Process Need for an emergency incidents protocol for impacts associated with for example hazardous waste and dredge vessel spills. Radiation impacts of dredged and stored material on workers and residents. Health and Safety Health impacts associated with aerosols from the processing plant. Health hazards during construction, operational and post-operational phases. Health impacts will not be fully understood by socio-economic specialist (request for health specialist). Leaks, rust, pipe pressure, blockages in pipeline. Use of tailings dam residue material. Technical Meet international guidelines to protect from seepage. Consider the corrosive effect of hydrogen sulphide, the effect of wave exposure and biofouling on the pipeline/s and moorings (infrastructure maintenance). Effect of Kuiseb floods on the pipeline. Impacts on marine biodiversity and keystone species including larvae inshore and migratory patterns. Impacts on benthic fauna, breeding grounds and ecosystem degradation (impacting fisheries). Impacts on live stocks in the Benguela Current Large marine ecosystem. Annual Cob run. Marine Ecology Since the dredging will be in the spawning grounds, will dredging continue in October which is an off month for fishing due to the spawning of hake? ‘Illegal fishing’ by workers, not adhering to closed seasons (construction and operational phases). Impact on seabird population if water in the buffer and or tailings ponds is contaminated. Impacts on oyster and mussel filter feeding aquaculture farms. Loss of terrestrial biodiversity (Dune Lark, beetle, birds). Terrestrial Ecology Pipe as barrier to movement of terrestrial fauna (brown hyenas, jackals, ostrich, springbok). Impact of stock piles on fauna living on the beach.
Final Scoping Report Sandpiper Marine Project EIA for Terrestrial Component April 2012 Page 58 of 137 SUMMARY OF ISSUES Public Consultation Process Proposed pipeline and holding pond areas is in Salsola hummocks which are an important habitat to a variety of wildlife. Birds: sewerage works, holding pond, temporary pools after Kuiseb floods. Benefits vs. opportunity costs of project for Namibian economy. Opportunity cost to Namibian citizens of not selling end product locally. Impact on existing and planned land-use (e.g. salt works, aquaculture, recreational fishing, tourism, Toppenaar, fishing, Economic Marina). Impacts on the sustainability of individual commercial fisheries within the Namibian fishing industry as job providers. Impact on nearby protected areas (e.g. Sandwich Harbour, Ramsar site). Air quality and visual impacts caused by development negatively impacting on tourism activities leading to loss of revenue from existing tourism trade. Tourism Impact of sedimentation on the beach and tourism excursions. Restrictions on land to vehicle access to beach and areas further south (e.g. Sandwich Bay) due to the buffer pond and pipe line. Availability of water. Fresh Water and Energy Management and treatment of water as a scarce resource. Resource Energy requirements and whether it can be met. Pollution impacts: ground water, dams, Narraville and sewage works (seepage, pond breaches, porous nature of soil). Fresh Water Quality Through-flow of Kuiseb River to ocean interrupted (groundwater re-charge). Pollution impacts:resulting from project activities including, heavy metals, changes in PH levels, microbiological contamination, pond breaches. Red tide and changes in salinity levels Turbidity of the returned water can cause gill clogging, reduced light, etc. Seawater Quality Increased concentration of dissolved nutrients due to the high concentration of the sediment pore water nutrients which may lead to increased number of local phytoplankton blooms. Potential impacts of flocculants on the marine environment. Need detailed pollution plume model.
Final Scoping Report Sandpiper Marine Project EIA for Terrestrial Component April 2012 Page 59 of 137 SUMMARY OF ISSUES Public Consultation Process Consider the sediment impacts of shell waste on intertidal ecosystem, marine life off Walvis Bay, both in terms of juvenile fish habitat, and possible aquaculture impacts as the species farmed are primarily filter feeders. Effects of stock piling and location of disposal. Waste and Shell Disposal Waste management (including ballast water of vessel). Volume, temperature, radioactivity levels, chemical analysis, and microbial content of any effluent and or waste material, inclusive of shell grit, returned to the sea are required. Impact of holding pond on national park, Kuiseb Delta and Sandwich Harbour. Impact of processing plant on surrounding land-use (Dorob Park, Narraville, green valley, eco-tourism). Pipeline route not to interfere with salt works operations. Site Selection Consider alternatives in design and location, including Dune 7, and ecological footprint if combine holding pond and processing plant on one site. Kuiseb river flood vs. project site. The current location puts a straightjacket around the lagoon. Buffer pond site will compromise potential World Heritage status of the Namib Desert. Pond site not in conformity with Nature Conservation Ordinance of 1975 Potential loss of traditional tenure rights. Having two separate EIAs might not consider the impacts holistically. EMP for construction, operation and closure, including rehabilitation plan. Governance Consider off-sets for environmental impacts. Consider Walvis Bay Structure Plan, SEA, set of Water and Sediment Quality Guidelines for the coastal zone of the BCLME; National Shellfish Sanitation Programme (in the process of being gazetted); Effluent permit from the Department of Water Affairs. External reviewer ideally to be appointed by Government or MET. The holding pond site falls under the ownership of the Ministry of Lands and Resettlement. Cumulative and Long- Long-term expansion of harbour activities and Walvis Bay. Term Impacts
Final Scoping Report Sandpiper Marine Project EIA for Terrestrial Component April 2012 Page 60 of 137 SUMMARY OF ISSUES Public Consultation Process Long-term impacts associated with accumulated pollution loads as project progresses. Contribution of project’s carbon footprint to climate change. Cumulative traffic impact owing to existing salt works trucks. Positioning of the Processing Plant and the future Phosphoric Acid Plant which is potentially 2-3 years away. Cumulative impacts of effluents along the coast and those associated with Gecko mining operations (consider synergy between two projects). Air quality impact owing to odorous materials in tailings dam. Air quality impact owing to prevailing SW winds and dry phosphate material stockpiles, open-bed trucks as means of transport and dust. Air Quality Impact of carbon emission, nitrous oxide and sulphur releases on air quality. Assurance is required that the dust generated from the handling of the product in the port will not cause contamination of the salt stored in the port. Noise and visual (lights at night) impacts associated with 24hr/7days a week operation. Noise and visual impacts resulting from conveyor belt and increased traffic. Noise and Visual Impacts Visual impact of slimes dam adjacent to Bird Paradise. Visual impact of pipeline and buffer pond for tourists near Sandwich Harbour. Rehabilitating tailings at the end of the mining operation. Impact of sand movement on all infrastructure. Infrastructure Concerns about harbour space. Constraints and congestions. On-shore sediment dynamics impacted due to dune stabilisation – potential to impact lagoon. Impact on marine and coastal sediment dynamics due to inlet and outlet pipes, and shell disposal. Sediment Dynamics What effect will the pipeline have on the movement of the sand dunes? This needs to be modelled to ascertain whether it would increase the deposition of Aeolian sand into the salt works’ ponds. Need for hydrodynamic modelling. Archaeology Archaeological impact on fossil oysters near buffer pond.
Final Scoping Report Sandpiper Marine Project EIA for Terrestrial Component April 2012 Page 61 of 137 SUMMARY OF ISSUES Public Consultation Process Loss of various animal and human tracks on clay surfaces. Impacts on Toppenaar gravesites, cultural artefacts and heritage. Physical objects must get approval from Directorate of Civil Aviation, e.g. chimneys and other high objects. High concentration of metals can cause possible interferences. Air pollution such as dust or steam can be safety risk near airports. Aviation Safety Bird strikes and ponds near airports. Need to respond to emergencies. Pipeline should not be a barrier. A safe distance of 11 m must be maintained between 2 vehicles. An increase in traffic can impact on this. Lessons learnt from similar projects in other countries. Benchmarking Are enough baseline studies & information are available to effectively determine what the final impact will be on the environment? Traffic jams near the harbour entrance, especially during peak traffic hours. Transport Transport of workers.
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5 BIOPHYSICAL AND SOCIO-ECONOMIC OVERVIEW OF THE RECEIVING ENVIRONMENT
The environment of the proposed project area is briefly described in this section. To enable the EIA Team to identify the key sensitivities of the area and how the project would potentially affect them. This section is introduced with an overview of the Walvis Bay areas, followed by more details of the pertinent environmental elements.
5.1 OVERVIEW OF THE WALVIS BAY ENVIRONMENT
The unique central coastal zone of Namibia in the region of Walvis Bay is formed by a combination of distinctive climatic conditions. They are mainly the South Atlantic Anticyclone, the northward flowing Benguela. Current and the divergence of the south-east trade winds along the coast.
The climate along this coast is cool temperate (average of around 15°C) and fog occurs frequently (between 50 and 100 days per annum). Southerly winds dominate of which the south-easterly is predominant, causing a movement of desert sand in a northerly and easterly direction. The maximum diurnal shifts in temperature occur in winter when the “berg” winds blow off the desert. These conditions cause temperatures which exceed 30°C. The area is hyper-arid with mean annual rainfall reported as 13.5mm for Walvis Bay (Meteorological Services, 2011).
The coastal rivers are ephemeral, occasionally breaking through to the ocean after heavy rains in the interior e.g the Kuiseb River in April 2011. An example is the Kuiseb River which flows into the Atlantic Ocean south of Walvis Bay. The surface flow of this river feeds large groundwater resources from where production boreholes supply Walvis Bay and the Central Namib. These aquifers are currently being mined to their capacity so that additional water supply to the area is a major concern. The Kuiseb River also provides natural resources to the resident Toppenaar community and is an important tourist attraction.
Other wetlands of importance are the Walvis Bay Lagoon, a Ramsar site and the freshwater wetland pond at the municipal sewerage works. These two wetlands are important habitats for birds and are tourist attractions.
The soils of the project area are mostly littoral sands of windblown origin forming large dune belts and lower hummocks. These dunes are unique habitats for a variety of desert fauna and they define the landscape. The Kuiseb Delta, intersecting the pipeline route, consists of clay plans with a flat gradient. With periodic floods these pans are filled with water.
Fishing, tourism, manufacturing and the port are the main pillars of Walvis Bay’s economy. Other key economic contributors are the salt works and aquaculture activities. The Walvis Bay resident population is estimated to be close to 80 000, with an unemployment rate of 36%.
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The Dorob National Park surrounding Walvis Bay and the Namib-Naukluft National Park to the south are state protected areas and plans are afoot to declare the Namib Desert as a World Heritage Site. The lagoon, Dune 7 and 4×4 routes to Sandwich Harbour and its Ramsar site in the Namib-Naukluft Park are important tourism destinations near Walvis Bay.
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Figure 5:1: Overleaf is a photographic illustration of the Walvis Bay environment. Photos sourced from the Walvis Bay Municipality website and supplied by Enviro Dynamics.
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5.2 BIO-PHYSICAL ENVIRONMENT
5.2.1 Sediment dynamics
The movement of sediment within the central coastal region involves a dynamic interaction between land and marine components. Sandwich Harbour has experienced dramatic changes in recent years. The lagoon was engulfed by sand with the rapid northward movement of the coastal spit in the early 1980s (Seely & Pallett, 2008). Offshore from Walvis Bay, Pelican Point (the tip of the coastal spit) migrated 100m from 2001-2008. Two sediment transport processes are at work in this dynamic environment – terrestrial aeolian (wind-blown) and wave-driven long shore transport processes.
5.2.2 Terrestrial Aeolian Transport
The dominant wind direction in the central coastal region is southerly (Seely & Pallett, 2008), and is stronger in summer than in winter. Winter experiences more intensive east winds. This bimodal wind regime is thought to be responsible for the production of linear dunes, which oscillate approximately 15m back and forth within a year (Seely & Pallett, 2008). There has been an observed northwards migration over the past 50 years. The northward extension of dunes into the Kuiseb River Valley (the northern boundary of the Namib sand sea) has been observed, with annual sand transport rate of up to approximately 150m3/m/year (Hughes, Brundrit, & Searson, 1992).
5.2.3 Coastal Transport
Key elements involved in marine related sediment transport include tidal movement, ocean currents, and local wave climate and sediment inputs from rivers.
Sediment that accumulates in the Kuiseb River valley from the northward migration of the Namib Sand Sea is removed by periodic flooding of the Kuiseb River. This sediment is redeposited to the south of the coastal spit west of Walvis Bay. Surf-zone (typically 150-250m wide) currents are dominated by wave-driven flows (CSIR, 2009). These longshore currents result from waves, which approach the shoreline at an angle. These currents generally transport unconsolidated sediments northward along the coast at a rate of approximately 800 000m3/m/year.
The proposed project could affect the marine and terrestrial sediment dynamics by introducing new structures in the ocean and on land which interrupt the sediment transport processes.
Table 5:1 below summarises the expected sensitivities related to aeolian and costal sediment transport.
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Table 5:1: Sensitivities related to sediment dynamics.
Environmental Sensitivity Potential impact/enhancement feature/aspect Drivers of coastal Negligible sensitivity as the buried pipe Negligible impact on winds, waves, processes: winds, waves, currents, (tides) is not anticipated to affect these currents, (tides). drivers. Coastal processes: e.g. Negligible sensitivity as the buried pipe Negligible impact on marine & coastal marine & aeolian sediment transport is not anticipated to affect the aeolian sediment transport. Potentially sediment transports. larger impact on aeolian sediment However, the buffer pond and transport & dune field landward of landward facilities could affect the backshore area. aeolian transport regime which is sensitive to disruptions & physical barriers. Coastal dynamics: beach Assuming correct/adequate burial Assuming correct/adequate burial profile, shoreline evolution, sediment depth, no sensitivity to pipeline. depth, no impact from pipeline. composition Walvis Bay Peninsula (spit) A large shoreline perturbation, morphology is very sensitive to resulting from large volume of shell marine/coastal sediment transports disposal on the coast could affect and feed from south. littoral transport to Walvis Peninsula and therefore its integrity. Others: backshore Backshore area/dunes are sensitive to A buried pipe would have virtually no area/dunes changes in aeolian sediment transport impact. regimes or degradation of vegetation. Depending on the distance from shore, the pond may not be located within the main coastal aeolian sediment pathway, thus only a small localised impact near the pond. Others: construction The alongshore surf zone current, Temporary, localised change in surf damages associated sediment transport and zone current, sediment transport subsequent shoreline morphology are regime and shoreline morphology. sensitive to disruptions / barriers Thus, local disruptions of intertidal, swash & supra-tidal zones and sed. transports. Construction activities temporarily increase local turbidity. Therefore temporary direct local disturbance of beach (& sediments). Return to natural state once cross- shore sheet piling/jetty structure has been removed.
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5.2.4 Intertidal and shallow subtidal marine communities
The marine ecology of the central Benguela region is to a large extent determined by wind-induced upwelling which is largely responsible for the rich biological productivity of the region. Biotic communities can be classified according to the habitat in which they are found, namely intertidal, subtidal and pelagic communities.
5.2.5 Intertidal communities
The community structure, abundance, biomass and diversity of intertidal communities are determined by:
Sand particle size Beach slope Wave climate
Figure 5:2: Intertidal and subtidal communities of the central Benguela region.
There are generally two main types of intertidal habitats found within the central Benguela region, namely sandy or rocky shores. Intertidal communities typically comprise invertebrate macrofauna, which are larger than 1mm in size. These include small crustaceans, polychaetes, gastropods and bivalves (Figure 5:2).
5.2.6 Subtidal communities
The subtidal community structure, abundance, biomass and diversity are determined by:
Sand particle size Depth
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Current velocity Organic content
These factors combine in generally two habitats, which are found in the central Benguela region – rocky subtidal reefs and sandy subtidal zones. Subtidal communities, like intertidal communities typically comprise of invertebrate macrofauna that are greater than 1mm in size. These include small crustaceans, polychaetes, gastropods and bivalves (Figure 5:2).
5.2.7 Pelagic Communities
Pelagic communities typically consist of plankton, fish and their predators. The predators include mammals (dolphins, whales and seals) and turtles.
Table 5:2: Sensitivities related to marine ecology
Environmental Feature Sensitivity Potential Impact
Intertidal beaches Changes in physical Change/Loss of invertebrate characteristics result in species diversity. invertebrate macrofaunal Cascade effects on higher-order community changes consumers. Surf-zone Nursery habitat for marine fish Disturbance through pipeline laying (cob and steenbras) and dredger discharges. Nearshore sandy habitats Migration corridors and calving Disturbance through pipeline laying areas for Southern Right whales and dredger discharges. Entanglement in buoyed end of pipeline.
5.2.8 Groundwater
The Kuiseb River, an ephemeral river, originates in the mountainous area of the Khomas Highland (up to 2,000mamsl), from where it flows through the interior plateau, across the escarpment as well as the coastal desert plain. The catchment has a size of approximately 14,700 km², with a river length of about 560km. Rainfall across the catchment area varies from 350mm/a (inland) to <50mm/a at the coast. Surface water runoff rarely reaches the coastal part of the river and if it does reach this part, it infiltrates into the delta area where dunes block the flow. During rare occasions the Kuiseb River does break through the dune area, from where it then spreads in a northerly and southerly direction into the coastal pans as well as into the Walvis Bay Lagoon (Ramsar Site).
The predominant south-south-easterly wind forces sand movement in a north-north-westerly direction, into the Kuiseb River, with a subsequent migration of the Kuiseb River bed in a similar direction. Airborne geophysical surveys conducted during the 1990’s indicated the presence of paleochannels in
Final Scoping Report Sandpiper Marine Project EIA for Terrestrial Component April 2012 Page 69 of 137 the Kuiseb River delta as far south as Sandwich Harbour. These paleochannels are filled with river sediments and dune sand and have a relatively high hydraulic conductivity. Groundwater from the current Kuiseb riverbed still seeps into the paleochannels, flowing through these channels towards the Atlantic Ocean. At Sandwich Harbour the fresh groundwater reaches the ocean, which allowed for early settlements to exist near these freshwater springs. Further north of Sandwich Harbour seawater migrates into the coastal sediments. A freshwater /seawater interface is formed where the less dense fresh groundwater meets with the saline seawater. This interface is predicted to shift backwards and forwards, depending on the levels of freshwater on the inland side of the interface. Groundwater on the inland side of the seawater interface is generally of a good quality and is abstracted for the water supply of the Central Namib Coast. This includes Swakopmund and even Rössing Uranium Mine. The Kuiseb River aquifer is considered to be one of the most important aquifers in Namibia. The Dorob Abstraction Scheme is located within the Kuiseb River delta and is the nearest groundwater abstraction scheme to the proposed project location, with the Rooibank and Swartbank abstraction schemes located further upstream.
Paleochannel material is expected to underlay much of the project area, as inferred from geophysical survey maps. Depth to bedrock in the area is assumed to be more than 50mbmsl. It can therefore be concluded that the underlying aquifer is a primary aquifer having coarser grain material in the paleochannels and finer grained material outside the paleochannels.
After years of discharging semi-purified water into the dune area adjacent to the Walvis Bay sewerage plant, a wetland was formed. This supports a habitat for various bird species within particularly dense vegetation unlike the rest of the town. It is predicted that a freshwater lens has formed underneath the wetland. Fresh water is less dense than saline water and it tends to float on the saline seawater, which has migrated in from the nearby Atlantic Ocean. The extent of the freshwater lense is unknown but it is expected to be important to sustain the various palm trees and other vegetation present.
The proposed location of the buffer pond and various pipelines will be in close proximity to the freshwater/seawater interface of the Kuiseb Aquifer. Pipelines between the buffer pond and the processing plant will transfer solutions past the Salt Works and Walvis Bay Lagoon, which is an important Ramsar Site. The processing plant’s planned location will be just east of the aforementioned sewerage works wetland.
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Figure 5:3: Hydrogeology map - Locality
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Figure 5:4: Hydrogeology map
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Table 5:3 below is a summary of the groundwater sensitivities and potential impacts.
Table 5:3: Sensitivities and potential impacts related to hydrogeology
Environmental feature Sensitivity Potential impact/enhancement Groundwater Important water supply source Contamination of groundwater
Vegetation Loss of vegetation that depends on fresh groundwater Surface water Lagoon & Pans (Ramsar Site) Eutrophication
Salt Works Contamination of salt pans (economic/ health risk) Sewerage Works Wetland Habitat Loss of freshwater may impact habitat that depends on this source of freshwater
5.2.9 Terrestrial Biodiversity
Full details on taxa recorded in the listed datasets from the study area on land are summarised here (Table 5:4).
Table 5:4: Summary of taxon characteristics for area (Irish, 2012)
Taxon Total species Endemic Threatened Legal status Mammals (non-marine) 34 7 (21 %) 1 (3%) 8 Birds 203 4 (2%) 22 (11%) 191 Reptiles 41 18 (44%) 3 (7%) 6 Amphibians 0 0 0 0 Freshwater fish 0 0 0 0 Invertebrate spp. 155 68 (44%) 19 (12%) 0 Invertebrate higher 69 - - 0 taxon Plants 112 12 (11%) 7 (6%) 0 Fungi, lichens ? ? ? 0 Total 614+ 109+ (17%) 52 (8 %) 205 (33 %)
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5.2.10 Diversity
No records of amphibians or freshwater fish from the study area are known, and given the lack of permanent natural water, none are expected to occur except as occasional vagrants following flooding in the Kuiseb River. No fungi or lichens were recorded, but this is a data deficiency, since both are known to occur in the area. The number for invertebrates is a minimum number – each of the higher taxa expected to occur may include from one to many species.
5.2.11 Endemism
The highest recorded endemism rates are for reptiles and invertebrates (44 % of recorded species each). The true endemism rate for invertebrates is likely higher, since the endemism status of many of the species that were recorded was not known. Birds, as can be expected from highly mobile animals, have the lowest endemism rate (2 %).
5.2.12 Conservation status
Most Namibian reptiles have not been evaluated, so the true number of Threatened taxa is likely much higher. Similarly, no Namibian invertebrates have been formally evaluated at all, but of the 97 Central Namib endemic invertebrates that have been informally evaluated (Irish 2009) all are indicated to be threatened, therefore the true level of invertebrate conservation status is likely to be much higher.
5.2.13 Legal status
The very high number of birds with legal status reflects the fact that, with the exception of a few nuisance species, all Namibian birds enjoy Protected status.
It follows that, on balance, the taxa of highest concern for the study area are reptiles and invertebrates, and these should get particular attention as the EIA process develops.
5.2.14 Biogeography
One way to cut through the deficiencies of taxon data is to rather consider the causes of species diversity, by means of calculating comparative bioclimatic envelopes for areas to be assessed. In a nutshell, a bioclimatic envelope is that area that shares similar environmental conditions (usually at 75% level) with the area of interest. The methods of Nix (1986) and Piñeiro et al. (2007) are used.
No bioclimatic envelope has yet been calculated for the current project, because no detailed GIS data on project extent has yet been provided. However, the general tendency is for bioclimatic envelopes to decrease dramatically in size with proximity to the coast in Central Namibia (Table 5:5).
Bioclimatic envelope size also closely parallels the calculated median size of the distribution range of endemic Central Namib invertebrates, which is 25 km2 (Irish 2009).
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Table 5:5: Decreasing size of bioclimatic envelopes with proximity to coast in western Namibia. Source: Irish, 2010-2011, four different studies, locational details withheld for client confidentiality since some projects unfinished.
Location Distance from coast Size of bioclimatic envelope 1 2 320 km 10000 km
2 2 190 km 7770 km
3 2 144 km 406 km
4 2 75 km 345 km
5 2 41 km 27 km
6 2 10 km 8 km
7 2 < 1 km 1 km
It follows that the bioclimatic envelope for the study area would be small and the affected area therefore highly sensitive from a biodiversity perspective. Specific sensitivities are indicated in (Table 5:6)
Table 5:6: Sensitivities and potential impacts related to vegetation
Environmental feature Sensitivity Potential impact/enhancement Biogeography Biogeographical uniqueness of the Loss of biogeographically unique Namib Desert, particularly the Inner areas with the species they (coastal) Namib, as evidenced by support. small bioclimatic envelopes Endemism High ratio of endemic species High ratio of extreme range- restricted endemic species. Conservation status High ratio of potentially threatened Threats to endemic and extreme species as a result of restricted range/restricted range species. ranges. Data availability Low knowledge levels for some Potential for extinction of species groups, coupled to high sensitivity, before they are even known to creates science. Coastal zone Already highly impacted coastal zone Cumulative, knock-on and distance effects of impacts of additional development Protected land status Planned location of buffer pond Detracts from continued within Namib-Naukluft Park and ecological functioning and Ramsar Site ecotourism potential of park, to general detriment of park's biodiversity.
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Environmental feature Sensitivity Potential impact/enhancement Walvis-Swakop dune belt Highly sensitive to disturbance and Disruption of food-bearing Aeolian unique sand stream and invertebrate dispersal routes feeding the dune belt. Sandy beach habitat Available habitat of already critically Habitat alteration and reduction endangered beach littoral down current of effluent return invertebrates like endemic Cicindelidae
5.2.15 Birds
The central coastline of Namibia is of significant importance hosting as many as four Important Bird Areas (IBAs), (Simmons et al., 1998). The Walvis Bay lagoon and surrounding ephemeral wetlands is a Ramsar Site (Wetland of International Importance) and an IBA and supports the largest population and diversity of water birds of any wetland in southern Africa (Wearne & Underhill, 2005). The average number of water birds are 156,000 in summer, and 82,000 in winter (Wearne & Underhill 2005). For 25 species, the maximum counts exceed the 1% thresholds for flyway populations (Wearne & Underhill 2005). Sandwich Harbour, 55 km south of Walvis Bay, is second in importance as a wader resort in southern Africa (Wearne & Underhill 2005). The ephemeral wetlands near the Kuiseb river mouth and towards the dunes, between Walvis Bay and Sandwich harbour have in recent years been under water, and have hosted many water birds, as many as 5,000 flamingos (Boorman M unpubl. Data, 2011). The flyways between the two most important wetlands in southern Africa are along the coast, and inland, where ephemeral wetlands can be found. The coastal area between Walvis Bay and Sandwich Harbour also harbours breeding colonies of Damara Terns Sterna balaenarum, a globally Near-threatened near- endemic seabird (IUCN 2009).
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Table 5:7: Sensitivities related to birds
Environmental feature Sensitivity Potential impact/enhancement Feeding habitat offshore Feeding grounds for divers (e.g. terns) Increased water turbidity resulting in from buffer pond decreased feeding success Beach where sediment Roosting sea- and shorebirds Disturbances to roosts will be released Buffer pond Artificial bird habitat creation Increase in birds attracted to artificially created ponds Areas along pipeline Possible breeding habitat for sea- and Breeding habitat loss, breeding success route shorebirds decreased, breeding failures of breeding birds disturbed by development Bird Sanctuary Roosting, breeding and feeding site for Disturbance created by development birds and running of processing plant, proximity to this area is in question Settling pond Artificial bird habitat creation Increase in birds attracted to artificially created ponds
The recently “renovated” Bird’s Paradise, located just east of the sewage works of Walvis Bay, hosts a significant number of water birds and is a habitat unique to the area because its salinity is much lower than other bird habitats (CETN unpubl. count data). Many breeding birds can be found here, including grebes, plovers, teal etc (CETN unpubl. data). The area has recently been overhauled and presents a unique wetland in a spectacular desert setting with major tourist attraction potential. Water birds here are extremely skittish and sensitive to disturbance (pers. obs., 2012).
The sensitivities related to birds that have been identified for this project are presented in (Table 5:7) above.
5.2.16 Air quality
Measurements of air pollution have not been made at Walvis Bay other than a short campaign during the power station EIA. Despite this ambient air quality may be regarded as generally good as the area is well ventilated being located on the coast and there are no major sources of air pollution. However, ambient air quality is impacted on at times by emissions from industrial boilers, exhaust emissions from transportation including motor vehicles, trucks and shipping, the handling of bulk products at the port and the entrainment of dust from paved and unpaved surfaces by vehicles and wind. Odour from fish meal production, fish holding pens and the transport of liquid offal through Walvis Bay also impact on air quality, particularly under northerly winds. Dust blown from the Namib Desert also impacts on air quality, mostly in winter.
Of these the fish processing industry is considered to be the most significant resulting in emissions of sulphur dioxide (SO2), oxides of nitrogen (NOx) and particulates from their boilers as well as odour. Shipping activity in the Walvis Bay harbour will also result in emissions of SO2, NOx, particulates
Final Scoping Report Sandpiper Marine Project EIA for Terrestrial Component April 2012 Page 77 of 137 including respireable PM10, and volatile organic compounds associated with diesel and fuel oil combustion including benzene. Collectively these emission sources will impact on air quality at times at the port and the neighbouring environment. The impact of motor vehicle and truck exhaust emissions on air quality will be limited to the main transport routes through Walvis Bay to the port, and are currently not expected to be significant. During dust storms high particulate concentrations will occur on a regional scale.
The key air quality sensitivities and the related impacts which need to be investigated in further detail are presented in (Table 5:8) below.
Table 5:8: Sensitivities and potential impacts related to air quality
Environmental feature Sensitivity Potential impact/enhancement Ambient air quality Ambient concentrations of Increased occurrence of respiratory illness, or criteria air pollutants exacerbation of existing conditions with exceeding health base exceedances of SO2, NOx or PM10 guidelines. guidelines. Air quality around the National Park, recreational Diesel exhaust emissions from diaphragm pumps pump station, pipeline area. may have localised impact on air quality and associated infrastructure. increasing concentrations of SO2 , NOx an PM10. Residential area and bird Residential and tourism land Diesel exhaust emissions from vacuum pumps paradise around uses may have localised impact on air quality processing plant. increasing concentrations of SO2 , NOx an PM10. Dust emissions from filter cake stockpile during stacking and reclaiming may increase PM10 and TSP concentrations at the plant. Wind entrained dust from the tailings dam when the material dries can impact on air quality may increase PM10 and TSP concentrations in the surrounding environment. ransport routes to the Already polluted, residential Trucks: Exhaust emissions from vehicles are harbour areas, routes used by road expected to impact on air quality along the main users. transport routes increasing concentrations of SO2 , NOx and PM10. Train: Exhaust emissions from diesel locomotives are expected to impact on air quality along the main transport routes increasing concentrations of SO2 , NOx and PM10. Conveyor: With a closed tube conveyor proposed the impacts on air quality are expected to be very low with no emission of dust Area around the harbour Residential areas Dust emission from stacking, reclaiming and loading the finished product may result in an increase ambient concentrations of PM10 and TSP
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Environmental feature Sensitivity Potential impact/enhancement at the port and the surrounding areas. Diesel emissions from ships and trucks delivering product may increase ambient concentrations of SO2 , NOx an PM10 at the port and the surrounding areas.
5.2.17 Noise
The changes in noise levels at the various project sites where activity is expected can be determined with the following baseline inputs:
Identification of sensitive locations in the vicinity of the project, i.e. those areas where people are likely to be affected by changes in noise levels such as residential areas, tourism and recreational facilities; Existing traffic characteristics; Climatic factors such as wind direction; and Topographical data.
These inputs will be obtained by conducting a desk study of the area, by taking background daytime and night-time noise measurements, as well as interacting with other specialists on the EA Team. Areas that are sensitive to changes in noise levels are where sensitive receptors to noise such as residences, tourism operations, recreational activities may be affected.
Sensitivities and associated potential impacts related to noise are listed in (Table 5:9) below.
Table 5:9: Sensitivities and potential impacts related to Noise Impacts
Environmental feature Sensitivity Potential impact/enhancement Walvis Bay residential Sensitive receptors of the residential Noise disturbance and nuisance due to areas and bird paradise areas and the bird paradise near the noise from the processing plant that close to the processing plant. processing plant. will not meet the noise guidelines. Walvis Bay residential Sensitive receptors along the transport Noise disturbance and nuisance that area along the transport route. will not meet the noise guidelines route (road, rail or conveyor). Walvis Bay residential Sensitive receptors of the residential Noise disturbance and nuisance that area near the Walvis Bay areas near the Port. will not meet the noise guidelines Port. Coastal section and Sensitive receptors and sense of place Noise disturbance and nuisance that surrounds adjacent to the of recreational/tourism area in the will not meet the noise guidelines Buffer Pond and along the pipeline. Namib Naukluft Park.
5.2.18 Radio-activity
Many radioactive isotopes (or radionuclides) occur naturally throughout the Earth's crust, and are present in most rocks, soils, river water as well as in seawater. Most of these naturally occurring
Final Scoping Report Sandpiper Marine Project EIA for Terrestrial Component April 2012 Page 79 of 137 radionuclides are members of four radioactive series identified as the uranium (U-238), actinium (U- 235), thorium (Th-232), and neptunium (Np-237)2 series, named according to the radionuclides that serve as progenitor (or parent) to the series products. Naturally occurring radionuclides that are of particular interest to radiation protection, which are not members of any of the four decay series, include isotopes of potassium (K-40) and rubidium (Rb-87). These isotopes are of interest because of their presence in environmental media and their contribution to human exposure (Martin, 2006).
Naturally occurring radionuclides and nuclides from extraterrestrial sources (cosmogenic radionuclides) form part of the background radiation to which all humans are exposed on a daily basis. Humans may be exposed to this background radiation throughout the air we breathe, water we drink, soil we live and work on as well as the food we eat (Kathren, 1998). These natural background radiation conditions define the radiation baseline conditions for the Namibian Marine Phosphate (NMP) Project. It can be observed in the ambient atmospheric (air) conditions, the natural soils in the vicinity of the project, surface water and groundwater resources, as well as in the local biota (fauna and flora). In terms of national and international regulations, human exposure to natural background radiation (i.e. to the baseline conditions) is not regulated.
In addition to the natural background radiation, human activities that exploit the earth’s resources may enhance the potential for exposure to naturally occurring radioactive materials in their products, by- products, residues and wastes.
Since naturally occurring radionuclides are associated with the submarine deposit of calcium phosphate, the NMP Project is an example of such an industry that has the potential to alter the natural background radiation conditions. The contribution of the proposed operation to radiation exposure, in addition to natural background radiation, is regulated.
Radiation protection principles and regulations require a prospective evaluation of the potential exposure to members of the public, as well as the potential exposure to workers (i.e. occupational radiation exposure) induced by the proposed operation (Table 5:10).Consistent with current international guidelines, the assumption is made that if humans are suffiently protected, at least at the species level (ICRP, 1991). The prospective worker and public safely assessments should consider all relevant exposlure conditions, exposure pathways (e.g. atmospheric, surface water and groundwater pathways) and exposure modes (e.g. ingestion, inhalation and external exposure).
2 Primordial sources of Np-237 no longer exist because its half-life is only 2.1 million years (Martin, 2006), which means that natural sources of Np-237 decayed to insignificant levels since their creation some 4.5 billion years ago.
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Table 5:10: Sensitivities and potential impacts related to radiation
Environmental feature Sensitivity Potential impact/enhancement Members of the public Exposure to radiation induced by the Incur radiation dose proposed operation Workers Exposure to radiation induced by the Incur radiation dose proposed operation
5.2.19 Archaeology
Previous detailed archaeological surveys of the !Khuiseb Delta have established the characteristics of past settlement in this area. The dating of the 235 sites located covers the last 2,000 years; 155 of the sites pre-dating European contact, and the great majority of post-contact sites were concentrated in the Walvis Bay dune fields.
The !Khuiseb3 Delta, is a complex landscape of mobile dunes and relict silt beds. It was here that regular contacts were first established between the ‡Aonin4 , or Topnaar, and visiting European ships, more than a century before the imposition of colonial rule. The well-preserved archaeological evidence found here reflects a crucial early phase Namibia’s history, and is, therefore, sensitive to development in the area.
Although the project might directly affect only a small number of archaeological sites in this area around the pipeline route it is important to appreciate the value of these sites in the context of the !Khuiseb Delta as a whole.
3 QRS and the Namib Desert Archaeological Survey employ the standard orthographic form !Khuiseb (rather than the corrupt form Kuiseb), following Haacke, WHG & Eiseb, E eds 2004. A Khoekhoegowab Dictionary. Windhoek, Gamsberg Macmillan. p354.
4 The term ‡Aonin is translated as “people of the point” by Budack, K.F.R. 1977. The ≠Aonin or Toppenaar of the lower !Khuiseb valley and the sea. Khoisan Linguistic Studies 3: 1-42.
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Archaeologically, the !Khuiseb Delta consists of a central, or core area in the Walvis Bay dune fields, where the greatest concentration of well preserved sites has been recorded. To the north of Walvis Bay, there is a minor group of sites associated with the mouth of the extinct Tumas River. To the south, there are two important archaeological localities, Frederiksdam and Sandwich Harbour. The lower !Khuiseb River between Gobabeb and Rooibank is associated with a narrow strip of thinly scattered sites close to the course of the river itself. The overall picture is therefore of a distribution that is confined to the lower !Khuiseb until it flares out among the Walvis Bay dune fields, particularly in the area nearest to the lagoon. The groups of archaeological sites north and south of this core zone are peripheral.
Figure 5:5: Archaeologically sensitive area located at the proposed pipeline route.
An important exception is the area around Sandwich Harbour, which is critical to the archaeology of settlement in this area and the recent history of the ‡Aonin.
Conditions in the !Khuiseb Delta are sometimes surprisingly favourable for the preservation of archaeological evidence, and this is best illustrated by the occasional survival of human and animal tracks in the surface of the colluvial deposits. Two kinds of deposits may be distinguished here: fine river silts, found mainly in the core zone of the Walvis Bay dune fields and parts of the lower !Khuiseb, and lagoon silts, on the eastern margins within up to 2km distance of the existing tidal lagoon. The river silts have several examples of animal spoor, including elephant, oryx, zebra and ostrich, evidently made on the edges of muddy pools that became temporary drinking places. The lagoon silts have a more complex depositional history: high tides filled temporary impoundments of highly saline water, reduced under evaporation to a saturated solution of gypsum, anhydrite and related minerals. In the latter case, spoor was preserved in the very hard, cement-like surface of the dried sediment. Examples of spoor dating to within the last 300 years have been found in several parts of the delta, and in both kinds of sediment.
Based on work already conducted by the archaeological specialist, the only area threatened by the project is along the pipeline route (Figure 5:5). More archaeological work is required in this area to explore avoidance possibilities and mitigation.
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Table 5:11: Archaeological sensitivity in the project area
Environmental feature Sensitivity Potential impact/enhancement Archaeological remains in Integrity of the archaeological heritage Destruction of archaeological heritage the vicinity of the pipeline in the Kuiseb Delta. and compromised integrity of the route. historical record of the area.
5.3 SOCIO-ECONOMIC ENVIRONMENT
5.3.1 Demography of Walvis Bay
According to the Uranium Rush SEA, the current population of the Erongo region is estimated to be 135, 250, which is higher than the 2001 regional population of 107, 663 (SAEIA, 2010). Approximately 80% of the population is thought to reside in urban areas such as Swakopmund and Walvis Bay (ERC, 2007). Pull factors to the region include the fishing industry, mining activities, and more recently, the ‘Erongo region uranium rush’. In Walvis Bay, a shortage of polio vaccines in 2006 indicated that the population was close to 60,000 at the time. This number was expected to grow to 70,000 by the end of 2009, and to almost double within the next 10 to 12 years (Marques, 2009)5
A number of factors contribute to Walvis Bay’s high unemployment rate of 36% (NPC, 2001). The town has a population growth rate which exceeds available jobs partly due to an influx of job seekers and their families and the seasonal variation of the fishing industry (Enviro Dynamics, 2010).
The economic activities of Walvis Bay rest on four pillars, namely fishing, tourism, manufacturing, and the port. The commercial fishing industry is the cornerstone of Walvis Bay’s economy; it is the biggest employer as it currently directly employs approximately 13,000 people throughout its value chain (Kathindi, 2011). Aquaculture is undertaken in the Bay and near Pelican Point.
Seawater is the main input with the salt works and it is one of the largest solar evaporation facilities in Africa as they annually process 24 million tons of sea water to produce more than 650,000 tons of high quality salt (WBSR, 2007). The Walvis Bay salt works is also part of the Ramsar Site at the lagoon and is important for the conservation of birdlife and tourism.
Almost one third of the Erongo Region is demarcated as state protected areas with two additional parks have recently been proclaimed, namely the Dorob and Ganab National Parks. Also, the process is currently underway to declare the Namib Desert as a World Heritage site, which is expected to bring about an additional tourist influx of 60-70% (Le Roux, 2011)6.
555 Marques, N., 2009. Interviewed by C. Biewenga, in Walvis Bay, on 12 June 2009. 6 Le Roux, M., 2011. Public meeting: Meeting with Authorities and Public in Windhoek on 1 December 2011.
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The lagoon, Dune 7 and 4×4 routes to Sandwich harbour and its Ramsar site in the Namib-Naukluft Park are important tourism destinations near Walvis Bay. A recent addition is the Bird Paradise, an eco- tourism venture at the sewerage treatment works. While the area behind the salt works southwards to the northern boundary of the Namib-Naukluft Park is a popular fishing area for recreational fishermen, many tourists and cyclists make use of the M0036 road (Le Roux, 2011)7.
The Toppenaar community has been living in the Kuiseb Delta for many years, hence many archaeological / historical sites can be found in that area. In order to limit unauthorized recreational and tourism activities which threaten these sites, the Kuiseb Delta Development Project has been established. Its purpose is protecting the historical sites while generating income from tourism. Socio- economic conditions of Walvis Bay and the region that are sensitive to change have been summarised in (Table 5:12) below.
7 Ibid
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Table 5:12: Sensitivities and potential impacts related to the socio-economic environment
Socio-Economic feature Sensitivity Potential impact/enhancement Employment Both the Erongo Region and Walvis Bay Contribution to job creation, both have estimated unemployment rates directly and indirectly, both during higher than 30%. construction and operational phases. Expertise and Skills Low skills level, especially in lower income Skills transfer and training. areas and also since this project will be a world first, specific skills will need to be acquired. National income NMP will contribute to the national economy by paying taxes and royalties. The multiplier effect. Fishing Industry The fishing industry is sensitive to changes The mooring point and pipeline in the fish stocks, potential pollution and running to the holding pond can limit catches are made as close as 0.5 m to the or hamper fishing activities in the shore. specific mooring point area. Fishing Industry The fish processing factories use water Pollution or changes in the water from the Bay in their canning and fish quality in the Bay can negatively processing operations and require it to be impact on the fish canning and of a certain quality. processing activities. Aquaculture Aquaculture activities take place in the Pollution or changes in the water Bay and these are reliant on a specific quality in the Bay can negatively water quality. impact on this economic activity. Conservation The NNP is in the process of being Restriction of access to the activities proclaimed as a National Heritage Site. of NMP within the national park. Recreation Many recreational fishermen frequent the Possible restriction of access to area between the Salt Works and fishing spots (caused by for example northern entry to NNP. pipelines) or disturbance to fish stocks in that area cause by activities associated with transferring the slurry form the vessel to the land and pollution issues. Recreation The road running from Walvis Bay past the Increase in traffic (i.e. trucks) can be a airport as well as the section leading to safety risk. Swakopmund behind the dunes is frequented by cyclists. Tourism Tourism activities are sensitive to changes Loss of revenue caused by a decrease in visual amenity and air pollution. in the number of tourist visiting the area due to visual and air pollution impacts.
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Socio-Economic feature Sensitivity Potential impact/enhancement Tourism Many tourism companies and concession Restriction of access to NNP and holders enter the NNP its northern Sandwich Harbour. boundary en-route to Sandwich Harbour. Tourism 4×4 excursions are undertaken to Sedimentation on the beach can Sandwich Harbour, entering the NNP at its cause restrictions on suitability and northern boundary. accessibility of driving on the beach. Tourism Planned tourism activities of the Kuiseb Disturbance to archaeological sites Delta Development Project, with special and features such as animal tracks on reference to their historical sites, !nara clay can negatively impact on the fields and springbuck in that area. The planned KDDP activities and KDDP area is to be declared as a National associated income. Heritage Site. Road Users The C14 road is used by tourists travelling Increase in traffic can increase the from Walvis Bay to places like Solitaire safety risk for users on the road. and Sossusvlei. Road Users Traffic problems are already experienced An increase in the number of trucks especially near the port entrances and on the road will further aggravate around peak traffic hours. traffic congestions, further inconveniencing road users and increase the safety risk. Livelihood activities The Toppenaar community has been Restriction of access to the !nara harvesting !nara in the Kuiseb river for fields or disturbance to the species, many years either for self consumption or negatively impacting on a livelihood selling. strategy of the Toppenaar community. Health Walvis Bay has the highest TB infection TB infections of the NMP workforce rate in Namibia. can lead to absenteeism and fatigue, ultimately impacting on productivity. Economics The Walvis Bay Salt Refiners’ (WBSR) Pollution can adversely impact on the activities are reliant water from the bay business activities and economics of and are sensitive to pollutants. WBSR. Existing In-migration Over the years, Walvis Bay has seen an This proposed project can further act trends influx of workers. as a pull factor for in-migration, adding to an existing trend. Existing Services Housing, water and electricity supply is An influx of workers or ex-patriots currently under pressure in Walvis Bay. employed by the project can further add to already pressures services and resources.
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5.3.2 Traffic
The processing site is located to the south of Main Road (MR) 36, south east of the existing weighbridge facility in Walvis Bay. MR 36 is a single lane bitumen surfaced road with spare capacity. The Roads Authority (RA) is currently investigating the feasibility of upgrading the road behind the dunes (C34) and MR 36 towards Solitaire. Should these upgrades come to pass, the traffic situation on MR 36, and within the project area will change substantially.
Road access from the processing site is possible. The current road route from the processing site to the harbour would be via MR 36, along 18th Road and 3rd Street East. Other road routes through Walvis Bay are possible but are not advised. The railway is situated directly north of MR 36 and is linked with the harbour. Rail access at the processing site would be possible but only with an additional siding and a rail/ road bridge.
Road traffic, especially within the Walvis Bay Central Business District (CBD) and Port area is already a sensitive issue as a result of congestion at the port entrance.
Should transport by a conveyor system be preferred, the route should follow the existing railway as far as possible since conveyor systems have inflexible alignment parameters similar to railways.
Figure 5:6: Road and Rail routes from the processing plant to the harbour.
Sensitive elements of the Walvis Bay traffic network are presented in (Table 5:13) below.
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Table 5:13: Sensitivities and potential impacts related to Transport
Feature Sensitivity Potential impact/enhancement Road network in Walvis Congestion at key intersections along Loss of intersection “level of service”. Bay the route.
Prolonged waiting times at intersections, leading to road network upgrade.
Necessitate road network upgrade. Rail Access to site Requires siding and rail/ road bridge. TransNamib logistical Potentially under capacity Rail congestion, logistical difficulties capacity and loss of productivity. Bulk handling facilities at Potentially under capacity Congestion, logistical difficulties and the Port loss of productivity. Operational and energy Carbon footprint and capital costs Excessive capital and carbon emissions. costs Public acceptance The Public is already affected by noise, Increased public nuisance (air pollution, air pollution and congestion. noise, congestion), negative public image.
5.3.3 Visual Resources
The project area is located in the direct vicinity of Walvis Bay and the coastal plain south of Walvis Bay. The terrain is relatively flat with small hummock dunes in the central section. The Central Namib Dune Belt between Walvisbay and Swakopmund is located to the north-east of the processing plant site of the project area, whereas the dune Belt south of the Kuiseb River is located further south of the holding pond.
To identify sensitive visual receptors in the vicinity of the project area the following criteria was applied:
A sight distance radius of up to 10 km, with a sight distance of up to 5 km as significant. The rationale for this selection is that the sight distance at the coast for clear conditions is approximately 8 km. Applied elevated conditions as a factor to increase sensitivity (Dune 7 and Rondeduin) The sight distance radius was applied to each of the holding pond site and the processing plant site. The access road and pipeline route is seen as not sensitive due to its low visibility and isolated locality. The visual receptors were selected based on:
Tourism relevance. Sense of place. Human settlement. Recreational relevance.
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The following were identified as possible sensitive visual receptors:
Table 5:14: Visual Receptor Catalogue
Potential Visibility No Viewpoint Name Processing Plant Holding Pond 1 Walvis Bay town area (Eastern Part). High / Medium Low
2 Walvis Bay Bird Sanctuary. High Low
3 The southern section of the Langstrand High / Medium Low approach to Walvis Bay. 4 Walvis Bay Lagoon. Medium / Low Low
5 Toppenaar historical sites south of Walvis Bay Medium Low near Wortel. 6 Proposed Wortel Camp Site. Low Low
7 The southern section of the Walvis Bay- High / Medium Low Swakopmund Dune Belt.
8 The M0036 approach from Rooikop Airport to High / Medium Low Walvis Bay. 9 Plum. Medium / Low Low
10 Pelican Point strip. Low Low
11 Paaltjies Beach (Southern Section) Low High/Medium
12 Rondeduin Low High
13 Western Section of the Ox Wagon Route up to Low Medium / High Rooibank 14 The Kuiseb Delta Low Medium / High
15 Prison Monument at Rooibank Low Low
16 Sandwich Beach approach (Northern section) Low Medium / High
The selected visual receptors were subjected to the 5km and 10km radius criteria of visibility in (Table 5:14) above. The selected visual receptors are split into two groups namely the receptors related to the Holding Pond and the viewpoints related to the Processing Plant.
From (Table 5:14) the following visual receptors need to be investigated for visual sensitivity:
The possible sensitive visual receptors for the processing plant: Walvis Bay town area (eastern part). Walvis Bay Bird Sanctuary. The southern section of the Langstrand approach to Walvis Bay.
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Walvis Bay Lagoon. Toppenaar historical sites south of Walvis Bay near Wortel. The southern section of the Walvis Bay-Swakopmund Dune Belt. The M0036 approach from Rooikop Airport to Walvis Bay.
The possible sensitive visual receptors for the Holding Pond: Paaltjies Beach (Southern Section). Sandwich Beach approach (Northern section). Rondeduin. Western Section of the Ox Wagon Route up to Rooibank The Kuiseb Delta.
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Figure 5:7: Visual resource and sensitive receptor distribution.
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These points will require further investigation to determine the actual view of the two visual sources, namely the Holding Pond and the Processing plant. Figure shows the various positions of the visual receptors in relation to the visual sources.
The visually sensitive terrain is therefore defined as:
The area between the salt works and Rondeduin in the Kuiseb Delta and along the coastline for the Holding Pond. The area between the Eastern Suburbs of Walvis Bay and the Rooikop Airport, with boundaries to the north from the southern section of the Walvis Bay-Swakopmund Dune Belt to the southern section of the Walvis Bay – Swakopmund road.
Sensitive elements of the Walvis Bay visual resources are presented in (Table 5:15) below.
Table 5:15: Sensitive visual resources in the project area
Environmental feature Sensitivity Potential impact/enhancement Tourism area around the The terrain is very flat with, little The degradation of the sense of place Kuiseb delta and along the immediate coastline at the vegetation; long sight distances and due to the visual intrusion of the holding pond. features a unique sense of place. holding pond and the shell dump. The eastern town area of The terrain is flat but slightly raised Degradation of the view along the main Walvis Bay and the main approaches to Walvis Bay. to the north-west with medium access routes (tourism) due to the density vegetation and low rise processing plant and tailings dam. buildings resulting in medium. Southern section of the The terrain is raised with very long Degradation of the view to the south- dine belt between Walvis Bay - Swakopmund. sigh distances and no visual west due to the processing plant and obstructions tailings dam.
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6 IDENTIFICATION OF KEY ISSUES
6.1 SCREENING OF ISSUES
In order to arrive at the final scope of the further investigations, all the baseline sensitivities, legal requirements as well as community concerns raised were collated. This list of issues was further screened to identify those for which further investigation is required, using a decision-making process explained in Figure
Does the issue fall within the scope of the study and the responsibility of NMP?
Yes No
Insufficient info Sufficient info available to assess available to address impact and consider the issue mitigation
Carry over to Issue communicated Key issue for further Environmental to applicable investigation Management Plan authority
Figure 6:1: Screening process to determine key issues
All the potential impacts identified for this project are presented in Figure 6:1with the above process applied. The highlighted rows represent potential significant impacts which require further investigation while the management of the remaining impacts will be addressed in the Environmental Management Plan.
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Table 6:1: Identification of key impacts
NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO Health and Safety Need for an emergency incidents Yes. Yes. Mitigation measures will be presented in the No. protocol for impacts associated EMP. with, for example, hazardous waste and dredge vessel spills. Radiation impacts of dredged and Yes. No. The radiation assessment will establish the Yes. Radiation Assessment study. stored material on workers and radiation levels and identify mitigation residents. measures. Health impacts associated with Yes. No. The air quality assessment will establish Yes. Air Quality Study. aerosols from the processing plant. whether there are aerosols and identify mitigation measures. Health hazards during construction, Yes. No. The air quality and radiation assessments will Yes. Air quality and radiation operational and post-operational identify hazards and mitigation measures. assessment studies. phases. Health impacts will not be fully Yes. No. The radiation, air quality and noise studies will Yes. Radiation, air quality and understood by socio-economic provide sufficient information to presented noise studies. specialist (request for health mitigation measures. No need for additional specialist). health and safety specialist. Technical Leaks, rust, pipe pressure, blockages Yes. Yes. Mitigation measures will be included in the Finalize designs and engineering in pipeline. EMP. work. Use of tailings dam residue material. Yes. No. A closure plan has to be compiled. Yes. Content analysis of tailings Rehabilitation measures will be presented in dam residue needed. the EMP.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO Meet international guidelines to Yes. No. Consider whether to line the ponds according Yes. Hydrogeological study. protect from seepage. to international guidelines. Consider the corrosive effect of Yes. (Technical Yes. Technical team to consider biofouling issue. No. Not in EIA. hydrogen sulphide, the effect of studies) wave exposure and biofouling on the pipeline/s and moorings (infrastructure maintenance). Effect of Kuiseb floods on the Yes. (Technical No. Yes. Depends on outcomes of geo-hydrology No. Finalize designs. pipeline. studies). study and final designs. Pipeline can be moved as a form of mitigation. Marine Ecology Impacts on marine biodiversity and Yes. No. A marine ecology study will be undertaken, Yes. Marine Ecology study. keystone species including larvae identifying the impacts and mitigations inshore and migratory patterns. measures to be included in the EMP. Impacts on benthic fauna, breeding Yes. No. A marine ecology study will be undertaken, Yes. Marine Ecology study. grounds and ecosystem degradation identifying the impacts and mitigations (impacting fisheries). measure to be included in the EMP. Impacts on live stocks in the Yes. No. A marine ecology study will be undertaken, Yes. Marine Ecology study. Benguela Current Large marine identifying the impacts and mitigations ecosystem. measures to be included in the EMP. Impacts on annual Cob run. Yes. No. A marine ecology study will be undertaken, Yes. Marine Ecology study. identifying the impacts and mitigations measures to be included in the EMP. ‘Illegal fishing’ by workers, not Yes. Yes. Mitigation measures to be outlined in the No. adhering to closed seasons EMP.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO (construction and operational phases). Impact on seabird population if Yes. No. A bird specialist study will be undertaken, Yes. Bird specialist study. water in the holding and/or tailings identifying the impacts and mitigations ponds is contaminated. measures to be included in the EMP. Impacts on oyster and mussel filter Yes. No. A marine ecology study will be undertaken, Yes. Marine Ecology study. feeding aquaculture farms. identifying the impacts and mitigations measures to be included in the EMP. Terrestrial Ecology Loss of terrestrial biodiversity (e.g. Yes. No. A terrestrial biodiversity study will be Yes. Terrestrial biodiversity study. biodiversity of dune belt, reptiles, undertaken, identifying the impacts and Dune Lark, beetle, birds). mitigations measures to be included in the EMP. Pipe as barrier to movement of Yes. No. A terrestrial biodiversity study will be Yes. Terrestrial biodiversity study. terrestrial fauna (brown hyenas, undertaken, identifying the impacts and jackals, ostrich, springbok). mitigations measures to be included in the EMP. Impact of stock piles on fauna living Yes. No. A terrestrial biodiversity study will be Yes. Terrestrial biodiversity study. on the beach. undertaken, identifying the impacts and mitigations measures to be included in the EMP. Proposed pipeline and holding pond Yes. No. A terrestrial biodiversity study will be Yes. Terrestrial biodiversity study. areas is in Salsola hummocks which undertaken, identifying the impacts and are an important habitat to a variety mitigations measures to be included in the of wildlife. EMP.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO Birds: sewerage works, holding Yes. No. A bird study will be undertaken, identifying Yes. Bird study. pond, temporary pools after Kuiseb the impacts and mitigations measures to be floods, beach. included in the EMP. Socio-Economic Benefits vs. opportunity costs of Yes. No. A socio-economic impact assessment will be Yes. Socio-economic study. project for Namibian economy. undertaken, identifying the impacts and enhancement/ mitigations measures to be included in the EMP. Opportunity cost to Namibian Yes. No. A socio-economic impact assessment will be Yes. Socio-economic study. citizens of not selling end product undertaken, identifying the impacts and locally. enhancement/ mitigation measures to be included in the EMP. Impact on existing and planned land- Yes. No. A socio-economic impact assessment will be Yes. Socio-economic study., use (e.g. salt works, aquaculture, undertaken, identifying the impacts and drawing on the other specialist recreational fishing, tourism, enhancement/ mitigation measures to be studies. Toppenaar, fishing, Marina). included in the EMP. Impacts on the sustainability of Yes. No. A socio-economic impact assessment will be Yes. Socio-economic study. aquaculture, individual commercial undertaken, identifying the impacts and fisheries within the Namibian fishing enhancement/ mitigation measures to be industry as job providers. included in the EMP. Impact on nearby protected areas Yes. No. A socio-economic impact assessment will be Yes. Socio-economic study. (e.g. Sandwich Harbour, Ramsar undertaken, identifying the impacts and site). Future International Heritage enhancement/ mitigation measures to be Site. included in the EMP. Increased influx of job-seekers Yes. No. A socio-economic impact assessment will be Yes. Socio-economic study putting additional pressure on undertaken, identifying the impacts and
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO already overloaded services and enhancement/ mitigation measures to be resources. included in the EMP. Tourism Air quality and visual impacts caused Yes. No. Socio-economic, visual impact assessment and Yes. Socio-economic study, Visual by development negatively an air quality study will be undertaken, study, and Air quality study. impacting on tourism activities identifying the impacts and enhancement/ leading to loss of revenue from mitigation measures to be included in the existing tourism trade. EMP. Impact of sedimentation on the Yes. No. A sediment dynamics study and socio- Yes. Socio-economic impact beach and tourism excursions. economic impact assessment will be assessment and sediment undertaken, identifying the impacts and dynamics study. enhancement/ mitigations measures to be included in the EMP. Restrictions on land to vehicle Yes. Yes. The pipeline will be buried, allowing access to The pipeline will be buried, access to beach and areas further the beach and NNP. Include in EMP. allowing access to the beach and south (e.g. Sandwich Harbor) due to NNP. Construction phase to be the buffer pond and pipe line. considered. Fresh Water and Energy Resources Availability of water. Yes. No. The source is currently uncertain. Yes. By NMP to obtain sustainable water resource. EIA assumes sustainable water resource. Management and treatment of Yes. No. A geo-hydrology study will be undertaken, Yes. Geo-hydrology study. water as a scarce resource. identifying the impacts and enhancement/ mitigation measures to be included in the EMP.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO Energy requirements and whether it Yes. No. A separate EIA will have to be conducted for Yes. Talks are underway between can be met. the construction of a new power line. NMP, NamPower and Erongo RED. Carbon footprint to be undertaken as part of EIA. Fresh Water Quality Pollution impacts: ground water, Yes. No. A geo-hydrology study will be undertaken, Yes. Geo-hydrology study. lagoon and salt pans, Narraville and identifying the impacts and enhancement/ sewage works wetland (seepage, mitigation measures to be included in the pond breaches, porous nature of EMP. soil). Through-flow of Kuiseb River to Yes. No. A geo-hydrology study will be undertaken, Yes. Geo-hydrology study. ocean interrupted (groundwater re- identifying the impacts and enhancement/ charge). mitigation measures to be included in the EMP. Seawater Quality Pollution impacts: red tide, salinity Yes. No. Geo-hydrology, marine ecology and sediment Yes. Geo-hydrology, marine levels, heavy metals, changes in PH dynamic studies will be undertaken, ecology and sediment dynamics levels, microbiological identifying the impacts and enhancement/ studies. contamination, pond breaches. mitigation measures to be included in the EMP. Turbidity of the returned water can Yes. No. Marine ecology and sediments dynamic Yes. Marine ecology and sediment cause gill clogging, reduced light, studies will be undertaken, identifying the dynamics studies. etc. impacts and enhancement/ mitigations to be included in the EMP. Increased concentration of dissolved Yes. No A marine ecology study will be undertaken, Yes. Marine ecology study. nutrients due to the high identifying the impacts and enhancement/
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO concentration of the sediment pore mitigation measures to be included in the water nutrients which may lead to EMP. increased number of local phytoplankton blooms.
Potential impacts of flocculants on Yes. No Marine ecology and sediment dynamics Yes. Marine ecology and sediment the marine environment. studies will be undertaken, identifying the dynamics studies. impacts and enhancement/ mitigation measures to be included in the EMP.
Need detailed pollution plume Yes. No A sediment dynamics study will be Yes. Sediment dynamics study model. undertaken, identifying the impacts and enhancement/ mitigation measures to be included in the EMP. Waste and Shell Disposal Consider the sediment impacts of Yes. No Marine ecology and sediment dynamics Yes. Marine ecology and sediment shell waste on intertidal ecosystem, studies will be undertaken, identifying the dynamics studies. marine life off Walvis Bay, both in impacts and enhancement/ mitigation terms of juvenile fish habitat, and measures to be included in the EMP. possible aquaculture impacts as the species farmed are primarily filter feeders. Effects of stock piling and location of Yes. No. Visual impact assessment and terrestrial Yes. Visual impact assessment and disposal. biodiversity studies will be undertaken, terrestrial biodiversity studies. identifying the impacts and enhancement/ mitigation measures to be included in the EMP.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO Waste management (including Yes. Yes. A marine ecology study will be undertaken, Yes. Marine ecology study. ballast water of vessel). identifying the impacts and enhancement/ mitigation measures to be included in the EMP Volume, temperature, radioactivity Yes. No. Marine ecology, geo-hydrology and sediment Yes. Marine ecology, water quality levels, chemical analysis, and dynamics studies will be undertaken, and sediment dynamics studies. microbial content of any effluent identifying the impacts and enhancement/ and or waste material, inclusive of mitigation measures to be included in the shell grit, returned to the sea is EMP. required. Site Selection Impact of holding pond on national Yes. No. Socio-economic and visual impact assessment Yes. Socio-economic impact park, Kuiseb Delta and Sandwich studies will be undertaken, identifying the assessment and Visual Impact Harbour. impacts and enhancement/ mitigation Assessment studies. measures to be included in the EMP. Impact of processing plant on Yes. No. Socio-economic and visual impact assessment Yes. Socio-economic impact surrounding land-use (Dorob Park, studies will be undertaken, identifying the assessment and Visual Impact Narraville, green valley, eco- impacts and enhancement/ mitigation Assessment studies. tourism). measures to be included in the EMP. Pipeline route not to interfere with Yes. Yes. Infrastructure EMP design no to interfere with No. Can be carried over to the salt works operations. salt work. Mitigation measures to be included EMP in the EMP. Consider alternatives in design and Yes. Yes. Avoidance of poorly selected alternatives. Yes. Derive info from the location, including Dune 7, and Definitive Feasibility Study. ecological footprint if combine holding pond and processing plant on one site.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO Kuiseb river flood vs. project site. Yes. No. A geo-hydrology study will be undertaken, Yes. Geo-hydrology study. identifying the impacts and enhancement/ mitigation measures to be included in the EMP. The current location puts a Yes. No. Geo-hydrology and sediment dynamics studies Yes. Geo-hydrology and sediment straightjacket around the lagoon. will be undertaken, identifying the impacts dynamics studies. and enhancement/ mitigation measres to be included in the EMP. Governance Buffer pond site will compromise Yes. No. A socio-economic impact assessment study Yes. Socio-economic impact potential World Heritage status of will be undertaken, identifying the impacts assessment. the Namib Desert. and enhancement/ mitigation measures to be included in the EMP. Pond site not in conformity with Yes. No. A socio-economic impact assessment study Yes. Socio-economic impact Nature Conservation Ordinance of will be undertaken, identifying the impacts assessment. 1975 and enhancement/ mitigation measures to be included in the EMP. Potential loss of traditional tenure Yes. No. A socio-economic impact assessment study Yes. Socio-economic impact rights. will be undertaken, identifying the impacts assessment and enhancement/ mitigation measures to be included in the EMP. Having two separate EIAs might not Yes. Yes. A final report combining all the issues from the Yes. consider the impacts holistically. marine and terrestrial component will be complied and submitted to DEA in order to view potential impact holistically.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO The sites fall under the ownership of Yes. Yes. N/A. Yes. NMP to apply for the land the Ministry of Lands and needed. Resettlement and MET. Cumulative and Long-term impacts Long-term expansion of harbour No. No. No. Yes. The Walvis Bay Structure plan activities and Walvis Bay. is to be updated and talks are underway with NamPort. Long-term impacts associated with Yes. No. Geo-hydrology, air quality and sediment Yes. Geo-hydrology, air quality accumulated pollution loads as dynamics studies will be undertaken, and sediment dynamics studies. project progresses. identifying the impacts and enhancement/ mitigation measures to be included in the EMP. Cumulative traffic impact owing to Yes. No. Transport and traffic studies will be Yes. Transport and traffic studies. existing salt works trucks. undertaken, identifying the impacts and enhancement/ mitigation measures to be included in the EMP. Positioning of the processing plant Yes. For the Consider strategically. Yes. Future, separate EIA for the and the future Phosphoric Acid Plant processing plant. Phosphoric Acid Plant. which is potentially 2-3 years away. Air Quality Air quality impact owing to odorous Yes. No. An air quality study will be undertaken, Yes. Air quality study. materials in tailings dam. identifying the impacts and enhancement/ mitigation measures to be included in the EMP. Air quality impact owing to Yes. No. An air quality study will be undertaken, Yes. Air quality study. prevailing SW winds and dry identifying the impacts and enhancement/
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO phosphate material stockpiles, mitigation measures to be included in the open-bed trucks as means of EMP. transport and dust. Impact of carbon emission, nitrous Yes. No. An air quality study will be undertaken, Yes. Air quality study. oxide and sulphur releases on air identifying the impacts and enhancement/ quality. mitigation measures to be included in the EMP. Assurance is required that the dust Yes. Yes. Engineering design consider this issue. Yes. Air quality study. Engineering generated from the handling of the Mitigation measures to be included in the design product in the port will not cause EMP. contamination of the salt stored in the port. Contribution of project’s carbon Yes. No. NO, need to be considered depending on Yes. Technical information footprint to climate change. sources of significant carbon loads. combined with carbon footprint study. Noise and Visual Impacts Noise and visual (lights at night) Yes. No. Visual impact assessment and noise impact Yes. Visual impact assessment and impacts associated with 24hr/7days assessment studies will be undertaken, noise impact assessment studies. a week operation. identifying the impacts and enhancement/ mitigation measures to be included in the EMP. Noise and visual impacts resulting Yes. No. Visual impact assessment and noise impact Yes. Visual impact assessment and from transport to harbour (three assessment studies will be undertaken, noise impact assessment studies. options) and harbour activities. identifying the impacts and enhancement/ mitigation measures to be included in the EMP. Visual, noise impact from processing Yes. No. A visual impact assessment study will be Yes. Visual impact assessment. plant and tailings dam. undertaken, identifying the impacts and
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO enhancement/ mitigation measures to be included in the EMP. Visual impact of pipeline and buffer Yes. No. A visual impact assessment study will be Yes. Visual impact assessment and pond for tourists near Sandwich undertaken, identifying the impacts and Socio-Economic Impact Harbour. enhancement/ mitigation measures to be Assessment. included in the EMP. Rehabilitating tailings at the end of Yes. No. A visual impact assessment study will be Yes. Visual impact assessment. the mining operation to limit visual undertaken, identifying the impacts and impacts. enhancement/ mitigation measures to be included in the EMP. A closure plan will also be developed. Infrastructure Impact of sand movement on all Yes. No. A sediment dynamics study will be undertaken, Yes. Sediment dynamics study. infrastructure. identifying the impacts and enhancement/ mitigation measures to be included in the EMP. Concerns about harbour space. Yes. In No. A transport and traffic study will be Yes. Transport and traffic study. Constraints and congestions. conjunction with undertaken, identifying the impacts and Talks by NMP with NamPort. NamPort enhancement/ mitigation measures to be included in the EMP. Talks are underway with NamPort. Sediment Dynamics On-shore sediment dynamics Yes. No. A sediment dynamics study will be undertaken, Yes. Sediment dynamics study. impacted due to dune stabilisation – identifying the impacts and enhancement/ potential to impact lagoon. mitigation measures to be included in the EMP.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO Impact on marine and coastal Yes. No. A sediment dynamics study will be undertaken, Yes. Sediment dynamics study. sediment dynamics due to inlet and identifying the impacts and enhancement/ outlet pipes, and shell disposal. mitigation measures to be included in the EMP. What effect will the pipeline have on Yes. No. A sediments dynamics study will be Yes. Sediments dynamics study. the movement of the sand dunes? undertaken, identifying the impacts and This needs to be modelled to enhancement/ mitigation measures to be ascertain whether it would increase included in the EMP. the deposition of aeolian sand into the salt works’ ponds. Need for hydrodynamic modelling. Yes. No. A sediments dynamics study will be Yes. Sediments dynamics study. undertaken, identifying the impacts and enhancement/ mitigation measures to be included in the EMP. Archaeology Archaeological impact on fossil Yes. Yes. The fossil oysters are not found near the buffer No. oysters near buffer pond. pond and are of little archaeological value.
Loss of various animal and human Yes. No. Route water pipeline sensitively Yes. Complete archaeological tracks on clay surfaces. study. Impact on Toppenaar grave sites, Yes. No. Route water pipeline sensitively. Yes. Complete archaeological cultural artefacts and heritage. study. Aviation Safety Physical objects must get approval Yes. No. Yes. Applicable regulations Yes, application to be made by from Directorate of Civil Aviation, NMP. Consider regulations in the e.g. chimneys and other high bjects. EIA which would trigger further applications.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO High concentration of metals can Yes. No. Yes. Determine heavy metal content cause possible interferences with for further possible work. aircraft operations. With aircraft operations. Air pollution such as dust or steam Yes. No. An air quality study will be undertaken, Yes. Air quality study. can be safety risk near airports. identifying the impacts and enhancement/ mitigation measures to be included in the EMP. Bird strikes and ponds near airports. Yes. No. A bird study will be undertaken, identifying the Yes. Bird study. impacts and enhancement/ mitigations to be included in the EMP. Need to respond to emergencies. Yes. Yes. Yes. Crossings should be clearly marked. No. Carry over to the EMP. Pipeline should not be a barrier. A safe distance of 11 m must be Yes. No. A transport and traffic study will be Yes. Transport and traffic study. maintained between 2 vehicles. An undertaken, identifying the impacts and increase in traffic can impact on this. enhancement/ mitigation measures to be included in the EMP. Transport Traffic jams near the harbour Yes. Transport No. A transport and traffic study will be Yes. Transport and traffic study. entrance, especially during peak and authorities. undertaken, identifying the impacts and traffic hours. enhancement/ mitigation measures to be included in the EMP.
Transport of workers. Yes. No. A transport and traffic study as well as socio- Yes. Transport and traffic study. economic impact assessment study will be Yes. Socio-Economic impact undertaken, identifying the impacts and assessment.
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NMP SUFFICIENT INFO FURTHER WORK TO BE IMPACT/ISSUE RESPONSIBILITY MITIGATION AVAILABLE YES/NO YES/NO CONDUCTED YES/NO enhancement/ mitigation measure to be included in the EMP.
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6.2 KEY ISSUES AND ASSOCIATED STUDIES
All the inputs received from the authorities, the public and from the specialists have been further condensed into main themes. Even though the themes overlap, a specialist can now be assigned to each area of study. Overlap between disciplines is accommodated by facilitating interaction between the various specialists.
(Table 6:2) below shows the key issues, the specialists assigned to each and their main Terms of Reference.
Table 6:2: Key issues to be investigated, specialists assigned and their main Terms of Reference
Theme / Study area Specialist Terms of Reference Marine ecology Dr Andrea Pulfrich Focus on the intertidal and shallow subtidal marine Pisces Environmental communities by studying changes in the: Services invertebrate macro-faunal community, nursery habitat, biodiversity and movement of marine fish (including larvae inchore and migratory patterns),
migration corridors and calving areas of the Southern Right whales. Sediment Dynamics Andre Theron, Focus on the marine and aeolian sediment dynamics Dr Gerhardus Diedericks CSIR by studying changes in the: sediment movement in the surf zone, beach and dunes due to the pipelines and other infrastructure and facilities, sediment movement in the surf zone due to the return of fines and shell to the sea Consider the effects of sealevel rise on the project activities. Terrestrial ecology Dr John Irish Focus on the terrestrial biodiversity by studying Biodata changes in the Inner (coastal) Namib due to: change in the ratio of endemic, range- restricted endemic and potentially threatened species, cumulative and related effects of change that the project add to the ecology. Birds Dr Justine Braby Focus on the avian interaction by studying changes in the: environment in the flight paths between
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Theme / Study area Specialist Terms of Reference wetlands, along the coast and to new manmade wetlands, feeding, roosting and breeding activities of birds dependent on the project area, bird distribution due to changed habitats and new artificial habitats, interaction of the birds with infrastructure, facilities and activities of the project and the consequences. Water Quality Pierre Botha Focus on the water and groundwater by studying (groundwater, surface Geo Pollution water on land and at sea) Technologies changes in the: groundwater quality and movement due to the infrastructure, facilities and activities of the project as well as in the surface water that periodically occurs in the project area, sea water quality due to the return of used seawater and process water to the sea. Semi purified water at the bird sanctuary due to the extraction and possible return of process water. Air quality Dr Mark Zunckel Focus on air quality by studying changes in the: uMOYA-NILU receiving environment by identifying potentially sensitive receptors, process emissions as well as baseline conditions at all infrastructure, facilities as well as the transport/export route, modelling the downwind air conditions created by the project infrastructure, facilities and activities. Noise Brett Williams Focus on noise by studying changes in the: Safetech receiving environment by identifying potentially sensitive receptors, process emissions as well as baseline conditions, modelling the noise conditions created by the construction and operation of the project infrastructure, facilities. Visual change Norman van Zyl Focus on visual changes in the: Enviro Dynamics receiving environment by identifying potentially sensitive receptors and visual sources generated by the project
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Theme / Study area Specialist Terms of Reference infrastructure, facilities and activities, generating a visual inventory to determine the value of the views from the various visual receptors, model the visibility of the project infrastructure, facilities and activities from significant views. Socio-economic, including Carla Saayman Focus on the socio-economic environment by tourism Enviro Dynamics studying changes in the: various forms of land-use, fishing, tourism, conservation, traditional livelihood industries, social and economic movement. Traffic Theo Potgieter Focus on the impact of traffic alternatives by: Burmeister & Part. reviewing the data of the Transport Study against existing information assess the changes in the environments in which the various transport options operates. Archaeology Dr John Kinahan Focus on the archaeology landscape of the Kuiseb QRS Namibia Delta and the surroundings by: conducting an overview of the project area to identify sensitive areas to avoid (completed to guide the planning process). detailed survey of the pipeline route to ensure that individual sites are avoided
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Theme / Study area Specialist Terms of Reference Carbon emissions Brett Cohen Conduct a carbon emissions study according to the The Green House Greenhouse Gas Protocol, to help delineate direct and indirect emission sources of the project, and improve transparency of the calculations as follows: Scope 1: Direct GHG emissions from sources that are owned or controlled by the company. For example, this would include emissions from company owned vehicles Scope 2: Electricity indirect GHG emissions from the generation of purchased electricity consumed by the operations. These emissions occur at the power station. Scope 3: Other indirect GHG emissions include those emissions that occur as “a consequence of the activities of the company, but occur from sources not owned or controlled by the company”. These might include production of purchased materials, transport of materials or products by an outside firm or emissions during the use of the products sold.
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Theme / Study area Specialist Terms of Reference Radioactivity Japie van Blerk Conduct a radiation impact study of the AquiSim Consulting (Pty) future impacts during the operation and Ltd closure of the land based process including the transport of product to the port and the loading thereof into vessels for export. This study should take account of sensitive areas such as the salt works, personnel exposed to the process, adjoining residential areas, and issues raised during scoping. The cumulative impact over time due to the build-up of radioactive material in the various stages of the process must be described. The minimum outputs of the study should include a qualitative radiological impact assessment, a radiation protection plan to be included in the overall EHS plan for the operation and closure of the land based process and the design of a radiation monitoring plan to be included in the EMP including post operations phase.
6.3 ALTERNATIVES
The EIA Team needs to consider the costs of the various site alternatives that are available and demonstrate how each fare in terms of sustainability criteria. Where technical constraints are applicable for certain options, they need to be identified and explained. The following alternatives will be considered:
6.3.1 Site alternatives:
Alternatives sites for mooring Buffer pond site alternatives Processing plant site alternatives
6.3.2 Alternative technologies for:
Water return Effluent disposal Pump technologies Sewage treatment
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Shell disposal Screening options Traffic options
6.4 IMPACT ASSESSMENT METHODOLOGY
The following methods will be used by all specialists to determine the significance rating of impacts identified:
6.4.1 Description of impact –
1. Reviews the type of effect that a proposed activity will have on the environment; 2. What will be affected; and 3. How will it be affected.
Points 1 to 3 above are to be considered / evaluated in the context of the following impact criteria: Extent; Duration; Probability; and Intensity / magnitude
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Table 6:3: Impact criteria for determination of significance
Extent Site specific Local Regional National International At the facility Limited to within a (100km radius) Namibia Extending constructed/ 15km radius beyond operated. Namibia’s borders Duration Very Short Term Short term Medium term Long term Permanent 3 days 3 days – 1 year 1 - 5 years 5 – 20 years > 20 years (life of mine) Intensity/ No lasting effect Minor effects Moderate effects Serious effects Magnitude No environmental The environment Environmental Environmental functions and functions, but in a functions and functions and processes are modified manner processes are processes are altered affected altered to such to such extent that extent that they they permanently temporarily cease cease
Status of the impact: A description as to whether the impact is positive (a benefit), negative (a cost), or neutral.
Degree of confidence in predictions: The degree of confidence in the predictions, based on the availability of information and specialist knowledge. This is assessed as high, medium or low.
Based on the above considerations, the specialist provides an overall evaluation of the significance of the potential impact, which is described as follows: Table 6:4: Significance descriptions
None Low Medium High Impact A concern or potential Any magnitude, impacts Impacts of moderate Impacts of high Significance impact that, upon will be localised and magnitude locally to magnitude locally and evaluation, is found to temporary regionally in the short in the long term have no significant Accordingly the impact is term. and/or regionally and impact at all. not expected to require Accordingly the impact beyond. amendment to the is expected to require Accordingly the project design. modification of the impact could have a project design or ‘no go’ implication for alternative mitigation. the project unless mitigation or re- design is practically achievable.
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Furthermore,
Impacts are described both before and after the proposed mitigation and management measures have been implemented; Where possible the impact evaluation takes into consideration the cumulative effects associated with this project. Cumulative impacts can occur from the collective impacts of individual minor actions over a period of time and can include both direct and indirect impacts; Mitigation / management actions: Where negative impacts were identified, the specialists specifies practical mitigation measures (i.e. ways of avoiding or reducing negative impacts); and Monitoring (forms part of mitigation): Specialists recommend monitoring requirements to assess the effectiveness of mitigation actions, indicating what actions are required, the timing and frequency thereof.
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7 THE WAY FORWARD
7.1 OBJECTIVES
The objectives of this report were as follows: (provided in Section 1), except for the way forward have been successfully met.
7.1.1 Assumptions and limitations
It is assumed that the water resource identified to supply the processing plant will be sufficient and sustainable. The semi-purified water from the municipal sewage treatment works will not fulfil the fresh water demand of the processing plant as originally envisaged. The project proponent is therefore responsible for identifying and securing an alternative water resource which is sufficient and sustainable. It is acknowledged that there are major constraints to the project in terms of transport, water and power supply, land availability and export logistics. These aspects are still being investigated by the project technical team. As soon as these have been resolved, stakeholders will be advised and given opportunity to comment and raise issues and concerns, which will be addressed by the appropriate specialists. Even though the specialist studies have been commissioned and will progress concurrently with the Definitive Feasibility Study Process, the final output of the latter study is required for the Draft Environmental Impact Report to be completed. The scope of this EIA excludes further local beneficiation and the power line route which are not included in the project description.
7.1.2 The Way Forward
This Draft Scoping Report will be circulated to the authorities and public for comment. These comments will be a) incorporated into the report and b) carried forward for consideration in the remaining phases of the EIA process. The Draft Scoping Report will be submitted to the DEA. Currently there is no legal obligation to obtain comment on the Scoping Report from the DEA, so it is submitted primarily as a progress report. The specialist studies have been commissioned, as outlined in Section 6 (this is the full investigation phase). These specialist studies will form the basis for the Draft Environmental Impact Report and will inform the environmental considerations of the Definitive Feasibility Study Process.
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8 WORKS CITED
Boorman M (2011) Unpublished data of ephemeral wetland counts in 2011.
Coastal Environment Trust of Namibia (CETN) (2012) Unpublished data of Walvis Bay counts in 2011.
International Union for Conservation of Nature (IUCN) (2009) Summary statistics for globally threatened species. www.iucnredlist.org/. Last accessed 2 February 2012.
Council for Scientific and Industrial Research (CSIR) (2009) Draft Environmental Impact Report for the Proposed Desalination Project at Mile 6 Near Swakopmund, Namibia. Unpublished Report.
Enviro Dynamics (2010) Environmental Impact Assessment Report for the Improved Water Supply To Langer Heinrich Mine. Unpublished.
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