No. 7258, Near Okahandja in the Otjozondjupa Region

Environmental Assessment (EA) For Exclusive Prospecting License (EPL) No. 7258, near Okahandja in the Otjozondjupa Region

FINAL REPORT

ECC APPLICATION Number: 001573

Author(s): Ms. Althea Brandt & Mr. Silas David Client: Johannes Malume Gariseb Reviewer: Mr. Nerson Tjelos Contact person: Johannes Malume Gariseb Company: Excel Dynamic Solutions (Pty) Ltd Telephone: +264 (0) 61 504 238 Telephone: +264 (0) 61 259 530 Email: [email protected] Fax2email: +264 (0) 886 560 836 Email: [email protected]

March 2020 Johannes Malume Gariseb EIA: EPL 7258

EXECUTIVE SUMMARY

Johannes Malume Gariseb (The Proponent), a holder of an Exclusive Prospecting License (EPL 7258) granted by the Ministry of Mines and Energy (MME), intends to acquire an Environmental Clearance Certificate (ECC) to be able to conduct prospecting and exploration activities on the EPL. The tenure of the licence is from 15 May, 2019 to 14 May, 2022. According to earth data available on the MME mining cadastral portal, the Proponent has been granted the mineral right to explore three commodities, with pending approval of the application for two additional commodity groups. The commodity groups covered by the licence are:

- Base and rare metals (granted)

- Precious metals (granted)

- Dimension stones (granted)

- Industrial Minerals (applied for)

- Semi-Precious Stones (applied for)

The licence is situated near Okahandja in the Otjozondjupa Region (coordinates: -21°50’24’’ S, 16°21’25’’ E), and it covers an area of 19442.7392 ha.

Excel Dynamic Solutions (Pty) Ltd (hereinafter referred to as EDS) has been appointed to conduct the Environmental Assessment (EA) required to apply for the ECC, in accordance with the Environmental Management Act (7 of 2007).

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Project Description

The Proponent plans to conduct prospecting and exploration activities to search for and potentially develop an economic mineral deposit. There are no records of any systematic exploration over the EPL. The selection of the potential mineralization model and exact exploration targets will be selected based on the regional and local geology. The scoping process will identify sensitive environmental features that might be affected by the proposed prospecting and exploration activities. The level and magnitude of planned exploration work is not clear at this stage. However, both invasive and non-invasive exploration activities are expected to take place upon issuance of an environmental clearance certificate. Non-invasive activities include geological field mapping, geophysical survey work, airborne and ground based surveys. Invasive activities involve soil and rock sampling, trenching and drilling. The Proponent plans to conduct a staged exploration approach as follows:

Prospecting and Exploration (Construction/Initiation Phase)

During the phase of prospecting and exploration, reviewing of existing reports and composite stratigraphic, lithological-geochemical maps of the targeted areas to identify prospective lithostratigraphic packages will be vital. Field work (lithological (soil/rock) mapping and sampling) will also be conducted to verify desktop work. Up to this point, no physical disturbance is required.

During a more advanced exploration phase the Proponent will assess the license area through detailed geological mapping, geophysical and geochemical surveys, supported where necessary by geophysical surveys, with a view to defining targets for drilling testing.

Exploration drilling, Sampling and Analysis (Operational and Maintenance Phase)

During this phase, the exploration program will be in operation. Therefore, the target areas within EPL 7258 boundaries, which have been acknowledged during the initial prospecting and exploration phase, will go through exploration drilling. Diamond drilling will be considered to test a number of targets. Larger amount of sample materials may be required for analysis in the advanced stage of exploration activities on the EPL, to perform processing trails. Furthermore, pits may be dug for sampling. Depending on the nature of mineralization observed from drilling, the sample size may be adjusted. No explosives will be used during the exploration phase.

Other aspects of the exploration include:

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ACCESS

The EPL is situated in central Namibia approximately 8 km west of Okahandja Town on the B2 road. Okahandja is connected to the capital city via B1 National road. The tenement can be reached from the B1 National road at Okahandja via a secondary gravel road that leads further westward to the EPL site. Regionally, the paved all weather Trans-Caprivi Highway road links Walvis Bay to the countries of Botswana, Zambia and Zimbabwe, as well as the Democratic Republic of Congo. In addition, the Trans-Kalahari Highway links Walvis Bay with South Africa’s Gauteng industrial heartland via Botswana. A harbour (Namport) is found in Walvis Bay that gives a platform for samples and mined materials to be offloaded or loaded onto transnational shipping lines.

RESOURCES

The required input for exploration program in terms of vehicles and equipment include; two SUV (4X4) vehicles, earthmoving equipment, jackhammers; compressor and generator, field storage and rocks analysis equipment (i.e., XRF analyser).

SERVICES AND INFRASTRUCTURE

Water & Power Supply: Water required for the operation phase will be obtained from nearest boreholes and off-site municipal source and/or from any other approved water sources, through water abstraction permits. The estimated total monthly water consumption is at ±12,800 litres for drinking, sanitation, cooking, dust control, and washing equipment. A diesel power generator will be used for power supply during the exploration phase.

Accommodation: Exploration staff will be accommodated in Okahandja. If the accommodation camp is to be set up on a neighboring farm, necessary arrangements will be done with the farm owner. Exploration activities will take place during day time only, and the exploration team will be commuting to the work site from their accommodation place.

Timeframe: The planned ground geophysical surveys will be done in stages on different parts of the properties. Geological mapping will be done in two (2) months; and a 9 to 12 months exploration period is predicted

Waste Management: Mineral waste and non-mineral waste will occur onsite. Depending on the amount generated, waste will be sorted and collected on a weekly or monthly basis and taken to the nearest landfill site. Ablution facilities will be chemical toilets and/or sealed septic tanks and

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Johannes Malume Gariseb EIA: EPL 7258 the sewerage taken to the nearest storage facility, periodically. The disposal of wastewater as well as all other type of waste will be strictly controlled.

Security: Temporary storage areas for machines and other project materials and equipment will be necessary at the camp. Security will be supplied on a 24-hour basis at the storage and/or camp site and exploration camp. A temporary support fence surrounding the storage/camp site will be constructed to ensure people and domestic animals are not put at risk.

Decommissioning and Rehabilitation Phase

This phase is primarily reinforced through a decommissioning and rehabilitation plan which, among others, consist of safety, health, environmental and contingency aspects. The economic situation or unconvincing exploration results may force the Proponent to eventually cease with the exploration program. Therefore, it is of best practice for the Proponent to ensure that the removal of all platforms constructed; and waste materials generated on site throughout the exploration phase are environmentally disposed of. Necessary landscaping of exploration areas will be undertaken upon completion of each phase of exploration.

Project Alternatives The alternatives for consideration of outcomes of the proposed development are summarized below:

 No-go alternative: The “No-Go” alternative is the option of not proceeding with the activity, which typically implies a continuation of the status quo. Should the proposed works of the prospecting and exploration plan be discontinued, none of the potential impacts (positive and negative) identified would occur. In considering the proposed project, the ‘no-go’ option is not considered the preferred alternative.

 Prospecting location: The prospecting/exploration location is dependent on the mineralogy and geology of the area. Therefore, finding an alternative location for the planned exploration activities is not possible. The tenement has sufficient surface rights that, should an economic mineral deposit be defined, there is an adequate area for potential storage and processing facilities.

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 Exploration Methods: Both invasive and non-invasive exploration activities are expected to take place. If an economically viable discovery is made, the project will proceed to mining phase. A separate full environmental assessment will be undertaken for the mining phase.

Impact Identification

The potential positive and negative impacts that have been identified for the proposed establishment activities are as follows:

Positive impacts:

 Creation of jobs to the locals (primary, secondary and even tertiary employment).  Uplift local economic growth.  Open up other investment opportunities.  Contribution to regional economic development. Negative impacts:

 Loss of biodiversity  Generation of dust  Waste generation  Water quality is affected  Land use conflict arises  Visual impact (scars) on landscape  Potential health and safety risks  Surrounding soils disturbance  Archaeological impact  Noise pollution  Socio-economic problems

Impacts Assessment and Mitigations

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The key potential impacts associated with exploration (operation and decommissioning phases of the project) were identified and assessed. In order to avoid and minimise (where impacts cannot be avoided) the identified project impacts, mitigation measures were recommended. The significant identified impacts for the project phases are summarized below. These impacts can be reduced or curtailed by implementing the mitigation measures given under the impact assessment chapter and also management actions plan provided in the Draft EMP.

 Loss of Biodiversity: Land degradation will occur due to drilling activities and earthworks done during exploration, which could have a catastrophic impact on the biodiversity of the area, leading to habitat loss for a diversity of flora and fauna. Endemic species are most severely affected as disruptions in their habitat can result in extinction. It is, therefore, important to identify and understand existing species and minimize impact upon them with operational management guidelines. Under the current status quo, the impact can be considered to be of a medium significance rating. With the implementation of appropriate mitigation measures, the rating will significantly be reduced to low. Generation of Dust: Dust emanating from site access roads when transporting exploration equipment and supplies to and from site, and eventual drilling done at the site may compromise the air quality in the area. The hot and dry environment, loose and sandy nature of the substrate and low vegetation cover, also causes ambient fugitive dust levels. The medium significance of this impact can be reduced by properly implementing mitigation measures.

 Waste Generation: Generation of waste during the prospecting and exploration phase may cause land and water pollution on site if waste is not disposed in a responsible way. Precautions should be taken to prevent any spreading of refuse. Waste containers should be covered with mesh to prevent access by animals. With mitigation measures, the impact will be reduced from medium significance to low significance.

 Visual Impact (Scars) on Landscape: Exploration activities leave scars on the landscape. Thus, causing a visual impact. If the exploration site is situated near tourists’ routes, these scars may contrast the surrounding landscape and this can potentially cause visual nuisance to tourists. However, it is vital to note that throughout exploration phase, assured measures will need to be taken into concern regarding the visual aspect. Currently, the visual impact can be rated as medium to low significance, but upon effectively implementing the measures.

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 Potential Health and Safety Risks: Inappropriate handling of exploration materials and equipment may cause health and safety risks such as injuries to workers. The impact is probable and has a medium significance rating. However, with adequate mitigation measures, the impact rating will be reduced to low.

 Surrounding Soils: Planned exploration activities will potentially disturb the soil structure on the site, which will leave the already exposed site soils vulnerable to erosion resulting into creation of gullies. This impact is likely because the proposed site has little vegetation cover. The impact can be rated as medium, if no mitigation measures are implemented. However, with the implementation of mitigation measures, the impact will reduce to low.

 Archaeological Impact: Historical resources may be impacted through unintentional destruction or damage during exploration activities. There has been information provided about the known heritage or site of cultural values within the site or in the vicinity of the project area. Therefore, this impact can be rated high, but upon implementation of the necessary measures, the impact will be reduced to medium and then to low.

 Noise and Vibrations: Noise pollution is most likely to be created by drilling machines during the exploration activities, which could be a nuisance to neighbours. Extreme noise pollution can cause hearing problems thus health risks to workers on the site. This impact is rated as of medium significance, and can be reduced to low significance by incorporating the SANS 10103 to address the environmental noise standard. The maximum impulsive sound tonality in accordance with SANS 10103 should not exceed 45 (dBA) per daytime throughout the exploration phase.

Conclusions

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The potential positive and negative impacts stemming from the proposed exploration activities on the EPL 7258 were identified, assessed and mitigation measures made thereof. The mitigation measures and recommendations provided in this EIA report and the management action plans provided in the draft EMP, can be deemed sufficient to avoid and/or reduce the risks to acceptable levels. EDS is therefore confident that these measures are sufficient and thus recommends that the Proponent be issued with the Environmental Clearance Certificate (ECC) to enable the exploration of base metals on the tenement, EPL 7258. However, the ECC should be issued on a condition that the provided management measures and action plans are effectively implemented on site and monitored. Should the ECC be issued, the Proponent will be expected to be compliant to the ECC conditions as well as legal requirements governing the mineral exploration and related activities.

Limitations

EDS warrants that the findings and conclusions contained herein were accomplished in accordance with the methodologies set forth in the Scope of Work and EMA, 2007. These methodologies are described as representing good customary practice for conducting an Environmental Impact Assessment of a property for the purpose of identifying recognized environmental conditions. There is a possibility that even with the proper application of these methodologies there may exist on the subject property conditions that could not be identified within the scope of the assessment or which were not reasonably identifiable from the available information. EDS believes that the information obtained from the record review and during the public consultation process concerning the subject property is reliable. However, EDS cannot and does not warrant or guarantee that the information provided by these other sources is accurate or complete. The conclusions and findings set forth in this report are strictly limited in time and scope to the date of the evaluations. No other warranties are implied or expressed.

Some of the information provided in this report is based upon personal interviews, community meetings and research of available documents, records, and maps held by the appropriate government and private agencies. This report is subject to the limitations of historical documentation, availability, and accuracy of pertinent records and the personal recollections of those persons contacted.

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COVID-19 Influences

Covid -19 has changed the way the world thinks, acts and does business. The pandemic has forced a comprehensive review of business practices, a higher level of engagement with technology to offset the constraints due to social distancing, restrictive travel, and a focus on social responsibility. The constraints had to change very little in the way we operate and provide public consultation services.

Although the Consultant operated with limited travel during the environmental assessment to comply with the measures and regulations put in place to curb the spread of Covid-19, various other platforms were used to communicate the project information. These platforms included emails, registered mails, notices, newspaper adverts, and telephonic communication.

The Consultant practices included but are not limited to:

 Social distancing was strictly enforced when on project site

 Face masks worn by members during site assessment visits

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... i LIST OF FIGURES ...... xii LIST OF TABLES ...... xii LIST OF APPENDICES ...... xiiixii LIST OF ABBREVIATIONS ...... xiv 1 INTRODUCTION ...... 1 Project Background ...... 1 Terms of Reference and Scope of Works ...... 2 Appointed Environmental Assessment Practitioner ...... 3 Details of the Project Proponent ...... 4 The Need for the Proposed Project ...... 4 2 PROJECT DESCRIPTION: PROPOSED EXPLORATION ACTIVITIES ...... 6 Pre-Development Phase (Prospecting) ...... 6 Site Preparation, Operation and Maintenance (Exploration Drilling, Sampling and Analysis)8 2.1.2 Equipment and Material ...... 9 2.1.3 Services and Infrastructure ...... 9 2.1.4 Accommodation ...... 9 2.1.5 Timeframe ...... 10 2.1.6 Waste Management ...... 10 2.1.7 Security ...... 10 2.2 Decommissioning and Rehabilitation Phase ...... 1011 3 PROJECT ALTERNATIVES ...... 12 3.1 Types of Alternatives Considered ...... 12 3.1.1 The "No-go" Alternative ...... 12 3.1.2 Exploration Location ...... 13 3.1.3 Exploration Methods ...... 13 4 LEGAL FRAMEWORK: LEGISLATION, POLICIES AND GUIDELINES ...... 14 The Environmental Management Act (No. 7 of 2007) ...... 14 5 ENVIRONMENTAL BASELINE ...... 20 5.1 Climate ...... 20 5.2 Topography and Local Geology ...... 24

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5.3 Soils ...... 25 5.4 Water Resources ...... 27 5.5 Fauna ...... 28 5.6 Flora ...... 28 5.7 Population of the Otjozondjupa Region ...... 30 Otjozondjupa Region is one of the largest regions in the country with a land surface area of 105,185 km and represents 12.8% of the total land surface area of Namibia. It divides into seven constituencies, namely: Grootfontein, Otjiwarongo, Otavi, Okakarara, Omatako and Okahandja. The region has a population of 135,723...... 30 5.8 Tourism, Heritage and Archaeology ...... 30 5.9 Surrounding Land Uses ...... 31 5.10 Services and Infrastructure ...... 33 6 PUBLIC CONSULTATION PROCESS ...... 34 Pre-identified and Registered Interested and Affected Parties (I&APs) ...... 34 Communication with I&APs ...... 35 6.1 First Round Public Feedback ...... 35 7 IMPACT IDENTIFICATION, ASSESSMENT AND MITIGATION MEASURES ...... 37 Impact Identification ...... 37 Impact Assessment Methodology ...... 38 7.1.1 Extent (spatial scale)...... 40 7.1.2 Duration ...... 40 7.1.3 Intensity, Magnitude/Severity ...... 40 7.1.4 Probability of occurrence ...... 41 7.1.5 Significance ...... 42 Assessment of Potential Negative Impacts: Surveys, Drilling, Sampling (Operational Phases) ...... 43 7.1.6 Loss of Biodiversity (Fauna and Flora) ...... 45 7.1.7 Generation of Dust ...... 46 7.1.8 Waste Generation ...... 47 7.1.9 Visual Impact (Scars) on Landscape ...... 48 7.1.10 Potential Health and Safety Risks ...... 48 7.1.11 Surrounding Soils Impacted ...... 49 7.1.12 Archaeological Impact ...... 50 7.1.13 Noise and Vibrations ...... 50

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Assessment of Potential Negative Impacts: Decommissioning Phase ...... 51 7.4.1 Impact on Employment Opportunities and Economic Contribution ...... 51 8 RECOMMENDATIONS AND CONCLUSIONS ...... 53 Recommendations ...... 53 Conclusions ...... 54 9 REFERENCES ...... 55

LIST OF FIGURES

Figure 1: Location of the EPL 7258 near Okahandja in the Otjozondjupa Region ...... 3 Figure 2: Diagram of the Life Cycle of a Mine (source: Superfund Research Project, 2019). The red box shows the Phase covered by this study ...... 6 Figure 3: The mineral exploration cycle (source: Savannah Resources, 2019) ...... 7 Figure 4: Graph showing temperature patterns for one year (March 2019-January 2020) in Okahandja, Otjozondjupa Region...... 21 Figure 5: Graph showing rainfall patterns between March 2019 and January 2020 in Okahandja, Otjozondjupa Region ...... 22 Figure 6: Graph showing wind patterns between March 2019 and January 2020 in Okahandja, Otjozondjupa Region...... 23 Figure 7: Graph showing humidity patterns between March 2019 and January 2020 in Okahandja, Otjozondjupa Region ...... 24 Figure 8: Map showing the geology of the project area...... 25 Figure 9: Typical soil types (a and b) on the proposed exploration site ...... 27 Figure 10: Typical flora found on the EPL 7258 ...... 29 Figure 11: Map showing vegetation structure and plants found on EPL 7258 and surrounding areas ...... 30 Figure 12: Map showing farms within the EPL 7258 site ...... 32 Figure 13: Environmental Assessment Process and Progress (source: Risk Based Solutions, 2019) ...... 38

LIST OF TABLES

Table 1: Proponent contact details and purpose of required ECC ...... 4 Table 2: Applicable local, national and international standards, policies and legislation guiding the proposed development ...... 15 Table 3: Summary of Interested and Affected Parties (I&APs) ...... 34 Table 4: Extent or Spatial Impact rating...... 40 Table 5: Duration impact rating ...... 40 Table 6: Intensity, Magnitude/Severity impact rating ...... 41

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Table 7: Probability of Occurence impact rating ...... 41 Table 8: Significance rating scale ...... 42 Table 9: Assessment of the impacts of exploration on biodiversity ...... 45 Table 10: Assessment of the impacts of exploration on air quality ...... 46 Table 11: Assessment of waste generation impacts ...... 47 Table 12: Assessment of the visual impact of exploration on landscape ...... 48 Table 13: Assessment of the impacts of exploration on health and safety ...... 48 Table 14: Assessment of the impacts of exploration on soils ...... 49 Table 15: Assessment of the impacts of exploration on archaeological sites ...... 50 Table 16: Assessment of the impacts of noise from exploration ...... 51 Table 17: Assessment of the impacts of closure of exploration activity on employment ...... 52

LIST OF APPENDICES

Appendix A: ECC Application Form plus Revenue Stamps

Appendix B: Environmental Management Plan (EMP)

Appendix C: Curricula Vitae (CV) for the Environmental Assessment Practitioner (EAP)

Appendix D: List of Interested and Affected Parties (I&APs)

Appendix E: Background Information Document (BID)

Appendix F: EIA Notification in the newspaper (Namibian Sun and Republikein – Market watch)

Appendix G: I&APs Letters

Appendix H: Copy of Mineral License Certificate from MME

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LIST OF ABBREVIATIONS

Abbreviation Meaning

AMSL Above Mean Sea Level

BID Background Information Document

CV Curriculum Vitae

DEA Department of Environmental Affairs

EA Environmental Assessment

EAP Environmental Assessment Practitioner

ECC Environmental Clearance Certificate

EDS Excel Dynamic Solutions

EIA Environmental Impact Assessment

EMA Environmental Management Act

EMP Environmental Management Plan

EPL Exclusive Prospecting License

GG Government Gazette

GN Government Notice

I&APs Interested and Affected Parties

MET Ministry of Environment and Tourism

MME Ministry of Mines and Energy

Reg Regulation

S Section

TOR Terms of Reference

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Key Terms

Alternative A possible course of action, in place of another that would meet the same purpose and need of the proposal.

Baseline Work done to collect and interpret information on the condition/trends of the existing environment.

Biophysical That part of the environment that does not originate with human activities (e.g. biological, physical and chemical processes).

Cumulative In relation to an activity, means the impact of an activity that in it may not Impacts/Effects be significant but may become significant when added to the existing and Assessment potential impacts eventuating from similar or diverse activities or undertakings in the area.

Decision-maker The person(s) entrusted with the responsibility for allocating resources or granting approval to a proposal.

Ecological Processes Processes which play an essential part in maintaining ecosystem integrity. Four fundamental ecological processes are the cycling of water, the cycling of nutrients, the flow of energy and biological diversity (as an expression of evolution).

Environment As defined in Environmental Management Act - the complex of natural and anthropogenic factors and elements that are mutually interrelated and affect the ecological equilibrium and the quality of life, including – (a) the natural environment that is land, water and air; all organic and inorganic matter and living organisms and (b) the human environment that is the landscape and natural, cultural, historical, aesthetic, economic and social heritage and values.

Environmental As defined in the EIA Regulations (Section 8(j)), a plan that describes how Management Plan activities that may have significant environments effects are to be mitigated, controlled and monitored.

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Interested and Affected In relation to the assessment of a listed activity includes - (a) any person, Party (I&AP) 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. Mitigate - practical measures to reduce adverse impacts. Proponent – as defined in the Environmental Management Act, a person who proposes to undertake a listed activity. Significant impact - means an impact that by its magnitude, duration, intensity or probability of occurrence may have a notable effect on one or more aspects of the environment.

Fauna All of the animals found in a given area/region, habitat or geological period.

Flora All of the plants found in a given area/region, habitat or geological period.

Mitigation The purposeful implementation of decisions or activities that are designed to reduce the undesirable impacts of a proposed action on the affected environment.

Monitoring Activity involving repeated observation, according to a pre-determined schedule, of one or more elements of the environment to detect their characteristics (status and trends).

Proponent Organization (private or public sector) or individual intending to implement a development proposal.

Public A range of techniques that can be used to inform, consult or interact with Consultation/Involvement stakeholders affected by the proposed activities.

Scoping An early and open activity to identify the impacts that are most likely to be significant and require specialized investigation during the EIA work. Can, also be used to identify alternative project designs/sites to be assessed, obtain local knowledge of site and surroundings and prepare a plan for public involvement. The results of scoping are frequently used to prepare a Terms of Reference for the specialized input into full EIA.

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Terms of Reference (ToR) Written requirements governing full EIA input and implementation, consultations to be held, data to be produced and form/contents of the EIA report. Often produced as an output from scoping.

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1 INTRODUCTION

Project Background

Johannes Malume Gariseb (hereinafter referred to as The Proponent), a holder of the Exclusive Prospecting License (EPL 7258) granted by the Ministry of Mines and Energy (MME) intends to acquire an Environmental Clearance Certificate (ECC) to be able to conduct prospecting and exploration activities on the EPL 7258. The tenure of the licence is from 15 May 2019 to 14 May 2022. The Proponent is a local miner with a good track record of mineral rights acquisition, exploration and development of semi-precious and base metal projects. On EPL 7258, the Proponent focuses on acquisition, exploration and development of Base and Rare Metals (granted), Precious Metals (granted), Dimension Stones (granted), Industrial Minerals (applied for), and Semi-Precious Stones (applied for) on the EPLs. The locality map of the EPL 7258, where exploration works would occur is shown in Figure 1.

In terms of Section 27 of the Environmental Management Act (EMA), No.7 of 2007, and in line with Sections 32-37 of the EMA, the proposed prospecting and exploration activities form part of the listed activities that may not be conducted without an ECC from the Department of Environmental Affairs (DEA), at the Ministry of Environment, Forestry and Tourism (MEFT) being obtained. The relevant listed activities as per EIA regulations are:

 3.1 The construction of facilities for any process or activities which requires a license, right of other forms of authorization, and the renewal of a license, right or other form of authorization, in terms of the Minerals (Prospecting and Mining Act, 1992).  3.2 other forms of mining or extraction of any natural resources whether regulated by law or not.  3.3 Resource extraction, manipulation, conservation and related activities.

Individuals or organizations may not carry out exploration activities among those listed above, without an EIA undertaken and an ECC awarded. Subsequently, the Proponent appointed Excel Dynamic Solutions (Pty) Ltd (EDS), an independent team of Environmental Consultants to conduct the required EA process and submit the ECC application to the MEFT and MME on their behalf. The draft EMP as required for this project under section 48 of the Prospecting and Mining Act, 1992; will be used by the Proponent and their employees to guide them throughout the

1 Johannes Malume Gariseb: EPL 7258 Johannes Malume Gariseb EIA: EPL 7258 operations, to ensure that the impacts on the environment are avoided or limited if they cannot be avoided completely.

Terms of Reference and Scope of Works

EDS was appointed by the Proponent to undertake an environmental assessment for the purpose of applying for an ECC for exploration work on the EPLs. There were no formal Terms of Reference (ToR) provided to EDS by the Proponent. The consultant, instead, relied on the requirements of the Environmental Management Act (No. 7 of 2007) (EMA) and its Environmental Impact Assessment (EIA) Regulations (GN. No. 30 of 2012) to conduct the study.

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Figure 1: Location of the EPL 7258 near Okahandja in the Otjozondjupa Region

Appointed Environmental Assessment Practitioner

In order to satisfy the requirements of the EMA and its 2012 EIA Regulations, the Proponent appointed Excel Dynamic Solutions Pty Ltd (EDS or the Environmental Assessment Practitioner hereafter), an independent consulting company, to conduct the required EIA process on their (Proponent's) behalf. The findings of the EIA process are incorporated into this report and the draft Environmental Management Plan (EMP) - (Appendix B) will be submitted as part of an application for an application for an ECC to the Environmental Commissioner at the DEA, MEFT.

The EIA project is headed by Mr. Nerson Tjelos, a qualified Geoscientist and experienced EAP. The consultation process and reporting are done by Ms. Althea Brandt with support from Mr. Silas

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David. Ms. Rose Mtuleni contributed to the report writing and review. The CV for Mr. Tjelos is presented in Appendix C.

Details of the Project Proponent

The details of the Proponent are presented in Table 1 below.

Table 1: Proponent contact details and purpose of required ECC

Full name of Contact number Postal ECC Application for: Proponent Address

Johannes Malume Telephone: +264 61 504 238 P.O Box 58, Exclusive Prospecting License Gariseb Uis (EPL) No. 7258 near Okahandja in Email Address: Namibia the Otjozondjupa Region, Namibia [email protected]

The Need for the Proposed Project

Mining is essential in meeting the ever-increasing demand for minerals for the world’s growing population and for prosperity. Mining has been the pillar of the Namibian economy for many years. The Proponent’s exploration programme represents a valuable opportunity to contribute to infrastructure minerals development, which is a key component in the development of Namibia and the nation’s economy. Exploration activities provide employment, dividends, and taxes that fund social infrastructure. The minerals sector yields foreign exchange and accounts for a significant portion of gross domestic product. In addition, the industry produces a trained workforce and small businesses that can service communities and may initiate related businesses. A number of associated activities are fostered, such as manufacturing of exploration and mining equipment, provision of engineering and environment services. Successful exploration work can lead to mining activities on the EPLs, which would feed into the national development plans such as NDP5, vision 2030. Moreover, the project is expected to generate full time medium to long term direct employment for at least 10 people. The majority of the unskilled to semi-skilled people (general labourers and operators) to be employed in the proposed

4 Johannes Malume Gariseb: EPL 7258 Johannes Malume Gariseb EIA: EPL 7258 exploration project. A geologist (s) and site manager will also be employed during the exploration programme. This project will contribute towards the socio-economic development of the region.

Given the fact that this activity creates employment to the local community and contributes to the country’s GDP, this justifies the need for exploration works on EPL 7258 to enable future mining works.

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2 PROJECT DESCRIPTION: PROPOSED EXPLORATION ACTIVITIES

The descriptions of exploration activities to be undertaken are presented below (Section 2.1, 2.2 and 2.3).

Figure 2: Diagram of the Life Cycle of a Mine (source: Superfund Research Project, 2019). The red box shows the Phase covered by this study

Pre-Development Phase (Prospecting)

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The prospecting and exploration phase includes reviewing existing reports and composite stratigraphic, lithological-geochemical maps of the targeted areas to identify prospective lithostratigraphic packages. In addition to literature review, field work (lithological (soil/rock) mapping and sampling) will be conducted to verify desktop work. Up to this point, no physical disturbance is anticipated. The selection of the potential mineralization model and exploration targets has been specially undertaken based on the regional and likely local geology as well as the results of the past exploration activities. Upon issuance of an ECC, the exploration program will commence. Ground geophysical survey which involve the use of both single instruments that are hand carried and other methods which use up to six people to put stainless steel electrodes in the soil and generate a current to charge the minerals so that a voltmeter can read the discharge of the voltage. The exploration program will explicitly provide about 10 job opportunities; some general labourers, operators of vehicles and equipment, a geologist and a site mine manager will be employed during the exploration phase. However, this number is likely to increase.

Figure 3: The mineral exploration cycle (source: Savannah Resources, 2019)

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Site Preparation, Operation and Maintenance (Exploration Drilling, Sampling and Analysis) During this phase, exploration program will be in operation, and the target areas within EPL 7258 boundaries; which have been acknowledged during the initial prospecting and exploration phase will go through exploration drilling. The preferred drilling technique for this exploration programme is Reverse Circulation (RC) Drilling. RC Drilling uses a pneumatic hammer which drives a rotating tungsten-steel bit. The technique produces an uncontaminated large volume sample which is comprised of rock chips. It is relatively quick and cheap compared with other techniques like Diamond Drilling. . In the advanced stage of exploration activities, larger amounts of sample material may be required for analysis and to perform processing trials. Pits may be dug for sampling. The size of the sample size may be adjusted depending on the nature of mineralization observed from drilling. No explosives will be used during exploration phase.

Other aspects of the exploration include:

2.1.1 Accessibility to Site

The EPL is situated in central Namibia approximately 8 km west of Okahandja. on the B2 road. The site is accessible via the B2 road, which is accessed from Okahandja. Okahandja is located about 80 km north of Windhoek, and it is connected to Windhoek via the B1 National road. Namibia is serviced by an international Airport located at Windhoek with regular flights to Europe and other parts of Africa. Regionally, the paved all weather Trans-Caprivi Highway road links Walvis Bay to the countries of Botswana, Zambia and Zimbabwe, as well as the Democratic Republic of Congo. In addition, the Trans-Kalahari Highway links Walvis Bay with South Africa’s Gauteng industrial heartland via Botswana. A harbour (Namport) is found in Walvis Bay that gives a platform for samples and mined materials to be offloaded or loaded onto transnational shipping lines.

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2.1.2 Equipment and Material

The input required for exploration program in terms of vehicles and equipment include; two SUV (4X4) vehicles, earthmoving equipment, drilling rigs and drilling support equipment, compressor and power generator, as well as field storage and rocks analysis equipment (i.e., XRF analyser).

Okahandja is a good source for semi-skilled and unskilled workers. The exploration project phase will make about 8-10 job opportunities available. Some general labourers, operators of vehicles and equipment, geologist and an exploration manager will be employed during the exploration phase. This number is likely to increase.

Equipment and vehicles will be stored at a designated area near the accommodation site or at a storage site established within the EPL area.

2.1.3 Services and Infrastructure

Water: Water required for the operation phase will be obtained from nearest boreholes and off- site municipal sources and/or from any other approved water sources, through water abstraction permits. The estimated monthly water consumption for the exploration project includes: 1000 litres of water for drinking, 3500-4000 litres of water for sanitation, 800 litres of water for cooking, 5000 litres of water for dust control, and 2000 litres of water for washing equipment.

Power supply: No power supply infrastructure will be installed for exploration works on the site. Instead, a diesel power generator will be used during exploration phase. Upon discovery of mineable resources, arrangement will be made with Namibia Power Corporation (NamPower) for possible supply of electricity for mining activities.

2.1.4 Accommodation

Exploration staff will be accommodated in Okahandja. A campsite will be set up for the exploration crew. If the accommodation camp is to be set up on a neighboring farm, necessary arrangements will be made with the farm owner. Exploration activity will take place during day time only, and the exploration team will commute to the site from their accommodation place.

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2.1.5 Timeframe

The planned ground surveys may last several weeks and will be done in stages on different parts of the property (EPL 7258). The geological mapping will be done in two (2) months, and a 9-to- 12-month period of exploration is anticipated.

2.1.6 Waste Management

A variety of waste types and quantities will be generated during the exploration phase. Depending on the amount generated, waste will be sorted and collected on a weekly or monthly basis and taken to the Okahandja waste/landfill site. The ablution facilities used will include chemical toilets and/or sealed septic tanks, and the sewerage periodically taken to the nearest treatment facility. Furthermore, the disposal of wastewater as well as all other type of waste will be strictly controlled. Wastewater is disposed of in evaporation ponds because no effluent may be discharged into the ephemeral, dry river beds in the interior of Namibia, therefore reclamation, re-use and recycling of wastewater is encouraged. The following types of waste will occur onsite:

Mineral Waste: Consists of solid products of exploration and mineral concentration to acquire the targeted minerals. Mineral waste will be produced throughout the exploration project. This waste will be stripped and dumped in allocated areas in accordance with the EMP.

Non-mineral Waste: Consists primarily of auxiliary materials that will support the exploration phase. This includes but is not limited to items such as empty containers, plastic etc and other domestic waste. This waste will be collected, sorted and taken to the dumpsite weekly.

2.1.7 Security

Temporary storage areas for drilling material, machines and other project material and equipment will be necessary at the camp. Security will be supplied on a 24-hour basis at the storage and/or camp site and exploration camp. A temporary support fence surrounding the storage/camp site will be constructed to ensure that exploration crew and domestic animals are not put at risk.

2.2 Decommissioning and Rehabilitation Phase

Decommissioning and rehabilitation are primarily reinforced through a decommissioning and rehabilitation plan which, among others, consist of safety, health, environmental and contingency

10 Johannes Malume Gariseb: EPL 7258 Johannes Malume Gariseb EIA: EPL 7258 aspects. The economic situation or unconvincing exploration results may force the Proponent to eventually cease the exploration program. It is, therefore, of best practice for the Proponent to ensure that the removal of all structures including camp sites, drilling casting and/ or concrete plinths; and waste materials generated on site throughout the exploration phase are environmentally disposed of. Additionally, the Proponent will need to put site rehabilitation measures in place. Rehabilitation may entail the revegetation of bare areas with species consistent with surrounding vegetation, refilling of trenches in such a way that subsoil is replaced first, and topsoil replaced last. Necessary landscaping of exploration areas is undertaken upon completion of each phase of exploration (drilling, sampling etc.).

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3 PROJECT ALTERNATIVES

Alternatives are “different means of meeting the general purpose and requirements of the activity” (Environmental Management Act (2007) of Namibia and its regulations (2012)). This section will highlight the different ways in which the project can be undertaken and identify the alternatives that will be the most practical but least damaging to the environment.

Once the alternatives are established, they are examined by using the following three questions:

 What alternatives are technically and economically feasible?

 What are the environmental effects associated with the feasible alternatives?

 What is the rationale for selecting the preferred alternative?

The alternatives considered for the proposed development are discussed below.

3.1 Types of Alternatives Considered

3.1.1 The "No-go" Alternative

The “No-Go” alternative is the option of not proceeding with the activity, which typically implies a continuation of the status quo. Should the proposed works of the prospecting plan be discontinued, none of the potential impacts (positive and negative) identified would occur. Potential local employees for the exploration project would be left unemployed and the Proponent would not be able discover and define the targeted resource for possible mining and contribute to the country’s economy through revenue and mining license royalty payments. If the proposed project is to be discontinued, the current land use for the proposed site will remain unchanged. In considering the proposed project, the ‘no-go’ option is not considered the preferred alternative.

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3.1.2 Exploration Location

The prospecting/exploration location is dependent on the mineralogy and geology of the area. Therefore, finding an alternative location for the planned exploration activities is not possible. This means that the exploration targets are primarily determined by the geology (host rocks) and the tectonic environment of the site (ore forming mechanism). The tenement has sufficient surface area that, should an economic mineral deposit be defined, there is an adequate area for potential tailings’ storage areas, waste disposal, heap leach pads (if required) and processing facilities.

3.1.3 Exploration Methods

Both invasive and non-invasive exploration activities are expected to take place. If an economically viable discovery is made, the project will proceed to mining phase.

3.2 Conclusion on Alternatives

The conclusions weighed and considered above are summarized below

 No-go Alternative: Should the proposed prospecting and exploration works on the EPL 7258 be discontinued, none of the potential impacts (positive and negative) identified would occur. The local residents meant to be employed by the project will be left unemployed and the Proponent would not be able to discover and define the targeted resources for possible mining to generate an income and contribute to the country’s economy through revenue and license royalty payments. In considering the proposed project, the ‘no-go’ option is not considered the preferred alternative.

 Exploration Location: Finding an alternative location for the planned exploration activities is not possible (refer to section 3.1.2)

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4 LEGAL FRAMEWORK: LEGISLATION, POLICIES AND GUIDELINES

The exploration activities have certain legal implications associated to certain applicable legal standards. A review of applicable and relevant Namibian legislation, policies and guidelines to the proposed development are given in this section. This review serves to inform the project Proponent, Interested and Affected Parties and the decision makers at the DEA of the requirements and expectations, as laid out in terms of these instruments, to be fulfilled in order to establish the proposed prospecting and exploration activities.

The Environmental Management Act (No. 7 of 2007)

This EA was carried out according to the Environmental Management Act (EMA) and its Environmental Impact Assessment (EIA) Regulations (GG No. 4878 GN No. 30).

The EMA has stipulated requirements to complete the required documentation in order to obtain an Environmental Clearance Certificate (ECC) for permission to undertake certain listed activities. These activities are listed under the following Regulations:

 3.1 The construction of facilities for any process or activities which requires a license, right of other forms of authorization, and the renewal of a license, right or other form of authorization, in terms of the Minerals (Prospecting and Mining Act, 1992).

 3.2 other forms of mining or extraction of any natural resources whether regulated by law or not.

 3.3 Resource extraction, manipulation, conservation and related activities.

The legal obligations that are relevant to the proposed cemetery and related activities are presented in Table 2.below.

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Table 2: Applicable local, national and international standards, policies and legislation guiding the proposed development

Legislation/Policy/ Relevant Provisions Implications for this project Guideline

Environmental Requires that projects with significant The EMA and its regulations Management Act environmental impacts are subject to an should inform and guide this EA EMA (No 7 of 2007) environmental assessment process (Section 27). process.

Details principles which are to guide all EAs.

Environmental Impact Details requirements for public consultation within Assessment (EIA) a given environmental assessment process (GN 30 Regulations GN 28-30 S21). (GG 4878) Details the requirements for what should be included in a Scoping Report (GN 30 S8) and an Assessment Report (GN 30 S15).

The Constitution of The Constitution of the Republic of Namibia (1990 By implementing the environmental the Republic of as amended) addresses matters relating to management plan, the Namibia, 1990 as environmental protection and sustainable establishment will be in conformant amended development. Article 91(c) defines the functions of to the constitution in terms of the environmental management and sustainability. Ombudsman to include: Ecological sustainability will be “…the duty to investigate complaints concerning the main priority for the proposed over-utilisation of living natural resources, the development. irrational exploitation of non-renewable resources, the degradation and destruction of ecosystems and failure to protect the beauty and character of Namibia…”

Article 95(l) commits the state to actively promoting and maintaining the welfare of the people by adopting policies aimed at the:

“…Natural resources situated in the soil and on the subsoil, the internal waters, in the sea, in the continental shelf, and in the exclusive economic zone are property of the State.”

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

The Regional This Act sets out the conditions under which The relevant Regional Councils are Councils Act (No. 22 Regional Councils must be elected and administer considered to be I&APs and must of 1992) each delineated region. From a land use and project be consulted during the planning point of view, their duties include, as Environmental Assessment (EA) described in section 28 “to undertake the planning process. The project site falls under of the development of the region for which it has the Otjozondjupa Regional Council; been established with a view to physical, social and therefore, they should be consulted. economic characteristics, urbanisation patterns, natural resources, economic development potential, infrastructure, land utilisation pattern and sensitivity of the natural environment.

The main objective of this Act is to initiate, supervise, manage and evaluate development.

Local Authorities Act To provide for the determination, for purposes of The Okahandja Constituency is the No. 23 of 1992 local government, of local authority councils; the responsible Local Authority of the establishment of such local authority councils; and area, therefore, they should be to define the powers, duties and functions of local consulted. authority councils; and to provide for incidental matters.

Water Act 54 of 1956 The Water Resources Management Act 11 of 2013 The protection (both quality and is presently without regulations; therefore, the Water quantity/abstraction) of water Act No. 54 of 1956 is still in force: resources should be a priority.

 Prohibits the pollution of water and implements the principle that a person disposing of effluent or waste has a duly of care to prevent pollution (S3 (k)).

 Provides for control and protection of groundwater (S66 (1), (d (ii)).

Liability of clean-up costs after closure/abandonment of an activity (S3 (l)).

Water Resources The Act provides for the management, protection, Management Act (No development, use and conservation of water 11 of 2013) resources; and provides for the regulation and monitoring of water services and to provide for incidental matters. The objects of this Act are to:

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

Ensure that the water resources of Namibia are managed, developed, used, conserved and protected in a manner consistent with, or conducive to, the fundamental principles set out in Section 66 - protection of aquifers, Subsection 1 (d) (iii) provide for preventing the contamination of the aquifer and water pollution control (Section 68).

Minerals (Prospecting The Prospecting and Mining Act aims to provide for The Proponent should enter into a and Mining Act) No. the reconnaissance, prospecting and mining for, written agreement with landowners 33 of 1992 and disposal of, and the exercise of control over, before carrying out exploration on minerals in Namibia; and to provide for matters their land as per the Section 52 of incidental thereto. the Minerals (Prospecting and Mining) Act No. 33 of 1992 and Section 52 requires mineral license holders to enter Section 2.2.3 of the Draft Minerals into a written agreement with affected landowners Policy of Namibia: before exercising rights conferred upon the license holder. Section 52 (1) The holder of mineral licence shall not exercise any rights conferred upon such holder by this Act or under any terms and conditions of such mineral licence –

(a) In, on or under any and until such time as such holder has entered into an agreement in writing with the owner of such land containing terms and conditions relating to the payment of compensation, or the owner of such land has in writing waked any right to such compensation and has submitted a copy of such agreement or waiver to the Commissioner.

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

Section 2.2.3 of the Draft Minerals Policy of Namibia states that the Licence Holder and/or mineral explorers currently have to negotiate a contract with landowners to gain access for or mining purposes.

National Heritage Act To provide for the protection and conservation of The Proponent should ensure No. 27 of 2004 places and objects of heritage significance and the compliance with this Acts' registration of such places and objects; to establish requirements. The necessary a National Heritage Council; to establish a National management measures and related Heritage Register; and to provide for incidental permitting requirements must be matters. taken. This done by consulting with the National Heritage Council of The National The Act enables the proclamation of national Namibia. Monuments Act (No. monuments and protects archaeological sites. 28 of 1969)

Soil Conservation Act The Act makes provision for the prevention and Duty of care must be applied to soil (No 76 of 1969) control of soil erosion and the protection, conservation and management improvement and conservation of soil, vegetation measures must be included in the and water supply sources and resources, through EMP. directives declared by the Minister.

Public Health Act (No. Section 119 states that “no person shall cause a The Proponent and all its 36 of 1919) nuisance or shall suffer to exist on any land or employees should ensure premises owned or occupied by him or of which he compliance with the provisions of is in charge any nuisance or other condition liable to these legal instruments. be injurious or dangerous to health.”

Health and Safety Details various requirements regarding health and Regulations GN safety of labourers. 156/1997 (GG 1617)

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

Road Traffic and The Act provides for the establishment of the Mitigation measures should be Transportation Commission of Namibia; for the provided for, if the roads and traffic Transport Act, No. 22 control of traffic on public roads, the licensing of impact cannot be avoided. of drivers, the registration and licensing of vehicles, The relevant permits must therefore 1999 the control and regulation of road transport across be applied for. Namibia's borders; and for matters incidental thereto. Should the Proponent wish to undertake activities involving road transportation or access onto existing roads, the relevant permits will be required.

Labour Act (No. 6 of Ministry of Labour (MOL) is aimed at ensuring The Proponent should ensure that 1992) harmonious labour relations through promoting the prospecting and exploration social justice, occupational health and safety and activities do not compromise the enhanced labour market services for the benefit of safety and welfare of workers. all Namibians. This ministry insures effective implementation of the Labour Act no. 6 of 1992.

National Solid Waste Details that the waste collection system at most This ESR and proposed EMP will Management Strategy municipalities is generally operating to an adequate form part of exploration program standard compared to waste disposal. However, Solid Waste Management strategy. there is scope for improvement in waste collection at all municipalities, in particular related to waste collection coverage in informal housing areas.

Dumping and litter in the areas under the administration of regional councils are a major problem.

In many cases there is no formal waste collection system in these areas. - In particular, local authorities need more resources (i.e. personnel) for organising solid waste management, monitoring waste generators and reducing the problems with illegal dumping.

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5 ENVIRONMENTAL BASELINE

The proposed exploration programme will be undertaken in specific environmental and social conditions. Understanding the pre-project conditions of the environment will aid in laying down background "information" of what was before and what would be after project. This also helps the EAP in identifying the sensitive environmental features that may need to be protected through the recommendation and effective implementation of mitigation measures. The summary of selected biophysical and social baseline information pertaining to the prospecting area is given below.

The baseline information presented below is sourced from different reports of studies conducted in the Otjozondjupa Region (at large) as well those done for Okahandja area and the EPL site.

5.1 Climate

5.1.1 Temperature

The EPL lies within the Okahandja area where the average annual temperatures lie between 18- 20oC. October to January are the warmest months with an average summer temperature of 300C, while June and July are the coldest months, with mild average winter temperatures of about 170C. On average, the Okahandja area receives 9-10 hours of sunshine per day (Mendelsohn et al, 2002). Figure 4 below shows the temperature patterns in the project area, (https://en.climate- data.org).

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Figure 4: Graph showing temperature patterns for one year (March 2019-January 2020) in Okahandja, Otjozondjupa Region.

5.1.2 Rainfall

Namibia is a dry country, which often experiences low and variable rainfall. The average annual rainfall in the EPL area is 300-350mm. The highest rainfall in the area is experienced in February, and may reach up to 450mm. Little to no rainfall periods are experienced from May to September with an average rainfall record of 0-3mm. Figure 5 below shows the rainfall patterns in the area, (https://en.climate-data.org).

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Figure 5: Graph showing rainfall patterns between March 2019 and January 2020 in Okahandja, Otjozondjupa Region

5.1.3 Wind

Primarily, northerly, westerly, easterly, north-westerly and north-easterly airflow is common in Okahandja. The strongest winds in Okahandja are experienced from August to October with a wind speed of 25.5 – 27.5 kmph. Figure 6 below depicts the wind patterns in the area, (https://en.climate-data.org).

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Figure 6: Graph showing wind patterns between March 2019 and January 2020 in Okahandja, Otjozondjupa Region.

5.1.4 Humidity

The relative humidity during the least humid months of the year, i.e., September to November, is 20-30%. September to November are usually the least humid months due to high temperatures, high levels of radiation and dry soils after the dry winter season. Figure 7 illustrates that the most humid months are February to April, with about 60-70% relative humidity. Namibia has low humidity levels in general, and the lack of moisture in the air has a major impact on its climate by reducing cloud cover and rainfall, an in turn increasing the rate of evaporation (Mendelsohn et al, 2002), (https://en.climate-data.org).

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Figure 7: Graph showing humidity patterns between March 2019 and January 2020 in Okahandja, Otjozondjupa Region

5.2 Topography and Local Geology

The study site is generally flat with several granite hills. The relief of small dry river courses and streams running in and around the area remains well developed and contributes well to drainage in the area. Surface drainage takes place through these waterways in the area, which eventually flow into the Swakop River. Geologically, the EPL area lies within the Central Zone of the Damara Orogen. The Damara Sequence in the area is composed of highly metamorphosed rocks of the Mesoproterozoic Abbacies Complex, which are exposed in domes and anti-forms. Magmatic rocks of the Karoo Sequence intrude and Cenozoic sediments overlie the Damara rocks West of Okahandja. Granitic rocks (coarse-grained, porphyritic Salem-type granite and medium – to coarse grained reddish granite) and erosion of these plutonic rocks has produced smoothly rounded hills displaying the typical onion-skin weathering. The granites are crosscut by pegmatite dykes. Other rock units mapped in the area as presented on the MME mining cadastre include

24 Johannes Malume Gariseb: EPL 7258 Johannes Malume Gariseb EIA: EPL 7258 marble; schist; ortho-amphibolite; quartzite, felsic metavolcanics, para-/orthogneiss, and metasediments. Figure 8 below displays the geology of the project site.

Figure 8: Map showing the geology of the project area.

5.3 Soils

The soils in the region can be classified into three groups: Aeolian sands, Calcareous soils; and Lithosols. Aeolian sands are fine to medium, non-plastic and uniformly graded materials present in many sandy sites, mainly in desert areas. Lithosols are mainly a group of shallow soils that lack well-defined horizons, especially an entisol consisting of partially weathered rock fragments, usually on steep slopes. The Calcareous soils have a presence of significant quantities of free excess lime (calcium or magnesium carbonate). The lime dissolves in neutral to acid pH soil, but does not readily dissolve in alkaline soil and instead, serves as a sink for surface absorbed calcium phosphate precipitation (Taalab, 2018).

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a.

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b.

Figure 9: Typical soil types (a and b) on the proposed exploration site

5.4 Water Resources

Access to water is an essential, yet limiting factor to many livelihoods in Namibia, both for urban and rural contexts, and for the region’s natural biota. Namibia’s water is used mainly for irrigation (42.6%), livestock (25.3%) and domestic purposes (28.1%) (Brown 1992; Ashley et al. 1995). The Okahandja Formation which consists of the Arises River Member (coarse grained white calcitic marble beds), the Otjongema Member (Calc-silicate dolomitic marble beds) and the Harmonie Member (Calc-silicate minor marble beds) is a source of water supply to local settlements and towns. However, the hydraulic yield of the aquifer is closely related to fracture storage, and is therefore highly variable and dependent on annual recharge. Due to its carbonate nature, the Karibib Formation maintains good quality water with a dominant calcium magnesium bicarbonate hydrochemical facie (Ca-Mg-HCO3) (Tordiffe, 2013).

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5.5 Fauna Namibian lands present great contrasts in physical environment that include some of the most distinctive of the world’s flora and fauna. Common animals found in the region are Kudu, Oryx, Springbok, Steenbok, Hartmann’s mountain Zebra, red hartebeest and Ostrich. There is a small population of black rhino in the area. There are about 300 bird species including the Yellow-billed stork, Osprey, African fish eagle, Goliath heron, Bradfield’s swift and Stark’s lark. The presence of campers in the veld may result in disturbance to animals such as birds, especially raptors. A number of these species, such as the White-backed vulture and Tawny eagle, are Red Data species. The project area and surrounds has approximately 61-71 mammal species. Animals such as Steenbok, Warthog, and Kudu, as well as tortoise and leguan are of high conservation priority, and may experience declines in their populations in the area, as farmers make efforts for hunting and/or ecotourism establishments. Therefore, mitigation strategies are necessary to protect these species during all phases of the project.

5.6 Flora

In the Western Highlands Savannah Biomes, tree cover is 2 to 10%, tree height is 2 to 5m, shrub cover is 2 to 10%, and grass height is >0.1m. The dominant vegetation type in this biome according to the ranking is acacia reficiens, euphorbia geuerichiana, colophospermum mopane, maerua schinzii, and ademolobius garipensis (Mendelson, 2002). The dominant biomes in the Otjozondjupa region are the northern Kalahari, thornbush savannah and the Karstveld. Bush encroachment is a major environmental degradation threat in the region. In addition to this, a study based on the vegetation of the Thornbush Savanna of central Namibia’s present vegetation at Farm Erichsfelde, Otjizondjupa Region, the vegetation associations were mapped using aerial images as well as the GPS position of the relevés as baseline. In addition, a Livestock Farming Suitability Index was calculated for each association, based on its habitat, composition and structure. Only the Ziziphus mucronata–Dichanthium annulatum association was rated highly suitable for livestock farming. The two plains associations, Ondetia linearis–Acacia mellifera and Aristida congesta–Acacia mellifera were rated moderately suitable, whilst all other associations were rated with a low suitability for livestock farming. The main reason for these fairly low ratings is a high degree of bush encroachment and low perennial grass cover. Figure 10 below shows the typical vegetation type found on the project area, and Figure 11 shows the vegetation structure and plants found on the site.

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Figure 10: Typical flora found on the EPL 7258

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Figure 11: Map showing vegetation structure and plants found on EPL 7258 and surrounding areas

5.7 Population of the Otjozondjupa Region

Otjozondjupa Region is one of the largest regions in the country with a land surface area of 105,185 km and represents 12.8% of the total land surface area of Namibia. It divides into seven constituencies, namely: Grootfontein, Otjiwarongo, Otavi, Okakarara, Omatako and Okahandja. The region has a population of 135,723.

5.8 Tourism, Heritage and Archaeology

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The Otjozondjupa Region has a variety of attractive tourist attractions. The Waterberg Plateau is a particularly prominent feature, elevated high above the plains of the Kalahari of Eastern Namibia. The plateau and about 405 km² of surrounding land were declared a Nature Reserve in 1972. Some of the species identified as endangered were translocated to the plateau in the early 1970s, in order to protect them from predators and poaching to extinction, because the plateau is largely inaccessible.

The Hoba Meteorite was discovered in the 1920’s on the farm Hoba, 19 km west of Grootfontein in the Otjozondjupa Region. It is estimated that the meteorite fell to earth about 80,000 years ago. It is the world largest meteorite and weighs 60 tonnes. It is approximately 3 m2 and about 1 m in depth and is made up of 82% iron 16,4% nickel and 0.76% cobalt. The Hoba meteorite was declared a national monument in March 1955, and it is a National Heritage Site. (Otjozondjupa Regional Council, 2020).

Tourism is important for the town of Okahandja as it plays an important role in economic development and growth. The Okahandja constituency is a home to various tourism related places too. The Von Bach Dam, Gross Barmen Resort, and many guesthouses and lodges.

Red Flag Day or Otjiserandu is celebrated annually at Moordkoppie in Okahandja, during the weekend nearest to the date of 23 August, to commemorate the battle known as ‘Bloodbath of Okahandja’, which took place on 23 August, 1850, as well as the burial of the late Chief Samuel Maharero on 23 August, 1923. The event attracts many local and international tourists.

5.9 Surrounding Land Uses

The farming activities of Okahandja and Otjiwarongo are homogenous as these parts are well known for cattle farming. The Otavi and Grootfontein districts, and to a lesser extent Otjiwarongo, are the granary of Namibia. The Otjozondjupa Region has a great potential to capitalize on and establish industries associated with such farming activities and by-products of it. It further has the advantage of combining communal and commercial farming in the same region.

The EPL falls within 100% of farmland (Figure 12). The Proponent is required to secure a signed agreement for site access from the affected landowners, as per the Section 52 of the Minerals (Prospecting and Mining) Act No. 33 of 1992 and Section 2.2.3 of the Draft Minerals Policy of Namibia:

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Section 52 (1) The holder of mineral licence shall not exercise any rights conferred upon such holder by this Act or under any terms and conditions of such mineral licence –

(b) In, on or under any and until such time as such holder has entered into an agreement in writing with the owner of such land containing terms and conditions relating to the payment of compensation, or the owner of such land has in writing waked any right to such compensation and has submitted a copy of such agreement or waiver to the Commissioner.

Section 2.2.3 of the Draft Minerals Policy of Namibia states that the Licence Holder and/or mineral explorers currently have to negotiate a contract with landowners to gain access for or mining purposes.

Figure 12: Map showing farms within the EPL 7258 site

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5.10 Services and Infrastructure The Okahandja area has the basic infrastructure necessary for transportation and telecommunication, as well as water and electricity supply. Okahandja forms part of an important national railway network, which is also linked to the South African railway network. The major national roads connect to Windhoek, the capital city, located approximately 80 km south of Okahandja (KRC, 2001).

In terms of the telecommunication facilities and infrastructure such as radio and television coverage, mobile networks; are good especially in the town and nearby places.

Sanitation network is only provided in the formalized neighbourhoods of the town and not in rural areas which are mainly the Rudenau and commercial farms. Cenored has provided electricity infrastructure in both urban area, private farms and some tourism related facilities and in some part of communal areas in collaboration with the Rural Electrification.

While potable water is supplied by NamWater through pipeline to the town and nearby area, some parts of the rural surrounds depend mainly on borehole infrastructure.

Most facilities and amenities are found in the town. Among many other infrastructures are four primary schools, two private schools, one police station, one hospital and two clinics, and government offices (Otjozondjupa Regional Council website, 2020).

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6 PUBLIC CONSULTATION PROCESS

Public consultation forms an important component of an Environmental Assessment (EA) process. Public consultation provides potential Interested and Affected Parties (I&APs) with an opportunity to comment on and raise any issues relevant to the project for consideration as part of the assessment process. Public consultation has been done in accordance with both the EMA and its EIA Regulations.

The public consultation process assists the Environmental Assessment Practitioner (EAP) in identifying all potential impacts and the extent to which further investigations are needed. Public consultation can also aid in the process of identifying possible mitigation measures.

Pre-identified and Registered Interested and Affected Parties (I&APs)

EDS identified relevant and applicable national, regional and local authorities, church leaders and other interested members of the public. The (pre-identified) I&APs were contacted directly and some were registered as I&APs upon their request (those that were registered after the EA notification in the newspapers). Newspaper adverts of the proposed exploration activities were placed in the Market watch section of the Republikein and Namibian Sun Newspapers on 16 February, 2020 and 23 February, 2020. The Republikein Newspaper contains up of three sections namely; Republikein, Namibian Sun and Allgemeine Zeitung, which is a widely-read national newspaper in the region. The project advertisement/ announcement ran for two consecutive weeks inviting members of the public to register as I&APs and submit their comments. The summary of pre-identified and registered I&APs is listed in Table 4 below and the complete list of I&APs is provided in Appendix D.

Table 3: Summary of Interested and Affected Parties (I&APs)

National (Ministries and State Owned Enterprises) Ministry of Environment and Tourism

Ministry of Urban and Rural Development

Ministry of Labour, Industrial Relations and Employment Creation

Ministry of Health and Social Services

Ministry of Agriculture, Water and Forestry

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Ministry of Mines and Energy

Roads Authority

Regional & Local Otjozondjupa Regional Council

Okahandja Constituency

General Public

Interested members of the public & Farm Owners

Communication with I&APs

Regulation 21 of the EIA Regulations details steps to be taken during a public consultation process and these have been used in guiding this process. Communication with I&APs about the proposed development was facilitated through the following means and in this order:

 A Background Information Document (BID) containing brief information about the proposed facility was compiled (Appendix E) and sent out to all pre-identified affected parties and upon request to all new registered Interested and Affected parties (I&APs);

 Project Environmental Assessment notices were placed in Republikein, Namibian Sun and Allgemeine Zeitung (Appendix F) dated 16 February 2020 and 23 February 2020, briefly explaining the activity and its locality, inviting members of the public to register as I&APs and submit comment;

 Notification letters were sent out to various farm owners and pre-identified I&APs (Appendix G).

 Due to safety regulations and travel restrictions put in place to curb the spread of COVID- 19, the Consultant could not organise for a public meeting in Okahandja, but had to rely on responses from the informed I&APs.

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6.1 First Round Public Feedback

No comments were received by EDS via email and other mode of communication after the EIA advertisement in the newspapers and upon placing public notices in Okahandja.

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The Draft EIA report together with all its appendices will be circulated to all I&APs for review for a period not less than 7 days. Should there be any comments, these will be documented in a Comments and Response Trail Document and incorporated into the Final Report that will be then submitted to the Department of Environmental Affairs (DEA) for evaluation and consideration of an ECC.

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7 IMPACT IDENTIFICATION, ASSESSMENT AND MITIGATION MEASURES

Impact Identification

Proposed developments/activities are usually associated with different potential impacts, be it positive or negative. For an environmental assessment, the focus is placed mainly on the negative impacts. This is done to ensure that these impacts are addressed by providing adequate mitigation measures such that an impact’s implication is brought under control, while maximizing the positive impacts of the development. The potential positive and negative impacts that have been identified from the prospecting activities are listed as follow:

Positive impacts:

 Creation of jobs to the locals (primary, secondary and even tertiary employment)  Helps boost local economic growth.  Open up other investment opportunities.  Contribution to regional economic development.

Negative impacts:

 Loss of biodiversity  Generation of dust  Water quality is affected  Waste generation  Visual impact (scars) on landscape  Potential health and safety risks  Surrounding soils impacted  Archaeological impact  Noise pollution

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Impact Assessment Methodology

Generally, an Environmental Assessment is primarily a process used to make sure that possible potential impacts that may occur from the prospecting and exploration activities, are identified, and legislatively and environmentally addressed. Prior to exploration activities, the impact assessment method used for this project is in accordance with Namibia’s Environmental Management Legislation (Environmental Management Act No. 7 of 2007) and its Regulations of 2012, as well as the International Finance Corporation (IFC) Performance Standards. Additionally, the Namibian Impact Assessment Method plays a major role in undertaking an EIA in order to obtain an ECC, deemed if the listed activities do not oppose threat to the environment. Therefore, the diagram below (Figure 13) shows the standard EIA process followed in Namibia, which is followed by EDS for this project. The current stage of the project is highlighted in red.

Figure 13: Environmental Assessment Process and Progress (source: Risk Based Solutions, 2019)

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The identified impacts were assessed in terms of probability (likelihood of occurring), scale/extent (spatial scale), magnitude (severity) and duration (temporal scale) as presented in Table 4, Table 5, Table 6 and Table 7.

In order to enable a scientific approach to the determination of the environmental significance, a numerical value is linked to each rating scale. This methodology ensures uniformity and that potential impacts can be addressed in a standard manner so that a wide range of impacts are comparable. It is assumed that an assessment of the significance of a potential impact is a good indicator of the risks associated with such an impact. The following process will be applied to each potential impact:

 Provision of a brief explanation of the impact;  Assessment of the pre-mitigation significance of the impact; and  Description of recommended mitigation measures.

The recommended mitigation measures prescribed for each of the potential impacts contribute towards the attainment of environmentally sustainable operational conditions of the project for various features of the biophysical and social environment. The following criteria is applied in this impact assessment:

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7.1.1 Extent (spatial scale)

Extent is an indication of the physical and spatial scale of the impact. Table 4 shows rating of impact in terms of extent of spatial scale.

Table 4: Extent or Spatial Impact rating

Low (1) Low/Medium (2) Medium (3) Medium/High (4) High (5)

Impact is localised Impact is beyond Impacts felt within Impact widespread Impact extend within the site the site boundary: adjacent far beyond site National or over boundary: Site only Local biophysical and boundary: Regional international social boundaries environments: Regional

7.1.2 Duration

Duration refers to the timeframe over which the impact is predicted to occur, measured in relation to the lifetime of the project. Table 5 shows the rating of impact in terms of duration.

Table 5: Duration impact rating

Low (1) Low/Medium (2) Medium (3) Medium/High (4) High (5)

Immediate Impact is quickly Reversible over Impact is long-term Long term; beyond mitigating reversible, short time; medium term closure; measures, term impacts (0-5 (5-15 years) permanent; immediate years) irreplaceable or progress irretrievable commitment of resources

7.1.3 Intensity, Magnitude/Severity

Intensity refers to the degree or magnitude to which the impact alters the functioning of an element of the environment. The magnitude of alteration can either be positive or negative. These were also taken into consideration during the assessment of severity. Table 6 shows the rating of impact in terms of intensity, magnitude or severity.

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Table 6: Intensity, Magnitude/Severity impact rating

Type of Negative criteria H- M/H- M- M/L- L-

(10) (8) (6) (4) (2)

Qualitative Very high Substantial Moderate Low Minor deterioration, deterioration, deterioration, deterioration, deterioration, high quantity death, illness discomfort, slight nuisance or of deaths, or injury, loss of partial loss of noticeable irritation, minor injury of illness habitat / habitat / alteration in change in / total loss of diversity or biodiversity or habitat and species / habitat, total resource, resource, biodiversity. habitat / alteration of severe moderate Little loss in diversity or ecological alteration or alteration species resource, no or processes, disturbance of numbers very little quality extinction of important deterioration. rare species processes

7.1.4 Probability of occurrence

Probability describes the likelihood of the impacts actually occurring. This determination is based on previous experience with similar projects, and/or on professional judgment. See Table 7 for impact rating in terms of probability of occurrence.

Table 7: Probability of Occurrence impact rating

Low (1) Medium/Low (2) Medium (3) Medium/High (4) High (5)

Probable if Definite (regardless Improbable; low Likely to occur Possible, distinct mitigating measures of preventative likelihood; from time to time. possibility, frequent. are not measures), highly seldom. No Low risk or Low to medium risk implemented. likely, continuous. known risk or vulnerability to or vulnerability to Medium risk of High risk or vulnerability to natural or induced natural or induced vulnerability to vulnerability to natural or hazards hazards. natural or induced natural or induced induced hazards. hazards. hazards.

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7.1.5 Significance

Impact significance is determined through a synthesis of the above impact characteristics. The significance of the impact “without mitigation” is the main determinant of the nature and degree of mitigation required. As stated in the introduction to this chapter, for this assessment, the significance of the impact without prescribed mitigation actions was measured.

Once the above factors (Table 4, Table 5, Table 6 and Table 7) are ranked for each potential impact, the impact significance of each is assessed using the following formula:

SP = (magnitude + duration + scale) x probability

The maximum value per potential impact is 100 significance points (SP). Potential impacts are rated as high, moderate or low significance, based on the following significance rating scale (Table 8).

Table 8: Significance rating scale

Significance Environmental Significance Points Colour Code

High (positive) >60 H

Medium (positive) 30 to 60 M

Low (positive) <30 L

Neutral 0 N

Low (negative) >-30 L

Medium (negative) -30 to -60 M

High (negative) >-60 H

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For an impact with a significance rating of high, mitigation measures are recommended are provided, to reduce the impact to a low or medium significance rating, provided, the impact with a medium significance rating can be sufficiently controlled with the recommended mitigation measures. To maintain a low or medium significance rating, monitoring is recommended for a period of time to enable the confirmation of the significance of the impact as low or medium and under control.

The assessment of the exploration phases is done for both pre-mitigation (before implementing any mitigation) and post-mitigation (after mitigations are implemented).

The risk/impact assessment is driven by three factors and these are:

 Source: The cause or source of the contamination.

 Pathway: The route taken by the source to reach a given receptor

 Receptor: A person, animal, plant, eco-system, property or a controlled water source. If contamination is to cause harm or impact, it must reach a receptor.

According to Booth (2011), a pollutant linkage occurs when a source, pathway and receptor exist together. The objective of the mitigation measures is to avoid first, the risk, and if the risk cannot be avoided, mitigation measures to minimize the impact are recommended. Once the mitigation measures have been applied, the identified risk will be of low significance.

This impact assessment focuses on the three project phases namely; prospecting/exploration, advanced exploration drilling, sampling (and possible analysis) and decommissioning. The potential negative impacts stemming from the proposed activities are described, assessed and mitigation measures provided thereof. Further mitigation measures in a form of management action plans will be provided in the Draft Environmental Management Plan.

Assessment of Potential Negative Impacts: Surveys, Drilling, Sampling (Operational Phases)

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The main potential negative impacts associated with construction and operational (and maintenance phases) identified are; soil disturbance, dust (air pollution), visual impact, loss of biodiversity (fauna and flora), health and safety, archaeological impact, waste generation and noise pollution. Potential impacts identified to be associated with the exploration discontinuation are loss of employment opportunities and loss of economic growth for the country.

 Loss of biodiversity - possible destruction of faunal habitats that may be encountered within the site soils.  Generation of dust (air quality) - generation of dust from the unpaved site access roads during construction and possible gaseous emissions into the air by unserviced vehicles and machinery  Waste generation - potential environmental pollution through uncontrolled waste disposal.  Visual impact  Potential health and safety risk - potential health and safety risks associated with mishandling of project equipment.  Soils disturbance/pollution - disturbance of site soils by exploration, project vehicles and machinery.  Archaeological impact - potential uncovering of unknown archeological objects during construction works or operational phase.  Noise – noise due to drilling during exploration

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7.1.6 Loss of Biodiversity (Fauna and Flora)

The drilling activities and earthworks done to expose the mineralized rock units may result in land degradation, thus destroying habitats of small animal species that may reside under the site soils and rocks. In order to enable the exploration operations, some site vegetation within the footprint of the exploration area may be removed. This could lead to the destruction of protected plant species, resulting in the loss of such species and eventual loss of biodiversity in the area. In fragile ecosystems, vegetation is easily disturbed, which often means any disturbance to the environment will result in the loss of flora. It is therefore important to identify what species are present, understand them and make efforts to minimise the impact upon them with operational management guidelines. The most obvious impact on vegetation is direct loss due to removal of soil by digging and trenching. EDS advises the Proponent to avoid unnecessary removal of vegetation, in order to promote a balance between biodiversity and their operations. Under the status, the impact is considered to be of medium significance rating. With the implementation of appropriate mitigation measures, the rating would significantly be reduced to low. The impact is assessed in Table 9 below.

Table 9: Assessment of the impacts of exploration on biodiversity

Mitigation Extent Duration Intensity Probability Significance Status Pre M - 3 M - 3 M - 6 M - 3 M – 36 mitigation Post L/M - 2 L/M - 2 L/M - 4 L/M - 2 L - 16 mitigation

Mitigations and recommendation to minimize the loss of biodiversity  Vegetation found on the site but not in the targeted exploration areas should not be removed, but left to preserve biodiversity on the site.

 Shrubs or trees found near drilling or sampling spots on site should remain intact. Therefore, care should be taken when extracting mineral resources without destroying the vegetation.

 Workers should refrain from killing or snaring animals’ species (big or small) that may be found on the site.

 Environmental awareness on the importance of biodiversity preservation should be provided to the workers.

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7.1.7 Generation of Dust

Dust emanating from site access roads when transporting exploration equipment and supply (water) to and from site (time-to-time) may compromise the air quality in the area. Vehicular movements create dust even though it is not always so severe. The hot and dry environment, loose and in some places sandy nature of the substrate, and low vegetation cover causes ambient fugitive dust levels. The medium significance of this impact can be reduced by properly implementing mitigation measures. The impact is assessed in Table 10 below.

Table 10: Assessment of the impacts of exploration on air quality

Mitigation Extent Duration Intensity Probability Significance Status Pre L/M - 2 L/M - 2 L/M- 4 L/M - 2 M – 16 mitigation Post L - 1 L - 1 L- 2 L - 1 L - 4 mitigation

Mitigations and recommendation to minimize dust  The Proponent should ensure that the exploration schedule is limited to the given number of days of the week, but not every day. This will keep the vehicle-related dust level minimal in the area.

 Since the project site is in an area where soils are exposed due to little vegetation cover, it is highly probable that more dust will be generated from exploration works. It is therefore advised that in extremely windy days, a reasonable amount of water should be used to supress the dust that may be emanating from certain exploration areas on the EPL.

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7.1.8 Waste Generation

Prospecting and exploration activities are usually associated with generation of waste of all kinds (domestic and general) and if these are not disposed of in a responsible manner, it will result in the pollution of the site and the surrounding environment. Industrial waste is a given by-product of any exploration operation. Non-biodegradable and biodegradable refuse should be stored in separate containers, collected on a regular basis and disposed of at a recognized disposal facility. Precautions should be taken to prevent spread of any refuse. The waste containers should be covered with mesh to prevent access from animals. Without any mitigation measure, the impact has a medium significance. The impact will be of low significance from medium, upon implementing the mitigation measures. The assessment of this impact is shown in Table 11.

Table 11: Assessment of waste generation impacts

Mitigation Extent Duration Intensity Probability Significance Status Pre M - 3 M/H - 4 M - 6 M - 3 M – 39 mitigation Post L - 1 L - 1 L - 2 L/M - 2 L - 8 mitigation

Mitigations and recommendation to waste management  Workers should be sensitized to dispose of waste in a responsible manner and not to litter.  After each daily works, the Proponent should ensure that there are no wastes left on site.  All domestic and general operational waste produced on a daily basis should be contained until such that time it will be transported to designated waste sites.  No waste may be buried or burned on site or anywhere else.  The exploration site(s) should be equipped with separate waste bins for hazardous and general waste/domestic.

 A penalty system for irresponsible disposal of waste on site and anywhere in the area should implemented.

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7.1.9 Visual Impact (Scars) on Landscape

Exploration activities leave scars on the landscape thus, causing a visual impact. If the exploration site is situated near tourists’ routes, these scars may contrast the surrounding landscape and this can potentially cause visual nuisance to tourists. However, it is vital to note that throughout exploration phase, assured measures will need to be taken into concern regarding the visual aspect. Currently, the visual impact can be rated as medium to low significance, but upon effectively implementing the measures. The assessment of this impact is presented in Table 12.

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Table 12: Assessment of the visual impact of exploration on landscape

Extent Duration Intensity Probability Significance Pre M - 3 M - 3 M - 6 M - 3 M – 36 mitigation Post L/M - 2 L/M - 2 L/M - 4 L/M -2 L - 16 mitigation

Mitigations and recommendation to minimize visual impact  The Proponent should consider the implementation of continuous rehabilitation programme, by using overburden waste rocks.

7.1.10 Potential Health and Safety Risks

Inappropriate handling of exploration materials and equipment may cause health and safety risks such as injuries to workers. The impact is probable and has a medium significance rating. However, with adequate mitigation measures, the impact rating will be reduced to low. This impact is assessed in Table 13 below and mitigation measures provided.

Table 13: Assessment of the impacts of exploration on health and safety

Mitigation Extent Duration Intensity Probability Significance Status Pre M - 3 L/M - 2 M - 6 M/H - 4 M – 44 mitigation Post L/M - 2 L/M - 2 L - 2 L/M - 2 L - 12 mitigation

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Mitigations and recommendation to minimize health and safety issues

 As part of their induction, the workers should be provided with an awareness training of the risks of mishandling equipment and materials on site.

 When working on site, employees should be properly equipped with personal protective equipment (PPE) such as coveralls, gloves, safety boots, earplugs, safety glasses, etc.

 No employee should be allowed to drink alcohol prior to and during working hours as this may lead to mishandling of equipment which results into injuries and other health and safety risks.

 No employee should be allowed on site if under the influence of alcohol.

7.1.11 Surrounding Soils Impacted

The planned exploration activities will potentially disturb the soil structure on the site, which will leave the already exposed site soils vulnerable to erosion resulting into creation of gullies. This impact is likely because the proposed site has little vegetation cover. The impact can be rated as medium, if no mitigation measures are implemented. However, with the implementation of mitigation measures, the impact will reduce to low. The impact is assessed in Table 14 below and mitigation measures are provided below.

Table 14: Assessment of the impacts of exploration on soils

Mitigation Extent Duration Intensity Probability Significance Status Pre L/M - 2 L/M - 2 M - 6 M - 3 M – 30 mitigation Post L - 1 L/M - 2 L - 2 L/M -2 L - 10 mitigation

Mitigations and recommendation to minimize impact on soil  Overburden material (if any) should be handled efficiently during exploration operations to avoid erosion when subjected erosional processes.

 Prevent the creation of huge piles of waste rocks by performing sequential backfilling.

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7.1.12 Archaeological Impact

During exploration works, historical resources may be impacted through inadvertent destruction or damage. This may include the excavation of subsurface graves or other archaeological objects. There was no information provided about known heritage or site of cultural values within the site or in the vicinity of the project site area. Therefore, this impact can be rated as medium to low, if there are no mitigation measures in place. Upon implementation of the necessary measures, the impact will be low. The impact is assessed Table 15.

Table 15: Assessment of the impacts of exploration on archaeological sites

Mitigation Extent Duration Intensity Probability Significance Status Pre M - 3 M - 3 M - 6 M - 3 M – 36 mitigation Post L/M - 2 L/M- 2 L/M - 4 L/M -2 L - 16 mitigation

Mitigations and recommendation to minimize impact on archaeological sites  The Proponent should consider having a qualified and experience archaeologist on standby during exploration work and sampling phase and as required during the entire operational phase. This action will be to assist on the possibility of uncovering sub-surface graves or other cultural/heritage objects and advice the Proponent accordingly.

 Identified graves or any archaeological significant objects on the site should not be disturbed, but must be reported to the project Environmental officer or National Heritage Council offices.

7.1.13 Noise and Vibrations

Prospecting and Exploration works (especially drilling) may be a nuisance to surrounding neighbours. Excessive noise can also be a health risk to site workers. However, the envisaged exploration equipment used for drilling and blasting on site is of medium size and the noise level is bound to be limited to the site only, and therefore, the impact likelihood is minimal. Without any mitigations, the impact is rated as of medium significance. In order to change the impact significance from the pre-mitigation significance to low rating, the mitigation measures should be implemented. This impact is assessed in Table 16 below.

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Table 16: Assessment of the impacts of noise from exploration

Mitigation Extent Duration Intensity Probability Significance Status Pre L/M - 2 L/M - 2 M - 6 M - 3 M – 30 mitigation Post L - 1 L/M - 2 L - 2 L/M -2 L - 10 mitigation

Mitigations and recommendation to noise  Noise from operations vehicles and equipment on site should be reduced to acceptable levels.

 The exploration operational times should be set such that, no exploration activity is carried out during the night or very early in the mornings.

 Exploration hours should be restricted to between 08h00 and 17h00 to avoid noise generated by exploration equipment and the movement of vehicles before or after hours.

 When operating the drilling machinery onsite, workers should be equipped with personal protective equipment (PPE) such as earplugs to reduce noise exposure.

Assessment of Potential Negative Impacts: Decommissioning Phase

Impacts pertaining to the closure of the exploration program have been identified. The impacts are; loss of employment by workers at the exploration site and contribution to the national economy (revenue and royalties’ payments). Another concern that stems from exploration program closure is the rehabilitation of the sites.

7.4.1 Impact on Employment Opportunities and Economic Contribution

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Should the exploration program come to an end, employees of the exploration project lose their jobs and source of income. This will also mean that there will be no more revenue and royalties paid to the government. This impact can be rated as of medium significance given that the program has a defined timeframe, which is clear to all parties involved. The impact significance of unemployment can be reduced from medium to low, by implementing mitigation measures. The impact assessed in Table 17 below is that of employment loss only.

Table 17: Assessment of the impacts of closure of exploration activity on employment

Mitigation Extent Duration Intensity Probability Significance Status Pre M - 3 L/M - 2 M - 6 M/H - 4 M – 44 mitigation Post L/M - 2 L/M - 2 L/M - 4 L/M - 2 L - 16 mitigation

Mitigations and recommendation to minimize joblessness  The Proponent should inform the employees on time, of its intentions to cease the exploration works and the expected date of such closure. This will provide the employees with enough time to search for work elsewhere.

 The Proponent should raise awareness of the possibilities for work in industrial sectors.

Conclusively, it is found that most of the identified potential negative impacts are rated as medium significant. Therefore, in order to reduce the significance from medium to low, it is recommended that the Proponent effectively implement mitigation measures, and continuously monitors their implementation, to maintain an overall low significance.

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8 RECOMMENDATIONS AND CONCLUSIONS

Recommendations The key potential impacts associated with the proposed exploration program and its associated activities were identified and assessed. In order to avoid and minimise (where impacts cannot be avoided) the identified project impacts, mitigation measures were recommended. The significant identified impacts for the project phases on the environmental features are summarized below. These impacts can be reduced or minimised by implementing the mitigation measures and given under the impact assessment chapter and also management actions plan provided in the Draft EMP.

 Loss of Biodiversity: EDS consultant has advised the Proponent (in section 7.3.1) to avoid unnecessary removal of vegetation, in order to promote a balance between biodiversity and their operations. Under the status quo, the impact can be considered to be of a medium significance rating. With the implementation of appropriate mitigation measures (provided in the EMP, Appendix B), the rating will significantly be reduced to low.

 Generation of Dust: The generation of dust by exploration operations is considered minimal, and therefore of medium significance without any mitigation measures. The medium significance of this impact can be reduced by properly implementing mitigation measures (provided in the EMP, Appendix B).

 Waste Generation: Without any mitigation measure, the impact has a medium significance. The impact will be of low significance from medium, upon implementing the mitigation measures (provided in the EMP, Appendix B).

 Visual Impact (Scars) on Landscape: Currently, the visual impact can be rated as slightly medium to low significance, but upon effectively implementing the measures (provided in the EMP, Appendix B).

 Potential Health and Safety Risks: Improper handling of mining materials and equipment may cause health and safety risks such as injuries to workers. The impact is probable and has a medium significance rating. However, with adequate mitigation measures, the impact rating will be reduced to low (provided in the EMP, Appendix B).

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 Surrounding Soils Impacted: The impact can be rated as medium, if no mitigation measures are implemented. However, with the implementation of mitigation measures, the impact significance will reduce to low (provided in the EMP, Appendix B).

 Archaeological impact: There is no information provided and/or established about the known heritage or site of cultural values within the EPL or within the vicinity of the project site area. Therefore, this impact can be rated medium to low, if there are no mitigation measures in place. Upon implementation of the necessary measures, the impact significance will be low (provided in the EMP, Appendix B).

 Noise: Without any mitigation, the impact is rated as of medium significance. In order to change the impact significance from the pre-mitigation significance to low rating, the mitigation measures should be implemented (provided in the EMP, Appendix B).

Conclusions

The potential positive and negative impacts stemming from the proposed prospecting and exploration activities on the EPL were identified, assessed, and mitigation measures made thereof. The mitigation measures and recommendations provided in this Environmental Assessment report and management action plans provided in the draft EMP, can be deemed sufficient to avoid and/or reduce (where impact avoidance is impossible) the risks to acceptable levels. EDS is therefore confident that these measures are sufficient and thus recommends that the Proponent be issued the Environmental Clearance Certificate (ECC) to enable exploration works on EPL 7258. However, the ECC should be issued on condition that the provided management measures and action plans are effectively implemented and monitored on site. Most importantly, the monitoring of the environmental components described in the impact assessment should be conducted by the Proponent and applicable Competent Authority. This is to ensure that all potential impacts identified in this study and other impacts that might arise during the exploration program implementation are properly identified on time and addressed. Lastly, should the ECC be issued, the Proponent will be expected to be compliant with the ECC conditions as well as legal requirements governing the mineral exploration and related activities.

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9 REFERENCES

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