EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

ENVIRONMENTAL IMPACT ASSESSMENT REPORT FOR EXCLUSIVE PROSPECTIVE LICENSEs (EPLs) 6561 & 5992 OTJOZONDJUPA REGION

April 2019

Prepared by: Philip Hooks p.1

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

EXECUTIVE SUMMARY

Kunene Resources (Pty) Ltd holds EPLs 6561 & 5992 which are roughly 164 939 hectares in extent located on communal land south and east of Grootfontein town. The licenses are granted for the exploration of precious metals, base and rare metals, dimensions stones as well as industrial minerals. This Environmental Impact Assessment Report, once complete, will be submitted for an application for Environmental Clearance to conduct mineral exploration work.

In this document the receiving environment is described, the envisaged activities are listed and described and the potential environmental impacts are explained. A Draft Environmental Management Plan has been compiled for Ministry approval. The EIA Report & Draft EMP describes mitigations to be applied, the aspects to be monitored and reported on, as well as delegate responsibilities to designated officials. Interested and Affected Parties are hereby requested to review the Draft EIA Report and Draft EMP and provided input prior to the submission of this report to the Ministry of Environment and Tourism.

The potential environmental impacts were assessed as being of medium to low significance if the suggested mitigations are strictly implemented. Stakeholder relations must be well developed, and specific conditions adhered to as per any negotiations with the interested and affected parties.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

TABLE OF CONTENTS EXECUTIVE SUMMARY ...... 3

1 INTRODUCTION ...... 6

2 OBJECTIVES ...... 7

3 ADMINISTRATIVE AND LEGAL FRAMEWORK ...... 8

4 PROJECT MOTIVATION ...... 10

5 SCOPE OF THE STUDY ...... 10

6 PROJECT DESCRIPTION ...... 11

6.1 PROSPECTING...... 11

6.2 EXPLORATION DRILLING, SAMPLE EXTRACTION AND ANALYSIS ...... 12

6.3 PITTING, TRENCHING, BULK SAMPLING AND TRIAL MINING ...... 13

7 DESCRIPTION OF THE ENVIRONMENT...... 15

7.1 LOCATION ...... 15

7.2 GEOLOGICAL SETTING ...... 16

7.3 CLIMATE ...... 17

7.3.1 Rainfall and Temperature ...... 17

7.3.2 Topography and hydrology/drainage ...... 18

7.4 BIOLOCAL ENVIRONMENT ...... 20

7.5 SOCIO-ECONOMIC ENVIRONMENT ...... 22

8 STAKEHOLDER CONSULTATION ...... 24

9 IMPACT ASSESSMENT ...... 26

10 ENVIRONMENTAL MANAGEMENT PLAN ...... 51

11 REPORTING AND MONITORING ...... 51

12 CONCLUSION ...... 52

13 REFERENCES ...... 52

APPENDIX A: PROOFS OF ECC APPLICATION REGISTRATIONS & EPL LICENCES ...... 53

APPENDIX B: PUBLIC PARTICIPATION DOCUMENTS ...... 77 APPENDIX C: DRAFT ENVIRONMENTAL MANAGEMENT PLAN FOR KUNENE RESOURCES (PTY) LTD WITHIN EPLS 6561 & 5992 ...... 105

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Table of Tables

Table 1: List of laws applicable to the EIA for EPLs 6561 & 5992 ...... 8

Table 2. International law to which Namibia is signatory ...... 10

Table 3. Climatic data provided by national database ...... 18

Table 4. General Flora Data (Atlas of Namibia) ...... 20

Table 5. General Fauna Data (Atlas of Namibia)...... 25

Table 6: Assessment methodology for evaluating potential impacts ...... 26

Table 7: Dust Impacts ...... 29

Table 8: Noise Impacts ...... 31

Table 9: Health & Safety Impacts ...... 33

Table 10: Health & Safety Impacts ...... 35

Table 11: Visual Impacts ...... 38

Table 12: Land Use Impact ...... 40

Table 13: Waste Impact ...... 41

Table 14: Ecological Impacts ...... 43

Table 15. Groundwater and Surface Water Impacts ...... 45

Table 16. Heritage ...... 48

Table 17: Socio-Economic Impact ...... 52

Table of Figures

Figure 1: Location of EPLs 6561 & 5992 within Northern Namibia and Otjozondjupa Region, and their relative size...... 6

Figure 2: Maps of EPLs with corner coordinates...... 16

Figure 3. Map of the river systems of the Otjozondjupa Region relative to the EPLs ...... 19

Figure 4. Map showing registered boreholes of the Omatako River Catchment within EPL6561 and registered boreholes within EPL5992 ...... 19

Figure 5. A map of the farms found within EPLs 6561 and 5992...... 23 p.5

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

1 INTRODUCTION Kunene Resources Namibia (Pty) Ltd is planning to carry out exploration activities on their Exclusive Prospecting License (EPL) 6561 & 5992, located in Otjozondjupa region, Grootfontein magisterial district, registration division B; south and east of Grootfontein. The two EPLs are roughly 164 939 hectares in extent located on communal and commercial farm land. The comprehensive exploration program is for base and rare metals, dimension stones, industrial minerals and precious metals groups of minerals.

The Exclusive Prospective Licences (EPLs) have been granted by the Ministry of Mines and Energy, but activities may not commence prior to the completion of an Environmental Impact Assessment (EIA) and the issuance of environmental clearance. Figure 1 renders a map showing the location and the relative extent of the two EPLs.

Figure 1: Location of EPLs 6561 & 5992 within Northern Namibia and Otjozondjupa Region, and their relative size.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Kunene Resources Namibia (Pty) Ltd is a subsidiary of a Canadian company, Namibia Critical Metals Inc., listed on the Toronto Stock Exchange. Namibia Critical Metals owns 95% and a Namibian partner, Amor Investments, 5% of Kunene Resources Namibia (Pty) Ltd. The focus of the exploration company is on the development of projects in Namibia with emphasis on the industrial mineral sector. Today, the company permanently employs about 20 people.

2 OBJECTIVES The objective of this assessment was to investigate the environmental adequacy during various phases of the project. Additionally, it is to provide The Ministry of Environment and Tourism with the assessment document in order for the Environmental Commissioner to issue an Environmental Clearance Certificate (ECC) for the exploration activities on EPLs 6561 & 5992. The ECC application registration proofs are rendered in Appendix A. Environmental Clearance for each EPL individually is to be applied for. The valid EPL licences are included in Appendix A. Possible environmental impacts were identified and assessed with recommendations on appropriate mitigation measures. Briefly, some objectives of the Environmental Impact Assessment study were: ▪ to define the project scope; ▪ to recognize and measure any potential destruction to flora, fauna and natural surroundings; ▪ ensure that the potential impacts that are identified are adequately addressed; ▪ to highlight the positive inputs towards the Namibian economy through employment creation and foreign capital gains through investments; ▪ to plan the provision of infrastructure and develop mitigation measures so as to minimize pollution, environmental disturbance and nuisance during the various phases of the project; ▪ to recognize, assess and specify methods, measures and standards to be included in the detailed design, construction and operation of the project necessary to moderate these environmental impacts and cumulative effects and reduce them to tolerable levels; ▪ facilitate an informed, transparent and accountable decision-making process by engaging with the relevant authorities and private landowners. Furthermore, the mitigation measures and continuous monitoring programme are described in the Draft Environmental Management Plan (EMP). Mr. Philip Hooks is the Environmental Assessment Practitioner (EAP) undertaking the EIA and the responsible person completing this report. Miss Lovisa Amwele, a student intern, assisted Mr. Hooks.

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3 ADMINISTRATIVE AND LEGAL FRAMEWORK The EIA is based on the requirements of the Namibian Environmental Management Act (Act. No. 7 of 2007), as well as supporting policies and guidelines, which include the environmental regulations of February 2012. An Environmental Clearance Certificate for mineral exploration activities is required and thus an EIA and Environmental Management Plan (EMP) needs to be submitted to the Ministry of Environment and Tourism (MET) of Namibia for approval. In agreement with the national legal framework, the following laws are relevant to the exploration program for base and rare metals, dimension stones, industrial minerals and precious metals groups of minerals on EPLs 6561 &5992 as per Table 1 and 2 below.

Table 1: List of laws applicable to the EIA for EPLs 6561 & 5992 YEAR LAW/ORDINANCE APPLICABILITY 1990 The constitution of Namibia (1990) Article ✓ Preservation of Namibia's Ecosystems, 95 (1) essential ecological process and biological diversity ✓ Sustainable use of Natural Resources 1992 The Labour Act, No. 6 of 1992 ✓ Safety and health requirements 2007 Labour Act No. 11 of 2007 & Rules and ✓ Safety and health requirements Regulations promulgated under the Act. 1998 Affirmative Action (Employment) Act No. ✓ Fair employment practice 29 of 1998 2005 Atomic Energy and Radiation Protection ✓ Protection of personnel exposed to Act No. 5 of 2005 radiation sources 1995 Namibia's Environmental Assessment ✓ Prescribes Environmental Impact Policy for Sustainable Development and Assessments for any developments Environmental Conservation of 1995 with potential negative impacts on the Environment 2013 Water Resources Management Act 11 of ✓ Effluent discharge permit required 2013 under section 70 ✓ Water related pollution and abstraction 2012 Environmental Management Act 7 of 2007 ✓ Establishes Principles for EA with Regulations of 2012 ✓ Ensures that significant effects of activities are considered timorously and carefully ✓ Allows for opportunities for participation by I & APs throughout the assessment process 1975 Nature Conservation Ordinance 4 of 1975 ✓ Protection of various species with amendments and special regulations p.8

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

1996 Nature Conservation Amendment Act 5 of ✓ To provide for an economically based 1996 system of sustainable management and utilisation of game in communal areas 2001 The Forestry Act 12 of 2001 ✓ To provide for the protection of the environment and the control and management of forest fires 1969 Soil Conservation Act No. 76 of 1969 ✓ To consolidate and amend the law relating to the combating and prevention of soil erosion, the conservation, improvement and manner of use of the soil and vegetation and the protection of the water sources 1992 United Nations Convention of Biological ✓ Protection of various species Diversity (1992) 1976 Atmospheric Pollution Prevention ✓ Pollution prevention Ordinance No.11 of 1976 with amendments as well as the associated proclamations of controlled areas 1974 Hazardous Substance Ordinance 14 of 1974, ✓ Pollution prevention and amendments 1990 Petroleum Products and Energy Act No. 13 ✓ For control of the furnishing of of 1990, as amended (1994, 2000, 2003) certain information regarding petroleum products ✓ Disposal of petroleum products 2000 Petroleum Products regulations (2000) ✓ Consumer installation certificates ✓ Safe disposal of petroleum products 1999 Draft Pollution and Waste Management Bill ✓ Protection for particular species, (1999) resources or components of the environment 2004 National Heritage Act 27 of 2004 ✓ Disturbance of archaeological or cultural sites 1994 Convention on Desertification of 1994 ✓ Combating desertification and mitigation of the effects of drought 1992 Minerals (Prospecting and Mining) Act 33 of ✓ Exploration and exploitation of 1992 and special regulations mineral resources

2000 Explosives Act of 1956 & Regulations of ✓ Safe transport and storage of 1972 promulgated in terms of the Explosives explosives Act 1956 ✓ Accident enquiries ✓ Permitting and penalties

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Table 2. International law to which Namibia is signatory INTERNATIONAL LAW TO WHICH NAMIBIA IS A SIGNATORY 1985 Vienna Convention for the Protection of the Ozone Layer 1987 Montreal Protocol on substances that deplete the Ozone Layer 1989 The Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and their Disposal 1989 The Rotterdam convention on the Prior Informed Consent Procedure for Certain Hazardous chemicals and Pesticides in International Trade 1992 The Rio de Janeiro Convention on Biological Diversity 1992 United Nations Framework Convention on Climate Change

4 PROJECT MOTIVATION Base and rare metals, industrial minerals, precious metals and precious stones are to be considered. This exploration project will contribute to sustaining Namibia’s economy.

The project forms part of Kunene Resource (Pty) Ltd Namibia’s endeavours to establish economically and environmentally sustainable operations.

5 SCOPE OF THE STUDY The scope of the EIA is to determine the potential environmental impacts arising from the proposed activities by doing a risk assessment. Relevant environmental data has been compiled by making use of secondary data from desk-top work. Existing fauna and flora data from the the national database was used to assess the impacts on biodiversity. The EIA Report and EMP will enable stakeholders to make informed judgements regarding the exploration activities from an environmental perspective.

The project’s potential environmental impacts and associated social impacts are identified and addressed in the report. The environmental assessment was conducted to comply with Namibia’s Environmental Management Act, the requirements of Local Authorities and all other legal requirements applicable to the project and the country.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

6 PROJECT DESCRIPTION Exploration follows three phases as described below. Firstly, there is a prospecting phase, then a drilling phase and lastly a pitting, trenching, bulk sampling and trial mining phase. Kunene Resources (Pty) Ltd plans to conduct a staged exploration approach as follows.

6.1 PROSPECTING

Aerial data is ascertained from existing maps and reports. In addition to this, Kunene Resources plans to undertake remote sensing using an airborne electromagnetic survey. This consists of flying low over the terrain in a small dust cropper like aircraft using sophisticated equipment to survey the electromagnetic anomalies in the ground below. The outcomes of this survey and the desktop research must then be verified through field work. So up to this point no physical disturbance is required.

Lithological (soil/rock) mapping, sampling and analysis will be necessary to verify the desktop and aerial survey work. The results from this initial lithological mapping may need further confirmation by means of small exploration pits as well.

Prospecting is in general a low intensity activity. Specifically it constitutes the following:

➢ A prospector (Geologists and geo-technicians) walking through the area with a rock hammer and GPS examining and mapping the outcropped lithology. ➢ Collecting rock and sand samples by hand for either mineral or chemical analysis. ➢ Possible follow up pitting. ➢ It is estimated that a maximum of 6 persons would be needed for these field aspects

For the first 12 months, prospecting will be done by:

➢ Data collection and compilation of all available information into GIS digital format and interpretation of data (2 months) ➢ Mapping of the area & prospect pitting (2 months) ➢ Analysis of samples (4 months) ➢ Compilation of data and preliminary viability calculations (5 months) p.11

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

For the remaining 24 months of the initial license tenement prospecting will be done by the following activities:

➢ The identification of potential mineral occurrences of base and rare metals, precious metals through additional remote sensing techniques. ➢ The identification of potential secondary mineral resources of economic interest. The area will also be looked at in the light of secondary mineralisation as well as for different types of mineral deposits.

6.2 EXPLORATION DRILLING, SAMPLE EXTRACTION AND ANALYSIS

This phase of exploration may begin in the first licence period or the subsequent licence periods. The most commonly used drilling techniques are Reverse Circulation Drilling (RC) or Diamond Drilling. Both methods are applied in exploration, resource evaluation and subsequently in defining an ore reserve.

Exploration Diamond Drilling differs from other geological drilling in that a solid core is extracted from depth, for examination on the surface. The key technology of the diamond drill is the actual diamond bit itself. It is composed of industrial diamonds set into a soft metallic matrix. The drill produces a "core" which is logged, photographed and split longitudinally. Half of the split core is assayed while the other half is permanently stored for future use and re-assayed if necessary.

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 Diamond Drilling.

The target areas within the EIA which have been identified during the prospecting phase will then undergo exploration drilling to obtain undisturbed samples of the lithology which are associated with the specific minerals present. A number of consecutive drilling campaigns on increasingly closer-spaced exploration grids might be conducted. Drilling is initially done with the diamond coring technique. Once the type of ore body is understood, emphasis then lies on obtaining more closed-spaced samples for gaining confidence and information on the statistical variance. For this latter process, RC Drilling is the preferred technique.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

If there are signs of specific target minerals present, then prospecting activities progress to more detailed work program. Drilling is then required to go deeper. Larger samples are geologically logged and analysed in a laboratory.

Exploration will take place during the day time only and staff will either commute to site from the town or there would be an establishment of a drilling camp at an approved site within the EPLs. Camp sites will be established in consultation with the local farm owners and be run according to strict conditions for control of litter and other disturbances.

Access will be organised along the existing roads as far as possible. Tracks for new access roads will be assessed for any environmental sensitivity. Solid waste will be removed off site and taken to Grootfontein’s approved landfill site. Ablution facilities will use chemical toilets and or sealed septic tanks and the sewerage taken to the Grootfontein sewerage plant periodically. No power supply infrastructure to the site is planned. Diesel power generation will be used. Temporary storage areas for drilling materials, machines etc. will be necessary at the camp. Security will be supplied on a 24 hour basis at the exploration camp. A fence surrounding the camp will be constructed to ensure people and domestic animals are not put at risk. These support services and facilities will be removed at the end of the 3rd phase of the exploration. An exploration team of 35 persons (4 drilling teams plus geologists and technicians) could potentially be required depending on the outcomes of the prospecting phase and the intensity of drilling requirements to meet the demands of market and investors.

Clearing of vegetation at the planned drill sites may be necessary and larger trees will be retained so that the bush can restore itself. Permits from the forestry directorate will be required for this purpose. Where necessary, stockpiling of top soil for rehabilitation at a later stage will be undertaken. Necessary landscaping of exploration areas will be undertaken upon completion of each phase of exploration.

6.3 PITTING, TRENCHING, BULK SAMPLING AND TRIAL MINING

In the advanced stage of exploration activities, larger amounts of sample material, whether a main mineral being targeted, or the secondary mineralisation target may be required for the performing processing trials and metallurgical testing programs. The ground conditions and geotechnical parameters would then be established with a view to extract the mineral from the ore reserve. p.13

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Bulk sampling for analytical processing will only be carried out if the material obtained during drilling is insufficient. Pits may be dug / excavated to a depth of 4m and 5 cubic meters of samples are taken. The location of the pits will depend on the drilling results. The size of the sample may be adjusted depending on the nature of the mineralisation observed from drilling. The pits and bulk sampling sites are determined from the results of the drilling and will most likely be where drilling had already taken place. A trench may span between drilling sites, thereby incurring additional disturbance.

Kunene Resources (Pty) Ltd plans to employ several people for the exploration phases. Initially, the exploration team doing field work would consist of a handful of geological personnel. During the drilling phase the exploration team will increase in numbers. For one RC rig the team consists of 4 members plus a driver. For one DD rig the team will consist of 5 members. Each drill rig will have one foreman and one geologist assigned to it. The camp will have one chef and a camp manager. So, for a very intensive drilling programme, 3 RC rigs and 3 DD rigs may be needed. The total personnel number would be no more than 35 for this configuration. At this stage it is not clear how many rigs will be mobilised. During exploration only temporary accommodation will be established within the respective EPL areas.

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7 DESCRIPTION OF THE ENVIRONMENT

7.1 LOCATION

The project is located in the Otjozondjupa region approximately 70 km to the east of the copper mining town of Tsumeb and adjacent to Grootfontein, a regional centre with all major supplies. Figure 2 renders maps of the EPLs with corner coordinates.

The project is linked to Windhoek by 580 km of excellent tar road. The international Port of Walvis Bay connects with the projects through about 700km of rail and road.

A small portion on the eastern side of EPL 5992 covers the Eden Nature Reserve and thus far the only known farm land around the project’s area that potentially has recognised conservation protection status. Generally, the area belongs to commercial farms which resulted in extensive debilitation of the surficial environment and pressure on water sources. There is no knowledge of any environmental sensitivity in the area, other than the critical role that ground water and other water sources play in the immediate and greater ecosystem.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Figure 2: Maps of EPLs with corner coordinates.

7.2 GEOLOGICAL SETTING

The project covers an area which is mainly underlain by the Grootfontein Metamorphic Complex and its south easterly contacts with the country rocks. The area is completely covered with thick alluvium and calcrete. The Grootfontein Metamorphic Complex consists of three main units:

1. Well foliated gneisses, amphibolites and metasedimentary rocks, 2. Grootfontein gabbro, and 3. Grootfontein granite (Miller, 2008).

The Grootfontein Metamorphic Complex is a 62 km long magnetic anomaly extending ENE of Grootfontein. The magnetic anomaly is caused by mafic and ultramafic rocks variously referred to as the Grootfontein mafic body or Grootfontein magnetic body (Miller, 2008).

The Grootfontein gabbro has intruded the older granitic gneisses of the Grootfontein Metamorphic Complex. The gabbro contains many large, partially digested xenoliths of gneiss and is highly p.16

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019 contaminated by the gneiss. Six core boreholes (GMB 1-6) were drilled by Gold Fields to investigate the mineral potential of the anomaly. Minor sulphide mineralisation was intersected with uneconomic copper concentrations. Copper sulphide mineralisation occurs disseminated in local zones and in veinlets of up to 30 cm width in the core of borehole GMB 6 (Miller, 2008). To the north of the EPLs application outcrop Otavi Group carbonates that host the Zn-Pb-V deposit of Berg Aukas.

The (Grootfontein Mafic Body) GMB constitutes a huge mafic complex of 60 km x 6 km. The mafic to ultramafic rocks of the GMB have the potential to host magmatic Ni, Cu, V, PGE and chromite mineralisation as cumulates or late magmatic disseminations and stockworks.

Previous work by Ongopolo Mining proved that the main intrusive of the GMB are depleted in nickel and copper. The metals were likely fractionated as sulphides during the intrusive phase, gravitationally accumulated in the magma and intruded in the adjacent, pre-existing rocks. As in other mafic hosted Cu-Ni deposits such as Norilsk and Voisey’s Bay, sulphidisation by scavenging of sulphur from country rocks and tectono-magmatic concentration of the sulphide-rich melts are the key for the formation of this type of magmatic Cu-Ni-deposits. Only two shallow drill fences (total of 1,386 m) were drilled by Anglo American in 1988 leaving 55 km of GMB strike length untested.

In addition, hydrothermal re-mobilisation has caused small-scale but high grade Cu-Ni mineralisation mainly to the south of the GMB. Exploration is regarded as high-risk/high-reward Greenfields reconnaissance for which a combination of EM and drilling is applied.

7.3 CLIMATE

7.3.1 Rainfall and Temperature Grootfontein is situated in a sub-humid climatic region. Heavy rainfalls in Grootfontein are mostly common between December and March, peaking mostly in January, whilst May to September had little or no rainfall recorded. The average annual rainfall ranges between 550 to 600mm/a, with a variation in rainfall of 30 to 40% and an average annual evaporation rate of between 3000 and 3200mm/a. The average maximum temperatures range from 23˚C in July, with 32˚C in October. The average minimum temperatures range between 6˚C in July to 18˚C in January. (Windhoek

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Metrogeological services, 2010-2011). Please note that the average temperature data presented above, is for the past 5 years. The average data is presented in Table 3 below.

Table 3. Climatic data provided by national database Average annual rainfall (mm/a) 550-600

Variation in annual rainfall (%) 30-40

Average annual evaporation (mm/a) 3000-3200

Water deficit (mm/a) 1501-1700

Average annual temperatures (°C) 20-21

7.3.2 Topography and hydrology/drainage The landscape is classified as being in the Karstveld, which is dominated by limestone with little or no surface run-off, strong development of sinkholes, dolines and caves. The EPL6561 is partially located within the catchment of the Omatako River (Figure 3), an ephemeral river catchment flowing in a north easterly direction and EPL5992 is located north of the headwaters of the Daneib river catchment (Figure 4). Surface drainage appears to be poorly developed within EPL5992 where rivers are poorly developed. The satellite imagery (Figure 2) reveals the presence of parallel dunes running east west within the eastern part of EPL5992. These dunes have subsequently been covered with vegetation.

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Figure 3. Map of the river systems of the Otjozondjupa Region relative to the EPLs

Figure 4. Map showing registered boreholes of the Omatako River Catchment within EPL6561 and registered boreholes within EPL5992 p.19

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

7.4 BIOLOCAL ENVIRONMENT

No field work was carried out for this aspect of the study and the Atlas of Namibia provided the necessary source of the information. Error! Reference source not found. Table 4 and Table 5 Error! Reference source not found. below indicate the fauna and flora found in the biome in which the EPLs are situated. The site is located within the Savanna biome, with Karstveld type vegetation. The vegetation structure type is classified as woodland, with a high diversity of higher plants.

Coleen Mannheimer, well known Namibian botanist and registered interested and affected party, provided some additional insight (correspondence received by email) as follows: ‘The trees in this area have already been heavily impacted by mining activities in the past, with an estimate of over 4 million large Tambotis (Spirostachys africana) used for mine supports for Tsumeb and Abenab, resulting in the bush encroached areas seen there now. Besides Tamboti, there are other important and protected species, such as Marula (Sclerocarya birrea) and Bird Plum (Berchemia discolor), for example. Other protected and/or restricted range species also occur, including Ficus petersii, Olea europaea subsp. africana, Lannea discolor and Pachypodium lealii, to mention a few. Furthermore, the Karst is one of the botanically most diverse areas of Namibia and, should mining be contemplated, then a specialist botanical study would be called for.’ These aspects are important for consideration and they are referred to again in the assessment section of the EIA report.

Some bush clearing may be required during the 2nd and 3rd phase of exploration where access roads, drill pads and bulk sample sites are chosen. The clearing of any vegetation would not be on the scale which triggers a full EIA but permits to fell trees and clear bush for exploration will require a Forestry Permit (Rothauge, 2017). In addition to this vegetation clearing restrictions within 100m of rivers must be taken into account (Rothauge 2017) as outlined in the draft regulations of the Water Resource Management Act.

Table 4. General Flora Data (Atlas of Namibia) Biome Savanna

Vegetation type Karstveld

Vegetation structure type Woodland

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Diversity of higher plants Highest (Diversity rank = 1 [1 to 7 representing highest to lowest diversity])

Number of plant species More than 500

Percentage tree cover 11-25

Tree height (m) 2-5

Percentage shrub cover 51-75

Shrub height (m) 1-2

Percentage dwarf shrub cover 2-10

Dwarf shrub height (m) < 0.5

Percentage grass cover 26-50

Grass height (m) < 0.5

Dominant plant species 1 Colophospermum mopane

Dominant plant species 2 Terminalia prunioides

Dominant plant species 3 Commiphora species

Dominant plant species 4 Combretum apiculatum

Dominant plant species 5 Acacia reficiens

Dominant plant species 6 Dichrostachys cinerea

Table 5. General Fauna Data (Atlas of Namibia)

Mammal Diversity 76 - 90 Species

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Rodent Diversity 24 - 27 Species

Bird Diversity 171 - 200 Species

Reptile Diversity 71 - 80 Species

Snake Diversity 35 - 39 Species

Lizard Diversity 24 - 27 Species

Frog Diversity 12 - 15 Species

Termite Diversity 7 - 9 Genera

Scorpion Diversity 6 - 9 Species

7.5 SOCIO-ECONOMIC ENVIRONMENT

The land use is mainly commercial farming where each farm has variable personnel who are employed to look after livestock. Figure 5 renders a map of the farms within the EPLs. In some cases the owners of the property live on the farms with their families and the employees too may have family members staying on the farm with them. From time to time the farm owners may travel to Grootfontein for access to food, fuel and medical services. A small portion of EPL5992 appears to be within communal farm areas and there is also a nature reserve in the south eastern portion of EPL5992.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Figure 5. A map of the farms found within EPLs 6561 and 5992.

Today the town functions as the shipping point for timber products arriving from Kavango- inhabited areas farther to the northeast, while copper and lead mined west of Grootfontein are smelted at Tsumeb. Local industries produce meat, dairy products, sorghum, peanuts, sunflowers and leather goods. Grootfontein is the center for a large cattle farming community. The area receives considerably higher rainfall than parts of Namibia situated further west and south and contains much of the country’s best commercial farmland. Grootfontein is a well-developed town with an infrastructure that can cope with any development. All municipal services and well- maintained gravel and tarred roads are available.

The district of Grootfontein is known mainly as an agricultural district with emphasis on extensive cattle farming and to a smaller extend agronomy where the following crops are being cultivated; Maize, Peanuts, Sorghum, Cotton, Sunflower and various types of animal fodder. Maize is by far the major crop. Due to the general shortage of water, agronomy under irrigation is done mostly on a small scale and then also mostly regarding citrus and vegetables.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Grootfontein is mainly a cattle area with emphasis on breeding cattle and weaners that are being sold to speculators and ox-farmers in the central parts of Namibia and feedlots in Namibia and South Africa. Sheep and goats are being farmed on a much smaller scale and then mostly for own consumption and a small surplus to sell privately. Small stock can definitely be farmed on a larger scale in the Northern parts of Namibia. There are 568 commercial farms in the Grootfontein district.

Some farmers use kilns to produce charcoal from encroachment bush that is a problem on many farms. Another advantage to this is that the farmer recovers his natural grazing by removing the bush. Opportunities in this regard are plentiful, especially if more economically viable markets for charcoal can be found. Transporting goods from Grootfontein is made easier with rail and road links to the south and road links to the west and the north. A tar road is being constructed between Gobabis and Grootfontein, to provide improved access to the Trans Kalahari Highway.

Grootfontein is the gateway to the north-eastern areas and towns of Namibia. Travellers and tourist often stop over at Grootfontein for refreshments, supplies and to rest. Apart from its historic sites and lush green peaceful atmosphere the town also boasts with some world renowned tourist attractions. Namely, the Hoba Meteorite, the Das Alte Fort Museum, the Baobab Tree, the Gaub Cave and the world’s largest underground lake – Dragons Breath.

The available census data for Grootfontein in 2011 publication indicates a population of 23,793 people.

8 STAKEHOLDER CONSULTATION Consultation with the public forms an integral component of an EIA investigation and enables Interested and affected parties (IAPs) e.g. neighbouring landowners, local authorities, environmental groups, civic associations and communities, to comment on the potential environmental impacts associated with the proposed development and to identify additional issues, which they feel, should be addressed in the EIA.

This background information document (BID) (See Appendix B) provided IAPs with the opportunity to register and engage in the public participation process. Through registering they have the opportunity to:

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➢ Provide the EIA coordinator with additional information which should be taken into account in the assessment of impacts and during decision-making; ➢ Attend meetings and obtain information about the proposed project; ➢ Share any comments, issues or concerns related to the proposed exploration activities; ➢ Review and comment on the draft report and EMP and findings from the EIA process.

The public participation notices for the EIA were advertised over two consecutive weeks in ‘The Namibian’ Newspaper on the 14th and 21st September 2018. The notice was also placed in the Republikein on the 11th and 18th January 2019. Furthermore, three EIA notices were placed in Grootfontein at the Spar and Mini market near the CBD and on the Municipality notice board. Proofs of the notices and adverts are found in Appendix B. No public meetings were arranged. During the 2nd publication period comments from members and representatives of the local farmer’s associations and the regional agricultural unions were received. The draft EIA report and EMP will distributed amongst the relevant members during the public review period which will last 21 working days.

A few objections and concerns were received to date. The comments received and the responses made to the registered IAPs can be found in the Appendix B. The list of the registered IAPs is also included in Appendix B.

Here is a summary of the main points of concern:

➢ Security (poaching and theft) ➢ Plant diversity and bush clearing (intrusive exploration) ➢ Groundwater integrity (drilling that punctures aquifers) ➢ Pollution (poor waste management) ➢ Negative economic impacts (disturbance to farming activities)

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9 IMPACT ASSESSMENT The purpose of this section is to assess and identify the most pertinent environmental impacts by describing certain quantifiable aspects of these impacts and to provide possible mitigation measures to minimise the magnitude of the impacts that would be expected from the various activities that constitute the proposed minerals exploration in EPLs 6561 & 5992.

The following potential impacts on the environment during exploration activities have been identified:

➢ Dust ➢ Noise ➢ Health & Safety ➢ Visual ➢ Land Use ➢ Waste ➢ Ecological ➢ Groundwater and surface water ➢ Heritage ➢ Socio-Economic

These identified potential impacts have been evaluated. Mitigation measures are proposed for each aspect of the different potential impacts identified. Comments and concerns raised during the public consultation process have been considered and included.

Table 6: Assessment methodology for evaluating potential impacts Risk Event Description of the risk that may lead to an impact.

Status (+ or -) Positive - environment overall will benefit from the impact

Negative - environment overall will be adversely affected by the impact

Neutral - environment overall will not be affected

Extent Site specific

Local (limited to within 15 km of the area) p.26

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Regional (limited to ~100 km radius)

National (limited to within the borders of Namibia)

International (extending beyond Namibia’s borders)

Duration Very Short (days, <3 days)

Short (days, 3 days – 1 year)

Medium (months, 1 - 5 year)

Long (years, 5 - 20 years)

Permanent (>20 years)

Intensity No lasting effect (No environmental functions and processes are affected)

Minor effects (The environment functions, but in a modified manner)

Moderate effects (Environmental functions and processes are altered to such extent that they temporarily cease)

Serious effects (where environmental functions and processes are altered such that they permanently cease and/or exceed legal standards/requirements)

Probability Refers to the probability that a specific impact will happen following a risk event.

Improbable (low likelihood)

Probable (distinct possibility)

Highly probable (most likely)

Definite (impact will occur regardless of prevention measures)

Prevention Measures to reduce the probability of an impact occurring.

Significance None (A concern or potential impact that, upon evaluation, is found to have (no no significant impact at all.) mitigation) p.27

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Low (Any magnitude, impacts will be localised and temporary. Accordingly the impact is not expected to require amendment to the project design.)

Medium (Impacts of moderate magnitude locally to regionally in the short term. Accordingly the impact is expected to require modification of the project design or alternative mitigation.)

High (Impacts of high magnitude locally and in the long term and/or regionally and beyond. Accordingly the impact could have a ‘no go’ implication for the project unless mitigation or re-design is practically achievable)

Mitigation Description of possible mitigation measures

Significance None (A concern or potential impact that, upon evaluation, is found to have (with no significant impact at all.)

mitigation) Low (Any magnitude, impacts will be localised and temporary. Accordingly the impact is not expected to require amendment to the project design.)

Medium (Impacts of moderate magnitude locally to regionally in the short term. Accordingly the impact is expected to require modification of the project design or alternative mitigation.)

High (Impacts of high magnitude locally and in the long term and/or regionally and beyond. Accordingly the impact could have a ‘no go’ implication for the project unless mitigation or re-design is practically achievable.)

Confidence The degree of confidence in the predictions, based on the availability of Level information and specialist knowledge.

Low (based on the availability of specialist knowledge and other information)

Medium (based on the availability of specialist knowledge and other information)

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High (based on the availability of specialist knowledge and other information)

Table 7: Dust Impacts Risk Event Disturbances to soil and rock resulting in excessive dust in the atmosphere

Nature of Impact Prospecting work is likely to create minimal dust. Drilling using reverse circulation or impact drilling is very likely to create dust due to the nature of the technique. The generated dust impacts on personnel working in close proximity to the drilling rig. Impacts on the photo-transpirational efficiency of the surrounding plants can be hampered. The dusty plants are less palatable to grazing or browsing animals.

Status Negative

Extent Site Specific and possibly local depending on mobility of particles and prevailing weather conditions. Only on very windy days would visually impacting dust travel further than 15km. The source does not move unlike with trucks on dirt roads so the impact is along a single vector.

Duration Short term if the drilling continued for more than three days and on a 24 hour basis. This is unlikely as the farmers will most likely only allow activities from dawn to dusk. There are also regular stoppages for maintenance and or shift changes.

The plants covered with dust whose functioning will be affected are those directly downwind and within the first 150m. Thereafter the conditions approach average ambient air quality conditions for the Namibian context.

Intensity Moderate effect in a radius of 150m. No known hazardous status of the substrate is expected p.29

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Probability Probable

Prevention Dust creation cannot be prevented completely.

Significance (no Medium to Low. Natural weather conditions can create very dusty atmospheric mitigation) conditions. The small scale and site specific exploration activities contribute very little to the widespread ambient conditions that often prevail. Cars travelling on the access roads can create dust plumes trailing behind them. Exploration activities entail driving or walking to particular sites to collect samples. The impact is not persistent for the long term. The site specific (<150m radius) perennial and every green grasses, shrubs and trees would usually experience relief from the dust laden covering on an annual basis as rainy periods wash off the dust. New growth would not be covered. The deciduous and annual plants would grow fresh and dust free foliage on an annual basis provided there is sufficient rainfall.

Mitigation Dust suppression techniques should be employed if the specific exploration activity is likely to create dusty atmospheric conditions in excess of the periodic extremes. The first two that are listed are easy to apply but the 3rd measure may not always be possible due to project deadlines. Measure number 4 may not be practical due to shortage of water in the area or on that particular farm.

1. Avoid activities that create excessive dust on extremely windy days. 2. Personnel are required to wear personal protection equipment if excessive dust is created for prolonged working periods. 3. Time the reverse circulation drilling to coincide with rainy times and or the last winter months before the rainy season. Avoid the 3 months immediately after the last rains. 4. If this cannot be avoided, manual spraying of the foliage within the first 10m around the drill pad will assist the plant productivity greatly after demobilising. This may not be a practical solution as this is an arid country where water resources must be used sparingly. p.30

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Significance Low (with mitigation)

Confidence High Level

Table 8: Noise Impacts Risk Event Disturbance of sense of place and the effect on tranquil ambient noise levels

Nature of Potential noise sources during the exploration within EPLs 6561 & 5992 could Impact originate from vehicles, blasting (when taking bulk samples), hammers, powered hand tools, excavators and drill rigs. The nuisance factor of these noise sources will depend on the proximity of the exploration activities to the national road, homesteads and sensitive animal habitats. Other vehicles travelling on the road contribute to the ambient noise levels. The exploration activities potentially contribute to the cumulative effects of traffic noise on the areas immediately (first kilometre) from the national and district roads. However, the further away from the roads that exploration drilling occurs the greater its role in contributing to the ambient noise levels. The noise may also impact on the temporary or permanent habits of the fauna in that particular location where drilling takes place.

Status (+ or -) Negative

Extent Site specific and Localised (up to 1km depending on the weather conditions)

Duration Short

Intensity Minor Effects (i.e. cumulative when near the national road) & Moderate Effects in quieter locations of farms, lodges and hunting establishments.

Probability Definite

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Prevention Noise creation cannot be prevented completely and will occur and should be mitigated as best as possible.

Significance (no Medium mitigation)

Mitigation For rural districts the day time ambient noise level requirement outlined in SANS 10103 (2008) between 6am and 10pm is 45dBA. This is in line with the guidelines published by the World Health Organisation (WHO).

There are industry standards to which the noise sources (i.e. machinery) must comply. Regular maintenance of machinery should maintain the acceptable noise levels for operators working with the machines. The activities are to take place during daylight hours only. Periods of silence during the day may be necessary.

Levels of 90dBA will be experienced alongside the drilling rigs, exposure to which over an 8 hour shift, can lead to hearing impairments. The guidelines and PPE mitigations are discussed under the health and safety section.

Arrangements to drill over the weekends or at other times need to made with landowners so that there is no conflict with tourist, hunting or domestic activities.

It is recommended that any complaints regarding noise be recorded in the bi- annual reports.

Significance Low (with mitigation)

Confidence High Level

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Table 9: Health & Safety Impacts Risk Event The effects of excessive noise and vibration on the health and safety of personnel.

Nature of Impact Noise:

Long term exposure to high levels of noise can cause permanent hearing loss. Neither surgery nor a hearing aid can help correct this type of hearing loss.

Short term exposure to loud noise can also cause a temporary change in hearing (your ears may feel stuffed-up) or ringing in your ears (tinnitus). These short- term problems may go away within a few minutes or hours after leaving the noisy area.

Vibration:

Different vibration types are defined as:

Hand-Arm Vibration is defined as mechanical vibration that, when transmitted to the human hand-arm system, entails risks to the health and safety of workers, vascular, bone or joint, neurological or muscular disorders.

Whole-Body Vibration is defined as the mechanical vibration that, when transmitted to the whole body, entails risks to the health and safety of workers lower back morbidity and trauma to the spine.

Status Negative

Extent Site Specific

Duration Short but continuous exposure to high noise levels may lead to permanent hearing loss

Intensity Moderate to Serious Effects

Probability Probable p.33

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Prevention Engineering controls that reduce sound exposure levels are available and technologically feasible for most noise sources. Engineering controls involve modifying or replacing equipment, or making related physical changes at the noise source or along the transmission path to reduce the noise level at the worker's ear. The same goes for vibration.

Choose low-noise tools and machinery.

Maintain and lubricate machinery and equipment (e.g. oil bearings).

Place a barrier between the noise source and employee (e.g., sound walls or curtains).

Enclose or isolate the noise source.

Significance (no High mitigation)

Mitigation Noise:

OSHA sets legal limits on noise exposure in the workplace. These limits are based on a worker's time weighted average over an 8 hour day. With noise, OSHA's permissible exposure limit (PEL) is 90dBA for all workers for an 8 hour day. The OSHA standard uses a 5dBA exchange rate. This means that when the noise level is increased by 5dBA, the amount of time a person can be exposed to a certain noise level to receive the same dose is cut in half.

The WHO guideline on maximum noise levels to prevent hearing impairment set noise level limits at an average of 70 dBA over a 24 hour period with maximum noise levels not exceeding 110 dBA during the period. These latter limits would apply if the day time shift is prolonged beyond the 8 hour day.

Mitigation include:

Operating noisy machines during shifts when fewer people are exposed.

Limiting the amount of time a person spends at a noise source. p.34

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Providing quiet areas where workers can gain relief from noise sources

Where possible, restricting worker presence to a suitable distance away from noisy equipment. (Controlling noise exposure through distance is often an effective, yet simple and inexpensive administrative control.)

In open space, for every doubling of the distance between the source of noise and the worker, the noise is decreased by 6dBA.

Hearing protection devices, such as earmuffs and plugs, are considered an acceptable, but less desirable option to control exposures to noise.

Vibration:

Industry vibration regulations, set daily exposure limit values and action values for both hand-arm and whole body vibration for eight hour shifts. Personnel can work shorter shifts where conditions exist causing excessive vibration.

Significance Low (with mitigation)

Confidence High Level

Table 10: Health & Safety Impacts Risk Event Injury risks due to normal working conditions

Nature of The potential impacts on human health and safety resulting from exploration Impact activities could include occupational accidents and injuries, vehicle accidents, exposure to weather extremes, trips and fall on uneven terrain, adverse health effects from dust generation and emissions, and contact with hazardous materials. The potential for these impacts to occur would be low because of the limited range of activities and number of workers required during exploration. Kunene Resources follows a set of industry-specific safety and health policies on the work place.

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Operational procedures during tanker ship offloading pose numerous risks to operational personnel. These risks are assessed in terms of the predicted impact if realised. Typical examples are:-

➢ Carcinogenic effects of some petroleum products ➢ Breathing in excessive fumes ➢ Product contact with eyes and skin ➢ Slipping on wet surfaces ➢ Working at heights ➢ Muscular injury from incorrect lifting techniques

Status (+ or -) Negative

Extent Site specific

Duration Permanent

Intensity Minor to Serious Effects

Probability Highly probable

Prevention The operations of the exploration can cause serious health and safety risks to workers on site. Occupational exposures are normally related to dermal contact with fuels and inhalation of fuel vapours during handling of such products. For this reason adequate measures must be brought in place to ensure safety of staff on site.

An integrated health and safety management system acts as a monitoring tool and mitigating tool. The monitoring tools are elaborated upon in the EMP.

Typical mitigating measures within the health and safety management systems are:-

➢ Operational and procedural manuals ➢ Health and safety training ➢ Housekeeping rules p.36

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

➢ Colour coding areas, pipes, equipment and substances ➢ Signage for personal protective equipment (e.g. protective clothing like safety boots and hard hats) ➢ Safe working procedures and permits to work ➢ Emergency response plans ➢ Material Safety Data Sheets (MSDS) ➢ First aid treatment and training ➢ Medical procedures and emergency services ➢ Daily safety reminders and/or drills ➢ Regulations for handling fuel

The MSDS gives health related medical responses for personnel assisting staff who are exposed to the fuels.

Significance (no Medium mitigation)

Mitigation Procedures for dealing with injuries or accidents must be in place and all contact details for emergency personnel available. The company safety manual is used as developed by the guidelines and statutory requirements under the Labour Act.

Significance Low (with mitigation)

Confidence High Level

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Table 11: Visual Impacts Risk Event Changes to the aesthetic appeal of the area due to presence of people, vehicles and machinery. Visible changes to habitats due to human activities.

Nature of Impact The experience of enjoying the vista unobstructed by human activities is considered highly desirable. Impact to visual resources would be considered adverse if the landscape were substantially degraded or modified. Exploration activities will only have temporary and minor visual effects, resulting from the presence of workers, vehicles and other equipment. Exploration activities would possibly contribute to this to some degree through drill pad and road construction. Prospecting phase activities would have negligible effect on this aspect.

Status Negative

Extent Localised

Duration Short (presence of vehicles, personnel and machinery) Long (un-rehabilitated prospecting holes or pits)

Intensity Moderate Effects

Probability Definite

Prevention For exploration to take place, personnel, vehicles and machinery will be deployed into the area for the short term periodically. Exploration is not possible without disturbing small sections of the various habitats.

Significance (no High mitigation)

Mitigation Best practice methodologies for exploration will be employed. They may include the following: (Some of these also apply to mitigations for ecological impacts as well) p.38

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

As far as is possible existing roads and tracks are used to access target sites for sampling and drilling.

Walking to target sites being careful not to disturb plants and faunal habitats.

Personnel to be trained regarding the observable signs of faunal and floral biodiversity and the avoidance of habitat disturbance.

Minimise the footprint of personnel, vehicles and machinery. As far as is possible no vegetation is to be removed. Where new roads are constructed the methods should be low intensive and possibly use manpower and not machines. New roads if planned well could assist with the future objectives of the farm, lodge or hunting establishment.

Rehabilitate habitats through the removal of obvious signs of human presence.

Remove all waste daily and dispose of it in the appropriate manner.

Removal of machinery from the exploration sites if periods of inactivity are protracted.

Drilling and subsequent phases should take place during the least busy tourism period as a measure to circumvent the negative publicity

Significance Medium (with mitigation)

Confidence Medium. Often, the sites that are disturbed and rehabilitated at least from an Level aesthetic perspective will in time be recolonized by both plants and animals. The aim is to minimise the footprint so as to achieve the least impact due to anthropogenic influences.

There is no way to predict that changing the drilling period to less busy tourist times, that tourists, even if fewer in number, will not publish negative publicity.

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Table 12: Land Use Impact

Risk Event Users and owners of the land could potentially experience restrictions to their constitutionally entitled liberties.

Nature of Impact EPLs 6561 & 5992 lies within state owned land and privately owned land consisting of farms which are privately owned.

Sometimes mineral exploration within the farming area is believed to be in opposition to the commercial, societal and biodiversity objectives of farming and natural environments.

A Potential win-win scenario could be sustainable for the farms and mining providing for future generations. The value that mineral exploration and later still possible mining could bring to the district needs to be discussed between the company and the landowners.

Status Negative

Extent Regional

Duration Short (non-tourism/nature reserve farms within the EPL) Long (tourism-based farms within the EPL)

Intensity Minor Effects (non-tourism/nature reserve-based farms) Serious Effects (for tourism based farms)

Probability Definite

Prevention Exploration implies the presence of an exploration team. The exploration activities would take place within sensitive nature reserve or tourist-based areas. Thus, it would not be possible to avoid the conflict of land use completely.

Significance (no High. The mineral exploration phase activities may impinge on the rights of the mitigation) farmers or lodge owners.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Mitigation Law requires that permission be provided through the issuing of an environmental clearance certificate for this listed activity. The EIA process facilitates a transparent process by which concerns can be raised. Common decency will direct Kunene Resources Namibia (Pty) Ltd to inform all stakeholders of the starting date for the activities once a positive record of decision has been issued by the government. The proponent (company) is subservient to the conditions laid down by the clearance certificate and the law that upholds it. The implementation of the exploration programme will be in accordance with the approved Environmental Management Plan (EMP). The draft EMP can be found in Appendix C.

Significance Medium to Low (the EMP must be strictly implemented and all efforts are (with mitigation) made to reduce the impacts on the biodiversity, commercial and social aspects of the farmers)

Confidence Medium

Level The Ministry of Environment & Tourism may need to clarify and justify any grounds for which the exploration company will not be able to undertake exploration activities within the EPL areas.

Table 13: Waste Impact Risk Event Waste Production

Nature of Impact The ability of a substance to be waste which must be cleaned up and or removed. Most of the waste produced will result from maintenance work performed on the machinery. Spilled product is also regarded as waste. Packaging from food products is included.

Status (+ or -) Negative

Extent Site specific

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Duration Short

Intensity Minor Effects

Probability Definite

Prevention Spillage prevention is possible through employing trained personnel and implementing general maintenance and upkeep of equipment.

Significance (no Medium mitigation)

Mitigation Spills and leaks must be reported and cleaned up without delay.

Workers will be made aware of their isolated living conditions, any goods for private use or for the business need to be brought a long way to the site and any waste generated also must be taken a long distance to the next dumping site. Therefore, avoidance of waste generation and recycling of all applicable materials are to be actioned daily.

The domestic waste, which is separated from all paper and organic materials, is taken to the nearest official dump site which is at Grootfontein. Oil from the servicing of the vehicles and machines is collected in drums and gets taken together with all other industrial waste which is generated on site to the hazardous waste site in Grootfontein or it is converted to energy by Oiltech who will remove the waste from site. Either way certificate of disposal need to keep on file.

Sewerage waste is to be removed from site. The department of water affairs have provided guidelines for the establishment of septic tanks.

Significance Low (with mitigation)

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Confidence High Level

Table 14: Ecological Impacts Risk Event Exploration activities may affect biodiversity of fauna and flora directly or through habitat alteration.

Nature of Impact Through the exploration for mineral resources there is potential for impacting the diversity of species within the various habitats by reducing population numbers of a particular species within the EPLs. Pressures on the population numbers can potentially pressurise the populations within an area to an extent that causes the species to no longer exist within that area. Should a species be endemic to that same area then the risk of extinction is high. Altering the habitat can potentially result in the same outcome.

No specialist fauna and flora studies were commissioned by the company for the EPLs EIA project. Specialist studies were deemed unnecessary for this environmental impact assessment due to low intensity and extent of the exploration activities. Exploration may occur throughout the whole EPLs but the total activity footprint as a percentage of the total areas of each habitat is estimated to be very low.

For the most part the endemic species found within the area under assessment are also found elsewhere in the country. However, there may be exceptions and a precautionary approach must be taken. The species that are classified as Near Threatened, Vulnerable and Critically Endangered are those that although found elsewhere in Namibia should be taken cognisance of. Their specific habitat and feeding, breeding, nesting and migratory habits must not be impacted upon in the least degree.

The Karst Vegetation has a high biodiversity and destruction of vegetation could impact this. Regulations and Policy needs to guide the operational activities when planning roads and drill pads. p.43

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Status Negative

Extent Localised

Duration Short to Medium term

Intensity Serious effect if an individual/s is/are disturbed or destroyed/killed

Probability Probable

Prevention Though the habitats will remain relatively undisturbed due to the very low percentage footprint of activities planned, without prior knowledge of the whereabouts of the vulnerable, threatened and critically endangered species and their preferred habitat, it may not be possible to prevent an impact, regardless of how small it might be.

Significance (no High Though the intensity of the exploration is very low, as already explained, mitigation) the significance of the impact is considered high based on the sensitivity of the species that occur here.

Mitigation Those areas targeted for exploration will be accessed along existing roads and tracks as far as possible. Many of the sites will initially be visited on foot. The latter two exploration phases may need to produce new tracks to access targeted sites. Dry water courses provide the next option for gaining access to remote sites for vehicles where no tracks formerly exist. These habitats are occasionally disturbed by flash floods and must re-establish communities of fauna and flora thereafter.

Exploration teams need to be trained and provided orientation on how to best access sites for exploration with least impact on the observable and hidden signs of fauna and flora and their habitats.

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Rehabilitation of sites that have been explored must restore the sites, as far as is possible to their prior state to mitigate the visual impact and to allow for the best possible re-colonisation of the site, by plants and animals.

Tree surveys prior to clearing roads and drill pads are mandatory and forestry permits are required by law. NO PROTECTED TREES SHOULD BE FELLED.

Significance Low (with mitigation)

Confidence Medium. Knowledge of the whereabouts of some species and their habitats Level may not be readily available and this makes it difficult to predict whether the low significance can be practically achieved. Surveys of the areas to be cleared will be required by the Forestry Directorate and bush clearing permits are to be issued by the same.

Table 15. Groundwater and Surface Water Impacts Risk Event Exploration activities may affect the availability of water and the quality thereof

Nature of Impact Through the exploration for mineral resources there is potential for impacting:

➢ Water availability for deep rooted trees in riverbeds (groundwater) ➢ Water availability and quality for people (groundwater) ➢ Water availability for animals’ habitat and for drinking (surface water)

Status Negative

Extent Localised

Duration Short to Long term

Intensity Serious effect if people’s lives are at stake or habitat is permanently lost. A permanent change to the availability of water would be devastating for the sustainable farming that occurs here. p.45

EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Probability Probable if boreholes puncture the Karst Formation, water abstraction is not controlled or water pollution is not prevented

Prevention It is possible to prevent over abstraction and pollution of water resources. It is also possible to prevent the puncturing of the Karst Formation through careful planning, knowledge and liaison with the Department of Water Affairs.

Significance (no High; Should the prevention measures not be in place then the significance of mitigation) the impact will be high. The population carrying capacity is already low due to limited water resources.

Mitigation No surface water bodies (eg. Farm dams) should be used for the exploration activities

Namwater could supply the exploration activities via the Grootfontein town. These sources should not jeopardise the farming community’s needs.

Farm boreholes may also be used but the sustainability of each farm borehole may differ. Again, only sustainable use of these sources should be made.

The siting and drilling of boreholes for exploration must be carried out very carefully and not in any way jeopardise the sustainable use of water from the Karst Formation.

Boreholes drilled in the field should not be contaminated in case they are linked to aquifers use of by nearby farmers. Should the company find good groundwater during the exploration activity, the borehole may be used as a water source provided the permission of the farmer is given and the necessary abstraction permit is attained from the department of water affairs. Again, only sustainable yields may be abstracted.

Farmers may choose to maintain the new water boreholes after the exploration ceases.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Camps and the setting up of ablution facilities must be done so that risks to groundwater quality are minimised.

Significance Low (with mitigation)

Confidence High, only if the mitigations are carried out strictly. Guarantees must be given Level by the exploration company that they do not in any way damage the susceptible water resource.

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EIA for Exploration Activities EPL6561 & 5992 held by Kunene Resources (Pty) Ltd April 2019

Table 16. Heritage Risk Event Exploration activities may impact archaeological or historical sites.

Nature of Impact Any archaeological or historic sites of significant importance within the EPLs that are damaged or destroyed, would constitute an impact on the heritage of Namibia.

The procedure of chance finds is to be followed where no known sites of importance are recorded for the EPLs area.

Status Negative

Extent Site specific

Duration Long term

Intensity Minor effect (no sites of importance are known eg. rock paintings)

Probability Unlikely

Prevention Impacts of this nature are avoided if the site locations are known and are then avoided.

Significance (no Medium mitigation)

Mitigation The chance find of any potential heritage site should be communicated to the police and the National Heritage Council of Namibia. If exploration activities occur at the location where a chance find could be made, then the activities should cease until the necessary authorities have visited the site and provided the go ahead to proceed with activities.

Significance Low (with mitigation)

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Confidence High; Knowledge of the whereabouts of heritage sites is not known. Level

Table 17: Socio-Economic Impact Risk Event Positive aspect of sustaining employment in the sector.

Nature of Impact The project to be carried out at EPLs 6561 &5992 site will employ a limited number of people involved with exploration on an intermittent basis. From 10 to 30 staff would be on site during the drilling phase depending on the intensity of the drilling programme. The downstream employment like transport and other services will most likely be out sourced. The project’s ability to earn foreign exchange through export makes it attractive to the Namibian fiscal services and is of national interest.

On the negative side, the social and economic basis of the farms may be adversely affected by the presence and activities of the exploration team and equipment. Potential lowering of the security currently enjoyed could be potentially interrupted.

Status Positive & Negative

Extent Regional (radius of up to 100 km)

Duration Short. Up to one year of drilling spread over a broad area.

Intensity Moderate effect (for the positive) Moderate effect (for the negative)

Probability Probable (both the negative and positive aspects)

Prevention If the environmental clearance certificate is not forthcoming, then the positive impact is halted.

Significance (no Low (positive) The project will employ very few personnel, so it is not mitigation) significant in the greater scheme of things. p.49

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Medium (negative) The security of the farms could potentially be lowered through negligence and or intentional misuse of the privileged access to the farms.

Mitigation Where possible, local persons (i.e. from the adjacent towns and farms) should be employed. This depends on the level of skills the local persons have. Sustainable employment will result should the project be allowed to go ahead.

The drilling programme could take place during less busy tourism times and if necessary increase the number of drill rigs during that time so as to shorten the period of activity.

Company supervisory staff must manage the access to and from the farms very strictly ensuring the staff stay within predetermined areas and ensuring all inter leading gates etc are closed and or locked as per the request of the farm owners.

Significance Low (positive)

(with mitigation) Low (negative)

Confidence High Level

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10 ENVIRONMENTAL MANAGEMENT PLAN The management of Kunene Resources is conscious of the company’s special operating conditions Therefore management will emphasize to all staff to be aware of the DOs and DON’Ts in this operational and living situation. The Draft EMP (Appendix C) provides an overview of the mitigation and monitoring measures for the planned exploration.

Limited impact is foreseen from the envisaged exploration programme. All phases and exploration measures will be communicated and agreed upon with the Department of Environmental Affairs and any other regulatory authority where permitting is required. All pits and trenches as well as borehole sites must be adequately rehabilitated.

All personnel involved in the exploration activities must undergo an environmental awareness training prior to prospecting on the ground together with tuition on safety and health issues.

Once approved, the EMP becomes the legally binding document to which the company can be held culpable in the event of non-compliance. Reference to the EIA report is still necessary to ensure the motivation for particular mitigations are understood by all personnel involved in the exploration programmes.

11 REPORTING AND MONITORING Compliance monitoring of the environment in accordance with the EMP must take place throughout the period of the operations. The company is committed to ensuring that all the proposed mitigation measures are implemented. Bi-annual monitoring and reporting will provide MET with the necessary feedback. Any problems or faults will be brought to the attention of the management team of Kunene Resources in order to discuss ways to improve the operational systems and controls.

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12 CONCLUSION In conclusion, this project in the EPLs 6561 & 5992 will explore base and rare metals, industrial minerals, dimension stone, precious metal group of minerals. Through exploring for these commodities, contributions to the Namibia’s economy will be made and continued employment to the existing staff is made possible.

For all aspects of operations and prospecting work strict adherence to the company’s Environment, Health and Safety policies must be ensured. Environmental training of the work force as well as monitoring of all aspects pertaining to Environment, Health and Safety must be carried out in accordance with the approved EMP.

The exploration within the EPL the company will follow a phased approach which will be in line with the relevant Namibian legislation and regulations. The exploration program will be conducted in line with the EMP thus implementing the necessary mitigation measures, monitoring and stipulated rehabilitation. It is of utmost importance that good relations are upheld with the farming community and other affected parties.

13 REFERENCES Mendelsohn, J., Jarvis, A., Roberts, C., & Robertson, T. (2003). Atlas of Namibia. A Portrait of the Land and its People. Cape Town: David Philip Publishers; New Africa Books (Pty) Ltd.

Rothauge, A., 2017. Bush Control Manual. AgriConsult Namibia. Ed. Ina Neuberger Wilkie. John Meinert Printing ISBN 978 99945 85 83 0

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APPENDIX A: PROOFS OF ECC APPLICATION REGISTRATIONS & EPL LICENCES

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APPENDIX B: PUBLIC PARTICIPATION DOCUMENTS

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Stakeholders / Interested & Affected Parties:

Authority Contact person

The Ministry of Agriculture, Water and Forestry Chief Forester - Natanael Amadhila (Otjiwarongo)

The Ministry of Mines and Energy Mining Commissioner – Mr. Shivolo

The Ministry of Environment and Tourism Environmental Commissioner Mr Theofilus Nghitila

Otjozondjupa Regional Council Chief Regional Council - Mr. B.E.O Kasete (Acting)

Ministry of Land Reform Deputy Director - Mr. Elifas Gotlieb

Municipality of Grootfontein

!Khung Traditional Authority

Jul’hoan Traditional Authority

NamWater

Cenored

Namibian Road Authority

Namibia Agricultural Union in the Grootfontein- Christine Stoman ( Secretary: Otavi Farmers’ Association) Tsumeb-Otavi region (Post office for 3 farmers’ associations found in the 2 EPL areas)

Farm Name / IAP Contact person

1. Strydfontein Schloder F.J

3. Ackerbau Kranzfontein Farming CC

32. Karlshof Smit C.H

34. Wasmer (sold to) Wilhem Gagiano

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36. Bohme (sold to) Marie Kriel

194. Brunkathen (1&2) Schneider C

Unknown status Reimo Schneider

195. Wilhemlsruf Halberstadt W

196. Kikuyu Halberstadt W

197. Waldheim Halberstadt H.E

198. Blocksaue Halberstadt H.E

212. Halberstadts Farm Von Wrede W

213. Bubus Boshof M.C

214. Philadelphia Uzepa E.H

215. Olienwenhof Taljaard H.V

216. Okanakasewa Oosthuizen F.J

216B. Omkrap CC

227. Oogies Heinshof Farming CC

230. Oond Sievers A.F

231. Namkali Mynhardt M

233. Omsons Wes Stroh C

242. Breedtskroon Enslin W.J

243. Omloop Kronsbein H

244. Neufeld GRN

246. Verweg Oosthuizen J.F

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262. Choiganab Oosthuizen J.F

263. Nuisib Water Hole Investments CC

371. Okanemie Tjetz H

372. Pitsburg Mutschler P

374. Gressenhof GRN/Halberstadt F.E

376. Tiefenwasser Halberstadt F.E

593. Berg Aukas Tsumeb Corp.(LTD)

597. Herrenhausen Kronsbein H/ Gunzel Farmerei CC

600. Highlands Lous Stein, Jakkie Stein

618. Achernar Bamberger F

619. Alamak Bamberger F

628. Beteiguse Bamberger F

629. Canopus Bamberger F

731. Nutsas Munchen H

732. Kalkfontein Wilfinger S

925. Langverweg Kazohwa J

925B. Nuwerus Coetzer H

944. Mooilaagte Breedt P.G

945. Rankroos Breedt J.G

946. Swaarwater Kazohwa C

947. Blystroom Kok P.V

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955. Dorsland Stroh C.V

987. Voorbegin (2&3) Oosthuizen M

987B. Eland Oosthuizen M

1066. Blydskap Otto R

1142. Mimosa Schreuder P.J

1144. Heidkrug Menge G.L

1152. Paarl Van Zyl J

1153. Lichtenau ( Northfolk)

1264. Eden Nature Reserve Jooste J.C

1274. Lahn Human J.C

Unknown status Düvel, Sylvia & Udo

AKWA Projects Pieter van Staden

Botanist Coleen Mannheimer

NM Consulting cc Nico Oberholzer

UNAM Student Swanu Muhenje

Ossa 1397 Wim Lubbe

Schaffeld 199 Sieglinde Zensi

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Comments Received from Interested & Affected Parties (IAPs) and Responses Given

Comments / Communication Received / Responses Sent (where applicable) Registered IAPs

Wido von Wrede (Farm Halberstadts 2046): Philip Hooks (Environmental Consultant): 1. What are the Phase 1 results (Environment 1. As I understand the question, the & Stakeholders)? comments of interested and affected 2. Why were the farmers not officially parties (IAPs) will be included in the contacted and this discussed? Scoping Report with Assessment. The 3. What is the detailed prospecting plans? assessment of any impacts will be included How, when, where, team size etc.? in the same report. The registered IAPs 4. What type of prospecting will be used? will receive a softcopy of the report and be Where exactly will the prospecting be given time to review (21 working days) the done? report and provide further input by the 5. How long is the prospecting right valid? close of that public review period. 6. What is the detailed timeline of 2. Firstly, prospecting licences are issued by prospecting? the Ministry of Mines & Energy and 7. What is the possible mining timeline? granted subject to the receipt of 8. Who does the environmental studies and environmental clearance from the Ministry by when? of Environment & Tourism. The usual first 9. If mining does happen, when and how and line of communication regarding the intent who will consult and handle queries? to prospecting in Namibia is via the public 10. When and how is the water use licence participation process of the Environmental applied for? Impact Assessment (EIA). A list of the farms was drawn up and the technician assigned to contacting the farms endeavoured to find the current owners contact details via the telephone directory and Grootfontein Municipality and Ministry of Agriculture. Subsequently, via the publication of the notice in the national press, to conduct an EIA, the Background Information Document (BID) was disseminated via the local Farmer’s association. These efforts form the initial official means to contact landowners. 3. The details of the prospecting will be outlined in the EIA report. p.93

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4. The methods of prospecting will be explained in the EIA report. 5. The initial prospecting right is valid for 3 years. The licence was granted on 29th November 2017. 6. The exact timeline would be communicated by the licence holder once the environmental clearance has been issued. 7. This cannot be answered at this stage. 8. I am conducting the EIA study. 9. Should the results of exploration deem it viable to mine any particular mineral another EIA would be commissioned and the consultants commissioned to undertake the study would initiate another round of public participation. The licence holders would also be involved in intense engagement with specific landowners to discuss the details of any potential mining activities. 10. As one of the outcomes of this EIA, the requirements to abstract water from groundwater will be stipulated. A licence needs to issued by the relevant authorities.

Reimo & Siegfried Schneider: Philip Hooks: as an effected party I strongly object to the Thank you for your correspondence. Please find exploration program of the EPLs 6561 & attached the background information document 5992. Please provide adequate information on the (BID) for the project. The period to receive initial planned activities. I expect also that you will hold comments will end on the 12th February 2019. The an official information day and that you will inform first publication of the project notice was last year all effected parties adequately ahead of in October and then a follow up notice was made time. Please see this as my official registration in January 2019.

There will be no public meeting for the EIA project. For mining projects it is deemed best

practice to hold public meetings but the relatively less intrusive nature of exploration is such that notification in the national press and site notices, as required by law, are deemed sufficient. Attempts were made to contact the owners and managers of the farms so as to directly inform them of the project. The word is getting around and I am confident that all Interested and Affected Parties p.94

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(IAPs) will have been notified of the project. Upon receipt of the BID please complete the form and return to me. Please provide me with all your concerns and comments so as to clarify and motivate your objections.

Once the EIA report and Draft EMP are complete a second round of public review will commence whereby you have an opportunity to review the EIA documents that would be submitted to MET & MME.

Reimo & Siegfried Schneider: Philip Hooks: Concerns are: Thank you so much for your input. All your points are appreciated and you raise concerns that are 1. Farming is our soul livelihood. Any form common to many of the landowners and in my of mining will restrain us in earning an experience on other projects where the legacy of income. exploration and mining companies leaves much to 2. Poaching by the exploration team be desired. Thus, I can appreciate the reluctance to members. Relevant for game as well as allow exploration to occur on your farm. birds. 3. Slaughtering/theft of cattle. Members of the exploration team get to know the farm With regards to your highlighting the unfounded and can slaughter cattle immediately or statement referring to the degradation of the area, I return long after the exploration team has thank you for your raising the issue. You are left. absolutely correct in raising a concern. As this 4. Damaging of roads, fences and water statement makes direct reference to the farms points. within the area under assessment, you are right in 5. Pollution of the environment with garbage. that there is no specific scientific evidence to back Animals can/will eat the garbage and it. I am afraid it was a statement carried over from become ill or die. 2 other projects in the far south and north west of 6. Disrupting cattle movement, and therefore the country where either commercial farming and cattle production, by e.g. leaving fences communal farming practice had in part contributed and gates open or noise. to the degradation of the veld. I must apologise for These concerns are based on facts experienced by this oversight and how it incorrectly overstated the farmers who had exploration teams on their farms. case for all the current area under assessment. I will rectify the matter and inform all interested and In your BID you state "Generally, the area belongs affected parties of the unfounded emphatic to commercial farms which resulted in extensive statement so used. I take full responsibility for the debilitation of the surficial environment and oversight. I am sure that with particular reference pressure on water sources". Please provide to your farm and the livelihood that it provides, adequate, scientific proof for this statement. This your own practices are such that the veld is taken seems like a subjective perspective of a mining care of diligently and the balance of veld, company. biodiversity, game, livestock and groundwater are monitored for sustainability's sake. p.95

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I appreciate your attention to detail and will value your comments on the EIA Report & Draft EMP. It will be of utmost importance that as the exploration company engages with you when planning the implementation of the programmes you re-iterate your concerns and measures to ensure the compliance with the EMP and statutory requirements.

I would like to send this response to Mrs. Christine Stoman, the secretary of the Agricultural Union in your area, so that it can be distributed to all those interested and affected parties in her mailing list. If you do not wish her to do so then let me know so I can draft a separate mail and cc you in.

Reimo Schneider: Philip Hooks: Feel free to forward the correspondence to Dear Christine, I trust you are well. I received some Christine Stoman. Please just delete the farm correspondence. Thank you. names. Reimo Schneider highlighted some issues and an error on my part. Could you forward my response and his email to those members of the union or associations that received the BID.

Jorg Schloder: Philip Hooks: I would like to make a further comment to the list I appreciate your very important input. This will of Reimo Schneider, which all concern me as change aspects of the assessment related to well:- groundwater and the mitigations will have to become stringent. At no point may the integrity of ➢ We have 2 very sensitive ‘subterranean the groundwater be compromised. water veins’ running from Grootfontein towards Berg Aukas. ➢ If these get damaged by drilling, water might leak to different rock formations underground and run away. ➢ Attached a map; indicating the location of these veins. ➢ The southern vicinity of Grootfontein, (the area where Mr. Schneider is farming) gets its underground water from these ‘dolomite’ faults.

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➢ You will also note ‘Karst Monitoring Boreholes’ marked by ‘’▲’’. (map below)

Christine Stoman (Farm Lardner): Philip Hooks: I sent the message below to the members of the I sent the BID and a clearer map to the secretary of Namibia Agricultural Union in the Grootfontein- the Agricultural Union. I requested a list of the Tsumeb-Otavi region. Hopefully they will contact farmers and their farms (no contact details as the you. CS the Sec secretary does not have the authority to disseminate this) so that I could verify the current ownership ”Beste lede van die GTO SLU listing against my list. Neem asb dringend kennis van die aangehegte dokument en registreer julself (indien betrokke) voor 5 Februarie. Julle sal sien die dokument bevat 2 goed. Ignoreer die tweede een wat op Erongo betrekking het. Prospektering vind plaas of mens dit wil hê of nie. Die beste is om al die inligting sorgvuldig deur te lees en mening uit te spreek voor 12 Februarie. Sorg dus dat jy registreer as Interested and Affected Party.”

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Good day, Please provide a detailed, clear map on Christine Stoman who sent it on to the agricultural which identified farms can be recognized by name union of your area. You may have received this for distribution to affected parties. Thank you. map already.

Pieter van Staden: Philip Hooks: Morning, Please register us an I&AP and send us BID sent and requested form to be filled in and the BID. state the interest in the project. Form received – Please keep us informed of progress

Coleen Mannheimer: Philip Hooks: Would you please register me as an I/AP for the Please find attached the BID for the EIA for the EPLs 6561 & 5992. exploration project. Your input is very welcome. I am glad to see the acknowledgement of large trees in this BID, because the trees in that area have already been heavily impacted by mining activities in the past, with an estimate of over 4 million large Tambotis (Spirostachys africana) used for mine supports for Tsumeb and Abenab, resulting in the bush encroached areas seen there now. Besides Tamboti, there are other important and protected species, such as Marula (Sclerocarya birrea) and Bird Plum (Berchemia discolor), for example. Other protected and/or restricted range species also occur, including Ficus petersii, Olea europaea subsp. africana, Lannea discolor and Pachypodium lealii, to mention a few. Furthermore, the Karst is one of the botanically most diverse areas of Namibia and, should mining be contemplated, then a specialist botanical study would be called for. Thank you for the opportunity to comment on this study.

Nico Oberholzer: Philip Hooks: I would like to register myself as an interested and Thank you Mr. Oberholzer. affected party to the planned EIA. Please indicate your motivation or reason for I’m an industry consultant in the Logistics and registration. Are you a farm owner or resident Supply Chain Industry and works closely with of Grootfontein or Government Ministry mines like B2Gold. representative. I try to stay on top of developments in the mining Thank you for stating your interest in the project. sector. Please find attached the BID for the exploration p.98

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Thank you for the scope and documents. project. Ignore the dates on the BID as we extended the public review period. I will complete the attached and return to you soonest.

Swanu Muhenje: Philip Hooks: requested the BID for use in an assignment for his A confidentiality agreement was signed and the course. document was provided to him.

Anastasia Chimwandi: (Ministry of Land & Philip Hooks: Resettlement) I trust you are well. Kunene Resources Namibia Please see the attached map as requested. I have has two EPLs near Grootfontein. Could you indicated that Omhul belongs to us and for indicate using the attached map which of the farms additional info Namkali belongs to the Ministry of within the EPL areas are resettlement farms. Veteran Affairs. Please comment on the project as you wish. I will forward the EIA Report and EMP for your input during the public review period. I have attached a BID for your information. Thank you for your assistance.

WF Lubbe: (Ossa 1397) Philip Hooks: Although our farm OSSA 1397 is not one of the named farms, we still are neighbouring the affected area. Our concern is the control of staff and illegal trespassing on our land. We already have theft problems due to the closeness to town. Who would cover the extra security cost should it deemed necessary? Can this operation assure us that your project would not harm us or damage our farming activities. Thank you

Sieglinde Zensi: (Schaffeld 199) Registered as an IAP I would like to be informed as part of the farm falls within the prospecting licence.

Johannes Enslin: (Mimosa & Waldheim) Registered as an IAP No comment received to date

Arne Gressman, (Nuisib 263) Registered as an IAP No comment received to date

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Curriculum Vitae of Environmental Assessment Practitioner:

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APPENDIX C: DRAFT ENVIRONMENTAL MANAGEMENT PLAN FOR KUNENE RESOURCES (PTY) LTD WITHIN EPLs 6561 & 5992

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