EXPORT OF MANGANESE ORE VIA THE PORT OF LÜDERITZ

ENVIRONMENTAL ASSESSMENT SCOPING REPORT

Assessed by: Assessed for:

May 2019

EXECUTIVE SUMMARY Pektranam Logistics (Pty) Ltd wish to realise the export of manganese ore, originating from the Northern Cape, South Africa, through the Port of Lüderitz. Geo Pollution Technologies (Pty) Ltd was requested to undertake an environmental assessment for all activities associated with the proposed transport, storage and handling of the manganese ore. The project will develop in a phased approach. Initial volumes to be exported are 30,000 tons per month as one shipment. Based on available port capacity, and depending on other port users, this can be increased to three shipments per month (90,000 tons). During the environmental assessment process, and based on public and authority consultation, a significant shift in the proposed project plan occurred. Therefore, the original project plan that that was communicated to the public when the project was initiated, differs from the current project as proposed in this assessment. Some of these changes were communicated to the registered interested and affected parties and authorities, during the assessment process, via electronic communication and a second public meeting. However, since then, and based on more public input and objections and authority recommendations, more changes to the project plan were made. These are presented in the current report, which will also serve to inform registered interested and affected parties and authorities of the changes, as well as allow for another round of review and commenting. The current plan will allow for the transport of the ore in either bulk bags, containerised, or as loose ore, and will be by rail and / or road. The ore will require temporary stockpiling at Lüderitz until sufficient volumes are available to load a bulk cargo ship. For purposes of stockpiling of ore, two locations in Lüderitz are considered, and either one or both the sites may be utilized. The choice of site(s) will depend entirely on the methods of transport of ore. For bulk bags and containers, the old Road Contractors Company yard will be used, while a closed warehouse will be constructed in the industrial area for storage of loose ore. Regardless of the site for stockpiling, ore will be moved through Lüderitz and to the port by truck, where the cargo hold of the ship will be filled. The environmental assessment is conducted to determine all environmental, safety, health and socio- economic impacts associated with the project. Relevant environmental data has been compiled by making use of secondary data and from a reconnaissance site visit. Potential environmental impacts and associated social impacts were identified and are addressed in this report. Due to the nature and location of the project, some impacts can be expected on the surrounding environment, see summary impacts table below. Impacts can be expected along the entire transport route, at the bulk storage yard(s) and in the harbour. To prevent or mitigate environmental impacts it is recommended that environmental performance be monitored to ensure regulatory compliance and that corrective measures be taken if necessary. The proposed project is in line with Namibia’s vision of becoming an international logistics hub. Revenue generated through the transport and logistics sectors associated with the project will contribute significantly to the Namibian economy. For three shipments of ore the income potential is estimated at up to 600 to 700 million Namibian dollar. Employment will depend on the transport methods. At least 12 permanent jobs will be created in Lüderitz while another four will be created in Ariamsvlei. These numbers assumes only rail transport of ore, but should road transport be utilised, more jobs will be created and / or sustained. The project will increase the spending power of a portion of the Lüderitz community and contribute to the economic resilience of existing businesses that can supply services to Pektranam Logistics. By appointing local contractors and employees and implementing educational programs, the positive socio-economic impacts can be maximised. The major concerns related to the project comprise of health impacts related to dust inhalation as well as impacts of the increased traffic, and its associated noise, on the national roads as well as through the town of Lüderitz. The potential impact on the tourism industry is of a concern to residents of Lüderitz as well as for tourist establishments along the route from Ariamsvlei to Lüderitz. Collisions with animals, especially wild horses and hyenas between Aus and Lüderitz is possible. Potential groundwater, surface water and soil contamination and the possibility of fire is associated with the consumer fuel installation. This will however be limited by adherence to South African National Standards for fuel installations and Material Safety Data Sheet instructions. Noise pollution should meet the minimum requirements of the World Health Organisation standards. Pektranam Logistics is committed to minimize and prevent the expected negative impacts as far as is practically possible. The use of road marshals has been proposed to manage traffic during transport activities through town. This is especially the case at the Helen van Rhijn School and road intersections. Alternative transport routes are under investigation by Namport which could significantly reduce negative impacts. The environmental management plan included in Section 9 of this document should be used as a reference document during all phases (planning, construction (care and maintenance), operations and decommissioning) of the project and its facilities. All monitoring and records kept should be included in a report to ensure compliance with the environmental management plan. Parties responsible for transgression of the environmental management plan should be held responsible for any rehabilitation that may need to be undertaken. A Health, Safety, Environment and Quality policy could be used in conjunction with the environmental management plan. Operators, contractors and responsible personnel must be taught the contents of these documents. Municipal or national regulations and guidelines must be adhered to and monitored regularly as outlined in the environmental management plan. Impact Summary Class Values Impact Category Impact Type Construction Operations Positive Rating Scale: Maximum Value 5 5 Negative Rating Scale: Maximum Value -5 -5 EO Skills, Technology and Development 2 3 EO Revenue Generation and Employment 2 4 SC Demographic Profile and Community Health -2 -2 SC Health, Safety and Security (Employees) -2 -4 PC Air Quality Related Impacts (Off-Site) -4 SC Traffic -1 -4 PC Fire -1 -1 PC Noise -1 -4 EO Vibration Impact - Buildings and Infrastructure -3 PC Waste Production -2 -2 BE Ecosystem and Biodiversity Impact - Terrestrial -1 -1 BE Ecosystem and Biodiversity Impact - Marine -3 PC Groundwater, Surface Water and Soil Contamination -2 -3 EO Impacts on Utilities and Infrastructure -3 SC Visual Impact -1 -1 Cumulative Impact -2 -2 BE = Biological/Ecological EO = Economical/Operational PC = Physical/Chemical SC = Sociological/Cultural TABLE OF CONTENTS 1 BACKGROUND AND INTRODUCTION ...... 1 2 SCOPE ...... 1 3 METHODOLOGY ...... 2 4 OPERATIONS AND RELATED ACTIVITIES ...... 2 THE PLANNED EXPORTS ...... 3 RAIL TRANSPORT : SOUTH AFRICA TO STORAGE YARD AT LÜDERITZ ...... 3 ROAD TRANSPORT : SOUTH AFRICA TO STORAGE YARD AT LÜDERITZ ...... 4 BULK STORAGE YARDS AND INFRASTRUCTURE ...... 4 TRANSPORT : STORAGE YARD TO PORT ...... 6 OFFLOADING ACTIVITIES IN THE PORT ...... 7 EMPLOYMENT ...... 7 ALTERNATIVES COMPARISON ...... 8 5 ADMINISTRATIVE, LEGAL AND POLICY REQUIREMENTS ...... 12 6 ENVIRONMENTAL CHARACTERISTICS ...... 17 LOCALITY AND SURROUNDING LAND USE ...... 17 CLIMATE ...... 20 CORROSIVE ENVIRONMENT ...... 24 TOPOGRAPHY AND DRAINAGE ...... 25 GEOLOGY AND HYDROGEOLOGY ...... 27 PUBLIC WATER SUPPLY ...... 28 FAUNA AND FLORA ...... 29 DEMOGRAPHIC AND ECONOMIC CHARACTERISTICS ...... 31 Demographic Characteristics ...... 31 The Port of Lüderitz ...... 31 Mining ...... 32 Fishing and Mariculture ...... 32 Tourism ...... 33 CULTURAL , HERITAGE AND ARCHAEOLOGICAL ASPECTS ...... 34 7 PUBLIC CONSULTATION ...... 36 8 MAJOR IDENTIFIED IMPACTS ...... 36 EMPLOYMENT ...... 37 ECONOMIC IMPACTS ...... 37 TOURISM IMPACTS ...... 37 AIR QUALITY RELATED HEALTH IMPACTS ...... 38 MARINE IMPACTS ...... 39 TERRESTRIAL ECOLOGY IMPACTS ...... 40 TRAFFIC IMPACTS ...... 40 HERITAGE IMPACTS ...... 41 HYDROCARBON POLLUTION ...... 41 NOISE IMPACTS ...... 43 FIRE ...... 43 9 ASSESSMENT AND MANAGEMENT OF IMPACTS ...... 43 RISK ASSESSMENT AND ENVIRONMENTAL MANAGEMENT PLAN ...... 44 Planning ...... 45 Skills, Technology and Development ...... 46 Revenue Generation and Employment ...... 47 Demographic Profile and Community Health ...... 48 Health, Safety and Security (Employees) ...... 49 Air Quality Related Impacts (Off-Site)...... 51 Traffic ...... 53 Fire ...... 55 Noise ...... 56 Vibration Impact – Buildings and Infrastructure ...... 58 Waste production ...... 59 Ecosystem and Biodiversity Impact - Terrestrial ...... 60 Ecosystem and Biodiversity Impact - Marine ...... 61 Groundwater, Surface Water and Soil Contamination ...... 62 Impacts on Utilities and Infrastructure ...... 64 Visual Impact ...... 65 Cumulative Impact ...... 66 DECOMMISSIONING AND REHABILITATION ...... 67 ENVIRONMENTAL MANAGEMENT SYSTEM ...... 67 10 CONCLUSION ...... 67 11 REFERENCES ...... 69

List of Appendices APPENDIX A: PROOF OF PUBLIC CONSULTATION ...... 72 APPENDIX B: MINUTES OF MEETINGS AND CORRESPONDENCE RECEIVED ...... 99 APPENDIX C: CONSULTANTS ’ CURRICULUM VITAE ...... 144

LIST OF FIGURES FIGURE 1. PROJECT LOCATION ...... 2 FIGURE 2. PRELIMINARY SITE LAYOUT FOR INDUSTRIAL YARD ...... 5 FIGURE 3. PRELIMINARY SITE LAYOUT FOR RCC YARD ...... 6 FIGURE 4. PROPOSED ROUTE TO THE PORT ...... 7 FIGURE 5. ALTERNATIVE ROUTE FOR TRANSPORT THROUGH LÜDERITZ ...... 11 FIGURE 6. PROJECT LOCATION IN RELATION TO LÜDERITZ TOWNLANDS AND TRANSPORT INFRASTRUCTURE ...... 17 FIGURE 7. LAND USE ALONG TRANSPORT ROUTE ...... 18 FIGURE 8. TRANS NAMIB RAILWAY YARD AND SIDING IN ARIAMSVLEI ...... 19 FIGURE 9. WIND ROSE FOR THE MONTHS OF JANUARY TO JUNE ...... 22 FIGURE 10. WIND ROSE FOR THE MONTHS OF JULY TO DECEMBER ...... 23 FIGURE 11. TOPOGRAPHY ...... 26 FIGURE 12. SURFACE DRAINAGE ...... 27 FIGURE 13. GEOLOGY MAP ...... 28 FIGURE 14. NAM WATER KOICHAB SCHEME WATER SUPPLY AND DEMAND STATISTICS FOR THE LAST 26 YEARS (SOURCE : NAM WATER 2018) ...... 29 FIGURE 15. TREAD LIGHT AND NO-GO AREAS (L ÜDERITZ STRUCTURE PLAN , SPC 2015) ...... 30 FIGURE 16. BROWN HYENA TERRITORIES AND MOVEMENTS (L ÜDERITZ STRUCTURE PLAN , SPC 2015) ...... 30 FIGURE 17. SIGNIFICANT HERITAGE BUILDINGS IN LÜDERITZ WITH THE PROPOSED ROUTE TO THE PORT INDICATED IN PURPLE (ADAPTED FROM SPC 2015) ...... 35 FIGURE 18. CONCEPTUAL LNAPL RELEASE TO THE VADOSE ZONE ...... 43

LIST OF PHOTOS PHOTO 1. INDUSTRIAL YARD AND VIEW TO NORTH ...... 19 PHOTO 2. NEIGHBOURING PROPERTIES TO THE WEST OF THE INDUSTRIAL YARD AND FIRE BRIGADE 19 PHOTO 3. VIEW OF INDUSTRIAL YARD AND TOWARDS THE SOUTH ...... 19 PHOTO 4. VIEW OF INDUSTRIAL YARD AND TOWARDS THE EAST ...... 19 PHOTO 7. RCC YARD ...... 20 PHOTO 2. DIESEL STORAGE TANKS AT RCC YARD ...... 20 PHOTO 3. EXISTING BUILDINGS TO BE RENOVATED AT RCC YARD ...... 20 PHOTO 4. EXISTING BUILDINGS TO BE RENOVATED AT RCC YARD ...... 20 PHOTO 5. TOURIST ACCOMMODATION IN BISMARCK STREET ...... 33 PHOTO 6. TOURISM ACCOMMODATION IN OLD BAY ROAD ...... 33 PHOTO 7. KRABBENH ӦFT UND LAMPE BUILDING ...... 34 PHOTO 8. DEUTSCHE AFRICA BANK BUILDING ...... 34

LIST OF TABLES TABLE 1. ALTERNATIVE COMPARISON TABLE ...... 8 TABLE 1. NAMIBIAN LAW APPLICABLE TO THE PROPOSED PROJECT ...... 12 TABLE 2. RELEVANT MULTILATERAL ENVIRONMENTAL AGREEMENTS FOR NAMIBIA AND THE DEVELOPMENT ...... 15 TABLE 3. STANDARDS OR CODES OF PRACTISE ...... 16 TABLE 4. SUMMARY OF CLIMATE DATA (D IGITAL ATLAS OF NAMIBIA ) ...... 21 TABLE 5. AVERAGE ANNUAL CORROSION RATE FOR VARIOUS METALS IN DIFFERENT LOCATIONS IN SOUTHERN AFRICA (FROM NICKEL DEVELOPMENT INSTITUTE : STAINLESS STEELS IN ARCHITECTURE , BUILDING AND CONSTRUCTION . HTTP :// WWW .NICKELINSTITUTE .ORG ) 24 TABLE 6. 2011 DEMOGRAPHIC CHARACTERISTICS OF LÜDERITZ BAY , THE KARAS REGION AND NATIONALLY (N AMIBIA STATISTICS AGENCY , 2011) ...... 31 TABLE 7. ROAD USE STATISTICS OF 2015 (S OURCE : ROADS AUTHORITY ) ...... 40 TABLE 8. ADDITIONAL HEAVY MOTOR VEHICLE ROAD USE PREDICTIONS BASED ON PEKTRANAM LOGISTICS ’ PROPOSAL FOR UP TO THREE SHIPMENTS OF 30,000 TON MANGANESE ORE PER MONTH ...... 41 TABLE 9. ASSESSMENT CRITERIA ...... 43 TABLE 10. ENVIRONMENTAL CLASSIFICATION (P ASTAKIA 1998) ...... 44 TABLE 12. IMPACT SUMMARY CLASS VALUES ...... 68

LIST OF ABBREVIATIONS

AIDS Acquired Immune Deficiency Syndrome AST Aboveground Storage Tank BE Biological/Ecological DWA Department of Water Affairs EA Environmental Assessment EIA Environmental Impact Assessment EMA Environmental Management Act No 7 of 2007 EMP Environmental Management Plan EMS Environmental Management System EO Economic/Operational ES Environmental Classification GPT Geo Pollution Technologies HIV Human Immunodeficiency Virus IAPs Interested and Affected Parties IUCN International Union for Conservation of Nature LNAPL Light Non-Aqueous Phase Liquids m/s Metre per second mbs Metres below surface MET Ministry of Environment and Tourism mm/a Millimetres per annum MSDS Material Safety Data Sheet NaCl Sodium chloride PC Physical/Chemical PPE Personal Protective Equipment ppm Parts per million SANS South African National Standards SC Sociological/Cultural SO2 Sulfur dioxide UNFCCC United Nations Framework Convention on Climate Change UST Underground Storage Tank WHO World Health Organization

GLOSSARY OF TERMS

Alternatives - A possible course of action, in place of another, that would meet the same purpose and need but which would avoid or minimize negative impacts or enhance project benefits. These can include alternative locations/sites, routes, layouts, processes, designs, schedules and/or inputs. The “no-go” alternative constitutes the ‘without project’ option and provides a benchmark against which to evaluate changes; development should result in net benefit to society and should avoid undesirable negative impacts. Assessment - The process of collecting, organising, analysing, interpreting and communicating information relevant to decision making. Competent Authority - means a body or person empowered under the local authorities act or Environmental Management Act to enforce the rule of law. Construction - means the building, erection or modification of a facility, structure or infrastructure that is necessary for the undertaking of an activity, including the modification, alteration, upgrading or decommissioning of such facility, structure or infrastructure. Cumulative Impacts - in relation to an activity, means the impact of an activity that in itself may not be significant but may become significant when added to the existing and potential impacts eventuating from similar or diverse activities or undertakings in the area. Environment - As defined in the Environmental Assessment Policy and Environmental Management Act - “land, water and air; all organic and inorganic matter and living organisms as well as biological diversity; the interacting natural systems that include components referred to in sub-paragraphs, the human environment insofar as it represents archaeological, aesthetic, cultural, historic, economic, palaeontological or social values”. Environmental Impact Assessment (EI A) - process of assessment of the effects of a development on the environment. Environmental Management Plan (EMP) - A working document on environmental and socio- economic mitigation measures, which must be implemented by several responsible parties during all the phases of the proposed project. Environmental Management System (EMS) - An Environment Management System, or EMS, is a comprehensive approach to managing environmental issues, integrating environment-oriented thinking into every aspect of business management. An EMS ensures environmental considerations are a priority, along with other concerns such as costs, product quality, investments, PR productivity and strategic planning. An EMS generally makes a positive impact on a company’s bottom line. It increases efficiency and focuses on customer needs and marketplace conditions, improving both the company’s financial and environmental performance. By using an EMS to convert environmental problems into commercial opportunities, companies usually become more competitive. Evaluation – means the process of ascertaining the relative importance or significance of information, the light of people’s values, preference and judgements in order to make a decision. Hazard - Anything that has the potential to cause damage to life, property and/or the environment. The hazard of a particular material or installation is constant; that is, it would present the same hazard wherever it was present. Interested and Affected Party (I&AP) - any person, group of persons or organisation interested in, or affected by an activity; and any organ of state that may have jurisdiction over any aspect of the activity. Mitigate - The implementation of practical measures to reduce adverse impacts. Proponent (Applicant) - Any person who has submitted or intends to submit an application for an authorisation, as legislated by the Environmental Management Act no. 7 of 2007, to undertake an activity or activities identified as a listed activity or listed activities; or in any other notice published by the Minister or Ministry of Environment & Tourism. Public - Citizens who have diverse cultural, educational, political and socio-economic characteristics. The public is not a homogeneous and unified group of people with a set of agreed common interests and aims. There is no single public. There are a number of publics, some of whom may emerge at any time during the process depending on their particular concerns and the issues involved. Scoping Process - process of identifying: issues that will be relevant for consideration of the application; the potential environmental impacts of the proposed activity; and alternatives to the proposed activity that are feasible and reasonable. Significant Effect/Impact - means an impact that by its magnitude, duration, intensity or probability of occurrence may have a notable effect on one or more aspects of the environment. Stakeholder Engagement - The process of engagement between stakeholders (the proponent, authorities and I&APs) during the planning, assessment, implementation and/or management of proposals or activities. The level of stakeholder engagement varies depending on the nature of the proposal or activity as well as the level of commitment by stakeholders to the process. Stakeholder engagement can therefore be described by a spectrum or continuum of increasing levels of engagement in the decision-making process. The term is considered to be more appropriate than the term “public participation”. Stakeholders - A sub-group of the public whose interests may be positively or negatively affected by a proposal or activity and/or who are concerned with a proposal or activity and its consequences. The term therefore includes the proponent, authorities (both the lead authority and other authorities) and all interested and affected parties (I&APs). The principle that environmental consultants and stakeholder engagement practitioners should be independent and unbiased excludes these groups from being considered stakeholders. Sustainable Development - “Development that meets the needs of the current generation without compromising the ability of future generations to meet their own needs and aspirations” – the definition of the World Commission on Environment and Development (1987). “Improving the quality of human life while living within the carrying capacity of supporting ecosystems” – the definition given in a publication called “Caring for the Earth: A Strategy for Sustainable Living” by the International Union for Conservation of Nature (IUCN), the United Nations Environment Programme and the World Wide Fund for Nature (1991).

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1 BACKGROUND AND INTRODUCTION Pektranam Logistics (Pty) Ltd is a registered Namibian company, with the objective of realising the export of manganese ore, originating from the Northern Cape, South Africa, through the Port of Lüderitz. Geo Pollution Technologies (Pty) Ltd was appointed by Pektranam Logistics to undertake an environmental assessment for the proposed manganese ore export project. The project components will include the transport, handling and temporary bulk storage of manganese ore, with the main activities centred at Lüderitz (Figure 1). A risk assessment was undertaken to determine the potential impact of construction, operational and possible decommissioning phases of the project on the environment. The environment being defined in the Environmental Assessment Policy and Environmental Management Act as “land, water and air; all organic and inorganic matter and living organisms as well as biological diversity; the interacting natural systems that include components referred to in sub-paragraphs, the human environment insofar as it represents archaeological, aesthetic, cultural, historic, economic, paleontological or social values”. The environmental assessment was conducted to apply for an environmental clearance certificate in compliance with Namibia’s Environmental Management Act (Act No 7 of 2007). Project Justification – The Government of Namibia, through Namibia’s Vision 2030 (Government of the Republic of Namibia 2004) and the various National Development Plans (NDP’s), aims at establishing Namibia as an industrialised country with an established network of modern infrastructure inclusive of rail, road, telecommunications and port facilities. The transport network is central to the vision of developing Namibia as an international logistics hub that will cater for the import and export needs of southern Africa. The Port of Lüderitz is specifically aimed at being an export point targeting the Northern Cape of South Africa (JICA 2015). Manganese ore is mined extensively in the Northern Cape province of South Africa. As a result of already congested ports and related logistical challenges, alternative avenues for the export of ore from South Africa to international markets are investigated. A favourable option is to export the ore via the Port of Lüderitz, which is under management of the Namibian Ports Authority (Namport). Benefits of exporting manganese ore via the Port of Lüderitz include:  Direct capital investment and contribution to National treasury through construction activities, logistic support services, customs clearance and port handling  Stimulation of economic development and investments  Skills development and employment  Diversification of the local and regional economy and increased spending power

2 SCOPE The scope of the environmental assessment is to determine the potential environmental impacts emanating from all the processes involved with the transport, storage and handling of manganese ore. Once determined, possible enhancement measures will be listed for positive impacts while mitigation / preventative measures will be provided for negative impacts. Relevant environmental data has been compiled by making use of primary data, secondary data and from a reconnaissance site visit. As per the findings of this scoping report, an environmental management plan (EMP) was incorporated into this report to be submitted to the Ministry of Environment and Tourism. The aims and objectives of this report are to: 1. Determine the potential environmental impacts emanating from all processes involved with the transport, storage and handling of manganese ore. 2. Identify a range of management actions which could mitigate the potential adverse impacts to acceptable levels. 3. Comply with Namibia’s Environmental Management Act (2007). 4. Provide sufficient information to the Ministry of Environment and Tourism to make an informed decision regarding the project.

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Should the Directorate of Environmental Affairs (DEA) find that the impacts and related mitigation measures, which have been proposed in this report are acceptable, an environmental clearance certificate may be granted to Pektranam Logistics. The environmental clearance certificate issued, based on this document, will render it a legally binding document which should be adhered to. Focus could be placed on Section 9, which includes an EMP for this project. It should be noted that the assessment process’s aim is not to stop the activity, or any of its components, but to rather determine its impact and guide sustainable and responsible development as per the spirit of the EMA.

Figure 1. Project Location 3 METHODOLOGY The following methods were used to investigate the potential impacts on the social and natural environment due to the project: 1. Baseline information about the site and its surroundings was obtained from existing secondary information as well as from a reconnaissance site visit. 2. As part of the scoping process to determine potential environmental impacts, interested and affected parties (IAPs) were consulted about their views, comments and opinions and these are put forward in this report.

4 OPERATIONS AND RELATED ACTIVITIES South Africa hosts the world’s largest known land-based manganese metal reserve (Beukes et al. 2016). This reserve of approximately 4,200 megatons (Mt) is found in the Kalahari Manganese Field in the Northern Cape, and comprises an estimated 77% share of the total global reserves. The manganese mined here are either exported as manganese ore via the Port Elisabeth and Saldanha Bay harbours, or processed into ferroalloy at processing plants in South Africa.

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Due to logistical problems faced with road transport of manganese ore, and the congestion of the two harbours, a more favourable avenue for manganese ore is required. The Port of Lüderitz is considered to be ideal for this purpose due to the following reasons:  Its proximity to the ore reserves, which is within a few kilometres equidistant to the distance between the reserves and the various ports in South Africa;  Available port capacity (the Port of Lüderitz is currently operated at less than 40% of its capacity);  Namibia’s political stability and safety;  Relatively flat and straight roads from Ariamsvlei to Lüderitz;  The Namibian Government’s support to realise the goal of developing Namibia as a logistics hub. After years of planning, Pektranam Logistics is now in a position to implement the ore export project. The manganese ore will be sourced from different mines in the Northern Cape and will be exported as nuggets. These will have a diameter varying between 3 and 10 cm. When the environmental assessment process was initiated, transport of the ore was proposed to be by tipper trucks, as bulk cargo that would have been stockpiled in the open, outside of Lüderitz. During the environmental assessment, and specifically the public and authority consultation process, it soon became evident that the proposed method will not be optimal and thus the project plan had to be adapted to achieve an acceptable and feasible project plan. The major adjustment had to be made in terms of the method of transport and storage of the ore. Transport may be by truck and / or rail and ore will be loaded as bulk (unpackaged), break bulk (two ton bags) and / or containerised. The method, or combination of methods, for transport may vary due to: 1) the recommendations of, as well as results of negotiations with, TransNamib and Roads Authority; and 2) the demand for manganese ore export via the Port of Lüderitz and the port’s capacity to handle bulk cargo ships. Initially, 30,000 tons of manganese ore will be exported per shipment per month. Depending on port availability, this will potentially increase to two or three shipments per month. The approach of this environmental assessment is to assess all methods, or combinations thereof, for transport as proposed. This will allow for a certain level of flexibility that has become evident, is required to feasibly execute the ore export project. The following sections provide an overview of all the different methods proposed.

THE PLANNED EXPORTS The project aims at exporting bulk shipments of 30,000 tons each. The Port of Lüderitz can only handle one bulk cargo ship of this capacity in the port at a time, and the ideal ship loading time is three days. Therefore, ore will be transported from South Africa via the Ariamsvlei border post over a three to four week period, prior to the arrival of the bulk cargo ship. The ore will be stockpiled in Lüderitz and once the ship arrives, it will be transported to the port and loaded onto the vessel over the three day period, for 24 hours a day.

RAIL TRANSPORT: SOUTH AFRICA TO STORAGE YARD AT LÜDERITZ For rail transport to realise, manganese ore will initially be transported by road, in two ton bulk bags, or in containers, from the mines in South Africa to the TransNamib rail siding outside of Ariamsvlei. Here, the bags or containers will be offloaded and temporarily stored until the train arrives. Rail cars will be loaded by means of a forklift or reach stacker and each rail car will be loaded with 26 tons. The total train length will be 35 wagons, thus allowing for the transport of 910 tons of ore at a time. The train will proceed to Keetmanshoop where the train will be split into two shorter trains (17 and 18 rail cars respectively) for the remainder of the route to Lüderitz. This is required due to the steep descent, limiting train length, as the railway line approach Lüderitz. For one shipment of 30,000 tons, rail transport will thus require approximately one 35 wagon train up to Keetmanshoop and two shorter trains to Lüderitz, on a daily basis. At the Lüderitz TransNamib rail siding, the trains will be offloaded and the bags or containers will be transported to a nearby yard (see section 4.4) for storage.

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For bulk bags, initial testing showed a safe re-use lifespan of 10 times before bag failure sets in. However, prior to each bag filling event all bags will be inspected and any bag with holes or obvious signs of flaws will be discarded in South Africa.

ROAD TRANSPORT: SOUTH AFRICA TO STORAGE YARD AT LÜDERITZ Manganese ore can be transported as bulk, in bags or in containers, if road transport is used. For bulk transport, side tipper trucks will be used and all loads will be covered to prevent product loss or dust. Bulk bags or containers will be transported on flatbed trucks and all loads will be secured to the truck. Bulk bags will be transported in a single layer on the truck. A maximum of 36 tons of ore will be loaded per truck. Trucks will be loaded at the mines and no further handling of ore will be required until it is offloaded at the stockpiling yard at Lüderitz. For a shipment of 30,000 tons of ore per month, and given that no rail transport is used, a total of 833 truckloads per month will be required. Namibian transport companies will be contracted for all road transport purposes. If road transport realises, emergency equipment attend to any breakdowns or accidental product loss along transport routes, will be on standby in Keetmanshoop. This will include a front-end loader and truck to recover spilled ore in the unlikely scenario of an overturned truck or bulk bag falling from a truck. One of the aspects that contributes to the feasibility of road transport is the cheaper fuel available in Namibia as compared to South Africa. It is thus a requirement that all refuelling of trucks take place in Namibia. Logistically, Keetmanshoop is the ideal location for refuelling. A refuelled truck can, from here, make a round trip to Lüderitz and back, as well as to the mines in South Africa and back.

BULK STORAGE YARDS AND INFRASTRUCTURE Depending on the method of transport, Pektranam will potentially make use of either one or two premises at Lüderitz for ore storage and their general operations. The first is the old Road Contractors Company (RCC) yard (hereafter referred to as RCC Yard), which they will lease if they make use of rail transport. It will thus be the site for bagged and containerised ore storage. The RCC Yard has some existing infrastructure which have been significantly vandalised since the RCC vacated the site. Some of the buildings will be upgraded and used for administrative and support purposes. There are two 23 m3 diesel tanks onsite and one of these will be used as a consumer fuel installation by Pektranam. When the trains arrive, bags or containers will be offloaded and transported to the yard on trucks. Here they will be stored under tarpaulins until the cargo ship arrives. For the second premises, Pektranam may acquire erven 2040, 2041 and 2042 situated in the new industrial area of Lüderitz (hereafter referred to as Industrial Yard). This will only realise should bulk road transport take place which will require stockpiling of ore inside a closed warehouse. The properties will be consolidated into one erf by the Lüderitz Town Council. Based on planned design parameters a warehouse of 9,000 m2 will be constructed on the Industrial Yard. The warehouse design will comprise of a steel structure with a concrete floor and access for trucks will be through roller doors. It will be divided into two storage bays, each with its own entrance and exit doors. The warehouse will host emergency showers, emergency eye wash stations, locker rooms, ablution facilities, showers and a freshwater dust suppression system operating at 50 litres/hour when required. Additional infrastructure will include a perimeter fence, offices, ablution facilities and support infrastructure. The preliminary layout of the warehouse are presented in Figure 2. Prior to construction all designs will be approved by the Lüderitz Town Council. Should both road and rail transport realise, both the RCC Yard and the Industrial Yard will be acquired and developed.

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Figure 2. Preliminary Site Layout for Industrial Yard

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Figure 3. Preliminary Site Layout for RCC Yard

TRANSPORT: STORAGE YARD TO PORT The proposed route from the Pektranam yards to the port is indicated in Figure 4. It follows Old Bay Road and then cross over to Bismarck Street at the first rail level crossing. A section of Bismarck Street is currently gravel and Pektranam is willing to interlock the road in a joint effort with the authorities and other bulk transport users of the road. For transport from the RCC yard an option exist to make use of a transport route that crosses the railway line near the siding and then enters Lüderitz via the district road D0701. Should this route be considered a rail level crossing will have to be constructed to TransNamib specifications. A total of 12 trucks will be used for transport of ore from the bulk storage area to the port and a total of 833 trips (one-way) will be made over a 72 hour period. To ensure the safety of school children at the Helen van Rhijn Primary School, Pektranam committed to work in cooperation with the school to place road marshals at strategic locations along nearby roads to ensure safe road crossing by children. Marshals will be placed for the duration of the 72 hours ship loading process, at times when children go to and leave the school. Marshals will also be placed at the intersections of Old Bay Road and Hafen Street with Bismarck Street. To reduce traffic impacts, noise and road wear and tear, it would be ideal if trucks can move through town at a constant speed and in convoys of three trucks at a time. When a convoy of three trucks approach an intersection, the marshal will stop traffic approaching from Old Bay Road or Hafen Street and allow the trucks to move through the intersection without stopping. The same traffic management will be performed for empty trucks returning to the Pektranam Yard. The traffic impact will thus realise as two truck convoys, one incoming and one outgoing, every fifteen minutes for the three day period. Aspects related to transport through town e.g. timing, marshals, convoy vs. spread out, will be finalised in conjunction with the town council and other role players.

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Reduction of noise and vibration impacts in town will further be achieved by making use of trucks with air suspension instead of conventional suspension systems. An alternative transport route through town is also under investigation. This is elaborated on in Section 4.8

Figure 4. Proposed Route to the Port

OFFLOADING ACTIVITIES IN THE PORT When the ship arrives in the port, the ore will again be loaded onto trucks for transport to the port. For bulk bags and containers it will be flatbed trucks whereas bulk ore will be in skips on flatbed trucks. In the port, the bags or skips will be lifted by crane into the cargo hold of the ship where the bags are bottom-opened and skips are tipped to empty the contents into the hold. If containers are used, they will be offloaded from the trucks with a reach stacker and emptied into the cargo hold of the ship. Empty bags, skips and containers will be returned to the truck, secured, and returned to the RCC yard. Bags and containers will be returned to South Africa for re-filling. All activities inside the port will be performed by a local logistics and stevedoring company.

EMPLOYMENT Should only rail transport realise, approximately 12 people will directly be employed by Pektranam in Lüderitz, while another four will be stationed in Ariamsvlei. This will include managerial staff, administrative staff and vehicle operators (e.g. forklifts). Truck drivers for the movement of ore from the RRC Yard to the Port of Lüderitz will be contracted for the period of ship loading. Should both yards be utilised, the employment figures will be slightly higher and indirect employment will increase significantly through the need for road transport contractors and drivers.

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ALTERNATIVES COMPARISON The project description as presented provides a number of alternatives, all of which are potential options to be used. Each alternative has its own positive and negative impacts. Table 1 presents a comparison of the different alternatives in terms of its advantages and disadvantages and suggest a preferred option based on the information presented. Table 1. Alternative Comparison Table Alternative Advantages Disadvantages Preferred Alternative Description Site Location RCC Yard  Rehabilitation of  Closer to Radford Bay and  Either one or a damaged infrastructure mariculture areas combination of the two and pollution left by the  Closer to environmentally locations as this Road Contractors sensitive habitats diversify the possible Company  Site will be leased, thus no options available to  Existing infrastructure capital investment in terms Pektranam Logistics that can be re-used of land ownership with regard to transport  Further away from and stockpiling methods. receptors in the town Industrial Yard  Already zoned for  Closer to residential areas industrial purposes  Further away from Radford Bay and mariculture areas  Revenue generation for Town Council trough sale of erven Bulk Storage Method As bulk ore on  Can immediately start  Dust impacts  Combination of methods paving (RCC project  Extensive dust suppression may increase project Yard)  Low capital expenditure required with possible high feasibility and provide increasing project water consumption for more than one feasibility  Public health and ecological transport option which in risks turn dilute traffic and  Visual impact related impacts. Bulk bags stored  Can immediately start  Cost of bags with limited under tarpaulins project lifespan (RCC Yard)  Excellent containment of  Increased handling time dust  Possibility of bags being damaged, resulting in spills Containerised  Can immediately start  Cost of containers (RCC Yard) project  Increased handling time  Excellent containment of dust As bulk ore in a  Excellent containment of  Possible delay in start of closed dust project to allow for warehouse  Capital investment construction of warehouse (Industrial through construction of Yard) warehouse  Low visual impact Transport Method – Ariamsvlei to Bulk Storage Yard Rail  In line with Namibia’s  More expensive than road  Rail. It is in line with Transport Master Plan transport – decreases project Namibia’s Transport  Reduced traffic on main feasibility Master Plan and will roads  Double handling at rail significantly reduce road  Less frequent movement sidings increases costs and related impacts such as of trains reduces possible environmental accidents, wear and tear possibility of collisions contamination should bulk and wildlife collisions. bags be used

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Alternative Advantages Disadvantages Preferred Alternative Description with wildlife and/or  Possible delays due to dune people migration over railway line  Revenue generated in the – decreases project form of TransNamib’s feasibility fees contributing to  Less employment created / funds for rail upgrades sustained  Sections of the railway line requires upgrading and may pose risks of accidents or derailment if caution is not taken Road  Cheaper and more  Increased traffic on national reliable than rail roads transport  Increased noise at receptors  Between 70 and 210 jobs along the national roads as truck drivers created /  Increased chance of sustained accidents and collisions with  Reduced handling time animals and people/vehicles  Revenue generated in the  Increased road wear and tear form of fuel levies and resulting in the need for fees contributing to premature rehabilitation / funds for road upgrades upgrade of national road infrastructure Transport Method – Bulk Storage Yard to Port Rail  Reduced traffic in streets  Due to short siding in the  Road transport, port only trains with a few especially if alternative railcars can be handled at a as indicated in Figure 5 time. The number of trains can be used. that will have to move between the yard and port will be excessive.  Noise – vibrations and noise caused by trains are much worse than trucks. Each time a train approach a rail level crossing they have to blow their horns. There are three such crossings in Lüderitz.  Trains will block rail level crossings for periods, especially at the entrance to the port, thus forcing vehicles to make use of alternative routes Road  No need for horn  Increased traffic in streets signalling as with trains  Increased chance of thus potentially less accidents noisy than trains although some noise will still be produced which will be a nuisance especially at night

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Various alternatives for the transport route through town have been considered. Ultimately fully loaded heavy motor vehicles need to travel on the straightest route possible. This reduces road wear and tear as well as decrease the chances of trucks overturning. An alternative to travelling along Bismarck Street has been proposed at the second public meeting. It was suggested that trucks travel along the rail track instead of on the roads. This will entail placement of concrete blocks along the rail tracks which will allow the trucks to drive “on” the railway line, see Figure 5 for the route alternative. There are a number of advantages to this strategy. These are:  Fewer receptors that will be impacted  Since the first section of the rail up to the Old Bay Road – Bismarck Street intersection is lowered below ground level, it will significantly reduce noise impacts at the properties along Bismarck Street.  Truck traffic will be kept out of the central business district preventing traffic impacts and potential accidents.  Reduced impacts on the tourism industry  Reduced impacts on buildings of historic or heritage value In addition to Pektranam Logistics’ trucks making use of the rail route, current heavy vehicle traffic through town can also be moved onto this route. Thus reducing existing impacts and thus a reduced cumulative impact. Since Namport and TransNamib both fall under the Ministry of Works and Transport, the ministry should investigate and drive this strategy as a very favourable solution to the concerns related to this and other projects. Potential users of this route should, together with TransNamib and the Lüderitz Town Council, develop a traffic management plan to implement this strategy. Pektranam Logistics has indicated that their preferred mode of transport of ore up to the storage yards at Lüderitz will be by rail. This decision was made based on the public’s and Roads Authority’s concerns regarding the number of trucks, and their related impacts, that will be present on the national road network (Ariamsvlei to Lüderitz) if only road transport is utilised.

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Figure 5. Alternative Route for Transport through Lüderitz

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5 ADMINISTRATIVE, LEGAL AND POLICY REQUIREMENTS To protect the environment and achieve sustainable development, all projects, plans, programmes and policies deemed to have adverse impacts on the environment require an environmental assessment, as per the Namibian legislation. The legislation and standards provided in Table 2 to Table 4 govern the environmental assessment process in Namibia and/or are relevant to the facility. Table 2. Namibian Law Applicable to the Proposed Project Law Key Aspects The Namibian Constitution  Promote the welfare of people  Incorporates a high level of environmental protection  Incorporates international agreements as part of Namibian law Environmental Management Act  Defines the environment Act No. 7 of 2007, Government Notice No. 232  Promote sustainable management of the environment of 2007 and the use of natural resources  Provide a process of assessment and control of activities with possible significant effects on the environment Environmental Management Act  Commencement of the Environmental Management Regulations Act Government Notice No. 28-30 of 2012  List activities that requires an Environmental Clearance Certificate  Provide Environmental Impact Assessment Regulations Namibia Ports Authority Act  Provides for the establishment of the Namibian Ports Act No. 2 of 1994 Authority to undertake the management and control of ports Territorial Sea and Exclusive Economic  Determine and define the territorial sea, internal Zone of Namibia Act waters, contiguous zone, exclusive economic zone Act No. 3 of 1990 and continental shelf of Namibia

Marine Resources Act  Provide for the conservation of the marine ecosystem Act No. 27 of 2000 and the responsible administration, conservation, protection and promotion of marine resources on a sustainable basis  Under this act the following were determined: o Regulations relating to the exploitation of marine resources (2001) o Declaration of the Namibian Islands’ Marine Protected Area: Marine Resources Act (2009)  Regulations relating to Namibian Islands’ Marine Protected Area: Marine Resources Act, 2000 (2012) Dumping At Sea Control Act  Provide for the control of dumping of substances in Act No. 73 of 1980 the sea  Provides for permits to be issued to allow dumping at sea of scheduled substances Road Traffic and Transport Act  Provides for the control of traffic on public roads and Act No. 52 of 1999 Government Notice No the regulations pertaining to road transport 282 of 1999

Road Traffic and Transport Regulations  Prohibits the transport of goods which are not safely Government Notice No 53 of 2001 contained within the body of the vehicle; or securely fastened to that vehicle, and which are not properly protected from being dislodged or spilled from that vehicle.

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Law Key Aspects Petroleum Products and Energy Act  Regulates petroleum industry Act No. 13 of 1990, Government Notice No. 45  Makes provision for impact assessment of 1990  Petroleum Products Regulations (Government Notice No. 155 of 2000) o Prescribes South African National Standards (SANS) or equivalents for construction, operation and decommissioning of petroleum facilities (refer to Government Notice No. 21 of 2002) The Water Act  Remains in force until the new Water Resources Act No. 54 of 1956 Management Act comes into force  Defines the interests of the state in protecting water resources  Controls the disposal of effluent  Numerous amendments Water Resources Management Act  Provide for management, protection, development, Act No. 11 of 2013 use and conservation of water resources  Prevention of water pollution and assignment of liability  Not in force yet Marine Resources Act  Prevents the discharge of anything that may be Act No. 27 of 2000 injurious to marine resources or may disturb ecological balance in any area of the sea or which may detrimentally affect the marketability of marine resources, or which may hinder their harvesting. Aquaculture Act (2002)  Provides for water quality monitoring to protect aquaculture activities Marine Traffic Act  Regulate marine traffic in Namibia Act No. 2 of 1981

Local Authorities Act  Define the powers, duties and functions of local Act No. 23 of 1992, Government Notice No. authority councils 116 of 1992  Regulates discharges into sewers

Regional Councils Act  Sets out the powers, duties, functions, rights and Act No. 22 of 1992 obligations of Regional Councils.  Provides the legal basis for the drawing up of Regional Development Plans. Public Health Act  Provides for the protection of health of all people Act No. 36 of 1919

Public and Environmental Health Act  Provides a framework for a structured more uniform Act No. 1 of 2015, Government Notice No. 86 public and environmental health system, and for of 2015 incidental matters  Deals with Integrated Waste Management including waste collection disposal and recycling; waste generation and storage; and sanitation.

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Law Key Aspects Atomic Energy and Radiation Protection  Provide for adequate protection of the environment Act and of people in current and future generations Act No. 5 of 2005, Government Notice No. 50 against the harmful effects of radiation by controlling and regulating the production, of 2005 processing, handling, use, holding, storage, transport and disposal of radiation sources and radioactive materials.  Provides for authorisation, licences and registrations with regard to import into or export from Namibia any radiation source or nuclear material or transport any radiation source or nuclear material  Provides for regulations (Government Notice No. 221 of 2011) with regard to radiation protection and waste disposal. National Heritage Act of Namibia  Provides for the protection and conservation of Act No. 27 of 2004 places and objects of heritage significance and the registration of such places and objects  Defines as protected any remains of human habitation or occupation that are 50 or more years old found on or beneath the surface on land.  Provides for reporting of heritage finds, issuing of permits, and archaeological impact assessments. The National Monuments Act of Namibia  No person shall destroy, damage, excavate, alter, Act No. 28 of 1969 remove from its original site or export from Namibia: o any meteorite or fossil; or o any drawing or painting on stone or a petroglyph known or commonly believed to have been executed by any people who inhabited or visited Namibia before the year 1900 AD; or o any implement, ornament or structure known or commonly believed to have been used as a mace, used or erected by people referred to in paragraph (b); or o the anthropological or archaeological contents of graves, caves, rock shelters, middens, shell mounds or other sites used by such people; or o e) any other archaeological or paleontological finds, material or object; except under the authority of and in accordance with a permit issued under this section. Labour Act  Provides for Labour Law and the protection and Act No 11 of 2007, Government Notice No. 236 safety of employees of 2007  Labour Act, 1992: Regulations relating to the health and safety of employees at work (Government Notice No. 156 of 1997) Atmospheric Pollution Prevention  Governs the control of noxious or offensive gases Ordinance  Prohibits scheduled process without a registration Ordinance No. 11 of 1976 certificate in a controlled area  Requires best practical means for preventing or reducing the escape into the atmosphere of noxious or offensive gases produced by the scheduled process Hazardous Substances Ordinance  Applies to the manufacture, sale, use, disposal and Ordinance No. 14 of 1974 dumping of hazardous substances as well as their import and export  Aims to prevent hazardous substances from causing injury, ill-health or the death of human beings

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Law Key Aspects Pollution Control and Waste Management  Not in force yet Bill (draft document)  Provides for prevention and control of pollution and waste  Provides for procedures to be followed for licence applications Integrated Coastal Zone Management Bill  Aims at coastal management and give effect to (2014) Namibia’s obligations in terms of international law regulating coastal management  Not adopted yet Draft Wetland Policy of 2003  Considering the Second Lagoon, the Wetland Policy of 2003 is of importance and includes:  Protection and Conservation of wetlands and ecosystems. Prevention and Combating of Pollution of  Provides for the prevention of pollution of the sea the Sea by Oil Act, 1981 (Act No. 6 of 1981) where oil is being or is likely to be discharged Prevention and Combating of Pollution of  Amends the Prevention and Combating of Pollution the Sea by Oil Amendment Act (No. 24 of of the Sea by Oil Act of 1981 to be more relevant to 1991) Namibia after independence

Table 3. Relevant Multilateral Environmental Agreements for Namibia and the Development Agreement Key Aspects

Stockholm Declaration on the Human  Recognizes the need for a common outlook and Environment, Stockholm 1972. common principles to inspire and guide the people of the world in the preservation and enhancement of the human environment. 1985 Vienna Convention for the  Aims to protect human health and the environment Protection of the Ozone Layer against adverse effects from modification of the Ozone Layer are considered.  Adopted to regulate levels of greenhouse gas concentration in the atmosphere. United Nations Framework Convention  The Convention recognises that developing countries on Climate Change (UNFCCC) should be accorded appropriate assistance to enable them to fulfil the terms of the Convention. Convention on Biological Diversity, Rio  Under article 14 of The Convention, EIAs must be de Janeiro, 1992 conducted for projects that may negatively affect biological diversity. Benguela Current Convention of 2013  The Convention is a formal treaty between the governments of Angola, Namibia and South Africa that sets out the countries' intention "to promote a coordinated regional approach to the long-term conservation, protection, rehabilitation, enhancement and sustainable use of the Benguela Current Large Marine Ecosystem, to provide economic, environmental and social benefits." International Convention on Oil  International maritime convention establishing Pollution Preparedness, Response and measures for dealing with marine oil pollution Cooperation of 1990 incidents nationally and in co-operation with other countries. National Marine Pollution Contingency  Coordinated and integrated national system for Plan of 2017 dealing with oil spills in Namibian waters.

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UN Convention for the Prevention of  Concerns itself with the protection of marine fauna Marine Pollution from Land-based and flora by preventing marine pollution from land- Sources based sources.  Contracted parties, are committed to take all possible steps to prevent pollution of the sea as well as the direct or indirect introduction of substances or energy by humans into the marine environment resulting in such adverse effects as harm to living resources and to marine ecosystems, hazards to human health, damage to services/ facilities or interference with other legitimate uses of the area. Abidjan Convention of 1981  The Convention for Cooperation in the Protection, Management and Development of the Marine and Coastal Environment of the Atlantic Coast of the West, Central and Southern Africa Region  Provides an overarching legal framework for all marine-related programmes in West, Central and Southern Africa. International Convention for the  Dealing with the prevention of pollution of the sea Prevention of Pollution from Ships by oil, sewage and garbage from ships. (MARPOL 73/78) IMO Guidelines on Marine Security:  Legislative framework for maritime security issues. International Ship and Port Facility  Aimed at Government, Port Authorities and ISPS Code shipping companies. IMO Biofouling Guidelines  Guidelines for the control and management of ships’ biofouling to minimize the transfer of invasive aquatic species

Table 4. Standards or Codes of Practise Standard or Code Key Aspects South African National Standards  The Petroleum Products and Energy Act prescribes (SANS) SANS standards for the construction, operations and demolition of petroleum facilities.  SANS 10131 2004: is specifically aimed at above- ground storage tanks for petroleum products  Provide requirements for spill control infrastructure

Namport Specifications and Legislation  Enforced Standards and Codes which governs construction and operations relating to the port. The project is listed as an activity requiring an environmental clearance certificate as per the following points from Section 9 of Government Notice No. 29 of 2012:  9.1 “The manufacturing, storage, handling or processing of a hazardous substance defined in the Hazardous Substances Ordinance, 1974.”  9.2 “Any process or activity which requires a permit, licence or other form of authorisation, or the modification of or changes to existing facilities for any process or activity which requires an amendment of an existing permit, licence or authorisation or which requires a new permit, licence or authorisation in terms of a law governing the generation or release of emissions, pollution, effluent or waste.”  9.4 “The storage and handling of a dangerous goods, including petrol, diesel, liquid petroleum gas or paraffin, in containers with a combined capacity of more than 30 cubic metres at any one location.”  9.5 “Construction of filling stations or any other facility for the underground and aboveground storage of dangerous goods, including petrol, diesel, liquid, petroleum, gas or paraffin.”

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6 ENVIRONMENTAL CHARACTERISTICS This section lists pertinent environmental characteristics of the study area and provides a statement on the potential environmental impacts on each. For p-purposes of this section, it is assumed that both the RCC Yard and the industrial yard will be utilised and that both rail and road transport is possible.

LOCALITY AND SURROUNDING LAND USE The locations of the RCC yard and the Industrial Yard (erven 2040, 2041 and 2042 within the new industrial area of Lüderitz) are indicated in Figure 1 and Figure 6. Access to the sites are gained from the B4 Main Road. To the south of the Industrial Yard is the Natis Licencing department while all other neighbouring properties are industrial erven owned by the town council. One of these erven hosts the fire brigade and all other erven are undeveloped. No active neighbours are present around the RCC yard. The proposed route through town and to the port area is surrounded by mixed land-use. The route follows Old Bay Road into Lüderitz before joining up with Bismarck Street, which leads up to the gate of the port. Along the way, the route passes the Helen van Rhijn Primary School, residential properties, tourist accommodation, restaurants and various business. There are no heritage or cultural sites located in the industrial area and in the harbour, but the built-up area surrounding the harbour, and sections along Bismarck Street, are considered to be of heritage value requiring protection (see section 6.9) (SPC 2015). In Ariamsvlei all handling of ore will occur at the TransNamib rail siding which is located and surrounded by land owned by TransNamib (Figure 8).

Figure 6. Project Location in Relation to Lüderitz Townlands and Transport Infrastructure

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Figure 7. Land Use along Transport Route

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Figure 8. TransNamib Railway Yard and Siding in Ariamsvlei

Photo 1. Industrial Yard and view to North Photo 2. Neighbouring properties to the west of the Industrial Yard and Fire Brigade

Photo 3. View of Industrial Yard and Photo 4. View of Industrial Yard and Towards the South Towards the East

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Photo 5. RCC Yard Photo 6. Diesel Storage Tanks at RCC Yard

Photo 7. Existing Buildings to be Renovated Photo 8. Existing Buildings to be Renovated at RCC Yard at RCC Yard

Implications and Impacts In terms of locality and surrounding land-use of the yard, operations will fall outside of Lüderitz (RCC Yard) and within the industrial area (Industrial Yard) where impacts will be limited. Impacts can however be expected in terms of the B4 junctions, the rail level crossings in town, the street network in Lüderitz, as well as the various properties along the proposed route. Impacts will mostly be related to noise, traffic and the potential generation of dust. Activities at the

CLIMATE Lüderitz is located on the Namibian coastline in the arid Namib Desert. The arid conditions are as a result of dry descending air and upwelling of the cold Benguela Current. As a result, thick fog or low stratus clouds are a regular occurrence in Lüderitz. This is due to the influence of the Benguela Current and forms a major source of water for the flora in the Namib Desert. Namibia is situated within an anti-cyclone belt of the southern hemisphere. Winds generated from the high-pressure cell over the Atlantic Ocean blow from a southerly direction when they reach the Namibian coastline. As the Namibian interior is warm (particularly in summer), localised low-pressure systems are created which draws the cold southerly winds towards the inland desert areas. These winds manifest themselves in the form of strong prevailing south to south-westerly winds, which range from an average of 20 knots (37 km/h) during winter months to as high as 60 knots (120 km/h) during the summer. Daily fluctuations in wind speed are characterised by calmer winds in the morning with strong wind from late morning to later afternoon. During winter, the east winds generated over the hot Namib Desert have a strong effect on temperature, resulting in temperature in excess of 30C and tend to transport plenty of sand. Rainfall is typically low with high variability of 80% to 90%. This results in average annual rainfall figures between 0 and 50 mm. Occasional however, high rainfall events do occur. One

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such occasion was when 102 mm of rain was recorded at Lüderitz between 16 and 23 April 2006 (Eckardt et al. 2012). Table 5 below presents a summary of climate conditions in the Lüderitz area. Table 5. Summary of Climate Data (Digital Atlas of Namibia) Average annual rainfall (mm/a) 0-50 mm; half of the rainfall occurs from May to June Variation in annual rainfall (%) 80 – 90% Average annual evaporation 2,400-2,600 (mm/a) Water deficit (mm/a) 1,701-1,900 Average maximum: Between 24 °C in March/April and 19.3 °C in September Temperature Average minimum: Between 16.5 °C in February and 9.1 °C in August Average annual >16 °C Fog Approximately 126.7 days of fog per year Wind Prevailing wind strong south-westerly All year wind rose for the period 2 July 2011 to 30 May 2018 for the Lüderitz Airport (http://mesonet.agron.iastate.edu/)

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Figure 9. Wind Rose for the Months of January to June

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Figure 10. Wind Rose for the Months of July to December

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Implications and Impacts The strong south to south-westerly winds year round, and the southeast to east winds mainly in winter months, will carry any dust on site, manganese ore dust or other, for great distances. This relates to the bulk storage, transport and loading of ships. Dust plumes may have potential health impacts (humans and animals), environmental impacts (e.g. marine environment), as well as cause damage to infrastructure and create a negative visual impact. Strong winds can cause damage to infrastructure not constructed or anchored to withstand them. Ship loading by crane may also be impacted by strong winds. Although infrequent, heavy rainfall do occur occasionally. During such an event manganese ore and its dusts, or other potential pollutants such as spilled hydrocarbons, may be washed off the site and enter the environment. Infrastructure damage can also occur.

CORROSIVE ENVIRONMENT The corrosive environment of Lüderitz can be closely related to that of Walvis Bay. The corrosive environment, which may be attributed to the frequent salt-laden fog, periodic winds and abundance of aggressive salts (dominantly NaCl and sulphates) in the soil. The periodic release of hydrogen sulphide (H2S) from the ocean is expected to contribute to corrosion (see Table 6 for corrosion comparison data of Walvis Bay with other centres). The combination of high moisture and salt content of the surface soil can lead to rapid deterioration of subsurface metal (e.g. pipelines) and concrete structures. Chemical weathering of concrete structures due to the abundant salts in the soil is a concern. Table 6. Average annual corrosion rate for various metals in different locations in southern Africa (from Nickel Development Institute: Stainless Steels in Architecture, Building and Construction. http://www.nickelinstitute.org) Pretoria Durban Bay Cape Town Durban Bluff Walvis Bay Sasolburg CSIR Docks Environment Location Rural, Very Marine, Marine, Severe Severe Industrial Type low Moderate Moderate marine, marine, low high pollution Pollution Pollution moderate or pollution pollution low pollution SO2 Range 6-20 10-55 19-39 10-47 NA NA µg/m3 Fog NA NA NA NA 113.2 NA days/year Avg. 146 1,018 508 1,018 8 677 rainfall (mm/year) Relative 26-76 54-84 52-90 54-84 69-96 49-74 humidity range % Temp. 6-26 16-27 9-25 16-27 10-20 5-20 Range °C Unpainted 5-15 3-5 3-7 3-5 0.6-2 5.-15 galvanized steel life, years Annual Corrosion Rate (mm/year) Stainless Steel Type 316 0.000025 0.000025 0.000025 0.000279 0.000102 NA Type 304 0.000025 0.000076 0.000127 0.000406 0.000102 NA Type 430 0.000025 0.000406 0.000381 0.001727 0.000559 0.000107 Aluminium Alloys AA 93103 0.00028 0.00546 0.00424 0.01946 0.00457 0.00281

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AA 95251 0.00033 0.00353 0.00371 0.01676 0.00417 NA AA 96063 0.0028 0.00315 0.00366 0.020 0.00495 NA AA 96082 0.00033 0.00366 0.0034 0.02761 0.00587 NA AA 85151 NA NA NA 0.0246 0.00375 0.00317 Copper 0.00559 0.0094 0.00711 0.0246 0.0384 0.014 Zinc 0.0033 0.0231 0.029 0.111 NA 0.0152 Weathering 0.0229 0.212 0.0914 0.810 1.150 0.107 Steel Mild Steel 0.0432 0.371 0.257 2.190 0.846 0.150

Implications and Impacts Corrosion levels may be high and must be kept in mind when planning the construction and maintenance activities on site.

TOPOGRAPHY AND DRAINAGE The terrain around Lüderitz consist of a number of rocky outcrops with islands and peninsulas. Surface drainage is poorly developed in the area, due to the minimal amount of precipitation that occurs. The Atlantic Ocean, specifically Radford Bay, is situated approximately 2 km west- southwest of the Pektranam Logistics yard. The industrial area is located in an area with relatively flat topography sloping downwards to the southwest (Figure 11). Surface drainage from the site will be towards the south to southwest (Figure 12). The commercial harbour occur in the bay adjacent to the peninsula and has mostly been levelled to allow for port related operations. Surface drainage within the harbour is significantly influenced by anthropogenic activity, but in general would be towards the northeast into the bay. Implications and Impacts Although rainfall in the area is typically very low, the occasional flash floods do occur. Water runoff from the northeast may result in infrastructure damage on site or dispersal of pollutants, including manganese ore dust, into the environment.

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Figure 11. Topography

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Figure 12. Surface Drainage

GEOLOGY AND HYDROGEOLOGY The project location is dominated by a desert environment with crystalline rock outcrops of the Mesoproterozoic Era (Schneider et al., 2004). The Namib Sand Sea occur at it closest roughly 7 km to the northeast of the Project Area. The Namib Sand Sea consist of shifting dunes which were formed by eroded rock and sand that have been transported to the area by water and wind during the Quaternary Age. The regional geology consists out of rocks from the Namibian- and Mokolian Age (Figure 13). The Namibian Age rocks are comprised of dolomite, shale, schist, greenschist, ortho-/para-amphibolite, quartzite and / or basal mixtite from the Gariep Complex. Rocks from the Mokolian Age underlie the project area and are comprised of biotite-rich augen gneiss, granites, amphibolite and / or intrusives. The Mokolian Age rocks are the oldest in Namibia and form part of the Namaqua Metamorphic Complex Gordonia Subprovince, dating back to 1,200 to 1,460 Ma. Pegmatitic intrusions from the Doornpoort/Eskadorn Formation are common, but basic intrusions are rare (Siegfried, 1992/93). The structural geology in the study area is very complex due to numerous deformation events. Two major deformation events were identified in the region. A parallel series of normal faults trending north to south occur in the study area. Preferential weathering along these faults has resulted in inlets in the Lüderitz area. They trend roughly 300° and although not always traceable, are of similar orientation to many of the faults in the basement (Siegfried, 1992/93). There are no thrusts in the project area. The closest thrust structures is 9 km west of the project area and commonly strike north - south, having minor thrusts and splays associated with them. Groundwater flow would mostly be along fractures, faults (secondary porosity) and other geological structures present within the formations as well as through primary porosity in the unconsolidated top cover. It is expected that the groundwater flow will be in a western direction. Groundwater may be more saline in some areas due to its proximity to marine water. No boreholes are known to be present in the vicinity of the study area. The groundwater basin is known as the Namib Basin and the location falls outside any groundwater control area. However,

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groundwater remains the property of the Namibian Government. Lüderitz derives all of its water from the NamWater Koichab water supply scheme, approximately 100 km east of Lüderitz.

Figure 13. Geology Map Implications and Impacts The manganese ore may contain gangue minerals that could contain contaminants such as sulphur or harmful metals that is soluble in groundwater. Geological fractures underneath the site may act as pathways for the contaminants and contaminate the groundwater. Contaminants from the operational equipment on site may also reach groundwater through fractures in the subsurface rock.

PUBLIC WATER SUPPLY The NamWater Koichab water supply scheme supplies Lüderitz with potable water. It consists of about nine production boreholes, supplying groundwater from the alluvial aquifer formed in a paleo-channel of the Khoichab River. During 2017/2018 the actual volume of water sold by NamWater was 1,021,442 m3 (Figure 14). The potential supply of the scheme is 1,460,000 m3 (Figure 14). Based on the initial water use records of the period April to October 2018 there does not seem to be an increase in the demand for potable water. The average monthly water use for this period is 86,131 m3 compared to 86,678 m3 for the same period in 2017. Thus, currently there is a surplus of 438,558 m3 of potable water.

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Figure 14. NamWater Koichab Scheme Water Supply and Demand Statistics for the Last 26 years (source: NamWater 2018)

Implications and Impacts Domestic use of potable water at the storage yard and offices will minimally impact on potable water supply. Should dust suppression with potable water take place the pressure on this resource will increase slightly. However, a shortage of water is not expected to occur as a result of the project.

FAUNA AND FLORA The Lüderitz peninsula is part of the Succulent Karoo Biome with a succulent steppe vegetation type and dwarf shrubland structure (Digital Atlas of Namibia). The Succulent Karoo is a biodiversity hotspot and has the world’s richest succulent diversity which is also characterised by high reptile and invertebrate diversity (CEPF 2005). In Namibia, almost the entire Succulent Karoo Biome is protected in the Tsau //Khaeb National Park (Sperrgebiet National Park). The project location is situated outside of the Tsau //Khaeb National Park. The Lüderitz structure plan identified sensitive and no-go areas based on available information (SPC 2015). These areas are indicated in Figure 15. While most of the surroundings of Lüderitz are regarded as “tread light” areas, the rocky outcrops are typically regarded as no-go areas. This is mainly due to niche differentiation that is more pronounced in the rocky outcrops. Both proposed storage yards are west of such a no-go areas. Brown hyena, jackal, springbok, porcupines, ostriches and oryx are some of the larger animals that utilize the areas surrounding Lüderitz. Brown hyenas roam in the vicinity of the proposed storage yard, but tend to avoid areas of human movement. They do however cross the B4 Main Road. Along the length of the transport route through Namibia various animals occur and can be found crossing the roads. This include kudu (especially in mountainous areas), spotted hyenas, jackal, the wild horses of the Namib, as well as livestock such as donkeys and cattle.

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Figure 15. Tread Light and No-Go Areas (Lüderitz Structure Plan, SPC 2015)

Figure 16. Brown Hyena Territories and Movements (Lüderitz Structure Plan, SPC 2015)

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Implications and Impacts The Industrial Yard falls within an area designated for industrial purposes and is already disturbed while the RCC Yard is an existing facility with infrastructure. No further impact on the environment is expected on the sites. However, downwind areas may be affected by windblown dust. Namibia is rich in wildlife and animals like kudu, brown hyenas and the wild horses often cross the roads. The trucking of manganese ore from South Africa along the main roads may result in animal strikes which, apart from the negative impact on animal populations, also pose a danger to truck drivers and other users of the roads.

DEMOGRAPHIC AND ECONOMIC CHARACTERISTICS

Demographic Characteristics From 2001 to 2011, the Karas Region showed a population increase of 1.1% (Namibia Statistics Agency, 2011). The Namibian intercensal demographic survey of 2016 shows an annual population growth rate of 2% and estimates the population at 85,759 (Namibia Statistics Agency, 2017). This is slightly more than the Namibian intercensal growth rate of 1.9%. For the period 2001 to 2011, Lüderitz showed a decline in population size of 5.6% and had a population size of 12,537 in 2011 (Namibia Statistics Agency, 2011). The remoteness of Lüderitz and the lack of employment and economic diversification opportunities possibly contributed to this decline. This may have led to some inhabitants relocating to other urban centres offering better prospects. Lüderitz had an unemployment rate of 28.2% which was slightly lower than the rate of 32.2% of the Karas Region (Namibia Statistics Agency, 2011). Table 7. 2011 Demographic Characteristics of Lüderitz Bay, the Karas Region and Nationally (Namibia Statistics Agency, 2011) Lüderitz Karas Region Namibia Population (Males) 6,300* 37,400 1,021,912 Population (Females) 6,200* 37,000 1,091,165 Population (Total) 12,500 74,400 2,113,077 (85,759)** (2,324,388)** Unemployment (15+ years) N/A 32.9% 33.8% Literacy (15+ years) N/A 93.2% 87.7% Education at secondary level (15+ years) 50% 55.2% 51.2% Households considered poor N/A 15.3% 19.5% *Data available from preliminary results only (National Planning Commission, 2012) **Namibian inter-censal demographic survey of 2016 (Namibia Statistics Agency, 2017)

Implications and Impacts The project will create new jobs and sustain existing jobs at local, regional and national level.

The Port of Lüderitz Although Lüderitz Bay was first visited by Bartholomew Diaz in the late 15th century, it, apart from the Khoisan moving through, remained uninhabited until 1883 when it was founded as a trading post (Robertson et al. 2012). Eventually, it would be the discovery of diamonds and the lucrative fishing and crayfish industry that would lead to the growth in the town up to what is established there today. Lüderitz was thus ultimately first established as a harbour town, with the port being central to its economic activities and resource imports and exports. Road and rail infrastructure were historically constructed with the main aim of serving the port. Today the port remains central to the mining and fishing industries of southern Namibia and

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is one of the main direct and indirect economic drivers of the town. A total of 92 people are directly employed by Namport in Lüderitz. The current available bulk cargo handling capacity of the port is a bit more than 1,000,000 tons per annum. This translates to about three additional 30,000 ton bulk cargo ships per month that can be handled in the port. Implications and Impacts The port currently operates at about a third of its capacity in terms of bulk cargo handling. Initiating the manganese export project will allow the port to operate at full capacity. This will generate increased revenue and contribution to national treasury.

Mining Lüderitz thrived in the early 20th century mainly as a result of the diamond mining industry. Today however, the sustaining industries in Lüderitz include fishing, mariculture and tourism. Diamond mining continues to be a major part of the mining industry in southern Namibia and provides employment to a significant portion of the region’s population. However, Namdeb recently decided to put the Elisabeth Bay mine, the diamond mining operations closest to Lüderitz, under care and maintenance. As a result, approximately 85 families who were dependent on Namdeb employment at Elisabeth Bay, had to be relocated from Lüderitz (Pers. Comm. Lüderitz community members). Similarly, sub-contractors working at and for the mine became redundant, which in turn led to retrenchments. As such, a number of Lüderitz inhabitants fear that the loss in business opportunities from the mine, coupled with the reduction in the population with expendable income, will have significant economic impacts on the town’s welfare. Presently, the future of the mine is not known, but Namdeb intends to sell the mine should a buyer emerge. Second to diamond mining is zinc and lead mining activities at Rosh Pinah. During the period April 2016 to March 2017 156,458 tons of zinc product and 15,070 tons of lead concentrate were exported via the Port of Lüderitz. Zinc oxide is also imported in small quantities for refining purposes at the Rosh Pinah mines. The Rosh Pinah mines requires sulphur for their refining process and during the 2016/2017 period 92,078 tons of sulphur was imported via the port. The Port of Lüderitz therefore plays an essential role in the mining sector of southern Namibia. Implications and Impacts Since all mining products are transported to the Port of Lüderitz with trucks, a cumulative impact by traffic on the B4 Main Road and streets within Lüderitz is expected. Should the target of 1,000,000 tons of additional ore exports realise (jointly by Pektranam Logistics and other potential exporters of ore), the traffic impacts in Lüderitz will be very high with potential increase in accidents, road surface wear and tear, noise and air pollution being the most important impacts.

Fishing and Mariculture Currently, the majority of employment in Lüderitz is provided by the fishing industry, which mainly exports fisheries products to Europe. Lüderitz is well known for its rock lobsters, which is one of the key fisheries resources exploited here. The Namibian mariculture industry is centred on Walvis Bay and Lüderitz. In Lüderitz abalone and oysters are farmed mainly for international markets. During the 2016/2017 period, 21,034 tons of frozen fish was exported from the Port of Lüderitz. Based on the 2011 census results (Namibia Statistics Agency, 2011), 2,211 residents of the Lüderitz Constituency are employed in the agricultural and fisheries industry. Since agriculture is practiced in a very small area of this constituency, it is safe to say that most of the 2,211 workers are employed in the fishing industry.

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Implications and Impacts The trucking of manganese ore through town is not expected to impact on the local fishing industry per se. However, if dust is not contained during loading of the bulk cargo ship, the manganese ore dust may impact on fishing vessels at berth in the port, especially when north to north-westerly winds blow. This impact can include contamination of fish products being offloaded from the vessels.

Tourism Lüderitz continues to mainly depend on the same economic sectors as when it was established, being mining and fishing. However, tourism plays an important part in the local economy. The uniqueness of the town, the rich heritage of the old buildings, and most importantly the ghost town of Kolmanskop, are the main factors drawing tourists to Lüderitz. Unfortunately, the town is situated in what is ultimately a 125 km long cul-de-sac. This deters a large number of tourists visiting Namibia, from including Lüderitz in their itinerary. Namibia in its entirety are increasingly focussing on tourism and many residents of Lüderitz have turned to the tourism and hospitality sector. This includes operating various types of accommodation including back packers, self-catering, bed and breakfast, and hotel accommodation, as well as day excursions to Kolmanskop and the Sperrgebiet, dolphin cruises, and guided trips to the restricted areas of the historic diamond mining areas. During the period April 2015 to March 2016, 19 passenger ships called at the Port of Lüderitz. For the same period 2016/2017 it was seven and 2017/2018 nine passenger ships. These cruise liners either enter and berth inside the Port of Lüderitz or anchor outside in deeper waters and transport passengers with smaller crafts to the port. Lüderitz is now host to an annual international speed sailing event which attract speed sailors from around the world who attempts to break various records during a six week period. The crayfish festival, with the aim of boosting local enterprise and investment, is another annual event aimed at locals and tourists. Based on the 2011 census results (Namibia Statistics Agency, 2011), 229 residents of the Lüderitz Constituency are employed in the accommodation and food service industry. Due to the growth in the tourism sector, this number is now expected to be higher.

Photo 9. Tourist Accommodation in Bismarck Photo 10. Tourism Accommodation in Old Street Bay Road

Implications and Impacts The cumulative impact of truck movement through town may negatively impact on tourism by creating noise and increasing traffic congestion. Noise impacts will especially be a nuisance when ship loading takes place at night and trucks drive past accommodation establishments.

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CULTURAL, HERITAGE AND ARCHAEOLOGICAL ASPECTS Lüderitz is one of the oldest towns in Namibia and therefore hosts a number of historically important buildings. Lüderitz developed around the port area and thus the historic centre of the town is also situated around the port. The structure plan for Lüderitz (SPC 2015) identified the existing national monuments and different conservation grade categories of buildings as is indicated in Figure 17. The status of some of the buildings have however changed by 2018, with more buildings being declared national monuments. In light of the heritage value of the buildings, the structure plan states: “it is the opinion of the authors of this report that it would be preferred over the long term if energy is directed toward the development of a second port rather than the expansion of the existing port, as expansion of the existing port may result in the following; o Increase in road and rail traffic may cause disruption to the functioning of the existing town, which is in direct conflict with government and town initiative to promote tourism through capital investment programs. o As an integral part of the town’s urban fabric, further industrialisation of the existing port will adversely affect the character of Lüderitz. o The neighbourhoods directly surrounding the port are those of the greatest historic value, so any expansion into these areas would adversely affect the heritage value of the town.” A number of buildings has been declared National Monuments in Lüderitz and these include, among others, the Railway Station Building in Bahnhof Street, the German Lutheran Church in Kirch Street, the Deutsche Africa Bank Building and Krabbenhӧft und Lampe Building in Bismarck Street.

Photo 11. Krabbenhӧft und Lampe Building Photo 12. Deutsche Africa Bank Building

Implications and Impacts The cumulative impact of trucks moving through the historic town centre, currently the only possible route to the port, will impact on the cultural and historically significant heritage areas of the town. A possibility of vibration and air pollution related damage to old and new buildings exist.

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* Conservation status include buildings declared as National Monuments and buildings with highest conservation status (blue / grade A) to lower conservation status (yellow / grade D) and no conservation status (white). Figure 17. Significant Heritage Buildings in Lüderitz with the Proposed Route to the Port indicated in Purple (adapted from SPC 2015)

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7 PUBLIC CONSULTATION Consultation with the public forms an integral component of an environmental assessment 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 facility and to identify additional issues which they feel should be addressed in the environmental assessment. Public participation notices were advertised twice in two weeks in the Market Watch Section published in the national newspapers: Republikein, Algemeine Zeitung and Namibian Sun on 19 and 26 November 2018. A site notice was placed on site and notification letters delivered to various ministries, the town council, and members of the Lüderitz community (business and residential) along the potential affected transport routes through town. In addition e-mail notifications were also sent to various individuals including key staff at ministries (Fisheries and Marine Resources, Environment and Tourism, Works and Transport), parastatals (Namport, Roads Authority, NamWater, etc.), the chairman of the Lüderitzbucht Foundation, the chairman of the Port Users Association, the Town Council, and a number of private consultants. Through communications, all interested and affected parties were invited to a public meeting which was held in Lüderitz on the 3rd of December 2018. During December 2018, another company started offloading manganese ore at the rail siding outside of Lüderitz. This was done without an environmental clearance certificate and without proper consultation with the Lüderitz community. It resulted in an outcry from the residents and a lot of publicity on social media and various newspapers. In response, Pektranam Logistics requested a second public meeting which was held on 29 January 2019. The aim of the meeting was to provide the Lüderitz community with additional information and clarifications pertaining to the proposed manganese ore export project, and to provide information on the commitments of Pektranam Logistics to conduct the manganese ore export project in a safe and responsible manner. See Appendix A for a complete account of the public participation processes and the minutes of all meetings and correspondence received. Throughout the public consultation process, contradicting opinions and views were received from interested and affected parties. A number of individuals from the business community of Lüderitz expressed the need for new economic drivers to be stablished. This even more so in the light of the recent closure and uncertain future of the Elisabeth Bay diamond mine, on which many individuals and businesses depended for their livelihoods. On the other hand, a number of individuals expressed their concern about potential negative impacts of the project on the town, to such an extent that they would like to see this project being prohibited. There is also the group that appreciates the potential benefits of the project, and as such would like to see it being implemented, but at the same time is concerned about the potential negative impacts. Based on experience with similar projects, both in Lüderitz and elsewhere, members of the community objecting against a specific project often are more outspoken, and provide more comment and input, than those for the project. As such the environmental assessment can sometimes present a skewed opinion from the general public. Based on personal communication with members of the Lüderitz community, inclusive of commercial enterprises and tourism and hospitality facilities, the current assessment will also be a skewed representation of the expectations of the Lüderitz community, if only written comments and the outcome of the public meeting are considered. This said, the authors of this report do recognise both the positive and negative impacts associated with the project and will attempt an objective representation of the concerns, aspirations and expectations of consulted IAPs. Section 8 provides a detailed description of the potential impacts, both positive and negative as raised by the IAPs and determined by the consultant.

8 MAJOR IDENTIFIED IMPACTS During the scoping exercise a number of potential environmental impacts have been identified. The following section provides a detailed description of the most important of these impacts while Section 9 provides an assessment of these impacts and presents a management plan to prevent or mitigate negative effects and promote positive outcomes.

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EMPLOYMENT Based on the previous national census, Lüderitz has an unemployment rate of 28.2%. Thus, there is a definite need for more employment opportunities in Lüderitz. In terms of direct employment opportunities, Pektranam Logistics will employ up to 16 local Namibians (12 in Lüderitz and 4 in Ariamsvlei), if the required skills are locally available. This will include both unskilled and skilled labourers. In addition truck drivers will be contracted to transport ore to the port. Should road transport from South Africa realise, the contract will be outsourced to one or more Namibian companies. Since the manganese import will be an ongoing process through the entire month, trucks and their drivers will be dedicated to this particular project. Up to 70 jobs as truck drivers will be created (or sustained) per 30,000 ton shipment, but this depends on the volumes of ore to be transported by road. In addition to the direct jobs a number of indirect jobs will be sustained or created. This include: employment within the stevedore and logistics sector; engineering, mechanical repairs, parts supply and maintenance; port operations; fuel and truck port supply; etc. During operations skills development and training will be a benefit to direct and indirect employees. Each employee will become financially more resilient and have more spending power in their hometowns or, in case of truck drivers, on their routes. During the development phase local and regional construction and building supply industries will temporarily benefit from construction activities associated with the establishment of the bulk storage yard(s). This include supply of materials like sand, bricks, pavers, fencing material, plumbing, etc.

ECONOMIC IMPACTS The economy of Lüderitz rests on three core industries namely fishing, mining and tourism. Diversification of economy is crucial in establishing economic resilience within the town and region as a whole. A reduction in productivity of either one of the three sectors (fishing, mining and tourism) can have significant economic impacts in the town. This has already been seen with the recent shutdown of the Elisabeth Bay diamond mine. Economic benefits will be direct and indirect in nature. It will also realise at local, regional and national level. Income will increase proportionally for each additional shipment of ore per month. Salaries, fuel and fuel related levies, maintenance and repairs, income tax, etc. will be indirect financial spinoffs. A portion of the Lüderitz and national population will have increased spending power which in turn helps to sustain various business.

TOURISM IMPACTS Noise will be the major negative impact on tourism, especially at accommodation establishments situated along or near the proposed transport route through Namibia and the town. Since it will be a 24 hour operation, for maximum nine days a month (if three shipments realise), noise impacts will also be experienced at night. The increased number of trucks travelling along Bismarck Street may also have some impact on tourists visiting the street and shops. It is likely that tourists may however also expect industrial and transport activities in Lüderitz since these are typically associated with harbour towns. Tourists visiting nearby Kolmanskop, Diaz Point, etc. will be minimally impacted by the operations that occur in town, but increased rail or road traffic between Aus and Lüderitz may be a nuisance to visitors of Kolmanskop and Lüderitz. What should be taken into consideration is that the B4 road and rail were constructed decades ago as links between the interior and the Port of Lüderitz. It can thus reasonably be expected that transport along these corridors will increase as the demand for port services increase.

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AIR QUALITY RELATED HEALTH IMPACTS Manganese is a heavy metal found naturally occurring in the earth’s crust in compound form as for example oxides or carbonates (Beukes et al. 2016). It is a trace element required for normal physiological function. The Tolerable Upper Intake Level for 70 kg adults is 11 mg manganese per day through ingestion of its inorganic forms (ATSDR 2012). Excessive exposure by ingestion or inhalation of manganese may result in adverse effects in humans and animals (see for example Zeng et al. 2009; Duka et al. 2011; ATSDR 2012). As with all substances, the likelihood of manifestation of toxic effects depends on the dose, duration and route of exposure. Typical sources of exposure to manganese include food, drinking water, cigarette smoke, workers in manganese mine operations, and industrial exposure (manganese refineries, welding, sintering, etc.). The major adverse effects that can be caused by excessive manganese exposure are neurological impairment (e.g. slow movements or reaction times and Parkinson’s-like symptoms), reproductive abnormalities and lung irritation that can lead to pneumonia (EPA 2003; WHO 2003; ASTDR 2012). Scientific evidence and case studies indicating the toxicity of manganese are mostly limited to scenarios where exposure is linked to ferroalloy smelters, sinters, welding operations and workers directly involved with mining activities (see for example the reviews by Santamaria 2008 and O’Neal and Zheng 2015). These are instances of chronic, and typically high dose, exposure. Severe instances of neurological impairment only becomes evident at levels twenty thousand to a million times higher than normal concentrations of manganese in air (ATSDR 2012). While the evidence for deleterious health effects has well been described for workers exposed to high levels of manganese in for example refineries and battery plants, data on acute high dose exposure to specifically manganese ore dust seems not to be available. One study conducted by Duka et al. (2011), assessed children living around an open manganese mine in Ukraine for chronic manganese toxicity. The sample group of 683 children in the manganese mine area were compared with 56 children from a reference area remote from mining activities. The study found that children near the mine had, among others, statistically significant more incidences of growth and developmental problems, which positively correlated with manganese concentrations in hair samples. The authors thus concluded that there are definite deleterious health consequence when living in a manganese mining area. However, although the conclusion of the paper only refers to a “mining area”, it does state in its methods, that a sinter plant (agglomeration plant) is also present. Thus, once again the conclusions are not based on low level ore dust exposure only, but possibly also on the presence of manganese fumes originating from the sinter plant. Given the existing information on manganese and its dose-response relationships in terms of exposure, it can be concluded that not enough scientific evidence is available on the potential low dose exposure effects that will be associated with the transport and handling of manganese ore with a 27% to 40% manganese content. Ultimately, there will be a number of factors that will determine the level of manganese exposure. These include:  Workers vs. residents  The concentration of actual elemental manganese in the ore  The volume and particle size of the wind dispersible dust present in the ore  The type concentration of gangue materials present in the ore  The strength and direction of the wind  The effectiveness of dust control measures (i.e. dust suppression, use of tarpaulins, wind breaks, etc.) Based on existing information, it is safe to say that acute exposure to specifically the manganese component of ore dust will not have severe or lasting negative effects. The human body has the ability to rid itself of manganese and the effects of exposure are thus mostly reversible (Duka et al. 2011; ASTDR 2012). The half-life of manganese in blood is for example less than 5 minutes, while in tissue it can be between 36 and 41 days (Coombs and Schillack 2005).

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Airborne exposure limits to manganese dust set by various countries and organisations differ. The OSHA and Namibian Labour Act regulations set an exposure limit of 5 mg/m3 manganese per 8 hour exposure period for workers. The Agency for Toxic Substances and Disease Registry (USA) set the Minimum Risk Level of manganese in air for chronic exposure (365 days) at 0.0003 mg/m3 while the WHO (2001) set the exposure level at 0.00015mg/m3. Given the potential toxicity of the manganese in the ore, the precautionary approach should be followed and all operations should be aimed at creating zero dust. Apart from manganese in ore dust, silicates and asbestos may be present that can also impact on the health of workers and residents, should it not be successfully contained. Thus even more so the need for zero dust emissions. In addition to possible ore dust impacts, exhaust gases may also deteriorate air quality in town. Exhaust gases typically contain nitrogen (67%), carbon dioxide (12%), Water (11%), oxygen (9%) and pollutant emissions (1%) that include carbon monoxide, hydrocarbons, nitrogen oxides, sulphur dioxide and particulate matter (Resitoglu and Altinisik. 2015). While carbon dioxide contributes to the greenhouse effect and climate change, it is the 1% pollutant emissions that are typically a health concern. Due to the frequent strong winds of Lüderitz, these gases and particulate matter are expected to disperse quickly, but may accumulate during periods of no or very calm winds.

MARINE IMPACTS Manganese occurs naturally in the marine environment and is required in trace amounts by marine organisms. However, excessive exposure to especially dissolved manganese leads to bio- concentration of the metal in marine organisms (Pinsino et al. 2012). This is especially the case in marine invertebrates where bio-concentration factors (BCF) of between 10,000 and 40,000 have been recorded (ATSDR 2008). This means that the concentration of manganese in invertebrates is between 10,000 and 40,000 times higher than the surrounding seawater. Manganese uptake by organisms in marine environments increase with increased water temperature and salinity and decreased pH (Baden et al. 1995). Marine invertebrates like crustaceans and molluscs are sensitive to manganese exposure (Pinsino et al. 2012). Therefore the abalone and oyster mariculture industry as well as the rock lobsters in the Lüderitz Rock Lobster Sanctuary will be at risk if significant manganese pollution of the environment occurs. In marine organisms, excessive exposure to manganese also results in neurological and immune system impacts. Studies have for example shown that manganese typically accumulate in the haemolymph and body tissue of lobsters and that it results in impairment of antennular flicking activity which in turn leads to disorientation and reduced food location ability (Baden & Neil, 1998; Krång and Rosenqvist, 2006). From literature it seems evident that manganese accumulation within an organism’s organs eventually reaches a plateau. However, the rates of accumulation increase exponentially with increased exposure concentrations. Thus, at low manganese concentrations in water, the plateau will only be reached after weeks of chronic exposure. At high concentrations the plateau are reached very fast and in a species of bivalve it was shown to be reached within three days (Pinsino et al. 2012). Luckily, the rate of removal of manganese from the tissues of the organisms also occur rapidly once exposure to manganese cease. It is only in the shells of marine invertebrates where manganese may remain for longer periods. However, sequestration of toxins in shells is a common safety mechanism employed to prevent harmful effects of exposure in these animals. The Benguela Current Large Marine Ecosystem (BCLME) water and sediment quality guidelines makes no provision for manganese. However, the World Health Organisation has set the Hazardous Concentration 5 value at 50% confidence (HC5(50)) for manganese in marine water at 0.4 mg/litre. This is the “hazardous concentration to protect 95% of species with 50% confidence — a “safe” value to ensure protection against chronic toxicity for most marine species” (Howe et al. 2004). However, acute exposure values may be set much higher, since organisms’ seems to be able to rid themselves of manganese quite rapidly after exposure.

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TERRESTRIAL ECOLOGY IMPACTS The bulk storage yards are located in the Succulent Karoo Biome, in an area sensitive to habitat disturbance. The roads leading to the yards have already been established, but may need some upgrading, but no further impact is expected as long as activities do not infringe on nearby undisturbed areas. The Industrial Yard itself still contain some natural vegetation, but has been earmarked for industrial use and it is assumed that for zoning purposes, sensitive areas has already been identified and set aside. Impacts in the terrestrial environment as a result of the project could result from the following:  Windblown ore dust contaminating the environment  Off-road driving in sensitive habitats  Poaching or illegal collection of plants  Truck / train – wild animal collisions. Brown hyenas and the wild horses of the Namib are the most serious concern between Aus and Lüderitz.  Bird impacts where bright lights are used at night that could disorientate birds flying at night e.g. flamingos

TRAFFIC IMPACTS For rail transport minor traffic impacts are expected and is limited to a number or rail level crossings along the rail route. However the frequency of trains as well as the length of the trains required are very limited and the impact is expected to be low. Trucks transporting manganese ore from South Africa will follow the B3, B1 and B4 Main Roads. Road use statistics for light motor vehicles and heavy motor vehicles respectively, for 2015, are presented in Table 8. More recent data will only be available later in 2019 from Roads Authority. Table 9 presents the increase in heavy motor vehicle traffic on these sections for different scenarios of transport and shipment of manganese ore. This include transporting the ore in either three or four weeks to Lüderitz, as well as one shipment of 30,000 tons of ore per month versus four shipments totalling 120,000 tons. Additional traffic are presented as both inbound (fully loaded) and outbound (likely to be empty) trucks. Table 8. Road Use Statistics of 2015 (Source: Roads Authority) Vehicles per Day Section Light Motor Heavy Motor Vehicles Total Vehicles B3 Ariamsvlei - Karasburg 180 160 340 Karasburg - Grünau 210 180 390 B1 Grünau - M26 Turnoff 330 270 600 M26 Turnoff - 335 270 605 Keetmanshoop B4 Keetmanshoop - Seeheim 300 90 390 Seeheim - Goageb 260 85 345 Goageb - Aus 180 75 255 Aus - Lüderitz 167 69 236

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Table 9. Additional Heavy Motor Vehicle Road Use Predictions Based on Pektranam Logistics’ proposal for up to Three Shipments of 30,000 ton Manganese Ore per Month Heavy Motor Vehicles Heavy Motor Vehicles Heavy Motor Section (Additional 80 trucks (Additional 240 trucks Vehicles (2015) per day over 3 weeks) per day over 3 weeks) (Vehicles per Vehicles per Day

Day) (% Increase from 2015) B3 240 480 Ariamsvlei - Karasburg 160 (50) (200) 260 500 Karasburg - Grünau 180 (44) (178) B1 350 590 Grünau - M26 Turnoff 270 (30) (119) M26 Turnoff - 350 590 270 Keetmanshoop (30) (119) B4 170 410 Keetmanshoop - Seeheim 90 (89) (356) 165 405 Seeheim - Goageb 85 (94) (376) 155 395 Goageb - Aus 75 (107) (427) 149 389 Aus - Lüderitz 69 (116) (464)

Due to the significant increase in slower moving heavy motor vehicles on these roads the likelihood for accidents will increase. Although most of the proposed roads are relatively flat and straight, light motor vehicle drivers may get impatient when frequently, or for long periods, being held up behind the trucks. This may lead to irresponsible overtaking of trucks and result in accidents.

HERITAGE IMPACTS Lüderitz is well known for its old buildings dating back to the beginning of the 20th century. Many of these being situated in the town centre neighbouring the port. Currently, there is no route to the port available that avoids the heritage rich town centre. Possible impacts on the buildings (old and new) include structural damage due to vibration impacts as well as potential discoloration, material loss, structural failure and soiling of buildings as a result of exhaust gases (Watkiss et al. 2000, Rao et al. 2015). Of these structural failure is unlikely. However, acidic deposition as a result of sulphur dioxide and nitrogen oxides can cause corrosion of calcareous stone, mortar, paint, concrete, aluminium and galvanised steel (Watkiss et al. 2000). Particulate matter in exhaust gasses may lead to soot build-up or soiling of the buildings. Nitrogen oxides, in the presence of sunlight, also reacts with reactive organic compounds (e.g. carbon dioxide and carbon monoxide) to form ozone. A high ozone level is also detrimental to modern paints and polymers like plastic and rubber (Brimblecomb and Grossi 2010). Ozone also seems to act synergistically with sulphur dioxide (Watkiss et al. 2000). Corrosion rates in Lüderitz, being in a coastal environment, is further expected to be 10 to 100 times higher as a result of the presence of sodium chloride (sea salt) in the air (Watkiss et al. 2000).

HYDROCARBON POLLUTION This section describes the most pertinent pollution impacts that can potentially emanate from the proposed diesel storage facility and its operations. Groundwater and soil pollution from

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hydrocarbon products are major issues associated with the storage and handling of such products. Both forms of pollution are prohibited in Namibia. When a release of hydrocarbon products takes place to the soil, the Light Non-Aqueous Phase Liquids (LNAPL) will infiltrate into the soil and start to migrate vertically. LNAPL transport in the subsurface environment occurs in several phases, including bulk liquid, dissolved, and vapour phases. Mechanisms that influence transport include the physicochemical properties of the specific compounds present such as density, vapour pressure, viscosity, and hydrophobicity, as well as the physical and chemical properties of the subsurface environment, including geology and hydrogeology. Hydrocarbon liquids are typically complex mixtures composed of numerous compounds, each with its own individual physicochemical and, therefore, transport properties. If small volumes of spilled LNAPL enter the unsaturated zone (i.e. vadose zone), the LNAPL will flow through the central portion of the unsaturated pores until residual saturation is reached. A three-phase system consisting of water, LNAPL, and air is formed within the vadose zone. Infiltrating water dissolves the components within the LNAPL (e.g., benzene, xylene, and toluene) and transports them to the water table. These dissolved contaminants form a contaminated plume radiating from the area of the residual product. Many components found in LNAPL are volatile and can partition into soil air and be transported by molecular diffusion to other parts of the aquifer. As these vapours diffuse into adjoining soil areas, they may partition back into the water phase and transfer contamination over wider areas. If the soil surface is relatively impermeable, vapours will not diffuse across the surface boundary and concentrations of contaminants in the soil atmosphere may build up to equilibrium conditions. However, if the surface is not covered with an impermeable material, vapours may diffuse into the atmosphere. If large volumes of LNAPL are spilled, the LNAPL flows through the pore space to the top of the capillary fringe of the water table. Dissolved components of the LNAPL precede the less soluble components and may change the wetting properties of the water, causing a reduction in the residual water content and a decrease in the height of the capillary fringe. Since LNAPL are lighter than water, it will float on top of the capillary fringe. As the head formed by the infiltrating LNAPL increases, the water table is depressed and the LNAPL accumulate in the depression. If the source of the spilled LNAPL is removed or contained, LNAPL within the vadose zone continue to flow under the force of gravity until reaching residual saturation. As the LNAPL continue to enter the water table depression, it spread laterally on top of the capillary fringe. The draining of the upper portions of the vadose zone reduces the total head at the interface between the LNAPL and the groundwater, causing the water table to rebound slightly. The rebounding water displaces only a portion of the LNAPL because the LNAPL remain at residual saturation. Groundwater passing through the area of residual saturation dissolves constituents of the residual LNAPL, forming a contaminant plume. Water infiltrating from the surface also can dissolve the residual LNAPL and add to the contaminant load of the aquifer. Decrease in the water table level from seasonal variations may lead to dropping of the pool of LNAPL. If the water table rises again, part of the LNAPL may be pushed up, but a portion remains at residual saturation below the new water table. Variations in the water table height, therefore, can spread LNAPL over a greater thickness of the aquifer, causing larger volumes of aquifer materials to be contaminated. Hydrocarbon products do biodegrade in the subsurface, although the effectiveness of this process depends on subsurface conditions. The type of hydrocarbon product plays a further role in the duration of biodegradation, with the longer chain components taking much longer to biodegrade.

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Figure 18. Conceptual LNAPL Release to the Vadose Zone

NOISE IMPACTS Construction related activities may result in temporary noise producing activities. Some noise will exist due to the heavy motor vehicles accessing the site and moving through town for ore delivery as well as the operations of front-end loaders and forklifts.

FIRE Diesel, that are not as flammable as more volatile fuels, will be stored on site. Manganese ore is not flammable per se, but significant concentrations of very fine airborne dust can ignite. The likelihood of this occurring is low.

9 ASSESSMENT AND MANAGEMENT OF IMPACTS The purpose of this section is to assess and identify the most pertinent environmental impacts that are expected from the construction, operational and potential decommissioning activities of the project. An Environmental Management Plan based on these identified impacts are also incorporated into this section. For each impact an Environmental Classification was determined based on an adapted version of the Rapid Impact Assessment Method (Pastakia, 1998). Impacts are assessed according to the following categories: Importance of condition (A1); Magnitude of Change (A2); Permanence (B1); Reversibility (B2); and Cumulative Nature (B3) (see Table 10). Ranking formulas are then calculated as follow: Environmental Classification = A1 x A2 x (B1 + B2 + B3) The environmental classification of impacts is provided in Table 11. The probability ranking refers to the probability that a specific impact will happen following a risk event. These can be improbable (low likelihood); probable (distinct possibility); highly probable (most likely); and definite (impact will occur regardless of prevention measures). Table 10. Assessment Criteria Criteria Score Importance of condition (A1) – assessed against the spatial boundaries of human interest it will affect Importance to national/international interest 4 Important to regional/national interest 3 Important to areas immediately outside the local condition 2 Important only to the local condition 1 No importance 0

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Magnitude of change/effect (A2) – measure of scale in terms of benefit / disbenefit of an impact or condition Major positive benefit 3 Significant improvement in status quo 2 Improvement in status quo 1 No change in status quo 0 Negative change in status quo -1 Significant negative disbenefit or change -2 Major disbenefit or change -3 Permanence (B1) – defines whether the condition is permanent or temporary No change/Not applicable 1 Temporary 2 Permanent 3 Reversibility (B2) – defines whether the condition can be changed and is a measure of the control over the condition No change/Not applicable 1 Reversible 2 Irreversible 3 Cumulative (B3) – reflects whether the effect will be a single direct impact or will include cumulative impacts over time, or synergistic effect with other conditions. It is a means of judging the sustainability of the condition – not to be confused with the permanence criterion. Light or No Cumulative Character/Not applicable 1 Moderate Cumulative Character 2 Strong Cumulative Character 3 Table 11. Environmental Classification (Pastakia 1998) Environmental Classification Class Value Description of Class 72 to 108 5 Extremely positive impact 36 to 71 4 Significantly positive impact 19 to 35 3 Moderately positive impact 10 to 18 2 Less positive impact 1 to 9 1 Reduced positive impact 0 -0 No alteration -1 to -9 -1 Reduced negative impact -10 to -18 -2 Less negative impact -19 to -35 -3 Moderately negative impact -36 to -71 -4 Significantly negative impact -72 to -108 -5 Extremely Negative Impact

RISK ASSESSMENT AND ENVIRONMENTAL MANAGEMENT PLAN The EMP provides management options to ensure impacts of the facility are minimised. An EMP is a tool used to take pro-active action by addressing potential problems before they occur. This should limit the corrective measures needed, although additional mitigation measures might be included if necessary. The environmental management measures are provided in the tables and descriptions below. These management measures should be adhered to during the various phases of the project. This section of the report can act as a stand-alone document. All personnel taking part in any phase of the project should be made aware of the contents in this section, so as to plan the operations accordingly and in an environmentally sound manner.

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The objectives of the EMP are:  to include all components of construction activities (including upgrades, maintenance, etc.) and operations of the project;  to prescribe the best practicable control methods to lessen the environmental impacts associated with the project;  to monitor and audit the performance of personnel in applying such controls; and  to ensure that appropriate environmental training is provided to responsible personnel. Various potential and definite impacts will emanate from the construction, operations and decommissioning phases. The majority of these impacts can be mitigated or prevented. The impacts, risk rating of impacts as well as prevention and mitigation measures are listed below. As depicted in the tables below, impacts are expected to range from low to high and can mostly be mitigated to have a medium to low significance. The extent of impacts are focussed around the transport routes, the bulk storage yard and the port. Due to the nature of the surrounding areas, cumulative impacts are possible and include noise and traffic impacts.

Planning During the phases of planning for construction, operations and decommissioning of the project, it is the responsibility of the proponent to ensure they are, and remain, compliant with all legal requirements. The proponent must also ensure that all required management measures are in place prior to and during all phases, to ensure potential impacts and risks are minimised. The following actions are recommended for the planning phase and should continue during various other phases of the project:  Ensure that all necessary permits from the various ministries, local authorities and any other bodies that governs the construction activities and operations of the project remains valid. This include valid work permits where required.  Ensure all appointed contractors and employees enter into an agreement with the proponent which includes the EMP. Ensure that the contents of the EMP are understood by the contractors, sub-contractors, employees and all personnel present, or who will be present, on site.  Make provisions to have a Health, Safety and Environmental Coordinator (in-house) to implement the EMP and oversee occupational health and safety as well as general environmental related compliance at the site.  Make provisions to have a community liaison officer on site who will handle complaints and community input. Communicate the contact details of the community liaison officer to interested and affected parties when the project is initiated.  Have the following emergency plans, equipment and personnel on site where reasonable to deal with all potential emergencies: o Risk management / mitigation / EMP/ Emergency Response Plan and HSE Manuals; o Adequate protection and indemnity insurance cover for incidents; o Comply with the provisions of all relevant safety standards; o Procedures, equipment and materials required for emergencies.  Establish and maintain a fund for future ecological restoration of the project site should a spill occur or project activities cease and the site is decommissioned and environmental restoration or pollution remediation is required.  Establish and / or maintain a reporting system to report on aspects of construction activities, operations and decommissioning as outlined in the EMP.  Keep monitoring reports on file for submission with environmental clearance certificate renewal applications where needed.  Appoint a specialist environmental consultant to update the EIA and EMP and apply for renewal of the Environmental Clearance Certificate prior to expiry.

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Skills, Technology and Development During various phases of the project, training is provided to a portion of the workforce. This include the trucking industry, stevedoring and logistics, heavy machinery operations, etc. Skills are transferred to an unskilled workforce for general tasks. Some technology required for the project is often new to the local industry. Development of people and technology are key to economic development.

Importance Magnitude

Permanence Reversibility Cumulative

B3)

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) ( Environmental Classification Class Value Probability Employment, technological Construction 2 1 2 3 1 12 2 Definite development and transfer of skills Employment, technological Daily Operations 3 1 2 3 2 21 3 Definite development and transfer of skills Transfer of skills and technological Indirect Impacts 2 1 2 3 2 14 2 Definite development

Desired outcome: To see an increase in skills of local Namibians, as well as development and technology advancements in the local industry. Actions Mitigation:  If the skills exist locally, contractors must first be sourced from the town, then the region and then nationally. Deviations from this practice must be justified.  The proponent must employ Namibians where possible. Deviations from this practise should be justified appropriately.  Skills development and improvement programs to be made available as identified during performance assessments.  Employees to be informed about parameters and requirements for references upon employment. Responsible Body:  Proponent  Contractors Data Sources and Monitoring:  Records should be kept of training provided.  Ensure that all training is certified or managerial references provided (proof provided to the employees) inclusive of training attendance, completion and implementation.  Bi-annual summary report based on records kept.

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Revenue Generation and Employment The project will change the way revenue is generated and paid to the national treasury. An increase of skilled and professional labour will result from the operations of the project. Employment for the bulk storage yards will be sourced locally while supply of transport may be sourced from other regions.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Construction Employment and contribution to 2 1 2 2 1 10 2 Definite local economy Daily Operations Employment contribution to local 3 3 2 2 2 54 4 Definite economy Indirect Impacts Decrease in unemployment, 3 1 2 2 1 15 2 Definite contribution to local economy

Desired outcome: Contribution to national treasury and provision of employment to local Namibians. Actions Mitigation:  The proponent must employ local Namibians where possible.  If the skills exist locally, employees must first be sourced from the town, then the region and then nationally.  Deviations from this practice must be justified. Responsible Body:  Proponent  Contractors Data Sources and Monitoring:  Financial statements and proof of taxes paid.  Bi-annual summary report based on employee records.

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Demographic Profile and Community Health The project is reliant on labour during the all phases. New developments often lead to an influx of people looking for jobs. This may lead to growth in informal settlements and unemployment. The size of the local workforce is limited and it is not believed that it will create a change in the demographic profile of the local community. Community health may be exposed to factors such as communicable disease like HIV/AIDS and alcoholism/drug abuse, associated with trucking industry. An increase in foreign people in the area may potentially increase the risk of criminal and socially/culturally deviant behaviour.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Construction In-migration and social ills related to 2 -1 2 2 2 -12 -2 Probable unemployment Daily Operations In-migration and social ills related to 2 -1 2 2 2 -12 -2 Probable unemployment Indirect Impacts The spread of disease 2 -1 2 2 2 -12 -2 Probable

Desired Outcome: To prevent the in-migration and growth in informal settlements and to prevent the spread of communicable diseases and prevent / discourage socially deviant behaviour. Actions: Prevention:  Employ only local people from the area, deviations from this practice should be justified appropriately.  Adhere to all municipal by-laws relating to environmental health which includes, but is not limited to, sanitation requirements. Mitigation:  Educational programmes for employees on HIV/AIDs and general upliftment of employees’ social status.  Appointment of reputable contractors, especially the transport company, who also has Educational programmes for employees on HIV/AIDs etc. Responsible Body:  Proponent Data Sources and Monitoring:  Facility inspection sheet for all areas which may present environmental health risks, kept on file.  Bi-annual summary report based on educational programmes and training conducted.  Bi-annual report and review of employee demographics.

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Health, Safety and Security (Employees) Every activity associated with the project is reliant on human labour and therefore exposes them to health and safety risks. Activities such as the operations of machinery and handling of chemicals and manganese ore, poses the main risks to employees. Security risks are related to unauthorized entry, theft and sabotage.

Value

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Probability Construction Physical injuries, exposure to 1 -2 2 3 1 --12 -2 Probable chemicals and criminal activities Daily Operations Physical injuries, exposure to 2 -3 3 2 2 -42 -4 Probable chemicals and/or manganese ore dust and criminal activities

Desired Outcome: To prevent injury, health impacts and theft. To prevent the health impacts as a result of acute or chronic exposure to manganese ore dust. Actions Prevention:  All Health and Safety standards specified in the Labour Act should be followed. This includes the limit set for exposure to manganese in the work place which is the time weighted average of 5 mg/m3 for a 40 hour work week.  Clearly label dangerous and restricted areas as well as dangerous equipment and products.  Provide all employees with required and adequate personal protective equipment (PPE) including dust masks and protective clothing for workers in close proximity to, or working with, the manganese ore. Accidental inhalation, ingestion, dermal or eye contact with ore dust must be prevented at all times.  Ensure that all personnel receive adequate training on operations of equipment / handling of hazardous substances.  Implementation of maintenance register for all equipment and fuel/hazardous substance storage areas.  Equipment that will be locked away on site must be placed in a way that does not encourage criminal activities (e.g. theft).  Appoint reputable contractors for transporting of ore who prioritise the safety and well- being of the truck drivers and the community. Mitigation:  Selected personnel should be trained in first aid and a first aid kit must be available on site. The contact details of all emergency services must be readily available.  Implement and maintain an integrated health and safety management system, to act as a monitoring and mitigating tool, which includes operational, safe work and medical procedures, permits to work, emergency response plans, housekeeping rules, MSDS’s and signage requirements (PPE, flammable etc.).  Dust suppression when required.  Emergency wash stations in case of accidental exposure to chemicals or manganese ore dust.  Security procedures and proper security measures must be in place to protect workers and clients.  Strict security that prevents unauthorised entry.

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Responsible Body:  Proponent  Contractors Data Sources and Monitoring:  Air quality monitoring must be conducted on site and within the port to especially monitor ore dust fallout. The dust must regularly be analysed for the occurrence of asbestos. Should asbestos be detected, all operations must cease and only be continued under very strict and approved health and safety procedures related to the handling of asbestos containing material. Monitoring to be conducted by an independent specialist.  Analyse one sample of ore for radioactivity and submit these results to the National Radiation Protection Authority prior to commencement of the transport of ore into Namibia.  Any incidents must be recorded with action taken to prevent future occurrences.  A report should be compiled every 6 months of all incidents reported. The report should contain dates when training were conducted and when safety equipment and structures were inspected and maintained.

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Air Quality Related Impacts (Off-Site) Reduced air quality as a result of windblown ore dust can cause health effects, especially through chronic inhalation of such dust. Reduced air quality as a result of exhaust gases of a large number of trucks moving through town. This may have health impacts as well as impact on buildings in terms of discoloration, material loss and soiling.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Daily Operations Exposure to manganese ore dust and 2 -3 3 3 2 -48 -4 Probable its subsequent inhalation and/or ingestion and inhalation of exhaust gases. Damage to historically significant buildings as a result of exhaust gases resulting in acid deposition, ozone and soot build-up.

Desired Outcome: To prevent health impacts and to maintain the integrity of the built environment, especially historically significant buildings. Actions Prevention:  Agency for Toxic Substances and Disease Registry (United States of America) sets the Minimum Risk Level of manganese in air that is expected not have any health risk over a specified duration of exposure at 0.0003 mg/m3. Air quality in Lüderitz or receptors on any part of the route of transport and at receptors may not increase above this limit.  All bulk bags must be checked prior to filling to ensure they are not damaged. Forklift operators to be suitably trained.  All truck loads must be suitably covered to prevent the escape of dust from the load bin. This include empty trucks that may still contain some dust.  Appoint reputable contractors for transporting of ore who prioritise a “zero dust policy”. Mitigation:  Dust suppression in the warehouse when required.  Cease any operations with immediate effect once dust plumes that cannot be contained becomes visible. Operations can commence once sufficient mitigation measures have been implemented or when the cause of dust disseminates. This includes operational processes such as handling and loading / offloading of ore at the bulk storage yard, transport through town, offloading in the port, etc.  All trucks transporting ore must be service regularly and make use of technology to reduce emissions. This include selective catalytic reduction, diesel particulate filters and diesel oxidation catalysts. Responsible Body:  Proponent  Contractors Data Sources and Monitoring:  Air quality monitoring must be conducted on site and at the port to monitor ore dust fallout. If air quality at receptors reach manganese levels in excess of 0.0003 mg/m3, all dust causing operations must cease and mitigation measures instigated or improved. If

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asbestos are detected, all operations must cease immediately and only be continued under very strict and approved health and safety procedures related to the handling of asbestos containing material. Monitoring to be conducted by an independent specialist.  Ore must be sampled irregularly once every 3 months by an independent specialist for asbestos in the ore.  Any complaints received regarding ore dust along the transport routes and sites of handling of ore must be recorded, investigated and the problem rectified.  Any incidents must be recorded with action taken to prevent future occurrences.  A report should be compiled every 6 months of all incidents reported and monitoring performed. The report should contain dates when safety equipment and structures were inspected and maintained.

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Traffic The transport of the manganese ore by trucks will impact on the national road network from Ariamsvlei to Lüderitz as well as on the internal road network of Lüderitz. The possibility of accidents and traffic congestion and delays will increase. Increased wear and tear on roads.

Project Activity / Resource Nature (Status) (A1) Importance (A2) Magnitude (B1) Permanence (B2) Reversibility (B3) Cumulative Environmental Classification Class Value Probability Construction Delivery of equipment and building 1 -1 2 2 2 -6 -1 Probable supplies Daily Operations Increased traffic, road wear and tear 3 -2 2 2 2 -36 -4 Definite and accidents

Desired Outcome: Minimum impact on traffic and no transport or traffic related accidents / incidents. Actions Mitigation:  Adhere to The Road Traffic and Transport Regulations, 2001 and all other applicable legislation related to road transport and maximum axle loads.  From the onset of the project, Pektranam Logistics together with the relevant authorities, Namport, other bulk transport entities, and members of the Lüderitz community, must investigate and work towards an alternative road or method of moving ore, or other bulk cargo, into and out of the port. The aim would be to continue the optimised use of the port, which is in national interest, while having minimum potential traffic and related impacts.  In consultation with the relevant authorities, erect clear signage regarding access and exit points, warnings, speed limits, etc., and determine the optimal route in and out of the port and town.  In consultation with the school and local authority, post marshals at selected sections of roads to assist school children crossing the road safely and investigate ways to regulate traffic to reduce impacts.  Impose safe speed limits for various sections of the entire transport route which include the national road network and towns. The national limit for main roads for trucks is 80 km/h. For the towns 40 km/h is proposed.  To prevent collisions with wildlife and the wild horses, all trucks travelling between Aus and Lüderitz at night may not exceed 60 km/h in high risk sections. Consultation with the Hyena Research Project and the Namibia Wild Horses Foundation to confirm sections where these speed limits should be implemented.  All trucks to be under real-time satellite tracking and disciplinary action taken for violations.  Trucks transporting ore from South Africa may not be allowed to enter the main business area of Lüderitz.  Trucks delivering ore to the port may not park in town.  No off road driving or parking outside of designated areas allowed.  Trucks delivering ore to the port must be clearly marked, and easy to identify by the general public as operating for Pektranam Logistics, in order to allow for easy and accurate reporting of misconduct. This will also reduce the reputational risk caused by truck operators of other companies not related to Pektranam Logistics. Responsible Body:  Proponent

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 Authorities  Contractors Data Sources and Monitoring:  The Road Traffic and Transport Regulations, 2001  All trucks to be fitted with GPS tracking and monitored for going off-route, into restricted areas, or exceeding the speed limit as per different sections of the roads.  Any complaints received regarding traffic misconduct should be recorded together with actions taken to prevent such events from repeating itself.  All traffic related incidents must be recorded.  A report should be compiled every 6 months of all incidents reported, complaints received, and actions taken.

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Fire Operational and construction activities may increase the risk of the occurrence of fire.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Construction Fire risk 1 -1 2 2 1 -5 -1 Improbable Daily Operations Fire risk 1 -1 2 2 1 -5 -1 Improbable

Desired Outcome: To prevent property damage, possible injury and impacts caused by uncontrolled fires. Actions: Prevention:  Ensure all fuel or chemicals are stored and handled according to MSDS and SANS instructions.  Maintain regular site, mechanical and electrical inspections and maintenance.  Clean all spills / leaks. Mitigation:  A holistic fire protection and prevention plan is needed. This plan must include an emergency response plan, firefighting plan and spill recovery plan.  Maintain firefighting equipment, good housekeeping and personnel training (firefighting, fire prevention and responsible housekeeping practices). Responsible Body:  Proponent  Contractors Data Sources and Monitoring:  A register of all incidents must be maintained on a daily basis. This should include measures taken to ensure that such incidents do not repeat themselves.  A report should be compiled every 6 months of all incidents reported. The report should contain dates when fire drills were conducted and when fire equipment was tested and training given.

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Noise Noise pollution will exist due to heavy motor vehicles accessing the site and transporting the ore along the national roads and through town. Construction (maintenance and upgrade) may generate noise.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Construction Excessive noise generated from 1 -1 2 2 1 -5 -1 Probable construction activities – nuisance and hearing loss Daily Operations Noise generated from the transport 3 -2 2 2 2 -36 -4 Definite and operational activities – nuisance

Desired Outcome: To prevent any nuisance and hearing loss due to noise generated. Actions Prevention: Bulk storage yard and port area:  Follow World Health Organization (WHO) guidelines on maximum noise levels (Guidelines for Community Noise, 1999) to prevent hearing impairment.  All machinery must be regularly serviced to ensure minimal noise production. Transport routes and towns:  From the onset of the project, Pektranam Logistics together with the relevant authorities, Namport, other bulk transport entities, and members of the Lüderitz community, must investigate and work towards an alternative road or method of moving ore, or other bulk cargo, into and out of the port. The aim would be to continue the optimised use of the port, which is in national interest, while having less noise impacts. Mitigation:  Hearing protectors as standard PPE for workers in situations with elevated noise levels.  All trucks must be regularly serviced and all sound mufflers in 100% working condition to ensure minimal noise.  Investigate anti-vibration systems which will reduce noise produced by trucks moving ore through Lüderitz. All trucks to be fitted with air suspension.  Driver behaviour and vehicle speed greatly influence noise levels. Driver education is imperative. No aggressive deceleration and acceleration and vehicles to maintain constant speed as far as is practically possible. Limit night time (20:00 – 07:00) speed to 40 km/h in or past towns on route from South Africa. Adhere to normal vehicle speed restrictions during day time.  Together with local authorities and community, investigate options to remove speed bumps (if any) and to possibly allow for trucks having right of way at four-way stops. Marshals can be used to regulate traffic should this option be implemented. Responsible Body:  Proponent  Contractors  Local Authority Data Sources and Monitoring:  WHO Guidelines  All trucks to be fitted with GPS tracking and monitored for going off-route, into restricted areas, or exceeding the speed limit as per different sections of the roads.

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 Maintain a complaints register  Bi-annual report on complaints and actions taken to address complaints and prevent future occurrences.

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Vibration Impact – Buildings and Infrastructure Vibration impacts will exist due to heavy motor vehicles transporting the ore through town.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Daily Operations Vibration generated from the 2 -2 2 2 3 -28 -3 Probable transport activities

Desired Outcome: To prevent any structural damage as a result of excessive vibrations. Actions Prevention:  From the onset of the project, Pektranam Logistics together with the relevant authorities, Namport, other bulk transport entities, and members of the Lüderitz community, must investigate and work towards an alternative road or method of moving ore, or other bulk cargo, into and out of the port. The aim would be to continue the optimised use of the port, which is in national interest, while having less vibration impacts. Mitigation:  All trucks must be regularly serviced and in good operational condition.  Investigate anti-vibration systems which will reduce vibrations produced by trucks moving ore through Lüderitz. All trucks used to transport ore between the warehouse and the port to be fitted with air suspension.  Driver education is imperative. No aggressive deceleration and acceleration and vehicles to maintain constant speed as far as is practically possible. Limit night time (20:00 – 07:00) speed to 40 km/h in or past towns on route from South Africa. Adhere to normal vehicle speed restrictions during day time.  Together with local authorities and community, investigate options to remove speed bumps and to possibly allow for trucks having right of way at four-way stops. Marshals can be used to regulate traffic should this option be implemented. Responsible Body:  Proponent  Contractors  Local Authority Data Sources and Monitoring:  Maintain a complaints register  Bi-annual report on complaints and actions taken to address complaints and prevent future occurrences.

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Waste production Various forms of waste will be produced during the construction and operational phases. Waste can be classified as hazardous and non-hazardous waste. Soil or water contaminated by for example hydrocarbons must be treated as hazardous waste.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Construction Excessive waste production, littering, 1 -2 2 2 2 -12 -2 Definite illegal dumping, contaminated materials Daily Operations Excessive waste production, littering, 1 -2 2 2 2 -12 -2 Definite contaminated materials

Desired Outcome: To reduce the amount of waste produced, and prevent pollution and littering. Actions Prevention:  A waste management plan must be developed.  Waste reduction measures should be implemented and all waste that can be re-used / recycled must be kept separate.  All staff as well as all truck drivers must be educated on the importance of not littering, including along transport routes.  Ensure adequate waste disposal storage facilities are available.  Ensure waste cannot be blown away by strong winds.  Prevent scavenging (human and non-human) of waste at the storage site. Mitigation:  Waste should be disposed of regularly and at appropriately classified disposal facilities, this includes hazardous material (empty chemical containers, contaminated rugs, paper water and soil).  See the material safety data sheets available from suppliers for disposal of contaminated products and empty containers.  The spill catchment traps at diesel storage facility of truck maintenance / repair area should be cleaned regularly and waste disposed of appropriately.  Liaise with the town council regarding waste and handling of hazardous waste. Responsible Body:  Proponent  Contractors Data Sources and Monitoring:  A register of hazardous waste disposal should be kept. This should include type of waste, volume as well as disposal method/facility.  Any complaints received regarding waste should be recorded with notes on action taken.  All information and reporting to be included in a bi-annual report.

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Ecosystem and Biodiversity Impact - Terrestrial Any impacts on the terrestrial environment including poaching and illegal collection of plant material, off-road driving, truck collisions with wild animals, bird impacts (e.g. collisions caused by bright lights when flying at night), and contamination of the environment.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Construction Impact on fauna and flora. Loss of 1 -1 3 2 2 -7 -1 Improbable biodiversity Daily Operations Impact on fauna and flora. Loss of 1 -1 3 2 2 -7 -1 Improbable biodiversity

Desired Outcome: To avoid pollution of and impacts on the terrestrial ecological environment. Prevent bird collisions. Actions. Prevention:  Reduce the numbers and intensity of lights at night to the minimum.  Down-shielding security lighting for on-ground facilities and equipment to keep light within the boundaries of the site. Mitigation:  Report any extraordinary sightings to the Ministry of Environment and Tourism.  Mitigation measures related to waste handling and the prevention of groundwater, surface water and soil contamination should limit ecosystem and biodiversity impacts.  Avoid scavenging of waste by fauna, mainly birds.  The establishment of habitats and nesting sites at the facility should be prevented where possible.  Install a rumble grid at the warehouse exit to dislodge and contain any ore nuggets trapped in tyres. Responsible Body:  Proponent Data Sources and Monitoring:  All information and reporting to be included in a bi-annual report.

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Ecosystem and Biodiversity Impact - Marine Any impacts on the marine environment which will mainly be related to the accidental spillage of manganese ore into the ocean during ship loading activities. Introduction of alien species through ballast water of ships.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Daily Operations Marine contamination by manganese 2 -2 2 2 2 --24 -3 Probable ore. Alien species introduction by ships’ ballast water.

Desired Outcome: To avoid pollution of and impacts on the marine ecological environment. Actions. Mitigation:  Loading of ships should be performed by responsible and well experienced operators of equipment.  All ships to be loaded on the northern end of the quay wall.  Dust suppression systems to be implemented if and when required.  Loading activities must cease when dust plumes become visible outside of the ship’s cargo hold and only be continued once mitigation measures have been implemented.  To prevent alien species introduction all vessels must follow the IMO Guidelines on Biofouling. This include, exchange ballast water once just outside the Namibia Exclusive Economic Zone and again just inside this zone. Responsible Body:  Namport  Contractors  Proponent Data Sources and Monitoring:  Air quality monitoring must be conducted at the port to monitor ore dust fallout. Monitoring to be conducted by an independent specialist.  All information and reporting to be included in a bi-annual report.

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Groundwater, Surface Water and Soil Contamination Operations entail the storage and handling of hydrocarbons which present a contamination risk. Contamination may either result from failing storage facilities, pumps and pipelines, or spills and leaks associated with overfilling or human error. Such spills may contaminate surface water, soil and groundwater. Manganese ore and its dust that are not contained in the warehouse or trucks can contaminate the environment.

/

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Construction Contamination from hazardous 2 -1 2 2 1 -10 -2 Probable material spillages and hydrocarbon leakages Daily Operations Contamination from hazardous 2 -2 2 2 1 -20 -3 Probable material spillages and hydrocarbon leakages

Desired Outcome: To prevent the contamination of water and soil. Actions Prevention:  Spill control structures and procedures must be in place according to SANS standards or better and connection of all surfaces where fuel is stored or handled, with an oil water separator.  All fuelling should be conducted on surfaces provided for this purpose. E.g. Concrete slabs with regularly maintained seals between slabs.  The procedures followed to prevent environmental damage during service and maintenance, and compliance with these procedures, must be audited and corrections made where necessary.  Proper training of operators must be conducted on a regular basis (fuel handling, spill detection, spill control).  Dust suppression in the warehouse to prevent dust blown into the surrounding environment when warehouse doors are opened.  Action must be taken immediately for all instances where ore dust is not contained. Dust causing actions must be halted and corrective measures implemented. Mitigation:  Any fuel spillage of more than 200 litre must be reported to the relevant authorities.  Spill clean-up means must be readily available on site as per the relevant MSDS.  Any spill must be cleaned up immediately.  The spill catchment traps should be cleaned regularly and waste disposed of at a suitably classified hazardous waste disposal facility.  Install a rumble grid at the warehouse exit to dislodge and contain any ore nuggets trapped in tyres. Also conduct visual inspection of the tyres. Responsible Body:  Proponent  Contractors Data Sources and Monitoring:  A report should be compiled bi-annually of all spills or leakages reported. The report should contain the following information: date and duration of spill, product spilled,

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volume of spill, remedial action taken, comparison of pre-exposure baseline data (previous pollution conditions survey results) with post remediation data (e.g. soil/groundwater hydrocarbon concentrations) and a copy of documentation in which spill was reported to Ministry of Mines and Energy.

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Impacts on Utilities and Infrastructure Any damage caused to existing infrastructure and services supply like water or electricity where present.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Construction Phase Disruption of services. 2 2 3 2 1 -24 -3 Probable

Desired Outcome: No impact on utilities and infrastructure. Actions Prevention:  Appointing qualified and reputable contractors is essential.  The contractor must determine exactly where amenities and pipelines are situated before construction commences (utility clearance e.g. ground penetrating radar surveys).  Liaison with the Municipality and suppliers of services is essential  The turnoffs from the B4 Main Road must be upgraded to Roads Authorities’ specifications. Mitigation:  Emergency procedures available on file.  Regular maintenance dredging to be performed when necessary. Responsible Body:  Lüderitz Town Council  Contractors  Proponent Data Sources and Monitoring:  Roads Authority  A report should be compiled every 6 months of all complaints received and actions taken.

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Visual Impact This is an impact that not only affects the aesthetic appearance, but also the integrity of the facility.

Importance Magnitude

Permanence Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Construction Aesthetic appearance and integrity of 1 -1 2 2 2 -6 -1 Probable the site Daily Operations Aesthetic appearance and integrity of 1 -1 2 2 2 -6 -1 Probable the site

Desired Outcome: To minimise aesthetic impacts associated with the facility. Actions Mitigation:  Regular waste disposal, good housekeeping and routine maintenance on infrastructure will ensure that the longevity of structures are maximised and a low visual impact is maintained. Responsible Body:  Proponent  Contractors Data Sources and Monitoring:  A report should be compiled every 6 months of all complaints received and actions taken.

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Cumulative Impact Possible cumulative impacts associated with the operational phase include increased traffic and noise.

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Importance Magnitude

Permane Reversibility Cumulative

Project Activity / Resource Nature (Status) (A1) (A2) (B1) (B2) (B3) Environmental Classification Class Value Probability Daily Operations The build-up of minor impacts to 2 -2 2 2 2 -24 -3 Probable become more significant

Desired Outcome: To minimise cumulative all impacts associated with the facility. Actions Mitigation:  Addressing each of the individual impacts as discussed and recommended in the EMP would reduce the cumulative impact.  Reviewing biannual and annual reports for any new or re-occurring impacts or problems would aid in identifying cumulative impacts and help in planning if the existing mitigations are insufficient. Responsible Body:  Proponent Data Sources and Monitoring:  Annual summary report based on all other impacts must be created to give an overall assessment of the impact of the operational phase.

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DECOMMISSIONING AND REHABILITATION Decommissioning is not foreseen during the validity of the Environmental Clearance Certificate. Decommissioning was however assessed as construction activities include modification and decommissioning. Should decommissioning occur at any stage, rehabilitation of the area may be required. Decommissioning will entail the complete removal of all infrastructure including buildings and underground infrastructure. Any pollution present on the site must be remediated. The impacts associated with this phase include noise and waste production as structures are dismantled. Noise must be kept within WHO standards and waste should be contained and disposed of at an appropriately classified and approved waste facility and not dumped in the surrounding areas. Future land use after decommissioning should be assessed prior to decommissioning and rehabilitation initiated if the land would not be used for future purposes. The Environmental Management Plan for the facility will have to be reviewed at the time of decommissioning to cater for changes made to the site and implement guidelines and mitigation measures.

ENVIRONMENTAL MANAGEMENT SYSTEM The proponent could implement an Environmental Management System (EMS) for their operations. An EMS is an internationally recognized and certified management system that will ensure ongoing incorporation of environmental constraints. At the heart of an EMS is the concept of continual improvement of environmental performance with resulting increases in operational efficiency, financial savings and reduction in environmental, health and safety risks. An effective EMS would need to include the following elements:  A stated environmental policy which sets the desired level of environmental performance;  An environmental legal register;  An institutional structure which sets out the responsibility, authority, lines of communication and resources needed to implement the EMS;  Identification of environmental, safety and health training needs;  An environmental program(s) stipulating environmental objectives and targets to be met, and work instructions and controls to be applied in order to achieve compliance with the environmental policy; and  Periodic (internal and external) audits and reviews of environmental performance and the effectiveness of the EMS.  The Environmental Management Plan

10 CONCLUSION Namibia’s Vision 2030 and National Development Plans promotes the development of the country as an international logistics hub with strong focus on the use of Namibia’s ports for import and export purposes for the southern African nations. Since the Port of Lüderitz is operating at about a third of its capacity, government realises the potential of this port to cater for the export of manganese ore from southern Africa. Projects of this nature can generate significant revenue for a country given that it is implemented with strict regulations regarding employment and services provision. Projects of this magnitude will likely cause environmental impacts, but these should be prevented and / or mitigated as far as is practically and reasonably possible or essential. The major impacts expected from the project is dust, noise and traffic. These impacts will in turn impact on residents (possible health and nuisance impact), tourism, the natural environment (e.g. collisions with animals), and road degradation. Some of these impacts can be prevented through careful planning and implementation of impact reducing mechanisms. This includes for example preventing dust plumes by covering all loads, storage of ore in a closed warehouse, and making use of dust suppression mechanisms. Others, such as traffic impacts and the noise associated with it, cannot be prevented, but can be mitigated to some degree through planning and technological applications. This include using trucks with air suspension in sensitive areas, speed restrictions, proper route planning and timing, etc.

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For the current project, noise and traffic will be inevitable impacts on and along the national road system as well as Lüderitz itself. However, the importance of the project in terms of potential revenue for Namibia, the region and the town, cannot be understated. Thus, preventative and mitigation measures have been proposed in the EMP, which should reduce impacts to more acceptable levels. In addition, an alternative transport route option has been proposed. Allowing trucks to follow the existing rail route through town will significantly mitigate traffic impacts on the town. Furthermore it will also present the opportunity for existing heavy motor vehicle traffic through town to move out of sensitive areas in town and therefore be an improvement in the status quo. This option should actively be pursued by all role players including the transport companies, Namport, the Lüderitz Town Council and the Ministry of Works and Transport. Negative impacts related to the bulk storage yards and related activities can successfully be mitigated. All health and safety related regulations should be adhered to as prescribed by the Labour Act and any other relevant legal requirements and internationally accepted standards of operation. All personnel should be issued with PPE when and where required. Noise pollution should at all times meet the prescribed WHO requirements to prevent hearing loss and not to cause a nuisance. Fire prevention should be adequate and regular training and drills conducted. SANS standards relating to the petroleum industry and prescribed by Namibian law must be followed during all operations of the consumer fuel installation. Any waste produced must be removed from site and disposed of at an appropriate facility or re-used or recycled where possible. Hazardous waste must be disposed of at an approved hazardous waste disposal site. The environmental management plan (Section 9) should be used as an on-site reference document for the operations of the facility. Parties responsible for transgressing of the environmental management plan should be held responsible for any rehabilitation that may need to be undertaken. The proponent use an in-house Health, Safety, Security and Environment Management System in conjunction with the environmental management plan. All operational personnel must be taught the contents of these documents. Table 12. Impact Summary Class Values Impact Category Impact Type Construction Operations Positive Rating Scale: Maximum Value 5 5 Negative Rating Scale: Maximum Value -5 -5 EO Skills, Technology and Development 2 3 EO Revenue Generation and Employment 2 4 SC Demographic Profile and Community Health -2 -2 SC Health, Safety and Security (Employees) -2 -4 PC Air Quality Related Impacts (Off-Site) -4 SC Traffic -1 -4 PC Fire -1 -1 PC Noise -1 -4 EO Vibration Impact - Buildings and Infrastructure -3 PC Waste Production -2 -2 BE Ecosystem and Biodiversity Impact - Terrestrial -1 -1 BE Ecosystem and Biodiversity Impact - Marine -3 PC Groundwater, Surface Water and Soil Contamination -2 -3 EO Impacts on Utilities and Infrastructure -3 SC Visual Impact -1 -1 Cumulative Impact -2 -2 BE = Biological/Ecological EO = Economical/Operational PC = Physical/Chemical SC = Sociological/Cultural

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Siegfried, P.R. 1992/93. Results of Preliminary Investigations into the Geology of the Diaz Point Formation, Lüderitzbucht, Namibia. GeoAfrica Prospecting Services, Windhoek. Communs Geological Survey Namibia, 8, 127-135.

SPC (Stubenrauch Planning Consultants). 2015. Lüderitz Structure Plan: Towards A Model Town Volume 1.

Watkiss, P., Eyre, N., Holland, M. 2000. Impacts of Air Pollution on Building Materials. Draft Report. https://www.researchgate.net/profile/Mike_Holland2/publication/268030572_IMPACTS_OF _AIR_POLLUTION_ON_BUILDING_MATERIALS/links/560102f408aec948c4fa9793/IM PACTS-OF-AIR-POLLUTION-ON-BUILDING- MATERIALS.pdf?origin=publication_detail accessed 17 December 2018

WHO (2003) Manganese in drinking-water. Background document for preparation of WHO Guidelines for drinking-water quality. Geneva, World Health Organization(WHO/SDE/WSH/03.04/104) https://www.who.int/water_sanitation_health/dwq/chemicals/manganesesum.pdf Accessed 2019-01-14

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WHO. 2001. Manganese. http://www.euro.who.int/__data/assets/pdf_file/0003/123078/AQG2ndEd_6_8Manganese.pdf Accessed 2019-02-07

Zeng GM, Liang J, Guo SL, Shi L, Xiang L, Li XD, Du CY (2009)Spatial analysis of human health risk associated with ingesting manganese in Huangxing town, middle China. Chemosphere 77:368–375

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Appendix A: Proof of Public Consultation

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I&APs Notified by E-Mail Name Designation/Division Organization Mike & Ann Scott African Conservation Services Jessica Kemper Biologist African Penquin Conservation Project Dr Hashali Hamukuaya Executive Secretary Benguela Current Commission (BCC) Inga Jaenecke Brown Hyena Research Project Sue Roux Acting Chairperson Coastal Environmental Trust of Namibia (CETN) Richard Mutendere Community Member G.A. Kessler Fiver Roses Aquaculture Director Jürgen Fleidl Director Five Roses Aquaculture Rassie Erasmus General Manager Hangana Abalone Hon. Rev. Jan A. Scholtz Chairman and Councillor / Karas Regional Council

Nicolaas De Wee Health, Water & Sewer Services Lüderitz Town Council Aunie Gebhard Chief Executive Officer Lüderitz Town Council Rod Braby Marine Spatial Management and Governance Project - MARISMA Richard Fryer Chief Warden //Karas Parks Ministry of Environment and Tourism Wayne Handley Ministry of Environment and Tourism Elton Kuruseb Ministry of Environment and Tourism Jean-Paul Roux Ecosystem Section Ministry of Fisheries and Marine Resources Graça D’Almeida Director: Resource Managment Ministry of Fisheries and Marine Resources Rudi Cloete Director of Aquaculture and Ministry of Fisheries and Marine Inland Fisheries Resources Foibe Nghoongoloka Fisheries Biologist Ministry of Fisheries and Marine Resources Viktor Libuku Fisheries Biologist Ministry of Fisheries and Marine Resources Anja Kreiner Senior Fisheries Biologist Ministry of Fisheries and Marine (Namibia Marine Spatial Planning Resources National Working Group) Frikkie Botes Chief Fisheries Biologist Ministry of Fisheries and Marine (Mariculture) Resources Erich Maletzky Senior Fisheries Biologist Ministry of Fisheries and Marine Resources Pinehas N. Auene Deputy Director: Marine Ministry of Works and Transport Pollution Control and SAR Gabes Simeon Chief Control Officer: Marine Ministry of Works and Transport Pollution Control and SAR M Nangolo Directorate of Maritime Affairs Ministry of Works and Transport Joyce Katjirua Environmental Management Namdeb Coordinator Simon Elwen Namibia Dolphin Project Monique Laubscher Field Technician Namibia Dolphin Project Cecil Kamupingene Marketing Specialist Namport

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Tim Eiman Co-ordinator (EMS & QMS) NamPort Elzevir Gelderbloem Port Engineer and Strategic Port NamPort Executive Stefanus Gariseb Safety, Health, Risk, Namport Environemnt and Quality Manager Max Cooper Port Manager: Luderitz Namport Johannes Isaaks Safety, Health, Risk, Namport Environemnt and Quality Officer Lüderitz NP du Plessis Senior Environmentalist: NamWater Water Quality and Environmental Services Jolanda Murangi Environmentalist In-Training NamWater Ferdi de Villiers Port Users Association of Lüderitz Eugene de Paauw Specialist Road Legislation, Roads Authority Advice & Compliance Johan Blaauw Regional Engineer Roads Authority Ezechiel Nsabibaruta Engineering Manager: Roads Authority Maintenance Hendrik Maritz Roads Authority Jason Burgess Shearwater Oysters Lewis Druker The Luderitz Foundation & Coastway Tours Lüderitz Crispin & Orti Clay The Lüderitzbucht Foundation

TransNamib Debmarine Namibia Chamber of Commerce and Industry

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I&APs Notified by Hand Delivered Letter Privacy Block Privacy Block Privacy Block Privacy Block

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Privacy Block Privacy Block Privacy Block Privacy Block

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Newspaper Advertisements Market Watch section appearing in the Republikein, Algemeine Zeitung and Namibian Sun Monday 19 November 2018

Monday 26 November 2018

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Site Notice at RCC Yard

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Notifications to Lüderitz Town Council

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Notifications to Relevant Ministries

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Registered I&APs

Name Position/Department Organisation Date Registered Alfonso Ferreira Private 2019-01-29 Alvin van Wyk Private 2019-01-25 Ann Scott African Conservation Services 2018-11-26 CC Arthur le Hanie Student 2019-01-29 Bernd Roemer Bahnhof Hotel Aus / Aus Desert 2018-12-16 Tours Bessly Makaula Teacher Lüderitz Junior Secondary School 2019-01-29 Cecil Kamupingene Marketing Specialist Namport 2019-01-29 Charmaine Kock Community Member 2019-01-29 Christaline Kaangundue Environmental Lüderitz Town Council 2019-01-29 Practitioners Crispin Clay Chairman Lüderitzbucht Foundation 2018-11-26 Crystal Jantjies Teacher Lüderitz Junior Secondary School 2019-01-29 David C Dennis Chief Fire Officer Lüderitz Town Council 2018-12-03 Deon Strohn Ops Manager Colman Transport 2018-12-03 Elisabeth Jantjies Community Member / Teacher 2019-01-29 Erkkie Andreas Community Member 2019-01-29 Eugene de Paauw Specialist Road Roads Authority 2018-11-19 Legislation, Advice & Compliance Ezechiel Nsabibaruta Roads Authority 2018-11-19 F Druker Managing Director Coastways Tours Luderitz Pty 2018-12-03 Ltd. Ferdie de Villiers Manager Novaship Namibia 2018-12-03 Fillipus Hedimbi Head of Cargo Namport 2019-01-29 Foibe Nghoongoloka Directorate of Ministry of Fisheries & Marine 2018-11-26 Aquaculture Resources Frans Ndjaleka Manager Ekuva Trading Enterprise 2019-01-29 Frikkie Botes CFB Mariculture Ministry of Fisheries and Marine 2018-11-26 Resources Fritz Hall Marine Technician Atlantech Marine Electronic cc 2018-12-16 G S Negongo Leader Community Member 2018-12-03 F Gariseb Community Member 2019-01-29 Giel du Toit Managing Director Rockbreaking and Demolitions 2019-01-26 Namibia cc H Plietz Private/ Owner A Plietz Engineering 2018-12-03 H Ludwicht Manager Office of the President, Lüderitz 2019-01-29 H Schmidt Community Member 2019-01-29 Heinz Manns Namib Offroad Excursions 2018-12-06 Helmuth Syvertsen Private 2019-01-26 Hennie Fourie B&E International 2018-12-03

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Howard Head CEO Ghost Town Tours 2018-11-26 Member Luderitz Tourism Forum Member Ocean Grown ( Oysters)

IN Tjipura Technical Manager Lüderitz Town Council 2018-12-03 Ileni Nghishekwa Inspector Ministry of Labour 2019-01-29 Ingrid Wiesel Senior Scientist Brown Hyena Research Project 2018-11-19 Innocent Sinvula General Manager Sturrock Grindrod 2019-01-29 JA Hendricks Area Manager Roads Authority 2018-12-03 Jacqueline Plaatjies HOD Helen van Rhijn Primary School 2018-12-03 Jason Burgess Shearwater Oysters 2018-12-03 Jean Paul Roux Scientist Ministry of Fisheries and Marine 2018-12-03 Resources Jessica Kemper Biologist Conservation Biologist and 2018-11-20 Lüderitz Resident Johan Blaauw Roads Authority 2018-11-19 Jolanda Environmentalist In- NamWater 2018-11-19 Murangi Training Josh Jones Community Member 2019-01-29 Jürgen Fleidl Director Five Roses Aquaculture 2018-11-27 Kakakoro Driver TransNamib Holdings 2019-01-29 Kennedy Jonas Community Member 2019-01-29 Kirsten Kessler NovaNam 2019-01-22 Kolette Grobler Ministry of Fisheries and Marine 2019-01-30 Resources L Schmidt Community Member 2019-01-29 Lea Apulile Community Member 2019-01-29 Lea Schroeter Private 2019-01-28 Leroy Makaula Student 2019-01-29 Linda & Erich Looser Owener Haus Sandrose 2018-12-07 Luqman Cloete Journalist The Namibian 2019-01-29 Manfred Anderson Community Member 2019-01-29 Manu Namukomba Human Resources NovaNam 2019-01-29 Marion Schelkle Ludertiz Safaris & Tours 2018-12-03 Marsha Pickering Community Member 2019-01-29 Matthew Adler Teacher Peace Corps 2019-01-29 Max Cooper Namport 2018-11-26 Michael Mackenzie NovaNam 2018-12-03 Michael Rumsey Kleber & Associates Consulting 2018-11-29 Engineers Michael Viljoen Manager Hangana Seafood 2019-01-29 Mike Scott African Conservation Services 2018-11-26 CC Mirjam Skeyer Station Master Lüderitz TransNamib Holdings 2019-01-22

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Naftal Trading 2019-01-29 Enterprises Norbit Klosta Salz Gossow 2019-01-29 NP du Plessis Senior Environmentalist NamWater 2018-11-19 P A Blaauw Private 2018-12-03 Patricia Kaulinge Environmental Section NovaNam 2019-01-29 Paul Schroeter Community Member 2019-01-28 Paulus Johannes Private 2019-01-26 Penda Ugwanga Community Member 2019-01-29 Piet Swiegers Klein-Aus Vista 2018-12-16 Priscilla Roode Community Member 2019-01-29 R Mutendere Private 2018-11-26 Rassie Erasmus General Manager Hangana Abalone 2018-11-26 Reginald Hercules Community Member 2019-01-25 Rian Jones SFRT Fisheries 2018-12-03 Rodney Braby Regional Technical Marine Spatial Management and 2018-11-26 Adviser Governance Project - MARISMA Ruth Community Member 2019-01-29 S Kalumbu Community Member 2019-01-29 Suzan Ndjaleka Manager COSDEC 2019-01-29 SP Prinsloo Namib Garage & Aus Haven 2018-12-17 Sakaria Hofni Community Member 2019-01-29

Simon Struben Community Member 2019-01-29 Stefan Metzger NovaNam 2019-01-22 Stefanus Gariseb SHREQ Manager Namport 2018-11-19 Suzan Ndjaleka Private 2019-01-26 Tekla Mutwmezi National Radiation Ministry of Health & Social 2018-11-30 Protection Service Services Tuulikki Abraham Private 2019-01-25 Ulf Grünewald General Manager Lüderitz Nest Hotel 2018-12-07 Verdiana Lucas Community Member 2019-01-29 Victor Musungo K&A Resident Engineer K&A Engineering 2019-01-29 Wayne Handley Ministry of Environment and 2018-11-26 Tourism Wetu Ndjonduezu Student 2019-01-29 Wetupa Nakathingo Lüderitz Town Council 2019-01-26 Wilhelm Steenkamp Community Member 2018-12-16 William Korff Supervisor Chemvet 2018-12-05 A Xamub Station Commander Nampol 2019-01-29 Yolande Steenkamp Community Member 2018-12-16 Yvan Jacobs 2019-01-29 Zebby Mukungu Act Executive: TransNamib Holdings 2019-01-21 Commercial and Marketing

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Clarification Letter: Illegal Offloading of Ore at Lüderitz

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Notification Letter: Second Public Meeting

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Notification Letter: Change of Location

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Appendix B: Minutes of Meetings and Correspondence Received

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TEL .: (+264-61) 257411  FAX .: (+264-61) 257411 CELL .: (+264-81) 1220082 PO BOX 11073  WINDHOEK  NAMIBIA E-MAIL : [email protected]

Minutes of Meeting Re: Public Meeting: Environmental Assessment for the Proposed Export of Manganese Ore via the Port of Lüderitz Date: Monday 03 December 2018 Time: 09h00-11h30 Venue: Ministry of Fisheries and Marine Resources Boardroom, Lüderitz

In attendance: Name Organisation Andre Faul Geo Pollution Technologies (GPT) Quzette Bosman Geo Pollution Technologies (GPT) Pieter Kruger Pektranam Logistics Ben Kruger Pektranam Logistics Johan Kruger Pektranam Logistics Dewald Kruger Pektranam Logistics J A Hendricks Roads Authority P H Head Alma Marine / Ghost Town Tours Rassie Erasmus Hangana Abalone P A Blaauw Private Victor Musungo K&A Engineering Marion Schelkle Lüderitz Safaris & Tours Deon Strohm Colman Transport F de Villiers Novaship Namibia Rian Jones Ministry of Fisheries and Marine Resources Jacqueline Plaatjies Helen van Rhijn Primary School Ulf Grunewald Lüderitz Nest Hotel I N Tjipura Lüderitz Town Council F Druker Coastways Tours Lüderitz Pty Ltd. Foibe B Nghoongoloka Ministry of Fisheries and Marine Resources C Clay Lüderitz Foundation G S Negongo Community Member J Kemper Private J P Roux Ministry of Fisheries and Marine Resources W Korff Chemvet H Plietz A Plietz Engineering David C Dennis Lüderitz Town Council Wetupa Nakathingo Lüderitz Town Council

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André Faul of Geo Pollution Technologies welcomed the audience to the meeting and proceeded with a presentation to introduce the different parties involved and to explain the purpose of the environmental assessment. He provided a brief introduction of the various components of the proposed manganese export process. After the presentation the audience was invited to provide input to be considered in the environmental assessment. Mr. Victor Musungo enquired whether there is an option to use the train since the railway has now completely been rehabilitated. He noted that at the proposed crossing over the railway line, as indicated on the maps, no rail level crossing is present due to it being part of the siding of the marshalling yard. He asked whether TransNamib has been consulted. His also asked whether there is any linkage between Pektranam Logistics’ proposed project and Tradeport’s project [which was advertised in the newspapers] as there seems to be similarities between the two projects. André Faul replied that the [exclusive] use of the rail system is currently not feasible. This is largely due to limitations on the size of trains [number of rail cars] that can be handled in the port as well as the double handling involved with rail transport. The ore will still have to be transported by truck to Ariamsvlei where it will have to be loaded onto trains. Once the train reach Lüderitz it will have to be offloaded at the bulk storage yard and then again be loaded onto trucks once the bulk cargo ship arrives in Lüderitz. This double handling becomes expensive and more opportunities exist for potential pollution related impacts. However, the client indicated that once the project has started [through trucking of ore only] and capital is generated, then it may become feasible to supplement the trucking of ore by rail. In terms of the rail siding, André indicated that he had a discussion with the client regarding the level crossing and suggested to the client that they make contact with TransNamib, Town Council and Roads Authority, regarding all junctions and crossings of roads and rail and movement through town. Regarding the Tradeport project André indicated that there is no link between the projects and that Geo Pollution Technologies (GPT) saw the advertisement for their EIA just when the Pektranam EIA was initiated. GPT also registered for the Tradeport project and is waiting for more information. What GPT does know is that they will use the existing interlocked slab at the rail siding for storage. Mr. Musungo expressed concern for instances where both companies [Pektranam and Tradeport] simultaneously have to load two separate ships in the port, and the impact that will result from traffic movement through town. André explained that the port can currently only handle one ship at a time and a slot needs to be booked for each shipment. Ms. Quzette Bosman added that from GPT’s side we are required to assess the cumulative impact of both projects, and that we are trying to get the information from the Tradeport EIA consultant. Some mitigation measures can then also be included. For example clearly marking of trucks to identify the respective companies so that the general public can see whose trucks are involved in any potential incidents. Mr. Ignasius Tjipuro requested clarification on whether transport from Ariamsvlei to Lüderitz will be by rail or truck. André confirmed it will at this stage be by truck. He noted and appreciated Pektranams willingness [in cooperation with other bulk transport companies using the road] to assist Town Council with upgrading the section of road in Bismarck Street that is not paved. He understands that levies are paid for road use by transport companies for such purposes, but indicated that very little of this money ever reach the local authority. He stated that Town Council did make a decision to approach the users of these roads, including transporters from Rosh Pinah and Namport, to assist with road upgrades. Mr. Pieter Kruger confirmed that they are willing to assist as the specific road is also not ideal for their trucks and it will be in their benefit to upgrade it. But, he again noted a relationship needs to be formed with other bulk transport users of the road to cooperate in this regard. Mr. Howard Head stated that the Namibian constitution makes provision for everyone’s right to an environment that is not harmful to your wellbeing and health. He noted that it comes down to risk versus reward and that over many years he has seen a number of EIAs in town and many promises being made initially, but once the project start they do not adhere to the EIA. An example is the fish meal plant that promised no odours due to advanced technology, but in reality this is not the case. A second example is the sulphur handled in port. He stated that he has observed that there is sulphur contamination in the water, on his boat and in his guest house. He asked who will be monitoring the proponent to ensure they

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follow their EMP. He stated that the economy of Lüderitz rests on mining, fishing and tourism. Of these, tourism is already threatened because Lüderitz is in a cul de sac. He further noted that although the client says there will be no dust, there will be friction during transport that cause dust. From the internet it is evident that manganese has health implications and it is a neurotoxin. He mentioned examples of other ports like Port Elisabeth, Saldanha Bay and Chicago where dust is an issue. He is therefore immensely concerned about health impacts. He also expressed concern about the noise impacts and noted that noise mitigation measures will not reduce the impact. He stated that he will address his concerns in writing, but these are his main concerns. André responded that Namport is currently developing an EMP for the entire port and that any operations within the port will have to abide by the EMP. Namport then becomes the regulatory and policing authority for all tenants in the port. He stated that he understands that the sulphur dust impact has lately been mitigated to some degree and conditions improved. Mr. Head replied that this is not the case. André then further explained that it is also the community’s right to report non-compliance with the Environmental Commissioner. Mr. Head asked what the recourse will be if non-compliance is experienced. André explained that an environmental clearance certificate is only valid for three years and if they do not comply and there is sufficient proof of non-compliance, their ECC will not be renewed or during the validity of the ECC they may also receive a non-compliance order which will mean they must stop with their activities. Quzette informed the audience that lately the environmental commissioner and his team are more active in the enforcing of environmental compliance and monitoring. Mr. Lewis Druker enquired about dust suppression [to prevent health impacts] by means of spraying with water and mentioned examples in Port Elisabeth. Mr. Pieter Kruger noted that he recognises the health effects possible from exposure to manganese, but also stated that it must be exposure to significant amounts. He stated that only about 27% of the ore is manganese and that because they will transport them as nuggets, dust will be minimal. He compared the manganese to the iron ore from Kathu and said dust is an inherent problem with iron ore, and that is why everything is pink where iron ore is handled, as for example in Saldanha Bay. He stated that dust is not an issue with manganese as it is with iron ore. He stated that his approach is not to make promises, but rather to show what is driving Pektranam [to prevent dust]. He stated it will not be in their interest to let dust be a problem if they want to be sustainable. He again reiterated that with the manganese ore being nuggets, dust will be negligible. Mr. Head enquired about the Kruger family and Pektranam. Mr. Pieter Kruger explained that it is a family business and although they are South African Citizens they have registered Pektranam Logistics as a Namibian company and only his son, Ben Kruger, who is also a microbiologist, will be stationed in Lüderitz. The remaining employees to be appointed will all be Namibian citizens. Mr. Head asked whether Mr. Pieter Kruger is positive there will be no dust since the prevailing winds will carry dust from the bulk storage area towards town and the bay. Mr. Kruger stated that he can’t say “no dust”, but he can explain their procedures. All loads will be covered by tarpaulins and the skips used to load the ships is lowered into the ship’s cargo bay while still being covered. Only then is it opened when it is tippled. Mr. Head enquired about dust at the bulk storage area. It transpired that some dust is expected to be present there, but the conversation did not continue on this subject. Dr. Jean-Paul Roux noted that for current bulk cargo handling in the port, at 20 to 25 knot winds, which is less than the daily average for summer months, there is dust when skips with tarpaulins are tippled into the ships. He mentioned that he does have photographs of this happening already with the lead, zinc and sulphur. He asked who will be responsible for this and is concerned about people “passing the buck” since there may very well not be any dust during transport, but there may be during loading of the ship which will be someone else’s responsibility. He stated that baseline conditions has to be determined prior to onset of the project. He also raised concern about potential marine impacts since the bay is a mariculture centre and good quality seawater is important. He noted that in terms of traffic it will be 277 trucks per day during loading of the ship. This is in addition to the zinc, lead and sulphur trucks as well as all the other regular trucks. André noted that any development in the port will lead to additional traffic through Lüderitz. With this project, once the project is off the ground [and capital is available], better alternatives can be invested

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in, that will reduce the traffic impacts. Quzette noted that in terms of the dust it is something that GPT will consider with seriousness in the EIA, regardless of the client’s notion that dust will be minimal. She further explained that the mining operator, for whom Petranam will handle the manganese ore, is a Namibian citizen who suggested considering Lüderitz as port of export to bring some benefits also to Namibia. She further explained that the “export route” through the Port of Lüderitz is not an established route and only once it is established investment can be made in infrastructure. It is also a government decision on whether they support the establishment of the route or not. It is not something that GPT as consultants can decide. Since there are potentially a number of similar projects in the pipeline for Lüderitz, she suggested that the Lüderitz community establish a forum at which these issues can be discussed and that government must be included in this. Ms. Marion Schelkle asked which port has been used for the export of manganese ore this far. Mr. Pieter Kruger explained that due to the amounts of manganese ore reserves in South Africa, it is exported via most ports over South Africa. The ports are however mostly congested while the Port of Lüderitz operates at about 35% capacity. It is not a matter of South African ports being “destroyed” by manganese [or other] exports and now they turn to a new port. For Pektranam the Port of Lüderitz is ideal from a transport point of view due to the flat, dry conditions. He explained that when they started the project two years ago, he found that there was already an expectation for the manganese exports. The manganese exports will establish a consistent industry making use of the port as opposed to the seasonality of for example the grapes from Aussenkehr. Mr. William Korff enquired about the dust monitoring stations. How many stations and how often will it be tested? He asked why a warehouse cannot be constructed in the harbour and what times the trucks will run. He expressed concern about trucks parking in town and driving past places like the school. André explained that for the period of loading of the ship it will be 24 hour operations for three days. He stated that considerations have been made with regard to mitigation of truck impacts in town. This include for example using different routes for incoming and outgoing trucks to dilute the impact and making use of marshals at selected points such as for example the school to prevent accidents. Mr. Ben Kruger explained in terms of dust monitoring it works on a bucket system that traps the dust and it can be checked at any time interval. They are usually on the perimeter fence or certain sections of the route. Quzette explained that the port does not have space for additional storage. This was confirmed by Mr. Ferdie de Villiers. The space that was available was secured by another party. He also commented on the grape export issue. He confirmed that the seasonality makes the grape exports not feasible since it is not feasible to put up cold storage that will be used for two months only. The same holds for the trucking of the grapes. The distance between Aussenkehr and Cape Town is basically the same and Cape Town already has infrastructure. Quzette explained more on the dust monitoring and noted that GPT will recommend monitoring options and look at international guidelines on air quality since Namibia does not have their own guidelines. She explained that we have to consult with all authorities and ministries on these issues. She confirmed that Ministry of Health has for example registered and requested analysis results of the manganese ore [specifically radioactivity]. Ms. Schelkle stated that this project will not be a win-win situation. She noted that “we [the residents] will lose”. She asked apart from Pektranam and Namport, who else will benefit? She stated that the trucking of ore through town will impact on the tourism industry and her own tourism business. She asked what will happen if a manganese ship is being loaded while a cruise liner is calling on port? How can passenger disembarking occur simultaneous with ship loading? She further reiterated the traffic and noise impacts in town that will also negatively impact on tourists. Quzette noted the comments and said that they will be addressed in the report. She further posed an open question to the audience regarding what growth they see in Lüderitz in terms of the port being an asset that is currently not operating at capacity. She urged the Lüderitz community to provide input in terms of how they see the growth of Lüderitz so that this information can be included in the environmental assessment. Ms. Schelkle noted that tourism is very sensitive and if the town’s reputation is damaged, tourists will refrain from coming again. She is worried about the risks to tourism on which they have worked hard to improve. She stated that Lüderitz used to receive about four cruise liners per year and that in now are about 15. Mr. de Villiers suggested that proper planning can reduce impacts. He confirmed that at any given stage when

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a cruise liner call on port, any bulk cargo ship loading must stop, and the ship moved out of port. However, cruise liners book well in advance and planning can thus prevent simultaneous visits of cruise liners and bulk cargo ships to the port. André mentioned that although he understands all the concerns, there is also the flipside of the coin. During this study’s public consultation, and with the previous Angra Point Deepwater Port assessment, a number of business owners and individuals expressed their desire to see some sort of development happening in town. During the Angra Point assessment one business owner noted that if some form of investment does not come to town he will have to close shop. Mr. Head sated that GPT’s public consultation may have been too selective and biased. André explained that this is not the case since all businesses and residential properties along Bismarck Street and Old Bay Road have been visited by walking door to door prior to the meeting. Mr. Head asked if this was Sunday? André confirmed it was on Friday and Saturday. He explained that one or two businesses were closed, but their numbers were taken and they will be contacted. Ms. Schelkle said nobody visited Lüderitz Safaris and Tours. Quzette confirmed she did visit them and delivered a notification letter to the lady who worked that day. André stated that it is impossible to visit each and every property in the entire town. He further stated that for Lüderitz he always notify Mr. Crispin Clay as chairman of the Lüderitzbucht Foundation since he [Mr. Clay] then always notify a wide range of community members. He stated that the advertisement was in the Algemeine Zeitung, Republikein and Namibian Sun newspapers once a week for two consecutive weeks. Quzette noted that from the social side of the assessment we consider economic resilience and aspirations for the future. She stated that Lüderitz needs economic growth and that “we don’t want Lüderitz to become another Kolmanskop.” Mr. Crispin Clay stated that one of their main fears in Lüderitz is that someone from outside comes in and develop a huge project and if it fails Lüderitz remains with the remnants thereof [white elephant]. He mentioned for example phosphate and diamond mining. He expressed his concern regarding dust when Lüderitz’s strong winds of 55 to 65 knots blows. He questioned the possibility of chemical reactions between the manganese and sulphur, lead and zinc when it gets into the marine environment or air. He questioned the efficiency of the air sampling bucket systems in terms of the strong winds. He established that Pektranam will be a subcontractor and that they will export to China which is an extra two days on sea when compared to South African ports. He mentioned that the frequent strong winds can stop loading operations or ships from coming into the port. He also stated that the possible negative impacts of manganese in terms of health may not be known now, but maybe later there will be. André noted all Mr. Clay’s concerns and stated that they will be addressed in the assessment report. Dr. Roux reiterated that tourism in Lüderitz is very important and is expected to grow with the new concessions in the //Tsau Khaeb Park. He asked how much economic benefit will come to town through the proposed project compared to tourism? Quzette stated this is an important aspect, but must also be considered at a regional and national level as it also have economic implications there. Quzette asked if there are some tourism statistics available for Lüderitz. Mr. Head explained more about tourism in Lüderitz and also stressed the safety on the roads for tourists. Mr. Tjipuro asked when the project will start if a clearance is granted since from Town Council’s side planning is required. Mr. Pieter Kruger said their client wants to start in January 2019, but this is not possible due to a number of planning issues still to be finalised. However it will be as soon as possible once all arrangements are in place. A question was raised regarding the environmental assessment timeline. André explained that GPT will try and finalise the draft report before the Christmas holidays. It will be circulated to all registered parties for further comment. He stated that submission will not be before January next year, and the time required for review by the competent authority is not known. There being no further comments the meeting was adjourned at 11:30am

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TEL .: (+264-61) 257411  FAX .: (+264-61) 257411 CELL .: (+264-81) 1220082 PO BOX 11073  WINDHOEK  NAMIBIA E-MAIL : [email protected]

Minutes of Meeting Re: Second Public Meeting: Environmental Assessment for the Proposed Export of Manganese Ore via the Port of Lüderitz Date: Tuesday 29 January 2019 Time: 18h00-22h00 Venue: German Hall, Angra Pequena Secondary School, Lüderitz

In attendance: Name Organisation André Faul Geo Pollution Technologies (GPT) Pierre Botha Geo Pollution Technologies (GPT) Pieter Kruger Pektranam Logistics Ben Kruger Pektranam Logistics Johan Kruger (senior) Pektranam Logistics Alfonso Ferreira Not Provided Arthur le Hanie Student Bessly Makaula Lüderitz Junior Secondary School Cecil Kamupingene Namport Charmaine Kock Community Member Christaline Kaangundue Lüderitz Town Council Crispin Clay Lüderitzbucht Foundation Crystal Jantjies Lüderitz Junior Secondary School Elisabeth Jantjies Community Member / Teacher Erkkie Andreas Community Member Ferdie de Villiers Novaship Fillipus Hedimbi Namport Frans Ndjaleka Ekuva Trading Enterprise F. Gariseb Community Member Giel du Toit Rockbreaking and Demolitions Namibia cc H. Ludwicht Office of the President H. Schmidt Community Member Howard Head CEO Ghost Town Tours Member Luderitz Tourism Forum Member Ocean Grown ( Oysters) I.N. Tjipura Lüderitz Town Council Ileni Nghishekwa Ministry of Labour Innocent Sinvula Sturrock Grindrod Jean Paul Roux Ministry of Fisheries and Marine Resources

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Josh Jones Community Member Jurgen Fleidl Five Roses Aquaculture Kakakoro TransNamib Holdings Kennedy Jonas Community Member L. Schmidt Community Member Lea Apulile Community Member Leroy Makaula Student Luqman Cloete The Namibian Manfred Anderson Community Member Manu Namukomba NovaNam Marion Schelkle Lüderitz Safaris & Tours Marsha Pickering Community Member Matthew Adler Peace Corps Max Cooper Namport Michael Mackenzie NovaNam Michael Viljoen Hangana Seafood Not Provided Naftal Trading Enterprises Norbit Klosta Salz Gossow Patricia Kaulinge NovaNam Paul Schroeter Community Member Penda Ugwanga Community Member Priscilla Roode Community Member Rassie Erasmus Hangana Abalone Reginald Hercules Community Member Ruth Community Member S. Kalumbu Community Member Suzan Ndjaleka COSDEC Sakaria Hofni Community Member Simon Struben Not Provided Tuulikki Abraham Private Verdiana Lucas Community Member Victor Musungo K&A Engineering Wetu Ndjonduezu Student A. Xamub Nampol Yvan Jacobs S/B Lüderitz

André Faul of Geo Pollution Technologies welcomed the audience to the meeting and proceeded with a presentation aimed at addressing some concerns of the general public, with regard to the proposed manganese ore export via Lüderitz. He introduced Geo Pollution Technologies as being responsible for the environmental assessment and Pektranam Logistics as the company who wants to realise the export of manganese ore via Lüderitz. On request by members of the Lüderitz public, André explained the Environmental Management Act regulations of 2012, in terms of the public participation process, the rights of registered interested and affected parties and non-compliance. He gave an overview of the current status of the environmental assessment being conducted for Pektranam Logistics and stated the

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process is still ongoing and public participation and stakeholder engagement are still open and ongoing. He stressed that the public must be clear that Pektranam Logistics has not been involved in the illegal transport and offloading of manganese ore in Lüderitz in December 2018. He also explained that part of the environmental assessment process, is to guide clients in terms of a projects’ execution and that this is the case with Pektranam Logistics as well. Specifically with regard to the storage of manganese which will now no longer be done in the open, but rather in closed bulk bags with a change to closed warehouse storage in future. Pieter Kruger of Pektranam Logistics proceeded with a presentation to put the project in perspective as seen from their side. He provided more background on the manganese ore in relation to its source as well as the plans for the project and Lüderitz. After the presentation the audience was invited to discuss the project and provide input to be considered in the environmental assessment. Dr. Jean Paul Roux congratulated Geo Pollution Technologies and Pektranam Logistics for being transparent and their willingness to hold a second public meeting to update the public on the project. He noted that the change of scope in Pektranam Logistics’ project, form open storage to closed handling and storage, is positive and that hopefully it will not revert back to open storage. Ms. Joan James expressed her disagreement with Pektranam Logistics’ statement that there will be an influx of business into Lüderitz as a result of the project. She stated that only Namport will receive business. She stated that [Pektranam Logistics] has clearly proved over Christmas that they will not adhere to what was promised in terms of warehousing and job creation and that imports was not done correctly. André once again stated that the client represented at the meeting is Pektranam Logistics and not the company who was responsible for the manganese ore offloading during December 2018. Ms. James confirmed that she is aware of this, but reiterated that locals will not be supported by this business [manganese ore export via Lüderitz], and stated that all that [Pektranam Logistics] are coming to do is to mess up the environment and all that was protected over the years and that the proposed project will destroy tourism. She again said that if [Pektranam Logistics] carry on dumping the ore like they have just proven all the rules are going to be broken. She said the imports were not done correctly, roads will be destroyed and that locals will not be supported and that only outsiders will make money. She repeated some of the arguments and again stressed that none of the [benefits] will realise as is promised. André noted the concerns and again stated that Pektranam Logistics should not be confused with the company involved with ore offloading during Christmas. It is thus a false accusation to state that they [Pektranam Logistics] have proven that they will not carry out the project as promised, even though they have not been involved in any ore offloading at Lüderitz. He further stated that Pektranam Logistics will have to comply with the EMP, which includes bulk bag or closed warehousing to prevent dust, since it will be part of the environmental clearance certificate conditions, and non-compliance is punishable under the Environmental Management Act. [Note that Ms. James did not register as interested and affected party for this project and has not completed the attendance register for the meeting. She also arrived late and clearly missed the important points discussed during the meeting.] Ms. Suzan Ndjaleka stated that, from an economic point of view, and Lüderitz’s economic stagnation, she foresees that the project will bring jobs and increase economic activities in town. She however also stressed that the manner in which the project is performed, must be sound, coordination must be strengthened, and all relevant authorities consulted. She concluded that she supports the project. Lesley Makula stated that, what was shared during the presentation, was educational and mind opening. He stated that this [the manganese ore export project] is welcoming development for Lüderitz and the locals. It however depends on the community themselves, on how they divide and organise themselves, how they will directly benefit from the project. He stated that the community should support a project such as this. He stated that he hope that the youth will be made aware of the development, the potential benefits, and the growth of the town [Lüderitz] in the region. Mr. Manfred Anderson reiterated Dr. Roux’s statement on how the presentation was put across the table. He however stated that it is irresponsible from Pektranam Logistics’ side to quote a general practitioner as to the safety of manganese ore and that tested facts and the World Health Organisation should rather be referenced. He further stressed that in future, information regarding staff turnover should be given in terms of mortalities and retirement in terms of medical disabilities. He stated that it

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was “conveniently” left out of the presentation and that this is irresponsible. André stated that, as he explained in the presentation, there is a lack of scientific information specific to manganese ore dust and that therefore the precautionary principle is followed which aims for zero dust. The OSHA (Occupation Safety and Health Administration) limits, as was presented, are the international standards. He stated that Pektranam Logistics is committed to zero dust. Mr. Pierre Botha stated that he would like comments to contribute to the discussion by presenting problems that need to be solved or solutions to such problems. Mr. Ignatius Tjipura stated that the Town Council is a government institution that acts as a catalyst for development in the constituency. They must cater for investment while working hand in hand with ministries like the Ministry of Environment and Tourism. He stated that manganese ore has been transported from Otjiwarongo to Okahandja, where it is stored in the open, and from there transported to Walvis Bay for export. He said he has never heard the people of Okahandja talking about manganese ore being toxic, or that any fatalities as a result of the ore has been recorded. He also cautioned the public from believing, beyond question, what is presented on the internet. From the Town Council’s side they support development that will lead to job creation in town. He encouraged the public to be entrepreneurial and to look at ways how they can get involved in, or benefit from, such projects. He noted and welcomed Mr. Kruger’s willingness to assist in upgrading Bismarck Street. Mr. Reginald Hercules thanked Mr. Tjipura for delivering the Town Council’s viewpoint. He stated that we [the Lüderitz residents] are not against development. He said that if the “toxic manganese ore” is transported in bulk bags or contained in a closed warehouse, the residents will not have a problem. He stated that in Chile they put the ore in sealed containers at the mine, and only then is it transported to the harbour. He referred to the Scorpion Zinc warehouse, a big investment, in the Port of Lüderitz which has a loop drainage and dust suppression system. He again stated that should this type of infrastructure be erected in accordance with the law, the residents will not have a problem. Mr. Hercules then expressed his view, that to bring in manganese ore and try and dump it in his back yard, is a big mistake. He stated that [Geo Pollution Technologies] conveniently did not mention the dust issues in related to manganese ore exports via the Cape Town harbour. Also, they [Geo Pollution Technologies] failed to mention the concerns of the Port Elisabeth people. He stated that what you [Pektranam Logistics] are trying to do is to make it a cheap operation through Lüderitz. He said that we [the residents] try everything to protect the environment. Mr. Hercules insisted that Pektranam must do their business right and not try and bring it [the ore] in cheaply and that the investment must be made here on the ground [the warehouse]. He stressed that if you try and dump stuff outside [ore at the TransNamib rail siding] you are in violation of every law. André reiterated that Pektranam Logistics was not responsible for dumping ore outside of Lüderitz and that they are willing to, as was clearly stated during the presentations, to invest in infrastructure and to use bulk bags to prevent and minimize dust. Mr. Ileni Nghishekwa reiterated that they [in his private capacity and as representative of the Ministry of Labour] are not against development as long as it is done safely and properly. He stated that if your business, example tourism, will not benefit from the manganese export project, you have to keep in mind that there is also a very large portion of the community that does not benefit from your tourism ventures. He continued that we should not be selfish, everybody cannot gain from each project, but we should allow others the opportunity, and that there will be spinoffs to the larger community. Mr. Paul Schroeter mentioned that manganese will not be listed as a heavy metal if it is harmless. Taking it in through something you eat is natural, but inhalation is not natural. He then expressed his concern regarding the volumes that will be transported in conjunction with what is already transported by, for example, Scorpion Zinc. He asked what the future implications of the large amount of trucks will be, for example, to the tourism sector and congestion in the main street. André explained that it is something that is being looked at in the environmental assessment and there are certain aspects that the client are investigating to minimize traffic related impacts in town. Mr. Tjipura stated that if the project commence, there are measures that can be taken or alternatives that can be investigated. It comes down to control of the traffic. He stated that should the Angra Point deep water port realise all trucks will move out of town.

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Ms. Marion Schelkle stated that fishing and diamond mining were always the main two legs of the economy, but tourism has become the third leg. She stated that there are 34 guesthouses and hotels in Lüderitz. She explained that there are many residents who are training in this industry and who will become part of the tourism industry. Ms. Schelkle expressed her concern with regard to the potential negative impact of traffic on tourism. She explained that tourism is frail and that there are many people in Lüderitz who relies on it. Pierre commented that it is a difficult element to assess and address in the environmental assessment. He said that just as one person has a right to do business, someone else also has a right to do business. It is difficult to find the balance between the two. That is why we ask for suggestions from the local public on how both can be accommodated. We can’t say potential port activities should no longer be entertained as this is now a tourist town. Ms. Schelkle confirmed that one has to be accommodating, but the tourism industry must not be forgotten. Mr. Fillipus Hedimbi welcomed the current meeting and the dissemination of information related to the environmental assessment and the project. He encouraged the public to do accurate research regarding the toxicity of manganese ore. He stated that if the plans are there [to prevent dust and mitigate impacts], and they are put in place, the project will be positive and provide employment. Development is thus welcomed. Mr. Max Kooper stated that passenger vessels will always get preference in the port. He also stated that monitoring systems are in place in the Port of Lüderitz to monitor for dust and other impacts. Namport also audit the monitoring results which include staff medicals, of the various port users. Namport thus ensure compliance to the respective EMPs of tenants. Mr. Michael Mackenzie stated his concern regarding possible port congestion. He is concerned that existing port users will be pushed aside. Secondly, he is concerned about the 12 to 15 days of trucks moving through the town. Mr. Kruger explained that it will be six to nine days combined for all parties involved in the manganese ore export, since the port is limited to sixty to ninety thousand tons of ore per month, which will mean two to three shipments. Pierre explained that the town council must make adjustments to traffic regulations, traffics signs, etc. in terms of the potential additional traffic that will be generated. Mr. Mackenzie noted that they should take away the rail section through town and put the trucks on that corridor. [The latter statement was received light-heartedly by the audience, but the idea was given serious consideration after the meeting. The possibility of using the railway servitude for both trucks and trains are now being investigated.] Mr. Cecil Kamupingene stated that he is impressed by the presentations. He emphasised that Namibia is a SADC member and have agreements with SADC members. He stated that, as Namport, it is their mandate to help Namibia reach its National Development Plan goals of becoming a logistics hub. That is the role of state owned enterprises, to drive the government programmes. He continued that from government’s side, he is sure they will welcome this type of development as capital influx is required and social economic deficit are addressed. He further mentioned that government will continue to assist other sectors, for example tourism, as this also forms part of the National Development Plans and Harambee Prosperity Plan. Dr. Roux said it will be useful to determine the baseline traffic conditions, taking into count all the existing trucking activities in town and especially Bismarck Street. He stated that Bismarck Street is the economical centre of town, with most of the major business and with many tourism establishments. He emphasised the potential impact on the traffic in Bismarck Street. Mr. Botha stated that the problem with Lüderitz and Walvis Bay is that the towns lock the harbour in, and then you sit with the problem that is now on the table in Lüderitz. Mr. Hercules reiterated his previous statements regarding doing the project in the right way, i.e. in bags and warehouses. He stated that the manganese that is currently stored in the rub hall in the port [impounded manganese from December manganese saga] is not ideal and does not conform to international standards. He felt that the international people regulating these issues should be invited to come and assess the situation on the ground. He proceeded to expand on the December manganese saga [which falls outside the scope of this meeting]. Mr. Botha stated that once the EIA is cleared and the environmental clearance certificate is issued, it becomes a contract between the client and government. He stated that the members of public must be the eyes and ears on the ground for government and if

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non-compliance is noticed, the public must notify the ministry. However, the true identity of the party at fault must be established. Mr. Anderson stated that the presentation lacks any information regarding the future environmental footprint that Pektranam will leave on the environment. He noted that the trucks will travel through a declared national park between Aus and Lüderitz. He continued that the trucks will pass many communities on the way from Ariamsvlei to Lüderitz. He noted that we [Geo Pollution Technologies] should not be preferential in who we decide would be in harm’s way. With the wind in Lüderitz a dust plume can reach wider than just the immediate surroundings of the storage yard or transport route. He stated that they [the people of Lüderitz] filtered information as pertaining to the events of December and that at no stage were the public against development. André stated that just because there are some impacts not mentioned in the presentation, does not mean they will not be assessed. Ms. Crystal Jantjies noted that the December incident has opened the eyes of the community and that there is nothing wrong with the fact that there were people on the ground that questioned the happenings. She said that what transpired in December provided Pektranam the opportunity to come back with transparency. Ms. Jantjies noted they will be watchdogs and that it is their right to question issues. Ms. Christaline Kaangundue asked, how will runoff water be collected and dealt with during dust suppression with fresh water? André explained that dust suppression is by a very fine mist and that water content of the ore may not become too high. There should therefore be no runoff. Mr. Ferdie de Villiers further explained that if water content of ore is too high, it becomes a safety risk in the ships. When the ore compact in the cargo ship, the weight of the ore will cause water to accumulate and can start rolling in the ship, which can in turn cause instability and capsizing. Thus the water content is strictly controlled. Mr. Hercules asked if a loop drainage system will be present in the proposed warehouse. He again emphasized that the investment must be made and the infrastructure must be in place prior to operations. André again explained that the commitment is there from the client’s side to from the start use bulk bags with warehousing at a later stage. Mr. Hercules asked about the bulk bag transport process. André explained that trucks carrying the bags will be offload at the storage yard, which currently will be the old RCC yard. Bags will be covered with tarpaulins at this location. Once a ship comes in, the bags will be loaded by forklift and transported to the harbour, where they will be loaded into the ship’s cargo hold and emptied. If needed, there can then also be dust suppression on the ship to prevent dust from escaping. Mr. Hercules expressed concern regarding dust fallout on the fishing vessels and the environment. André noted that in the Port of Lüderitz, the ore handling ships are only allowed on the northern end of the quay wall. This is because the prevailing winds are in a north-westerly direction, which will take dust away from the fishing vessels. André again elaborated on the role of the Ministry of Environment and Tourism and the public’s role in playing watchdog. Pierre stated that it was Geo Pollution Technologies’ aim to advocate zero dust from the start. There being no further comments the meeting was adjourned at 22h00.

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Email Correspondence Received The following section presents all written communication received from registered interested and affected parties. All communication is presented as it was received with only font formatting standardised. Due to the repetitive nature of many questions, answers to questions that have been covered in the scoping assessment are not provided specifically. Only where certain issues or concerns were not addressed in the scoping assessment, or during the meeting as presented in the minutes, are answers / comments provided. Communication Received After during the First Round of Public Consultation

From: Crispin Clay Chairman: Lüderitzbucht Foundation / 2018-11-27 Resident One immediate question arises: I see no mention in the Background Info document of our railway line which ‘we’ assumed was for bulk loads to our port. Our B4 road was built in the mid 1970s – now over 40 years old – and it was never intended to carry the heavy trucks from Rosh Pinah or Kuruman. The line ends next to the quay. RSVP! Comment: Ad dressed in report and minutes of meeting

From: Crispin Clay Chairman: Lüderitzbucht Foundation / 2018-11-29 Resident Some questions, online info, reactions from a few locals consulted: 1. WHO is behind this proposal? WHO are Pektranam and their owners? 2. Will they use sea-water for washing down and dust-capture? Don’t use our fresh water. 3. Will (our local?) scientists take soil samples now, as a base-line to measure soil contamination for years to come and monitor it successfully? [This was a major issue that was overlooked when the sulphur project started many moons ago.] See Chicago below. 4. Despite active water-based ‘fugitive dust’ suppression methods, operators must monitor levels of respirable dust throughout the dry bulk handling and while the material is stored to await further shipment. When maximum levels are hit, port operators must shut down and incur expensive delays. Would these not apply here? 5.Check out Industrial dust control in Chicago’s winds by HKD-Blue machines: https://www.hkdblue.com/2018/05/01/chicago-dry-bulk-fugitive-dust-control/ 6. Check queried manganese exports via CT: https://www.iol.co.za/news/south-africa/probe-into- loading-of-manganese-at-cape-town-harbour-2093693 Under 100,000 tons needs no licence in RSA. What about these 30,000 ton loads? Namibian licence? 7. Manganese affects mainly the respiratory tract and the brains. Symptoms of manganese poisoning are hallucinations, forgetfulness and nerve damage. Can also cause Parkinson, lung embolism and bronchitis. Men exposed to manganese for a longer period of time may become impotent. 8. Chronic Manganese poisoning may result from prolonged inhalation of dust and fume. The central nervous system is the chief site of damage from the disease, which may result in permanent disability. Symptoms include languor, sleepiness, weakness, emotional disturbances, spastic gait, recurring leg cramps, and paralysis. A high incidence of pneumonia and other upper respiratory infections has been found in workers exposed to dust or fume of Manganese compounds. 9. What beneficiation is ‘planned’ in the future? What value added IN Namibia? What 2ndary industries can come out of it? What benefit to LZ? Instead of a major port at Angra Point, Could ‘they’ consider a refinery at say Seeheim: near to Naute and Neckartal Dams, roads and rail and airport, and workers in the area? Then export MUCH smaller tonnages of concentrate by RAIL through existing port. Or even spin-off industries locally adding value. 10. More accidents, HIV/AIDS, drugs, violence and other diseases. Stay in RSA!

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11. COST to our town of road damage, disruptions, pollution, effects on tourists and locals, effe cts on local marine resources, birds, other exports. 12. Let them rather go the similar distance from Hotazel/Kuruman to CT/Saldanha, PE, Richards Bay/Moputo, than ruin OUR roads, town, port, lives/health, buildings, marine life etc. ‘But it would save us so much time and money and two days at sea’ - Tough. Not at OUR expense. Rather theirs. Their ports already congested? Tough. Do without the manganese then. Save the carbon. 13. Why are grapes still not being exported via LZ having been promised so often? But THIS may get priority? … Priorities! Comment: Mostly ad dressed in report and minutes of meeting. With regard to licencing, they will require the environmental clearance certificate. Issues related to future beneficiation and refining falls outside the scope of this assessment.

From: Gordon Negongo Community Member 2018-12-03 I am Gordon S Negongo i attended the EIA the above mentioned subject heading as is clear on the attendance list i was there in my capacity as a community member and i got to attend the meeting by chance as the news papers that it was advertised in are not the once that i read and i know that the Namibian is the most popular news paper in the country anyway here are my question. No:1 I have to say that i do agree with Mr Head on who will be held liable for the people that will be affected over a long period of inhaling the dust from that will be blown from the storage site when offloading and load on the trucks takes place as you will clearly see that should one stand at the storage site and look to the north one will see the houses of Area 2. No:2 What if any are the will be the the Social Obligations of the company should the our Government approve the Plan. No:3 How transparent will selection of the locals be in the recruitment for jobs not only in the construction phase but also in the operational phases of the company and how will it be done and by whom and who will evaluate that it was and is indeed don in a way that gives preference to the locals. I thank you and look forward to hearing from you so that i can report back to the members that i represent. Comment: Ad dressed in report and minutes of meeting.

From: Michael Mackenzie Novanam / Resident 2018-12-03 We only have the following few questions 1. Will they be washing material down to prevent dust. 2. Who will maintain the road from storage area to port 3. Will cargo be covered during transportation to port. 4. When will proper enclosed storage facilities be build. 5. The road alongside the lagoon area is used by a lot of tourist who stop to take photos on route to Diaz point ,having so many trucks travelling this route will result in injuries or serious accidents. 6. As Luderitz has a premonitory southern wind ,dust particles will be blow straight on the town ,who will monitor these effects as dust particles will result in MANGANISM sickness. 7. What will be done to noise pollution and traffic congestion during the 24 hours planned operations as the route passes guest houses ,restaurants and residential areas. Who will take responsibility for loss of income to center town businesses. Comment: Dust suppression by means of washing down will be performed when required. Maintenance of all public roads will remain the responsibility of the relevant authorities. Pektranam indicated their willingness to support the authorities in upgrading sections of roads should other bulk transport users of these roads also contribute. Private roads will be the responsibility of Pektranam.

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From: Martin Mouton TrenTyre / Resident 2018-12-04 Hi I just want to inform u that there is no negative impact from our side. Its just that we see this in a way of good business for our small town. We self at Tren Tyre are interested to do business with u people. Don’t hesitate to contact me for any further assistance. Comment: Noted

From: Crispin Clay Chairman: Lüderitzbucht Foundation / 2018-12-04 Resident Here are some more comments to pass on: 1. From News24: a double-load of manganese dumped in the middle of Barkly West just last Tuesday! Shows the amount of ‘product’; the size of the truck&trailer; the dark dust : https://www.news24.com/Video/SouthAfrica/News/watch-northern-cape-protesters-force-truck-carrying- manganese-to-dump-load-20181130 2. On human-health hazards: https://www.researchgate.net/publication/237079224_Manganese_Environmental_Pollution_and_Health_Effects 3. On cleaning up: see page 24 for manganese: http://standard- club.com/media/23964/15056CargoJan2011Bulletinv06.pdf 4. Cape Town Probe , Nov 2016: https://www.iol.co.za/news/south-africa/probe-into-loading-of-manganese-at- cape-town-harbour-2093693 5. I’m sure those concerned will know – Google INTERNATIONAL MARITIME ORGANIZATION (IMO): SHIPPING CODE UPDATES 6. And https://www.sciencedirect.com/science/article/pii/S0025326X16303861 Luderitz - On top of existing traffic hazards and wear-and-tear on OUR LIFELINE B4: 7. At the B4 turn-off south to the old RCC Depot currently being demolished: There ‘may be’ congestion near the already-dangerous bend before the Prison turn-off: A) Full trucks coming in from RSA/Aus turning left south to the RCC depot, plus B) Full trucks with skips coming from RCC depot turning left west to the port, C) empty trucks from RCC depot turning right east across traffic towards Aus/RSA, D) empty skip trucks coming back from the port turning right south across traffic to RCC, E) full sulphur trucks coming from the town towards Aus and F) empty ones coming back from Aus to the port; G) full Trucks with Lead / Zinc concentrate ingots inwards to port, and H) empty trucks out again to Aus; I) ‘normal’ traffic of taxis, , trucks, bowsers, cars, buses , coaches, caravans, campers , 4x4 convoys … J) HOPEFULLY the latter (the 4 Cs) will increase as tourism grows with the Oranjemund road and National Park opening up to break the cul-de-sac syndrome. 8. The 60cm diameter concrete pipe under the roadway just south of the RCC turn-off might collapse under the first full truck of 65 tons. Trucks will need a slip-road to take the right-angled turn coming in from the east/Aus (4A above) or going west to the port (4B above). The river has been known to rage in full spate during and after rare storms, cutting the road and damaging it. And then? Impact on schedules? Backing-up of trucks – where? NO spaces in town most of the time.

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The gravel roads will be quagmires during and after any rain that falls: the RCC depot road; on the west side of the railway from the Water-tank hardstand to the Radford Pan causeway; and the southern gravel part of Bismarck Street from the level crossing to the bridge junction. 9. Will there be a full truck-port with its own fuel-pumps ? If so, where? Out of the way of normal traffic, some of which are ALSO on tight schedules? 10. Manganese Supply ‘jumped 30% against August and 22% year on year to 666,000 tonnes due to miners in China ramping up to feed manganese-alloy smelter restarts when environmental restrictions ended’, https://www.metalbulletin.com/Article/3846693/World-manganese-ore-supply-jumped-in-October-led-by-ramp- ups-in-Africa-China.html What happens when ‘environmental restrictions’ are replaced by even tougher ones soon? Especially for shipments by sea. Extra costs all round. China under huge pressure to clean up their acts. The ore going via Luderitz would be going to China … 11. South African miners will continue to need road transportation to get their material to port, according to Thembalani Gantsho, joint chief executive officer of Kudumane Manganese Resources. Road freight will be needed to meet the shortfall in capacity offered by the country’s rail freight company, Transnet, Gantsho told delegates to Fastmarkets International Ferroalloys Conference in Lisbon, held November 11-13, 2018. Although improvements have been made in the performance of the rail service for manganese ore freight, Transnet remains a brake ... Hence we would not be able to get rolling stock from RSA for our railway-line anyway. For anything . Get our own ? Guess who from … Ooops. Free - in exchange for this manganese?! 12. This EIA was only for ONE outfit? What about the second one that most of us didn’t know about? Who are they anyway? When will they want our attendance at THEIR EIA meetings? Any others ? 13. When the price of manganese on the world markets drops or collapses , which export operation will be the first operation to be closed down? Luderitz of course – with no recourse for rehabilitation of damage, eyesores and environmental threats. The Namibian drivers will suddenly be stranded. No doubt the trucks will be whisked back to RSA. They should have to pay a deposit to cover such restoration afterwards anyway. 14. ‘Not past MY front door thank you!’ Comment: Mostly addressed in report and minutes of meeting. Point 8 – trucks will be 36 tons, not 65 tons. There will only be a consumer fuel installation supplying diesel to front-end loaders and vehicles on site. Trucks from South Africa will refuel in Keetmanshoop.

From: Howard Head Alma Marine / Cormorant Guest House / CEO 2018-12-04 Ghost Town Tours Thank you for the opportunity of commenting on yo ur environmental meeting held yesterday. Firstly let me reiterate that I am not averse to economic development in Luderitz. However past experiences have proven that once the EIA has been completed and the necessary license obtained, the conditions are not always adhered to leaving the citizens of Luderitz with little or no recourse. My concerns are as follows: 1. Mr Pieter Kruger referred to the fact that the health risks of being exposed to Manganese dust as being “highly unlikely”. Conversely then it can also be “likely”. Is this a researched and documented fact or merely his own opinion as the client. 2. He also mentioned that there will be limited or no dust from the manganese ore during transport, storage, loading and shipping . I would like to see a step by step procedural plan of how this will be achieved and who will monitor the systems and what measures will be put in place to handle dust and spillage should they occur. Our prevailing Southerly winds would transport any manganese dust from the potential storage area at the old RCC camp into our homes and businesses. As I understand the manganese will just be dumped and ag ain loaded with a front -end loader onto the skip bearing trucks. I am of the opinion that with the

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friction during this process Man ganese dust will be created. You need only to research Manganese dust in Port Elizabeth to see what we will be dealing with. 3. Has any research been done on what the effect of the increase in heavy traffic will do to the condition of our roads. 4. Reference was made to mitigating measures to reduce noise levels of the trucks. What are these and how will they be implemented when the 24/7 transport of the ore takes place during the loading. 5. The noise levels of the trucks passing churches and schools on their proposed route would disrupt services and also classroom activities. The route passes the AFM and Roman Catholic Churches as well as right in front of the Helena van Rhijn Primary school. 6. The safety of our children in this busy road in close proximity to the school needs to be taken into account as well as the dust created on the gravel road that will envelop the school buildings. 7. Hospitality establishments housing guests along the route will be negatively effected. It only takes a few review posts on social media to stop potential clients booking due to excessive noise levels . 8. Marine water pollution is of concern as expressed by Dr J.P. Roux from the Ministry of Fisheries and Marine Resources. 9. Luderitz has a large mariculture industry. Oysters being filter feeders could be negatively affected by any manganese dust entering the water. Easterly winds would drive the dust directly from the storage areas onto the Oyster farms. 10. Tourism in Luderitz is a major contributor to the economy of our town. Being a cul de sac destination we have worked hard to make the town a destination of choice in Southern Namibia. We are blessed to have Kolmanskop which is rated the number one Ghost Town in the world as the major draw card. Coupled with this is the fact that Luderitz will be considered the gateway for the new MET Sperrgebiet National Park. The aesthetic nature of Luderitz with its unique architecture and pristine peninsula are what we pride ourselves on in the the industry. 11.The considered manganese exports will most certainly sound the death knell for tourism as we know it. Turning the town center into a highway of trucks operated on a 24/7 basis. Initially Pektranam plans to operate for 3 days per month with a ramp up to 12 days per month. I am unsure of the frequency of export of the other company involved. Should this be the same we are looking at an eventual 24 days of 24/7 operations excluding the daily Zinc trucks from Rosh Pinah. I have been in the tourism industry since 1997 and one thing I have learned in this time is that touring companies are unemotional about destinations or activities. If tourists do not enjoy the experience and the challenges and complaints are too numerous , they merely take the route off their itinerary. This is something that the town can ill afford. In closing I would like to say that the consideration should be the risk for the town , citizens and environment versus the reward for the town , citizens and environment. We need not only to be blinded by the the revenue for the Port . Maybe the building of the new Port at Angra Point as proposed by Namport should be re visited. It is my considered opinion that the risks in this instance are greater than the rewards. Comment: Ad dressed in report and minutes of meeting. The report addressed the dust issue with the assumption that the ore will contain a certain amount of dust and as such compulsory preventative and mitigating measures are listed. Should evidence become available that Pektranam does not adhere to the EMP, including prevention of dust, the environmental commissioner can issue a non-compliance order and activities must then cease.

From: Crispin Clay Chairman: Lüderitzbucht Foundation / 2018-12-05 Resident Good grief - FRESH water – for WASHING DUST off ORE? In such a DROUGHT/desert? More responses:

1. How many times a day would our own Water Tank(s) be emptied?

2. How long will Koichab reserves last?

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3. Where will the rinse go? Include section on prevent overspray

4. Who, IN LUDERITZ, will have the POWERS to STOP the operation when it FAILS environmentally?

5. What ‘mitigating’ efforts would have to be made to PREVENT pollution of our nearby marine resources? Also while THEY are being loaded?

6. Lots more questions no doubt from our marine industries.

7. Which do we prefer - that our town stays clean or that South Africa and China use up our fresh water to wash their ROCKS ? They can research ways to use salt water without negative chemical reactions in their ore. And then use a South African port’s sea water. Not ours - which must also be kept as pure as possible for OUR EXISTING PROVEN-SUSTAINABLE industries.

8. Having FOUGHT in the 1960s to GET the Koichab Scheme, our town EVENTUALLY saw it happen in 1969. Before that, our water was amongst the most expensive and difficult in the world. We do not now wish to sell the remaining water before it reaches saline levels just to WASH ROCKS, DUST and QUAYS - of all wasteful absurdities. For South Africa’s and China’s benefit and our own irrevocable damage perhaps – even more absurd.

9. Why has RSA not built manganese refineries for value-added secondary industries instead of these huge problems exporting the raw ore? ABSURD! Comment: Addressed in report and minutes of meeting. The Khoichab Scheme can currently sa fely meet the demand for additional water usage. Due to the expense of the water, it will be in Pektranam’s own interest to use water sparingly. The environmental commissioner has the power to stop the activity if not compliant to the EMP. Refineries in South Africa falls outside the scope of this assessment.

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From: Ulf Grünewald Lüderitz Tourism Forum / Lüderitz Nest 2018-12-07 Hotel / Resident

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Comment: Addressed in report and minutes of meeting

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From: Crispin Clay Chairman: Lüderitzbucht Foundation / 2018-12-10 Resident It is sad to appear negative in the face of what some believe is an attractive major ‘development’ for Luderitz. But there is a serious threat to our town and we urge those in power to hear us. I propose that we call for an urgent MORATORIUM on ALL NEW such plans to export South Africa and/or Botswana piecemeal through our country at vast risk to our people, our resources, our environment: for instance the transit -export of manganese, coal, iron ore, uranium ore, phosphates etc. All require ‘washing’ – with our scarce precious clean drinking water, whether in Luderitz, Walvis Bay, Gobabis or anywhere in our ‘Land Between Two DESERTS.’ Our primary concerns are our people’s health and lives; our water; our land and sea and air purity; our roads; our existing industries which so many Namibians already rely on despite difficult global conditions. As Howard puts it, RISK versus REWARD . Our potentially affected industries already face so many risks for such variable and VULNERABLE rewards that increasing our risk for OTHER countries’ reward is frankly ABSURD and should be stopped. Preferably permanently, but at least until COMPREHENSIVE independent , international, credible, scientific environmental studies are COMPLETED, assessed by all relevant parties, and CONSENSUS on the way forward reached. This should include a broad educational element – for ALL stakeholders including politicians, ministries, local and regional officials as well as affected industries, NGOs, activists – and the next generation who have to cope with the results of our decisions. Those studies, those conversations, do not happen overnight. Let us beware of speedy-greedy permits that MAY do irrevocable damage , to OUR town and to OUR country in the long term. Comment: Noted

From: Lewis Druker Coastways Tours / Resident 2018-12-10 We as Luderitz Buchters strongly oppose to the handling/exporting of Manganese via our port. Comment: Noted

From: William Korf Chemvet CC t/a Coldwater Divers / Resident 2018-12-11 With regard to the meeting held on the 3rd December at Ministry of Fisheries Luderitz I would like to raise a few points please We welcome any new business to our Town as long as there is Investment and benefit and not to the detriment. Has an Environmental Management Plan been formulated due to the highly flammable nature of the product. Do we have the relevant Fire Response needed. Is the promise of building a small piece of tar road that will only be used for themselves the only benefit to the town. Are there any studies conducted on the traffic flow and the disruption the trucks will cause. Has the option of closed containerization for the transport of the product been considered Is there a fund available for the rehab in the event of the stockpile being abandoned What recourse will there be for medical issues arising from the product dust pollution (being a windy town) What recourse is there for business and property owners regarding the pollution and noise disturbance Where will disputes be handled seeing as the principal contractor is a South African Operation Why is the Mining Company and owner of the product not included in this study, only the Transport Company is involved Where will the truck drivers be accommodated and for refueling as there is very little parking available and only two service stations What employment options are available for the locals as per your mention of 30 positions

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More time is needed to do a study of the impact on the many marine aquaculture facilities in the immediate area. None of the relevant fishing operators were involved in the public meeting and it is vital that their input be considered. No one from Namport was present either. The meeting was not well publicized in the Town. The local newspapers are not available on the day of publication so it is not a reliable way to inform the locals of public meetings. 3rd party social media did inform some of us Why was the Health Department not present to provide important information Can the manganese dust react with any of the other products that are presently being stored and shipped from the Port Is this not setting a precedent for companies to use existing properties as an open mine storage facility Comment: Addressed in report and minutes of meeting. The current document inclu des the environmental management plan for the project. Manganese ore in nugget form is not flammable. Only when it is in powder form will it become flammable and only if significant amounts, in high concentration, becomes air born and an ignition source exist. A restoration fund is prescribed in the EMP. There will be a Pektranam representative based in Lüderitz who will also act as community liaison officer. The mining company and owner of the product being based in South Africa falls outside the scope of the current assessment. Truck drivers sleep in the cabs of their trucks and can do so at any location. Refuelling will take place at Keetmanshoop. Namport, the fishing industry and the Ministry of Health and Social Services were directly consulted with regard to the project. The newspaper advertisements were placed well in advance and the general public had ample opportunity to take cognisance of them. All companies who wish to use existing properties for storage will have to obtain permission from the owners of such properties and conduct their own EIAs if required.

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From: Jessica Kemper Scientist / Resident 2018-12-11

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Comment: Addressed in report and minutes of meeting.

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From: Howard Head Alma Marine / Cormorant Guest House / Ghost 2018-12-13 Town Tours / Resident The rail crossing at the four way stop in Bismarck Street will become problematic given the increase in volume of traffic. I am not quite sure of your proposed routes but this will have to be taken into consideration . The two pedestrian crossings also bear looking into as a safety concern with the traffic volume.

Comment: Addressed in report and minutes of meeting.

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From: Jean-Paul Roux Ministry of Fisheries and Marine Resources and 2018-12-16 Resident

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Comment: Noted and addressed in the report

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From: Fritz Hall Atlantech Marine Electronic cc / Resident 2018-12-16 As a resident of Luderitz I completely oppose the plan of Manganese export through the Luderitz port. The reason why I do this is as follows: 1. The heavy traffic that will occur not only in Bismarck street but also on the road to Luderitz a. The tar road has not been constructed to carry such heavy traffic like that of trucks b. The more trucks on the road the greater the possiblity of accidents. c. With our tourism coming into Luderitz by means of self driving the risk of accidents occurring is very high because lots of them are from outside Africa meaning Europe and USA. Most of them are using rental cars and are not always good at driving in our conditions. 2. Dust and noise pollution I work for a Business in Bismarck street and daily see the dust and noise from the already incoming trucks from Coleman Transport. Many times I have observed the trucks nearly run people over due to negligence. Tourists like to walk on the streets of our town but with so many trucks in Bismarck street as planned it will be nearly impossible to get over the street unharmed. In Bismarck street there are also guesthouses where tourists like to stay, but with the noise pollution of all the trucks I think they will rather not come to Luderitz any more. 3. Dump site at old RCC camp. Since the most of the time our wind is from the southwest the site will be right in the corridor of the wind blowing the dust right over the town which then poses a Health risk to residents. Manganese is a neurotoxin and therefore not good for humans. However I believe that there will be measures in place to keep spillage to the minimum. The same happens to the sulphur that is exported in Luderitz. You can see the pebbles everywhere on the quay and as far as the prison barracks in the beginning of the town. It does not matter how good and big your fight against spillage is, from time to time it will happen. When Manganese is loaded onto the vessel and something goes wrong the ore is spilled into the sea that will also kill all our marine life in the already fragile environment not to mention what will happen with the dust rising when ore is loaded into the vessel. The wind will carry that dust over the sea to our abalone farm situated on the other side of the bay killing th is industry in Luderitz. The same goes to our fishing factories which is a lot nearer than the abalone farm. We have a lot of guest houses on the other side of Shark island—a few hundred meters from the loading site. In this case this action will endanger the tourists health and once again they will also leave Luderitz. My question is what will happen in the future when the export stops and the habour is not needed for this any more. How will the dump site be cleaned and restored to its original state? My Last question is: Will you book a guest house in a street where you know lots of trucks run up and down and lay down and relax with the knowledge that the loads on these trucks are a health risk to you and the noise is so loud you can hardly sleep? Comment: Addressed in report and minutes of meeting.

From: Bernd Roemer Bahnhof Hotel Aus / Aus Desert Tours 2018-12-16 Regarding the abovementioned subject of Manganese exportation via the harbour of Lüderitz, we would like to register as Interested and Affected Parties, as Aus is very much also affected by certain aspects of this undertaking, because we will be directly affected by any possible negative side effects: 1) In Aus there are about 150 people directly employed by Tourism / Accommodation related enterprises. 2) At least 200 persons are crossing the B4 main trunk road between Keetmanshoop and Lüderitz at Aus two times per day, as factually all abovementioned employees are staying in Khaubeb and have to walk over the B4 to reach their place of employment and or pick-up point. Likewise do the pensioners have to cross the main road in order to get to the Post Office on pay-out days.

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3) Any resulting train traffic will cause a h igh risk accident zone at the railway crossing below the police station, as everyone is used to NO train movements at this location for the last 16 years, with subsequent disregard for the existing signage. 4) Long and slow moving trains crossing that road intersection at Aus might block the access route to town, resulting in frustrated motorists to turn around (although difficult on the steep incline) and skipping Aus altogether. 5) All the accommodation establishments in Aus will be negatively affected by noise pollution, no matter wether it is resulting from train traffic or truck movements. 6) The same establishments might be affected by dust pollution caused by manganes ore in transit, as Aus can have strong wind regiments at times, dispersing any dust particles over the town. 7) The B4 runs for ± 110 kms through a Nature Park and an increased vehicular traffic volume will have an impact on inter alia the Wild Horses of the Namib - especially at night collisions with horses have happened on various occasions. 8) Should the tourism industry of Lüderitz be negatively impaired through a decrease in visitor numbers, will Aus be directly affected as well. Most of the visitors coming to and through Aus, have the Wild Horses and Lüderitz (Kolmanskop) on their itinerary and if Lüderitz is not attractive any more, the whole route might be scrapped altogether. Comment: Concerns noted and addressed throughout the report.

From: Wilhelm & Yolanda Residents 2018-12-16 Steenkamp From Essenzeit Restaurant, guesthouses , any hospitality and Tourist supporting business view this will be a mesh for any further expansion of tourism business. We also agree with the arguments that this project makes very little sense in terms of increase economy value for Luderitz as town, and neither will impact positively on the people living in Luderitz. It will be a nuisance in terms of traffic , noise and dust for us Living in Luderitz, but also for the tourists visiting the town. For us it’s a “NO GO, PLEASE!! Let the Authorities look tourist wise to Luderitz and environment. Open the Khoichab Pan for Tourists and other to help a better distribution of visiting destinations for Tourists and look to the income Namibia got/get out of the Tourist market and how many Namibian work for the Tourists and Hospitality Industry. Boost it, it is CLEAN AND A WIN WIN FOR ALL NAMIBIANS – NOTHING TO WONDER ABOUT!!! Comment: Comments noted and addressed in the report. Promoting Lüderitz and surroundings as a tourist destination falls outside the scope of this assessment.

From: Crispin Clay Chairman: Lüderitzbucht Foundation / 2018-12-17 Resident Further questions for the EIA on manganese exports via Luderitz: The B4 Road to and in Luderitz has, within the final kilometer, 3 level crossings (with barriers?), two Namport gates, one bridge, one circle: DUST, sand and gravel on tar and interlocks? TRAFFIC BUILD-UP? DELAYS of all OTHER movements? WHO has priority? Contingency plans for breakdowns, spillage etc? 2 x 18t load per truck, for ONE ship taking 30,000 tons per month = 833 full trucks in 3 days = 277 per day = 11 per HOUR = 1 truck every five minutes in then out day and night for three days and nights per month. Correct? If ‘successful’, increase to TWO ships a month = 6 days and nights of loading a month; If ‘successful’, then bring FOUR ships a month = 12 days and nights of loading a month IF there are 2 OUTFITS = 24 days and nights of loading per month. Really?

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Can our streets take 8,330 trucks more than now every month? For how many years? Humans are not clocks: loading will not be a straightforward pattern of dependable precision timings of material, trucks, drivers, loaders, co-ordinators, papers, traffic, pedestrians and police all flowing in harmony – that is a pipe-dream: we are in Namibia. This is Luderitz. NOTHING is easy in Luderitz: Murphy’s Law, Clay’s Corollary: If NOTHING can go wrong, it will. Contingency plans? Plan B? RELIABILITY is the main concern. How much water will be USED to wash the ore AND the trucks AND the interlocks at both ends down? Details? Where, how, by whom and how often will that USED water be disposed of? Details? Can Namwater tell us how this new ‘usage’ of Koichab Pan water will affect that resource – especially iro salinity and estimated duration of potability? Please include these in your Assessment. Comment: Concerns noted and addressed throughout the report. Note that it will be two to three ships per month.

From: S.P. Prinsloo Namib Garage & Aus Haven 2018-12-17 RE: Planned Manganese Export via Luede ritz Harbour Regarding the abovementioned subject of Manganese exportation via the harbour of Lüderitz, we would like to register as Interested and Affected Parties, as Aus is very much also affected by certain aspects of this undertaking, because we will be directly affected by any possible negative side effects: Background: Namib Garage & Aus Haven is a guest accommodation , fuel station and General Dealer, with about 54 beds of accommodation in Aus next to the B4. In Aus there are about 150 people directly employed by Tourism / Accommodation related enterprises. At least 200 persons are crossing the B4 main trunk road between Keetmanshoop and Lüderitz at Aus two times per day, as factually all abovementioned employees are staying in Khaubeb and have to walk over the B4 to reach their place of employment and or pick-up point. Any resulting train traffic will cause a high risk accident zone at the railway crossing below the police station, as everyone is used to NO train movements at this location for the last 16 years, with subsequent disregard for the existing signage. Long and slow moving trains crossing that road intersection at Aus might block the access route to town, resulting in frustrated motorists wanting to fill op on fuel to turn around and skipping Aus. All the accommodation establishments in Aus will be negatively affected by noise pollution, no matter whether it is resulting from train traffic or truck movements. The same establishments might be affected by dust pollution caused by manganes ore in transit, as Aus can have strong wind regiments at times, dispersing any dust particles over the town. The B4 runs for ± 110 kms through a Nature Park and an increased vehicular traffic volume will have an impact on inter alia the Wild Horses of the Namib - especially at night collisions with horses have happened on various occasions. Should the tourism industry of Lüderitz be negatively impaired through a decrease in visitor numbers, will Aus be directly affected as well. Most of the visitors coming to and through Aus, have the Wild Horses and Lüderitz (Kolmanskop) on their itinerary and if Lüderitz is not attractive any more, the whole route might be scrapped altogether. Comment: Concerns noted and addressed throughout the report.

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Communication Received After the Second Public Meeting

From: Michael Mackenzie NovaNam 2019-01-31 Please advise when will construction start on the planned shed by Pektranam as this question was not raised. Comment: The warehouse will be constructed if road transport wi ll be used . The scope of the project has changed to such a degree that a combination of bulk bag, containerised and bulk transport and storage of ore is possible.

From: Crispin Clay Chairman: Lüderitzbucht Foundation / 2019-02-01 Resident I do have a couple more points which I felt it pointless to raise there but which you might care to include in your answers:

1. Will you apply ISO 45001? 2. Where will the ore be put into bags? At the mine or at the border? 3. How many bags per truck? 4. On pallets? 5. How many layers per truck? 6. All covered by tarps? Also in the warehouse? 7. How will they be prevented from sliding off pallets and flatbeds? 8. How will the ore be loaded onto ships? In bags on pallets? 9. If on pallets, fork-lifts will be used rather than scoops? 10. Measures to deal with breakage of bags? 11. Origin, material and strength of bags? 12. From which mines will you draw stocks for export? 13. Will there be any statistical record of traffic-flow BEFORE the operation begins, especially at: Radford Junction; Kapps Junction; Plietz Junction; OK Junction? 14. Will the EIA and EMP deal in detail with both road and rail transport, or only road? 15. Why has South Africa not built more refineries for all the iron and manganese ore leaving for China from one quite small area centred on Kuruman? Comment: Questions noted and addressed in the report. Pektranam Logistics can consider implementing ISO standards related to occupational health and safety and environmental management systems.

From: Heinz Manns Namib Offroad Excursions 2019-02-05 There seem to be so many issues here – Luderitz is definitely not going to be the same after this and Tourism will be over – that’s a fact, considering the truck traffic and the possibility of building bulk storage on the Peninsula. Should one not look at the bigger picture and move the whole project a bit north past Agate beach, bringing the rail in from Kolmanskop , past Charlottental, in front of the dune belt to Smithfield ( About 5Km north of Agate beach) There is so much flat ground right at the shore - North of Luderitz – out of harms way. There Namport can build a proper bulk terminal with breakwaters – much deeper water. And Out of sight and possible danger to the people of Lüderitz – and everybody can live in harmony. Maybe this suggestion could be passed on to Namport re. future planning of the bulk terminal? Comment: Namport has conducted feasibility studies for a new deepwater port. Various locations have been considered including north of Lüderitz. Based on their research these locations are not feasible.

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Communication Received After the Location Change Notification

From: Marsha Pickering Community Member 2019-02-27 Is it possible to see the blueprint of the building that will be built there. Ho w is this going to be sealed off as this area is quite close to area 7, the police station and the new extension of area 2 Comment: The warehouse will have rolling doors which will only be opened when trucks enter or exit the warehouse. Furthermore dust suppression will be performed with water should dust become a problem during strong winds.

From: Eugene de Paauw Specialist Road Legislation, Advice & 2019-02-28 Compliance, Roads Authority We are of the view that the existing access from the trunk roa d to the proposed yard is not designed to accommodate the number of heavy vehicles as planned for by the proponent and needs to be suitably upgraded to the satisfaction of the Roads Authority. Comment: Noted . Communicated to Pektranam Logistics

Additional Verbal and Other Comments and Exposure In addition to the above comments, an email was received from a person recently retrenched due to the closure of the Elisabeth Bay mine. A request was made to forward the person’s details to Pektranam for consideration for a position related to the proposed manganese project. Pekranam was notified of this. Geo Pollution Technologies also received a telephone call from a Lüderitz resident enquiring about the potential job opportunities related to the project. Numerous posts on social media as well as newspaper articles were published regarding the manganese ore export projects. These have not been included in this report.

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Correspondence from Competent Authorities National Radiation Protection Authority, Ministry of Health and Social Services:

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Comment: A meeting was held on the 27 th of February 2019 with the director Mr. Axel Tibinyane and Ms. Mutwamezi. At the meeting it was concluded that Pektranam Logistics must analyse one sample of ore for radioactivity and submit these results to the National Radiation Protection Authority. Based on the results Pektranam Logistics will either be exempted from any permits or be provided with a permit, inclusive of conditions, for the transport and handling of the ore. It was agreed that the EIA and EMP can be finalised and submitted for approval without the sample analyses results. However, a condition of the EMP must be that the analyses results be submitted prior to any ore transport into Namibia.

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Roads Authority Roads Authority was extensively consulted regarding the proposed project. The following letter was sent to Roads Authority regarding the proposed trucking of ore to Lüderitz:

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Response received from Roads Authority:

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Comment: Roads Authority’s concerns regarding the transport of ore with trucks are understood and noted. However, there is a number of factors that should be taken into account during the review of the EIA. These are:  Pektranam Logistics is now actively pursuing the use of rail transport.  Namibia’s vision of becoming a logistics hub is severely hampered by outdated transport infrastructure. Limiting road transport also prevents income from being generated that will contribute towards the funds required to upgrade the infrastructure.  A president was set by granting an environmental clearance certificate to Tradeport who also intend to make use of the road network for ore transport. They have however not consulted with Roads Authority in this regard.  Legally, heavy motor vehicles adhering to all legal requirements for road transport cannot be prohibited from using the roads.

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Privacy Block Privacy Block

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Communication Received Based on the Draft Scoping Report

From: Marion Schelkle Lüderitz Safaris & Tours 2019-04-26 Thank you Andrè – for this very detailed report. We still not all like or agree on this “impact of noise and traffic”, and sincerely hope that all these measures to minimise the impact will be adhered to. Controlling this should have priority. Comment: Noted

From: Mike & Ann Scott African Conservation Services cc 2019-04-29 Thank you for the opportunity to comment – you and your team have done a very thorough job! Just one comment, regarding the identified potential impact of bright lights that could disorientate birds (8.6 Terrestrial Ecology Impacts, p40) and in view of the many seabirds in the area: possible mitigation measures could be included in 9.1.12 (e.g. reducing numbers and intensity of lights at night to the minimum; down-shielding security lighting for on-ground facilities and equipment to keep light within the boundaries of the site; if there are high structures such as towers, using intermittent light, preferably strobes and, if there is a choice of colour, white lights appear to have lower (collision) impacts than red. These measures could also possibly be cross-referenced to those for visual impacts. Two other minor details: p29, last para of 6.7 – place ostrich in a separate group to mammals; and p39, para 2 of 8.5: antennular ficking activity = flicking? Comment: Impact of bright lights on birds with preventative measures included in section 9.1.12 . There will be no towers on site. Errors corrected.

From: Howard Head Alma Marine / Cormorant Guest House / CEO 2019-04-29 Ghost Town Tours Having perused the comprehensive EIA application for Pektranam logistics it is again apparent that the main concerns as eluded to in your conclusion remain. This being Dust, Noise and Traffic My previous concerns as stated therefor also remain. The measures proposed will to some extent mitigate them but here are my further concerns and comments: 1. The bulk discharge of manganese from side tippers are problematic and can only be done inside an enclosed warehouse. 2. Any visible dust from any area of operation should trigger an immediate halt and result in an investigation. 3. The alternative route on the railway line into town should be prioritized. 3. The bi - annual report on complaints and actions taken as proposed should be changed to quarterly for the sake of transparency and efficacy. 4. I did not see an avenue for complaints by the public for non compliance by Pektranam Logistics regarding their operations. Comment: Bulk discharge from side tippers will be in a warehouse. Mitigation measures in section 9.1.6 requires actions to be taken for any uncontained dust. Included a community liaison officer in section 9.1.1 whose details must be communicated to interested and affected parties if the project is initiated. Bi-annual monitoring is typical for environmental monitoring summary reports. The presence of a community liaison officer will allow for the opportunity to, if reasonable justification exist, request monitoring data on a more regular basis.

From: Eugene de Paauw Specialist Road Legislation, Advice & 2019-05-03 Compliance, Roads Authority We wish to respond as follows: • We consider that both accesses to the potential storage areas (RCC and municipal) from proclaimed roads need to be upgraded to Roads Authority standards, and • that transport of the manganese ore needs to be by rail and not road for reasons given in our letter of 28 February 2019. Comment: Noted

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From: Heidi Skrypzeck Senior Fisheries Biologist, Ministry of Fisheries 2019-05-03 & Marine Resources Please see the following concerns/comments with regard to the EIA:Manganese Export Pektranam Logisitics: • The report indicate that “some impacts can be expected on the surrounding environment, see summary impacts table below.” However, for the Impact type: Ecosystem and Biodiversity Impact - Marine (BE) no ratings were given. I find this highly unlikely that no manganese ore (dust) would enter and have an effect on the marine environment especially if the loose manganese option is going to be used or when bags/containers/skips are to emptied. • Your report on Marine Impacts fails to consider manganese toxicity on phytoplankton, embrio development of invertebrates and fish, and actual mortalities caused in marine resources. Some species of phytoplankton require metals, such as iron and manganese to from red blooms. An oyster hatchery is operating in Lüderitz, and heavy metals contamination (in the water) would have a potential detrimental effect on the (development and survival) larvae. • If Pektranam Logistics is committed to zero dust the option of loose ore should not be considered at all nor the emptying of bags and containers while loading the ore on the vessels. The managense ore should be contained in sealed containers and bags used and as such loaded on the vessels. • Your report state the following: “ A meeting was held on the 27th of February 2019 with the director Mr. Axel Tibinyane and Ms. Mutwamezi. At the meeting it was concluded that Pektranam Logistics must analyse one sample of ore for radioactivity and submit these results to the National Radiation Protection Authority. Based on the results Pektranam Logistics will either be exempted from any permits or be provided with a permit, inclusive of conditions, for the transport of the ore. It was agreed that the EIA and EMP can be finalised and submitted for approval without the sample analyses results. However, a condition of the EMP must be that the analyses results be submitted prior to any ore transport into Namibia. ” How can the EIA and the EMP be finalized for approval if there are no results (confirmation) for potential radioactivity? So only conditions would be attached to the transport of this manganese ore (if radioactive) but no conditions during the handling/off-loading, or environmental monitoring at the Port in Luderitz? This part of your report is not transparent and should be captured in the scoping document clearly with results in order to give guidance towards the EIA and EMP with regard to the potential negative effect and their cumulative effects on the marine environment and mariculture industry. • For the EMP: The proponent must implement a water monitoring programme for oysters and mussels in order to provide an index of manganese pollution, and provide a 6-monthly report to the Ministry of Fisheries and Marine Resources. Comment: Error on impacts table corrected. The description of marine pollution and potential impacts on marine life is not meant to be a detailed description of all potential impacts, but rather to illustrate that excessive manganese pollution in the ocean will have negative impacts, and as such should be prevented. However, the additional impacts as mentioned in the comments are noted as additional to those in the report. Comment on handling of ore noted. The National Radiation Protection Authority regulates any radioactive material handling and transport in Namibia. The report mistakenly only mentioned transport, but “handling” has now been included. The National Radiation Protection Authority will thus set guidelines within which Pektranam Logistics must operate should radioactivity be present and be within allowed levels. Pektranam Logistics, if granted and ECC, will not be the only exporter of manganese ore via the Port of Lüderitz. A water monitoring programme cannot be expected only from them as it would not distinguish between pollution originating from Pektranam Logistics and other role players. A holistic environmental and water quality monitoring programme is required that does not only take into account the manganese ore, but also the lead and zinc and any other future products to be imported or exported via the port. This falls within the mandate of Namport whose functions under the Namibian Ports Authority Act includes: (i) to protect the environment within its areas of jurisdiction.

From: Crispin Clay Chairman: Lüderitzbucht Foundation / 2019-05-04 Resident Re: Pektranam Manganese Ore Exports via Luderitz: Weighbridges? We did not see this point addressed or even mentioned in the EIA:

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1. It is obvious that our roads (B4 and Luderitz streets) will suffer damage over time. They were not designed for such loads or frequency. 2. It would be folly to rely on any company to stick to the 36 ton limit if they could add one or two tons per load and not measurably affect their trucks: one ton extra would save them one truck in 36 – hence 23 trucks per ship. Two tons extra? Quite a cost saving without anybody noticing. But at what longterm cost to OUR roads? Hence trucks ‘should’ all be weighed en route – especially before entering the Park. What provision will be made for ensuring that axle weights are not exceeded? 3. The weighbridge on the B1 might not cover all trucks coming to Luderitz. Will any provision be made for a weighbridge near Aus on the B4 road – e.g. at the fenced entrance to the Park to stop by-passing a weighbridge? 4. It would have to be in place first, as a permanent fixture, with proper arrangements for officials, equipment, signage – done procedurally and staff trained and established on site. The weighbridge would control all mining trucks and other bulk loads, but ignore normal traffic. 5. There would have to be charges for use of the weighbridge, plus severe penalties for excess tons. How administered? There may be other issues to be addressed in this regard but we are sure that such a weighbridge would help to preserve our roads as long as possible. Any major repairs to our roads will obviously cause further major disruption to already disrupted and increased traffic-flows. We trust this will receive serious consideration by all involved. It is a major cause of concern in Luderitz. That road is our umbilical cord. Comment: Included adherence to The Road Tra ffic and Transport Regulations of 2001 in section 9.1.7 . Among others the regulations pertain to maximum axle loads, gross vehicle mass, etc. Furthermore it is the responsibility of the Road Traffic & Transport Inspectorate of the Roads Authority to:  Control overloading by weighing all heavy vehicles above 3,500 kg aimed at reducing road damage and thus prolonging the lifespan of Namibia’s national roads.  Enforce vehicle/ load related standards on all commercial vehicles through inspections conducted at weighbridges and on national roads to ensure compliance with relevant legislations.  Enforce road safety regulations by inspecting all commercial vehicles at weighbridges and on national roads for roadworthiness and thus promoting road safety.  Enforce legislative compliance to domestic and cross border road transportation through inspections of commercial vehicles at weighbridges and on national roads.  Support Road Fund Administration (RFA) by enforcing mass distance and entry fee charges through inspections of commercial local and foreign vehicles at weighbridges and on national roads. Furthermore, incoming trucks are weighed at the mine, at Upington’s weighbridge and again at Ariamsvlei.

From: Jessica Kemper Scientist / Resident 2019-05-05 Thank you for the opportunity to comment on the EIA for the proposed Pektranam project. At this stage I have nothing further to add. I would like to commend you on the thorough assessment, including following an extensive public participation process, and meticulously exploring various option to mitigate potentially significant negative effects, particularly with respect to dust and traffic. The resulting report is impressively comprehensive. Comment: Noted

From: Heinz Manns Namib Office Machines 2019-05-05 Thank you for involving us in this matter. The problem I see is the traffic. If you could bulk store in the harbor it would ease that problem, and save a lot on handling cost. Comment: Noted. Space constraints within the harbour prevents Pektranam Logistics from stockpiling there.

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From: Marion Schelkle / Lüderitz Safaris & Tours / Resident 2019-05-06 Gisela Schmidt • we are not happy about the green light given by MET for the use of our harbour to export these masses of manganese ore through our harbour. Our harbour may not be used to full capacity, but in our eyes we are being exploited by the South African mine operator. • the tarred roads leading into and through the town of Luderitz were not constructed to take this burden at all. Additional to the zinc ore coming from Rosh Pinah, these 800 + trucks rambling through our town, will definitely damage the surface severely – and as far as can be seen from the detailed report we have received from you – no provision has been made by Pektram to restore the damage envisaged by this very heavy additional burden. There is merely mention of an interlocking part of the top of Bismarck Street, which Pektranam has promised to construct. And we doubt if this would be strong enough to last for a long time. • We again would like to air our concern about the impact this additional traffic through the town of Luderitz will have on our tourism industry, which has taken us so long to build up. 32 guest houses and hotels – and various operators and shops, depend on this income. Lüderitz continuously keeps developing tourism routes and makes improvements to appeal to the visitor- and such additional traffic, noise - and probably dust – may just have a negative impact on the stream of visitors planning to visit our clean coastal resort. • From the report you have submitted, it still is not clear how the ore will actually be transported. Either by train OR by road transport, either in bags OR as loose material on trucks covered with tarpaulins OR in closed containers. The latter option – in our opinion – would be the best way of doing it. The siding outside Luderitz has a platform designed for containers and could possibly to extended, which could simplify matters greatly. Our port is too small to make divisions for different materials- raw ore and other cargo- to be handled. • It is also a miracle to us how this immense capacity of ore can be loaded into a ship which is only in port for 3 days maximum. Close to 1000 trucks would have to tackle this task – and which truck owner in Namibia could provide (or finance !) such a task ? • We also cannot see anyone else benefitting from this ore export other than Namport. The owners promised the audience at the Luderitz meetings, prosperity in every respect, additional employment, turnover etc etc – with due respect, its hard to image. • The only solution would be the development of the bigger port at Angra Point – which also happens to be a popular recreational area on the Luderitz peninsula Comment: All comments noted. No approval has been granted to Pektranam Logistics for the export of manganese ore, but approval was granted to another company. The Port of Lüderitz however remains a Namibian strategic asset that should be managed profitably. Since there are many other road users, for example the zinc ore trucks as mentioned, it would be unfair to expect Pektranam Logistics should be solely responsible for restoring damaged roads. Therefore the recommendation in this report that all role players should come together in obtaining workable solutions to traffic and related impacts. Due to various inputs received, all methods of ore transport as discussed in the report are possible options. Based on the calculations of local logistics companies, loading of the vessel in three days is achievable. While 833 trips into the harbour is foreseen, there is no need for 833 different trucks. Trucks that have been offloaded will return to the storage yard to be loaded again. This way, only 12 trucks will be needed for transport purposes through town.

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Appendix C: Consultants’ Curriculum Vitae

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Hydrogeologist Pierre Botha Pierre Botha is the Managing Director of Geo Pollution Technologies, Namibia. Mr. Botha has excellent experience and knowledge in Environmental Impact Assessments, groundwater pollution assessment, groundwater exploration, resource evaluation, urban and rural water supply, groundwater management, monitoring and hydrochemistry. He gained most of his experience in Namibia and is involved in the Namibian groundwater industry since 1992. Mr Botha's experience in the environmental / groundwater field has been gained from various projects ranging from groundwater exploration, groundwater management and modelling, environmental impact assessments, pollution mapping and rehabilitation to health risk evaluations. CURRICULUM VITAE PIERRE BOTHA Name of Firm : Geo Pollution Technologies (Pty) Ltd. Name of Staff : PIERRE BOTHA Profession : Hydrogeologist / Hydrologist Environmental Assessment Practitioner Years’ Experience : 27 Nationality : Namibian Position : Managing Director Specialisation : Hydrogeology Languages : Afrikaans – speaking, reading, writing – excellent English – speaking, reading, writing – excellent

EDUCATION AND PROFESSIONAL STATUS: B.Sc. Geology & Geography : University of OFS, 1992 B.Sc. (Hons.)( cum laude ) Geohydrology/Hydrology : University of OFS, 1994

First Aid Class A EMTSS, 2017 Basic Fire Fighting EMTSS, 2017

PROFESSIONAL SOCIETY AFFILIATION: Environmental Assessment Professionals of Namibia (EAPAN) – President 2014 - Vice President 2012, 2013 Hydrogeological Association of Namibia (HAN) Geological Association of Namibia

AREAS OF EXPERTISE: Knowledge and expertise in:  risk based corrective action analyses  bioremediation  monitoring, mapping and evaluation of groundwater pollution  hydrochemistry studies  environmental impact assessments  project management  soil vapour surveys  groundwater modelling  groundwater monitoring  hydrocensus  hydrogeological data evaluation and interpretation  groundwater exploration and resource evaluation  geophysical interpretations (Ground Penetrating Radar, Electrical Resistivity, Electromagnetic & Magnetic)  urban and rural water supply  groundwater management  borehole siting, drilling and test pumping supervision, aquifer testing

EMPLOYMENT: 1998-Date : Geo Pollution Technologies (Pty) Ltd 1995 : Parkman Namibia (Groundwater Consulting Services) - Hydrogeologist 1994 : Institute for Groundwater Studies, University of the Orange Free State - Hydrogeologist 1992-1993 : Groundwater Consulting Services - Field Geologist 1988 : Tsumeb Corporation Ltd - Student geologist

PUBLICATIONS: Contract reports : +400 Publications : 1

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ENVIRONMENTAL SCIENTIST André Faul André entered the environmental assessment profession at the beginning of 2013 and since then has worked on more than 70 Environmental Impact Assessments including assessments of the petroleum industry, harbour expansions, irrigation schemes, township establishment and power generation and transmission. André’s post graduate studies focussed on zoological and ecological sciences and he holds a M.Sc. in Conservation Ecology and a Ph.D. in Medical Bioscience. His expertise is in ecotoxicological related studies focussing specifically on endocrine disrupting chemicals. His Ph.D. thesis title was The Assessment of Namibian Water Resources for Endocrine Disruptors. Before joining the environmental assessment profession he worked for 12 years in the Environmental Section of the Department of Biological Sciences at the University of Namibia, first as laboratory technician and then as lecturer in biological and ecological sciences. CURRICULUM VITAE ANDRÉ FAUL Name of Firm : Geo Pollution Technologies (Pty) Ltd. Name of Staff : ANDRÉ FAUL Profession : Environmental Scientist Years’ Experience : 17 Nationality : Namibian Position : Environmental Scientist Specialisation : Environmental Toxicology Languages : Afrikaans – speaking, reading, writing – excellent English – speaking, reading, writing – excellent

EDUCATION AND PROFESSIONAL STATUS: B.Sc. Zoology : University of Stellenbosch, 1999 B.Sc. (Hons.) Zoology : University of Stellenbosch, 2000 M.Sc. (Conservation Ecology) : University of Stellenbosch, 2005 Ph.D. (Medical Bioscience) : University of the Western Cape, 2018

First Aid Class A EMTSS, 2017 Basic Fire Fighting EMTSS, 2017

PROFESSIONAL SOCIETY AFFILIATION: Environmental Assessment Professionals of Namibia (Learner Practitioner)

AREAS OF EXPERTISE: Knowledge and expertise in:  Water Sampling, Extractions and Analysis  Biomonitoring and Bioassays  Biodiversity Assessment  Toxicology  Restoration Ecology

EMPLOYMENT: 2013-Date : Geo Pollution Technologies – Environmental Scientist 2005-2012 : Lecturer, University of Namibia 2001-2004 : Laboratory Technician, University of Namibia

PUBLICATIONS: Publications: 5 + 1 in preparation Contract Reports +80 Research Reports & Manuals: 5 Conference Presentations: 1

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ENVIRONMENTAL ASSESSMENT PRACTITIONER Quzette Bosman Quzette Bosman has 12 years’ experience in the Impact Assessment Industry, working as an Environmental Assessment Practitioner and Social Assessment practitioner mainly as per the National Environmental Legislation sets for South Africa and Namibia. Larger projects have been completed in terms of World Bank and IFC requirements. She studied Environmental Management at the Rand Afrikaans University (RAU) and University of Johannesburg (UJ), including various Energy Technology Courses. This has fuelled a passion towards the Energy and Mining Industry with various projects being undertaken for these industries. Courses in Sociology has further enabled her to specialize in Social Impact Assessments and Public Participation. Social Assessments are conducted according to international best practise and guidelines. Work has been conducted in South Africa, Swaziland and Namibia.

CURRICULUM VITAE QUZETTE BOSMAN Name of Firm : Geo Pollution Technologies (Pty) Ltd. Name of Staff : QUZETTE BOSMAN Profession : Social Impact Assessor / Environmental Assessment Practitioner Years’ Experience : 12 Nationality : South African Position : Senior Environmental Consultant Specialisation : ESIA & ESMP; SIA Languages : Afrikaans – speaking, reading, writing – excellent English – speaking, reading, writing – excellent

EDUCATION AND PROFESSIONAL STATUS: BA Geography & Sociology : Rand Afrikaans University, 2003 BA (Hons.) Environmental Management : University of Johannesburg, 2004

First Aid Class A EMTSS, 2017 Basic Fire Fighting EMTSS, 2017

PROFESSIONAL SOCIETY AFFILIATION: Namibian Environment and Wildlife Society International Association of Impact Assessors South Africa (IAIA SA) Member 2007 - 2012 Mpumalanga branch Treasurer 2008/2009

OTHER AFFILIATIONS Mkhondo Catchment Management Forum (DWAF): Chairperson 2008-2010 Mkhondo Water Management Task Team (DWAF): Member 2009

AREAS OF EXPERTISE: Knowledge and expertise in:  environmental impact assessments  project management  social impact assessment and social management planning  community liaison and social monitoring  public participation / consultation  social risk management  water use licensing  environmental auditing and compliance  environmental monitoring  strategic environmental planning

EMPLOYMENT: 2015 - Present : Geo Pollution Technologies – Senior Environmental Practitioner 2014-2015 : Enviro Dynamics – Senior Environmental Manager 2010 - 2012 : GCS – Environmental Manager (Mpumalanga Office Manager) 2007 - 2009 : KSE-uKhozi - Technical Manager: Environmental 2006 -2007 : SEF – Environmental Manager 2004 - 2005 : Ecosat – Environmental Manager

PUBLICATIONS: Contract reports : +150 Publications : 1

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Hydrogeologist Jannie van der Merwe Jannie van der Merwe holds an honours degree in hydrology and geohydrology from the Northwest-University Potchefstroom (NWU) South Africa. He first completed a B.Sc. degree in Geology and Geography in the required time also from the Northwest University Potchefstroom South Africa. His honours project entailed Preparing Groundwater Resource Directed Measures for Catchment: J21A Beaufort West in South Africa. In his honours year he also completed an advanced course in ArcMap (GIS). He started working at Geo Pollution Technologies at the beginning of 2016 and he regularly conducts or assists in soil vapour surveys, groundwater monitoring and sampling, soil sampling, tank pit surveys, geophysics (borehole siting), hydrocensus studies, pump testing and groundwater specialist studies.

CURRICULUM VITAE JANNIE VAN DER MERWE Name of Firm : Geo Pollution Technologies (Pty) Ltd. Name of Staff : JANNIE VAN DER MERWE Profession : Hydrogeologist Nationality : Namibian Position : Environmental Scientist Specialisation : Groundwater, Geology Languages : Afrikaans – speaking, reading, writing English – speaking, reading, writing

EDUCATION AND PROFESSIONAL STATUS: B.Sc. Geology and Geography : Northwest University (NWU) 2014 B.Sc. (Hons.) Hydrology and Geohydrology : Northwest University (NWU) 2015

First Aid Class A EMTSS, 2017 Basic Fire Fighting EMTSS, 2017

AREAS OF EXPERTISE: Knowledge and expertise in:  Groundwater  Geology  Geophysics  Basic Geographic Information Skills (ArcGIS, Manifold)

EMPLOYMENT: 2016 - Date : Geo Pollution Technologies – Environmental Scientist

PUBLICATIONS: Contract Reports: +30

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