For Proposed Exploration of Dimension Stone on EPL 5161, Erongo Region, Namibia

Environmental Assessment and Environmental Management Plan (EMP) for proposed exploration of dimension stone on EPL 5161, Erongo Region, Namibia

Date: 04 June 2020

Ecc App No.: APP-001762

Prepared for: Best Cheer Investments Namibia (Pty) Ltd

Prepared by: OMAVI Geotechnical & Geo-Environmental Consultants CC (OGGC) Tel.: +264 81 300 3872 or +264 81 478 6303 Email: [email protected]

EXECUTIVE SUMMARY Best Cheer Investments Namibia (Pty) Ltd (the client or Best Cheer hereafter) intends to carry out exploration activities to investigate the potential of granites and granitoid bodies on Exclusive Prospecting License (EPL) no. 5161, for use as dimension stones. The EPL is located about 25 km northeast of Arandis and covers an area of about 5059 ha. The area falls under the Karibib Constituency jurisdiction and extends across three (3) commercial farms namely Vergenoeg (no. 92), Valencia (no. 122), Namibplaas (no. 93) and one (1) communal farm Trekkopje (no. 120), however work will focus on Farm Trekkopje, particularly the middle and western parts. In order to undertake these exploration activities, an environmental clearance certificate (ECC) is required in terms of the Environmental management Act (Act No.7 of 2007) and its 2012 EIA regulations. As such, Best Cheer appointed Omavi Geotechnical and Geo-environmental Consultants CC to conduct the necessary assessments including public participation, and prepare this environmental scoping assessment (ESA) report.

Best Cheer intends to adopt a systematic prospecting approach starting with desktop study, which will mostly be office based, focusing on historical data, followed by field evaluation and mapping, whereby a qualified geologist will walk the area and map it to produce a geological map with rocks of interest. Rock mass properties such as colour, texture, discontinuities will be noted to allow rating of rocks. Focus will then be narrowed down to areas yielding a good rating, which will then be drilled to further establish these rock properties at depth during detailed exploration. If the outcome of this evaluation is positive, selected areas will be subjected to test mining, whereby blocks will be extracted and transported to the factories for testing. These results will then determine whether or not the resource is worth pursuing, in which case a Mining Licence will be required.

The proposed project has the potential to improve the sustainability of existing dimension stone factories and to provide employment opportunities to the local people, which in turn contributes to the region’s economy. Additionally, the exploration programme will allow acquisition of skills through on the job training. However the project also has the potential to negatively impact the receiving environment. Impacts identified were assessed by considering the potential risk areas associated with the receiving biophysical and social environment and the issues raised during the public consultation process. The key impacts resulting from this process are as follows:

 Impact on Soils – was divided into soil pollution and soil disturbance. Potential sources of soil pollution include petrochemical spills from vehicles (bakkies), water trucks, the drill rig, diesel operated generator as well as the trailer mounted diesel tank for fuel storage. In terms of soil disturbance, most of it is anticipated during the early stages of the project, whereby roads will need to be created, exploration camp to be erected and clearing of selected areas for detailed mapping traverses.

 Impact on air quality - The possible source of air pollution would be the dust and fumes generated by project vehicles and trucks, diesel powered machinery, as well as dust from drilling and cutting.

 Impact on biodiversity and habitat destruction – could potentially result from the removal of vegetation to create access roads and erect temporary exploration camps onsite during field exploration. However, this is likely to be minimal, given that the vegetation is scattered. The scrapping of overburden to expose rocks for drilling and cutting might result in habitat disturbance.

 Impact on surface and groundwater resources – it was established that there is no surface water in the area as it seldom receives rainfall, and communities rely on groundwater. Therefore, to avoid putting pressure on this scares resource, the project will source water offsite and transport it in water tankers on a weekly basis. This takes away possible lowering of the groundwater table as a result of abstraction. In terms of water quality, potential sources of pollution can be spills of petrochemicals from vehicles (bakkies), water trucks, the drill rig as well as the trailer mounted diesel tank for fuel storage.

 Visual impact – this is a potential impact during the feasibility stage where blocks of rock will be taken or cut from selected areas for testing. However, the significance of this impact is lowered by the fact that test mining will only cover selected areas, which reduces the spatial extent of impact. Additionally, if test mining does not yield positive results, such that there will be a need to apply for a mining licence, the testing blocks will be put back and the area will be rehabilitated.

 Noise impact: There is an inconvenient impact of noise to neighbouring locals associated with exploration vehicles, trucks and equipment. The noise from machinery may also pose a health risk to workers that operate them or the ones working directly in noisy areas.

 Impact on vehicular traffic safety - having water trucks, heavy trucks on the road for drill rigs as well as those transporting mined blocks from site to the factories for testing may impact traffic safety.

 Impact on archaeology - Destruction of archaeological sites might occur during excavation and test mining using a butterfly cutter. However, the likelihood or probability of this happening is minimal as there are no other known archaeological sites or sites of heritage importance known in the project area, except the ones considered in this assessment.

 Impacts the health and safety of workers – from the handling of equipment and use of machinery as well as potentially contracting diseases.

The significance of these impacts has been assessed in terms of the scale, duration, intensity or magnitude as well as probability of occurrence. All impacts were assessed in Section 6.3, and they had medium to low significance. Mitigation measures were recommended in the scoping report and outlined in the EMP for implementation by respective parties. Based on this assessment and the information provided in this report, OMAVI is confident the identified risks associated with the project can be reduced to acceptable levels, if the measures recommended in the EMP are implemented and monitored. It is therefore recommended that the project receives Environmental Clearance, provided that the EMP be implemented.

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CONTENTS PAGE

1 INTRODUCTION ...... 1 1.1 PROJECT BACKGROUND ...... 1 1.2 PROJECT JUSTIFICATION ...... 2 1.3 APPOINTED ENVIRONMENTAL ASSESSMENT PRACTITIONER ...... 3 1.4 PURPOSE OF ENVIRONMENTAL SCOPING ASSESSMENT ...... 3 2 PROJECT DESCRIPTION ...... 4 2.1 PROPOSED EXPLORATION TECHNOLOGIES ...... 5 2.1.1 Desktop Study ...... 5 2.1.2 Field evaluation ...... 5 2.1.3 Detailed exploration ...... 5 2.1.4 Feasibility study...... 5 2.2 PROJECT REQUIREMENTS AND ASSOCIATED INFRASTRUCTURE ...... 6 2.2.1 Power Requirements ...... 6 2.2.2 Water supply ...... 6 2.2.3 Roads ...... 7 2.2.4 Waste production and sanitation ...... 7 2.2.5 Temporary shelter / accommodation ...... 7 2.2.6 Personnel and site safety ...... 7 2.3 PROJECT ALTERNATIVES ...... 7 2.3.1 Alternative supporting infrastructure ...... 7 2.3.2 No-go alternative ...... 8 3 LEGAL REQUIREMENTS ...... 9 3.1 APPLICABLE LEGISLATIONS AND COMPLIANCE STATUS ...... 9 3.2 RELEVANT LISTED ACTIVITIES IN TERMS OF EMA...... 21 4 THE RECEIVING ENVIRONMENT ...... 22 4.1 BIOPHYSICAL ENVIRONMENT ...... 22 4.1.1 Climatic Conditions ...... 22 4.1.2 Geology and soils ...... 24 4.1.3 Topography and Drainage of Area ...... 26 4.1.4 Groundwater Resources ...... 27 4.1.5 Biodiversity Baseline Information...... 27 4.1.6 Archaeology ...... 30 4.2 THE SOCIO-ECONOMIC ENVIRONMENT ...... 33 4.2.1 Population Density and Socio-economic Profile ...... 33 4.2.2 Current Land Use of the area ...... 34 4.2.3 Nearby Mines ...... 34 4.2.4 Air quality and Noise levels ...... 35 4.2.5 Existing infrastructure ...... 36 4.3 KEY IMPACTS IDENTIFIED ...... 37 5 THE PUBLIC PARTICIPATION PROCESS ...... 37 5.1 INTERESTED AND AFFECTED PARTIES (I&APS) ...... 37 5.2 THE PUBLIC CONSULTATION PROCESS ...... 38 5.2.1 Notices ...... 38 5.2.2 Consultation Meetings ...... 38 5.3 KEY ISSUES RAISED ...... 39 5.3.1 First round of public consultation ...... 39 5.3.2 Second round of public consultation ...... 41 6 IMPACT ASSESSMENT ...... 42 6.1 KEY IMPACTS IDENTIFIED AND THEIR SOURCES PER PROJECT PHASE ...... 42

6.1.1 Desktop study ...... 42 6.1.2 Impacts identified for Field evaluation...... 42 6.1.3 Impacts identified for Detailed exploration ...... 43 6.1.4 Impacts identified for Feasibility study ...... 45 6.2 IMPACT ASSESSMENT METHODOLOGY ...... 47 6.2.1 Extent (spatial scale) ...... 47 6.2.2 Duration ...... 48 6.2.3 Intensity, Magnitude / severity ...... 48 6.2.4 Probability of occurrence ...... 48 6.2.5 Significance ...... 49 6.3 IMPACT ASSESSMENT ...... 50 6.3.1 Field evaluation ...... 50 6.3.2 Detailed exploration ...... 53 6.3.3 Feasibility stage ...... 58 6.3.4 Cumulative Impacts...... 65 7 CONCLUSIONS AND RECOMMENDATIONS ...... 66 8 REFERENCES ...... 69

LIST OF FIGURES

Figure 1: Locality map indicating the location of EPL 5161 on a regional scale ...... 1 Figure 2: Close up locality map indicating the location of EPL 5161, the farms covered as well as nearby infrastructures ...... 2 Figure 3: An example of technologies and equipment to be used during exploration...... 6 Figure 4: The maximum, minimum and average temperature for the Arandis area (World Weather Online, 2020) ...... 23 Figure 5: The rainfall patterns around Arandis (after World Weather Online, 2020) ...... 23 Figure 6: A geological map of the area...... 25 Figure 7: The local geology of the area...... 26 Figure 8: Areas of high biodiversity value in the central Namib in the context of the uranium rush (MME, 2010)...... 30 Figure 9: The cemetery area, seen to be well preserved and protected by the fencing...... 31 Figure 10: The EPL 5161 (grey polygon) in relation to known archaeological/heritage sites (green squares), with Trekopje Battlefield enclosed by peony pink polygon (Kinahan, 2020). 32 Figure 11: The contemporary battlefield sketch in the lower part of the diagram shows the extent of entrenchments and other features in relation to Trekkopje Station (Kinahan, 2020).32 Figure 12: Proposed temporary Exclusion Area (No-Go Area) on EPL5161 to provide for conservation of archaeological/heritage resources associated with the April 1915 Battle of Trekopje pending detailed field assessment (Kinahan, 2020)...... 33 Figure 13: Location of features observed on Farm Trekkopje during the site visit, including the boreholes, cemetery and abandoned quarry...... 35 Figure 14: Powerlines passing through the EPL and Farm Trekkopje...... 36 Figure 15: A site notice placed on Erongo Regional Council notice board...... 38 Figure 16: Pictures from the public consultation meeting held on Farm Hakskeen...... 39

LIST OF TABLES

Table 2-1: Alternative infrastructure...... 7 Table 3-1. Applicable legislation, policies and guidelines to the proposed exploration activity...... 10 Table 3-2: Applicable listed activities in terms of the EMA EIA Regulations of 2012 ...... 21 Table 4-1: A summary of observed vegetation...... 27 Table 5-1: A summary of key issues received...... 39 Table 6-1: Impacts identified desktop study ...... 42 Table 6-2: Impacts identified for field evaluation ...... 42 Table 6-3: Impacts identified for Detailed exploration ...... 43 Table 6-4: Impacts identified for Feasibility study ...... 45 Table 6-5: Extent or spatial impact rating ...... 47 Table 6-6: Duration impact rating ...... 48 Table 6-7: Intensity, magnitude or severity impact rating ...... 48 Table 6-8: Probability of occurrence impact rating ...... 48 Table 6-9: Significance rating scale ...... 49 Table 6-10: Assessment of the impacts of field evaluation on soil pollution...... 50 Table 6-11: Assessment of the impacts of field evaluation on soil disturbance ...... 51 Table 6-12: Assessment of the impacts of field evaluation on biodiversity (flora) ...... 51 Table 6-13: Assessment of the impacts of field evaluation on biodiversity (fauna) ...... 52 Table 6-14: Assessment of the impacts of field evaluation on water quality ...... 52 Table 6-15: Assessment of the impacts of field assessment on air quality ...... 53 Table 6-16: Assessment of the impacts of field evaluation on soil pollution...... 53 Table 6-17: Assessment of the impacts of field evaluation on soil disturbance ...... 54 Table 6-18: Assessment of the impacts of field evaluation on biodiversity (flora) ...... 54 Table 6-19: Assessment of the impacts of field evaluation on biodiversity (fauna) ...... 55

Table 6-20: Assessment of the impacts of field evaluation on water quality ...... 56 Table 6-21: Assessment of the impacts of field assessment on air quality ...... 56 Table 6-22: Assessment of the noise impact from the detailed exploration activities ...... 57 Table 6-23: Assessment of the impacts of the detailed exploration on traffic (vehicular) safety ...... 57 Table 6-24: Assessment of the impacts of the detailed exploration on health and safety ..... 58 Table 6-25: Assessment of the impacts of field evaluation on soil pollution...... 59 Table 6-26: Assessment of the impacts of field evaluation on soil disturbance ...... 59 Table 6-27: Assessment of the impacts of field evaluation on biodiversity (flora) ...... 60 Table 6-28: Assessment of the impacts of field evaluation on biodiversity (fauna) ...... 60 Table 6-29: Assessment of the impacts of field evaluation on water quality ...... 61 Table 6-30: Assessment of the impacts of field assessment on air quality ...... 62 Table 6-31: Assessment of the noise impact from the detailed exploration activities ...... 62 Table 6-32: Assessment of the impacts of the detailed exploration on traffic (vehicular) safety ...... 63 Table 6-33: Assessment of the impacts of the detailed exploration on health and safety ..... 64 Table 6-34: Assessment of visual impact during feasibility stage ...... 65 Table 6-35: Assessment of archaeological impact during feasibility stage ...... 65

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ABBREVIATIONS DEA Department of Environmental Affairs DSMGMR Dimension Stone Mining Global Market Report EA Environmental Assessment EIA Environmental Impact Assessment ECC Environmental Clearance Certificate EMP Environmental Management Plan EMA Environmental Management Act EPL Exclusive Prospecting Licence ESA Environmental Scoping Assessment I&APs Interested and Affected Parties MEAC Ministry of Education, Arts and Culture MAWLR Ministry of Agriculture, Water & Land Reform MEFT Ministry of Environment, Forestry and Tourism MLIEC Ministry of Labour, Industrial Relations and Employment Creation MME Ministry of Mines and Energy MoHSS Ministry of Health and Social Services MURD Ministry of Urban and Rural Development NHC National Heritage Council of Namibia NBG National Botanical Gardens OGGC OMAVI Geotechnical and Geo-environmental Consultants cc TA Traditional Authority(s)

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1 INTRODUCTION

1.1 Project background Best Cheer Investments Namibia (Pty) Ltd (the client or Best Cheer hereafter) intends to carry out exploration activities to investigate the potential of granites and granitoid bodies on Exclusive Prospecting License (EPL) no. 5161, for use as dimension stones. The EPL is located approximately between coordinates 22.284568S/ 15.059525E and 22.319516S/ 15.295920E, about 25 km northeast of Arandis and covers an area of about 5059 ha. The area falls under the Karibib Constituency jurisdiction and extends across three (3) commercial farms namely Vergenoeg (no. 92), Valencia (no. 122), Namibplaas (no. 93) and one (1) communal farm Trekkopje (no. 120) as seen in Figure 1 and Figure 2. Although this is the case, works on this EPL will focus on Farm Trekkopje.

Figure 1: Locality map indicating the location of EPL 5161 on a regional scale

Figure 2: Close up locality map indicating the location of EPL 5161, the farms covered as well as nearby infrastructures

1.2 Project justification The consumption of dimension stones is growing at a rate significantly higher than most mineral products, with a compounded annual growth rate of about 0.8% anticipated in 2020 and an expected global value of nearly US$5.22 billion by 2022 according to the 2020 Dimension Stone Mining Global Market Report. This growth is largely driven by increasing demand for high value natural stones in the construction and real estate sectors in China, India and Eastern Europe. It is partly on these grounds that Best Cheer Investments Namibia (Pty) Ltd decided to pursue the project under review.

Another motivator for pursuing the proposed exploration activities stems from the fact that there are already set up and fully operational factories in Karibib and Walvis Bay for processing and beneficiating dimension stone blocks. Therefore, this project will provide business to these local processing factories, so that the quarrying and processing industry remains sustainable in the region, especially considering that the reserves in the existing quarries are depleting. This will not only contribute to the Namibian economy (through tax revenues to the Namibian government), but it will also help to empower the local communities of Arandis, Karibib and nearby settlements through job opportunities.

Additionally, exploration work will equip the locals with technical skills, which in turn can sustain or improve the socio-economic standing of the region. Furthermore, the EPL has existing transport infrastructure including the B2 national road and the Trans-Kalahari rail passing through it, which provides good connection to the target market via the Walvis Bay Port, thereby reducing the project footprint.

Therefore, to realize the vision of Best Cheer, a basic exploration program will be carried out and shall involve both non-intrusive and intrusive techniques, in order to determine the economic potential of the target area.

However, it is acknowledged that exploration activities for dimension stones are usually associated with both potential positive and negative impacts on the receiving environment. If these impacts are not well understood prior to project implementation, to enable their timely avoidance or significance reduction, they have the potential to harm the environment temporarily or permanently. Furthermore, the extraction of mineral resources is a listed activity that must not be undertaken without an Environmental Clearance Certificate (ECC) from the Ministry of Environment, Forestry and Tourism (MEFT). In order to inform the ECC decision, an Environmental Scoping or Impact Assessment (ESA/EIA) must be conducted, as per the requirements of the Environmental Management Act (Act No. 7 of 2007) (EMA) and its 2012 EIA Regulations. It was in line with this requirement that Best Cheer appointed an Environmental Assessment Practitioner (EAP) to carry out this assessment.

1.3 Appointed Environmental Assessment Practitioner Best Cheer Investments Namibia (Pty) Ltd (the proponent) appointed OMAVI Geotechnical & Geo-environmental Consultants CC (OMAVI hereafter) as an independent environmental consultant, to investigate the potential biophysical and socio-economic environmental impacts that would arise from the planned exploration activities. The findings of the scoping assessment are aimed at assisting the Ministry of Environment, Forestry and Tourism’s (MEFT) Department of Environmental Affairs (DEA) with sufficient factual information to make an informed decision on the granting of an ECC for the proposed activities. Linda Uulenga an Environmental Assessment Practitioner for OMAVI conducted this EA process. Refer to Appendix A for the Environmental Practitioner’s CV.

1.4 Purpose of Environmental Scoping Assessment The environmental scoping assessment (ESA) process investigates potential positive and negative impacts associated with the proposed exploration activities on the biophysical and socio-economic environment. It is also the purpose of this assessment to ensure that the impacts are taken into account during all phases of the project from temporary site establishment through actual exploration to decommissioning of the exploration camps. The

ESA also aims at informing all interested and affected parties about the proposed exploration works and obtaining their views on the project through consultations.

These assessment processes and steps followed in undertaking this environmental assessment are summarised below: 1. Project screening process. 2. Preparation of the Background Information Document (BID) and ECC Application and their submission to the Office of the Executive Director in the Ministry of Mines and Energy (MME) (Competent Authorities) for notification and recommendations. The date stamped copy of the ECC Application from the MME was uploaded to the MEFT’s EIA online portal for registration and notification of the commencement of the ESA. 3. Invitation / notices to stakeholders (I&APs) and the public to participate in environmental assessment process issued through local newspaper advertisements as well as via direct emails communications to key authoritative institutions such as Line Ministries, Regional and Local Governments, and affected Traditional authority and farm/land owners or occupiers of land. 4. Compilation of the Draft ESA Report (consolidating all findings from the I&APs/public consultation, and based on the provided project activities and research) and Environmental Management Pan (EMP) – Appendix H. 5. Circulating the Draft ESA Report (with all appendices) to the public (I&APs) for review and comments. 6. Incorporate comments and inputs from stakeholder consultations into the Final Scoping and EMP Reports. 7. Submission of the final ESA report (including all appendices) and EMP to the Department of Environmental Affairs and Forestry in fulfilment of the requirements of the Environmental Impact Assessment (EIA) Regulations No. 30 of 2012 and the Environmental Management Act, (EMA), 2007, (Act No. 7 of 2007) for application of the Environmental Clearance Certificate (ECC) for the proposed project.

It is worth noting that his scoping assessment is only for exploration activities, however, should a promising resource be found, an application will be launched with the Ministry of Mines and Energy (MME) for a mining licence, which will be accompanied by a separate environmental impact assessment for mining.

2 PROJECT DESCRIPTION

As part of exploration, Best Cheer Investment (Pty) Ltd intends to adopt a systematic prospecting approach starting with desktop study, field evaluation and mapping, and

4 ultimately, drilling and possibly test quarrying in selected areas where the outcomes of field evaluation are positive.

2.1 Proposed exploration technologies 2.1.1 Desktop Study The exploration program will commence with a review of geological maps and historical drilling and / or quarrying data for the area. 2.1.2 Field evaluation Field evaluation will be carried out by a competent and qualified geologist, aimed at locating suitable outcrops in the field and subsequently delineating potential granite intrusions. Granite bodies identified will be ranked in order of priority for follow up exploration based on various factors such as: • Size (both lateral & vertical thickness) of the granite intrusion • Colour, texture, pattern and frequency / intensity of the granite intrusion rock mass • Discontinuities by mapping presence of joints and veins, and evaluating their spacing At this stage, small hand samples (about 30 cm3 in dimension) will be taken for cutting and polishing to provide insight on hardness of the stone and whether or not the stone can be polished to an acceptable finish. As an end product, a geological map of the area will be produced to assist in target generation for subsequent detailed exploration such as drilling and possibly test mining.

2.1.3 Detailed exploration Vertical and inclined core drilling with a DTH (down the hole) drill rig will be carried out in selected areas, to provide information on the vertical extent of the formation, as well as the colours, textures and joint spacing or possible defects at depth. Where cleaning of the rock units is required, a bulldozer will be used to scrap off overburden, after which an air compressor will be used to further expose the rocks for mapping. This will aid delineation of major geological structures such as fault and shear zones, the extent of veins, frequencies of fracture/ discontinuity, thereby refining the produced geological map. The refined map will then be used to define targets for feasibility or test quarrying.

2.1.4 Feasibility study Where drilling yields positive results, test quarrying by means of butterfly cutting will be conducted to fully evaluate the recovery of saleable blocks, and better optimize the extraction methods, production rates and operational costs. This will be carried out in selected areas only and shall be performed on as small an area as possible to minimize

5 environmental impacts. Project feasibility will also be measured in terms of accessibility from site of occurrence to nearby relevant infrastructure such as roads, railway, etc.

Areas found to comprise good quality rocks in economic volumes will then be delineated for possible mining, subject to the granting of a valid mining license by the Ministry of Mines and Energy (MME). Therefore it should be noted that this scoping report is only for the different exploration phase or activities. Figure 3 shows some of the technologies and equipment to be used in this study. Although the pictures are showing the use of such technologies in mining, for this study they will be used for exploration purposes.

Overburden Removal (applied in mining) Down-the-Hole drilling (applied in mining) Figure 3: An example of technologies and equipment to be used during exploration.

2.2 Project requirements and Associated infrastructure 2.2.1 Power Requirements It is anticipated that onsite machinery will be diesel powered. It will mainly be used in powering the compressors for surface cleaning, drilling and cutting machinery. The amount of diesel to be used has not been determined, however it will be delivered to site as required and stored in a trailer mounted bowser. This eradicates the need to connect to the national power grid. 2.2.2 Water supply About 2000 litres of water will be required for operations per day. Therefore, to avoid putting pressure on surface and groundwater resources in the area, water for exploration activities will be sourced either from Karibib or from the proponent’s warehouse water supply line in Swakopmund. The water will then be transported to site by truck and kept onsite in water tankers. Therefore, no abstraction will take place from local boreholes. The water will primarily be used to cool and lubricate cutting and drilling machinery and will be recycled to make maximum use of available water.

2.2.3 Roads The project will utilise existing farm roads and where necessary, temporary informal access routes will be created to gain access to the actual targeted sites for the drilling rig, air compressor and water trucks. 2.2.4 Waste production and sanitation Movable ablution facilities with septic tanks will be put up for sanitation purposes for the exploration team. General solid waste will be collected and sent to the Arandis Landfill. 2.2.5 Temporary shelter / accommodation A temporary camp will be set up to accommodate the exploration team. It will primarily be an erection of tents and other temporary structures such as pre-fabricated structures that will be used as office and storage space. All this will take place subject to approval by the farm owners. 2.2.6 Personnel and site safety A total of about seven (7) people will be employed during exploration and all workers will be equipped with adequate and appropriate personal protective equipment (PPE), that will be replaced or repaired to ensure workers’ occupational health and safety. For safety and security reasons, the localized high-risk working sites will be temporarily fenced off. The site and exploration vehicles will be equipped with fire extinguisher in cases of fire outbreaks while carrying out exploration activities.

2.3 Project Alternatives Project alternatives can be defined as a possible course of action, in place of another, that would meet the same purpose and need. The role of alternatives is to find the most effective way of meeting the need and purpose of the proposal, either through enhancing the environmental benefits of the proposed activity, and/ or through reducing or avoiding potentially significant negative impacts. In this section alternatives to the proposed project are evaluated with respect to: • Supporting infrastructure during different stages of the project, and; • The “No-go” alternative option 2.3.1 Alternative supporting infrastructure Alternatives were considered for the different envisaged supporting infrastructures, to ensure that the most feasible options were selected. Due consideration was given to technological, economic and environmental limitations in selecting the most feasible option. Table 2-1: Alternative infrastructure. Category of Infrastructure Alternatives Considered Justification for selected option Install fixed facility with septic To avoid long-term visual tank impacts & minimize Ablution facilities Portable facilities with septic rehabilitation costs, portable tank facilities were selected as the best option

Shade structure made from Shade structure made from blue/ red corrugated sheets corrugated sheets deemed Shade Structure for working Shade structure made with most suitable due to areas shade net robustness, & resistance to wind destruction

Use existing farm boreholes To avoid putting pressure on Drill own new borehole existing water resources, the Water supply Bring water from elsewhere option to bring in water from elsewhere was chosen.

Install fixed above-ground The use of a trailer mounted diesel tank on site diesel tank for fuel storage Trailer mounted diesel tank was chosen due to great mobility requirements during Diesel storage exploration

Diesel generator set Most practical & economically viable for exploration and test mining Power supply phase Install photovoltaic panels Option likely to be considered for long-term operations if economic deposit with high life of mine is found

Erect dis-mantable Favoured during field prefabricated units exploration phase due to: - Ease of installation - Low installation costs - Ease of dismantling & Offices, accommodation moving Erect Permanent buildings Lease favoured & unlikely No office, accommodation Option likely to be structures on site considered in future, should the project proceed to quarrying/ mining phase. This will minimize risk of veld fires, bush hunting, visual impact from such structures, security risk, & minimize number of people on site.

2.3.2 No-go alternative The “No-Go” alternative is the option of not proceeding with the proposed activity, which typically implies a continuation of the status quo. Should the proposed project be

8 discontinued, none of the potential impacts identified in Subsection 7 will occur. On the other hand, if the project is to be discontinued, the potential economic benefits of the project will not come to fruition. These include:  Loss of foreign direct investment  Jobs for community members will not be realized  Loss of potential income to local and national government through land lease fees, license lease fees and various tax structures  Socio-economic benefits such as skills acquisition to local community members  Compromise towards ensuring sustainability of dimension stone processing factories in Karibib and Walvis Bay, with potential job losses and compromise on livelihoods in future.

In light of the above losses, the ‘no-go’ option is not considered a preferred alternative.

3 LEGAL REQUIREMENTS

3.1 Applicable Legislations and Compliance Status In Namibia all mineral rights, related to small to medium-scale mining, are vested in the state and are regulated by the Ministry of Mines and Energy (MME), with the Minerals Prospecting and Mining Act (Act no. 33) of 1992 as the principal act governing exploration and mining of mineral resources in the Republic of Namibia. From an environmental management standpoint this Act stipulates the undertaking of an environmental impact assessment during prospecting or mining operations, coupled with the development of a thorough and implementable environmental plan (EMP) where any pollution is anticipated. The Ministry of Mines and Energy is the custodian agency for the administration of the mining act.

Meanwhile, the Ministry of Environment, Forestry and Tourism (MEFT) regulates sustainable exploitation of natural resources and management of the environment and use is regulated by the under the Environmental Management Act (EMA) of 2007 and its Environmental Impact Assessment (EIA) Regulations of 2012. This administration and enforcement is specifically entrusted with the Department of Environmental Affairs within MEFT. This Act stipulates that possession of an Environmental Clearance Certificate (ECC) is a pre-requisite for issuing any license or permit by any authority for any activities related to the ones listed under the Environmental Impact Assessment Regulations of 2012. The Act further sets out under Section 58 and in the Government Notice No. 29 of 2012 a detailed framework and schedule for conducting Environmental Impact Assessments for mining companies.

In addition to these two acts, there are host of legal and policy documents and guidelines to consider when undertaking an ESA or EIA for mining projects as indicated in Table 3-1.

Table 3-1. Applicable legislation, policies and guidelines to the proposed exploration activity.

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts The Constitution Government of the Republic of The Namibian government has adopted several policies that promote sustainable of the Republic Namibia development. Most of these originate in clauses of the Constitution of the Republic of Namibia. of Namibia In Article 95 (i), the State undertakes to actively promote and maintain the welfare of the (1990) people by adopting policies aimed at the utilisation of natural resources on a sustainable basis for the benefit of all Namibians. Articles 91(c) and 95(l) are also of relevance to sound environmental management practice. In summary, these refer to:

 Guarding against over-utilisation of biological natural resources.  Pursuing sustainable natural resource use  Limiting over-exploitation of non-renewable resources.  Maintaining biological diversity  Ensuring ecosystem functionality.  Protecting Namibia’s sense of place and character.

Through implementation of the mitigation measures set out in this Scoping Report (ESA) and Environmental Management Plan (EMP), the owner of the ECC shall be advocating for sound environmental management as set out in the Constitution.

Environmental Part 2 of the Act sets out 12 principles of environmental management, summarized as follows: Management MEFT: DEA Act No. 7 of  Community involvement in natural resources management, must be promoted and 2007 and its facilitated. 2012 EIA  The participation of all I&APs must be promoted and decisions must consider the Regulations Government interest, needs and values of I&APs. Notice 28-30

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts (Government  Equitable access to environmental resources must be promoted and the functional Gazette integrity of ecological systems must be considered to ensure sustainable systems. 4878  Assessments must be undertaken for activities which may have significant effects on the environment or the use of natural resources.  Sustainable development must be promoted in all aspects relating to the environment.  Namibia’s cultural and natural heritage including, its biological diversity, must be protected and respected.  The option that provides the most benefit or causes the least damage to the environment, at a cost acceptable to society must be adopted to reduce the generation of waste and polluting substances at source.  The reduction, re-use and recycling of waste must be promoted.  A person who causes damage to the environment must pay the costs associated with rehabilitation of damage to the environment and to human health caused by the pollution.  Where there is sufficient evidence which establishes that there are threats of serious or irreversible damage to the environment, lack of full scientific certainty may not be used as a reason for postponing cost-effective measures to prevent environmental degradation; and  Damage to the environment must be prevented and activities which cause such damage must be reduced, limited, or controlled.

The proponent has the responsibility to ensure that the proposed activity, as well as the ESA process, conforms to the principles of this Act. In developing the ESA process, Omavi has been cognizant of these requirements, and accordingly the ESA process has been undertaken in conformance with this Act and the EIA Regulations (2012). Several listed activities in terms of

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts the Act, are triggered by the proposed activities.

Mineral MME Sections 50, 52, 54, 57 and 130 of this Act sets out provisions for environmental management for Prospecting & activities arising from mineral exploration and mining, as follows: Mining Act (Act no. 33 of 1992)  That the mineral license holder is required to prepare an ESA or EIA and an EMP and make revision of such EMP from time to time  That the mining license holder is liable to pay compensation where in course of the mining operations; any damage is done to the surface of land, water source, cultivation, building or any other structure  That the holder of a mineral license cannot exercise any rights on a private land until the holder has entered into an agreement with the owner regarding payment of compensation  That the license holder shall take all necessary remedial steps to reasonable satisfaction of the minister for any damage caused by any mining operations on closure of mines.  That the minister is empowered to direct the mineral license holder for carrying out good reconnaissance, mining and prospecting practices for the protection of the environment, and conservation of natural resources payment of liability fees and royalty and remedial steps for any damages and  That the mineral or mining license holder shall report pollution in course of any mining or prospecting operations and make remedial measures for such. The abovementioned provisions are all relevant to the proposed activities and were thus considered in the ESA process and drafting of the EMP.

Pollution Control MEFT and others This Bill serves to regulate and prevent the discharge of pollutants to air and water as well as & Waste

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts Management providing for general waste management. The Bill repeals the Atmospheric Pollution Prevention Bill Ordinance (11 of 1976). In terms of water pollution, it will be illegal to discharge of, or dispose of, pollutants into any watercourse without a Water Pollution Licence (apart from certain accepted discharges). Similarly, an Air Quality Licence will be required for any pollution discharged to air above a certain threshold. The Bill also provides for noise, dust or odour control that may be considered a nuisance. The Bill advocates for duty of care with respect to waste management affecting humans and the environment and calls for a waste management licence for any activity relating to waste or hazardous waste management.

The proposed exploration and quarrying of dimension stone and industrial minerals would not entail the discharge of large quantities of gaseous pollutants into air but might result in the generation of noise and dust during the construction, operational and closure phases.

Water Act (No. MAWLR: Department of Water Makes provision for several functions pertaining to the management, control and use of water 54 of 1956) Affairs resources, water supply and the protection of water resources.

The Proponent should prevent any potential pollution of groundwater. Water should be used in a sustainable way. Water abstraction and use should be done in a responsible and sustainable manner.

Water This Act provides a framework for managing water resources based on the principles of Resources integrated water resources management. It provides for the management, development, Management protection, conservation, and use of water resources. Should the proponent wish to undertake Act (Act No. 11 of 2013) activities involving water abstraction and/or effluent discharge, the relevant permits will have to be applied for.

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts Furthermore, any watercourse on/or near the site and associated ecosystems should be protected in alignment with the principles above. Mitigations measures were included in the EMP to reduce impacts on watercourses that could not be avoided

Nature MEFT The Nature Conservation Amendment of 1996 (section 73.1) provides for an economically Conservation based system of sustainable management and utilization of game in communal areas; to Ordinance (Act delete references to representative authorities; and to provide for matters incidental hereto. No. of 1996)

Although the proposed sites for development are not located within protected areas, there is indigenous vegetation on the sites and therefore this Ordinance is relevant. A permit is required should any species onsite, with a protected or endangered status, be damaged or removed. If required, the proponent will apply for such a permit prior to commencing with the proposed activities.

Forestry Act MEFT The Act provides for the management and use of forests and forest products. (Act No. 12 of 2001)

Section 22. (1) provides: “Unless otherwise authorised by this Act, or by a licence issued under subsection (3), no person shall on any land which is not part of a surveyed erven of a local authority area as defined in section 1 of the Local Authorities Act, 1992 (Act No. 23 of 1992) cut, destroy or remove - (a) vegetation which is on a sand dune or drifting sand or on a gully unless the cutting, destruction or removal is done for the purpose of stabilising the sand or gully; or (b) any living tree, bush or shrub growing within 100 m of a river, stream or watercourse.”

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts The proponent will apply for the relevant permit under this Act if it becomes necessary.

Soil MAWLR The Act makes provision for the prevention and control of soil erosion and the protection, Conservation improvement and conservation of soil, vegetation and water supply sources and resources, Act (Act No. 76 through directives declared by the Minister. of 1969)

This Act is applicable since stripping of topsoil will take place to expose the targeted rock units. Mitigation measures are included in the EMP to preserve topsoil and reduce impacts on topsoil.

Regional MURD The Regional Councils Act legislates the establishment of Regional Councils that are Councils Act responsible for the planning and coordination of regional policies and development. (Act No. 22 of 1992) The main objective of this Act is to initiate, supervise, manage, and evaluate development in the regions.

The relevant Regional Council for this project is the Erongo Regional Council which is an I&AP and has been provided with the opportunity to comment on the proposed project.

Petroleum MME: Petroleum Affairs Division Regulation 3(2)(b) states that “No person shall possess or store any fuel except under authority Products of a licence or a certificate, excluding a person who possesses or stores such fuel in a quantity and Energy Act of 600 litres or less in any container kept at a place outside a local authority area. (No. 13 of 1990)

Regulations (2001) The Proponent should obtain the necessary authorization from the MME for the storage of fuel on-site.

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts The Road Traffic MWT: Roads Authority The Act provides for the establishment of the Transportation Commission of Namibia; for the and control of traffic on public roads, the licensing of drivers, the registration and licensing of Transport Act vehicles, the control and regulation of road transport across Namibia's borders; and for matters (No. 22 of 1999) incidental thereto.

Should the proponent wish to undertake activities involving road transportation or access onto existing roads, the relevant permits will be required.

Traditional MURD Namibian legislation recognizes both statutory and customary forms of governance. The Authority Act Traditional Authorities Act recognizes Traditional Authorities (TAs), as the customary leadership (Act No. 25 of of traditional communities as legal entities. 2000)

The primary functions of these authorities are to promote peace and welfare amongst the community members, as well as to supervise and ensure the observance of the customary law of that community by its members.

The Act also stipulates that TAs should ensure that natural resources are used on a sustainable basis that conserves the ecosystem. The implications of this Act are that TAs must be fully involved in the planning of land use and development for their area. It is the responsibility of the TA’s customary leaderships, the Chiefs, to exercise control on behalf of the state and the residents in their designated area.

The EPL under consideration in this project is predominantly located on Farm Trekkopje No. 120, which is a communal farm under the! Oe#Gan Traditional Authority. As such this TA is a key I&AP and will therefore be provided with the opportunity to comment on the proposed

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts project.

National MEAC The Act makes provision for the protection and conservation of places and objects of heritage Heritage Act significance and the registration of such places and objects. Part V Section 46 of the Act (Act No. 27 of prohibits removal, damage, alteration or excavation of heritage sites or remains, while Section 2004) 48 sets out the procedure for application and granting of permits such as might be required in the event of damage to a protected site occurring as an inevitable result of development. Part VI Section 55 Paragraphs 3 and 4 require that any person who discovers an archaeological site should notify the National Heritage Council. Section 51 (3) sets out the requirements for impact assessment.

No objects of heritage concern were noted onsite. However, should any objects of heritage significance be identified during exploration, quarry development and mining phase, the work must cease immediately in the affected sites and the necessary steps taken to seek authorisation from the Council.

Public Health MoHSS: Occupational Health The Act serves to protect the public from nuisance and states that no person shall cause a Act (Act No. 36 nuisance or shall suffer to exist on any land or premises owned or occupied by him or of which of 1919) he is in charge any nuisance or other condition liable to be injurious or dangerous to health.

The proponent should ensure that the facility is designed and operated in a way that is not unsafe, or injurious or dangerous to public health and that the noise and dust emissions which could be considered a nuisance remain at acceptable levels. This will be applicable during the exploration, structure construction and mining phases of the proposed project to the

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts employees but not so much to landowners as farmhouses and settlements are located far away from where quarrying will take place.

Labour Act, MLIEC Sections 3, 4, 5, 11, 16, 23-27, 44 and 135 make provision for the following: 2007  That a person may not employ a child under the age of 14years  That children are prohibited for employment in a mine and other dangerous circumstances  That forced employment of persons is prohibited  That an employee is entitled to monetary remuneration daily, weekly, fortnightly, or monthly in cash, cheque, and direct deposit into a bank account  That the work hours of an employee are 45 hours in a week, over and above which an employee is entitled to additional payment overtime wage  That employees are entitled to (a) annual leave on the basis of the average number of days worked over the year, (b) a day’s sick leave for every 26days worked, (c) compassionate leave for a period of 5days in 12 months which is fully paid, and (d) leave on public holidays,  That female employees that have completed 6 months of employment are entitled to 12 weeks of maternity leave, which can be extended for a further period of one month  That the minister is empowered to make regulations in relation to safety, health, hygiene, sanitation, and welfare of persons employed in or about mines, including sea- bed operations

The proponent is expected to be compliant with the above provisions and as such the above

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts provisions were accounted for in the ESA report and EMP.

Relevant Policies and Regulations

Environmental MEFT: DEA This policy aims to promote sustainable development and economic growth while protecting Assessment the environment in the long term by requiring environmental assessment prior to undertaking of Policy (1994) certain activities. Annexure B of the policy contains a schedule of activities that may have significant detrimental effects on the environment, and which require authorisation prior to undertaking. Please see Table 3-2 for a summary of the activities that would require authorisation for the proposed exploration and quarrying of dimension stone and industrial minerals.

Mine Health & MME: Mine Safety & Services These set of regulations are aimed at ensuring that mines are operated in a safe manner to Safety Division prevent fatalities, injuries, and long-term health hazards. The regulations make provision for: Regulations (under section MoHSS: Occupational Health  Employee’s right to leave unsafe working places 138A of the Division  Obligation of a mine manager to provide for all safety measures in a mine or quarry Mining Act, 1992)  Reporting of accidents to the chief inspector and keeping a record of such accidents  Requirements for the mine manager to provide occupational health services at area of mining activity  Requirements for stability of excavations; provision of waiting areas; provision of fencing and gates; schemes for working in vicinity of water body.  Provision for mine dump or mine tailings facility  Ensuring that all parts of a mine are well ventilated with minimum standards of air quality  The mine manager’s responsibility to formulate a scheme for safe movement of vehicles being use in the mine/ quarry

LEGISLATION CUSTODIAN ORGAN OF STATE ASPECT OF PROJECT CONSIDERED Relevant Acts  The mine manager’s responsibility to formulate a scheme for identifying hazards at the area of mining activity and provision of appropriate protective equipment  Ensure that the mine manager provides first aid and firefighting equipment and procedures where exploration/ quarrying activities are being conducted All the above-mentioned provisions are relevant to this project and were thus considered in the ESA process and EMP.

Atmospheric MoHSS This ordinance provides for the prevention of air pollution and is affected by the Health Act 21 Pollution of 1988. Under this ordinance, the entire area of Namibia, apart from East Caprivi, is Prevention proclaimed as a controlled area for the purposes of section 4(1) (a) of the ordinance. Ordinance (1976) Hazardous MoHSS The ordinance provides for the control of toxic substances. It covers manufacture, sale, use, Substance disposal and dumping as well as import and export. Although the environmental aspects are Ordinance, No. not explicitly stated, the ordinance provides for the importing, storage, and handling. 14 of 1974 Road MWT: Roads Authority Width of proclaimed roads and road reserve boundaries (S3.1) Control of traffic on urban trunk Ordinance 1972 and main roads (S27.1) (Ordinance 17 of 1972) Infringements and obstructions on and interference with proclaimed roads. (S37.1)

3.2 Relevant Listed Activities in terms of EMA The EMA identifies and lists activities that require environmental clearance prior to commencement. The proposed project would trigger a number of listed activities as indicated in Table 3-2. Table 3-2: Applicable listed activities in terms of the EMA EIA Regulations of 2012 ACTIVITY DESCRIPTION OF ACTIVITY RELEVANCE OF LISTED ACTIVITY

Activity no. The construction of facilities The proposed activity will require development of 2.1 for waste sites, treatment of stockpiles for waste rock on a small-scale during test waste and disposal of waste mining, as well as stockpiling of topsoil stripped off to expose the targeted rock unit. These are both preserved for rehabilitation purposes

Activity No. The construction of facilities The proposed project will entail exploration activities, 3.1 for any process or activities which require environmental clearance and an Exclusive which requires a license, Prospecting Licence prior to commencement. right or other form of authorization, and the renewal of a license, right or other form of authorization, in terms of the Minerals (Prospecting & Mining Act), 1992

Activity No. Other forms of mining or The proposed project would require cleaning over the 3.2 extraction of any natural footprint of the targeted rock units, with possibility of resources whether regulated butterfly cutting for test mining and block sampling. by law or not

Activity No. Resource extraction, 3.3 manipulation, conservation & related activities

Activity no. Change in land use from The proposed project would require the establishment of 5.1(c & d) agricultural use to industrial portable temporary housing/ office units and small (mining & marginal quarries at the targeted sites, thus changing the land use beneficiation) use for the duration of the exploration activities Activity No. The storage and handling of It is anticipated that a portable diesel generator will be 9.4 a dangerous goods, used for power generation for both domestic and including petrol, diesel, liquid industrial use at the site. petroleum gas or paraffin, in containers with a combined capacity of more than 30 m3 (30 000L) at any one

ACTIVITY DESCRIPTION OF ACTIVITY RELEVANCE OF LISTED ACTIVITY

location

Activity No. The construction of – public The proposed project may include the construction of 10.1 (b) roads access roads for access to the sites

4 THE RECEIVING ENVIRONMENT

An understanding of the existing environment can inform the management of potential impacts. Therefore, the environmental practitioner undertook a site visit on the 18th July 2020, to confirm and collect baseline information. The subsequent section discusses the existing environment both from literature as well as from field observation and verbal communication with the residents who gave the site tour. Located approximately 90 km inland from the west coast of Namibia, its climate is moderated by the cold Benguela current and the regular fog bank. This section describes the main climatic parameters within the licence area and surrounding, the resulting living environment as well as its current socio-economic standing.

4.1 Biophysical environment 4.1.1 Climatic Conditions The area generally has a desert climate, with warm temperatures occurring in the inland areas during the day, and cooling at night due to outgoing solar radiation under typically clear skies (MME, 2010). Limpitlaw and Hoadley (2009) described it as a hyper arid desert climate. Maximum and minimum temperatures at the coast are moderated by the effects of the cold Benguela current and the regular fog bank. Given that Arandis is the closest town to the site, reference was made to the Arandis weather information. The town experiences an average annual temperature of 19°C, with maximum temperatures ranging between 17 and 27°C and minimum temperatures ranging between 12 and 21°C over the past 10 years (World Weather online, 2020) ( Figure 4).

Figure 4: The maximum, minimum and average temperature for the Arandis area (World Weather Online, 2020)

In terms of rainfall, it is noted that annual rainfall in the Erongo Region generally increases with distance from the coast. The project site is situated in a belt that receives an average of less than 100mm of rain per annum, with rainfalls of less than 10mm received in 2020 as shown in Figure 5. The recorded rainfall data for Arandis indicates that rainfall events are uncommon, wiith the chance of rain on any given day being calculated at less than 5%, with an annual rainfall of approximately 44mm (ClimateData.org).

Figure 5: The rainfall patterns around Arandis (after World Weather Online, 2020)

Within the Erongo Region, fog can extend up to 110 km inland. Therefore, the project site is within the coastal fog belt and fog events provide an important source of moisture to the functionality of the ecosystem. The wind regime includes prominent southerly and south- westerly winds during the summer, and north-easterly winds in the winter that sometimes reach gale force and mobiles the entire desert surface (MME, 2010). The area also

23 experiences berg wind conditions that introduce hot air to the town and sometimes associated with dust storms. According to the spatial potential evaporation distribution map of Namibia by BGR (20005), the area falls in the range of 3 200 to 3 400mm/a, which could be accredited to high desert temperatures.

4.1.2 Geology and soils The project area is located within the southern Central Zone (sCZ) of the Neo-Proterozoic Damara Orogenic Belt. This area is underlain by the Abbabis Metamorphic Complex (AMB) characterised by basement dome structures and antiforms with northeast elongation exposed along the Swakop and Khan Rivers. The Abbabis Metamorphic Complex is overlain unconformably by the Damara Supergroup, which comprises mainly metasedimentary rocks deposited in the period from about 900 to 700 Ma (Miller, 1983a). The lower part of the Damara Supergroup is dominated by meta-arkoses and calc-silicate rocks of the Nosib Group, while the upper portion of the sequence consists of alternating marble, calc-silicate rock and schist (Swakop Group). The Swakop Group in the rea is represented by rocks of the Chuos (diamictites and boulder-bearing schists), Karibib (Calcitic marble, calc-silicate interlayers and schists), and Kuiseb (interbedded schist, arkosic quartzites and calc-silicate) Formations as seen in Figure 6. The area was later intruded by numerous syn- to post-tectonic granitic plutons, which include minor meta-gabbro, diorite and tonalite, abundant coarse- grained granite, leucogranite and pegmatite (Miller, 2008). Unconsolidated Quaternary sediments consisting mainly of elluvium, alluvium, fanglomerates and calcretes cover large parts of the area. The extremely dry and hot environment and associated formation of evaporates at shallow depths has resulted in the accumulation of salts within the soil profile.

Figure 6: A geological map of the area.

The local geology of the area is characterized by relatively flat light-brown sand, rocky and gravel plains of the Namib Desert with outcrops of granite and quartzite (GCS Water and Environmental Consultants, 2017). The proposed site has undulating hills locally termed koppies, with dolerite dykes (of the Etendeka Formation) cross-cutting intercalated feldspathic granites and calc-silicate outcrops, and with windblown sand and gravels at the foot of the koppies as seen in Figure 7.

Figure 7: The local geology of the area.

4.1.3 Topography and Drainage of Area The general topography is such that there is a gradual decrease in altitude from east to west. The town of Arandis is located some 581 meters above mean sea level. The proposed site has a relatively flat topography, characterized by undulating and occasional hills locally termed koppies.

According to Africa Planning Forum (2019), the area does not have significant natural surface water bodies, except for the Khan River, which lies to the south east and east of the project area. The non-perennial Khan River occurs in a river canyon, beyond which the surrounding becomes mountainous. The Khan River flows to the south west where it joins the Swakop River, and the combined flow goes to the Atlantic Ocean.

The absence of surface water in the area was backed by Limpitlaw and Hoadley (2009), who stated that it only occurs during rare periods of exceptional rainfall but the major rivers in the region, such as the Swakop River usually flow less than five times in a decade. Occasional thunderstorms however do occur turning the small river courses into fast flowing rivulets and causing flashflood conditions (Speiser and Mulder, 2012).

4.1.4 Groundwater Resources The project area falls under the Central Namib-Windhoek Groundwater Basin. The area generally has low and limited potential for groundwater and the water is often of poor quality due to high salinity (Limpitlaw and Hoadley, 2009). Current water supply sources in the coastal areas of Erongo are the Omdel and Kuiseb Aquifers and the desalination plant built and owned by AREVA. Christelis and Struckmeier (2011) further noted that the limited quantities of groundwater in the area is partly due to the low rainfall and lack of recharge, and partly due to the generally unfavourable aquifer properties of Damara Sequence rocks. The latter is also reason why groundwater vulnerability is considered to be low in the area. Shagama (2020) indicated that vulnerability of groundwater to pollution in the project area ranges from rather low to moderate which could be explained by the geology of the site area that is mainly characterized by metamorphic rocks such as granites, dolerite, basalts, marbles, and schists. These rock units without any fractures/faults or joints are considered aquitards (rock units that restrict water flow or hardly transmit water from one rock unit to the other), which in in turn also restricts movement of pollutants in the aquifer system.

4.1.5 Biodiversity Baseline Information The project site falls within what Mendelsohn, Javis, Roberts, & Robertson (2002), call the Namib Desert Biome. The area is characterized by low rainfall with extreme temperatures and unique climatic factors influencing the natural environment and biodiversity. 4.1.5.1 Flora The overall vegetation density ranges from sparse to moderate depending on local soil conditions. This can also be attributed to the predominantly low rainfall and extreme weather conditions in the area. Most of the plants are found within the washes and channels and these are predominantly grasses and thorn shrubs. The vegetation within the study area is sparsely distributed. The dominant plant occurrences observed during the site visit to the project area include Melkboom (a succulent), Camelthorn tress and shrubs, Fat Plant, Quiver trees and Elephant’s Foot plant in decreasing order of abundance. Table 4-1: A summary of observed vegetation. Plant name Occurrence Photograph Melkboom This species of plants (Euphorbia was by far the most damarana dominant in the greater shrubland) area, as well as in the proposed area especially the southern part of Farm Trekkopje. The bushes are very

scattered.

Camelthorn The Acacia trees were (Acacia sparsely distributed on erioloba) the flatter portion of the farm, with Acacia bushes found mostly along some Khan River tributaries.

Fat Plant The Fat Plant had very limited occurrence, and seems to be confined to the mountaneous areas.

Quiver Tree Very few seen in the area, confined to granite outcrops.

Elephant’s foot This plant was seen to a plant limited extent (Adenia pechuelli)

Although the Melkboom was quite common in the area, they are an endemic specie, which according to Burke (2008)’s study on recovery potential and sensitivity of vegetation, have a low recovery.

4.1.5.2 Fauna In terms of fauna, the general area is said to be a home, migratory and grazing site to wild animals. No animals were seen during the site visit, however according to the locals, some leopards (Panthera pardus) live in the caves of the Khan River mountains. The farmers also revealed that gemsbok, springbok and to a limited extend Kudus used to be dominant wildlife on the farms but these have since disappeared either due to drought, hunting and possibly migration triggered by scarcity of water. An occurrence of Berg Zebras, snake types such as Puff Adder, Zebra Snake and Yellow Cobra was noted by the locals.

The Strategic Environmental Impact Assessment (SEIA) for the Central Namib Uranium Rush (2010) classified the region into biodiversity ‘red’ and ‘yellow’ flag areas in terms of certain biodiversity, tourism and heritage hotspots. “Red Flag” status which means that the area is by default unavailable for mining and prospecting unless an extraordinary mineral deposit of national importance occurs in the area. Yellow Flag’ status means mineral licence applications in these areas will be considered only after careful assessment. In terms of biodiversity, the map in Figure 8 was proposed on the basis of the following guiding principles: • Areas with high levels of endemicity and diversity; • Conservation status of species; • The extent to which habitats are threatened or vulnerable to disturbance; and • Habitats or migration routes which are critical for species’ survival

Figure 8: Areas of high biodiversity value in the central Namib in the context of the uranium rush (MME, 2010).

The intention of designating these areas is to highlight them as areas requiring greater protection and conservation than surrounding areas. As it can be seen in Figure 8, the EPL area has a yellow flag on the far west and a red flag on the far east. The yellow is termed Plains S of Trekkoppje, known for its relatively undisturbed gravel plains, wildlife concentrations (springbok, ostrich). Very large, dense field of Sarcocaulon marlothii, while the red is the Khan River, made sensitive by the fact that it is a linear oasis, riparian woodland, aquifer recharge, rich wildlife, bird flight paths (MME, 2010). However, the area of interest is falling in between these sensitivity classes.

4.1.6 Archaeology A burial site was observed on Farm Trekkopje No. 120 (the Trekkopje Cemetery) during the site walk over, however it is well-preserved, fenced off and well documented by the Commonwealth War Graves Commission. It is known locally, and according to the local community, there are about 18 graves from the time of the German war and annual commemorations are usually held in celebration of their lives. It is well fenced off as seen in Figure 9.

Figure 9: The cemetery area, seen to be well preserved and protected by the fencing.

An archaeological desk assessment study was undertaken by Dr John Kinahan to evaluate the archaeological status of the affected area on Farm Trekkopje and surrounding areas. The study revealed that EPL 5161 includes the whole of the battlefield where Allied and German forces engaged in the Battle of Trekkopje in April 1915, and although it is not sufficiently well surveyed as a heritage site, it is considered to be especially sensitive. According to Kinahan (2020) the eleven Allied and German servicemen killed at the Battle of Trekkopje are buried in a fenced and well-maintained cemetery. Kinahan (2020) further adds that there are remains of entrenchments and earthworks that were carried out at the time of the battle and these are found outside the cemetery to the north and east. These and related remains have not been documented in detail. On the eastern side of the railway line adjacent to the site of the Trekkopje Station is a further cemetery containing ten graves, of which three are those of children (Kinahan, 2020). Although no documentation of this cemetery has been found and none of the graves are marked, Kinahan (2020) indicated that it is possible that they date to the years immediately after World War I in 1918, when the so-called Spanish Flu spread through Namibia, often carried by people travelling by train. Similar cemeteries are found at other railway sidings in remote parts of Namibia where the dead were evidently taken from the trains and buried immediately. This is still to be confirmed in the case of Trekkopje.

Figure 11 shows the distribution of archaeological sites known from previous surveys as well as the extent of the area covered by the Trekkopje battlefield site, while Figure 11 shows a contemporary sketch of a battlefield, indicating the entrenchments around Trekkopje battlefield.

Figure 10: The EPL 5161 (grey polygon) in relation to known archaeological/heritage sites (green squares), with Trekopje Battlefield enclosed by peony pink polygon (Kinahan, 2020).

Figure 11: The contemporary battlefield sketch in the lower part of the diagram shows the extent of entrenchments and other features in relation to Trekkopje Station (Kinahan, 2020).

Figure 12: Proposed temporary Exclusion Area (No-Go Area) on EPL5161 to provide for conservation of archaeological/heritage resources associated with the April 1915 Battle of Trekopje pending detailed field assessment (Kinahan, 2020).

The grave sites are nonetheless vulnerable to disturbance if exploration involving earthmoving and invasive sampling are permitted in their near vicinity. It is also a matter of concern that the actual battlefield at Trekkopje has not been surveyed at all and that historically important remains of the conflict might be destroyed in the course of exploration and mining. It is therefore recommended that the battlefield itself (as demarcated in pink polygon in Figure 10 and Figure 12) be excluded from the exploration licence area either permanently or until it has been satisfactorily surveyed. The Archaeological Report from the desk assessment by Dr Kinahan, (herein referenced as Kinahan, 2020) can be found in the attached as Appendix J of this document.

4.2 The socio-economic environment 4.2.1 Population Density and Socio-economic Profile The 2011 Population and Housing Census indicated that the population of Erongo Region was 150 809, with an overall annual growth rate of 3.4%. The region’s economic growth has been largely due to mining, habour operation and fishing industry, as well as tourism, giving the region the second highest per capita income after Khomas (MME, 2010).

The nearest town to the site proposed for this project is Arandis, which had a population of 5170 in 2011 (Population and Housing Census, 2011). According to Hoadley (2009) Arandis

33 was established in 1976 to house employees of the Rössing Uranium Mine (RUL). It has always been very economically dependent on RUL as most residents either worked at the Rössing mine or were contractors for the mine. Other affected communities include Swakopmund and Karibib where the water will be sourced from and where the testing factories are located.

4.2.2 Current Land Use of the area Majority of Erongo Region forms part of the desert, most of which is state owned as protected areas under conservation management (MME, 2010). This includes the Namib- Naukluft Park, the Dorob National Park, National Coast Tourist Recreational Area, etc. managed by MEFT. Further inland is communal land, which is also under conservation management by conservancies such as ≠Gaingu (centred around Spitzkoppe); Tsiseb (focused on Brandberg), Otjimboyo and Ohungu. Small stock farming is common in these areas. East of the communal land are commercial farms which are privately owned and practice mostly cattle ranching and ecotourism (particularly desert excursions). The arid nature of the landscape means that very little of the area has agricultural potential.

Farm Trekkopje is a communal farm, with only one occupant at the moment. He lived on the farm for 30 years, and he keeps cattle and sheep on a small scale. He indicated that it is difficult making a living on these surrounding farms due to water scarcity, therefore other farmers relocated to nearby towns and settlements such as Spitzkopje, Usakos, Arandis, Henties Bay and Karibib where some of them are employed. There are existing boreholes on the farm that were either hand dug or drilled by the government, however they yield saline water, which is only used for livestock. Water levels taken in these boreholes were all less than 15m. The farmer indicated that he gets water for domestic use by truck from AREVA as part of their social responsibility.

4.2.3 Nearby Mines There are a number of mining and mineral exploration activities happening in the region. Some large projects include: two operating uranium mines, Rössing and Swakop Uranium / Husab, and Langer Heinrich which is under care and maintenance due to a drop in uranium price. Other uranium ventures in the area include exploration works by Reptile Mining, Bannerman Resources, Areva Resources Namibia/Trekkopje and Norasa Group/Valencia. Other mining activities in the region include gold mining at Navachab Mine, dimension stones from numerous marble and granite quarries, salt at the Walvis Bay Salt Works, Swakopmund and Cape Cross, as well as mining of semi-precious stones by small scale miners in the Spitzkopje and surrounding.

The site visit revealed that the site is not inert, and there has been mining activities in the past. An abandoned quarry was discovered on the border of Farm Trekkopje and Vergenoeg, going into Haskeen. No rehabilitation has taken place and infrastructure is still partly in place. Although still on Farm Trekkopje, the abandoned site is outside the EPL area. The relative positions of items or features observed during the field visit are shown in Figure 13.

Figure 13: Location of features observed on Farm Trekkopje during the site visit, including the boreholes, cemetery and abandoned quarry.

4.2.4 Air quality and Noise levels The existing mining activities in the region, are a source of gaseous and particulate emissions. Fugitive dust sources associated with mining activities include drilling and blasting operations,

35 materials handling activities, vehicle-entrainment by haul vehicles and wind-blown dust from tailings impoundments and stockpiles. Although no ambient air quality data is available for the area, the Erongo SEA study indicate exceedances of the selected air quality evaluation criteria, which according to Liebenberg-Enslin et. al., (2010) is due to the windblown dust from east-wind conditions. The B2 main road that links central Namibia to the coast contributes to gaseous emissions such as CO2, CO, hydrocarbons (HCs), SO2, NOx, particulates and lead. In addition to air quality, these activities are also great contributors to noise levels. This includes vehicle movement on the public road network, rail transport activities, aircrafts flying to local airports, etc. Potential receptors of noise are the residents of the nearby farms, the town of Arandis and tourists that frequently visit the various attractions in the surrounding area, as well as fauna.

4.2.5 Existing infrastructure The project site has access to the national B2 road which links it to the neighbouring Walvis Bay and Swakopmund going west and Karibib to the east. Additionally, the Trans-Kalahari Highway runs through the EPL and parallel to the B2 road. There is also powerlines that run through the farm and EPL (as seen in Figure 14), known to supply power to both Husab and Rossing operations and Swakopmund.

Figure 14: Powerlines passing through the EPL and Farm Trekkopje.

4.3 Key impacts identified In order to have an impact, there needs to be a source, a pathway and a receptor. In this context, a number of impacts could potentially be generated from the proposed exploration activities, in which case the activities would be the source. Different components of the receiving environment become receptors. Therefore, with this in mind, different impacts were identified and listed below:

 Impact on the physical environment  Impact on soils  Impact on water resources (ground and surface water)  Impact on biodiversity (fauna and flora)  Impact on air quality  Impact on archaeology  Impact on traffic  Impact on health and safety  Impact from noise  Impact on socio-economic standings

5 THE PUBLIC PARTICIPATION PROCESS

The public participation process (PPP) forms an important part of this scoping report, as it provides all persons or organizations an opportunity to comment on the proposed activity and register their views and concerns. This was done in accordance with both the EMA and its EIA Regulations.

5.1 Interested and Affected Parties (I&APs) OMAVI identified stakeholders who were considered to be relevant to the proposed activity including applicable organs of state (national, regional and local). Thereafter, notices regarding the project were placed in widely circulated national newspapers inviting members of the public to register as interested and/or affected parties (I&APs), who were contacted and added to the stakeholders list. These contacts formed part of the mailing list for all communications pertaining to the proposed project. A summary of I&APs identified are presented below and the complete stakeholders list is provided in Appendix B.  Key Ministries  Regional governance  Traditional and local authorities  Service providers (NGOs and SEOs)  Farm owners  Members of the public

5.2 The Public Consultation Process Regulation 21 of the EIA Regulations details steps to be taken during a given public consultation process and these have been used in guiding this process. Communication with I&APs about the proposed development was facilitated through the following means and in this order: • A Background Information Document (BID) containing descriptive information about the proposed exploration activities was compiled and sent out to all identified and registered I&APs; 5.2.1 Notices • Notices were placed in The Namibian Sun, Allgemeine Zeitung and Die Republikein newspapers, briefly explaining the activity and its locality and inviting members of the public to register as I&APs. First adverts were run on 19 June 2020 but due to the Covid-19 pandemic the Region was put on stage one lockdown with immediate effect of the stage of emergency. This led to the decision to only run the second advertisements on 20 July 2020 once the region’s movement and activities were moved to stage three of the state of emergency. These are included in Appendix C; • Notice boards were fixed at visible locations in the Erongo Regional Office as well as at the Arandis Town Council office notice boards (Figure 15).

Figure 15: A site notice placed on Erongo Regional Council notice board.

5.2.2 Consultation Meetings • A meeting with Local Authority was arranged for the 9th July 2020 10h00 and was done virtually via Zoom due Covid-19 and resulting lockdown regulations imposed on the Erongo Region. Minutes for this meeting were emailed to all identified authority on 21st July 2020 and are included in Appendix D.

• A public consultation meeting was carried out 25 July 2020, 14h00 at the water point on Farm Hakskeen. A radio announcement was done on a local radio station by the Head of Traditional Authority, inviting the public to the meeting. At the public meeting, a presentation was given by OMAVI (with the assistance of a local translator between English and both Afrikaans and Damara-Nama), and the attendees were requested to fill in an attendance register attached as an Appendix E. Minutes for this meeting were emailed to all the registered interested and affected parties who had e-mail addresses in July 2020 and can be found in Appendix D, together with the minutes for the authority meeting.

Figure 16: Pictures from the public consultation meeting held on Farm Hakskeen.

5.3 Key issues raised 5.3.1 First round of public consultation A number of issues and concerns were raised during the public participation period, some of which were registered via email and others during the public consultation meeting. These are summarized in Table 5-1 below. Comments registered via email are furnished in the Issues and Response Trail presented in Appendix F and the proof of communication is presented in Appendix G. Table 5-1: A summary of key issues received. Environmental Concern Response component Groundwater Limited groundwater in the area and low Refer to Groundwater specialist study

rainfall report in Appendix I of the Scoping Report. Additionally, no water will be sourced from the area. It will be imported from elsewhere and recycled. Biodiversity Area might have environmentally sensitive This impact has been assessed under habitats for botany, invertebrates, reptiles section 6.3 of the environmental and mammals scoping assessment (ESA) report. Measures towards preservation of fauna and flora in the area have been outlined in the EMP

Aesthetics Potential visual impact and altering of This impact is anticipated to be low landscape from the mine quarry as well as considering that no quarrying for the campsite mining purposes will take place. Only rather extraction of selected blocks for testing. Measures to minimize this impact are outlined in the section 6.3 of the ESA report and the EMP. Air Quality Potential dust and airborne emissions The impact assessment for this resulting from the proposed excavation, component has been done in drilling, stone cutting and related activities Chapter 6 of the ESA report and mitigation measures are outlined in the EMP. Soil and water Risk of hydrocarbon spillages This impact has been assessed under section 6.3 of the ESA report. Measures towards prevention, containment, and clean up of hydrocarbon spills have been outlined under mitigations as well as in the EMP

Noise Noise from vehicles, drilling and cutting Measures were recommended to machinery keep the noise to an acceptable level. Refer to sections 6.3.2.5 and 6.3.3.5 as well as the EMP. Traffic and roads Deterioration of roads infrastructure due to Best Cheer should operate within the infrastructure exploration Roads Act and be subjected to weigh bridges and necessary fees. Licencing Is the work only with respect to exploration The present ESA is only for exploration or includes mining? activities. If this process yields positive

results, an application for a mining licence will be launched with MME, accompanied by a separate EIA to assess impacts of mining. Socio-economic - Concerns of employment as Communication forwarded to Best community requests for transparency Cheer Investments Namibia (Pty) Ltd from the proponent and honouring of their commitment. - Capacity building must involve transfer of more sophisticated skills as opposed to driving trucks and shovelling.

Animal safety Potential for animals to fall into mined This impact will be minimal, as no during mining areas actual mining will be taking place. Sites from which testing blocks will be extracted will be fenced off until they are reinstated. Communication How the community can hold the A suggestion was made for the and proponent accountable and community, the proponent and the Accountability communicate effectively with the consultant to establish a structure or proponent channel of communication. The EMP will also be binding for the proponent to uphold their obligations.

5.3.2 Second round of public consultation The comments received in the first round of public consultation were included in the draft environmental scoping assessment (ESA) report, which was circulated to all I&APs for review. This was done via email and hard copies of the report were also couriered to the central offices for the local community to comment and give feedback as part of the second round of public consultation. No further comments or feedback was received from the second stage, therefore the draft ESA report was finalised for submission and evaluation by the DEA at MEFT. However, on submission, there was a requirement for a consent letter from the National Heritage Council of Namibia (NHC), which prompted the need for an archaeological study. This communication is included in Appendix G together with other communications and in response, an Archaeological study was done by an independent consultant, Dr Kinahan, whose feedback has been incorporated in this assessment and his full report is included in Appendix J.

6 IMPACT ASSESSMENT

By considering the potential risk areas associated with the receiving biophysical and social environment as well as the issues raised during the public consultation process, the following key impacts have been highlighted for consideration.

6.1 Key impacts identified and their sources per project phase A number of impacts could potentially be generated from the proposed exploration activities as documented in this section as well as their sources. It is important to realize that the type and scale of these impacts will differ between different phases of the exploration project. The potential sources of impact associated with the different project phases are described below, and an assessment of impacts identified are discussed in the subsequent subchapters.

6.1.1 Desktop study This phase will have no impact on the environment as it is primarily office based and involves review of geological maps and historical drilling and/ or quarrying data for the area.

Table 6-1: Impacts identified desktop study Feature Description of Project Activity Potential Impact

Positive

Employment Appointment of a project geologist Employment opportunity for a local to do desktop studies. graduate

Negative

None

6.1.2 Impacts identified for Field evaluation The potential impacts associated with field evaluation will be minimal as this phase will employ non-invasive / destructive techniques. It strictly entails walking the area to map out outcrops and delineate potential granite intrusions to produce a geological map. Thereafter, the intrusions will be ranked in terms of size, colour, texture, patterns and presence of discontinuities as mapped. Additionally, hand samples (about 30 cm3 in dimension) will be collected during this stage and will be taken for hardness testing as well as polishing trials. This stage will primarily involve personnel walking the site and minimal driving in a 4x4 vehicle. Therefore, the impacts identified at this stage will primarily result from the following facets:

Table 6-2: Impacts identified for field evaluation Feature Description of Project Activity Potential Impact

Feature Description of Project Activity Potential Impact

Positive

Employment Appointment of technical or field Employment opportunity for local assistants to the project geologist to graduates assist with mapping.

Negative

Soil Petrochemical spills from Potential soil disturbance and pollution exploration vehicles

Clearing of pathways for exploration vehicles and setting up of exploration camp during field evaluation

Surface and Petrochemical spills from Potential contamination of surface groundwater exploration vehicles and groundwater

Biodiversity Clearing of pathways for Loss of vegetation exploration vehicles and setting up

of exploration camp during field Habitat destruction for fauna evaluation

Air quality Potential gas and dust generation Short-term decrease in surrounding air by exploration vehicles quality

6.1.3 Impacts identified for Detailed exploration This phase will employ invasive techniques such as diamond core drilling, to permit a better understanding of vertical extent of the formation, colour and texture as well as joint spacing or possible defects at depth. It is anticipated that drilling activities will require small, tracked access roads to gain entry to the actual drilling sites by the air compressor and water truck. Therefore, the impacts identified at this stage can be summarized as follows:

Table 6-3: Impacts identified for Detailed exploration Feature Description of Project Activity Potential Impact

Positive

Employment This stage will require both technical Employment opportunity for 5 local and non-technical personnel to non-technical personnel assist with drilling activities and

Feature Description of Project Activity Potential Impact

Local and regional operate machinery. Therefore, in Positive contribution to the general economy addition to the geology team, economy of the Erongo Region. operators will be sourced from the local community.

Procurement of consumable project needs such as PPE, spare parts for machinery and lubricants from local businesses

Skills and knowledge Through skills transfer, training and Local community empowerment certification of local communities

Negative

Soil Petrochemical spills from vehicles Potential soil disturbance and pollution and diesel operated machinery

Widening of pathways for vehicles, air compressor and water trucks.

Removal of top soil over the footprints of mapping transverses

Surface and Mishandling and improper disposal Potential contamination of surface groundwater of petrochemicals, spills from and groundwater vehicles and diesel operated machinery

Biodiversity The potential removal of small Loss of vegetation shrubs within the project footprint to Habitat destruction widen pathways for vehicles, air compressor and water trucks as well as for mapping transverses

Traffic Increased traffic and presence of Short-term increase of traffic in the heavy equipment on site area.

Air quality Potential gas emission from diesel Short-term decrease in surrounding air powered machinery. quality

Dust generation by moving vehicles

Noise Exploration equipment will Noise impact inevitably produce noise.

Feature Description of Project Activity Potential Impact

Wildlife The introduction of activities such as Habitat disturbance and Potential drilling has potential to drive away poaching of wildlife wildlife from their habitat due to noise and constant movement. Presence of people may lead to hunting of wild animals

Health and Safety Improper handling of equipment Potential health and safety risk and machinery may compromise the health and safety of the employees

Contracting of diseases

6.1.4 Impacts identified for Feasibility study This activity will only be undertaken if the detailed exploration yields positive results and will target areas with good potential. The techniques will include butterfly cutting and extraction of blocks for evaluation. These are invasive techniques, therefore impact will come from the features summarized in Table 6-4:

Table 6-4: Impacts identified for Feasibility study Feature Description of Project Activity Potential Impact

Positive

Employment This stage will require both technical Employment opportunity for 5 local and non-technical personnel to non-technical personnel assist with drilling activities and operate machinery. Therefore, in Local and regional Positive contribution to the general addition to the geology team, economy economy of the Erongo Region. operators will be sourced from the local community.

Procurement of consumable project needs such as PPE, spare parts for machinery and lubricants from local businesses

Skills and knowledge Through skills transfer, training and Local community empowerment certification of local communities

Negative

Feature Description of Project Activity Potential Impact

Soil Petrochemical spills from vehicles Potential soil disturbance and pollution and diesel operated machinery

Scrapping of overburden and air compressing rock surfaces to clean and better expose them.

Surface and Mishandling and improper disposal Potential contamination of surface groundwater of petrochemicals, spills from and groundwater vehicles and diesel operated machinery

Biodiversity The potential removal of vegetation Loss of vegetation scrapping of overburden to better

expose target rock

Wildlife Activities such as drilling and cutting Habitat disturbance has potential to drive away wildlife Potential poaching of wildlife from their habitat due to noise and constant movement.

Loss of habitat for some animals that reside on these koppies

Presence of people may lead to hunting of wild animals

Traffic Increased traffic and presence of Short-term increase of traffic in the heavy equipment on site area.

Air quality Potential gas emission from diesel Short-term decrease in surrounding air powered machinery. quality

Dust generation by moving vehicles, from air compressing and cleaning of rock surfaces and the cutting of blocks.

Noise Drilling and cutting equipment will Noise impact inevitably produce noise.

Feature Description of Project Activity Potential Impact

Health and Safety Improper handling of equipment Potential health and safety risk and machinery may compromise the health and safety of the employees

Contracting of diseases

Visual Removal of blocks can lead to Small scale visual impacts compromised natural beauty and deterioration in sense of place.

Littering by exploration staff.

Archaeology Removal of blocks that could Disturbance of heritage or contain archaeological evidence archaeology

The purpose of impact assessment is to identify and evaluate the significance that these impacts can have on identified receptors and resources, and come up with measures to minimise or prevent them all together. The identified potential impacts were assessed according to defined assessment criteria discussed below.

6.2 Impact Assessment Methodology The potential impacts pertaining to the exploration activities were assessed in terms of probability (likelihood of occurring), scale/extent (spatial scale), magnitude (severity) and duration (temporal scale) as presented in Table 6-5, Table 6-6, Table 6-7 and Table 6-8. To enable a scientific approach to the determination of the environmental significance, a numerical value is linked to each rating scale. This methodology ensures uniformity and comparability over a wide range of impacts.

It is assumed that an assessment of the significance of a potential impact is a good indicator of the risk associated with such an impact. The following criteria will be applied to each potential impact to determine its significance.

6.2.1 Extent (spatial scale) Extent is an indication of the physical and spatial scale of the impact. Table 6-5 shows rating of impact in terms of extent of spatial scale.

Table 6-5: Extent or spatial impact rating Low (1) Low/Medium (2) Medium (3) Medium/High (4) High (5)

Low (1) Low/Medium (2) Medium (3) Medium/High (4) High (5) Impact is localised Impact is beyond Impacts felt within Impact Impact extend within the site the site boundary: adjacent widespread far National or over boundary: Site only Local biophysical and beyond site international social boundary: boundaries environments: Regional Regional 6.2.2 Duration Duration refers to the timeframe over which the impact is expected to occur, measured in relation to the lifetime of the project. Table 6-6 shows the rating of impact in terms of duration.

Table 6-6: Duration impact rating Low (1) Low/Medium (2) Medium (3) Medium/High (4) High (5) Immediate Impact is quickly Reversible over Impact is long-term Long term; beyond mitigating reversible, short time; medium term closure; measures, term impacts (0-5 (5-15 years) permanent; immediate years) irreplaceable or progress irretrievable commitment of resources

6.2.3 Intensity, Magnitude / severity Intensity refers to the degree or magnitude to which the impact alters the functioning of an element of the environment. The magnitude of alteration can either be positive or negative. These were also taken into consideration during the assessment of severity. Table 6-7 shows the rating of impact in terms of intensity, magnitude or severity.

Table 6-7: Intensity, magnitude or severity impact rating Type of Negative criteria H- M/H- M- M/L- L- (10) (8) (6) (4) (2) Qualitative Very high Substantial Moderate Low Minor deterioration, deterioration, deterioration, deterioration, deterioration, high quantity death, illness or discomfort, slight nuisance or of deaths, injury, loss of partial loss of noticeable irritation, minor injury of illness habitat / habitat / alteration in change in / total loss of diversity or biodiversity or habitat and species / habitat, total resource, resource, biodiversity. habitat / alteration of severe moderate Little loss in diversity or ecological alteration or alteration species resource, no or processes, disturbance of numbers very little extinction of important quality rare species processes deterioration.

6.2.4 Probability of occurrence Probability describes the likelihood of the impacts actually occurring. This determination is based on previous experience with similar projects and/or based on professional judgment. See Table 6-8 for impact rating in terms of probability of occurrence.

Table 6-8: Probability of occurrence impact rating Low (1) Medium/Low (2) Medium (3) Medium/High (4) High (5)

Low (1) Medium/Low (2) Medium (3) Medium/High (4) High (5) Probable if Definite (regardless Improbable; low Likely to occur Possible, distinct mitigating measures of preventative likelihood; from time to time. possibility, frequent. are not measures), highly seldom. No Low risk or Low to medium risk implemented. likely, continuous. known risk or vulnerability to or vulnerability to Medium risk of High risk or vulnerability to natural or induced natural or induced vulnerability to vulnerability to natural or hazards hazards. natural or induced natural or induced induced hazards. hazards. hazards.

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

Once the above factors (Table 6-5, Table 6-6, Table 6-7 and Table 6-8) have been ranked for each potential impact, the impact significance of each is assessed using the following formula:

SP = (magnitude + duration + scale) x probability

The maximum value per potential impact is 100 significance points (SP). Potential impacts were rated as high, moderate or low significance, based on the following significance rating scale (Table 6-9).

Table 6-9: Significance rating scale SIGNIFICANCE ENVIRONMENTAL SIGNIFICANCE POINTS COLOUR CODE

High (positive) >60 H

Medium (positive) 30 to 60 M

Low (positive) <30 L

Neutral 0 N

Low (negative) >-30 L

Medium -30 to -60 M (negative)

High (negative) >-60 H

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

The potential impacts associated with the proposed project and their assessments are described in the subsequent subchapters.

6.3 Impact assessment The potential impacts associated with the different project phases (Field evaluation, detailed exploration and feasibility stage) are described and assessed in the following subchapters. For each impact evaluated or assessed, it is assumed that the significance of that potential impact is a good indicator of the risk associated with such an impact. Therefore, for each potential impact:  a brief explanation is given;

 A significance rating is given for pre- and post-mitigation of the impact; and

 The recommended mitigation measures are given.

The recommended mitigation measures prescribed for each of the potential impacts contribute towards the attainment of environmentally sustainable operational conditions of the project for various features of the biophysical and social environment.

6.3.1 Field evaluation 6.3.1.1 Impact on soils At this stage the potential sources of soil pollution would be spills of petrochemicals from exploration vehicles during field evaluation.

Table 6-10: Assessment of the impacts of field evaluation on soil pollution Extent Duration Intensity Probability Significance Pre-mitigation L-/M - 2 L – 1 M/L - 4 L/M - 2 L – 14 Post-mitigation L- 1 L – 1 L - 2 L/M - 2 L – 8

6.3.1.1.1 Mitigations and recommendation to soil pollution  Contamination control measures should be put in place to manage soil pollution.

 The Project Environmental Officer or Proponent should ensure that a sufficient number of drip trays are available on-site and that these are utilised in the event of leakage from vehicles.  Contaminated soils that may have resulted from leakage/spillage from exploration bakkies should be removed to a depth dependent on the size of the spill

 The contaminated soils should completely be removed and treated or disposed off in accordance to municipal wastewater discharge standards thereafter replaced with clean soil.  Drip trays must be used when exploration bakkies are idle to contain any potential spillages. This measure is to prevent pollutants from reaching to surrounding soils.

 The proponent should appoint an Environmental officer to monitor soil contamination on site on a weekly basis.

Soil disturbance would most likely come from creation of access roads and setting up of temporary camps as assessed below.

Table 6-11: Assessment of the impacts of field evaluation on soil disturbance Extent Duration Intensity Probability Significance Pre-mitigation L-/M - 2 M - 3 M/L – 4 L/M - 2 L - 18 Post-mitigation L - 1 L/M - 2 L - 2 L/M - 2 L - 10

6.3.1.1.2 Mitigations and recommendation to soil disturbance  Topsoil should be removed and stockpiled for putting back during restoration and reclamation works to help minimise erosion and run-off on the smooth surfaces.

 Use of existing roads as much as possible and restrict vehicles to only use created access roads to prevent further disturbance

6.3.1.2 Impact on biodiversity and habitat destruction About 80% of the project footprint is open space i.e. no vegetation. There is few vegetation on the project site and it is quite scattered. The removal of vegetation for creating access routes and setting up a campsite might not be necessary, which reduces the significance of impact. Table 6-12: Assessment of the impacts of field evaluation on biodiversity (flora) Extent Duration Intensity Probability Significance Pre-mitigation L/M - 2 M - 3 M/L – 4 M - 3 L - 18 Post-mitigation L - 1 L/M - 2 L - 2 L/M - 2 L - 10

6.3.1.2.1 Mitigations and recommendation to biodiversity (flora)  The exploration camp should be set up in an open space that will not require removal of vegetation.

 Existing roads must be utilised as much as possible to avoid creating new ones where possible.

 Minimize driving especially to access outcrops. The mapping team must access these by walking to reduce the extent of impact.

 New access routes must go around the sparse vegetation in order to preserve it. Work together with the National Botanical Gardens (NBG) in plant rescue and relocation.

 Stockpiling of the top soils will create a seed bank which helps to restore the environment during reclamation.

In terms of animals, the movement of exploration team in the area might temporarily drive away animals. Another impact could result from the incoming of people who might take advantage of their access to the project area to hunt wild animals. Fatalities of fauna may occur from collision with vehicles and earth moving equipment.

Table 6-13: Assessment of the impacts of field evaluation on biodiversity (fauna) Extent Duration Intensity Probability Significance Pre-mitigation L-/M - 2 L - 1 M/L - 4 L/M - 2 L - 14 Post-mitigation L- 1 L - 1 L - 2 L/M - 2 L - 8

6.3.1.2.2 Mitigations and recommendation to biodiversity (fauna)  Minimize driving especially to access outcrops. The mapping team must access these by walking to reduce the potential of driving away animals.

 Discourage indiscriminate killing of perceived dangerous species (e.g. snakes and scorpions)

 Remove and relocate perceived dangerous species (e.g. snakes) to similar undisturbed habitats in the general area.

 A speed limit of 60km/h for light vehicles and 30km/h for heavy vehicles must be maintained onsite to prevent fatalities of fauna that may manifest from collisions with vehicles and earth moving equipment

 The Proponent should implement a severe penalty system for any worker who will be found hunting wild animals in the area.

 Local people should be employed to prevent poaching as the locals will be inclined to protecting their wildlife.

6.3.1.3 Impact on water resources Spills of petrochemicals from exploration vehicles have the potential to contaminate surface water bodies or seep into the ground and contaminate groundwater. The assessment of this impact is presented in Table 6-14: Assessment of the impacts of field evaluation on water quality Extent Duration Intensity Probability Significance Pre-mitigation L-/M - 2 L - 1 L - 4 L/M - 2 L - 14 Post-mitigation L-/M - 2 L - 1 L - 2 L - 1 L - 5

6.3.1.3.1 Mitigations and recommendation to water pollution  The Project Environmental Officer or Proponent should ensure that a sufficient number of drip trays are available to be utilised in an event of leakage from vehicles. Drip trays must be used when exploration bakkies are idle

 Contaminated soils that may have resulted from leakage/spillage from exploration bakkies should be removed to a depth dependent on the size of the spill to prevent pollutants from leaching into the ground to contaminate groundwater.  Spillages must be completely be removed and treated or disposed off in accordance to municipal wastewater discharge standards.

6.3.1.4 Impact on air quality The current possible source of air pollution at this stage would be the dust and fumes generated by exploration vehicles. However, this impact is of low significance due to the fact that the impact will be temporary i.e. impacts lasts only for a few weeks of field assessment. The assessment of this impact is presented in

Table 6-15: Assessment of the impacts of field assessment on air quality Extent Duration Intensity Probability Significance Pre-mitigation L-/M - 2 L-/M - 2 M /L - 4 L/M - 2 L - 16 Post-mitigation L - 1 L - 1 L - 2 L/M - 2 L - 8

6.3.1.4.1 Mitigations and recommendation to air pollution  Dust generation should be kept at an acceptable level, by using existing roads and avoiding driving where possible.  A speed limit of 60km/h for exploration vehicles must be maintained onsite to minimise the dust generated by vehicles  Exploration vehicles must not be left idling on site when not in use, to minimize gas emissions.  The Proponent must ensure that the exploration vehicles are properly serviced so that they do not give off harmful gases.  The proponent should appoint an Environmental officer to monitor dust and gas on site on a weekly basis during this phase.

6.3.2 Detailed exploration 6.3.2.1 Impact on soils At this stage the potential sources of hydrocarbon spills will include vehicles (bakkies), water trucks, as well as the drill rig.

Table 6-16: Assessment of the impacts of field evaluation on soil pollution Extent Duration Intensity Probability Significance Pre-mitigation L-/M - 2 L/M - 2 M/L - 4 L/M - 2 L - 16 Post-mitigation L- 1 L/M - 2 L - 2 L/M - 2 L - 10

6.3.2.1.1 Mitigations and recommendation to soil pollution  Contamination control measures should be put in place to manage soil pollution.  The Project Environmental Officer or Proponent should ensure that a sufficient number of drip trays are available on-site and must be used at all times when vehicles, trucks are idle as well as under the diesel trailer to contain any potential spillages.

 Contaminated soils that may have resulted from leakage/spillage from vehicles or machinery should be removed to a depth dependent on the size of the spill  The contaminated soils should completely be removed and treated or disposed off in accordance to municipal wastewater discharge standards thereafter replaced with clean soil.  The trailer with a diesel tank must have designated parking on site, which must be lined ground to prevent pollutants from reaching the soil.  Chemical used for drilling activities (in the drilling mud) should be non-hazardous and biodegradable.  The proponent should appoint an Environmental officer to monitor soil contamination on site on a weekly basis.

In terms of soil disturbance, not much will be done at this stage as the access roads created during field assessment will be used, and the temporary camps will already be. However, where necessary, roads will be expanded with high consideration of the environment.

Table 6-17: Assessment of the impacts of field evaluation on soil disturbance Extent Duration Intensity Probability Significance Pre-mitigation L/M - 2 L/M - 2 M/L – 4 L/M - 2 L - 16 Post-mitigation L - 1 L/M - 2 L - 2 L/M - 2 L - 10

6.3.2.1.2 Mitigations and recommendation to soil disturbance  Existing campsite should be used to avoid erecting temporary infrastructure in a different place.  Existing roads must be utilised as much as possible to avoid creating new ones where possible.  Where necessary, roads must be expanded with highest consideration of the environment.

6.3.2.2 Impact on biodiversity and habitat destruction The removal of vegetation will be minimal at this stage as the access roads created during field assessment will be used, and the temporary camps will already be setup. Where expansion of access roads will be necessary, care will be taken for maximum preservation of plant species. Table 6-18: Assessment of the impacts of field evaluation on biodiversity (flora) Extent Duration Intensity Probability Significance Pre-mitigation L/M - 2 L/M - 2 M/L – 4 M - 3 L - 24 Post-mitigation L - 1 L/M - 2 L - 2 L/M - 2 L - 10

6.3.2.2.1 Mitigations and recommendation to biodiversity (flora)

 Existing campsite should be used to avoid erecting temporary infrastructure in a different place.  Existing roads must be utilised as much as possible to avoid creating new ones where possible.  Where necessary, roads must be expanded with highest consideration of the environment.

 Stockpiling of the topsoils will create a seed bank which helps to restore the environment during reclamation.  Where possible, plants must be carefully removed and transplanted. Work together with the National Botanical Gardens (NBG) in plant rescue and relocation.

In terms of animals, movement of vehicles around the project area will now be narrowed down to a localised site where drilling equipment will be set up. Animals will have the freedom to roam around in other areas of the project that are excluded from drilling. Therefore, this brings down the spatial extend of impact, thereby reducing the impact significance as assessed in table. Probability remains high as there will now be more vehicles which increases chances of collision.

Table 6-19: Assessment of the impacts of field evaluation on biodiversity (fauna) Extent Duration Intensity Probability Significance Pre-mitigation L/M - 2 L/M - 2 M/L – 4 M - 3 L - 24 Post-mitigation L - 1 L/M - 2 L - 2 M - 3 L - 15

6.3.2.2.2 Mitigations and recommendation to biodiversity (fauna)  Minimize driving especially to access areas that are excluded from drilling to reduce the potential of driving away animals.  Existing roads must be utilised as much as possible to avoid creating new ones where possible.  Discourage indiscriminate killing of perceived dangerous species (e.g. snakes and skorpions)  Remove and relocate perceived dangerous species (e.g. snakes) to similar undisturbed habitats in the general area.  A speed limit of 60km/h for exploration vehicles must be maintained onsite to prevent fatalities of fauna that may manifest from collisions with vehicles and earth moving equipment  The Proponent should implement a severe penalty system for any worker who will be found hunting wild animals in the area.  Local people should be employed to prevent poaching as the locals will be inclined to protecting their wildlife.

6.3.2.3 Impact on water resources Spills of hydrocarbons from vehicles (bakkies), water trucks, the drill rig have the potential to contaminate surface water bodies or seep into the ground and contaminate groundwater. Table 6-20: Assessment of the impacts of field evaluation on water quality Extent Duration Intensity Probability Significance Pre-mitigation L-/M - 2 L-/M - 2 M - 6 M - 3 L - 30 Post-mitigation L - 1 L-/M - 2 L - 4 L/M - 2 L - 10

6.3.2.3.1 Mitigations and recommendation to water pollution  The Project Environmental Officer or Proponent should ensure that a sufficient number of drip trays are available on-site and must be used at all times when vehicles, trucks are idle as well as under the diesel trailer to contain any potential spillages.  Contaminated soils that may have resulted from leakage/spillage from vehicles or machinery should be removed to a depth dependent on the size of the spill to prevent pollutants from leaching into the ground to contaminate groundwater.  The contaminated soils should completely be removed and treated or disposed off in accordance to municipal wastewater discharge standards thereafter replaced with clean soil.  The trailer with a diesel tank must have designated parking on site, which must be lined ground to prevent pollutants from leaching into the ground and potentially contaminating groundwater.  Spillages must be completely be removed and treated or disposed off in accordance to municipal wastewater discharge standards.  Personnel must use the toilet facilities provided onsite to prevent potential contamination of water resources.

6.3.2.4 Impact on air quality T The possible source of air pollution at this stage would be the dust and fumes generated by general vehicles and trucks, diesel powered machinery, as well as minor drilling dust.

Table 6-21: Assessment of the impacts of field assessment on air quality Extent Duration Intensity Probability Significance Pre-mitigation M - 3 L-/M - 2 M - 6 L/M - 2 L - 22 Post-mitigation L - 2 L-/M - 2 L - 4 L/M - 2 L - 16

6.3.2.4.1 Mitigations and recommendation to air pollution  Dust generation should be kept at an acceptable level, by using existing roads and avoiding driving where possible.  Water must be used during drilling to suppress the dust generated.  Dust collectors must be used to catch the dust created from drilling  A speed limit of 60km/h for light vehicles and 30km/h for heavy vehicles must be maintained onsite to minimise the dust generated by vehicles

 Exploration vehicles and trucks must not be left idling on site when not in use, to minimize gas emissions.  The Proponent must ensure that all vehicles are properly serviced so that they do not give off harmful gases.  Drill equipment should be regularly maintained to ensure drilling efficiency and so reduce dust generation.

6.3.2.5 Impact of Noise The noise produced by the drill rig and diesel generator may be a nuisance to the employees and the neighbouring locals.

Table 6-22: Assessment of the noise impact from the detailed exploration activities Extent Duration Intensity Probability Significance Pre-mitigation L - 1 L - 1 M/L - 4 L/M - 2 L - 12 Post-mitigation L - 1 L - 1 L - 2 L/M - 2 L - 8

6.3.2.5.1 Mitigations and recommendation to noise  Noise from general vehicles and equipment should be reduced to an acceptable level.  Noisy equipment such as drill rigs should be shut down when they are not in use (when not needed) to avoid unnecessary noise on site.  Workers performing noisy tasks should be rotated regularly (work on shifts) to avoid exposing them to excessive noise for a long period of time in a day.  Workers should be equipped with personal protective equipment (PPE) such as earplugs to reduce noise exposure.  Vehicles and machinery must be well serviced and lubricated to reduce noise  In order to limit the noise from drilling equipment and the movement of vehicles, exploration works should be limited to or only be done between 08h00 and 17h00.

6.3.2.6 Impact on traffic Impact on traffic safety when the drill rigs are brought to the area, which can result in slow moving traffic. Additionally, the weekly delivery of water tankers by water trucks from Swakopmund or Karibib can cause an increase in traffic. However, these will not go on for extended periods and will as such reduce the duration of impact. Table 6-23: Assessment of the impacts of the detailed exploration on traffic (vehicular) safety Extent Duration Intensity Probability Significance Pre-mitigation L/M - 2 L - 1 M/L - 4 L/M - 2 L - 14 Post-mitigation L/M - 2 L - 1 L - 2 L/M - 2 L - 10

6.3.2.6.1 Mitigations and recommendation to traffic safety  Trucks delivering water to the exploration site must have a scheduled time for travelling to and from site so that they do not interfere with daily traffic in the area  Abnormal vehicles carrying drilling equipment must be well signaged to caution other drivers.

 All drivers of the project vehicles should be in possession of valid and appropriate driving licenses to operate such vehicles.  Project vehicles should be in a road worthy condition and serviced regularly in order to avoid accidents as a result of mechanical faults of vehicles  Best Cheer should operate within the Roads Act and be subjected to weigh bridges and necessary fees for road maintenance

6.3.2.7 Impact on health and safety The general safety of workers onsite must be emphasized to comply with the Public Health Act (Act no. 36 of 1919) as well as the Labour Act. Therefore, handling of equipment and use of machinery onsite must not compromise the health and safety of employees. Table 6-24: Assessment of the impacts of the detailed exploration on health and safety Extent Duration Intensity Probability Significance Pre-mitigation L - 1 L - 1 M/H - 8 L/M - 2 L - 20 Post-mitigation L - 1 L - 1 L - 2 L/M - 2 L - 8

6.3.2.7.1 Mitigations and recommendation for health and safety  Workers must be equipped with personal protective equipment PPE such as coveralls, gloves, safety boots, safety glasses and hard hats at all times at all times on work sites.  Workers must be provided with sufficient training on how to handle different machinery and equipment. personnel should be trained in/sensitised to the potential health and safety risks associated with their respective jobs  Workers must only operate within their designated areas and only operate machinery they have been trained to use  No workers should be allowed to drink alcohol during working hours.  No workers should be allowed on site if under the influence of alcohol.  General vehicles should have designated parking, well away from the rigs.  Drilled holes that are no longer be in use or will not be used later should be properly marked for visibility and capped/closed off.  Employees should be sourced locally, to avoid transmission of infectious diseases.  An emergency preparedness plan should be compiled and all personnel appropriately trained.  Equip site with firefighting equipment (such as fire extinguishers) so that they are readily available for use in case of a fire.

6.3.3 Feasibility stage 6.3.3.1 Impact on soils At this stage the potential sources of soil contamination include petrochemical spills from vehicles (bakkies), water trucks, the drill rig, diesel operated generator as well as the trailer mounted diesel tank for fuel storage. The use of diamond wire cutting to obtain bulk samples has reduced the use of explosives in obtaining the blocks, which reduces the potential contamination of soils.

Table 6-25: Assessment of the impacts of field evaluation on soil pollution Extent Duration Intensity Probability Significance Pre-mitigation L/M - 2 L/M - 2 M – 6 M - 3 L - 30 Post-mitigation L - 1 L/M - 2 L - 2 M - 3 L - 15

6.3.3.1.1 Mitigations and recommendation to soil pollution  Contamination control measures should be put in place to manage soil pollution.  The Project Environmental Officer or Proponent should ensure that a sufficient number of drip trays are available on-site and must be used at all times when vehicles, trucks are idle as well as under the diesel trailer to contain any potential spillages.  Contaminated soils that may have resulted from leakage/spillage from vehicles or machinery should be removed to a depth dependent on the size of the spill  The contaminated soils should completely be removed and treated or disposed off in accordance to municipal wastewater discharge standards thereafter replaced with clean soil.  The trailer with a diesel tank must have designated parking on site, which must be lined ground to prevent pollutants from reaching the soil.  The proponent should appoint an Environmental officer to monitor soil contamination on site on a weekly basis.

In terms of soil disturbance, not much will be done at this stage as the access roads created during field assessment will be used, and the temporary camps will already be set up. However, a new source of disturbance would be the scrapping of overburden to expose rocks for drilling and cutting. However, this will only be done in selected areas and the impact of this is likely to be small as the rocks in the area are generally exposed with little to no soil cover. Therefore the impact will be over a limited area.

Table 6-26: Assessment of the impacts of field evaluation on soil disturbance Extent Duration Intensity Probability Significance Pre-mitigation L/M - 2 L/M - 2 M/L – 4 M/L - 4 M - 32 Post-mitigation L - 1 L/M - 2 L - 2 L/M - 2 L - 10

6.3.3.1.2 Mitigations and recommendation to soil disturbance  Existing campsite should be used to avoid erecting temporary infrastructure in a different place.  Existing roads must be utilised as much as possible to avoid creating new ones where possible.  Rehabilitation of openings create by removal of blocks, should the project not be feasible such that there is no need to apply for a mining licence.  Stockpile the topsoils to have a seedbank for reclamation works

6.3.3.2 Impact on biodiversity and habitat destruction The removal of vegetation will be minimal at this stage as the access roads created during field assessment will be used, and the temporary camps will already be setup. However, the scrapping of overburden to expose rocks for drilling and cutting might result in habitat disturbance. However this will have minimal impact because most of the targeted rocks are already exposed or outcropping. Table 6-27: Assessment of the impacts of field evaluation on biodiversity (flora) Extent Duration Intensity Probability Significance Pre-mitigation L/M - 2 L/M - 2 M - 6 M/H - 4 M - 40 Post-mitigation L - 1 L/M - 2 M/L - 4 M - 3 L - 21

6.3.3.2.1 Mitigations and recommendation to biodiversity (flora)  Existing campsite should be used to avoid erecting temporary infrastructure in a different place.  Existing roads must be utilised as much as possible to avoid creating new ones where possible. Where necessary, roads must be expanded with highest consideration of the environment.  Where possible, plants must be carefully removed and transplanted. Work together with the National Botanical Gardens (NBG) in plant rescue and relocation.  Harvesting of seeds for replanting during reclamation  Stockpile the topsoils to have a seedbank for reclamation works

In terms of animals, movement of vehicles around the project area will now be narrowed down to a localised site where drilling and cutting will be taking place. Animals will have the freedom to roam around in other areas of the project that are excluded from test mining. Therefore, this brings down the spatial extend of impact, thereby reducing the impact significance. For small mammals and reptiles that might be living on the areas selected for cutting out blocks, their habitat might be disturbed. However, this will be a limited area.

Table 6-28: Assessment of the impacts of field evaluation on biodiversity (fauna) Extent Duration Intensity Probability Significance Pre-mitigation M - 3 L/M - 2 M – 6 M - 3 M - 33 Post-mitigation M - 3 L/M - 2 M/L - 4 M - 3 L - 21

6.3.3.2.2 Mitigations and recommendation to biodiversity (fauna)  Minimize driving especially to access areas that were excluded from drilling to reduce the potential of driving away animals.  Existing roads must be utilised as much as possible to avoid creating new ones where possible.  Discourage indiscriminate killing of perceived dangerous species (e.g. snakes and scorpions)

 Remove and relocate perceived dangerous species (e.g. snakes) to similar undisturbed habitats in the general area.  The Proponent should implement a severe penalty system for any worker who will be found hunting wild animals in the area.  Worked out areas must be demarcated and fenced off to keep animals out until they can be rehabilitated  A speed limit of 60km/h for light vehicles and 30km/h for heavy must be maintained onsite to prevent fatalities of fauna that may manifest from collisions with vehicles and earth moving equipment

6.3.3.3 Impact on water resources The potential impact relating to water that would be a concern is the possible lowering of the groundwater table as a result of abstraction. However, the exploration activities will not use water from boreholes in the area. Water tankers will be brought to site on a weekly basis, therefore no pressure on the local water resources. Unlike in the metal extraction industry, the mining and refining process of dimension stones does not require addition of chemicals in to concentrate and extract from an ore, neither does it output chemicals. The product is rather left in its inert state. Therefore, this reduces the potential of polluting or contaminating groundwater. Additionally, the use of diamond wire cutting has reduced the use of explosives in obtaining the blocks, which reduces the potential contamination of water. For this reason it can be said that the potential sources of pollution in this case can be spills of petrochemicals from vehicles (bakkies), water trucks, the drill rig as well as the trailer mounted diesel tank for fuel storage. Table 6-29: Assessment of the impacts of field evaluation on water quality Extent Duration Intensity Probability Significance Pre-mitigation M - 3 L-/M - 2 M - 6 M - 3 M - 33 Post-mitigation L-/M - 2 L-/M - 2 L - 4 L/M - 2 L - 16

6.3.3.3.1 Mitigations and recommendation to water pollution  The Project Environmental Officer or Proponent should ensure that a sufficient number of drip trays are available on-site and must be used at all times when vehicles, trucks are idle as well as under the diesel trailer to contain any potential spillages.  Contaminated soils that may have resulted from leakage/spillage from vehicles or machinery should be removed to a depth dependent on the size of the spill to prevent pollutants from leaching into the ground to contaminate groundwater.  The contaminated soils should completely be removed and treated or disposed off in accordance to municipal wastewater discharge standards thereafter replaced with clean soil.

 The trailer with a diesel tank must have designated parking on site, which must be lined ground to prevent pollutants from leaching into the ground and potentially contaminating groundwater.  Spillages must be completely be removed and treated or disposed off in accordance to municipal wastewater discharge standards.  The use of diamond wire cutting in obtaining the blocks, to reduce the use of explosives which reduces the potential contamination of water  Personnel must use the toilet facilities provided onsite to prevent potential contamination of water resources.

6.3.3.4 Impact on air quality The possible source of air pollution at this stage would be the dust and fumes generated by general vehicles and trucks, diesel powered machinery, as well as dust from drilling and cutting. The assessment of this impact is presented in

Table 6-30: Assessment of the impacts of field assessment on air quality Extent Duration Intensity Probability Significance Pre-mitigation M - 3 L-/M - 2 M /H - 8 M/H - 4 M - 52 Post-mitigation L - 2 L-/M - 2 L - 4 L/M - 2 L - 16

6.3.3.4.1 Mitigations and recommendation to air pollution  Dust generation should be kept at an acceptable level, by using existing roads and avoiding driving where possible.  Water must be used during drilling to suppress the dust generated.  Dust collectors or buckets must be used to capture some of the dust generated by cutting and drilling  Exploration vehicles and trucks must not be left idling on site when not in use, to minimize gas emissions.  The Proponent must ensure that all vehicles are properly serviced so that they do not give off harmful gases.  Drill equipment should be regularly maintained to ensure drilling efficiency and so reduce dust generation.  The proponent should appoint an Environmental officer to monitor dust and gas on site on a weekly basis during this phase.  A speed limit of 60km/h for light vehicles and 30km/h for heavy vehicles must be maintained onsite to minimise the dust generated by vehicles

6.3.3.5 Impact of Noise The possible sources of noise include the drill rig, the diamond wire cutter and diesel generator, which may be a nuisance to the employees, the neighbouring locals and animals. Table 6-31: Assessment of the noise impact from the detailed exploration activities

Extent Duration Intensity Probability Significance Pre-mitigation L /M - 2 L - 1 M/L - 4 L/M - 2 L - 14 Post-mitigation L /M - 2 L - 1 L - 2 L/M - 2 L - 10

6.3.3.5.1 Mitigations and recommendation to noise  Noise from general vehicles and equipment should be reduced to an acceptable level.  Noisy equipment such as drill rigs should be shut down when they are not in use (when not needed) to avoid unnecessary noise on site.  Workers performing noisy tasks should be rotated regularly (work on shifts) to avoid exposing them to excessive noise for a long period of time in a day.  Workers should be equipped with personal protective equipment (PPE) such as earplugs to reduce noise exposure.  Vehicles and machinery must be well serviced and lubricated to reduce noise  In order to limit the noise from vehicles, drilling and cutting equipment as well as the movement of vehicles, test mining works should be limited to or only be done between 08h00 and 17h00.

6.3.3.6 Impact on traffic Impact on traffic safety includes having heavy trucks on the road for drill rigs as well as for transporting mined blocks from site to the factories for testing. This can result in slow moving traffic. Additionally, the weekly delivery of water tankers by water trucks from Swakopmund or Karibib can cause an increase in traffic. However, these will not go on for extended periods and will as such reduce the duration of impact. Table 6-32: Assessment of the impacts of the detailed exploration on traffic (vehicular) safety Extent Duration Intensity Probability Significance Pre-mitigation M - 3 L - 1 M/L - 4 L/M - 2 L - 16 Post-mitigation M - 3 L - 1 L - 2 L/M - 2 L - 12

6.3.3.6.1 Mitigations and recommendation to traffic safety  Trucks delivering water to the exploration site must have a scheduled time for travelling to and from site so that they do not interfere with daily traffic in the area  Abnormal vehicles carrying drilling equipment or granite blocks must be well signaged to caution other drivers.  All drivers of the project vehicles should be in possession of valid and appropriate driving licenses to operate such vehicles.  Project vehicles should be in a road worthy condition and serviced regularly in order to avoid accidents as a result of mechanical faults of vehicles  Best Cheer should operate within the Roads Act and be subjected to weigh bridges and necessary fees for road maintenance

6.3.3.7 Impact on health and safety The general safety of workers onsite must be emphasized to comply with the Public Health Act (Act no. 36 of 1919) as well as the Labour Act. Therefore handling of equipment and use of machinery onsite must not compromise the health and safety of employees. Another health hazard could be transmission of diseases including HIV/AIDS, however this would only be a concern if there was an influx of workers from elsewhere. This is reduced by the fact that local people will be prioritized for employment. Table 6-33: Assessment of the impacts of the detailed exploration on health and safety Extent Duration Intensity Probability Significance Pre-mitigation L/M - 2 L - 1 M/H - 8 L/M - 2 L - 22 Post-mitigation L/M - 2 L - 1 L - 2 L/M - 2 L - 10

6.3.3.7.1 Mitigations and recommendation on health and safety  Workers must be equipped with personal protective equipment PPE such as coveralls, gloves, safety boots, safety glasses and hard hats at all times at all times on work sites.  Workers must be provided with sufficient training on how to handle different machinery and equipment.  Workers must only operate within their designated areas and only operate machinery they have been trained to use  No workers should be allowed to drink alcohol during working hours.  No workers should be allowed on site if under the influence of alcohol.  General vehicles should have designated parking, well away from the rigs  Employees should be sourced locally, to avoid transmission of infectious diseases.  An emergency preparedness plan should be compiled and all personnel appropriately trained.  Equip site with firefighting equipment (such as fire extinguishers) so that they are readily available for use in case of a fire.  Worked out areas must be demarcated and fenced off to keep people out until they can be rehabilitated  All employees must be aware of the assembly point in case of emergency.  Fires and cooking places must be well away from the diesel storage trailers.

6.3.3.8 Visual Impact Since the targeted rock mass stands out due to its high relief, the proposed project is anticipated to potentially cause visual impact on the landscape, which takes away from the sense of the place and could potentially affect tourism. This is because scars of test mining working areas may be visible from long distances. However, this will only be the case if land reclamation and restoration is not properly executed. Additionally, this will only be restricted to the period of test mining, and unlike actual mining, it will only aim for certain parts of the targeted outcrops, therefore the spatial extent of impact will be low.

Table 6-34: Assessment of visual impact during feasibility stage Extent Duration Intensity Probability Significance Pre-mitigation L-/M - 2 M/H - 4 M/L - 4 M/H - 4 M - 40 Post-mitigation L - 1 L-/M - 2 L - 2 M/L - 2 L - 10

6.3.3.8.1 Mitigations and recommendation to visual impact  Rehabilitation by backfilling of openings create by removal of blocks, should the project not be feasible such that there is no need to apply for a mining licence.  Rock shading to temporarily reduce visual impact before rehabilitation

6.3.3.9 Impact on Archaeology Destruction of archaeological sites might occur during excavation and test mining as these are intrusive techniques of exploration. However, the likelihood or probability of this happening has been reduced as the area that has high potential for archaeology has been demarcated for permanent exclusion from exploration activities, or until such a time that the area has been satisfactorily surveyed (Kinahan, 2020). The desk archaeological assessment study conducted by Dr Kinahan delineated a temporary exclusion area (No-Go Area) within EPL5161 to provide for conservation of archaeological/heritage resources. Therefore, it can be said that prior to mitigation, the impact is medium, however it can be reduced significantly once mitigation measures are implemented, and the exclusion is respected.

Table 6-35: Assessment of archaeological impact during feasibility stage Extent Duration Intensity Probability Significance Pre-mitigation L - 1 H - 5 M/H - 8 M/H - 4 M - 56 Post-mitigation L - 1 L - 1 L - 2 L - 1 L - 4

6.3.3.9.1 Mitigations and recommendation to archaeological  Personnel should be informed not to destroy, damage, remove or throw away any unknown objects found/discovered on site during operations,  If any archaeological materials are found, the National Heritage Council’s Chance Find Procedures (presented in the EMP) should be followed. Furthermore, the worksite manager should be notified, and all on-site activities stopped immediately, upon which the NHC is contacted for further instructions and actions.  The proponent must have the layout of access tracks (roads), field camps and other related infrastructure submitted to the NHC to verify the possible presence of archaeological objects or sites near these infrastructures.

6.3.4 Cumulative Impacts Cumulative impacts are defined as “those that result from the successive, incremental, and/or combined effects of an action, project, or activity (collectively referred to in this document as “developments”) when added to other existing, planned, and/or reasonably anticipated future ones” (International Finance Corporation, 2013).

One cumulative impact to which can result from the proposed project is the impact on air quality from gases and dust generated during the different stages of exploration. These contribute to the general gas and dust emissions from other sources in the region. The proposed exploration activity also contributes cumulatively to various activities such as noise and traffic. The contribution of the proposed project to these cumulative impacts is however not considered significant given that mineral exploration activities will take place on a small area (spatial scale) and it will go on for a short period (duration).

7 CONCLUSIONS AND RECOMMENDATIONS

The aim of this environmental scoping assessment was to identify the potential impacts associated with the proposed exploration activities on the EPL 5161, assess and recommend practical mitigation measures. The public was consulted as required by the EMA and its 2012 EIA Regulations (Section 21 to 24). The public was informed via the three newspapers used for this assessment; site/public notices placed in the project site area, relevant local and regional offices notice boards. For consultation meetings, the public meeting was held in person for the local community and a virtual meeting for the national authorities. The interested and affected parties raised their comments and concerns on the proposed project activities, which formed the basis for this report as well as the EMP.

This environmental scoping assessment permitted for key potential impacts related to the proposed exploration project to be identified and assessed. All impacts had a medium to relatively low rating and suitable mitigation measures (where required and possible) were recommended to minimise them further. Based on the findings of this impact assessment the impacts identified can be summarised as follows:

 Impact on biodiversity and habitat destruction – could potentially result from the removal of vegetation to create access roads and erect temporary exploration camps onsite during field evaluation. The scrapping of overburden to expose rocks for drilling and cutting might result in habitat disturbance.

 Impact on surface and groundwater resources – it was established that there is no surface water in the area as it seldom receives rainfall, and communities rely on groundwater. Therefore, to avoid putting pressure on this resource, the project will source water offsite and transport it in water tankers on a weekly basis. This takes away possible lowering of the groundwater table as a result of abstraction. In terms of water quality, potential sources of pollution can be spills of petrochemicals from vehicles (bakkies), water trucks, the drill rig as well as the trailer mounted diesel tank for fuel storage.

 Impact on archaeology - Destruction of archaeological sites might occur during the implementation of the project, especially when intrusive exploration techniques are employed. However, the likelihood or probability of this happening has been reduced as the area that has high potential for archaeology has been demarcated for permanent exclusion from exploration activities, or until such a time that the area has been satisfactorily surveyed.

 Impacts the health and safety of workers – from the handling of equipment and use of machinery as well as potentially contracting diseases.

All these impacts can be adequately addressed by the recommendations given under subchapter 6.3 together with management actions given in the EMP (Appendix H). Some positive impacts were also identified, which include creation of temporary employment, skills transfer, training and certification of local communities which results in community empowerment.

Based on the findings of this assessment and on the information provided in this report, OMAVI Geotechnical & Geo-Environmental Consultants CC therefore recommends that an Environmental Clearance Certificate be issued for the proposed exploration works on EPL 5161, subject to the following recommendations:

 All required permits, licenses and approvals for the proposed activities should be obtained as required. These include permits and licenses for exploration activities, onsite fuel storage, land/farm access agreements, etc. as well as ensuring compliance with these specific legal requirements. (please refer to the Permitting and Licensing Table in the Environmental Management Plan (Appendix H).

 The Proponent complies with the legal requirements governing this type of project and its associated activities.

 All mitigations provided in this ESA Report and the management action plans in the EMP should be implemented and monitoring conducted as recommended.

 All the necessary environmental and social (occupational health and safety) precautions provided should be adhered to.

 Site areas where exploration and mining activities have ceased should be rehabilitated, as far as practicable, to their original state.

 The monitoring of the implementation of mitigation measures should be conducted, applicable impact’s actions taken, reporting done and recorded as recommended in the Draft EMP.

Omavi is confident that the identified impacts associated with the proposed exploration project can be reduced to acceptable levels by implementation of the measures recommended in the EMP. It is therefore recommended that the project receives Environmental Clearance, provided that the EMP be implemented.

8 REFERENCES

• Africa Planning Forum. (2019). Environmental Scoping Report: Construction and Operation of Arandis Data Center, Arandis Erongo Region. Windhoek: Ministry of Environment, Forestry and Tourism. Retrieved from http://eia.met.gov.na/screening/30_Final%20EMP%20Arandis%20Data%20Cent er.pdf • BGR. (2005). Investigation of Groundwater Resources and Airborne- Geophysical Investigation of Selected Mineral Targets in Namibia: Groundwater Investigations in the Eastern Caprivi Region. Windhoek and Hannover: BGR. • Burke, A. (2008). The vegetation of the Spitzkoppe area–2115CC. Dinteria, 30, 93-131. • Christelis, G. & Struckmeier, W., 2001. Groundwater in Namibia: an explanation to the Hydrogeological Map. Windhoek: John Meinert Printing. • GCS Water & Environmental Consultants. (2017). National Environmental Assessment for the MTC Namibia 100% Population Coverage Project: Landscape Specialist Report. Windhoek: MTC Namibia. • Hoadley, M. 2009. Socio-Economic Component of the Social and Environmental Impact Assessment Report for the Rio Tinto Rössing Uranium Limited Mine Expansion Project, Socio-Economic Baseline Study • International Finance Corporation, 2013. Good Practice Handbook: Cumulative Impact Assessment and Management. Washington: International Finance Corporation. • Kinahan, J. (2020). Archaeological Assessment of proposed mining claims 71609-71617 located on Farms Sukses and Hakskeen and Area of Interest on farm Trekkopje within EPL 5161 in the Erongo Region, Namibia: A Specialist Report. Windhoek: Unpublished. • Limpitlaw, D. and Hoadley, M. 2009. Trekkopje Uranium Project Environmental and Social Impact Assessment. For AREVA Resources Namibia Ltd. • Mendelsohn, J., Jarvis, A., Roberts, C., & Robertson, T. (2002). Atlas of Namibia. A portrait of the land and its people. Ministry of Environment and Tourism. • Miller R.G. (1983a). The Pan-African Damara Orogen of South West Africa/Namibia, 431-515. • Miller R.G. (2008). The Geology of Namibia. Geological Survey of Namibia, Windhoek. • MME (2010). Strategic Environmental Assessment for the central Namib Uranium Rush. Ministry of Mines and Energy, Windhoek, Republic of Namibia.

Page 69 • Namibia Statistics Agency, 2014. Namibia 2011 Population & Housing Census Main Report, s.l.: Republic of Namibia. • Shagama F. (2020). Groundwater study for proposed exploration and mining of dimension stone on EPL 5161, Erongo Region, Namibia • Speiser, A. and Mulder, S. 2012. Scoping Report for the proposed Arandis Thermal Power Generation and Waste Oil Recycling Plants • World Weather Online. (2020). Arandis - Erongo Region, Namibia Weather. Retrieved June 18, 2020, from World Weather Online: https://www.worldweatheronline.com/arandis-weather- averages/erongo/na.aspx

9 AUTHORIZATION

L. Uulenga 04/06/2020 Author Date

Page 70 LIST OF APPENDICES

APPENDIX A: CV OF EAP

APPENDIX B: INTERESTED AND AFFECTED PARTY DATABASE

APPENDIX C: PUBLIC NOTICES

APPENDIX D: AUTHORITY AND PUBLIC MEETING MINUTES

APPENDIX E: PUBLIC MEETING ATTENDANCE REGISTER

APPENDIX F: ISSUES AND RESPONSE TRAIL

APPENDIX G: PROOF OF COMMUNICATION

APPENDIX H: ENVIRONMENTAL MANAGEMENT PLAN (EMP)

APPENDIX I: GROUNDWATER STUDYSPECIALIST REPORT FOR EPL 5161

APPENDIX J: ARCHAEOLOGICAL ASSESSMENT SPECIALIST REPORT OF PROPOSED MINING CLAIMS 71609-71617 LOCATED ON FARMS SUKSES AND HAKSKEEN AND AREA OF INTEREST ON FARM TREKKOPJE WITHIN EPL 5161 IN THE ERONGO REGION

Page 71

APPENDIX A – CV OF ENVIRONMENTAL ASSESSMENT PRACTITIONER (AEP) PERSONAL INFORMATION Full Names: Linda Uulenga Nationality: Namibian Cellphone Number: +264 81 300 3872 Email address: [email protected]

EDUCATION: - Bachelor of Science Honours in Environmental Management, University of South Africa-final year - Bachelor of Technology: Land Management, Polytechnic of Namibia- 2010 - National Diploma in Land Use Planning, Polytechnic of Namibia- 2009 - Matric Endorsement – Diocesan School for Girls (DSG) – 2005

TRAININGS AND CERTIFICATES: - Construction and Building Inspectors’ Programme, HRD Africa- 2015 - Monitoring and Evaluation Programme, PAMI- 2014 - Public Policy Analysis and Management Programme, ESAMI- 2012

3. Development Planner, Ministry of Veterans Affairs, April 2012- April 2016 - Drafting of submission letters regarding farm purchases, construction and renovation of houses for veterans - Assessment of veterans requests for need of housing assistance - House construction, monitoring and inspections for beneficiaries - Inspection of rehabilitation farm for beneficiaries - Assisting with the assessment and procurement of individual veterans projects - Record keeping and updating of constructed houses and resettled farms records

4. Land Use Planning and Allocation Clerk, Ministry of Lands and Resettlement, January 2011- March 2012 - Acceptance and recording of farm offers - Acceptance and recording of objections and complaints - Preparation of letters/submissions for assessment, waivers, exemption certificates - Updating ministerial of farm Master list - Acting as secretary to the Director: Land Reform

5. Programme Analyst, National Planning Commission, May 2010- December 2010 - Lead, guide and train fieldwork team - Responsible for fieldwork team communication and management with office staff - Map reading skills and GPS point reading to identify/ confirm working environment - Download, Capture and Analyze data captured by fieldwork team using Quantum - GIS Publicity work to promote and inform communities about the project

6. Young Professional Trainee, Integrated Environmental Consultants Namibia, February 2010- April 2010 - Ministry of Environment and Tourism (MET) Namibia: Member of National Adaptation Working Group in a United Nations Development Programme (UNDP) funded project on establishing Investment and Financial Flows (I&FF) for the agriculture and Land Use, Land Use Change and Forestry (LULUCF) sectors in Namibia. - Attended the Africa Adaptation Programme (AAP) induction workshop - Assisted with International Union for Conservation of Nature (IUCN) - Commission on Education and Communication vice-chair duties whereby a survey was created for the Western, Central, Southern and Eastern regions

7. Department Assistant, Polytechnic of Namibia, Windhoek, Namibia, January 2009- June 2009 - Providing administrative services - Maintaining the departments filing system - Attending and following up standard requests - Monitoring the department budget, preparing and following up requisitions - Receptionist services - Organization and coordination of meetings - Compiling small reports or other document

8. In-Service Training, Ministry of Lands and Resettlement supported by the German Technical Cooperation (GTZ), Windhoek, Namibia, July 2008- November 2008 - Compiled several short reports on the duties carried during this period, independently - Assisted with the Ministry’s new filing system for the farms - Took part in farm assessment and monitoring field work - Assisted with administrative work at the GTZ offices

9. Gobabeb In-Service Training Junior Researcher, Gobabeb Training and Research Centre, Gobabeb, Namibia, January 2008 – June 2008 - Conducted independent research project on “The Extent and Effects of Local Transportation in Central Namib.” - Supported Center’s long-term ecological research projects through collection of climate, Welwitschia spatial distribution, pitfall trap data

- Organized the coordination of peer research projects - Published articles relating in-service training experience in Regional Newspaper and Gobabeb Newsletter

ADDITIONAL SKILLS: - Technical: Microsoft Office, Handheld GPS, Geo-Information Systems, ArcGIS, ERDAS IMAGINE, Driver’s license - Personal: Effective communication, team-work, interpersonal relationships, multi-tasking and leadership.

LANGUAGES:

REFERENCES: Mr. Sakaria Nalusha Managing Partner Green Team Consultants Tel: +264 85 222 5600 Email: [email protected]

Ms. Kuana Aihuki Deputy Director: Regional Coordination Office of the Vice President: Veterans Affairs Tel: +264 61 296 3039 Email: [email protected]

Mrs. Eloise Carstens Environmental Manager Tel: +64 27 258 9337 Email: [email protected]

APPENDIX B TO G

APPENDIX B –– INTERESTED AND AFFECTED PARTY DATABASE Stakeholders list

Organisation Contact person Department/Position/Affiliation

Omavi Geotechnical & Geo-Environmental

Consultants Linda Uulenga Environmental Assessment Practiotioner

Organisation Contact person Department/Position

Theo Nghithila Executive Director Timoteus Mufeti Environmental Commissioner Deputy Director: Environmental Assessment, Waste Management, Ministry of Environment and Tourism Saima Angula Pollution Control and Inspections Hiskia Mbura Directorate of Environmental Assessment Malakia Ilungu Programme Manager: Communal Land Development Damian Nchindo Directorate of Environmental Assessment Mr. Peter Amutenya Executive Director Ministry of Land Reform Malakia Ilungu Programme Mananger: Communal Land Ministry of Works & Transport Mr. Willem Goeiemann Executive Director

CentralGovernment Ministry of Agriculture, Water & Forestry Mr. Percy Misika Executive Director Mr. Simeon Negumbo Executive Director Ministry of Mines & Energy Erasmus Shivolo Mining Commisioner Ministry of Urban and Rural Development Nghidinua Daniel Executive Director

Organisation Contact person Department/Position/Affiliation

Neville Adre Govenor Ms Ludmilla H Doeses Chief Regional Officer Ms. Surina F. Eichas Private Secreatary to Chief Regional Officer Erongo Regional Council Mr Meroro Deputy Director: Planning

Ms Dimari Van Rensburg Town and Regional Planner Regional GRN Regional

Organisation Contact person Department/Position/Affiliation

Karibib Town Council Mr. Lesley Goreseb CEO Karibib Constituency Office Hon. Melanie Ndjago Karibib Constituency Councillor

Karibib Constituency Office Katrina Shikongo Chief Administration Officer Daures Constituency Office Hon Haoseb Daures Constituency Councillor Daures Constituency Office Essen Haipinge Chief Administration Officer

Usakos Village Council Mr. David Shikoyeni Planner LocalGRN Arandis Town Council Stanley Noris CEO Arandis Constituency Office Mr. S Areseb Chief Administration Officer

Organisation Contact person Department/Position/Affiliation

Mr. Abraham Nehemia CEO

Namwater Nicolaas du Plessis Environmental Manager Johannes K Shigwedha Corporate Communications manager Fillemon Aupokolo Environmentalist Jacky Mukuka Road Network Planning Parastatals Eugene de Paauw Specialist Road Legislation, Advice and Compliance Roads Authority Jacky Mukuka Head: Road Network Planning

Elina Lumbu Head: Road Planning Legal

Organisation Contact person Department/Position/Affiliation

Farm Valencia 122 Jacobus Francois Horn Owner and I&AP

Farm Trekkopje Jefta So/Oabeb Owner and Resident Immanuel Gaseb/ Mr. Honeb/ Farm Trekkopje 120/ !Oe#Gan Traditional Authority !Oe#Gan Traditional Authority Leadership & Farmers Mr Goeseb/ Mr Maletzky National Heritage Council of Namibia Erica Ndakalako Head: Heritage Management Namibia Chamber of Mines Veston Malango CEO IdentifiedI&Aps Botanical Society Venessa Stein Member of staff Karibib Farmers Association Mr Cash van Wyk Chairman Karibib Farmers Association Mrs Doris Gladis Secretary Omaruru Farmers Association Mr Christian Traupe Chairman Omaruru Farmers Association Mrs Karen Schmidt Secretary Organisation Contact person Department/Position/Affiliation

Namib Plains, Farming and Tourism cc (Namib Plaas Dr M M Engelbrecht Farm Owner 93) Farm Valencia 122 Mr Schurz Farm Owner Mr Kobus Smit Farm Owner Nagenoeg Investment Pty Ltd (for Farm Vergenoeg Morne Potgieter Farm Manager 92) Mr Oliver Krappmann Farm Owner Representative Namibia Botanical Gardens CC Frank Löhnert Interested party !Oe#Gan Traditional Authority Mr Goaseb Senior Traditional Authority Councillor

RegisteredI&APs Karibib K.N. Kamati Interested party Community Activist - Karibib Bianca Foelscher Community Activist Mining and Construction Entrepreneur - karibib Alfred Sanekavo George Community Lobbyist

APPENDIX C – NEWSPAPER ADVERTISEMENTS

APPENDIX D – AUTHORITY AND PUBLIC MEETING MINUTES

Authority Meeting Minutes

Subject: EA for the proposed exploration and mining of dimension stone on mining claims 71608-71617 AND exploration activities on EPL 5161

Venue: Online via Zoom

Date: 09 July 2020

Time: 10:00

Attendance: L. Uulenga; N. Merero; D. Van Rensburg

1 PROCEEDINGS

Ms. Linda Uulenga welcomed those who attended and explained the purpose of the meeting. The Environmental Assessment process and description of the proposed exploration project activities was provided. Comments were then invited from the attendees.

The following points were raised during the meeting:

 Ms. Van Rensburg raised a concern about where the mining employees will be accommodated during these activities. - Ms. Uulenga responded to the query and informed the audience that during exploration pre-fabricated accommodation may be set up at site subject to the approval of the farm owners. But during the mining phase the accommodation set up will be off site to mitigate risks such as illegal hunting, potential veld fires, noise level at night and avoid having people on site during the night.  How far is the site from Karibib in Km - Karibib is far from the site, closest town is Arandis which is about 38-45km southwest of the mining claims sites and about 25km southwest of the EPL.

The meeting was adjourned at 10h30.

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Authority Meeting Minutes

Subject: EA for the proposed exploration and mining of dimension stone on mining claims 71609-71617 AND exploration activities on EPL 5161

Venue: Farm Hakskeen (Tree near farm Water Point)

Date: 25 July 2020

Time: 14:05

Attendance: Linda Uulenga (OGGC)- chairperson Mike Sai and Brian representing Best Cheer Investments Namibia (Pty) Ltd And I&AP- see attached register

TABLE OF CONTENTS

1 INTRODUCTION AND WELCOMING ...... 2 2 OVERVIEW OF PROPOSED PROJECT ...... 2 3 ISSUES IDENTIFIED ...... 4 4 QUESTIONS AND COMMENTS REGARDING THE PROPOSED PROJECT ...... 5 5 CONCLUSION ...... 17

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1 INTRODUCTION AND WELCOMING

Ms Linda Uulenga with the assistance of Casius Skoppellitus translating, welcomed and thanked everyone for attending.

Meeting was officially opened by Hon. H Honeb, the owner of Farm Hakskeen and representative of the !Oe#Gan Traditional Authority. He emphasized that the area is behind in-terms of development and initiatives such as these are welcomed provided the right channels of communication are adopted and the environment is safe-guarded.

Ms Uulenga then explained the purpose of the meeting and presented an overview of the Environmental Assessment (EA) process. She described the four main phases of the EA process: obtaining information, report writing, circulation of draft report with I&APs, and finally submission of scoping and EMP reports to the Department of Environmental Affairs as part of an application for the Environmental Clearance Certificates (ECCs).

2 OVERVIEW OF PROPOSED PROJECT

Ms Uulenga then provided a brief overview of the proposed activity on behalf of Okonde Mining and Exploration cc and Best Cheer Investments Namibia (Pty) Ltd. The main aspects of the planned activities were outlined as follows:

 Project Description:

o Exploration of Dimension stones on:

- Mining Claims (MCs 71609- 71617) on Farms Hakskeen and Susksess only for Dolerite host rock - Exclusive Prospecting License (EPL 5161) on Farm Trekkopje only for granite host rock

o The EPL 5161 activities will stop here, but if positive results are achieved at exploration stage Best Cheer Investments Namibia (Pty) Ltd will have to apply for a mining license and carry out a full Environmental Impact Assessment before any mining activities can commence.

o The MCs 71609-71617 can proceed into mining activities if positive results are achieved at exploration stage. The Environmental Clearance Certificate (ECC) will enable them to quarry for 3 years with a possible renewal.

 Processes:

o For EPL 5161

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- Exploration: this stage will produce a local geological map that will enable the proponent to have information on rock type, spatial extent of host rock, weathering patterns and form, and geological structures. It is a non-invasive technique as only hand sized rock specimens will be collected. - Diamond Core Drilling: this stage shall produce core samples from which geological and geotechnical aspects such as rock hardness and strength, nature and frequency of discontinuities, rock texture, etc can be evaluated. - Test Mining: this stage exposes intact bedrock to extract few (two or three) block samples through butterfly cutting for further analysis to provide information on rock patterns, texture, colour and discontinuities. - EPL Exploration activities end here! o For Mining Claims 71609-71617

- Exploration: this stage will produce a local geological map that will enable the proponent to have information on rock type, spatial extent of host rock, weathering patterns and form, and geological structures. It is a non-invasive technique as only hand sized rock specimens will be collected. - Diamond Core Drilling: this stage shall produce core samples from which geological and geotechnical aspects such as rock hardness and strength, nature and frequency of discontinuities, rock texture, etc can be evaluated. - Test Mining: this stage exposes intact bedrock to extract few (two or three) block samples through butterfly cutting for further analysis to provide information on rock patterns, texture, colour and discontinuities. - Quarry Development: this stage includes setting up of temporary support facilities such as container office, septic tank ablution, shade structures, narrow access roads, drilling or rehabilitation of new or existing old boreholes for water supply; proximal to areas of high potential.

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- Extraction: this stage shall entail the removal of large blocks for further processing at local factories/ facilities in Karibib and/ or Walvis Bay. This stage will also entail ongoing restoration through rock shading, and partial backfilling with top soil. - Decommissioning: project discontinuity stage where site should be rehabilitated as much as possible.

 Service Infrastructure:

o Diesel generators during project lifetime

o Water supply will be brought to site with a water tanker daily from elsewhere for the duration of the exploration phase

o Ablution will make use of a septic tank

o Access tracks or roads will make use of existing dirt road linking proposed site to main road network

3 ISSUES IDENTIFIED

Ms Uulenga then described some of the potential impacts associated with the proposed activities. The following issues were highlighted:

 Data collection and analysis on groundwater of the area

 Contribution to national, regional and local revenue

 Some employment opportunities for local community

 Potential noise and visual disturbance

 Effect on possible migratory fauna in the area

 Topsoil removal to create roads leading to sites

 Potential soil pollution from hydrocarbon spillages

 Generation of domestic waste

These impacts, as well as any new impacts identified will be assessed in more detail during the scoping assessment which is ongoing.

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4 QUESTIONS AND COMMENTS REGARDING THE PROPOSED PROJECT

Opportunity was then given for those present at the meeting to ask questions, provide inputs, raise concerns or make comments with respect to the proposed activity. These are presented in the table below:

Table 1: Questions and comments register Question/ Comment by Question/ comment Response by Response

Mr Oliver Krappmann 1. Who are the owners and shareholders of Best Mr Mike Sai 1. Best Cheer is owned by Hong Kong Development Cheer Investments Namibia (PTY) LTD and Company 100%. Okonde Mining and Exploration cc is

Okonde mining and exploration cc owned by Andreas Indongo, and could not make it to site due to personal/ family commitments

2. Best Cheer Investments Namibia (PTY) LTD is the 2. What is the relationship between Best Cheer technical and financial partner as they have expertise Investments Namibia (PTY) LTD and Okonde and financial means Mining and Exploration cc?

3. Details and company registration for Okonde 3. Okonde Mining & Exploration cc is owned 100% by Ms Linda Uulenga Mining and Exploration cc Andreas Indongo who is a Namibia citizen

Mr Hansie Guibeb Can we be shown samples of the rocks to be mined? Mr. Casius Skoppellitus No, there are no available samples

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Question/ Comment by Question/ comment Response by Response

Mr Jakob Pienaar During the mining activities are you cutting out boulders Mr Mike Sai Smaller surficial boulders will most likely be crushed to produce (big blocks) or small stones? Is it the operations like they aggregates while loose bigger boulders will be considered for the

are doing in Spitzkoppe cutting out big stones? making tombstones through a partnership with the local community.

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Mr Oliver Krappmann 3 m x 2 m big blocks that are seen being transported to the harbour is what will be removed. The black ridges being observed

in the surrounding is dolerite dyke, it runs for many km in the area. The granite is most of Spitzkoppe and being mined at Groot

and Klein Spitzkoppe. It is not only surface loose stones but a deep whole will be created. The rocks can be found at many

places in Namibia, it is important where the rocks are being mined there should not be conflict. Best Cheer Investments Namibia wants the rock close to the road so they get it to the

factory quickly. It is more important for us that there is no

conflict. So to establish that there is no conflict one has to do specialist studies on:

- Groundwater to avoid contamination during mining

- Biodiversity (Plants and Animals)

- Noise and visual impacts, visual being most important as the butterfly cut will create an eye

sore especially for tourists

As the Environmental consultant, we have received Mr. Ms Linda Uulenga Krappmann’s list of specialist studies and his concerns have been attended to and were substantiated the studies are being carried out. Regarding the visual impact the dykes are dark in colour hence not so visible and partial backfilling and rock shading with

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Question/ Comment by Question/ comment Response by Response natural local rubble and top soil will be carried out as quarrying progresses.

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Mr Lesley 1. A miner at Spitzkoppe has left the site exposed Ms Linda Uulenga 1. Your concern has been noted, to avoid a debate it is and animals are falling in. Numerous letters have best we not accuse Best Cheer based on sites mined by

been sent to Ministry of Environment regarding other individuals or companies who have abandoned the concerns. Klein Spitzkoppe has been quarry sites without rehabilitation. To be objective and

completely damaged. fair let’s treat each miner on their own merit

2. As an Environmental Consultant, you are to 2. I have mentioned the potential impacts identified so protect the environment and I do not feel that far. Also I am here to collect further information/

you have stated all the potential impacts from concerns from the directly impacted community and the this project interested and affected parties. All impacts identified so far plus those raised here today and new ones not

mentioned but may be identified as the scoping phase

advances will be incorporated into the draft scoping report which will be shared with all I&APs for review and further input.

This is a meeting were the individuals can deny what has been Mr Herman Honeb said. There is no mining currently, the mining will come once the reports have been written. We as the community of this area have the right to hold Best Cheer and its partners accountable and responsible for any mining activities in our area or community. We should have the names and contacts of all

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Question/ Comment by Question/ comment Response by Response relevant persons and come up with an agreement contract on how operations will proceed.

Mr Herman Honeb We should put forth points that will enrich the report being Raised comment has been noted created by the environmental consultants. Let us not protest without facts. We ask that materials should not just be removed from the ground and exported but should be processed in Namibia to enable job creation both upstream and downstream of the value chain.

Mr Pienaar Since creation, there has been a lot of damage on the earth Raised comment has been noted through weather, etc. But since human creation, humans have brought many destructions to the surrounding environment. The mountains (dykes) around us, within these farms, are not being used for tourism. So if this project can develop this community by employing our children then that is a good thing provided that the environmental commitments mentioned will be sustained.

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Question/ Comment by Question/ comment Response by Response

Mr Headman Benjamin A lot of things in this gathering is true, the comments by Mr. Sai We acknowledge your input and have take note of all the issues Namaseb Mr Krappmann are valid and true and concern to us. The raised so far. To ensure accountability from our side the EMP parties present (against and for) are raising good points, (environmental management plan) document will be binding to only difference is the parties for the project are making us. Also it is important that mutual agreements are made promises. His concerns are: between Best Cheer and community leaders (representing the communities) to ensure that promises made are fulfilled should - In the beginning great promises are made and after the project see the light of day sometime the relationship becomes sour leaving the traditional authority to be blamed for these incidents

- He remains neutral in the matter, but if this project can bring development then it is a good thing provided the environmental concerns are considered

- Sadly the people present at the meeting will likely not be the people that will be at the site upon operation.

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Question/ Comment by Question/ comment Response by Response

Mr Lesley What mechanisms are in place to help the community Mike Sai That is misinformed public knowledge, millions are not made assist itself from this project in terms of loyalties or social from quarrying as the Ministry of Mines and Energy requires responsibility? Because it is public knowledge that millions certain percentages from royalties. If it were true that millions are gained from these activities. are made from mining why have many been abandoned?

Social responsibility: When we took the responsibility of the processing plant it is a huge risk. In Namibia Electricity is expensive but we took this risk to create employment and transfer skills to Namibians. Mining is a risky industry as the market fluctuates and sales are not a guarantee. Being an experienced company and having been in the business long after careful if we decide to go ahead with this project we will work out affordable packages.

Mr Herman Honeb Mike should be specific as to what he will offer and not Mr Mike Sai If ECC approved, before we start work we promise to rehabilitate just say offer packages existing water borehole to avail community with drinkable water.

Ms Erna !Noabes Concerned about community employment as most Ms Linda Uulenga & Mr An Environmental Management Plan is a legally binding company makes promises to employ the community and Mike Sai document and holds a lot of weight, therefore the community come in to start operations with its own people. can use that document against the proponent if they are not meeting the agreements as per document.

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Question/ Comment by Question/ comment Response by Response

Mr Naftali Goagoseb Gave an example of a Chinese company that had employed Mr Mike Sai Once again treat Best Cheer on its own merit. them and exploited their services despite having employment papers. They also requested for a borehole before operations and promised to drill a borehole for the community, but upon operation the company was bringing water from Karibib and the promise for a borehole was never delivered. A request for PPE was also made and nothing was done to meet needs. To avoid such matters it would be good to have transparent transactions.

Ms Wilhelmina Guriras Meetings such as these are important so that communities Raised comment has been noted are informed and hopefully its results are fruitful

Mr Herman Honeb What are the available channels to report disputes of Mr Casius Skoppellitus A suggestion is made that the community, proponent and affected people? Because after meetings/ consultation is consultant can come up with methods/ structure of done one has no document or methods to hold proponent communication to minimize conflict. responsible. The ministry of environment does not pay attention to the pleas of communities as they do not come out to do any assessments.

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Question/ Comment by Question/ comment Response by Response

Mr Hansie Guibeb How will you get so much dolerite on a small area? Mr Mike Sai It’s a total of 9 mines but one will not mine the whole area as some areas may have low potential. Test samples will be taken

to determine/ inspect fractures or continuity of host rock unit.

A mining claim is pegged and applied for, for mining exploitation, Mr Oliver Krappmann a target identified for prospecting which is an area of about 300 x 600 m. It is a huge block, not small!

Mr Hansie Guibeb The invitation for this meeting came to us as small scale Mr Mike Sai The invitation went out to everyone through the traditional miners, what are the benefits for them or why have we authority as a request was done for all relevant community been invited? members and infected and affected parties of the mining activity and to gather vast knowledge about the area.

Mr Casius Skoppellitus If ECC is approved and the mining is a go ahead, what are Mr Mike Sai Promises made at this stage are empty as there is no mining. But the benefits for the community on these farms as directly we can work a community project of tombstones through affected parties? shareholding that can be should to neighbouring countries. And also the possibility of a borehole before commencement of any work.

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Question/ Comment by Question/ comment Response by Response

Create a structure for further communication. Raised comment has been noted Independent consultant to note down the concerns of the people and identify other institutions that affected regarding these projects such as Heritage Council. As visible the community is struggling with farming and water is the biggest challenge hence when plans are being made they should be inclusive of all impacts for sustainable development. I am happy that this meeting request was well communicated to the community and the turn up this much. The concerns raised here should reach the Ministry of Environment please.

Mr Petrus Gurirab Concerned with environmental damages left behind by Mr Herman Honeb Raised comment has been noted mining activities

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Question/ Comment by Question/ comment Response by Response

Mr Casius Skoppellitus Mr Oliver you have mentioned a few concerns regarding Mr Krappmann It is the job of the environmental consultant to take into this project as I can sense that you have many danger consideration of all the aspects and that in the end there is no warnings for us? severe and long lasting effect if the mining goes there. I mentioned a few such as groundwater, noise, visual but one also

needs to look at the traffic and to ensure that the tourism sector does not suffer due to visual effect. My point is mining should not take place where there is conflict, it should not take place due to convenience but in a location where the impacts are least.

I’m specifically against the 9 mining claims as they are in a short So you are not 100% against the proposed project, just distance to the Swakop road and anyone who drives by will be fairly against it? able to see it.

Mr Hansie Guibeb The community is requesting the owner of the Mining Ms Linda Uulenga Noted, he will be informed Claims to meet with them.

Mr Robert Mukwgua The community should create a sheet with those that are Mr Mike Sai A structure can be formed for communication between for and against with reasons community and the proponent.

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5 CONCLUSION

Ms Uulenga then closed the meeting by mentioning the way forward, which is to write minutes and distribute them to all registered I&APs. Followed by the draft scoping report and a final scoping report for submission to the Department of Environmental Affairs.

Mr Honeb then asked for a community “general feeling” regarding the project. That they want to be recognised as affected members and appreciated the efforts carried out to reach out for consultation. He then finalised that only one person (representative of Farm Vergenoeg) is opposing the proposed projects.

A prayer was then offered by Headman Ben Uiseb.

Meeting concluded at 16:28

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APPENDIX E - PUBLIC MEETING ATTENDANCE REGISTER

APPENDIX F – ISSUES AND RESPONSE TRAIL

Issues and response trail

Date of Mode of Contributor Organisation communicat communicat Comment/Concern/Question EAP Response Action ion ion BID shared, registered as an BID shared, registered as an I&AP, As the owner of Namib Plaas I I&AP, requested to provide requested to provide contact wish to register as an I&AP before contact details for details for neighbouring Farm you start operations for ECC. neighbouring Farm Valencia. Valencia. Refer to Geo-hydrology specialist Raised Environmental Concerns Comment has been well study Appendix H of the Scoping specifically on lack of water in received and will be Report. Additionally, no water will the area due to low rainfall, with considered for the scoping be sourced in the area. It will be prevalant drough for about 8 report. imported from elsewhere and years. recycled. Concerns on increased vehicle Comment has been well movement in the area resulting to Impact will be kept as low as received and will be nuisance and off road driving possible by adhering to the Dr MM considered for the scoping Namib Plaas 93 23/06/2020 Email could result in excessive mitigation measures in the EMP. Engelbrecht report. mechanical transgression Concerns on impacts of The proposed exploration actiivities Comment has been well exploration and mining on the will focus on the central and received and will be environment - such disturbance western parts of the EPL, which considered for the scoping could affect eco-tourism in the excludes Namib Plaas. No sites for report. area. ecotourism will be disturbed. Residents of these farms will be prioritised for employment, which Comment has been well increases accountability as they will Concerns of crime and trespassing received and will be be more inclined to protecting their due to increase human activity considered for the scoping own enviornment. Activities will within the area report. also be limited to strict operating hours to reduce movement at odd hours.

Requested that the scoping report Comment has been well should include groundwater Refer to Geo-hydrology specialist Aupokolo received and will be NAMWATER 29/06/2020 Email abstraction and the ECC should study Appendix H of the Scoping Fillemon considered for the scoping also cover the activity. Registered Report report. as an I&AP.

Date of Mode of Contributor Organisation communicat communicat Comment/Concern/Question EAP Response Action ion ion

Objected the proposed activity on merit that it causes permanent Comment has been well Rehabilitation efforts to reduce damage to the environment and received and will be visual impact were recommended in landscape, which cannot be fully considered for the scoping the EMP. Works will exclude Farm rehabilitated, therefore will report. Vergenoeg. reduce land value of the farm. Requested that baseline studies Baseline studies addressed in be done to determine sensitivity Chapter 4 of the Scoping Report. of the area and specialist studies Comment has been well Groundwater study report is an on groundwater, Visual, Soils and received and will be Appendix H. Specialist studies were Rehabilitation, Socio-economic, considered for the scoping deemed unnecessary considering fauna, Noise, Hydrocarbons and report. that it is only exploration stage, cumulative environmental and will only be considered in the Oliver impacts. EIA for mining Letter Krappmann Comment has been well Vergenoeg 02/07/2020 submitted Is the environmental impact and Mr Kobus received and will be Clarified in sub-chapter 2.1 of the via Email assessment only with respect to Smit exploration or with the view of considered for the scoping Scoping Report obtaining an ECC for mining? report. Objected the establishment of an exploration camp on Vergenoeg or in its proximity as it would imply Comment has been well Vergenoeg will be excluded from increased demand for scares received and will be the proposed activity. The camps resources such as firewood and considered for the scoping will have temporary visual impact groundwater and will have visual report. for the period of exploration. impact, therefore will reduce land value of the farm. Comment has been well Corrected project information on Information was corrected under received and will be Geology and Hydrogeology in the sub-section 4.1.2 and 4.1.4 of the considered for the scoping BID Scoping Report report.

Letter via Questioned the real benefit of the Best Cheer should operate within Comment has been well Email project to the community "our the Labour Act and ensre that the Bianca Community received and will be 06/07/2020 through the environemnent will be destroyed employees and affected Foelscher Activist considered for the scoping Karibib in order to develop and beautify communities benefit from the report. Constituency foreign countries and foreign real project.

Date of Mode of Contributor Organisation communicat communicat Comment/Concern/Question EAP Response Action ion ion office estate sectors"

Comment has been well Requested for proof of Newspaper received and will be Refer to Appendix C of Scoping adverts considered for the scoping Report report. Requested Best Cheer Investments Namibia (Pty) Ltd Comment has been well (hereafter BCIN) to provide Communication forwarded to Best received and will be registered names of the Cheer Investments Namibia (Pty) considered for the scoping dimension stones processing Ltd report. factories in Karibib and Walvis Bay Comment has been well Requested BCIN to disclose names Communication forwarded to Best received and will be of directors and company Cheer Investments Namibia (Pty) considered for the scoping managers Ltd report. Comment has been well Number of employees at BCIN and Communication forwarded to Best received and will be Namibian to foreign employee Cheer Investments Namibia (Pty) considered for the scoping ratio Ltd report. Request for BCIN to publish latest Comment has been well Communication forwarded to Best annual financial statements/ received and will be Cheer Investments Namibia (Pty) reports for the two factories in considered for the scoping Ltd local newspapers report. Comment has been well Does BCIN and the two factories Communication forwarded to Best received and will be have EPZ or any other tax friendly Cheer Investments Namibia (Pty) considered for the scoping statuses in Namibia? Ltd report. Water resource concern - that Comment has been well Water will no be sourced locally. proponent must obtain clearance received and will be Additionally, no quarrying will take for water abstraction prior to considered for the scoping place under this project. Only test quarrying report. mining.

Date of Mode of Contributor Organisation communicat communicat Comment/Concern/Question EAP Response Action ion ion Concern on fauna and flora - Comment has been well Foreign investors not being received and will be sympathetic towards our fragile Measures towards preservationof considered for the scoping indigenous habitat and natural fauna and flora in the area haave report. environment in Africa. been outlined in the EMP Concerned about added burden Comment has been well on road infrastructure - damage Best Cheer should operate within received and will be of existing roads and Namibian the Roads Act and be subjected to considered for the scoping taxpayers to carry the weigh bridges and necessary fees report. maintenance rates. Socio-economic impacts - Proponent must support local businesses and not import Comment has been well Communication forwarded to Best everything from China. Capacity received and will be Cheer Investments Namibia (Pty) building must involve transfer of considered for the scoping Ltd more sophisticated skills as report. opposed to driving trucks and shovelling.

Please register Namib Botanical Gardens project as I&AP. Please register NBG as a prospective partner and destination site in the rescue and relocation of indigenous and protected flora. NBG has recently participated in a Frank Namib number of plant rescue & BID shared, registered as an Löhnert Botanical 10/08/2020 Email relocation exercises with Husab I&AP, Comment considered Gardens CC mine and also at Rössing Uranium for the scoping report. mine. Namib Botanical Gardens may be able to assist the proponent in National Botanical Gardens have relocation exercises from subject been included as part of the EMP site. measures to rescue and relocate indigenous and protected flora.

Date of Mode of Contributor Organisation communicat communicat Comment/Concern/Question EAP Response Action ion ion Party was made aware of all Quarried how the EA has being the public announcements Refer to sub-section 5.2.1 and conducted as he has not seen or done via radio, newspapers as Appendix C for Site Notices and heard any information regarding well as site notices at Newspaper Adverts Alfred the project in Karibib respective office centres in Community Sanekavo 21/07/2020 Email the region. Lobbyist George Party was informed and invited to the public meeting Meeting invitation was extended to Requested for a meeting to be already planned on Farm him and was advised to otherwise held in Karibib Hakskeen, or alternatively send through his concerns via submit concerns via email email.

APPENDIX G – PROOF OF COMMUNICATION RECEIVED

Nagenoeg Investments (Pty) Ltd

1 July 2020

OMAVI Geotechnical & Geo-Environmental Consultants CC

For attention: Mr Etula Ms Linda Uulenga e-mail: [email protected] [email protected]

Dear Madam and Sir,

BEST CHEER INVESTMENTS NAMIBIA (PTY) LTD RE: EPL5161

1. We address this letter to you in our capacity as the registered owner of the Farm Vergenoeg 92 (the “Property”).

2. We have considered the background information document pertaining to the environmental assessment for the proposed exploration activities on EPL5161 and comment thereon as follows:

2.1. we note that you intend to conduct baseline studies to determine the sensitivity of the receiving environment and population to the proposed project. Please furnish us with a list of the planned baseline studies and the particulars of the independent specialist expertise identified for these baseline studies;

2.2. we strongly object to the undertaking of the activities detailed in paragraph 2.1 on the Property. These activities will result in permanent damage to the natural environment and landscape which damage is not capable of being fully rehabilitated and will consequently have a negative impact on the value of the Property;

2.3. clarity is required as to whether this environmental impact assessment is being conducted only in respect of EPL5161 or with a view to also obtaining an environmental clearance certificate for mining activities;

2.4. we note from paragraph 2.2 that a camping facility for the workforce is envisaged which will inter alia include water tanks with dispersion pipelines, pre-fabricated offices and accommodation and a borehole for water supply. We strongly object to the establishment of a camping facility on the Property or in close proximity to the Property. The Property and surrounding areas are situated in an arid desert region and an increased demand for scarce resources such as fire wood and groundwater will only perpetuate the already existing problems. Furthermore, given the landscape, a camping facility will be visible from afar and will have a negative impact on the value of the Property;

Nagenoeg Investments (Pty) Ltd │ Reg no: CC/2001/0419 P O Box 347 │ Outjo │ Namibia │ Tel +264 67 333461 │ Director: Kobus Smit

2.5. with reference to the equipment, machinery and infrastructure planned for the proposed exploration and quarrying phases, we would require that the following independent specialist studies be conducted:

2.5.1. a groundwater study by a hydrogeological consultant, including the preparation of a groundwater management plan;

2.5.2. a visual impact assessment;

2.5.3. study of soils and rehabilitation of land surface;

2.5.4. study on the socio-economic aspects of the project;

2.5.5. studies on botany, invertebrates, reptiles and mammals are required as the affected area falls into a number of environmentally sensitive habitats;

2.5.6. a noise impact assessment;

2.5.7. a study on the dust and airborne emissions resulting from the proposed excavation, drilling, stone cutting and related activities;

2.5.8. a risk assessment on hydrocarbon spillages;

2.5.9. specialist risk assessments with modelling of the long-term effect of the negative impacts identified in paragraph 4.1.2;

2.6. the geological project description detailed in paragraph 3.1.1 is wrong and entirely misleading for the project site as well as for the target rock resource;

2.7. the statement that the project area is part of the Central Namib-Windhoek Groundwater Basin is factually incorrect and misleading. Although the location falls within the Central Namib – Windhoek Area according to the hydrogeological map of Namibia (2011), groundwater in the area is not contained in a basin but in a large number of separate and distinct aquifers of different sizes and with individual properties. Detailed specialist studies on the groundwater aspects, yield, quality and sustainability are required for the environmental impact assessment phase;

2.8. the alleged positive impacts of the project listed in paragraph 4.1.1 constitute bald assertions. Please furnish us with details as to the investigations conducted in this regard and the specialist reports prepared in support of these assertions.

3. Please acknowledge receipt hereof.

Yours sincerely,

Kobus Smit Director NAGENOEG INVESTMENTS (PTY) LTD

APPENDIX H – ENVIRONMENTAL MANAGEMENT PLAN (EMP)

Environmental Management Plan (EMP) for proposed exploration of dimension stone on EPL 5161, Erongo Region, Namibia

ECC App No.: APP-001762

Date: 04 June 2020

Prepared for: Best Cheer Investments Namibia (Pty) Ltd

Prepared by: OMAVI Geotechnical & Geo-Environmental Consultants CC (OGGC) Tel.: +264 81 300 3872 or +264 81 478 6303 Email: [email protected]

CONTENTS PAGE

1 PROJECT BACKGROUND ...... 1 1.1 PROPOSED EXPLORATION WORK ...... 4 1.1.1 Desktop studies ...... 4 1.1.2 Field evaluation ...... 4 1.1.3 Detailed exploration ...... 4 1.1.4 Feasibility study ...... 4 1.2 PROJECT REQUIREMENTS AND ASSOCIATED INFRASTRUCTURE ...... 5 1.2.1 Power Requirements ...... 5 1.2.2 Water supply ...... 5 1.2.3 Roads ...... 6 1.2.4 Waste production and sanitation ...... 6 1.2.5 Temporary shelter / accommodation ...... 6 1.2.6 Personnel and site safety ...... 6 1.3 KEY IMPACTS IDENTIFIED AND MANAGEMENT OBJECTIVES ...... 6 2 MANAGEMENT MEASURES ...... 8 2.1 APPOINTED ENVIRONMENTAL ASSESSMENT PRACTITIONER ...... 8 2.2 PURPOSE OF EMP ...... 8 2.3 ROLES AND RESPONSIBILITIES FOR EMP IMPLEMENTATION ...... 9 2.3.1 Exploration Manager ...... 9 2.3.2 Environmental Control Officer (ECO) ...... 9 2.4 APPLICABLE LEGISLATION: AUTHORISATION (PERMITS AND LICENSES) ...... 10 3 MANAGEMENT PLAN ACTIONS ...... 12 4 ENVIRONMENTAL MONITORING AND PERFORMANCE ASSESSMENT ...... 28 4.1 MONITORING PROGRAMMES ...... 28 4.1.1 Dust monitoring ...... 28 4.1.2 Monitoring for soil pollution ...... 28 4.1.3 Fauna and flora inventory ...... 28 4.2 ENVIRONMENTAL AWARENESS PROGRAMME ...... 28 4.2.1 Induction ...... 28 4.2.2 On the job training ...... 29 4.2.3 Inhouse communication...... 29 4.3 ENVIRONMENTAL EMERGENCY PREPAREDNESS ...... 29 5 CONCLUSION ...... 29

LIST OF FIGURES

Figure 1 Locality map of the project site EPL 5161 near Arandis in Erongo Region...... 3 Figure 2: An example of some of the techniques to employed in this exploration project. 5

LIST OF TABLES

Table 1: A summary of identified impacts and their environmental objectives ...... 6 Table 2: Applicable legislations in terms of permits or licenses for the proposed exploration and mining activities ...... 10 Table 3: A summary of identified impacts, their management actions and responsible parties 13 ABBREVIATIONS EA Environmental Assessment ECC Environmental Clearance Certificate ECO Environmental Control Officer EIA Environmental Impact Assessment EM Exploration Manager EMA Environmental Management Act EMP Environmental Management Plan ESA Environmental Scoping Assessment I&APs Interested and Affected Parties MEFT Ministry of Environment, Forestry and Tourism MME Ministry of Mines and Energy NBG National Botanical Gardens OGGC OMAVI Geotechnical and Geo-environmental Consultants cc SHE Safety, Health, and Environment

1 PROJECT BACKGROUND

Best Cheer Investments Namibia (Pty) Ltd (the client or Best Cheer hereafter) intends to carry out exploration activities to investigate the potential of granites and granitoid bodies on Exclusive Prospecting License (EPL) no. 5161, for use as dimension stones. The EPL is approximately located between coordinates 22.284568S/ 15.059525E and 22.319516S/ 15.295920E, about 25 km northeast of Arandis and covers an area of about 5059 ha. The area falls under the Karibib Constituency jurisdiction and extends across three (3) commercial farms namely Vergenoeg (no. 92), Valencia (no. 122), Namibplaas (no. 93) and one (1) communal farm Trekkopje (no. 120) as seen in Figure 1. Although this is the case, works on this EPL will focus on Farm Trekkopje.

Page 1

Page 2 Figure 1 Locality map of the project site EPL 5161 near Arandis in Erongo Region.

Page 3 1.1 Proposed exploration work As part of exploration, Best Cheer Investment (Pty) Ltd intends to adopt a systematic prospecting approach starting with desktop study, field evaluation and mapping, and ultimately, drilling and possibly test quarrying in selected areas where the outcomes of field evaluation are positive. 1.1.1 Desktop studies The exploration program will commence with a review of geological maps and historical drilling and/ or quarrying data for the area. 1.1.2 Field evaluation To be carried out by a competent and qualified geologist, aimed at locating suitable outcrops in the field and subsequently delineating potential granite intrusions. Granite bodies identified will be ranked in order of priority for follow up exploration based on various factors such as: • Size (both lateral & vertical thickness) of the granite intrusion • Colour, texture, pattern, and frequency/ intensity of the granite intrusion rock mass • Discontinuity mapping to get joint and vein spacing can be evaluated Small hand samples (about 30 cm3 in dimension) will be taken for cutting and polishing to provide insight on hardness of the stone and whether the stone can be polished to an acceptable finish. As a product, a geological map of the area will be produced to assist in target generation for subsequent detailed exploration such as drilling and possibly test quarrying.

1.1.3 Detailed exploration Vertical and inclined core drilling with a DTH (down the hole) drill rig will be carried out in selected areas to provide information on the vertical extent of the formation, colour and texture as well as joint spacing or possible defects at depth. Where cleaning of the rock units is required, a bulldozer will be used to scrap off overburden, after which an air compressor will be used to further expose the rocks for mapping. This will aid delineation of major geological structures such as fault and shear zones, the extent of veins, frequencies of fracture/ discontinuity, thereby refining the produced geological map. The refined map will then be used to define targets for feasibility or test quarrying.

1.1.4 Feasibility study Where drilling yields positive results, test quarrying by means of butterfly cutting will be conducted to fully evaluate the recovery of saleable blocks, and better optimize the extraction methods, production rates and operational costs. This will be carried out in select targeted areas only and shall be performed on as small an area as possible to

Page 4 minimize environmental impacts. Project feasibility will also be measured in terms of accessibility from site of occurrence to nearby relevant infrastructure such as roads, railway, etc. Figure 2 summarizes the technologies and equipment to be used. Although the pictures are showing the use of such technologies in mining, for this study they will be used for exploration purposes.

Overburden Removal Down-the-Hole drilling

Figure 2: An example of some of the techniques to employed in this exploration project.

Areas found to comprise good quality rocks in economic volumes will then be delineated for possible mining, subject to the granting of a valid mining license from the Ministry of Mines and Energy (MME).

1.2 Project requirements and Associated infrastructure 1.2.1 Power Requirements It is anticipated that onsite machinery will be diesel powered. It will mainly be used in powering the compressors for surface cleaning, drilling and cutting machinery. The amount of diesel to be used has not been determined, however it will be delivered to site as required and stored in a trailer mounted bowser. This eradicates the need to connect to the national power grid. 1.2.2 Water supply About 2000 litres of water will be required for operations per day. Therefore, to avoid putting pressure on surface and groundwater resources in the area, water for exploration activities will be sourced either from Karibib or from the proponent’s warehouse water supply line in Swakopmund. The water will then be transported to site by truck and kept onsite in water tankers. Therefore, no abstraction will take place from local boreholes. The water will primarily be used to cool and lubricate cutting and drilling machinery and will be recycled to make maximum use of available water.

Page 5 1.2.3 Roads The project will utilise existing farm roads and where necessary, temporary informal access routes will be created to gain access to the actual targeted sites for the drilling rig, air compressor and water trucks. 1.2.4 Waste production and sanitation Movable ablution facilities with septic tanks will be put up for sanitation purposes for the exploration team. General solid waste will be collected and sent to the Arandis Landfill. 1.2.5 Temporary shelter / accommodation A temporary camp will be set up to accommodate the exploration team. It will primarily be an erection of tents and other temporary structures such as pre- fabricated structures that will be used as office and storage space. All this will take place subject to approval by the farm owners. 1.2.6 Personnel and site safety A total of about seven (7) people will be employed during exploration and all workers will be equipped with adequate and appropriate personal protective equipment (PPE), that will be replaced or repaired to ensure workers’ occupational health and safety. For safety and security reasons, the localized high-risk working sites will be temporarily fenced off. Exploration vehicles will also be equipped with fire extinguisher as well as at the drilling site in cases of fire outbreaks while carrying out exploration activities.

1.3 Key impacts identified and management objectives Based on the outcomes of the scoping assessment, potential impacts associated with the proposed exploration activities are as follows:  Impact on soils

 Impact on surface and groundwater resources

 Impact on the surrounding fauna and flora

 Impact on surrounding air quality

 Impact on the socio-economic environment

Table 1: A summary of identified impacts and their environmental objectives

Environmental Aspect Management Objective Soil (contamination)  To minimise soil degradation through contamination.

Soil disturbance  To conserve the soil resources on site  To minimise physical disturbance of the soil Biodiversity (flora)  To limit the impact of exploration and associated infrastructure on the vegetation in the area  Protect the rare and endangered plant species on site.

Page 6 Environmental Aspect Management Objective Biodiversity (fauna)  To minimise habitat destruction resulting from exploration and associated infrastructure  Protect the rare and endangered animal species on site Surface water (Contamination of  To prevent the contamination of the Khan River and its surface water run-off) tributaries close to site.

Groundwater (Impact on groundwater  To ensure that the exploration activities do not put quality and levels due to potential over- pressure on groundwater availability for the local abstraction) groundwater users.  To prevent lowering of groundwater levels due to over- abstraction.  To prevent contamination of groundwater  To make careful use of available water by recycling it. Air Quality (dust and gases)  To minimize the impact of exploration activities on the surrounding air quality.  To minimize the cumulative impact of dust generation by exploration activities on the overall air quality of the region.  To reduce the potential of dust deposition to the surrounding as it could potentially affect the functionality of the ecosystem. Noise (Increased noise levels during the  To minimise the impact of noise on workers, animals as later stages of exploration) well as the residents

Visual Aspects (Impact on Sense of  To reduce the visual impact caused by the test mining on Place) the surrounding area.

Storage and handling of diesel,  Ensure that no contamination results from the stored lubricants / oils diesel on site.  To ensure that all safety and environmental measures are in place during the storage and usage of hydrocarbon products on site. Health and Safety  To ensure that the health and safety of the workers are not compromised.  To ensure that the mine has enough safety warnings at all risk potential areas  Ensure that there is/are site workers that are responsible for the implementation of safety measures on site at all times.  To ensure that firefighting equipment (such as fire extinguishers) are always ready for use in case of a fire. Waste Management  To minimize environmental degradation (pollution)  To ensure that there is enough waste management equipment on site to avoid environmental pollution. Regional Socio-economic structure  To ensure that preference for employment is given to the (Social investment activities, job locals. creation, number of households  General contribution to the local and regional economy

Page 7 Environmental Aspect Management Objective benefiting directly and indirectly)

2 MANAGEMENT MEASURES

2.1 Appointed Environmental Assessment Practitioner Best Cheer Investments Namibia (Pty) Ltd appointed OMAVI Geotechnical & Geo- environmental Consultants CC (OMAVI hereafter) as an independent environmental consultant, to investigate the potential biophysical and socio-economic environmental impacts that would arise from the planned exploration activities. The findings of the scoping assessment are aimed at assisting the Ministry of Environment, Forestry and Tourism’s (MEFT) Department of Environmental Affairs and Forestry (DEAF) with sufficient factual information to make an informed decision on the granting of an ECC for the proposed activities. Linda Uulenga an Environmental Assessment Practitioner for OMAVI conducted this EA process and prepared this Environmental Management Plan (EMP).

2.2 Purpose of EMP A ‘management plan’ is defined as: “…a plan that describes how activities that may have significant environments effects on the environment are to be mitigated controlled and monitored.”

An EMP provides a link between the impacts identified in the EIA process and synthesizes all the proposed mitigation and monitoring actions, set to a timeline and with specific assigned responsibilities. Therefore, it can be said that the purpose of an EMP includes:

 To prevent, reduce and manage potential negative impacts.  To enhance potential positive impacts.  To ensure implementation of recommended mitigation measures; and  To monitor how effective the mitigation measure proposed are. This EMP has been compiled based on the scoping assessment and specialist groundwater study conducted for the area. The project specific information used in this document is as provided by the Proponent, from site observations, OMAVI Consultants experience and relevant literature. OMAVI therefore assumes that all the project technical information and data provided by the Proponent is correct and accurate, and that all necessary information has been disclosed which led to the development of this EMP.

Page 8 It is important to note that an EMP is a legally binding document and a person who contravenes the provisions of this EMP may face imprisonment and/or a fine. This EMP is a living document and should be amended to address project changes and/or environmental conditions and feedback from compliance monitoring.

2.3 Roles and responsibilities for EMP implementation The proponent (Best Cheer Investments Namibia (Pty) Ltd) and its employees are ultimately responsible for the implementation of the EMP. The responsibilities for the effective implementation of this EMP will be entrusted with the following key personnel:

 Exploration Manager (EM)

 Environmental Control Officer (ECO)

2.3.1 Exploration Manager

The Proponent should appoint an Exploration Manager to act on their behalf in overseeing the general / day to day flow of exploration works, which includes implementation of environmental measures. Overall responsibility for all activities that take place at the exploration sites will reside with this manager. In this regard the following roles and responsibilities are applicable:

 Management and monitoring of individuals and/or equipment onsite in terms of compliance with this EMP.

 Maintaining stakeholder engagement and grievance mechanisms.

 The implementation of and compliance with the environmental management measures proposed in this document.

 Ensuring that the monitoring, auditing, and reporting programmes are scoped and included in the annual budgets; and

 Ensuring compliance with relevant environmental and related authorisations and licensing conditions.

 Issuing fines to individuals who contravene EMP provisions and if necessary, removing such individuals from site.

2.3.2 Environmental Control Officer (ECO) The Proponent should assign the responsibility of overseeing the implementation of the whole EMP on the ground, especially from Field Evaluation stage. The responsibilities of the Environmental Control Officer will include among others:

 Management and facilitation of communication between the Proponent, Exploration Manager and Interested and Affected Parties (I&APs) regarding this EMP.

Page 9  Conducting site inspections (to be done on a monthly basis at minimum) and preparing quarterly environmental reports of all areas with respect to the implementation of this EMP

 Give training to the general staff on the implementation of the EMP.

 Ensuring all incidents are recorded and documented.

 Manage monitoring and auditing programmes for the site and prepare quarterly monitoring reports for submission with MEFT.

 Undertaking an annual review of the EMP and recommending additions and/or changes to this document.

 Archaeology: To exercise due caution if archaeological remains are found, secure the site and advise management timeously. To determine safe working boundaries and request inspection by an archaeologist

2.4 Applicable Legislation: Authorisation (Permits and Licenses) This section covers information on the legal obligations (legislations, policies, and guidelines) that governs certain project activities, where permitting and/or licensing may be required from different applicable regulatory authorities

Table 2: Applicable legislations in terms of permits or licenses for the proposed exploration and mining activities

Legislation Provisions Contact Details

Environmental Activities listed in Government Notice (GN) Mr Damian Nchindo (Ministry of Management Act 2007 No. 29 of GG No. 4878 require an Environment, Forestry and Environmental Impact Environmental Clearance Certificate (ECC). Tourism’s Department of Assessment (EIA) The amendment, transfer, or renewal of the Environmental Affairs and Regulations (EIAR) (GG ECC (EMA S39-42; EIAR Regs19 & 20). Forestry (DEAF) – Chief Conservation Scientist) No. 4878) Amendments to this EMP will require an amendment of the ECC. Tel: (061) 284 2701 The ECC needs to be renewed every 3 years.

The Water Act 54 of 1956 The Water Act 54 of 1956 was formulated to Mr Franciskus Witbooi (Deputy consolidate and amend the laws relating to Director: Water Policy and the control, conservation and use of water Water Law Administration. The Water Resources for domestic, agricultural, urban and Management Act No. 11 Tel: (061) 208 7158 industrial purposes; to make provision for the of 2013 (unpromulgated) control, in certain respects, of the use of sea water for certain purposes; for the control of certain activities on or in water in certain areas. Provision for a water use permit for commercial use to be applied for and obtained from the Department of Water Affairs (DWA): Directorate of Water Resources Management. When issued, Proponent, the permit should be renewed as required (as

Page 10 Legislation Provisions Contact Details

stipulated in therein).

Mineral Prospecting & Section 71(1): Provides for the validity of an Mr Erasmus Shivolo (Mining Mining Act (Act No. 33 of exclusive prospecting licence (EPL). Commissioner) 1992) Section 72 (2): Applications for renewal of an Tel: 061 284 8167 exclusive prospecting licence. The EPL needs to be renewed every 3 years, not later than 90 days before expiry.

Under this Act (Section 51 (1a)), holder of a The Proponent should enter into mineral license cannot exercise any rights on and sign access and land use a private land until the holder has entered agreement with respective into an agreement with the owner regarding affected farm owners as listed payment of compensation in the Stakeholders’ (Interested and Affected Parties) list.

Road Traffic and Provides for the control of traffic on public Mr Eugene de Paauw (Roads Transport Act 52 of 1999 roads and the regulations pertaining to road Authority – Specialist Road and its 2001 Regulations transport, including the licensing of vehicles Legislation) and drivers. Tel.: (061) 284 7027 A site access road permit from the main road (B2) should be applied for and obtained from the Roads Authority and conditions set therein to be compiled with.

Petroleum Products and Regulation 3(2)(b) states that “No person Carlo Mcleod (Ministry of Mines Energy Act (No. 13 of shall possess or store any fuel except under and Energy: Acting Director – 1990) Regulations (2001) authority of a licence or a certificate, Petroleum Affairs excluding a person who possesses or stores Tel.: (061) 284 8291 such fuel in a quantity of 600 litres or less in any container kept at a place outside a local authority area”

Forestry Act (No. 12 of Permits are required for the removal of The nearest Forestry Office 2001) protected plants species. (Ministry of Agriculture Water and Land Reform) Nature Conservation Permits are required for the removal of Mr Joseph Hailwa (Director: Ordinance No. 4 of 1975 protected plants species. Forestry), Tel: (061) 208 7663 (as amended)

National Heritage Act The Act makes provision for the protection Ms. Erica Ndalikokule (Head: (Act No. 27 of 2004) and conservation of places and objects of Heritage Management) – heritage significance and the registration of National Heritage Council of such places and objects. Part V Section 46 of Namibia the Act prohibits removal, damage, Tel: (06) 301 903 alteration or excavation of heritage sites or OR remains, while Section 48 sets out the procedure for application and granting of Mr Manfred Gaeb (Regional permits such as might be required in the Heritage Officer) – National event of damage to a protected site Heritage Council of Namibia occurring as an inevitable result of Tel:(061) 301 903 development. Part VI Section 55 Paragraphs 3 and 4 require that any person who

discovers an archaeological site should notify the National Heritage Council. Section

Page 11 Legislation Provisions Contact Details

51 (3) sets out the requirements for impact assessment. Should any objects of heritage significance be identified during the exploration, the work must cease immediately in the affected sites and the necessary steps taken to seek authorisation from the Council.

Labour Act 11 of Adhere to all applicable provisions of the No permit is required, but 2007Health and Safety Labour Act and the Health and Safety adherence to the Act’s Regulations (HSR) GN regulations. Relevant Regulations is highly 156/1997 (GG 1617). recommended.

3 MANAGEMENT PLAN ACTIONS

The aim of the management actions of the EMP is to avoid potential impacts where possible, and where impacts cannot be avoided, measures are provided to reduce the significance of these impacts. Management actions recommended to manage the potential impacts rated in the environmental scoping report should be carried out for the proposed exploration works as presented in Table 3. The responsible persons at Best Cheer must therefore assess these commitments in detail and should acknowledge their commitment to the specific management actions detailed in the table.

Page 12 Table 3: A summary of identified impacts, their management actions and responsible parties Environmental Aspect Impact Management Actions Responsibility Timeline EMP implementation Lack of EMP awareness Proponent Prior to project  A Comprehensive Health and Safety Plan for the and training and implications thereof project activities should be compiled. This will include commencement all the necessary health, safety, and environmental (pre-exploration) considerations applicable to respective works on sites.  An EMP non-compliance penalty system should be implemented on site.  The Proponent should appoint an Environmental Control Officer to be responsible for managing the EMP implementation and monitoring

Authorizations Lack of Agreements,  All the necessary agreements should be applied for Proponent Prior to project Permits/ Licenses and signed before commencement of work on the commencement EPL (pre-exploration)  All the required licenses or permits should be applied for and acquired before commencement of work on the EPL. This includes land access to be granted by land/farm or property owners, permits for petroleum storage, etc.

Communication Lack of communication Proponent Prior to project  The Proponent should appoint an Exploration between the Proponent (proper liaison) Manager to liaise with the farmers/landowners. commencement and landowners or between farmers and  The Exploration Manager should be introduced to the (pre-exploration) occupiers of land Proponent with regards farm owners and his or her contact details provided to to land use them prior to undertaking activities for easy communication during the exploration activities.

Page 13 Environmental Aspect Impact Management Actions Responsibility Timeline  A clear communication procedure/plan which should include a grievance mechanism should be compiled

Environmental systems Legal non-compliance  The Proponent should appoint an Environmental Proponent / Prior to project Control Officer to be responsible for managing the Exploration commencement EMP implementation and monitoring. Manager (EM) (pre-exploration)  Device an EMP non-compliance penalty system.  Management and facilitation of communication between the project team and Interested and Affected Parties (I&APs) regarding this EMP, to increase transparency and public perception.

 A Comprehensive Health and Safety Plan for the Environmental Prior to project project activities should be compiled. Control Officer commencement  Undertaking an annual review of the EMP and (ECO) (pre-exploration) recommending additions and/or changes to this document

Employment Creation of Proponent / EM Pre-project  Recruitment of exploration staff should prioritize employment people from the locally affected area, in accordance activities and opportunities with procedures approved by the relevant authorities. when necessary,  Equal opportunity should be provided for both men throughout and women.

Specialised Exploration contractors EM Pre-project  All services related to exploration activities such as procurement of services and services drilling that the Proponent may need, preference activities and should be given to local providers of such services. If when necessary,

Page 14 Environmental Aspect Impact Management Actions Responsibility Timeline not available locally, the services search should be throughout extended to a Regional level (Erongo Region) and lastly, nationally, or international, if all efforts lead to no success.

Biodiversity Loss of biodiversity  Draw up a flora inventory, including their sensitivity ECO Throughout the (flora) and status of endemism, to ensure preservation of exploration endemic plant species. phase  Advise on the layout of access roads to ensure minimal disturbance, hence preservation of plants as much as possible.  Enforce strict driving on the created roads and impose fines for off-road driving that could potentially destroy plant life  Plants must be carefully removed and transplanted. Work together with the National Botanical Gardens (NBG) in plant rescue and relocation.  Ensure stockpiling the topsoil to have a seedbank and harvesting of seeds for replanting for reclamation works.  No onsite vegetation should be cut or used for firewood related to the project’s operations. The Proponent should provide firewood for his onsite camping workers from authorized firewood producer or seller.

Page 15 Environmental Aspect Impact Management Actions Responsibility Timeline Loss of biodiversity  Draw up a fauna inventory, including their sensitivity ECO Throughout the (fauna) and status of endemism exploration  Ensure that existing roads are utilised as much as phase possible to avoid creating new ones where possible as this minimizes habitat destruction.  Discourage indiscriminate killing of perceived dangerous species (e.g. snakes and scorpions)  Remove and relocate perceived dangerous species (e.g. snakes) to similar undisturbed habitats in the general area.  Ensure that worked out areas are demarcated and fenced off to keep animals out until they can be rehabilitated

 Ensure that speed limit of 60km/h for light vehicles and EM Throughout the 30km/h for heavy is maintained onsite to prevent exploration fatalities of fauna that may manifest from collisions phase with vehicles and earth moving equipment

 Implement a severe penalty system for any worker who will be found hunting wild animals in the area.

Page 16 Environmental Aspect Impact Management Actions Responsibility Timeline Chemical risk by Pollution of soils  Warrant that enough drip trays are available on-site Proponent / EM Throughout the hydrocarbons and are used at all times when vehicles, trucks are idle exploration as well as under the diesel trailer to contain any phase potential spillages.

 Ensure that drip trays are always used when vehicles, ECO Throughout the trucks are idle as well as under the diesel trailer to exploration contain any potential spillages. phase

 Put in place contamination control measures to manage soil pollution.

 Ensure that contaminated soils that may have resulted from leakage/spillage from vehicles or machinery are removed completely and treated or disposed of in accordance with the nearest municipal wastewater discharge standards and the contaminated soils must be thereafter replaced with clean soil.

 The trailer with a diesel tank must have designated parking on site, which must be lined ground to prevent pollutants from reaching the soil.

 Do daily inspections and monitor soil contamination on site on a weekly basis.

Page 17 Environmental Aspect Impact Management Actions Responsibility Timeline Pollution of water  Warrant that enough drip trays are available on-site Proponent / EM Throughout the and are used at all times when vehicles, trucks are idle exploration as well as under the diesel trailer to contain any phase potential spillages.

 Ensure that contaminated soils that may have resulted ECO Throughout the from leakage/spillage from vehicles or machinery are exploration removed completely to prevent pollutants from phase leaching into the ground to contaminate groundwater

 The trailer with a diesel tank must have designated parking on site, which must have an impermeable liner to prevent pollutants from leaching into the ground and potentially contaminating groundwater.

 Personnel must use the toilet facilities provided onsite to prevent potential faecal contamination of water resources.

Physical disturbance Soil disturbance and loss  Only one campsite should be used to avoid erecting ECO & EM Throughout the of habitat temporary infrastructure in different places and exploration causing further disturbance to the environment. phase

 Enforce strict driving on the existing and created access roads and impose fines for off-road driving that

Page 18 Environmental Aspect Impact Management Actions Responsibility Timeline could potentially destroy plant life.

 Location of campsite must be selected with ultimate consideration of the environment, while making it convenient for exploration staff.

 Rehabilitation of openings create by removal of blocks, should the project not be feasible such that there is no need to apply for a mining licence.

 Stockpile the topsoil to have a seedbank for reclamation works to restore the environment to as close to its original state as possible

Air Quality (Dust and Air pollution  Must ensure that all vehicles are properly serviced so Proponent & Throughout the Gases) that they do not give off harmful gases EM exploration phase  A speed limit of 60km/h for light vehicles and 30km/h for heavy vehicles must be maintained onsite to minimise the dust generated by vehicles.

 Implement a penalty system for speeding onsite.

Page 19 Environmental Aspect Impact Management Actions Responsibility Timeline  Ensure that dust generation is kept at an acceptable ECO & EM Throughout the level, by using existing roads and avoiding driving exploration where possible. phase

 Dry dust suppression methods such as reasonable amount of water should be employed to minimise dust generation.

 Ensure that dust collectors or buckets are used to capture some of the dust generated by cutting and drilling

 Exploration vehicles and trucks must not be left idling on site when not in use, to minimize gas emissions.

 Drill equipment should be regularly maintained to ensure drilling efficiency and so reduce dust generation.

 Device a dust monitoring programme and compile inhouse monthly air quality reports and quarterly ones for submission to MEFT

Noise Impact of noise on the  Noisy equipment such as drill rigs should be shut down ECO & EM Throughout the environment, the when they are not in use (when not needed) to avoid exploration workers, and the unnecessary noise on site. phase surrounding community  Ensure that workers performing noisy tasks equipped

Page 20 Environmental Aspect Impact Management Actions Responsibility Timeline with personal protective equipment (PPE) such as earplugs to reduce noise exposure

 Employ a regular rotation of workers (work on shifts) to avoid exposing them to excessive noise for a long period of time in a day.

 Vehicles and machinery must be well serviced and lubricated to reduce noise

 To limit the noise from vehicles, drilling and cutting equipment as well as the movement of vehicles, test mining works should be limited to or only be done between 08h00 and 17h00.

Visual Aspects Visual impact (Impact  Rock shading of areas used for test mining, to ECO & EM Throughout the on Sense of Place) temporarily reduce visual impact before rehabilitation exploration phase  Ensure that should the project not be feasible, such that work is discontinued, the blocks extracted for testing must be returned to site for backfilling of openings and for use in the rehabilitation process.

Vehicular Traffic Vehicular traffic safety  Trucks delivering water to the exploration site must Proponent Throughout the have a scheduled time for travelling to and from site exploration so that they do not interfere with daily traffic in the phase area

Page 21 Environmental Aspect Impact Management Actions Responsibility Timeline  Abnormal vehicles carrying drilling equipment or granite blocks must be well equipped with visible signages to caution other drivers.  The Proponent should make provision for safe materials and equipment offloading and loading areas on sites.  Vehicle drivers should adhere to the road safety rules and speed limits. A speed limit of 60km/h for light vehicles and 30km/h for heavy should be maintained onsite.

 All drivers of the project vehicles should be in possession of valid and appropriate driver’s licenses to operate such vehicles.

 Vehicles drivers should not be allowed to operate vehicles while under the influence of alcohol.  There should be sufficient parking area on site for all project vehicles should be provided for and clearly demarcated on sites.  No heavy trucks or project related vehicles should be parked outside the project site boundary or demarcated areas for such purpose.

 Project vehicles should be in a road worthy condition and serviced regularly to avoid accidents because of mechanical faults of vehicles

 Site access roads should be provided for in such ways

Page 22 Environmental Aspect Impact Management Actions Responsibility Timeline that they do not interfere with other traffic movement and/or compromise traffic safety on the host farms

Health and Safety of Impact on Health and  Workers must be equipped with personal protective ECO Throughout the workers Safety of workers equipment (PPE) such as coveralls, gloves, safety exploration boots, safety glasses and hard hats always on work phase sites.

 Arrange for trainings so that the workers are provided with sufficient training on how to handle different machinery and equipment.

 Ensure that workers only operate within their designated areas and only operate machinery they have been trained to use

 No workers should be allowed to drink alcohol during working hours.

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

 General vehicles should have designated parking, well away from the rigs so that it is safe

 Employees should be sourced locally, to avoid transmission of infectious diseases.

Page 23 Environmental Aspect Impact Management Actions Responsibility Timeline  An emergency preparedness plan should be compiled, and all personnel appropriately trained.

 Equip site with firefighting equipment (such as fire extinguishers) so that they are readily available for use in case of a fire.

 Worked out areas must be demarcated and fenced off to keep people out until they can be rehabilitated

 All employees must be aware of the assembly point in case of emergency.

 Fires and cooking places must be well away from the diesel storage trailers.

Socio-economic  Proponent must prioritise the locals for employment to Proponent Throughout the aspects empower local community and only if necessary and exploration due to lack of skills in the area, out-of-area people phase can be given some of the work

 The locals to be employed during the project phases should be provided with the necessary training of skills required for the project to avoid bringing in many out- of-area employees. Capacity building must involve transfer of more sophisticated skills and not only unskilled labour.

Page 24 Environmental Aspect Impact Management Actions Responsibility Timeline  Consumable project needs such as PPE, spare parts for machinery and lubricants must be sourced from local businesses

 The workers should be engaged in health talks and training about the dangers of engaging in unprotected sexual relations which results in contracting HIV/AIDS and other sexual related infections.

 Out-of-area workers that may be employed (due to their unique work skills) on site should be sensitized on the importance of respecting the local values and norms, so that they can co-live in harmony with the local communities during the duration of their employment on site

Archaeology and Disturbance of ECO and Throughout the  The area recommended for exclusion (the Trekkopje heritage archaeological and Battlefield or No-Go zone) must be excluded from all Exploration exploration heritage sites exploration activities, unless a detailed Manager phase archaeological study has been undertaken to clear the area of archaeological importance.

 The layout of access routes going through the “No- Go” area must be submitted to the NHC for verification and approval before they can be constructed.

Page 25 Environmental Aspect Impact Management Actions Responsibility Timeline  Field camps and other related infrastructure should be constructed outside the No-Go area.

 Caution should be exercised when carrying out excavations associated with the exploration activities if archaeological/heritage remains are discovered  Identified of any archaeological significant objects on the site should not be disturbed but are to be reported to the project Environmental/Safety officer or National Heritage Council offices for further instructions and actions.  Workers should be educated to not destroy or throw away but report (to the environmental/Safety officer) of any unknown object found/discovered on site.

 Personnel should be informed not to destroy, damage, remove or throw away any unknown objects found/discovered on site during operations,

 If any archaeological materials are found, the National Heritage Council’s Chance Find Procedures should be followed. Furthermore, the foreman, through the Exploration Manager onsite should be notified, and all on-site activities stopped immediately.

 ECO must establish good relations with the National Heritage Council and familiarise themselves with procedure of reporting discovered heritage or

Page 26 Environmental Aspect Impact Management Actions Responsibility Timeline archaeological sites.

Page 27 4 ENVIRONMENTAL MONITORING AND PERFORMANCE ASSESSMENT

To aid the prevention and minimize the above-mentioned environmental impacts, and also ensure EMP implementation, site monitoring measures need to be implemented. The monthly exploration budget must also make provision for these measures.

4.1 Monitoring programmes 4.1.1 Dust monitoring A dust monitoring network must be setup, focusing on areas that potentially generate dust. These are for example near access roads as well as in the vicinity of drilling and cutting areas.

 Air quality monitoring equipment must be set up and dust monitoring reports must be produced monthly (for use inhouse) and quarterly air quality reports for submission to MEFT.

4.1.2 Monitoring for soil pollution This will primarily entail inspections and look out for dark spots of oils and petrofuels on the premises. It will also address evidence of erosion onsite.

 Surrounding soils must be inspected daily to ensure that there are no spills on the soils and to allow for a timely reaction (soil removal and replacement) in cases where spills are noticed.

 The parking area for the trailer housing the fuel tank must be inspected daily.

4.1.3 Fauna and flora inventory Draw up a flora and fauna inventory, including their sensitivity and status of endemism. This will aid identification of sensitive fauna and flora and will inform the handling procedure to ensure their preservation.

4.2 ENVIRONMENTAL AWARENESS PROGRAMME 4.2.1 Induction Comprehensive induction is a critical component during exploration works. This includes the following:

 Ensuring that all employees are aware of their individual impact on the environment.

 Ensuring that employees are aware of the measures and procedures to be followed should ecologically sensitive, culturally sensitive, or historically sensitive sites be detected.

Page 28  Ensure that employees are aware of the measures and procedures to be followed should an environmental impact (such as a hydrocarbon spill, etc.) take place.

4.2.2 On the job training This refers to ongoing training on aspects pertaining to the project. Employees must receive on the job training on ad-hoc.

4.2.3 Inhouse communication The ECO together with the site foreman must hold daily caucus with the workers at the beginning of every shift to give them a refresher on safety aspects. This will also allow them to report incidents from the previous shift. Hold safety, health, and environment (SHE) meetings that include the environment.

4.3 Environmental emergency preparedness Environmental emergencies are those that occur over a short term and require an immediate response. Considering this urgency an effective, comprehensive, well- considered and tested Environmental Emergency Preparedness and Response Plan has the potential to save lives, prevent unnecessary damage to the company and other property. Therefore, Best Cheer must device an Environmental Emergency Preparedness and Response Plan and disseminate it to all its employees and contractors. It should include crucial service providers that should be contacted in a case of emergency.

 Fire department.

 Police.

 Emergency health services such as ambulances, paramedic teams.

 Hospitals, both local and further afield, for specialist care.

 Public health authorities.

 Environmental agencies, especially those responsible for air, water, and waste issues.

 Public works and highways departments, port; and

 Public information authorities and media organizations.

5 CONCLUSION

This Environmental Management Plan (EMP) the management measures that must be implemented to mitigate the environmental impacts of the proposed activities.

Page 29 The EMP is a legal document, which commits the applicant to comply with all management measures, monitoring programmes and the Environmental Emergency Preparedness and Response procedure other plans as presented herein.

The effective implementation of the recommended management actions (mitigation measures) will see the significance reduction in impacts’ significance (that cannot be avoided) from medium to low as well as maintaining the low rating of impacts. The Proponent together with the Environmental Control Officer and the rest of the team must strive to implement these measures and monitor each component, so that the identified impacts can be minimized and other impacts that might arise during project can be detected in a timely manner. Therefore, the issuance an Environmental Clearance Certificate (ECC) will be on condition that the recommendations and impact mitigation measures in this report and all the provisions in the EMP are adhered to.

Page 30 L. Uulenga 04/06/2020 Author Date

Page 31

APPENDIX I – GROUNDWATER STUDY REPORT FOR EPL 5161

Desktop Groundwater Impact Assessment (DGIA) for the Proposed Exploration Activities on Exclusive Prospecting License (EPL) 5161 near Arandis Town in the Erongo Region

Document Version: Final

Proponent: Best Cheer Investments Namibia (Pty) Ltd

Date: 01 August 2020

July 2020 Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

DOCUMENT INFORMATION Title: Desktop Groundwater Impact Assessment (DGIA) for the Proposed Exploration Activities on Exclusive Prospecting License (EPL) 5161 near Arandis Town in the Erongo Region

Prepared on behalf of Omavi Geotechnical & Geo-Environmental Consultants by:

Author: Fredrika N. Shagama Qualifications: PhD. Student: Civil Engineering (Geotechnics & Hydrogeology), VSB - Technical University of Ostrava, Czech Republic

MSc. Geological Engineering (cum laude) with primary focus in Hydrogeology, VSB - Technical University of Ostrava, Czech Republic

BSc. Geological Engineering, VSB - Technical University of Ostrava, Czech Republic

Professional Affiliations: International Association of Hydrogeologists (IAH) - Full (online) Member, Membership No.139790

Namibian Hydrogeological Association (NHA) – Member

Environmental Assessment Professionals of Namibia (EAPAN) - Ordinary Member Practitioner (Membership No. 183)

Signature:

Date: 01 August 2020

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

EXECUTIVE SUMMARY Best Cheer Investments Namibia (Pty) Ltd (hereinafter referred to as Best Cheer Investments Namibia or the Proponent) intends to undertake exploration activities on Exclusive Prospecting License (EPL) 5161 near Arandis in the Erongo Region (the project). The EPL is located about 15 km northeast of the Arandis Town. And covers a surface area of 5 058 hectares (ha). Potential commodities on EPL 5161 include base and rare metals, dimension stone, nuclear fuel mineral and precious metals. However, for the purpose of this project only dimension stone exploration has been applied for and on which this study has been conducted.

The proposed exploration is however among the listed activities in the Environmental Management Act (EMA) No. 7 of 2007 and its 2012 Environmental Impact Assessment (EIA) Regulations that may not be undertaken without getting the environmental clearance certificate (ECC). Consequently, the Best Cheer Investments Namibia (Pty) Ltd appointed Omavi Geotechnical & Geo-Environmental Consultants CC (hereinafter referred to as Omavi Consultants) to undertake the required EIA process and apply for the project ECC.

To ensure that all the significant environmental components are considered as part of the EIA study, Omavi Consultants subcontracted Ms. Fredrika Shagama (an independent Hydrogeologist) to undertake a desktop impact assessment study for one of the physical environmental components (groundwater), i.e. a geohydrological/hydrogeological assessment for the proposed project.

It is for this reason, that this desktop groundwater impact assessment report was compiled. The aim of the report was to determine the possibility/likelihood and extent of groundwater being impacted by the proposed exploration activities, assess the potential impacts, and provide the necessary practical measures to manage avoid and or minimize their significance.

RECOMMENDATIONS AND CONCLUSIONS

The aim of this report was to assess the potential impacts of the proposed exploration activities on the groundwater resources. The assessment has been undertaken on a desktop level, i.e. based on information provided by Omavi Geotechnical & Geo-Environmental Consultants (the project Environmental Assessment Practitioner/Consultant) obtained from their own site visit, information provided by the project proponent, author’s professional judgment complemented by experience as well as review of previous relevant studies conducted within proximal distance from the project.

The recommendations provided to the assessment and conclusions made are as follows:

Recommendations

Given the assessment results, to manage and protect the groundwater resources in the project area, the following management measures should be implemented: ii

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

Given the assessment results, to manage and protect the water resources, the following management measures should be implemented:

Groundwater Abstraction and Use Mitigation Measures

 Please note that it is unlikely that a Groundwater Abstraction and Use permit (license) would be required, therefore not significant. This is firstly because the Proponent will not be abstracting water directly from an aquifer but carted to site and secondly during the exploration, the activities will not be yielding any income i.e. not commercially valuable yet. Water use is limited to exploration activities only which is short-term. With this said, it will be very crucial for the Proponent to adhere to the actual water volumes required for the exploration activities even if they will not be abstracting directly from site boreholes.

 The water user (Proponent) should consider voluntary water use reduction by sticking to the proposed daily threshold volume of 5 m3 or 5 000 litres, which is 155 000 litres per month (5 000 litres x 31 days = 155 000 litres or 155 m3). This amounts to 1 860 000 litres or 1 860 m3 per year (155 m3 x 12 months).

 Sufficient water from outside the area should be carted to site on certain days and stored in onsite water tanks. This is to ensure the Proponent’s water trucks are not traveling on the local and regional roads everyday which would exert pressure on and impact the services infrastructure such as roads during water transportation. This is to avoid taking from the outside area water supply line in Swakopmund or Karibib in large amounts every day and put unnecessary pressure on the main regional groundwater scheme supplies.

 Given the indication that some abstraction from the saline borehole at Trekkopje mine may occur to supplement carted water for exploration, if ‘’push comes to shelf’’, the water abstracted from the borehole should also be used efficiently and enough should be abstracted just enough to augment the carted water. For instance, if the carted water can supply 3 000 litres (3 m3) then the borehole can supply the remaining 2 000 litres (2 m3) of the required volume, but only when deem necessary.

 The Proponent should implement water reuse/recycling methods as far as practicable. Water used to cool off exploration equipment should be captured and used for the cleaning of equipment if possible.

 Water conservation awareness and saving measures training should be provided to all the project workers so that they understand the importance of conserving water and become accountable.

Groundwater Pollution Mitigation Measures

iii

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

 Exploration site areas where hydrocarbons will be utilized, the surface should be covered with an impermeable plastic liner (e.g. an HDPE liner), carefully placed so as to minimize risk of puncturing, to prevent any spillages from getting into direct contact with the soils and prevent eventual infiltration into the ground.

 Project machines and equipment should be equipped with drip trays to contain possible oil spills when operated during exploration works.

 All wastewater and hydrocarbon substances and other potential pollutants associated with the project activities should be contained in designated containers on site and later disposed of at nearby approved waste sites in accordance with MAWLR’s Water Environment Division standards on waste discharge into the environment. This is to ensure that these hazardous substances do not infiltrate into the ground and affect the groundwater quality.

 In cases of accidental fuel or oil spills on the soils from site vehicles, machinery and equipment, the polluted soil should be removed immediately and put in a designate waste type container for later disposal as per the preceding bullet point. The removed polluted soil should either be completely disposed of or cleaned and returned to where it was taken from on site or can be replaced with a cleaner soil. This is to ensure that the pollutants contained int the soil does not infiltrate into the site soils and eventually reach to groundwater.

 Although fuel (diesel) required for exploration equipment will be stored in a tank or tanks mounted on a mobile trailer, drip trays must be readily available on this trailer and monitored to ensure timely cleanup of accidental fuel spills along the tank trailer path/route around the exploration sites. This all aimed at preventing accidental fuel spills or leaks from spreading to the soil and eventually to groundwater.

 Spill control preventive measures should be in place on site to management soil contamination, thus preventing and or minimizing the contamination from reaching groundwater bodies. Some of the soil control preventive measures are:

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

o Maintain a fully provisioned, easily accessed spill kit. Spill kits should be located throughout the active project sites contain the floor dry absorbent material and absorbent booms, pads, mats. These would be suitable for ground surface areas that are covered mainly by hard rocks. o All project employees should be made aware of the impacts of soil pollution and advised to follow appropriate fuel delivery and handling procedures. o Develop and prepare countermeasures to contain, clean up, and mitigate the effects of an oil spill. This includes keeping spill response procedures and a well- stocked cache of supplies easily accessible. o Ensure employees receive basic Spill Prevention, Control, and Countermeasure (SPCC) Plan training and mentor new workers as they get hired in each phase of the project.

Conclusions

Water abstraction (use): Water abstraction (use): The impact on local groundwater resources (abstraction) will be none because no groundwater will be abstracted from the local aquifers of the project magnitude (small to medium as the required water will be carted into the area. Therefore, the impact on groundwater resources (quantity) from the exploration activities is non-existent, provided that the Proponent strictly uses carted water and not abstract from the local boreholes.

Water pollution: As it is common with every new and existing project, ground surface pollution is anticipated from the project operations and related activities. This potential pollution would be from improper disposal of hazardous products such as hydrocarbons (fuel/oils) and effluent from exploration works on site. The geology of the project area would make the groundwater less vulnerable to pollution from the surface due to the type (igneous and metamorphic rocks) and nature (unfractured/faulted) of rocks would inhibit further spreading pollution of potential pollutants in the water. The avoidance of pollution from reaching the ground surface (into groundwater) and effective implementation of pollution management plans will greatly aid in minimizing groundwater pollution. The impact is therefore considered low (minimal) to slightly moderate and according to the Groundwater Resources Vulnerability to pollution Map, the general site area has a rather low and, in some parts, moderate risk of pollution.

Furthermore, the potential pollution impact is short-term (short lifespan), as it will only be existing during the duration of exploration activities, which means that the impact will be only limited to the duration of the proposed activities.

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

In conclusion, the proposed project activities will not impact the local groundwater resources therefore the impacts’ significance will be none for water quantity (no direct abstraction from local boreholes) and low to slightly medium (for water quality). Therefore, it is vital for the Proponent and their contractors (if any) to effectively implement and monitor the recommended management measures to protect both the biophysical and social water environment. All these would be done with the aim of promoting environmental sustainability while ensuring a smooth and harmonious existence and purpose of the project activities in the hosting biophysical and social environment.

To protect groundwater, it is necessary for different water users in societies to recognize that water resources are finite and vulnerable and find ways to reconcile the demands of human activities with the tolerance of nature. The essential first step to making water use sustainable is awareness and knowledge of human impacts on the environment, specifically on water resources. This will not only be applicable to the project proponents but also members of the public who may have been living in the area prior to developments, such as the proposed exploration.

The Proponent will also be required to ensure that all their activities comply with the legislation governing their project activities with respect to groundwater resources management and protection.

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

TABLE OF CONTENTS DOCUMENT INFORMATION ...... i EXECUTIVE SUMMARY ...... ii TABLE OF CONTENTS ...... vii LIST OF FIGURES ...... viii LIST OF TABLES ...... ix LIST OF ABBREVIATIONS ...... ix 1 INTRODUCTION ...... 1 1.1 Brief Project Background and Location ...... 3 2 TERMS OF REFERENCE, SCOPE OF WORKS AND LIMITATIONS ...... 5 2.1 Terms of Reference for the Study ...... 5 2.2 Scope of Works...... 5 2.3 Limitations of the Study ...... 5 3 APPROACH AND METHODOLOGY ...... 6 3.1 Desktop (Baseline) Study ...... 6 3.2 Impact Assessment Methodology ...... 6 3.2.1 General Concept of Impact (Risk) Assessment ...... 6 3.2.2 Impact Assessment Criteria ...... 7 3.2.3 Impact Significance ...... 9 3.3 Reporting ...... 10 4 LEGAL FRAMEWORK FOR WATER RESOURCES MANAGEMENT AND PROTECTION 10 4.1 Applicable National Legal Framework ...... 10 5 DESCRIPTION OF THE (RELEVANT) RECEIVING ENVIRONMENT ...... 12 5.1 Climate and Topography ...... 12 5.2 Soil and Geology...... 14 5.3 Hydrology and Catchments ...... 17 5.4 Hydrogeology ...... 17 5.4.1 Groundwater Recharge ...... 18 5.4.2 Baseline Groundwater (Borehole) Yields and Levels ...... 19 5.4.3 Groundwater Quality ...... 20 5.4.4 Vulnerability of Groundwater to Over-abstraction ...... 22 5.4.5 Vulnerability of Site Area groundwater resources to Pollution ...... 23 5.5 Vegetation...... 24 6 EXISTING AND PROPOSED WATER ABSTRACTION AND USE ...... 25 vii

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

6.1 Existing Groundwater abstraction and Use ...... 25 6.2 Proposed Water abstraction and Use for the Project Activities ...... 26 7 SUB-CATCHMENT DELINEATION ...... 27 8 GROUNDWATER IMPACTS: DESCRIPTION AND ASSESSMENT ...... 29 8.1 General Concept of Impact (Risk) Assessment ...... 29 8.2 Groundwater Impact Assessment (Over-abstraction) ...... 29 8.2.1 Brief Impact Description – Water Quantity ...... 30 8.3 Groundwater Impact Assessment (Pollution) ...... 31 8.3.1 Brief Impact Description – Water Quality ...... 31 8.3.2 Pollution Impact Assessment ...... 32 9 GROUNDWATER MANAGEMENT MEASURES ...... 34 9.1 Groundwater Abstraction Management Plans ...... 35 9.2 Groundwater Pollution Management Plans ...... 36 10 RECOMMENDATIONS AND CONCLUSIONS ...... 37 10.1 Recommendations ...... 38 10.2 Conclusions ...... 40 11 REFERENCES LIST ...... 42

LIST OF FIGURES Figure 1: Location of the EPL 5161 (project site) near Arandis in the Erongo Region ...... 4 Figure 2: The spatial distribution of potential evaporation in Namibia (after BGR, 2005)...... 13 Figure 3: The rainfall patterns for the Arandis area (source: World Weather Online, 2020) ....13 Figure 4: The maximum, minimum and average temperature Arandis area (source: World Weather Online, 2020) ...... 13 Figure 5: Geological features of the project area as presented with regards to the Omdel Aquifer (edited after Matengu et al, 2019) ...... 15 Figure 6: Approximate geological section (map) and Legends of the project site area extracted from a 1:250 000 geological sheet ...... 16 Figure 7: Hydrogeological map of Namibia with rock bodies groundwater potential with the approximate location of project site indicated by the light green arrow on the map ...... 18 Figure 8: Recharge zones derived from annual rainfall map (DEA, 2002), after Winker (2010) 19 Figure 9: Location of the sampling points for the 2010 Khan-Swakop River Catchment groundwater quality assessment (edited after Kringel et al, 2010)...... 21 Figure 10: Spatial distribution of Electrical Conductivity (EC) at the sampled area (Kringel, 2010) 22 Figure 11: Vulnerability of groundwater resources to Pollution (Van Wyk et.al, 2001)- approximate project site area enclosed by the light green circle ...... 24 Figure 12: Sub-catchment delineation map for the EPL site area ...... 28

viii

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

LIST OF TABLES Table 1: Impact assessment criteria ...... 7 Table 2: Impact significance rating scale ...... 9 Table 3: Assessment of the project impact on water resources abstraction (quantity) ...... 31 Table 4: Assessment of the project impact on groundwater resources (quality) ...... 34

LIST OF ABBREVIATIONS °C: Degree Celsius

µS/cm: microsiemens per centimetre

ArcGIS: A geographic information system for working with maps & geographic information

BGR: Bundesanstalt für Geowissenschaften und Rohstoffe (The Federal Institute for Geosciences and Natural Resources of the Republic of Germany)

CC: Close Corporation

DEM: Digital Elevation Model

DGIA: Desktop Geohydrological (Groundwater) Impact Assessment

DWA: Department of Water Affairs

EC: Electrical Conductivity

EEA: European Environmental Agency

EIA: Environmental Impact Assessment

EMA: Environmental Management Act

EMP: Environmental Management Plan

EPL: Exclusive Prospecting License

HDPE: High Density Polyethylene km: kilometre km2: square kilometre m: Metres m3: Cubic metre m3/day: cubic metre per day m3/h: cubic metre per hour m3/year: cubic metre per year (annum)

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161 mm/a: millimetre per annum (year)

Mm³: Million cubic metres

Mm3/a: Million cubic metres per annum (year) mS/m: Millisiemens per metre

NamWater: Namibia Water Corporation Limited (The National Bulk Water Supplier)

OMDEL/Omdel: Omaruru Delta Aquifer

S-P-R: Source-Pathway-Receptor

SPCC: Spill Prevention, Control, and Countermeasure

TDS: Total Dissolved Solids

TOR: Terms of Reference

Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161

1 INTRODUCTION Mining is the backbone of the Namibian economy constituting about 9.3% contribution to Gross Domestic Product (GDP). About 52.7% of export-earnings from mining were recorded in the Chamber of Mines’ 2013 Annual Report. Other sectors contributing to the GDP include fisheries, agriculture, and tourism (Mweemba, 2014). Minerals extracted in Namibia range from diamonds, uranium, base metals (copper, lead, zinc, etc.), gold, industrial minerals (sand, limestone, and graphite), dimension stones (marble, dolerite) and semi-precious stones/gemstones. Some listed minerals and stones are either mined at a small, medium, or large-scale level, depending on the; ore deposit, specimen size sought after, available resources and geological extent, etc.

The exploration and mining activities of these above-mentioned minerals groups (mainly preceded by exploration activities) usually to certain extents require the use of water to fully operate. Like any other type development (activity), exploration and mining activities usually comes with positive impacts such as income generation, employment creation, contribution to local and regional socio-economic development as well as the country’s revenue through taxes and royalties by the project owners (Proponents). However, these activities also associated with some negative (adverse) environmental issues. If these issues (impacts) are not well understood prior to project implementation and enable their timely avoidance or significance reduction, they can potentially harm both the physical and social environment or its components during the project lifecycle. One of the vital environmental physical components that can be potentially impacted by the exploration activities is water resources, particularly groundwater.

Groundwater is one of the most valuable yet vulnerable natural resources for people, animals, and the general environment owing to sudden adverse changes in the water systems. Therefore, affecting water resources systems and overall natural environment functionality. It is, therefore, very crucial to understand the impacts of proposed (new) projects on groundwater, in terms of over-utilization (over- abstraction) and pollution (quality). Groundwater over-abstraction does not only result in aquifer depletion and water-quality degradation, but also impacts the ecological integrity of streams and wetlands, resulting in significant losses of habitat and biodiversity. This impact is felt more in semi-arid and arid areas with high water demand and low rainfall (limited groundwater recharge) compared to humid areas. In other words, although water scarcity often happens in areas with low rainfall, human activities aggravate the problem particularly in areas with high population density, tourist inflow, intensive agriculture and other water demanding industries.

Over abstraction of groundwater leads to water scarcity, whereby there is insufficient water resources to satisfy long-term average requirements. According to the European Environmental Agency (EEA) (2018), water scarcity refers to long-term water imbalances, combining low water availability with a level of water demand exceeding the supply capacity of the natural system. Water scarcity is driven primarily by two factors:

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 Climate, which controls the availability of renewable freshwater resources and seasonality in water supply, and  Water demand, which is largely driven by population and related economic activities

With every new project planned for in the society (natural and social environment), it is vital that all possible impacts on water resources from such developments’ activities are considered, how to prevent them and or minimize their significance (if avoidance is impossible) and come up with practical mitigation measures. All this is done to ensure that the projects and development activities run in an environmentally and socially manner to ensure sustainability, while maximizing the positive impacts (benefits) of the projects.

This document aims to confirm, assess potential impacts on groundwater resources associated with the proposed exploration activities in the Erongo Region, inland of the west coastal side of Namibia, and provide mitigation measures to avoid and or minimize the significance of these impacts.

With that in consideration and commitment to continue operating to generate income, positively impact the lives of Namibian citizens (through employment) and economic development to the Erongo Region and Namibian nation, as one of the dimension stone exploration companies in Namibia, Best Cheer Investments Namibia intends to continue with their line of operations, which is exploration. They intend on doing this by exploring on prospective target areas of an exclusive prospecting license (EPL).

For Namibia, water resources are protected under Water Act (1956) and the new Water Resources Management Act (2013). Water resources protection and management is also listed under the Environmental Management Act No. 7 of 2007 and its 2012 Environmental Impact Assessment (EIA) Regulations as one of the activities that may not be undertaken without an environmental clearance certificate (ECC). Most importantly for this project, the EMA also made provision for ECC abstraction and use of groundwater for commercial purposes (only for mining activities to be specific, since it is when project owners/proponents start to make profit from selling the mined commodities). The EMA requirements would include a condition for the proponents to apply for and obtain groundwater abstraction and use permit from the Department of Water Affairs. However, with that said, exploration activities would not require such a permit.

To ensure that all the significant environmental components are considered and to satisfy the requirements by both the Proponent and public (public consultation requests), as part of the main EIA study, Omavi Geotechnical & Geo-Environmental Consultants(the project Environmental Consultants) subcontracted Ms. Fredrika Shagama (an independent Hydrogeologist) to undertake a desktop groundwater (hydrogeological) assessment for the proposed project activities.

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It is for this reason, that this desktop groundwater impact assessment report was compiled. The aim of the report was to determine the possibility of groundwater being impacted by the proposed exploration activities on the EPL, assess the potential impacts, and provide the necessary management measures to reduce the significance of these impacts.

1.1 Brief Project Background and Location The Namibian water resources are protected by the old Water Act No. 54 of 1956 and the new unpromulgated Water Resources Management Act No. 11 of 2013, that require that a water abstraction and use permit should be obtained for every commercial water use. The abstraction and use of water resources (groundwater) is also listed under the Environmental Management Act No. 7 of 2007 and its 2012 Environmental Impact Assessment (EIA) Regulations as one of the activities that may not be undertaken without an environmental clearance certificate.

It is for these legal reasons that Best Cheer Investments Namibia (Pty) Ltd (hereinafter referred to as Best Cheer Investments Namibia or the Proponent) appointed Omavi Geotechnical & Geo-Environmental Consultants CC (hereinafter referred to as Omavi Consultants) to undertake the required environmental assessment for their proposed exploration activities on Exclusive Prospecting License (EPL) 5161 located about 15 km northeast of the Arandis Town in the Erongo Region (the project) - Figure 1. Potential commodities on EPL 5161 include base and rare metals, dimension stone, nuclear fuel mineral and precious metals. However, for the purpose of this project, only dimension stone has been applied for and the reason for this study. The EPL covers a surface area of 5 058 hectares (ha). Best Cheer Investments Namibia intends to undertake exploration activities on the EPL. It should be noted that this document only covers the exploration phase activities.

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Figure 1: Location of the EPL 5161 (project site) near Arandis in the Erongo Region

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2 TERMS OF REFERENCE, SCOPE OF WORKS AND LIMITATIONS

2.1 Terms of Reference for the Study There was no formal Terms of Reference (TOR) provided by Omavi Consultants. However, this document has been prepared as guided by their requirement for the water resources component as part the main project Environmental Impact Assessment (EIA). The water resources impact assessment covered in this report primarily deals with the potential impacts of the proposed exploration activities on groundwater resources on site and in the immediate areas.

2.2 Scope of Works The scope of work for this study is limited to the water resource impact assessment with a cursory look at the project impacts on groundwater in terms of quantity (abstraction) and quality (pollution). The scope of works for this study is presented below:

 Baseline assessment (desktop study) of existing site information as provided by Omavi Consultants and general literature on the broader area in relation to the proposed project site and overall project activities.

 A review and brief presentation of legislation that governs water resources management and protection in Namibia.

 A description of the physical conditions; climatic, pedological (soil), geological, hydrological (surface) and hydrogeological (groundwater) conditions of the project site area.

 The proposed (future) water abstraction for the project activities.

 Determination/estimation of the groundwater rapid (desktop) reserve of the project area and sustainable (abstractable) water volume per day (and year); and

 Identification of the potential impacts from the proposed project activities on groundwater resources, their descriptions, assessment, and recommendations on mitigating these impacts.

2.3 Limitations of the Study The following assumptions apply to this assessment:

 This report has been compiled on a desktop level i.e. no detailed fieldwork/site visit was conducted by the Author for this assessment. The project specific information used in this document is as provided by Omavi Consultants from the Proponent.

 The Author assumes that all the project information and data provided by Omavi Consultants and the Proponent is correct and accurate, and that all necessary information has been disclosed.

 It is also assumed that the relevant information obtained from different literature consulted is accurate; and

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 The report has been compiled on an assumption that there will be no significant changes to the proposed activity or the affected water environment between the time of compiling this report and implementation of the proposed project activities that could substantially influence findings of this document. It is also assumed that there will be no significant changes to the project activities that could substantially influence the mitigation measures given and recommendations made for the management and protection of groundwater resources.

The methodology employed for this study (assessment) is presented under the following chapter.

3 APPROACH AND METHODOLOGY To ensure that the requirements of the study addresses the main issues, the following methods and tasks have been employed to aid in undertaking a concise assessment and to make informed decisions.

3.1 Desktop (Baseline) Study For this study, an analysis of existing project information as presented by Omavi Consultants and Proponent and reviewing of literature and legislation relevant to the study (baseline assessment) were undertaken. This review entails reports containing information on the area geology, soil, climate, and hydrology. Other existing reports of similar or related studies conducted in the area were also reviewed. This also entailed the review of relevant books in the field of hydrogeology that significantly contribute to the study.

3.2 Impact Assessment Methodology The potential impacts of the project activities on the groundwater resources has been described and presented as per criteria presented under section 3.2.1 and section 3.2.2, respectively and in detail under Chapter 8 (impacts’ description and assessment). The mitigation (management) measures to avoid or minimize these potential impacts are provided under Chapter 9.

The methodology used to assess and determine the significance of the potential project impacts on the water resources is as explained below.

3.2.1 General Concept of Impact (Risk) Assessment Generally, an environmental risk occurs when there is a hazard (e.g. process, activity, or substance) that can result in a harmful impact on the surrounding environment. The part of the environment which is, or could be, affected is known as a receptor. Receptors include humans, flora and fauna, the built environment and water resources (controlled waters).

According to SRK (2006), the presence of a hazard alone does not constitute a risk; a risk is only present if there is a means by which the hazard can impact on sensitive receptor(s). The connection between the hazard and receptor is known as a pathway, and all three elements together.

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

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 Source: The cause or source of the contamination.

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

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

A pollutant linkage occurs when a source, pathway and receptor exist together (Booth, 2011). The objective with the mitigation measures is to firstly avoid the risk and if the risk cannot be avoided, mitigation measures to minimize the impact are then recommended. Once the mitigation measures have been applied, the identified risk will be of low significance, provided there is sufficient monitoring of measures’ implementation.

3.2.2 Impact Assessment Criteria The methodology employed for this assessment was adopted from typical environmental assessment reports based on research and analysis of other consultants’ reports on the suitable project assessment methodology.

The proposed exploration activities will likely to some scale/extent (spatial scale), magnitude (severity) and duration (temporal scale) have impacts on certain biophysical and social components. The potential impacts were assessed as per methodology presented in Table 1.

To enable a scientific approach to the determination of the environmental significance, a numerical value is linked to each rating scale. This methodology ensures uniformity and that potential impacts can be addressed in a standard manner so that a wide range of impacts are comparable.

It is assumed that an assessment of the significance of a potential impact is a good indicator of the risk associated with such an impact. The following process will be applied to each potential impact:

 Provision of a brief explanation of the impact.

 Assessment of the pre-mitigation significance of the impact; and

 Description of recommended mitigation measures.

Table 1: Impact assessment criteria

Nature Description Rating Extent (Spatial scale) An indication of the physical and Low (1): Impact is localized within the site spatial scale of the impact. boundary: Site only.

Low/Medium (2): Impact is beyond the site boundary: Local.

Medium (3): Impacts felt within adjacent

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Nature Description Rating biophysical and social environments: Regional.

Medium/High (4): Impact widespread far beyond site boundary: Regional

High (5): Impact extend National or over international boundaries.

Duration The timeframe, over which the Low (1): Immediate mitigating measures, impact is expected to occur, immediate progress measured in relation to the lifetime Low/Medium (2): Impact is quickly of the project. reversible, short term impacts (0-5 years)

Medium (3): Reversible over time; medium term (5-15 years).

Medium/High (4): Impact is long-term.

High (5): Long term; beyond closure; permanent; irreplaceable or irretrievable commitment of resources

Intensity, Magnitude / The degree or magnitude to which Medium/low (4): Low deterioration, slight Severity (Qualitative the impact alters the functioning of noticeable alteration in habitat and criteria) an element of the environment. The biodiversity. Little loss in species magnitude of alteration can either numbers. be positive or negative Low (2): Minor deterioration, nuisance or irritation, minor change in species / habitat / diversity or resource, no or very little quality deterioration.

Probability of occurrence Probability describes the likelihood Low (1): Improbable; low likelihood; of the impacts occurring. This seldom. No known risk or vulnerability to determination is based on previous natural or induced hazards. experience with similar projects Medium/low (2): Likely to occur from and/or based on professional time to time. Low risk or vulnerability to judgment natural or induced hazards.

Medium (3): Possible, distinct possibility, frequent. Low to medium risk or vulnerability to natural or induced hazards.

Medium/High (4): Probable if mitigating measures are not implemented. Medium risk of vulnerability to natural or induced hazards.

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Nature Description Rating High (5): Definite (regardless of preventative measures), highly likely, continuous. High risk or vulnerability to natural or induced hazards.

3.2.3 Impact Significance This is determined through a synthesis of the above impact characteristics (in Table 1 above). The significance of the impact “without mitigation” is the main determinant of the nature and degree of mitigation required. As stated in the introduction to this chapter, for this assessment, the significance of the impact without prescribed mitigation actions was measured.

Once the above factors (Table 1) have been ranked for each potential impact, the impact significance of each is assessed using the following formula:

SP = (magnitude + duration + scale) x probability

The maximum value per potential impact is 100 significance points (SP). Potential impacts were rated as high, moderate, or low significance, based on the following significance rating scale (Table 2).

Table 2: Impact significance rating scale

Significance Environmental Significance Points Colour Code

High (positive) >60 H

Medium (positive) 30 to 60 M

Low (positive) <30 L

Neutral 0 N

Low (negative) >-30 L

Medium (negative) -30 to -60 M

High (negative) >-60 H For an impact with a significance rating of high, mitigation measures are recommended to reduce the impact to a low or medium significance rating, provided that the impact with a medium significance rating can be sufficiently controlled with the recommended mitigation measures. To maintain a low or medium significance rating, monitoring is recommended for a period to enable the confirmation of the significance of the impact as low or medium and under control.

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

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3.3 Reporting All the information obtained from the project Proponent, site knowledge (by Omavi Consultants) and literature review have been analysed and consolidated into this document. The information includes physical settings/conditions of the area, relevant maps, water resources, impact assessment, and recommendations on water resources management and protection. The recommendations made herein will be incorporated into the project Environmental Management Plan (EMP) by Omavi Consultants as the Environmental Assessment Practitioner.

The following chapter presents the national and international legal requirements that are applicable and relevant to this assessment and groundwater resources

4 LEGAL FRAMEWORK FOR WATER RESOURCES MANAGEMENT AND PROTECTION The project’s primary purpose entails the exploration of dimension stone and this will at some extent require the use of water. The exploration activities, depending on their operational scales and type can potentially have impacts on the water resources, specifically groundwater (in terms of quantity and quality). It is therefore necessary to consider the national legislations and legal requirements governing the water management and protection.

4.1 Applicable National Legal Framework The Namibian legislations that govern the use, management and protection of water resources and related activities are as follows:

 Water Act No. 54 of 1956: To consolidate and amend the laws relating to the control, conservation and use of water for domestic, agricultural, urban and industrial purposes; to make provision for the control, in certain respects, of the use of sea water for certain purposes; for the control of certain activities on or in water in certain areas; for the control of activities which may alter the natural occurrence of certain types of atmospheric precipitation; for the control, in certain respects, of the establishment or the extension of townships in certain areas; and for incidental matters.

 Water Resources Management Act No. 11 of 2013: This Act (Government Gazette 5367) has been passed by Parliament, but it has not yet been brought into force. The Regulations have been passed in December 2016 but have not yet been promulgated. Therefore, the Regulations of the 1956 Water Act still apply. The objectives of this Act are to ensure that the water resources of Namibia are managed, developed, used, conserved, and protected in a manner consistent with, or conducive to, the fundamental principles set out in relevant Sections.

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 Environmental Management Act No. 7 of 2007 and its 2012 Environmental Impact Assessment (EIA) Regulations: The Act aims at promoting sustainable management of the environment and use of natural resources. The Environmental Management Act (EMA) is broad; it regulates land use development through environmental clearance certification and/or Environmental Impact Assessments. The Act provides for the clearance certification for:

o ‘’Regulation 3.1 The construction of facilities for any process or activities which requires a license, right or other forms of authorization, and the renewal of a license, right or other form of authorization, in terms of the Minerals (Prospecting and Mining Acts), 1992 o Regulation 8.1 The abstraction of ground or surface water for industrial or commercial purposes."

 Soil Conservation Act No.76 of 1969: The Act makes provision for the prevention and control of soil erosion and the protection, improvement and conservation of soil, vegetation and water supply sources and resources, through directives declared by the Minister.

 The Water Policy: National Water Policy White Paper, August 2000 (this laid the basis for the new Water Resources Management Act).

The relevant baseline environment of the project site and surrounding broader area interest is presented under the following chapter.

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5 DESCRIPTION OF THE (RELEVANT) RECEIVING ENVIRONMENT The baseline (pre-project site conditions) information of a project area is crucial to one’s understand as it aids in undertaking a concise assessment and make informed conclusions on the proposed project’s impacts on environmental components, such as water resources. The baseline information (conditions) of the site area and broader area that are relevant to this assessment are briefly described below.

5.1 Climate and Topography According to African Planning Forum (2019), Arandis generally experiences all year healthy and bearable climatic conditions where warm days are followed by cool nights. Thus, Arandis can be considered to have a desert climate.

The spatial potential evaporation distribution in Namibia map is presented in Figure 2 with the project area being in the range of 3 200 to 3 400 mm/a. The location of the Arandis area being the nearest town to the EPL site is estimated by the red arrow (between Swakopmund and Usakos) on the western coastal part of Namibia.

Arandis Area

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Figure 2: The spatial distribution of potential evaporation in Namibia (after BGR, 2005)

The only rains fall during the summer months and on average most of this rainfall is experienced from February to April (African Planning Forum, 2019). In the past 10 years, the highest rainfall recorded for Arandis was 51 mm (in February 2011) – Figure 3. African Planning Forum (2019) further states that occasional thunderstorms however do occur turning the small river courses into fast flowing rivulets and flash flood conditions do occur. The average rainfall for the region over the long term is less than 100 mm per year but due to the erratic distribution, much of the area receives less than 50 mm per year.

Figure 3: The rainfall patterns for the Arandis area (source: World Weather Online, 2020)

The maximum temperatures recorded for the site area for the period of 2010 and 2020 range between 17°C and 27°C whereas the minimum temperatures range between 13°C and 21°C. The average temperatures between 13 and 19°C. These temperature components are shown in Figure 4 below.

Figure 4: The maximum, minimum and average temperature Arandis area (source: World Weather Online, 2020)

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With regards to topography, the town of Arandis is located some 581 metres above mean sea level. The area is characterized by undulating hills and sandy valley areas (Africa Planning Forum, 2019). In the Erongo Region, the land rises steadily from sea level to about 1,000 m across the breadth of the Namib. The Namib land surface is mostly flat to undulating gravel plains, punctuated with occasional ridges and isolated ‘inselberg’ hills and mountains (Southern African Institute for Environmental Assessment (SAIEA), 2011). Aurecon Environment and SLR Environmental Consulting (2014) further state that broad geomorphological characteristics include a shore of mixed sand and rock, with gravelly coastal plains in the study area, with the Arandis Mountain (just over 600 m high) further to the east and a narrow dune belt further to the south.

5.2 Soil and Geology According to GCS Water & Environmental Consultants (2017), the soils of Namib Desert are knowns as “syrosems” and calcareous soils. The syrosem soils were formed when solid rock is exposed, mainly broken down by mechanical weathering. Rock fragments and exfoliation chips gather around the outcrops, where they undergo further processes of weathering. The calcareous (from limestone) soils were formed during a pluvial period when a minimum of groundwater was available. The subsoil rises to the surface through capillary action and deposits the dissolved CaCO3 on evaporation, forming the deep soils. The texture of the Namib Desert soil is classified as coarse to moderately coarse. These soils are prone to collapse when disturbed

The geology of the central region is dominated by the Damara Sequence. This sequence underlies most of central and northern Namibia. The basal arenitic succession of the Nosib Group was laid down between 850 and 700 million years (Ma) ago. There is a large gap in the geological history of the central area after the Damara orogenesis. Sediments of the Karoo Sequence were deposited and largely eroded afterwards, except for some remnants preserved under volcanic rocks. In the early Cretaceous, the continental breaks up of South America and Africa caused widespread volcanic activity. From 180 to 120 Ma ago, basaltic lava erupted from deep-seated fissures and covered large parts of Namibia. Erosion has removed most of these sheet basalts, but their feeder channels are still present in the form of dolerite dykes (dolerite is a coarse-grained basalt). The north-north east striking dykes are found throughout the Namib Desert (Christelis and Struckmeier, 2011). A general geological setting of the project area (enclosed by a light green rectangle) is shown in Figure 5 below.

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Figure 5: Geological features of the project area as presented with regards to the Omdel Aquifer (edited after Matengu et al, 2019)

The geology of the area is also characterized by relatively flat light-brown sand, rocky and gravel plains of the Namib Desert with outcrops of granite and quartzite (GCS Water & Environmental Consultants, 2017). Although windblown sand is found along the foot of the dolerite ridges the topsoil found within the Arandis area generally comprise of gravel plains comprising of surface quartz gravels (Africa Planning Forum, 2019). Site observations indicated the presence of granite and calc- silicate outcrops.

The general geology map of the project site and surrounding areas is shown in Figure 6 with the approximate project area enclosed by the green ellipse.

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Figure 6: Approximate geological section (map) and Legends of the project site area extracted from a 1:250 000 geological sheet

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5.3 Hydrology and Catchments The site area does not have significant natural surface bodies such as rivers. According to Africa Planning Forum (2019), the only nearby surface water body is the Khan River, a prominent ephemeral river located south of the Arandis Town. The town therefore falls within the Kahn River catchment area of which in turn is part of the greater Swakop River catchment area. Further north of the town the catchment area of the Omaruru River is found. All these rivers are ephemeral and are dry for most parts of the year.

Given the proximity of the project site to the Town of Arandis, it is assumed that the site also falls within the same (Khan River) catchment. According to Strohbach (2008), the Khan River has a surface area of 8 399 274 km2. This River is located on the eastern side of the EPL, following a south- eastern southwestern trend.

5.4 Hydrogeology The project site is within the groundwater basin of the Central Namib-Windhoek Area, which according to Christelis and Struckmeier (2011) extends from Windhoek in the east to the Atlantic Ocean in the west. Several towns are situated in the catchment of the Swakop and Khan rivers: Okahandja, Otjimbingwe, Karibib, Usakos and Arandis as well as the Rössing uranium mine.

The fact that most towns in the western Central Region are situated on or near rivers reflects groundwater availability in the area. Sufficient water for larger settlements can only be obtained by surface water storage in dams or from alluvial aquifers, while the potential of bedrock aquifers is very limited. This is partly due to the low rainfall and lack of recharge, and partly to the generally unfavourable aquifer properties of Damara Sequence rocks (Christelis and Struckmeier, 2011). Groundwater reserves in the vicinity of the study area are limited to the Kuiseb, Swakop, and Omaruru alluvial bed aquifers of the Erongo groundwater basin, which supply Henties Bay, Swakopmund and Walvis Bay as well as Arandis, and historically Rössing Uranium and Langer Heinrich Mines (Aurecon Environment and SLR Environmental Consulting, 2014).

Christelis and Struckmeier (2011) further states that moderate yields are also encountered in the marble and schist aquifers around Karibib and the calcrete aquifer in the Kranzberg area at Usakos. But while the marbles supply the much larger town of Otjiwarongo further north, the recharge at Karibib is insufficient to maintain the required yields, and the water supply to the town and Navachab gold mine is augmented by the Swakoppoort Dam. Borehole yields decrease to very low and limited in the Namib.

The Hydrogeological map of Namibia with groundwater potential of rock units is shown in Figure 7 According to this map, the project site area (as shown by the green arrow) is largely found in generally low, locally moderate groundwater potential and in some further areas, very low and limited potential.

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Figure 7: Hydrogeological map of Namibia with rock bodies groundwater potential with the approximate location of project site indicated by the light green arrow on the map

5.4.1 Groundwater Recharge The effective groundwater recharge from rainfall is the portion of rainfall that reaches the groundwater table. The remainder of the rainfall is lost to surface water runoff, evapo-transpiration, and soil moisture. The effective rainfall-recharge is dependent on the rainfall intensity, soil and vegetation characteristics, catchment geology, surface water ponding and the available storage. As a general principle, it can be assumed that an increase in water available in a portion of the catchment (from rain or ponding of surface water) would increase the recharge in the area. Thin soil cover further promotes recharge.

Usually, groundwater recharge of a site is calculated from a conservative annual recharge derived from annual rainfall. A recharge value for the two sub-catchments was calculated from recharge zones given by Winker (2010) and these are shown in Figure 8 below with the Arandis and the EPL site area indicated as ‘’PS’’.

Recharge rates of the catchments which reported by several investigations varied from 0.3 to 10 % of annual rainfall (Winker, 2010). Given low rainfall received in Namibia over the past years, and climatic conditions of the project area, normal or worst-case scenario rainfall and conservative annual

18 Groundwater Impact Assessment Best Cheer Investments Namibia (Pty) Ltd DGIA: EPL 5161 rainfall values are always used to estimate groundwater reserve of the area to ensure that calculations and resulting values are not over-exaggerated and distorted from real site conditions.

Figure 8: Recharge zones derived from annual rainfall map (DEA, 2002), after Winker (2010)

5.4.2 Baseline Groundwater (Borehole) Yields and Levels Moderate yields are also encountered in the marble and schist aquifers around Karibib and the calcrete aquifer in the Kranzberg area at Usakos. But while the marbles supply the much larger town of Otjiwarongo further north, the recharge at Karibib is insufficient to maintain the required yields, and the water supply to thetown and Navachab gold mine is augmented by the Swakoppoort Dam. Other bedrock aquifers in the eastern part of the Namib, e.g. in the former Damaraland, are barely able to supply enough water for stock watering. Many dry boreholes were drilled in this area. The yield potential is generally low, but locally moderate. Yields decrease to very low and limited in the Namib (Christelis and Struckmeier, 2011).

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The groundwater map (in Figure 7) presents a color scheme that subdivides the rock bodies into aquifer (blue, green) and non-aquifers (brown) and further into fractured (green) or porous (blue) ones. Dark blue and dark green illustrate aquifers with high potential and yields generally above 15 m3/h, while the light colors describe aquifers with moderate potential and yields between 3 and 15 m3/h (Winker, 2010). With that said, it can be safely concluded that the light and dark brown colors in the same map represent areas of very low, limited and generally water potential with yield less than 3 m3/h. This is the scenario with the project area (Arandis Town and the EPL site area). However, moderate potential and yield areas could be encountered on certain local aquifers (small light green patches around the project area in the map). The probability of encountering such aquifers would be depended on correct siting of boreholes in the area targeting these specific moderate aquifer bodies.

During the site visit conducted on 18 July 2020, two boreholes were observed within the site area, near Farm Trekopje. The borehole near the Farm was dug by hand and has salty water which is only used for livestock (sheep) watering and has a water level of 11 m below ground. This borehole location is shown in the locality map in Figure 1 and sub-catchment map under Figure 12 under Chapter 7. The borehole has been names as Farm Trekopje borehole (FTBH) and its coordinates are presented below.

FTBH GPS Coordinates: 22°16'22.19"S 15° 6'2.59"E

The second borehole that is located about 20 m southeast from the Farm borehole is Government drilled and owned (as part of the Rural Water Supply Scheme) and the water level was recorded at 10.3 m below ground. This borehole water is also saline.

5.4.3 Groundwater Quality According Christelis and Struckmeier (2011), groundwater in fractured aquifers between the coast and 20-150 km inland is mostly saline. Fractured aquifers with inadequate yields are used at the Spitzkoppe (94) and Tubussis (101) water supply schemes. The Spitzkoppe is a popular tourist attraction in the Erongo Region. The mountain consists of granite intruded into meta-sediments of the Swakop Group. A settlement established at the foot of the mountain depends mainly on tourism and some small stock farming. The water scheme’s boreholes are sited on fractures intersecting the small Spitzkoppe River. Their yields are low, recharge is erratic, and its absence leads to poor water quality of Group C-D. A treatment plant to improve water for domestic consumption has been built.

A local groundwater quality assessment was conducted by BGR for the Khan and Swakop River Catchments in 2010 – Figure 9.

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EPL 5161

Arandis

Figure 9: Location of the sampling points for the 2010 Khan-Swakop River Catchment groundwater quality assessment (edited after Kringel et al, 2010)

The spatial distribution of Electrical Conductivity (EC) from groundwater samples from this assessment (study) is shown in Figure 10. According to Kringel et al (2010), generally, the occurrence of low salinity groundwater is restricted to the headwater region of the two rivers. In the downstream region, groundwater is saline. For the Khan River catchment samples with high EC also occur upstream of any discharge point from the Rössing Uranium Mine. Elevated EC is also found upstream of the Langer Heinrich Uranium Mine. Apart from a few exceptions, samples east of 15.35° latitude are in group “excellent” (A) and “acceptable” (B) while to the west of this latitude the groundwater is in group C or lower, making it unsuitable for human consumption. The unsuitability of this poor-quality water could also be explained by complaints received from some farm owners (about salty borehole water in the area) during the site visit on the 18th to 19th July 2020.

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EPL 5161 Arandis

Figure 10: Spatial distribution of Electrical Conductivity (EC) at the sampled area (Kringel, 2010)

5.4.4 Vulnerability of Groundwater to Over-abstraction The over-abstraction of groundwater in any aquifer in an area does not only affect the surrounding users (humans), but also the general environment (ecosystem) that depends on the same water resource. Over-abstraction would lead to significant lowering of groundwater levels in surrounding boreholes and the eventual gradual depletion of the aquifer. The lowering of the water table also means a decrease in borehole water levels for downstream water users. A decrease in water level in the surrounding (downstream) users' boreholes could increases pumping costs. This is true because advanced pumping equipment would be required to reach the new borehole water levels, thus affecting the rights of pre-existing water users in the area.

Groundwater over-abstraction does not only affect water users and the ecosystem, but also surface water-groundwater interactions which is a crucial component of the hydrologic cycle. Furthermore, over-pumping of groundwater would also induce the intrusion of salt water into the aquifer for aquifers in coastal areas, leading to poor water quality.

The water potential of the project site area, and this part of the Erongo Region is classified as generally low, locally moderate groundwater potential and in some further areas, very low and limited potential. The long-term unmanaged water abstraction from the aquifers with even moderate to good potential would still make the aquifers vulnerable to over-abstraction, therefore it would even be worse for aquifers with low to limited potential. However, the vulnerability of groundwater to over-abstraction would be dependent on the amount of water abstracted from the aquifer and frequency of abstraction.

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With regards to the proposed water use on the project activities (without considering the existing water uses and with the absence of pre-project concerns), the nature and duration of the proposed project activities (specifically exploration being a short-term activity) as well as volume of water required, groundwater vulnerability to over-abstraction owing to the project activities is considered low to slightly moderate. The impact of the proposed project activities on the groundwater resources in the area is describe and assessed under Chapter 8.

5.4.5 Vulnerability of Site Area groundwater resources to Pollution In areas where activities such as extensive agricultural, exploration and mining, waste management and industrial activities are practised with poor planning prior to project implementations, groundwater pollution becomes one of the main environmental and social concerns. However, as mentioned in the preceding subsection, poor water quality does not only come from direct pollution from the ground surface, but also from over-abstraction of aquifers, especially the poorly recharged and managed ones. Given the nature, type and scale of the proposed project activities, groundwater vulnerability to pollution owing to the project activities is rather low.

The Groundwater Resources Vulnerability Map of Namibia in Figure 11 shows that the vulnerability of groundwater to pollution in the project area ranges from rather low to moderate. This vulnerability status could be explained by the geology of the site area that is mainly characterized by metamorphic rocks such as granites, dolerite, basalts, marbles, and schists. Groundwater is hosted in both these secondary aquifers (fractured or faulted rocks units) and at some places in unconsolidated sediments in this part of the Namib Desert. These rock units without any fractures/faults or joints are considered aquitards (rock units that restrict water flow or hardly transmit water from one rock unit to the other, which in a way would move pollution in the aquifer system, if present in the water).

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Figure 11: Vulnerability of groundwater resources to Pollution (Van Wyk et.al, 2001)- approximate project site area enclosed by the light green circle

5.5 Vegetation The knowledge and consideration of vegetation cover in an area is crucial as evapotranspiration is one of the important components of the hydrologic cycle, and mostly on groundwater recharge. It is therefore vital to understand the vegetation cover in an area of interest.

According to Jacobson et al (1995), variation in rainfall is the primary determination of the western catchment vegetation. The classification of Giess (63) provides a broad overview of vegetation types found in the western catchments. The mountainous highlands associated with the headwaters of the Swakop and Kuiseb catchments, the highland savanna is composed of a complex mixture of Acacia species along with Combretum, Euclea, Rhus and perennial and annual grass species (Jacobson et al, 1995).

Moving westward off the inland plateau and towards the Namib Desert, the vegeation shifts from upland savannas to vegetation more suited to arid conditions. The transition zone between savanna and semi-desert is composed of a great variety of species, many of which are endemic to the Erongo Region (Jacobson et al, 1995). These vegetation species include Euphorbia, Cyphostemma, Moringa, Adenolobus, and Acacia.

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The common vegetation on and around the project site area include quiver trees (Aloidendron dichotomum), camelthorns (Acacia erioloba) and cactus (Cactaceae juss).

Since the purpose of this report is to assess the impact of the proposed project exploration activities on groundwater, certain factors need to be considered first prior to the actual assessment. Therefore, firstly the volume of water required for the project activities need to be known or at least estimated (Chapter 6) to make sound assessments of the potential impact and conclusions on the natural resource.

6 EXISTING AND PROPOSED WATER ABSTRACTION AND USE

6.1 Existing Groundwater abstraction and Use Groundwater in the sub-catchments is used for stock watering, industrial, mining, tourism, and domestic consumption. Water required by commercial water users such as mining and for urban consumption such as towns with the broader catchment is abstracted from the Omaruru Delta Aquifer (Omdel) near Usakos. From here, operated and managed by NamWater, the water is channelled via pipelines to reservoirs for distribution to these different consumers. The catchment includes towns such as Arandis, Usakos, Swakopmund and Henties Bay.

Current water supply sources in Erongo’s coastal region are the Omdel and Kuiseb Aquifers and the desalination plant built and owned by Areva. The Omdel dam, and aquifer recharge scheme was completed in 1994 but its sustainable yield is not fully understood. Based on the water figures in 2000, NamWater calculated that it has a sustainable yield of 9.8 Mm3/a. Water Scarcity Solutions estimated the extractable recharge of Omdel to be about 7.1 Mm3/a (Aurecon Environment and SLR Environmental Consulting, 2014).

According to Aurecon Environment and SLR Environmental Consulting (2014), the domestic demand in the coastal region is estimated to be 12.4 Mm3/a in 2014 and could rise to 14.7 Mm3/a by 2018. The demand in the mining and industrial sectors is predicted to be 5.4 Mm3/a in 2014 and could rise to 13.7 Mm3/a by 2018 with just the certain users, including Rossing Mine. When these demand predictions are balanced with the supply, including being supplied 10 Mm3/a from Areva, there could be a shortfall of about 5 Mm3/a in 2016 which would rise to 8 Mm3/a from 2017 (Aurecon Environment and SLR Environmental Consulting, 2014).

With regards to the Arandis Town, the terminal reservoir capacity is 60 000 m3 (comprised of three 20 000 m3 reservoirs), and the Rossing Uranium Mine has access to 48 000 m3 or 80% of this stored capacity. The low-level limit is set at 30% of full level, which translates to 6 000 m3 of unusable storage in one reservoir. By adding 2 days of working storage and 2 days of emergency storage for Arandis a further 6 000 m3 of storage is rendered unavailable. This adds to make a total of 12 000 m3 reserved for Arandis, and the remaining 48 000 m3 for the Mine (Aurecon Environment and SLR Environmental Consulting, 2014).

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Based on the information gathered on site during the visit conducted on 18 July 2020, the borehole water in the area is salty and therefore not fit for human consumption. The water from local site boreholes is currently used for stock watering. Water for drinking is carted into the area and stored in tankers on farms. The carted water is provided by AREVA as part of their operations’ social responsibilities.

The above water figures have been provided to give a general outlook on the groundwater consumption by major users (towns, industries, and mines) in the Erongo Region. This water is however not abstracted from the project site area but from the Omdel aquifer because the project site area’s hydrogeological settings (potential) cannot yield nor cater for such huge volumes of water. The proposed exploration activities will therefore be solely supplied with water from the same schemes that supply Swakopmund (as mentioned under the next section).

With the above said, it can be assumed that the local aquifers around the project site (catchments) are only abstracted by potentially existing small-scale miners and farmers for their stock watering water needs (cumulative water abstraction and use). It should also be noted that due to lack of baseline information on local water use, the total volume of water consumption by local activities that rely or depend on these aquifers is unknown.

6.2 Proposed Water abstraction and Use for the Project Activities The Proponent anticipates the use of water volumes within the range of 3 000 and 6 000 litres of water (i.e. 3 and 6 m3) per day, averaging to a monthly volume of 93 000 and 186 000 litres (93 and 186 m3/month). In case that the exploration activities would be carried out for a year or more, the annual water demand would be 1 116 and 2 232 m3 (1 116 000 and 2 232 000 litres). The water required for this project will be mainly used for down-the-hole drilling, butterfly cutting during exploration, cleaning, and cooling off drilling/exploration equipment. Water recycling will be prioritized to conserve water.

A worst-case scenario of the water requirements, a daily volume of 5 000 litres will be used for this report’s considerations and as maximum for the proposed project activities. This value would amount to an average of 155 000 litres per month (1 860 m3 or 1 860 000 litres per year). It is important to note that this water will not be abstracted from existing site boreholes but carted from outside the project area (from a water supply line in Swakopmund or Karibib) and stored in industry standard water tanks on site for project use. Sufficient water from the outside area supply will be carted to site on certain days of the week only (not every day). This is to ensure the Proponent’s water trucks are not traveling on the local and regional roads daily which would exert pressure on and impact the roads (traffic).

With this said, there will be no water abstraction from the local aquifers.

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It is very important to determine or at least estimate the amount of water resource that is available in a certain area, as this helps in setting up management plans for the resource. This would usually be done by undertaking a preliminary groundwater reserve estimation for an area to determine the available abstractable (sustainable) water volume. The sustainable water volumes would be calculated from the (sub) catchment water balance and then determine the stress index level of the aquifer for the study/project area.

Since there will be no water abstraction from the catchment for exploration activities, there will be no need to calculate the available groundwater reserve (reserve estimation) of the area. However, it is vital to delineate the project catchment area and obtain crucial information such as sub-catchment and catchment areas and direction of potential flow in events of pollution from the sites. This information is given under the next chapter.

7 SUB-CATCHMENT DELINEATION The project site was delineated by using ArcGIS. The digital elevation model (DEM) was used as an input to enable the delineation of a drainage system and then quantify the characteristics of that system. The tools in the extension allows the user to determine, for any location in a grid, the upslope area contributing to that point and the down slope path that would be followed by the water. This data is usually important during impact assessments.

According to Robins (2020), groundwater flows on a catchment scale from beneath the higher ground towards the lower ground to discharge as baseflow into the surface waters. The speed of the flow is a function of the hydraulic gradient, or the inclination of the water table, and the permeability or transmissive properties of the rocks. The volume of groundwater in the flow system depends on the effective rainfall, which is the actual rainfall minus evaporation, less any surface water runoff.

With that said, a site sub-catchment delineation map was created for the EPL site area and is shown in Figure 12. As it can be seen in the map, the EPL area falls into three different sub-catchments of the main catchments. These sub-catchments are labelled in the map as sub-catchment ‘’1’’, Sub- catchment ‘’2’’ and sub-catchment ‘’3’’. The sub-catchments (surface areas) will be used in the calculations to estimate the reserves of the site area. The surface areas of the sub-catchment ‘’1’’, ‘’2’’ and ‘’3’’ are 168.12 km2, 134.61 km2 and 1 041.50 km2, respectively.

The significant identified borehole near the EPL site (Farm Trekopje) is also included in the sub- catchment map and falls under the delineated sub-catchment ’1’’ of the larger catchment A.

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Figure 12: Sub-catchment delineation map for the EPL site area

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The following chapter (Chapter 8) covers the potential impacts of the proposed exploration activities on groundwater, with primary focus on possible over-abstraction and pollution. Under the same chapter, these two aspects are described, and assessed (section 8.2 and 8.3).

8 GROUNDWATER IMPACTS: DESCRIPTION AND ASSESSMENT

8.1 General Concept of Impact (Risk) Assessment Generally, an environmental risk occurs when there is a hazard (e.g. process, activity, or substance) that can result in a harmful impact on the surrounding environment. The part of the environment which is, or could be, affected is known as a receptor. Receptors include humans, flora and fauna, the built environment and water resources (controlled waters).

 Source (or hazard): a substance capable of causing pollution or harm.

 Receptor (or target): something which could be adversely affected by the contaminant.

 Pathway: a route by which contaminants can reach the receptor.

The environmental risk assessment is the process whereby S-P-R linkages are identified and assessed. In the case that any of the three elements are absent, then there is no complete linkage and thus no verifiable unacceptable risk. The magnitude of a risk is a function of the consequences of risk and the likelihood that such rick will occur.

The risk/impact assessment for the three identified potential impacts that may impact the water resources during the duration of the project activities is presented under the subsections below. The subsections provide a brief description to each potential impact (as per the S-P-R system) and then assessed according to the criteria provided (for both the pre-mitigation and post mitigation scenarios) under section 3.2.2 and 3.2.3.

8.2 Groundwater Impact Assessment (Over-abstraction) Groundwater resources is impacted by project developments/activities in two ways, namely through pollution (water quality) or over-abstraction (water quantity) or at times both.

Based on the groundwater potential map, it could be clearly seen that groundwater resources in the project area are already scarce. The abstraction of more water than it can be replenished from an area with low and limited groundwater potential would negatively affect the local communities (farmers) that depend on the same ("struggling") groundwater resource (aquifer) and low yielding boreholes.

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8.2.1 Brief Impact Description – Water Quantity The impact of the exploration activities on the resources would be dependent on the required volumes of water. Commonly exploration activities use a lot of water, mainly in drilling. However, this depends on the type of drilling methods employed (diamond drilling is more consuming compared to drilling methods such as reverse circulation for instance) and the type of mineral being explored for.

The drilling method to be employed for this project’s exploration activities is down-the hole (DTH). According to Jeansson (2014), water is required and used to power the impact mechanism of the hammer at a high frequency rate and bring any cuttings to the surface and clean the borehole. Additionally, the hydrostatic column, which is created above the hammer, helps to keep the hole stable while preventing potential collapse. This also prevents water from being drawn into the borehole, which increases hole stability and prevents potential environmental issues. Using water as a flushing medium also has a secondary effect in terms of borehole cleaning. This is important if the purpose of the borehole is for injection of cement (grouting) for ground improvement. Dust (compressed air + cuttings) clogs cracks, while the water cleans the borehole. This increase both productivity and quality in the grouting process. Water also acts as a lubricant and eliminates the need for any oil. This means that the ground is not polluted and workers or people in the vicinity are not exposed to oil mist or dust caused by the drilling process (Jeansson, 2014).

The required water for exploration (5 000 litres per day) will be used for drilling purposes and cooling drilling equipment. Given the low groundwater potential of the project site and area, the required water will be carted into the area from outside. The proposed option will be to supply the project from an outside area water supply in Swakopmund or Karibib and stored in industry standard water reservoirs/tanks on site. Although exploration may be requiring a lot of water, this would also be dependent on the duration of the exploration works and number of exploration boreholes required to make reliable interpretation on the commodity explored for.

In terms of water abstraction and use, the project activities will not use a significant amount of water that would impact the already struggling resources in the area, because no groundwater abstraction will be done during exploration works. Therefore, no pressure (or threat) to the local aquifers in terms of water quantity (abstraction).

The assessment of this potential impact on water abstraction from the aquifers is summarized as follows:

 Source: The sources in this aspect would be the over-abstraction from the aquifers, which could affect other water users and the environment. However, there is no anticipated local groundwater abstraction from these proposed project activities, as the required water will be carted into the area.

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 Pathway: The pathway is determined by the depth to water table, type of lithology in the area and groundwater flow direction. In the case of water abstraction from local aquifers(boreholes), the impact is none because the project site’s groundwater is mainly hosted in the above-mentioned rock units, therefore, rapid drawdown is unlikely and no water will be abstracted from the local boreholes.

 Receptor: The neighbouring farms (boreholes) and other water users (downstream to the west) and surrounding environmental components like vegetation could be considered potential receptors. However, this will not be experienced owing to the project activities because there will be no local groundwater abstraction.

Furthermore, based on the impact assessment criteria presented under the Methodology chapter, this impact has been assessed as follows (Table 3).

Table 3: Assessment of the project impact on water resources abstraction (quantity)

Mitigation Extent Duration Intensity Probability Significance Status Pre L/M - 2 M - 3 L/M - 4 L/M - 2 L -18 mitigation Post L - L - 1 L - 2 L - 1 L - 4 mitigation

8.3 Groundwater Impact Assessment (Pollution)

8.3.1 Brief Impact Description – Water Quality In areas where activities such as extensive agricultural, mining, waste management and industrial activities are practiced with poor planning prior to project implementations, groundwater pollution becomes one of the main environmental and social concerns. However, as mentioned in the preceding subsection, poor water quality does not only come from direct pollution from the ground surface, but also from over-abstraction of aquifers, especially the poorly recharged and managed ones. Given the nature, type and scale of the proposed project activities, groundwater vulnerability to pollution owing to the project activities is rather low.

The anticipated potential source of pollution to groundwater resources from the project activities would be hydrocarbons (oil) from project (exploration) vehicles, machinery, and equipment as well as potential wastewater/effluent from exploration works. The spills (depending on volumes spilled on the soils) from these machinery, vehicles and equipment could infiltrate into the ground and pollute the already shallow and permeable aquifers on site, and with time reach further groundwater systems in the area.

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8.3.2 Pollution Impact Assessment The main concern regarding groundwater pollution would be on areas that are underlain by fractured/faulted rock units or partly overlain by the limited sediments. These sediments or fractured rock structures would provide ready passage for pollutants into groundwater, but without faults or fractures, these rock units would behave as aquitards, but not aquifers. If there is a significant point source of pollution, the pollution vulnerability would be bound to fractured/faulted rock units, therefore low (for fractured/faulted rocks) and slightly moderate (for distinctive unconsolidated sediment aquifer areas).

Furthermore, although not significant, measured nor monitored, there could already be an existing pollution from other pre-proposed project (existing) anthropogenic activities undertaken in the site area. These existing activities or some of them could also have been the sources of such pollution. Therefore, it is of great importance to first assess the baseline (water quality) information pre- exploration activities so that future pollution scenarios will not be solely pointed to the proposed project activities, but to also consider the possibility of cumulative occurrence of such an impact (pollution) in the area. Groundwater pollution risk can also arise from localized pollution sources, in combination with the aquifer’s vulnerability to pollution.

Overall, the likelihood of significant pollution to groundwater in the project area is low due known low rainfall in the area and eventually little to no groundwater recharge, which could carry polluted water into the local aquifers.

The potential impact of pollution arising from the proposed project is described below as per the three elements of risk/impact assessment given under Section 8.1:

 Source: As mentioned above, potential sources of pollution from the project activities would be hydrocarbons (oil) from project (exploration) vehicles, machinery, and equipment as well as potential wastewater/effluent from exploration works.

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Further cumulative sources of pollution are wet waste/effluent from improperly managed sewage facilities, fertilizers, pesticides, and hydrocarbons from other existing anthropogenic activities in the site area. Another significant potential (cumulative) source of pollution in the area is the material from the tailings storage facility (TSF) at Rössing Mine (subject to capping, so that fresh material deposited onto the TSF forms a solid crust after a period of a few months). According to von Oertzen (2015), after this, very little material can be mobilized by wind from this surface. This means that it is the freshly deposited and dried material on the TSF that is most likely to be mobilized by wind. Dust that has been deposited in the plume during the season of east wind tends to have formed a hard crust by the time the next east wind season occurs, and very little further distribution of this material then occurs through wind erosion. Further mobilization of this material now occurs through water erosion during infrequent rainstorm events, which collect dust from the surface and accumulate the material in gullies. Water erosion therefore collects material which was distributed in a thin layer on the surface and gathers it in small accumulations in lower lying areas. During heavy rainy seasons, these pollutants would be carried by rainwater through surface runoff and infiltrate into the ground, recharge local aquifer systems and pollute them.

 Pathway: Polluted or poor-quality water would travel from the potential sources (points) of pollution downstream of the sites in the project area. In some parts of the site areas that may be underlain by the porous and unconsolidated sediments (aquifers), these aquifers in these parts may be prone to pollution risk. Given the high permeability of such sediments, water can enter the groundwater system easily and rapidly. In events of high pollution on the surface, the nature of these sediments would be expected to cause rapid infiltration of pollutants to groundwater and spreading of pollutants over a large area. In parts of the project areas underlain by the consolidated rocks such as dolerite, basalts, schists and marbles, the pollution transport would not penetrate the aquifers. This could be because of the presence of these host rocks (if not fractured) that act as pollution barriers (aquitards), thus preventing or delaying any possible pollutant transport in groundwater.

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 Receptor: Should there be an excessive abstraction from the local aquifers, the impact could be felt by communities and natural biophysical environments downstream depending on groundwater, and they would be considered potential receptors of this pollution from the exploration activities’ sources. A sudden worsened groundwater quality downstream during the project operations would at some extent be linked to the project activities. However, this would need to be verified against baseline water quality analysis data (results) recorded pre-exploration activities to prove that the experienced water quality issue has indeed been worsened by the exploration activities on the EPL. This would also be a challenge to prove because of the short lifespan of exploration activities and the slow movement of groundwater from one area to the other over time would mean that the impact would only be felt some time after the activities are completed. In other words, should the exploration activities end there (in this phase) without progressing to the mining phase where groundwater quality monitoring could be conducted.

From the above description of the impact, it can be concluded that without implementing any measures to avoid or minimize the impact, the impact significance will moderate and once the mitigation measures have been implemented, the significance will be reduced to low. The assessment is also presented in Table 4 below.

Table 4: Assessment of the project impact on groundwater resources (quality)

Mitigation Extent Duration Intensity Probability Significance Status Pre M - 3 M - 3 L/M - 4 M - 3 M - 30 mitigation Post L/M - 2 L/M - 2 L - 2 L - 1 L - 6 mitigation

After assessing the site area based on the available information, literature and professional judgement, the impact of pollution on the groundwater resources, this impact is considered low. Furthermore, the project impact is short-term, i.e. the potential impact will only be existing during (limited to) this phase.

The next chapter (Chapter 9) presents the groundwater abstraction management plans to ensure groundwater protection against over-abstraction (overexploitation) and potential pollution.

9 GROUNDWATER MANAGEMENT MEASURES The following water management plans are recommended, and they should be effectively implemented and monitored by the project Proponent to mitigate and effectively manage the potential impacts on groundwater resources in the area.

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9.1 Groundwater Abstraction Management Plans Over-abstraction of both surface and groundwater resources can have severe impacts on people, animals and surrounding environment supported by the same water resource. Therefore, it is very important to manage water abstraction. If too much groundwater is abstracted, the aquifer may become depleted. The depletion of groundwater has adverse impacts like drying up of shallow water boreholes, deterioration of water quality and a decrease in groundwater levels, which results in increased water pumping costs (GCS Water & Environmental Consultants, 2016). It is therefore important to manage the abstraction from an aquifer.

However, there will be no anticipated abstraction from the local aquifers because the required water will be carted into the area from Proponent’ supply line in Swakopmund that is fed by the main groundwater scheme(s) for Swakopmund and other coastal towns. Although the project water will be sourced from the said outside supply system, it is equally vital to ensure that certain water management measures are in place for implementation by all commercial water users, regardless of whether they directly abstract from the aquifer (natural resource) or supplied via a supply scheme. The following water use management plans are recommended to mitigate the impact of groundwater (over) abstraction on a larger scale:

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 Water conservation awareness and saving measures training should be provided to all the project workers so that they understand the importance of conserving water and become accountable.

9.2 Groundwater Pollution Management Plans It is important to note that the potential pollution from the project does not constitute the absence of current (cumulative) and future anthropogenic activities that are already or will be contributing to groundwater pollution in the project area. Nevertheless, to avoid and or minimize the potential impact of pollution stemming from the project activities, the following measures are recommended for implementation:

 Project machines and equipment should be equipped with drip trays to contain possible oil spills when operated during exploration works.

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o Identification of oil storage and use locations on site and allocate drip trays and polluted soil removal tools suitable for that specific surface (soil or hard rock cover) on the sites. o Maintain equipment and fuel storage tanks to ensure that they are in good condition thus preventing leaks and spills. o The oil storage and use locations should be visually inspected for container or tank condition and spills. o Maintain a fully provisioned, easily accessed spill kit. Spill kits should be located throughout the active project sites contain the floor dry absorbent material and absorbent booms, pads, mats. These would be suitable for ground surface areas that are covered mainly by hard rocks. o All project employees should be made aware of the impacts of soil pollution and advised to follow appropriate fuel delivery and handling procedures. o Develop and prepare countermeasures to contain, clean up, and mitigate the effects of an oil spill. This includes keeping spill response procedures and a well-stocked cache of supplies easily accessible. o Ensure employees receive basic Spill Prevention, Control, and Countermeasure (SPCC) Plan training and mentor new workers as they get hired in each phase of the project.

The recommendations and conclusions made for the overall assessment are as presented under Chapter 10 below.

10 RECOMMENDATIONS AND CONCLUSIONS The aim of this report was to identify and assessed the potential impacts of the proposed exploration activities on the groundwater resources. The assessment has been undertaken on a desktop level, i.e. based on project information provided by Omavi Consultants (the project Environmental Assessment Practitioner), author’s review of previous and available different relevant studies conducted in the project area by other consultants and relevant information from data sources in the field of groundwater.

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The recommendations provided to the assessment and conclusions made are presented under the following sections (10.1 and 10.2):

10.1 Recommendations Given the assessment results, to manage and protect the water resources, the following management measures should be implemented:

Groundwater Abstraction and Use Mitigation Measures

 Water conservation awareness and saving measures training should be provided to all the project workers so that they understand the importance of conserving water and become accountable.

Groundwater Pollution Mitigation Measures

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 Project machines and equipment should be equipped with drip trays to contain possible oil spills when operated during exploration works.

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o Develop and prepare countermeasures to contain, clean up, and mitigate the effects of an oil spill. This includes keeping spill response procedures and a well-stocked cache of supplies easily accessible. o Ensure employees receive basic Spill Prevention, Control, and Countermeasure (SPCC) Plan training and mentor new workers as they get hired in each phase of the project.

10.2 Conclusions Water abstraction (use): Water abstraction (use): The impact on local groundwater resources (abstraction) will be none because no groundwater will be abstracted from the local aquifers of the project magnitude (small to medium as the required water will be carted into the area. Therefore, the impact on groundwater resources (quantity) from the exploration activities is non-existent, provided that the Proponent strictly uses carted water and not abstract from the local boreholes.

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The Proponent will also be required to ensure that all their activities comply with the legislation governing their project activities with respect to groundwater resources management and protection.

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11 REFERENCES LIST Africa Planning Forum. (2019). Environmental Scoping Report: Construction and Operation of Arandis Data Center, Arandis Erongo Region. Windhoek: Ministry of Environment, Forestry and Tourism. Retrieved from http://eia.met.gov.na/screening/30_Final%20EMP%20Arandis%20Data%20Center.pdf Aurecon Environment and SLR Environmental Consulting. (2014). Social and Environmental Impact Assessment for the Proposed Rossing Uranium Desalination Plant near Swakopmund, Namibia. Windhoek: Rossing Uranium .

BGR. (2005). Investigation of Groundwater Resources and Airborne-Geophysical Investigation of Selected Mineral Targets in Namibia: Groundwater Investigations in the Eastern Caprivi Region. Windhoek and Hannover: BGR.

British Geological Survey. (2020, May 6). Earthwise. Retrieved from Atlas Groundwater Africa: Hydrogeology of Namibia: http://earthwise.bgs.ac.uk/index.php/Hydrogeology_of_Namibia#Groundwater- Surface_Water_Interaction European Environmental Agency (EEA). (2018, November 22). European Environmental Agency. Retrieved from Environmental Topics. Water Use and Environmental Pressures: https://www.eea.europa.eu/themes/water/european-waters/water-use-and-environmental- pressures/water-use-and-environ GCS Water & Environmental Consultants. (2016). Okatji Marble Mine Water Use Permit Application. Windhoek: Unpublished.

GCS Water & Environmental Consultants. (2017). National Environmental Assessment for the MTC Namibia 100% Population Coverage Project: Landscape Specialist Report. Windhoek: MTC Namibia. GCS Water & Environmental Consultants. (2018, January 18). MTC Namibia. Retrieved from Old MTC Namibia Website - Environment: Downloads: http://www.oldmtcweb.mtc.com.na/pdf/gcs-pdf/Appendix_C_Baseline_Report.pdf

Hertsted, O. (2014). Groundwater Management Plan: Environment. Perth: Fortescue Metals Group.

Christelis, G and Struckmeier, W (eds). (2011). Groundwater in Namibia: An Explanation to the Hydrogeological Map. Windhoek: Department of Water Affairs.

Jacobson, P.J,. Jacobson, K.M and Seely, M.K. (1995). Ephemeral Rivers and their Catchments: Sustaining People and Development in Western Namibia. Windhoek: Desert Research Foundation of Namibia. Jeansson, J. (2014, September). Wassara. Retrieved from Water Powered Drilling: The Water Hydraulic DTH Technology - The DTH Hammer: https://www.wassara.com/SysSiteAssets/wassara/brochures/technology/technology_brochure Kringel, R., Wagner, F. and Klinge, H. (2010). Groundwater quality in the Khan- and Swakop River Catchment with respect to geogenic background concentrations of dissolved uranium. Hannover: BGR Germany. Land and Water Management Division. (2010). Michigan State. Retrieved from General Guidelines for Calculating a Water Budget: https://www.michigan.gov/som/ Lee, G. F and Jones-Lee, A. (2007). Focus on Irrigated Agriculture Pollution of Groundwater Excerpt from "Groundwater Quality Protection Issues". Sacramento: G. Fred Lee and Associates.

Matengu, B., Xu, Y and Tordiffe, E. (2019). Hydrogeological characteristics of the Omaruru Delta Aquifer System in Namibia. Springer-Verlag.

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Mweemba, M. S. (2014). Small-Scale Mining in Namibia: Theme: “Earth Sciences and Climate Change: Challenges to Development in Africa”: 7th conference of the African Association of Women in Geosciences. Windhoek.

Parsons, R. and Wentzel, J. (2007). Groundwater Resource Directed Measures Manual.109pp. Pretoria: Department of Water Affairs and Forestry (South Africa).

Robins, N. (2020). Introducing Hydrogeology. Edinburgh: Dunedin Academic Press Ltd.

Southern African Institute for Environmental Assessment (SAIEA). (2011). Strategic Environmental Assessment for the Central Namib Uranium Rush. Windhoek: Ministry of Mines & Energy.

SRK. (2006). Preliminary Surface and Ground Water Impact Assessment for the Scoping Supplementation: Assessment for the Proposed New Filling Station in Paul Kruger Street, Secunda. Northlands: SRK.

Strohbach, B. J. (2008). Mapping the Major Catchments of Namibia. Windhoek: Namibia University of Science and Technology. Van Wyk, A.E., Strub, H. and Struckmeier, W. (2001). Hydrogeological Map of Namibia, Scale 1:000 000 : Vulnerability of Groundwater Resources Map. Windhoek: Ministry of Agriculture, Water and Forestry. von Oertzen, G. (2015). Risk assessment on Rossing Uranium mine's tailings dust. Aachen: Brenk Systemplanung GmbH.

Winker, F. (2010). Groundwater Model of the Swakop River Basin. Freiburg: University of Freiburg.

World Weather Online. (2020). Arandis - Erongo Region, Namibia Weather. Retrieved April 8, 2020, from World Weather Online: https://www.worldweatheronline.com/arandis-weather- averages/erongo/na.aspx

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