Environmental Assessment (EA) Report for Exclusive Prospecting Licenses (Epls) No

Home , Gobabis, Hardap region, Omaheke Region, Witvlei

Environmental Assessment (EA) Report For Exclusive Prospecting Licenses (EPLs) No. 7028 and 7029 near Witvlei Settlement in the Omaheke Region, Namibia

REPORT VERSION: FINAL

EDS Project No.: PNEA2019-33

Author(s): Ms. Althea Brandt and Mr. Client: Aloe Investments Two Hundred and Thirty-Seven Nerson Tjelos (Pty) Ltd Reviewer: Ms. Fredrika Shagama

Company: Excel Dynamic Solutions (Pty) Contact person: Mr. Robert Middleton Ltd Telephone: +264 (0) 61 259 530 Telephone: +264 (0)61 429 851/001-289-952-3695 Fax2email: +264 (0) 886 560 836 Fax: 001-807-623-0877 Email: [email protected] Email:[email protected]/[email protected]

Date: 08 November 2019

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

EXECUTIVE SUMMARY

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd (The Proponent), a 100% subsidiary of a Canadian-based mineral exploration company White Metal Resources Corporation has a 95% interest in Exclusive Prospecting Licences EPL 7028 and 7029. The remaining 5% is owned by a Namibian company, Altan Minerals and Investments CC. The licences were granted to the latter by the Ministry of Mines and Energy (MME). The tenure of these licences is from 13 June 2018, as per agreement with the Ministry of Mines and Energy. The earth data of the covered area is prospective with regards to three groups of commodities, upon which detailed prospecting and exploration activities will be conducted:

- Base Metals and Rare Metals (main target)

- Industrial Minerals

- Precious Metals

The tenements are situated near Witvlei Settlement in the Omaheke Region, covering a combined total area of 39,008.2746 Ha. The covered area is located within the Kalahari Copperbelt, 55 km west of Gobabis. Occurrences of copper mineralization in the area have been explored since the 1970s, re- activated in the 1980s, but then ceased due to low prices for copper ore on the world market. Aloe Investments Two Hundred and Thirty-Seven (Pty) plans to conduct prospecting and exploration activities leading to the estimation and delineation of the target resource. Prospecting and exploration form part of the listed activities that may not be undertaken without an Environmental Clearance Certificate (ECC).

Project Description

Based on technical report which covered literature review of all available geological data sets pertaining to previous exploration activities in the surroundings area, EPL 7028 and 7029 have a potential to host stratabound copper-silver mineralization. The objective of the planned prospecting and exploration is to identify geological features and lithostratigraphic entities as well as to delineate the mineral (copper) deposits and determine whether the deposits are economically viable. The scoping process will identify sensitive environmental features that might be affected by the proposed prospecting and exploration activities. The level and magnitude of planned exploration work is not clear at this stage. However, both invasive and non-invasive exploration activities are expected to take place upon issuance of an environmental clearance certificate.

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

Non-invasive activities include geological field mapping and geophysical ground-based survey work. Invasive activities involve soil and rock sampling, trenching and drilling. The prospecting and exploration activities entail the following three mineral commodity groups: (i) Base and rare metals, (ii) industrial minerals, and (iii) precious metals. Base metal (i.e. copper) is the main target for the planned exploration work. The Proponent plans to conduct a staged exploration approach as follows:

Prospecting (Construction/Initiation Phase)

Prospecting phase include reviewing existing reports and composite stratigraphic, lithological- geochemical maps of the targeted areas to identify prospective lithostratigraphic packages. In addition to literature review, field work (lithological (soil/rock) mapping and sampling) will be conducted to verify desktop work. Up to this point no physical disturbance is required.

The selection of the potential mineralization model and exploration targets has been specially selected based on the regional and likely local geology as well as the results of the past exploration activities. Upon issuing of the clearance certificate, the exploration program will commence with ground geophysical surveys which involve the use of both single instruments that are hand carried and another method which uses up to 6 people to put stainless steel electrodes in the soil and generate a current to charge the minerals so a volt meter can read the discharge of the voltage. Bush trimming may be required to create survey lines. This will only happen if the vegetation is too thick to walk through.

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

This is the phase during which the exploration program will be operational. The target areas within the EPLs boundaries which have been identified during the prospecting phase will then undergo exploration drilling. The preferred drilling technique for this exploration programme is Reverse Circulation (RC) Drilling. RC Drilling uses a pneumatic hammer which drives a rotating tungsten-steel bit. The technique produces an uncontaminated large volume sample which is comprised of rock chips. It is relatively quick and cheap compared with other techniques like Diamond Drilling. There has been past drilling activities on the areas, and understandably using diamond coring technique. Based on the past findings and recommendation from past geology studies, RC Drilling is the preferred technique for the planned exploration work. In the advanced stage of exploration activities, larger amount of sample material may be required for analysis and to perform processing trials. Pit may be dug to sampling. The size of the

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029 sample size may be adjusted depending on the nature of mineralization observed from drilling. No explosives will be used during exploration phase. Other aspects of the exploration operations include:

Access

The Witvlei Property is situated about 150 km east of Windhoek via B6 Motorway and just about 3.3 km from the village of Witvlei which is a small village with one school, one clinic, one petrol station (Figure 1) and a police station. Windhoek is the social, economic, political, and cultural centre of the country. Most of the commercial industry, governmental offices, educational institutions are headquartered in Windhoek. To the east of Witvlei and about 52 km on B6 Motorway is the regional capital of the Omaheke Region, Gobabis. Access to exploration site(s) will be organised along the existing roads as far as possible Tracks for new access roads will be assessed for any environmental sensitivity.

Resources

The input required for exploration program in terms of vehicles and equipment include; SUV (4X4) vehicles, air compressor, truck mounted drill rig and diesel-powered generator. Drilling crew of about five (5) people will be at site, including a geologist, a helper and 3 drillers. Equipment and vehicles will be stored at a designated area near accommodation site or a storage site established within the EPL area.

Services infrastructure

Water: No water is required for RC drilling. Water required for other exploration activities and human consumption will be obtained from existing boreholes, or from approved water sources, through water abstraction permits. Water required primarily for drinking and washing is supplied from two key service providers: Witvlei town (sourced from Namwater), and possibly farmers’ boreholes.

Power supply: No power supply infrastructure to the exploration site is planned for. Diesel power generation will be used during exploration phase. Upon discovery of mineable resources, arrangement will be made with Namibia Power Corporation (NamPower) for possible supply of electricity for mining activities.

Accommodation

Exploration crew will be accommodated in Witvlei Settlement or any nearby available place i.e. farms. Exploration will take place during the day time only and staff will be commuting to exploration site from the accommodation town/place.

Timeframe

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The ground geophysical survey program may last several months and will be done in stages on different parts of the property (EPL 7028 and 7029) depending on prospecting results. RC drilling is anticipated to last 3-4 months on each of the two licences, EPL 7028 and 7029. A two-year exploration program is envisaged.

Waste Management

The site will be equipped with secured waste bins for each waste type. Depending on the amount generated, waste will be sorted and collected on a weekly basis or monthly and taken to the Wetvlei landfill site. Ablution facilities will use chemical toilets and/or sealed septic tanks and the sewerage taken to the Wetvlei storage periodically.

Security

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

Decommissioning Phase

As it is with all exploration projects, exploration activities on EPL 7028 and 7029 will come to an end . The decommissioning of the exploration operations may be considered due to poor exploration results or declining in the copper market price. During the operational phase and before decommissioning, the Proponent will need to put site rehabilitation measures in place. Where necessary, stockpiling of top soil for rehabilitation at a later stage will be undertaken. Necessary landscaping of exploration areas will be undertaken upon completion of each phase of exploration (drilling, sampling etc.).

Project Alternatives

The conclusions weighed and considered above are summarized below:

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

• No-go alternative: The “No-Go” alternative is the option of not proceeding with the activity, which typically implies a continuation of the status quo. Should the proposed works of the prospecting and exploration plan be discontinued, none of the potential impacts (positive and negative) identified would occur. Furthermore, the local people to be employed for exploration work will be left unemployed and the Proponent would not be able discover and define the targeted resource for possible mining and contribute to the country’s economy through revenue and license royalty payments.

If the proposed project is to be discontinued, the current land use for the proposed site will remain unchanged. In considering the proposed project, the ‘no-go’ option is not considered the preferred alternative.

• Prospecting location: The prospecting/exploration location is dependent on the mineralogy and geology of the area. Therefore, finding an alternative location for the planned exploration activities is not possible. In other words, the base metals (i.e. copper) mineralization is area specific, which means exploration targets are primarily determined by the geology (host rocks) and the tectonic environment of the site (ore forming mechanism).

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

Impact Identification

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

Positive impacts:

• Creation of jobs to the locals • Helps boost local economic growth. • Open up other investment opportunities. • Contribution to regional economic development. Negative impacts:

• Loss of Biodiversity • Generation of dust

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

• Waste generation • Visual impact (scars) on landscape • Potential health and safety risks • Surrounding Soils Impacted • Archaeological Impact • Noise

Impacts Assessment and Mitigations

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

• Loss of Biodiversity: The drilling activities and earthworks done to expose the copper bearing rock units will potentially result in land degradation, thus destroying habitats of small animal species that may be encountered under the site soils and rocks. In order to enable the exploration operations, some site vegetation within the footprint of the exploration area may be removed. This will lead to the destruction of protected plant species. Thus, resulting in the loss of such species and eventual loss of biodiversity in the area. In fragile ecosystems, vegetation is easily disturbed, which often means any disturbance to the environment will result in the loss flora. It is therefore important to identify what species are present, understand them and try to minimise the impact upon them with operational management guidelines. The most obvious impact on vegetation is direct loss due to removal of soil by digging and trenching. EDS advises the Proponent to avoid unnecessary removal of vegetation, in order to promote a balance between biodiversity and their operations. Under the current status, the impact can be considered to be of a medium significance rating. With the implementation of appropriate mitigation measures, the rating will significantly be reduced to low (Mansfeld, 2006).

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

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

• Waste Generation: Prospecting and exploration activities are usually associated with generation of waste of all kinds (domestic and general) and if these are not disposed of in a responsible manner, it will result in the pollution of the site and the surrounding environment. Industrial waste is a given by-product of any exploration operation. Non-biodegradable and biodegradable refuse should be stored in a container and collected on a regular basis and disposed of at a recognized disposal facility. Precautions should be taken to prevent any refuse spreading. The container should be covered with mesh to prevent access from animals. Without any mitigation measure, the impact has a medium significance. The impact will be of low significance from medium, upon implementing the mitigation measures (Mansfeld, 2006).

• Visual Impact (Scars) on Landscape: Visual impact due to exploration is aesthetic damage to the landscape. Drilling activities usually leave scars on the local landscape. If the exploration sites are located close to or along tourist routes, these scars in many cases contrasts the surrounding landscape and thus may potentially become a visual nuisance, especially to tourists in tourist- prone areas. Nonetheless, it is a vital to acknowledge that during prospecting phase, certain measures will need to be taken into consideration regarding the visual aspect. Currently, the visual impact can be rated as slightly medium to low significance, but upon effectively implementing the measures (Manger Mining EIA Report, 2019).

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

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• Surrounding Soils: Drilling works will potentially result in soil disturbance which will leave the already exposed site soils vulnerable to erosion. This impact is probable because the proposed site is vacant (bare) with no vegetation cover. Contamination of sewage and mineral processing, extraction and recovery processes can affect large areas. The impact can be rated as medium, if no mitigation measures are implemented. However, with the implementation of mitigation measures, the impact significance will reduce to low.

• Archaeological Impact: During exploration works, historical resources may be impacted through inadvertent destruction or damage. This may include the excavation of subsurface graves or other archaeological objects. There was no information provided about known heritage nor site of cultural values within the site nor in the vicinity of the project site area. Therefore, this impact can be rated medium to low, if there are no mitigation measures in place. Upon implementation of the necessary measures, the impact significance will be low.

• Noise: The exploration work, especially drilling may be a nuisance to surrounding neighbours. Excessive noise can also be a health risk to site workers. Furthermore, the exploration equipment used for drilling on site is of medium size and the noise level is bound to be limited to the site only, and therefore, the impact likelihood is minimal. Without any mitigations, the impact is rated as of medium significance. In order to change the impact significance from the pre-mitigation significance to low rating, the mitigation measures should be implemented.

Conclusions

The potential positive and negative impacts stemming from the proposed exploration activities were identified, assessed and mitigation measures made thereof. The mitigation measures recommended in this report and management action plans provided in the draft EMP, can be deemed sufficient to avoid and/or reduce (where impact avoidance is impossible) the risks to acceptable levels. EDS is therefore confident that these measures are sufficient and thus recommends that the Proponent be issued with the Environmental Clearance Certificate (ECC) to enable the exploration works on EPL 7028 and 7029. However, the ECC should be issued on condition that the provided management measures and action plans are effectively implemented on site. Most importantly, monitoring of the environmental components described in the impact assessment chapter should be conducted by the Proponent and applicable Competent Authority.

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This is to ensure that all potential impacts identified in this study and other impacts that might arise during implementation are properly identified in time and addressed. Lastly, should the ECC be issued, the Proponent will be expected to be compliant with the ECC conditions as well as legal requirements governing the mineral exploration and related activities.

Limitations

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

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

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... i LIST OF FIGURES ...... xii LIST OF TABLES ...... xii LIST OF APPENDICES ...... xiii LIST OF ABBREVIATIONS ...... xiv 1 INTRODUCTION ...... 1 1.1 Project Background ...... 1 1.2 Terms of Reference and Scope of Works ...... 1 1.3 Appointed Environmental Assessment Practitioner ...... 3 1.4 Details of the Project Proponent ...... 3 1.5 The Need for the Proposed Project ...... 4 2 PROJECT DESCRIPTION: PROPOSED EXPLORATION ACTIVITIES ...... 5 2.1 Prospecting ...... 5 2.2 Exploration Drilling, Sampling and Analysis ...... 6 2.3 Decommissioning Phase ...... 8 3 PROJECT ALTERNATIVES...... 9 3.1 Types of Alternatives Considered ...... 9 3.1.1 The "No-go" Alternative ...... 9 3.1.2 Prospecting Location ...... 9 3.1.3 Exploration Methods...... 10 3.2 Conclusion on Alternatives ...... 10 4 LEGAL FRAMEWORK: LEGISLATION, POLICIES AND GUIDELINES ...... 11 4.1 The Environmental Management Act (No. 7 of 2007) ...... 11 5 ENVIRONMENTAL BASELINE ...... 17 5.1 Climate ...... 17 5.2 Topography and Drainage ...... 19 5.3 Soils ...... 20 5.4 Geology ...... 22 5.5 Water Resources ...... 23 5.6 Fauna ...... 24 5.7 Flora ...... 25

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5.8 Population of Omaheke Region ...... 28 5.9 Tourism ...... 28 5.10 Surrounding Land Uses ...... 29 5.11 Heritage and Archaeology ...... 30 5.12 Economic Development ...... 30 5.13 Services Infrastructure ...... 31 5.13.1 Roads and Transport modes ...... 31 5.13.2 Power Supply ...... 31 5.13.3 Water Supply ...... 31 6 PUBLIC CONSULTATION PROCESS ...... 32 6.1 Pre-identified and Registered Interested and Affected Parties (I&APs) ...... 32 6.2 Communication with I&APs ...... 33 6.3 Second Public Meeting: 2 October 2019 ...... 34 6.4 First Round Public Feedback ...... 35 7 IMPACT IDENTIFICATION, ASSESSMENT AND MITIGATION MEASURES ...... 36 7.1 Impact Identification ...... 36 7.2 Impact Assessment Methodology ...... 36 7.2.1 Extent (spatial scale) ...... 38 7.2.2 Duration ...... 38 7.2.3 Intensity, Magnitude / severity ...... 38 7.2.4 Probability of occurrence ...... 39 7.2.5 Significance ...... 39 7.3 Assessment of Potential Negative Impacts: Surveys, Drilling, Sampling (Operational Phase)41 7.3.1 Loss of Biodiversity (Fauna and Flora) ...... 42 7.3.2 Generation of Dust ...... 43 7.3.3 Waste Generation ...... 43 7.3.4 Visual Impact (Scars) on Landscape ...... 44 7.3.5 Potential Health and Safety Risks ...... 45 7.3.6 Impact on Surrounding Soils ...... 45 7.3.7 Archaeological Impact ...... 46 7.3.8 Noise ...... 47 7.4 Assessment of Potential Negative Impacts: Decommissioning Phase ...... 47 8 RECOMMENDATIONS AND CONCLUSIONS ...... 49

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8.1 Recommendations ...... 49 8.2 Conclusions ...... 50 9 REFERENCES ...... 51

LIST OF FIGURES

Figure 1: Location of the EPL No. 7028 and 7029 near Witvlei settlement, in the Omaheke Region ...... 2 Figure 2: Diagram of the Life Cycle of a Mine (after Superfund Research Project, 2019). The phase covered by this study is highlighted with a red box...... 5 Figure 3: A graph showing temperature patterns for one year (September 2018 – September 2019) in Gobabis which is located about 50 km west of Wetvlei in Omaheke Region ...... 18 Figure 4: A graph showing Wind patterns for one year (September 2018 – September 2019) in Gobabis which is located about 50 km west of Wetvlei in Omaheke Region...... 19 Figure 5: Hydrology Map of EPL 7028 & 7029 ...... 20 Figure 6a &b: Typical sand soils on the proposed site ...... 21 Figure 7: Map displaying geology of the project area...... 23 Figure 8a&b: Some vegetation seen on site ...... 27 Figure 9: Map of farms covered by the EPLs ...... 29 Figure 10: Public notices placed in Witvlei ...... 33 Figure 11: Public meeting turn out for the first meeting scheduled for 25 September 2019 ...... 34

LIST OF TABLES

Table 1: Proponent contact details and purpose of the required ECC ...... 3 Table 2: Applicable local, national and international standards, policies and guidelines governing the proposed development ...... 11 Table 3: Water distribution in Omaheke by NamWater ...... 24 Table 4: Summary of Interested and Affected Parties (I&APs) ...... 32 Table 5: Summary of main issues and comments received during the first public site engagement ...... 34 Table 6: Extent or spatial impact rating ...... 38 Table 7: Duration impact rating ...... 38 Table 8: Intensity, magnitude or severity impact rating ...... 38 Table 9: Probability of occurrence impact rating...... 39 Table 10: Significance rating scale ...... 40 Table 11: Assessment of the impacts of exploration on biodiversity ...... 42 Table 12: Assessment of the impacts of exploration on air quality ...... 43 Table 13: Assessment of waste generation impact ...... 43 Table 14: Assessment of the exploration on visual ...... 44 Table 15: Assessment of the impacts of exploration on health and safety ...... 45 Table 16: Assessment of the impacts of exploration on soils ...... 46

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Table 17: Assessment of the impacts of exploration on archaeological sites ...... 46 Table 18: Assessment of the impacts of noise from exploration ...... 47 Table 19: Assessment of the impacts of exploration activities closure on employment ...... 48

LIST OF APPENDICES

Appendix A: ECC Application Form Plus Revenue Stamps

Appendix B: Environmental Management Plan (EMP)

Appendix C: Curricula Vitae (CV’s) for the Environmental Assessment Practitioners (EAPs)

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

Appendix E: Background Information Document (BID)

Appendix F: EIA Notification in the newspapers (New Era and the Namibian)

Appendix G: Public Meeting Minutes (held on 25 September 2019 and 2 October 2019)

Appendix H: Public Meeting Attendance Register

Appendix I: Copy of Mineral Licenses Certificates from MME

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LIST OF ABBREVIATIONS

Abbreviation Meaning

AMSL Above Mean Sea Level

BID Background Information Document

CV Curriculum Vitae

DEA Department of Environmental Affairs

EA Environmental Assessment

EAP Environmental Assessment Practitioner

ECC Environmental Clearance Certificate

EDS Excel Dynamic Solutions

EIA Environmental Impact Assessment

EMA Environmental Management Act

EMP Environmental Management Plan

EPL Exclusive Prospecting License

GG Government Gazette

GN Government Notice

I&APs Interested and Affected Parties

MET Ministry of Environment and Tourism

Reg Regulation

S Section

TOR Terms of Reference

UK United Kingdom

Key Terms

xiv Aloe Investments: EPL 7028 & 7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

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

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

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

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

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

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

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

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

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

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Fauna - All of the animals found in a given area

Flora - All of the plants found in a given area

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

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

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

Public consultation/involvement - A range of techniques that can be used to inform, consult or interact with stakeholders affected by the proposed activities

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

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

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1 INTRODUCTION

1.1 Project Background White Metal Resources Corp. (hereinafter referred to as White Metal Resources) is a Canadian-based, international mineral exploration company focused on the acquisition, exploration and development of precious and base metal projects. White Metal Resources, through its 100% owned subsidiary Aloe Two Hundred and Thirty Seven (Proprietary) Limited (hereinafter referred to as “Aloe Investments 237”), has a 95% interest in Exclusive Prospecting Licences (EPL) 7028 and 7029. The two licenses are part of the DorWit Copper Project (DorWit Technical Report, 2019). There are no known impediments to the continued exploration and evaluation of these EPLs. The locality map of the proposed EPLs 7028 & 7029 site is shown in Figure 1.

In terms of Section 27 of the Environmental Management Act (EMA), No.7 of 2007 and its 2012 Environmental Impact Assessment (EIA), some activities as listed may not be carried out without an Environmental Impact Assessment (EIA) being undertaken and Environmental Clearance Certificate (ECC) being obtained. The relevant listed activities as per EIA regulations are:

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

Consequently, Aloe Investments 237 appointed Excel Dynamic Solutions (Pty) Ltd (“EDS”), an independent team of Environmental Consultants to conduct the required EA process and submit the ECC application to the Ministry of Environment and Tourism and Ministry of Mines and Energy on their behalf.

1.2 Terms of Reference and Scope of Works Exploration activities are listed among those that may not be carried out by individuals or organizations without an EIA being undertaken and an ECC granted. EDS was appointed by the Proponent to undertake an environmental assessment for the purpose of applying for an ECC for exploration work on EPL 7028 & 7029. There were no formal Terms of Reference (ToR) provided by the Proponent to EDS. The consultant, instead, relied on the requirements of the Environmental Management Act (No. 7 of 2007) (EMA) and its Environmental Impact Assessment (EIA) Regulations (GN. No. 30 of 2012) to conduct the study.

1 Aloe Investments: EPL 7028 & 7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

Figure 1: Location of the EPL No. 7028 and 7029 near Witvlei settlement, in the Omaheke Region

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1.3 Appointed Environmental Assessment Practitioner In order to satisfy the requirements of the EMA and its 2012 EIA Regulations, Aloe Investments 237 appointed EDS or the Environmental Assessment Practitioner hereafter, an independent consulting company to conduct the required EIA process on their (Proponent's) behalf. The findings of the EIA process are incorporated into this report and the draft Environmental Management Plan (EMP, Appendix B) will be submitted as part of an application for an ECC to the Environmental Commissioner at the Department of Environmental Affairs (DEA), Ministry of Environment and Tourism (MET).

The entire EIA project is headed by Mr. Nerson Tjelos. The consultation process and reporting are conducted by Ms. Althea Brandt with the support of Mr. Kai Kleingunther. Mr. Nerson Tjelos, a qualified and experienced Geoscientist and experienced EAP conducted public meetings and contributed to report writing and review. The CV for Mr. Tjelos is presented in Appendix C.

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

Table 1: Proponent contact details and purpose of the required ECC

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

Aloe C/O L&B Secretarial Services, Unit 3, Private Bag 12012, Exclusive Prospecting License (EPL) Investments 2nd Floor, Dr. Agostinho Neto Road, Windhoek No. 7028 and 7029 near Witvlei Two Hundred Ausspannplatz, Windhoek, Namibia Settlement in the Omaheke Region, and Thirty- Namibia Tell: +264 (0)61 429 851 Seven (Pty) Ltd

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1.5 The Need for the Proposed Project Exploration and Mining activities contribute to 25% of the country’s income, thus regarded as one of the largest contributors to the Namibian economy. Namibia has various natural resources including diamonds, uranium, copper, gold, lead, tin, lithium, cadmium, zinc, salt and vanadium. Participation of local communities in prospecting, exploration and mining sector does not only create employment and increase revenue, but also contribute to the Gross Domestic Product (GDP) of the country, which can help achieve a balance between the creation and distribution of wealth. Moreover, mining forms the core of some of Namibia’s development plans, namely: National Development Plan 5 (NDP5) and Harambee Prosperity Plan (HPP). In addition, mining does not only form the core of the national development plans, but the Vision 2030 too. A discovery of an economic deposit on any of the two or on both EPLs will contribute positively, as a solution, to the ever-increasing demand for base metals for the world’s growing population and for prosperity. Copper is one of the metals on which a technological society is based. In addition, its (Copper) behaviour as an electrical and thermal conductor appears to ensure a long-term future for the metal in spite of threats of substitution by fibre optics and ceramic superconductors. Moreover, because of the large number of producers in the world, the metal is not as susceptible as other commodities to large price swings as a result of speculation or cartel sales.

Given the fact that this activity creates employment to the local community and contributes to the country’s GDP, this justifies the need for exploration work on EPL 7028 & 7029 to enable future mining works, if found to be economically feasible.

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2 PROJECT DESCRIPTION: PROPOSED EXPLORATION ACTIVITIES The description of exploration activities to be undertaken is presented below (section 2.1, 2.2 and 2.3).

Figure 2: Diagram of the Life Cycle of a Mine (after Superfund Research Project, 2019). The phase covered by this study is highlighted with a red box.

2.1 Prospecting The prospecting phase includes; reviewing of existing reports and composite stratigraphic, lithological- geochemical maps of the targeted areas to identify prospective lithostratigraphic packages. In addition to literature review, field work (lithological (soil/rock) mapping and sampling) will be conducted to verify desktop work. Up to this point no physical disturbance is required.

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2.2 Exploration Drilling, Sampling and Analysis This is the operational phase of the exploration program. The target areas within the EPLs boundaries which have been identified during the prospecting phase will then undergo exploration drilling. The preferred drilling technique for this exploration programme is Reverse Circulation (RC) Drilling. RC Drilling uses a pneumatic hammer which drives a rotating tungsten-steel bit. The technique produces an uncontaminated large volume sample which is comprised of rock chips. It is relatively quick and cheap compared with other techniques like Diamond Drilling. There have been past drilling activities on the areas, and understandably using diamond coring technique. Based on the past findings and recommendation from past geology studies, RC Drilling is the preferred technique for the planned exploration work. In the advanced stage of exploration activities, larger amount of sample material may be required for analysis and to perform processing trials. Pit may be dug to sampling. The size of the sample size may be adjusted depending on the nature of mineralization observed from drilling. No explosives will be used during exploration phase. Other aspects of the exploration operations include:

2.2.1 Site Access

The Witvlei Property is situated about 150 km east of Windhoek via B6 Motorway and just about 3.3 km from the village of Witvlei which is a small village with one school, one clinic, one petrol station (Figure 1) and a police station. Windhoek is the social, economic, political, and cultural centre of the country. Most of the commercial industry, governmental offices, and educational institutions are headquartered in Windhoek. To the east of Witvlei and about 52 km on B6 Motorway is the regional capital of the Omaheke Region, Gobabis. Access to exploration site(s) will be organised along the existing roads as far as possible. Tracks for new access roads will be assessed for any environmental sensitivity.

2.2.2 Resources

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2.2.3 Services

Water: No water is required for RC drilling. Water required for other exploration activities and human consumption will be obtained from existing boreholes, or from approved water sources. Water required primarily for drinking and washing is supplied from two key service providers: Witvlei settlement, and farmers.

Power supply: No power supply infrastructure to the exploration site is planned for. Diesel power generation will be used during exploration phase.

2.2.4 Accommodation

2.2.5 Timeframe

2.2.6 Waste Management

2.2.7 Security

Temporary storage areas for drilling materials, machines and other project materials and equipment will be necessary at the camp. Security will be supplied on a 24-hour basis at the storage and/or camp site and

7 Aloe Investments: EPL 7028 & 7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029 exploration camp. A temporal support fence surrounding the storage/camp site will be constructed to ensure people and domestic animals are not put at risk.

2.3 Decommissioning Phase As it is with all exploration projects, exploration activities on EPL 7028 and 7029 will come to an end. The decommissioning of the exploration operations may be considered due to poor exploration results or declining in the copper market price. During the operational phase and before decommissioning, the Proponent will need to put site rehabilitation measures in place. Where necessary, stockpiling of top soil for rehabilitation at a later stage will be undertaken. Necessary landscaping of exploration areas will be undertaken upon completion of each phase of exploration (drilling, sampling etc.).

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

Once the alternatives have been established, these are examined by asking the following three questions:

• What alternatives are technically and economically feasible?

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

• What is the rationale for selecting the preferred alternative?

The alternatives considered for the proposed development are discussed in the following subchapters.

3.1 Types of Alternatives Considered

3.1.1 The "No-go" Alternative

The “No-Go” alternative is the option of not proceeding with the activity, which typically implies a continuation of the status quo. Should the proposed works of the prospecting plan be discontinued, none of the potential impacts (positive and negative) identified would occur. Furthermore, the local people to be employed for exploration work will be left unemployed. Without the exploration activities, the Proponent would not be able discover and define the targeted resource for possible mining and contribute to the country’s economy through revenue and mining license royalty payments. If the proposed project is to be discontinued, the current land use for the proposed site will remain unchanged. In considering the proposed project, the ‘no-go’ option is not considered the preferred alternative.

3.1.2 Prospecting Location

The prospecting/exploration location is dependent on the mineralogy and geology of the area. Therefore, finding an alternative location for the planned exploration activities is not possible. In other words, the base metals (i.e. copper) mineralization is area specific, which means exploration targets are primarily determined by the geology (host rocks) and the tectonic environment of the site (ore forming mechanism).

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3.1.3 Exploration Methods

Both invasive and non-invasive exploration activities are expected to take place. If an economically viable discovery is made, the project will proceed to mining phase. Metals can be extracted from the earth by two main methods, namely surface (open cast) and underground mining.

3.2 Conclusion on Alternatives The conclusions weighed and considered above are summarized below:

• No-go alternative: Should the proposed prospecting and exploration works on the two EPL 7028 &7029 be discontinued, none of the potential impacts (positive and negative) identified would occur. Furthermore, the local people to be employed by the project will be left unemployed and the Proponent would not be able discover and define the targeted resource for possible mining to generate an income and contribute to the country’s economy through revenue and license royalty payments. In considering the proposed project, the ‘no-go’ option is not considered the preferred alternative.

• Prospecting location: Finding an alternative location for the planned exploration activities is not possible (refer to section 3.1.2)

The exploration activities have certain legal implications and these applicable legal standards are presented in the following chapter.

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4 LEGAL FRAMEWORK: LEGISLATION, POLICIES AND GUIDELINES A review of applicable and relevant Namibian legislation, policies and guidelines to the proposed development are given in this chapter. This review serves to inform the project Proponent, Interested and Affected Parties and the decision makers at the DEA of the requirements and expectations, as laid out in terms of these instruments, to be fulfilled in order to establish the proposed prospecting and exploration activities.

4.1 The Environmental Management Act (No. 7 of 2007) This EIA was carried out according to the Environmental Management Act (EMA) and its Environmental Impact Assessment (EIA) Regulations (GG No. 4878 GN No. 30).

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

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

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

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

Table 2: Applicable local, national and international standards, policies and guidelines governing the proposed development

Legislation/Policy/ Relevant Provisions Implications for this project Guideline

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

Details principles which are to guide all EAs.

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

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

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

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

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

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

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

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

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

Minerals (Prospecting Section 52 requires mineral license holders to enter into The Proponent should enter into a and Mining) Act (No. 33 a written agreement with affected landowners before written agreement with landowners of 1992) exercising rights conferred upon the license holder. before carrying out exploration on their land. Section 52(1) mineral licence holder may not exercise his/her rights in any town or village, on or in a The Proponent should carry out an proclaimed road, land utilised for cultivation, within assessment of the impact on the 100m of any water resource (borehole, dam, spring, receiving environment. drinking trough etc.) and boreholes, or no operations in The Proponent should include as part municipal areas, etc.) which should individually be of their application for the EPLs checked to ensure compliance. measures by which they will Section 54 requires written notice to be submitted to the rehabilitate the areas where they Mining Commissioner in the event that the holder of a intend to carry out mining exploration mineral license (which includes and EPL) intends to activities. abandon the mineral license area. The Proponent may not carry out Section 68 stipulates that an application for an exclusive exploration activities within the areas prospecting license (EPL) shall contain the particulars of limited by Section 52(1) of this Act the condition of, and any existing damage to, the environment in the area to which the application relates and an estimate of the effect which the proposed prospecting operations may have on the environment and the proposed steps to be taken in order to prevent or minimize any such effect.

Section 91 requires that rehabilitation measures should be included in an application for a mineral license.

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

Mine Health & Safety Makes provision for the health and safety of persons The Proponent should comply with all Regulations, 10th Draft employed or otherwise present in mineral license areas. these regulations with respect to their These deal with among other matters; clothing and employees. devices; design, use, operation, supervision and control of machinery; fencing and guards; and safety measures during repairs and maintenance.

Petroleum Products and Regulation 3(2)(b) states that “No person shall possess The Proponent should obtain the Energy Act (No. 13 of [sic] or store any fuel except under authority of a licence necessary authorisation from the 1990) Regulations or a certificate, excluding a person who possesses or Ministry of Mines and Energy (MME) (2001) stores such fuel in a quantity of 600 litres or less in any for the storage of fuel on-site. container kept at a place outside a local authority area”

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

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

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

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

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

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

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

Forestry Act (No. 12 of Part IV of this Act provides for the general protection of 2001) the environment.

Permits are required for the removal of protected plants Permits should be obtained if there will species. be any removal of or damage to

Nature Conservation Makes provision for the protection of indigenous flora protected plant species. and fauna. Ordinance No. 4 of 1975 Permits are required for the removal of protected plants (as amended) species.

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

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

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

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

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

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

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

The following chapter is a presentation of the pre-prospecting baseline (environmental baseline).

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

The baseline information presented below has been sourced from different reports of studies conducted in the Omaheke Region (at large) as well those done for the Town of Witvlei. The rest of the information has then been obtained by the Environmental Consultant upon site visit conducted on 25 September 2019 and then again on 2 October 2019.

5.1 Climate 5.1.1 Rainfall

Generally, the Omaheke Region is known for unpredictable rainfall patterns, high temperature and evaporation. According to Mendelsohn et al (2002), rainfall is most received in the summer months when moist air feeds the area from tropical zones. Most of the farms in the Omaheke region currently receive between 308 and 478mm/year, which is expected to fall to 154 ‐ 307mm/year by 2080.There is not much rainfall in Witvlei all year long. The driest month is July. In January, the precipitation reaches its peak (https://en.climate-data.org).

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Figure3: A graph showing rainfall patterns for one year (September 2018 – September 2019) in Gobabis which is located about 50 km west of Wetvlei in Omaheke Region

5.1.2 Temperature

The average maximum temperatures during the hottest month in the area ranges from 32-34°C. In Witvlei, the average annual temperature is 19.3 °C. With an average of 24.3 °C, December is the warmest month. At 12.3 °C on average, July is the coldest month of the year (https://en.climate-data.org)

Figure 3: A graph showing temperature patterns for one year (September 2018 – September 2019) in Gobabis which is located about 50 km west of Wetvlei in Omaheke Region

5.1.3 Evaporation

The average annual evaporation rate of the Omaheke Region ranges between 1960 mm/year and 2100 mm/year.

5.1.4 Wind

Gobabis has predominantly easterly wind. Southerly, easterly and northerly airflow is common. The highest wind speeds are attained in September as shown in figure 4.

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Figure 4: A graph showing Wind patterns for one year (September 2018 – September 2019) in Gobabis which is located about 50 km west of Wetvlei in Omaheke Region

5.2 Topography and Drainage The area of Witvlei are generally flat and dominantly covered with Acacia trees. There are pockets of swamps and water pans observed in the area. This could be attributed by the presence of the Acacia trees, once precipitation is received it is intercepted by leaves and able to percolate underground and recharge groundwater reserves. See below the hydrology map in figure 5.

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Figure 5: Hydrology Map of EPL 7028 & 7029

5.3 Soils The key biomes of Omaheke Region are the central Kalahari and southern Kalahari, characterised by sandy soils and acacia savannahs. The Witvlei-Gobabis area has preserved Witvlei Group consisting of a mixed coarse- to fine-grained siliciclastic and carbonate strata deposited in deep to shallow marine, and locally non-marine, settings along the post-rift continental margin of the Kalahari Craton prior to the onset of foreland basin sedimentation recorded by the overlying terminal Neoproterozoic–Cambrian Nama Group.

The site is overlain by sandy soils, in light brown (Figure 6a&b below).

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(a)

(b)

Figure 6a &b: Typical sand soils on the proposed site

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5.4 Geology The two EPLs (7028 & 7029) are situated in the Kalahari Copperbelt stretching from Central Namibia to Northern Botswana. In central Namibia, copper mineralization, hosted by slate and phyllite, is intermittently developed over more than 60 km of strike of the Kagas Member of the Klein Aub Formation. The structural associations (e.g., the relation to a late reverse fault at Klein Aub) and detailed textural features (e.g., copper in veins, brittle fractures, cleavage-parallel lenticles and tectonic breccia zones) indicate that copper mineralization was emplaced into structurally controlled sites, late in the deformation history of the region. The conclusion of the present review is that economically viable copper accumulations resulted predominantly from one or more regionally extensive but locally structurally controlled hydrothermal events, mostly subsequent to formation of the dominant cleavage. As a result, modern exploration should focus primarily on favourable structures, particularly potential dilatant sites in tectonically complex zones.

The deposits are described as sediment-hosted copper deposits, the second most important sources of copper next to porphyry copper deposits, which account for about 20% of the world’s copper production. In 2007, West Africa Gold Exploration (Namibia) (Proprietary) Limited (“WAGE”) calculated a Joint Ore Reserves Committee (“JORC”) compliant Inferred Mineral Resource for the Koperberg Prospect (Dordabis Property), reported as 1.74 Mt grading 0.97% Cu (representing approximately 17,000 tonnes of in situ copper metal) at a cut-off grade of 0.5% Cu. MSA (2009), audited and verified the methodology and calculations of the Koperberg Prospect mineral resource statement and found it to be acceptable according to JORC guidelines (DorWit Copper Project – Namibia, 2019).

Below in figure 7, the map illustrates the specific rock types found at the site.

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Figure 7: Map displaying geology of the project area.

5.5 Water Resources The water supply situation in the Omaheke Region is split between two key service providers: the Directorate of Water Supply and Sanitation Coordination, and NamWater. The Directorate of Water Supply and Sanitation Coordination manages approximately 505 water points in four constituencies, mostly by the use of diesel engines, of which 211 were rehabilitated for communities in order that they might manage themselves. It is also estimated that out of the total water points only 279 water point committees are functional in managing their water points in accordance with the strategy of community- based management. The Directorate of Water Supply and Sanitation Coordination estimates that an additional 146 boreholes in the four communal constituencies run privately without the assistance of Government (Omaheke Regional Development Profile, 2019).

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Table 3: Water distribution in Omaheke by NamWater

5.6 Fauna According to (RBS, 2015) Omaheke regions is home to reptiles, mammals, birds and reptiles. Reptiles of greatest concern are probably the two species classified as insufficiently known and rare (Mehelya vernayi and Psammophis jallae) and the tortoises (Stigmochelys pardalis and Psammobates oculiferus) which are often consumed by humans; Python natalensis which is indiscriminately killed throughout its range and Varanus albigularis (food) as well as the various Pachydactylus species geckos of which 71.4% are viewed as endemic. None of the reptiles are exclusively associated with the EPLs.

Ninety three (93) species of mammals are expected to occur in the general area of Omaheke and in other parts of Namibia. Only 2% are endemic and 30% are classified under international conservation legislation. The most important species under Namibian legislation are those classified as rare (Namibian wing-gland bat, Woosnam’s desert mouse, hedgehog and black-footed cat), endemic and vulnerable (especially

24 Aloe Investments: EPL 7028 & 7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029 eland) species. Other important species are pangolin (which are used for traditional medicinal purposes) and the African wild dog that occasionally occurs in the general area (Annex 2). None of the mammals are exclusively associated with the two EPLs.

The birds classified as endangered, near threatened and vulnerable by the IUCN (2014) – Kori bustard, white-backed vulture, bateleur, black harrier, martial eagle and secretary bird – are also viewed as important. However, none of these birds are exclusively associated with the EPLs.

An environmental assessment carried out by Resilient Environmental Solutions (2019) indicated that faunal species diversity in Omaheke’s Kalahari savanna is less than in other parts of Namibia because of the relatively lower habitat variety and the lack of surface water. Apart from trees, and a few outcrops within the project area in general, there are no outstanding landforms or unique habitats that host particular endemic species. The animal life that is expected to occur in the project area is expected to be widely distributed in similar habitats within the wider biome area (SAIEA, 2016).

5.7 Flora Vegetation on the Witvlei property comprises the Camelthorn Savanna, an area of grassland with an upper layer of large shrubs and/or trees which are dominantly Camelthorn.

The project area is located within the Central Kalahari vegetation type. The vegetation of the area is classified as northern Kalahari bush savannah (Mendelsohn et al. 2002) and is characterised by dense stands of edible bush covering the dunes, of which Croton gratissimus, Combretum apiculatum, Terminalia sericea and Philenoptera nelsii, and shrubs such as Bauhinia petersiana and Grewia species are the most common (Rawlinson 1994). Terminalia sericea is regarded as the main bush encroaching species in the study area (De Klerk 2004). Figure 8 shows the typical vegetation type in Witvlei.

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(a)

(b)

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(c)

Figure 8a&b: Some vegetation seen on site

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5.8 Population of Omaheke Region The Omaheke Region is situated in the Eastern Namibia. It borders Botswana in the east, while within the country it borders the Hardap region to the south-west, Khomas region to the west and Otjozondjupa region to the north-west. Omaheke is known for cattle farming and the TransKalahari highway. The highway is Namibia’s most important Central-Eastern gateway for travellers, and connects the country to Botswana, South Africa and Zimbabwe for goods transportation (National Statistics Agency, 2011). The population of Omaheke Region recorded in the Omaheke 2011 Census Regional Profile in 2011 was 71 233 (34 016 females and 37 217 males). This figure shows that the Regional population had increased from 68 039 since recorded in 2001 (Namibia Statistics Agency (NSA), 2011).

5.9 Tourism Namibia is experiencing a boom in tourism and is ranked as the fourth fastest growing tourism destination in the world. In 2012, tourism (mostly cultural) accounted for 19.7% of Namibia’s employment statistics. As Omaheke means “sandveld”, which is derived from being situated in the western parts of the Kalahari Desert, the region is ideal for 4x4 routes, dune hiking and walking trails, amongst other such activities. Omaheke Region’s capital centre Gobabis serves as an important tourism gateway between the SADC Countries. It links to one of the most important tourism routes, the Trans Kalahari Highway, which connects the Omaheke Region with the Okavango Delta and the rest of Namibia.

In summary, Omaheke’s tourism attractions focus on culture, cultural landscapes, values and lifestyle, heritage, visual and performing arts, traditions and leisure pursuits of the host community. Omaheke has been identified as having great potential to diversify Namibia’s overall tourism product.

Omaheke has 43 tourism establishments, mainly guest/hunting farms on commercial land and accommodation establishments in Gobabis. The guest/hunting farms are known for trophy hunting and an annual meat festival that attracts many tourists (Omaheke Regional Development Profile, 2015).

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5.10 Surrounding Land Uses The Witvlei Settlement town has schooling, health clinic, shopping, postal office and a fueling facility and is rapidly developing additional townships at the settlement. The EPLs (which share borders near the settlement town center) falls within a mixed communal, private commercial farmland. The overall landscape in Omaheke and specifically in the licences areas is dominated by topographically low laying areas of the Kalahari Desert landforms cut across by a number of major and minor streams. The land uses in these areas are mainly dominated by agriculture (cattle, sheep and goats). Other land use activities found in the general areas include tourism and crop farming in some limited areas due to the limitation on water supply.

Figure 9: Map of farms covered by the EPLs

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5.11 Heritage and Archaeology Omaheke region, like other regions in Namibia, has different ethnic groups such as the Herero/Ovambanderu, Tswana, Kavango, Ovambo, San and Damara/Nama. Cultural festivals are held every year from constituency to regional level where different groups showcase their traditional dress, dancing, and rituals. Various programmes initiated by the Directorate of National Heritage and Culture have been undertaken in order to encourage Namibians from all cultural backgrounds to take part in nation building activities and show mutual respect and understanding for each other. Additionally, the establishment of processes and networks to develop Namibians’ material and spiritual culture, to establish and maintain links beyond national borders and to contribute towards human culture development and international understanding are required. The Directorate organizes cultural activities, cultural exchange activities, workshops, conferences and training programmes, exhibitions and culture and heritage conservation activities (Omaheke Regional Development Profile, 2015).

5.12 Economic Development Omaheke is a net exporter of beef and operates in a fiercely competitive market which determines sales prices. The region ensures that the production chain is passed on to the producer primarily through its abattoir in Gobabis. The abattoir in Witvlei ceased operation in 2015.There are alsoseveral auction facilities that are situated along the Trans Kalahari Highway and constituencies.

One of Omaheke Region’s intentions is to become the beef basket of Namibia by specializing in the production and processing beef and by-products. This is in line with government policies of ensuring that value is added to products produced within the country, rather than solely exporting cattle on-hoof which leads to the re-import of cattle by-products that originated from Namibia.

The region has a well-known and prosperous agricultural industry comprised mainly of cattle, goat and sheep farming. In 2001, 28% of the households in Omaheke Region reported farming as their main source of income. That figure was reduced to 22% in 2011 (Omaheke Regional Development Profile, 2015).

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5.13 Services Infrastructure

5.13.1 Roads and Transport modes

The Witvlei properties are situated in a desirable location when it comes to infrastructure due to the proximity to major city center, direct access by roads to Licences, railway, and commercial ports. Windhoek (population 325,858 in 2011) is the social, economic, political, and cultural centre of the country. Nearly every Namibian national enterprise, governmental body, educational and cultural institution is headquartered there.

B6 motorway which part of the Trans-Kalahari Corridor runs next to EPL 7028 and EPL 7029. This corridor connects with the port of Walvis Bay and is accesses the landlocked countries of the Democratic Republic of Congo, Zambia, Botswana and Zimbabwe.

The Windhoek Hosea Kutako International Airport is between 80 km of both EPL 7028 and EPL 7029. It has daily flights to regional and international destinations such as OR Tambo International Airport in Johannesburg, South Africa that serves as a regional hub to the connections to the rest of the world.

Rail service in Namibia is provided by TransNamib. Namibia’s rail network consists of 2,382 route- kilometres of track. This railway system of tracks runs through EPL 7029 and the station is located in Windhoek with connections to other locations.

5.13.2 Power Supply

No power supply infrastructure to the exploration site is planned for. Diesel power generation will be used during exploration phase. Upon discovery of mineable resources, arrangement will be made with Namibia Power Corporation (NamPower) for possible supply of electricity for mining activities.

5.13.3 Water Supply

No water is required for RC drilling. Water required for other exploration activities and human consumption will be obtained from existing boreholes, or from approved water sources. Water required primarily for drinking and washing is supplied from two key service providers: Witvlei town (sourced from Namwater), and upon agreements, possibly from farmers’ boreholes.

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

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

6.1 Pre-identified and Registered Interested and Affected Parties (I&APs) EDS identified relevant and applicable national, regional and local authorities, church leaders and other interested members of the public. The (pre-identified) I&APs were contacted directly and some were registered as I&APs upon their request (those that were registered after the EA notification in the newspapers). Newspaper adverts of the proposed exploration activities were placed in two widely-read national newspapers in the region (The Namibian and New Era newspapers). The project advertisement / announcement ran for two consecutive weeks inviting members of the public to register as I&APs and submit their comments. The summary of pre-identified and registered I&APs is listed in Table 4 below and the complete list of I&APs is provided in Appendix D.

Table 4: Summary of Interested and Affected Parties (I&APs)

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

Ministry of Urban and Rural Development

Ministry of Labour, Industrial Relations and Employment Creation

Ministry of Health and Social Services

Ministry of Agriculture, Water and Forestry

Ministry of Mines and Energy Roads Authority Regional & Local Omaheke Regional Council

Witvlei Village Council

General Public Interested members of the public & Farm Owners

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

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

• Project Environmental Assessment notices were placed in The Namibian and New Era newspapers (Appendix F) dated 5 September 2019 and 19 September 2019, briefly explaining the activity and its locality, inviting members of the public to register as I&APs and submit comment;

• Public notices were placed at frequented places (Figure 10) in Witvlei to inform members of the public of the EIA process and register as I&APs as well as submit comments; and

• A public meeting was scheduled and held on 25 September 2019 in Witvlei and again on the 2 October 2019 (Figure 11).

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Figure 10: Public notices placed in Witvlei

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Figure 11: Public meeting turn out for the first meeting scheduled for 25 September 2019

6.3 Second Public Meeting: 2 October 2019 A second meeting was held in Witvlei, Haodadi Community Hall, Omataura at 17h00. The meeting was well-attended by some members of the public as well as the local authorities from Witvlei. The attendance register (Appendix H) and meeting minutes were compiled and are attached as Appendix G

These issues that were raised have been recorded; responses provided and are fully presented in the meeting minutes in Appendix G and incorporated in the environmental report and EMP. The summarized issues raised in the meeting are presented in Table 5 below. The issues raised and responses (by EDS) are attached under Appendix G.

Table 5: Summary of main issues and comments received during the first public site engagement

Issue Concern

Employment Will the project offer opportunities to community members?

Village has high unemployment rate of youth and elders

Can Witvlei community members be considered for other future projects by the same Proponent elsewhere?

How many people will be employed?

Business opportunities Exploration team should consider community services providers instead of sourcing goods from other towns and regions, especially if they are available in Witvlei

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Issue Concern

Noise Drilling activities can be noisy. What measures will be taken to ensure there is no noise disturbance to the community

Water Scarcity Wetvlei is faced with water scarcity. This is a concern even for future development.

Damage to properties Damaging of roads, fences and other properties especially those belonging to farmers

Theft concerns Illegal trespassing on people’s land and their activities. The cost of security needs to be addressed

Other benefits: housing, Will the project help support community members in need of housing, build CSR schools or support existing service provision entities

Time period How long is the project going to take?

Trust Community has had exploration teams in the past who promised them opportunities but nothing happened. How is the new team different

Presentation of EIA findings Consultants must come back to us once the study is completed

6.4 First Round Public Feedback Apart from issues raised during the (second) public meeting, there was no other comment received by EDS either via email or any other mode of communication after the EIA advertisement in the newspapers or upon placing public notices in Witvlei.

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

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7 IMPACT IDENTIFICATION, ASSESSMENT AND MITIGATION MEASURES

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

Positive impacts:

• Creation of jobs to the locals • Helps boost local economic growth. • Open up other investment opportunities. • Contribution to regional economic development.

Negative impacts:

• Loss of Biodiversity • Generation of dust • Waste generation • Visual impact (scars) on landscape • Potential health and safety risks • Surrounding Soils Impacted • Archaeological Impact

7.2 Impact Assessment Methodology The impact assessment method used for this project was adopted from previous environmental reports that were compiled by the author and as well as published reports online through research on the suitable project assessment methodology.

The identified impacts were assessed in terms of probability (likelihood of occurring), scale/extent (spatial scale), magnitude (severity) and duration (temporal scale) as presented in Table 5, Table 6, Table 7 and Table 8.

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

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

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

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7.2.1 Extent (spatial scale)

Extent is an indication of the physical and spatial scale of the impact. Table 6 shows rating of impact in terms of extent of spatial scale.

Table 6: Extent or spatial impact rating

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

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

7.2.2 Duration

Duration refers to the timeframe over which the impact is expected to occur, measured in relation to the lifetime of the project. Table 7 shows the rating of impact in terms of duration.

Table 7: Duration impact rating

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

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

7.2.3 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 8 shows the rating of impact in terms of intensity, magnitude or severity.

Table 8: Intensity, magnitude or severity impact rating

Type of criteria Negative

H- M/H- M- M/L- L-

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

Qualitative Very high Substantial Moderate Low deterioration, Minor deterioration, deterioration, deterioration, slight noticeable deterioration, high quantity of death, illness or discomfort, partial alteration in nuisance or deaths, injury of injury, loss of loss of habitat / habitat and irritation, minor illness / total loss habitat / diversity biodiversity or biodiversity. Little change in species /

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Type of criteria Negative

H- M/H- M- M/L- L-

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

of habitat, total or resource, resource, loss in species habitat / diversity alteration of severe alteration moderate numbers or resource, no or ecological or disturbance of alteration very little quality processes, important deterioration. extinction of rare processes species

7.2.4 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 9 for impact rating in terms of probability of occurrence.

Table 9: Probability of occurrence impact rating

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

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

7.2.5 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, Table 7, Table 8 and Table 9) 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 10).

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Table 10: 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 of time to enable the confirmation of the significance of the impact as low or medium and under control.

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

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

• Source: The cause or source of the contamination.

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

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

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

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

7.3 Assessment of Potential Negative Impacts: Surveys, Drilling, Sampling (Operational Phase) The main potential negative impacts associated with construction and operational (and maintenance phases) identified are; soil disturbance, dust (air pollution), visual impact, loss of biodiversity (fauna), health and safety, archaeological impact, waste generation and noise. Potential impacts identified to be associated with the exploration discontinuation; loss of economic growth for the country.

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

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7.3.1 Loss of Biodiversity (Fauna and Flora)

The drilling activities and earthworks done to expose the copper bearing rock units will potentially result in land degradation, thus destroying habitats of small animal species that may be encountered under the site soils and rocks. In order to enable the exploration operations, some site vegetation within the footprint of the exploration area may be removed. This will lead to the destruction of protected plant species. Thus, resulting in the loss of such species and eventual loss of biodiversity in the area. In fragile ecosystems, vegetation is easily disturbed, which often means any disturbance to the environment will result in the loss flora. It is therefore important to identify what species are present, understand them and try to minimise the impact upon them with operational management guidelines. The most obvious impact on vegetation is direct loss due to removal of soil by digging and trenching. EDS advises the Proponent to avoid unnecessary removal of vegetation, in order to promote a balance between biodiversity and their operations. Under the current status, the impact can be considered to be of a medium significance rating. With the implementation of appropriate mitigation measures, the rating will significantly be reduced to low. The impact is assessed in Table 11 below.

Table 11: Assessment of the impacts of exploration on biodiversity

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

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

• Even if a certain shrub or tree is found along drilling or sampling spots on sites, this does not mean that it should be removed. Therefore, care should be taken when extracting mineral species without destroying the vegetation.

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

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

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7.3.2 Generation of Dust

Dust emanating from site access roads when transporting exploration equipment and supply (water) to and from site (time-to-time) may compromise the air quality in the area. Vehicular movements create dust even though it is not always so severe. The hot and dry environment, loose and in some places sandy nature of the substrate and low vegetation cover causes ambient fugitive dust levels. The medium significance of this impact can be reduced by properly implementing mitigation measures. The impact is assessed in Table 12 below.

Table 12: Assessment of the impacts of exploration on air quality

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

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

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

7.3.3 Waste Generation

Prospecting and exploration activities are usually associated with generation of waste of all kinds (domestic and general) and if these are not disposed of in a responsible manner, it will result in the pollution of the site and the surrounding environment. Industrial waste is a given by-product of any exploration operation. Non-biodegradable and biodegradable refuse should be stored in a container and collected on a regular basis and disposed of at a recognized disposal facility. Precautions should be taken to prevent any refuse spreading. The container should be covered with mesh to prevent access from animals. Without any mitigation measure, the impact has a medium significance. The impact will be of low significance from medium, upon implementing the mitigation measures. The assessment of this impact is given in Table 13.

Table 13: Assessment of waste generation impact

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

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

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

7.3.4 Visual Impact (Scars) on Landscape

Visual impact due to exploration works is aesthetic damage to the landscape. Drilling and sampling activities usually leave scars on the local landscape. If the mining sites are located close to or along tourist routes, these scars in many cases contrasts the surrounding landscape and thus may potentially become a visual nuisance, especially to tourists in tourist-prone areas. Nonetheless, it is a vital to acknowledge that during prospecting phase, certain measures will need to be taken into consideration regarding the visual aspect. Currently, the visual impact can be rated as slightly medium to low significance, but upon effectively implementing the measures, the significance will be very low.

The assessment of this impact is presented in Table 14.

Table 14: Assessment of the exploration on visual

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

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

7.3.5 Potential Health and Safety Risks

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

This impact is assessed in Table 15 below and mitigation measures provided.

Table 15: Assessment of the impacts of exploration on health and safety

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

Mitigations and recommendation to minimize health and safety issues • As part of their induction, the workers should be provided with an awareness training of the risks of mishandling equipment and materials on site.

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

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

• Employees should not be allowed on site if under the influence of alcohol.

7.3.6 Impact on Surrounding Soils

Exploration works will potentially result in soil disturbance which will leave the already exposed site soils vulnerable to erosion. This impact is probable because the proposed site is vacant (bare) with no vegetation cover. Contamination from exploration related activities can affect large areas. The impact can be rated as medium, if no mitigation measures are implemented. However, with the implementation of mitigation measures, the impact significance will reduce to low.

The impact is assessed in Table 16 below and mitigation measures are provided below.

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Table 16: Assessment of the impacts of exploration on soils

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

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

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

• All waste should be correctly sorted and stored on site in designated waste containers until such as time that they will be disposed of at the nearby approved waste management facilities.

7.3.7 Archaeological Impact

During exploration works, historical resources may be impacted through inadvertent destruction or damage. This may include the excavation of subsurface graves or other archaeological objects. There was no information provided about neither known heritage nor site of cultural values within the site nor in the vicinity of the project site area. Therefore, this impact can be rated medium to low, if there are no mitigation measures in place. Upon implementation of the necessary measures, the impact significance will be low.

The impact is assessed in Table 17. below and mitigation measures are provided below

Table 17: Assessment of the impacts of exploration on archaeological sites

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

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

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

7.3.8 Noise

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

This impact is assessed in Table 18 below.

Table 18: Assessment of the impacts of noise from exploration

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

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

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

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

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

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

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7.4.1 Impact on Employment Opportunities and Economic Contribution

Should the exploration program come to an end, workers that are employed by the exploration company lose their jobs and source of income. This will also mean that there will be no more revenue and royalties paid to the government. This impact can be rated as of medium significance and given that the program has defined timeframe, only so much can be done by the Proponent to assist the workers in this regard. Regarding the national revenue and royalties’ payment, there will be unfortunately nothing that the Proponent would do to mitigate this. The impact significance of unemployment can be reduced from medium to low, by implementing mitigation measures. The impact assessed in Table 19 below is that of employment loss only.

Table 19: Assessment of the impacts of exploration activities closure on employment

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

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

• The Proponent should raise awareness of the possibilities for work in a similar or other industrial sectors.

To conclude this chapter, it is found that most of the identified potential negative impacts are rated as medium significant. Therefore, in order to reduce the significance from medium to low, it is recommended that the Proponent effectively implement mitigation measures. Furthermore, in order to maintain low significance, the implementation of measures will need to be continuously monitored.

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8 RECOMMENDATIONS AND CONCLUSIONS

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

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

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

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

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

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

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

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• Archaeological impact: There is no information provided and/or established about a known heritage nor site of cultural values within the site nor in the vicinity of the project site area. Therefore, this impact can be rated medium to low, if there are no mitigation measures in place. Upon implementation of the necessary measures, the impact significance will be low (provided in the EMP, Appendix B).

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

8.2 Conclusions The potential positive and negative impacts stemming from the proposed exploration activities were identified, assessed and mitigation measures made thereof. The mitigation measures recommended in this report and management action plans provided in the draft EMP, can be deemed sufficient to avoid and/or reduce (where impact avoidance impossible) the risks to acceptable levels. EDS is therefore confident that these measures are sufficient and thus recommends that the Proponent be issued with the Environmental Clearance Certificate (ECC) to enable the exploration works on EPL 7028 and 7029. However, the ECC should be issued on condition that the provided management measures and action plans are effectively implemented on site. Most importantly, monitoring of the environmental components described in the impact assessment chapter should be conducted by the Proponent and applicable Competent Authority. This is to ensure that all potential impacts identified in this study and other impacts that might arise during implementation are properly identified in time and addressed. Lastly, should the ECC be issued, the Proponent will be expected to be compliant with the ECC conditions as well as legal requirements governing the mineral exploration and related activities.

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9 REFERENCES Angula, S. E. (2007). The Environmental Impacts of Small-Scale Mining in Namibia: A Case Study of Uis Small-scale Mining Site - Erongo Region. Windhoek: University of Namibia.

Atlas of Namibia Project (2002) Directorate of Environmental Affairs, Ministry of Environment and Tourism website: (http://209.88.21.36/Atlas/Atlas_web.htm)

Benito, G., Rohde, R., Seely, M., Külls, C., Dahan, O., Enzel, Y., Roberts, C. (2009). Management of Alluvial Aquifers in Two Southern African Ephemeral Rivers: Implications for IWRM. Water Resources Management. Water Resources Management: Springer Link, 641-667.

Booth, P. (2011). Environmental Conceptual Site Model Exercise: Source – pathway – receptor. WSP Global: Semantic Scholar.

Christelis, G. and Struckmeier, F. (editors). (2001). Groundwater in Namibia: An Explanation to the Hydrogeological Map. Windhoek: Ministry of Agriculture, Water and Forestry.

Christelis, G. and Struckmeier, W. (eds). (2001). Groundwater in Namibia: An Explanation to the Hydrogeological Map. Windhoek: Ministry of Agriculture, Water and Forestry.

COWI 2017. Techno-economic advisor for the feasibility study of the encroacher bush biomass power project in Namibia – Biomass Source Report. Reference code: 2015059 NA ITF

EIS 2017. Environmental Information Service, www.the-eis.com

Geological Survey of Namibia website – http://www.mme.gov.na/gsn/

Mendelsohn, J., Jarvis, A., Roberts, C. & Robertson, T., 2003. Atlas of Namibia. 2nd ed. Cape Town: David Philip Publishers.

Miller R. McG. (2008), Geology of Namibia, Ministry of Mines and Energy, Geological Survey of Namibia, Windhoek.

Mweemba, M. S. (2014). Small-Scale Mining in Namibia: An Overview. Theme: “Earth Sciences and Climate Change: Challenges to Development in Africa” : 7th conference of the African Association of Women in Geosciences, Sub theme: Earth sciences and the community (p. 4). Windhoek: Ministry of Mines and Energy.

Namibia Statistics Agency. (2011). Namibia 2011: Population and Housing Census Main Report. Windhoek: Namibia Statistics Agency.

Robert S. Middleton., 2019: Competent Persons Report for White Metal Resources Corp, Effective Date of June 4, 2019.

World Population Review. (2019). World Population Review: United Nations population estimates and projections - Namibia Population. Retrieved October 10, 2019, from World Population Review: http://worldpopulationreview.com/countries/namibia-population/

World Weather Online Site: https://www.worldweatheronline.com/

51 Aloe Investments: EPL 7028 & 7029 APPENDIX A: COPY OF ENVIRONMENTAL CLEARANCE CERTIFICATE APPLICATION (FORM 1)

APPENDIX B: DRAFT ENVIRONMENTAL MANAGEMENT PLAN (EMP)

Environmental Management Plan (EMP)

Environmental Assessment (EA) For Exclusive Prospecting License (EPL) No. 7028 and 7029 near Witvlei Settlement in the Omaheke Region, Namibia

FINAL REPORT

EDS Project Number: PNEA2019-06

Author(s): Ms. Althea Brandt and Mr. Client: Aloe Investments Two Hundred and Thirty-Seven Nerson Tjelos (Pty) Ltd Reviewer: Ms Fredrika Shagama Contact person: Robert Middleton

Company: Excel Dynamic Solutions (Pty) Telephone: +264 (0)61 429 851/001-289-952-3695 Ltd Fax: 001-807-623-0877 Telephone: +264 (0) 61 259 530 Email: Fax2email: +264 (0) 886 560 836 [email protected]/[email protected] Email: [email protected]

Date: 08 November 2019

November 2019 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EMP: EPL 7028-7029

TABLE OF CONTENTS

LIST OF FIGURES ...... ii LIST OF TABLES ...... ii 1 INTRODUCTION ...... 1 1.1 Project Background ...... 1 1.2 Aim of the Draft Environmental Management (EMP) ...... 4 1.3 Appointed Environmental Assessment Practitioner ...... 6 1.4 Details of the Project Proponent ...... 6 1.5 Environmental Assessment Legal Requirements ...... 6 1.6 Draft EMP Limitations ...... 10 2 EMP ROLES AND RESPONSIBILITIES ...... 10 2.1 Key Potential Environmental Impacts to be managed ...... 12 2.2 Aim of the Environmental Management Plan Actions ...... 12 2.3 Phase 1: Operation (and Maintenance) Phase Management Action Plans ...... 13 2.4 Phase 2: Monitoring Phase Management Action Plans ...... 17 2.5 Phase 3: Decommissioning Phase ...... 21 3 ENVIRONMENTAL MONITORING ...... 23 4 CONCLUSIONS ...... 23

LIST OF FIGURES

Figure 1: Location of the EPL No. 7028 and 7029 near Witvlei settlement, in the Omaheke Region .... 3

LIST OF TABLES

Table 1: Proponent contact details and purpose of the required ECC ...... 6 Table 2: Applicable legal requirements and permits to the activities of EPL 7028-7029 ...... 7 Table 3: Summary of key potential environmental impacts per project phase ...... 12 Table 4: Management action plans for the Operation and Maintenance Phase ...... 13 Table 5: Management action plans for the Monitoring Phase ...... 17

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1 INTRODUCTION

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

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

This document has been prepared as a legal requirement by the Section 8 of the Environmental Management Act (EMA), No.7 of 2007 and its 2012 Environmental Impact Assessment (EIA). The compilation of this EMP was also one of the requirements (scope of work) presented to EDS by Aloe Investments 237. It is required of the Environmental Consultant to comply with the Environmental Management Act and provide for the following:

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• Prepare a detailed Environmental Management Plan that can be used as guide to monitor compliance to the recommendation made in the EIA and to assist in managing and monitoring activities during the construction, operation and maintenance of the proposed network tower. • Furthermore, the Environmental Consultant must clearly clarify in the EMP the roles and responsibilities of Aloe Investments 237, the contractors and any other identified stakeholders.

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Figure 1: Location of the EPL No. 7028 and 7029 near Witvlei settlement, in the Omaheke Region

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1.2 Aim of the Draft Environmental Management (EMP) Regulation 8 of the Environmental Management Act (EMA) (7 of 2007) Environmental Assessment Regulations (2012) requires that a draft Environmental Management Plan (EMP) be included as part of the Scoping Environmental Assessment (EA) process. 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 is one of the most important outputs of the EA process as it synthesizes all of the proposed mitigation and monitoring actions, set to a timeline and with specific assigned responsibilities. It provides a link between the impacts identified in the EIA Process and the required environmental management on the ground during project implementation and operation. 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 adapt to address project changes and/or environmental conditions and feedback from compliance monitoring.

The purpose of this document is therefore to guide environmental management throughout the different phases of the proposed exploration activities, namely prospecting surveys, drilling, sampling (operation) and decommissioning phases:

• Operation and maintenance - This is the phase during operation where the proponent will exploring/prospecting for copper and undertaking related activities on site. It is also the phase during which maintenance of the area, equipment and machinery is done by Aloe Investments 237. • Environmental Monitoring Requirements - In order to support and ensure that the proposed mitigation measures are achieving the desired results, a monitoring plan must be implemented alongside the mitigation plan. • Decommissioning – This is the phase during which the exploration activities are ceased. The decommissioning of the exploration operations may be considered due to poor exploration results or declining in the copper market price. During the operational phase and before decommissioning, the Proponent will need to put site rehabilitation measures in place. Where necessary, stockpiling of top soil for rehabilitation at a later stage will be undertaken. Necessary landscaping of exploration areas will be undertaken upon completion of each phase of exploration (drilling, sampling etc.)

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The draft EMP will be used by the Proponent and their employees and/or contractors in guiding them during the exploration work to ensure that impacts on the environment are avoided or limited if they cannot be avoided completely.

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1.3 Appointed Environmental Assessment Practitioner In order to satisfy the requirements of the EMA and its 2012 EIA Regulations, Aloe Investments 237 appointed EDS an independent consulting company to conduct the required EIA process on their (Proponent's) behalf. The findings of the EIA process are incorporated into this report and the draft Environmental Management Plan (EMP)) will be submitted as part of an application for an ECC to the Environmental Commissioner at the Department of Environmental Affairs (DEA), Ministry of Environment and Tourism (MET).

This document was compiled by Ms. Althea Brandt, a qualified Junior Environmental Assessment Practitioner. and Mr. Nerson Tjelos. Mr. Tjelos is a trained Geoscientist and an experienced Environmental Assessment Practitioner (EAP) registered with the Environmental Assessment Professionals of Namibia (EAPAN).

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

Table 1: Proponent contact details and purpose of the required ECC

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

Aloe C/O L&B Secretarial Services, Unit Private Bag 12012, Environmental Assessment (EA) For Exclusive Investments 3, 2nd Floor, Dr. Agostinho Neto Windhoek Prospecting License (EPL) No. 7028 and 7029 Two Hundred Road, Ausspannplatz, Windhoek, near Witvlei Settlement in the Omaheke and Thirty- Namibia Region, Namibia Seven (Pty) Tell: +264 (0)61 429 851 Ltd

1.5 Environmental Assessment Legal Requirements The content of the EMP must meet the requirements Section 8 (j) of the EIA Regulations. The EMP must address the potential environmental impacts of the proposed activity on the environment throughout the project life-cycle. It must also include a system for assessment of the effectiveness of monitoring and management arrangements after implementation.

Aloe Investments 237 therefore has the responsibility to ensure that the proposed activities as well as the EIA process conform to the principles of EMA and must ensure that employees also comply with such principles. Table 2 below lists the requirements of an EMP as stipulated by Section 8 (j) of the EIA

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Regulations, primarily on specific approvals and permits that may be required for the activities required of EPL 7028-7029.

Table 2: Applicable legal requirements and permits to the activities of EPL 7028-7029

Legislation/Policy/ Relevant Provisions Implications for this project Guideline

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

Details principles which are to guide all EAs. Should the ECC be issued to the Proponent, it should be renewed Environmental Details requirements for public consultation within a given every 3 years, counting from the Impact Assessment environmental assessment process (GN 30 S21). date of issue. (EIA) Regulations Details the requirements for what should be included in a GN 28-30 (GG 4878) Contact details at the Department Scoping Report (GN 30 S8) and an Assessment Report (GN 30 of Environmental Affairs (DEA), S15). Ministry of Environment and Tourism (MET)

Contact person(s) at MET and their details:

Mr. Damian Nchindo or Mr. Josafat Hiwana (Chief and Senior Conservation Scientists and EIA Report Reviewers/evaluators)

Tel: +264 61 284 2717 and +264 61 284 2962

Email: [email protected] and [email protected], respectively

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

Minerals Section 48 (3): In order to enable the Minister to consider any The Proponent needs to conduct (Prospecting and application referred to in section 47 the Minister may (b) require an EA for their proposed Mining) the person concerned by notice in writing to (i) carry out or cause exploration operations. to be carried out such environmental impact studies as may be Furthermore, the Proponent Act (No. 33 of 1992) specified in the notice. needs to plan rehabilitation actions for future exploration Section 54(2): details provisions pertaining to the decommissioning. The Proponent decommissioning or abandonment of a mine should ensure that all the necessary permits/authorisation for this exploration activities (if any) are obtained from the Ministry of Mines & Energy (MME)

Contact person and details at the MME (Mining Commissioner)

Mr. Erasmus Shivolo

Tel: +264 61 284 8167

Email: [email protected]

Labour Act 11 of Adhere to all applicable provisions of the Labour Act and the 2007 Health and Safety regulations.

Health and Safety Regulations (HSR) GN 156/1997 (GG 1617).

Forestry Act 12 of Prohibits the removal of any vegetation within 100 m from a Should there be protected plant watercourse (Forestry Act S22 (1)). The Act prohibits the removal species, which are known to occur 2001, Amended Act of and transport of various protected plant species. within the project sites, these are 13 of 2005 required to be removed and a permit should be obtained from the nearest Forestry office (Ministry of Agriculture, Water & Forestry(MAWF)) prior to removing them.

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Legislation/Policy/ Relevant Provisions Implications for this project Guideline

Contact Details at MAWF (Director of Forestry and )

Mr. Joseph Hailwa

Tel: +264 61 208 7663

Email: [email protected]

Contact

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

National Heritage Call for the protection and conservation of heritage resources Should any archaeological Act No. 76 of 1969 and artefacts. material, e.g. bones, old weapons/equipment etc be found on the exploration sites, work should stop immediately and the National Heritage Council of Namibia must be informed as soons as possible. The Heritage Council will then decide to clear the area or decide to conserve the site or material.

Contact Details at National Heritage Council of Namibia

Mr. Salomon April

Tel: +264 81 244 375

Road Traffic and Provides for the control of traffic on public roads and the Eugene de Paauw (Roads Transport Act 52 of regulations pertaining to road transport, including the licensing Authority – Specialist Road 1999 and its 2001 of vehicles and drivers. Legislation) Tel.: (061) 284 7027 Regulations

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1.6 Draft EMP Limitations This EMP has been drafted with the acknowledgment of the following limitations:

• This EMP has been drafted based on the Scoping Environmental Assessment (SEA) conducted for prospecting and exploration of copper near Witvlei Settlement in Omaheke region. No specialist study was included as part of the environmental assessment. • The mitigation measures recommended in this EMP document are based on the risks/impacts in the EIA Report which were identified based on the project description as provided by the Proponent, site investigation and public input. Should the scope of the proposed project change, the risks/impacts will have to be reassessed and mitigation measures provided accordingly.

The following chapter presents the project’s roles and responsibilities to be assigned as deemed necessary by the Proponent pertaining to the implementation of this document.

2 EMP ROLES AND RESPONSIBILITIES The Proponent is ultimately responsible for the implementation of the EMP. Alternatively, the Proponent may delegate this responsibility at any time, as they deem necessary during the project phases. The delegated responsibility for the effective implementation of this EMP will rest on the following key individuals which may be fulfilled by the same person:

• Proponent’s Representative (PR): If the Proponent does not personally manage all aspects of the planning and design, construction and operation and maintenance phase activities, decommissioning and rehabilitation, referred to in this EMP, they should assign this responsibility to a suitably qualified individual referred to in this plan as the Proponent’s Representative (PR). The Proponent may decide to assign the role of a PR to one person for both phases or a PR may be appointed to manage the EMP aspects for each project phase. The PR's responsibilities include:

o Managing the implementation of this EMP and updating and maintaining it when necessary. o Management and monitoring of individuals and/or equipment on-site in terms of compliance with this EMP. o Issuing fines for contravening EMP provisions.

• Exploration Project Manager (as appropriate):

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• This individual(s) will be responsible for the implementation of the the prospecting and exploration program as appointed by the Proponent. The Manager's responsibilities will include:

o Ensure that the relevant commitments contained in the EMP Action Plans are adhered to. o Setting up and managing the schedule for the day-to-day activities

o Issuing fines to individuals who contravene EMP provisions and if necessary, removing such individuals from site o Ensure relevant staff is trained in procedures. o Liaison with all relevant interested and affected parties/stakeholders. o Maintain records of all relevant environmental documentation. o Undertaking an annual review of the EMP and amending the document when necessary.

Alternatively, the Manager/Proponent may delegate an Environmental Officer (ECO) from within Aloe Investments 237 itself or they may appoint an external ECO to ensure EMP compliance throughout the project life cycle.

• Environmental Control Officer (ECO) or Environmental, Health, Safety (SHE) Officer: The Proponent should assign the responsibility of overseeing the implementation of the whole EMP to a designated member of staff or external qualified and experienced person, referred to in this EMP as the Environmental Control Officer (ECO) or SHE Officer. The ECO will have the following responsibilities:

o Management and facilitation of communication between the Proponent, PR and Interested and Affected Parties (I&APs) with regard to this EMP. o Conducting site inspections (recommended frequency is monthly during the construction phase and bi-annually for the operation and maintenance) of all areas with respect to the implementation of this EMP (monitor and audit the implementation of the EMP). o Advising the PR on the removal of person(s) and/or equipment not complying with the provisions of this EMP. o Making recommendations to the PR with respect to the issuing of fines for contraventions of the EMP. o Undertaking an annual review of the EMP and recommending additions and/or changes to this document.

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2.1 Key Potential Environmental Impacts to be managed From the assessment conducted, the following key potential negative impacts have been identified per project phase and are summarized in Table 3 below.

Table 3: Summary of key potential environmental impacts per project phase

Potential negative impacts identified in the EA

1 Health and safety, visual, waste, noise

2 The monitoring of exploration work impacts in remote locations can be problematic due to difficulties of access

3 Loss of employment by workers o exploration and contribution to the national economy

2.2 Aim of the Environmental Management Plan Actions The aim of the management actions of the EMP is to avoid potential negative impacts where possible. Where impacts cannot be avoided, measures are provided to reduce the significance of these impacts.

Management actions recommended for the potential impacts rated in the EIA carried out for the prospecting and exploration activities were based on the three project phases listed below:

• Operation (surveys, drilling sampling…) phase (Table 4) • Monitoring (Table 5) • Decommissioning

The responsible persons at Aloe Investments 237 should assess these commitments in detail and should acknowledge their commitment to the specific management actions detailed in the phases given under the following subchapters.

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2.3 Phase 1: Operation (and Maintenance) Phase Management Action Plans The management action plans recommended for this phase are presented in Table 4 below.

Table 4: Management action plans for the Operation and Maintenance Phase

Environmental Impact Management Actions Responsible person(s) / Timeframe (When?) Feature Implementation responsibility EMP training Lack of EMP • All personnel should be educated about the necessary health, safety and Proponent: ECO/SHE Officer Prior to site setup awareness and the environmental considerations applicable to their respective works. activities implications thereof Ongoing

Monitoring EMP non-compliance • The ECO or the Proponent should monitor the implementation of this Proponent: ECO/SHE Officer Throughout EMP. exploration phase

• An EMP non-compliance penalty system should be implemented on site

Visual (sense of Visual • All the necessary options to improve the aesthetic of the site should be ECO/Exploration Manager/SHE Throughout place) considered and incorporated in the activities of the prospecting and Officer exploration phase exploration program.

Biodiversity Loss of biodiversity • Vegetation found on the site, but not in the targeted areas of ECO/SHE Officer/ /Exploration Throughout exploration should not be removed, but left to preserve Manager; Workers exploration phase biodiversity on the site.

• Even if a certain shrub or tree is found along drilling and sampling areas on sites, this does not mean that it should be removed. Therefore, care should be taken when exploring for target mineral without destroying the vegetation.

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

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Environmental Impact Management Actions Responsible person(s) / Timeframe (When?) Feature Implementation responsibility • Environmental awareness on the importance of biodiversity preservation should be provided to the workers

Employment Labour recruitment • Preference for casual works during operational phase should be given to Proponent: Human Resources Witvlei\locals. Department.

• No recruitment should be done on site. Air Quality Generation of dust • Prospecting schedule should be limited to weekdays only and between Exploration Manager/ SHE Officer During exploration and emissions of 08h00 and 17h00. This will keep the vehicle-related dust level minimal phase hydrocarbons from in the area. vehicles • Vehicles and machinery on site should be serviced regularly to prevent emission of harmful gases

Waste Generation Environmental • Workers should be sensitised to dispose of waste in a responsible ECO/Exploration Manager; During exploration Pollution manner and not to litter. Workers phase • After each daily works, the Proponent should ensure that there are no waste left at the work site. • All domestic and general operational waste produced on a daily basis should be contained until such that time it will be transported to designated waste sites. • No waste may be buried or burned on site or anywhere else. • The exploration site should be equipped with separate waste bins for hazardous and general waste/domestic. • A penalty system for irresponsible disposal of waste on site and anywhere in the area should implemented.

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Environmental Impact Management Actions Responsible person(s) / Timeframe (When?) Feature Implementation responsibility Health and Safety Health and safety of • Proponent /Exploration Manager/ Prior to site setup the workers SHE Officer activities and as • As part of their induction, the workers should be provided with an required during this awareness training of the risks of mishandling equipment and materials phase on site.

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

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

• Employees should not be allowed on site if under the influence of alcohol.

Noise Nuisance • During exploration, the operational times should be set such that, no Exploration Manager Ongoing activity is carried out during the night or very early in the mornings.

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

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

Soils Land Degradation • Spill control preventative measures should be put in place to manage soil ECO/Exploration Manager Ongoing contamination, no matter how small the amount of pollution (spill) is.

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Environmental Impact Management Actions Responsible person(s) / Timeframe (When?) Feature Implementation responsibility • Site soils should not be disturbed, if not needed or related to the actual exploration works.

• Overburden material should be handled more efficiently during exploration operations to avoid erosion when subjected erosional processes.

• Prevent the creation of huge piles of waste materials by performing sequential backfilling where possible

Archaeology and Potential disturbance • Caution should be exercised when carrying out excavations associated ECO/Exploration Manager Prior to site setup cultural heritage to archaeological and with the exploration activities in the event that archaeological/heritage activities. Ongoing cultural heritage remains are discovered. observation resources • The worksite/exploration manager should familiarise themselves with the National Heritage Council’s

Communication Lack of • The Proponent should appoint a Public Relation Officer (PRO) to liaise PRO Throughout the communication with the farmers/landowners. exploration phase ECO (proper liaison) • The PRO should be introduced to the farm owners and his or her contact between farmers and details provided to them prior to undertaking activities for easy Proponent with communication during the exploration activities. regards to site use • The Proponent should compile a clear communication procedure/plan which should include a grievance mechanism

• The Proponent should enter into a written agreement with landowners before carrying out exploration on their land.

16 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd: EPL 7028-7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EMP: EPL 7028-7029

Environmental Impact Management Actions Responsible person(s) / Timeframe (When?) Feature Implementation responsibility HIV and AIDS Potential increase of • The workers should be engaged in health talks and training about the SHE Officer During site setup (Other STIs) prevalence of HIV dangers of engaging in unprotected sexual relations which results in and throughout and AIDS, as well as contracting HIV/AIDS and other sexual related infections. exploration phase other STIs • Provision of condoms and sex education through distribution of prevalence. pamphlets. These pamphlets can be obtained from local health facilities.

2.4 Phase 2: Monitoring Phase Management Action Plans In order to support and ensure that the proposed mitigation measures are achieving the desired results, a monitoring plan must be implemented. The management action plans recommended for exploration work are presented in Table 5 below.

Table 5: Management action plans for the Monitoring Phase

Environmental Impact Management Actions/Monitoring Objectives Responsible person(s) Frequency Threshold Action if Feature / Implementation threshold is responsibility exceeded Soils Loss of top soil • All measures should be considered to prevent SHE Weekly Proliferation of Rehabilitation the loss of top soil Officer/Exploration new vehicle tracks of affected Manager areas

Monitoring EMP non- • The ECO or the Proponent/Contractor should ECO/ SHE Officer Daily Increase in health, Daily safety

compliance monitor the implementation of this EMP to safety and talks, Remedy ensure compliance. environmental the • The ECO(s) should inspect the site throughout damage incidence consequences the exploration period and after completion.

17 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd: EPL 7028-7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EMP: EPL 7028-7029

Environmental Impact Management Actions/Monitoring Objectives Responsible person(s) Frequency Threshold Action if Feature / Implementation threshold is responsibility exceeded Biodiversity Loss of biodiversity • Clear only footprint areas to maintain as much Proponent: ECO Weekly Vegetation Rehabilitation of the remaining natural vegetation on site clearance outside of affected and to prevent loss of habitat outside areas of of marked areas. areas to the interest Workers involved in satisfaction of this phase the SHE Officer • No equipment should be left leaning on or on top of the site shrubs or trees during and after exploration work

Health and Safety Health and safety Exploration workers should be trained on how Proponent: ECO / Daily/Weekly Health and safety Remedy the of the workers to handle materials and equipment on site (if Environmental, Health incident consequences they do not already know how to) in order to & Safety Officer avoid injuries.

• Exploration equipment and materials

transported to site should be securely

fastened to the vehicles (trucks and cars). This is to ensure that the materials and equipment do not fall off the vehicles and cause injuries

to anyone while transporting them. Workers involved in this phase

18 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd: EPL 7028-7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EMP: EPL 7028-7029

Environmental Impact Management Actions/Monitoring Objectives Responsible person(s) Frequency Threshold Action if Feature / Implementation threshold is responsibility exceeded • The proponent and ECO/SHE Officer should ensure that all personnel are provided with appropriate personal protective equipment (PPE), such as gloves, safety boots, safety glasses and hard hats at all times during exploration (operation) hours on site to prevent serious injuries or loss of life

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

Neighbours to the Disturbance • Exploration works schedule should be Proponent: ECO Weekly A logged complaint Revision of site site about excessive activities limited to normal working hours, Construction noise between 08h00 and 17h00. This is to contractor/manager ensure generated noise does not disturb

residents during home hours.

19 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd: EPL 7028-7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EMP: EPL 7028-7029

Environmental Impact Management Actions/Monitoring Objectives Responsible person(s) Frequency Threshold Action if Feature / Implementation threshold is responsibility exceeded Waste Environmental • The exploration site should be kept tidy at all Proponent: ECO/SHE Daily Visible littering Clean-up of the Pollution times. Officer around project site affected areas • All domestic and general construction waste and ensuring A logged complaint produced on a daily basis should be cleaned exploration

and contained daily to prevent environmental workers utilise pollution. waste • Separate waste containers (bins) for containers

hazardous and domestic / general waste must provided. be provided on site to avoid mixing of waste Workers involved in this phase

Transport • Exploration project workers will be Proponent: ECO/ SHE Daily A logged complaint transported, in an SUV/ bus (or similar suitable Officer about bad form of passenger vehicle) to and from site prevent transport inhaling of dust.

HIV and AIDS or Potential increase • To prevent new infections in the area SHE Officer Monthly STIs infections in HIV and AIDS prevalence

20 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd: EPL 7028-7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EMP: EPL 7028-7029

Environmental Impact Management Actions/Monitoring Objectives Responsible person(s) Frequency Threshold Action if Feature / Implementation threshold is responsibility exceeded Vehicular traffic Increase in local • All drivers of the project vehicles should be in Proponent: ECO/ SHE Weekly A logged complaint Find safety traffic flow possession of valid and appropriate driving Officer about traffic alternative licenses to operate such vehicles. increase or access roads damage to RA for the team. • Project vehicles should be in a road worthy roads Rehabilitation condition and serviced regularly in order to of affected avoid accidents as a result of mechanical faults roads of vehicles.

• Vehicles drivers should not be allowed to operate vehicles while under the influence of alcohol.

• No heavy trucks or project related vehicles should be parked next to the residents' properties or obstruct the local traffic in any way.

2.5 Phase 3: Decommissioning Phase Decommissioning and rehabilitation will involve the following:

• Capping or backfilling of all drilled holes with loose materials

• Collection and disposal of domestic waste at the nearest solid waste disposal site.

• Levelling of any topsoil stockpiled during exploration activities.

21 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd: EPL 7028-7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EMP: EPL 7028-7029

• Any temporary work camps setup should be dismantled, and the area rehabilitated as far as practicable, to their original state

22 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd: EPL 7028-7029 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EMP: EPL 7028-7029

3 ENVIRONMENTAL MONITORING In order to reduce the "medium" and maintain the "low" significance ratings of impacts identified and assessed in the EIA report. A bi-annual EMP compliance audit should be undertaken throughout the project cycle. The first bi-annual audit exercise should be done counting 6 months from the date of ECC issuance. Monitoring reports are to be compiled and submitted to the Department of Environmental Affairs (DEA) for archiving. This practice will make the ECC renewal easy when it is about to expire. Therefore, Aloe Investment 237should effectively monitor and submit the reports to the DEA. The submission is not only done for record keeping purposes, but also in compliance with the environmental legislation.

4 CONCLUSIONS The potential positive and negative impacts stemming from the proposed exploration activities were identified, assessed and mitigation measures made thereof. The mitigation measures recommended in this report and management action plans provided in the draft EMP, can be deemed sufficient to avoid and/or reduce (where impact avoidance impossible) the risks to acceptable levels. EDS is therefore confident that these measures are sufficient and thus recommends that the Proponent be issued with the Environmental Clearance Certificate (ECC) to enable the exploration works on EPL 7028 and 7029. However, the ECC should be issued on condition that the provided management measures and action plans are effectively implemented on site. Most importantly, monitoring of the environmental components described in the impact assessment chapter should be conducted by the Proponent and applicable Competent Authority. This is to ensure that all potential impacts identified in this study and other impacts that might arise during implementation are properly identified in time and addressed. Lastly, should the ECC be issued, the Proponent will be expected to be compliant with the ECC conditions as well as legal requirements governing the mineral exploration and related activities.

23 Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd: EPL 7028-7029 APPENDIX C: CV OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (MR. NERSON TJELOS)

Nerson Tjelos

Role: Head of Operations at Excel Dynamic Solutions (Pty) Ltd Experience • Over 5 Years’ of Research, Mining and Consulting Experience as a young Namibian Geoscientist, Climate/Environmental scientist and Project Manager, and Founder of Excel Dynamic Solutions (Pty) Ltd • Head of Operations (EDS - Namibia) – current • Business Development Manager – Business Intelligence Dynamics Pty Ltd - current • Database Geologist (Langer Heinrich Mine – Namibia) (Jan2015-Jun2016) • Consulting Geologist (Matrix Consulting Services – Namibia) (Aug-Dec2014) • Researcher (Gobabeb Research and Training Centre – Namibia) (Jan-Jun2014) Selected • Established and turned EDS Pty Ltd into a credible consulting firm employing more than 8 consultants of different background i.e. Geoscience, Data science, Technology Accomplishments and Project managers. • Project manager for various geologic, environmental, data science and technology projects carried out by the firm (see selected below). • Managed to create projects partnerships with renown companies from South Africa, Nigeria, Zambia and Zimbabwe (for instance Afzelia Consultants Pty Ltd, GCS Water Engineering, Sustainable Drop Projects Pty Ltd, ETL Consulting Pty Ltd, among others) Qualifications • Masters of Science in Geoinformation Science and Earth Observation: NUST Namibia – in progress • Bachelor of Science in Geology: UNAM • Certificate in Project Management: I-O-C Business Integration South Africa Experience / Skills • Geology and Environmental Science • Climate Change Studies • Data Quality Assurance/Control • Project/Business Management • Effective Communication and Stakeholders Management • Risks Assessment and Management • Business Processes Review, Design and Implementation • Public and Authority Consultation • Business Requirements Specification, Systems Integration Design • Proposals writing, review and presentation Recent Project • Project Manager: Geology, groundwater and environmental work for Manger Management Mining Pty Ltd mine in Usakos – plus update for mining licence renewal • Geological Mapping and Environmental work, 2019 (Exclusive Prospecting (request for a list of Licence: 6765, 6991, 7013, 7285, 7015, 7028, 7029, 7030, 7071, 3980 etc.) geology, mining, • Project Manager: National educational programme for small-scale miners on environmental, and prospecting, exploration to mining. Lately, involved with small scale miners in Uis and Karibib area in Erongo Region helping them with geological reports, groundwater understanding of mining and environmental regulations and educating them studies) about sustainable mining practices. • Assistant Project Manager for compilation and modelling of climate, soil and hydrogeology data for Agro-Ecological Zone and Carrying Capacity Maps for the entire country (ongoing) • Co-project manager for Lesotho telecom data management project (ongoing). • Project Lead: Development of Namibia’s 8th Mining Expo and Conference website development (2019) • Co-project manager for the development of the 5th and 6th National ICT Summit web and mobile Applications (2018 -2019) • Tony Elumelu Business Mentorship: to 5 African business owners from 3 different countries Computer programs • Microsoft Project • Surfer • Centric • Albion • Open Stereo • Statistical (R, SPSS, ATLAS TI) • ArchGIS, PostgreSQL, GEOSERVER, • ENVI • Climate: EasyREMO, PRECIS, MM5 Awards • Top 100 Most Influential Young Africans nomination, 2019 • Emerging Entrepreneur of the year 2017: Namibian Business Hall of Fame • Climate Reality Leader awarded by Former US Vice President Al Gore, USA, 2018 • Top 10 Total Startupper of the Year Challenge (2019)

• Top 10 Development Bank of Namibia Innovation Award, 2018 • Recipient of Tony Elumelu Entrepreneurship Training Programme and Seed Capital, Nigeria, 2018 • African Entrepreneurship Awards (by African Development Bank) Stage II or Semi-Finalist, 2018 • Southern Africa Startup Awards Finalist – Water Management Solutions, 2018 • Top 100 Young Brightest Minds (BYM) in Africa: awarded in South Africa • Tony Elumelu Foundation Nominee, 2018 • Namibia Business Start-up of the year finalist 2017: SANLAM in collaboration with Namibia Business Innovation • Mandela Washington Fellowship Semi-Finalist 2017 and 2018 • Best presenter (Geology student), Faculty of Science Annual Research Conference, 2013 Membership • Geoscience Council of Namibia (Co-opted Member) • Geological Society of Namibia • Namibia Scientific Society • Namibia Chamber of Commerce and Industry (NCCI) Mining Committee • Namibia Hydrogeological Society • Environmental Economics Network of Namibia • Environmental Assessment Professionals Association of Namibia • Climate Reality Project, headquartered in the US (Country Coordinator) • Team 54 Project, founded in Nigeria (Country Coordinator) Selected Referees • Ministry of Mines and Energy, Namibia (Request for a full list • Ministry of Environment and Tourism, Namibia • Ministry of Land Reform, Namibia with contact details) • Chamber of Mines of Namibia • Manger Mining Pty Ltd, Lodestone Mining Pty Ltd among other mining companies • Namibian Business Hall of Fame • Desert Research Foundation of Namibia • Langer Heinrich Namibia Pty Ltd • Namibia Business Innovation Institute • Tony Elumelu Foundation, Nigeria • Climate Reality Project, US

APPENDIX D: LIST OF INTERESTED AND AFFECTED PARTIES (I&APS) Pre-Identified List of Interested and Affected Parties (I&APs) Environmental Assessment for Exclusive Prospecting License (EPL) No. 7028 and 7029, Witvlei Settlement in the Omaheke Region

Ministry of Environment and Tourism (Department of Environmental Affairs)

1. Mr. Teofillus Nghitila Executive Director

2. Dr. Fredrick Sikabongo Deputy Environmental Commissioner

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd

Senior Manager 3. Mr. Robert Middleton

Ministry of Land and Reform

4. Ms. Esther Kaapanda Executive Director (Acting)

5. Secretary to Executive Director

Ministry of Agriculture Water and Forestry

6. Mr. Percy Misika Executive Director

7. Mr John Hailwa Directorate of Forestry - Director

Ministry of Works and Transport

8. Mr Willem Goeiemann Executive Director

9. Ms. Monica A. Uupindi Personal Assistant to Executive Director

Ministry of Urban and Rural Development

10. Mr N. Daniel Executive Director

11. Ms. Rosalia Ruben Secretary to Executive Director

Ministry of Health and Social Services

12. Mr. Ben Nangombe Executive Director

13. Ms. Petty Tjaimba Personal Assistant to the Executive Director

Ministry of Mines and Energy

14. Mr Simeon Negumbo Executive Director

Roads Authority

15. Mr C. M. Lutombi Chief Executive Officer

Senior Specialist Road Legislation, Advice & Compliance NP&C 16. Mr E. de Paauw

Omaheke Regional Council

Honourable Festus T. 17. Regional Governor Ueitele

18. Hon. Raphael Mokaleng Regional Councilor

19. Ms. Naomi Kaapama Control Administrative Officer

Ms. Maria Chief Regional Officer 20. Vaendwanawa

Witvlei Village Council

21. Mr. Hendrik Muisoor Chief Executive Officer

Owners / Occupiers of Land and Neighbouring Property Owners

22. Mr. Joel Shafashike GCT (Namibia) PTY Ltd

Abraham Jan Albertus 23. Weshof – No. 585 Grobbel

24. Pack Beef Investments Okasewa – No. 103

Okasewa Ranch 25. Okasewa North – No. 121 Number Two

Christian Wilhelm 26. Otjiwarumendu – No. 119 Schullenbach/Pack

Losberg Farming (Pty) 27. Losberg – No. 105 Ltd

28. Wilfried Horsthemke Pomona - No. 214

29. Hans Joachim Ruckert Okatjirute West – No. 324

Georg Wilhelm August 30. Okatjirute (Ost) – No. 323 Von Kuhne

31. Coral Trading Cc Pack-Grunental – No. 1031

32. Michell Gammas Witvlei Village Council

33. Imelda Goras Witvlei (Location)

34. Jane’ Moolman Witvlei Service Station

35. Ronel Bezuidenhoudt Witvlei Service Station

36. Cycil Jantjies Witvlei Service Station

37. Given Taurob Witvlei Service Station

APPENDIX E: BACKGROUND INFORMATION DOCUMENT (BID)

Physical Address: 122, Robert Mugabe, Windhoek Postal Address: PO Box 997154 Maerua Mall, Windhoek Telephone: +264 (0) 61 259 530 Fax2email: +264 (0) 886 560 836 Email: [email protected] Web: www.edsnamibia.com

Document Type: Background Information Document (BID)

Project Name: Environmental Assessment (EA) For Exclusive Prospecting License (EPL) No. 7028 and 7029 near Witvlei Settlement in the Omaheke Region, Namibia

Environmental Assessment Practitioner: Excel Dynamic Solutions (Pty) Ltd

Proponent: Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd

Date: 06 September 2019

1 INTRODUCTION resource. Prospecting and exploration form part of the listed activities that may not be undertaken without an Environmental Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd (The Clearance Certificate (ECC). Thus, the EPL 7028 and 7029 are Proponent) has been granted with Exclusive Prospecting Licenses subjected to a Clearance Certificate to be issued by the Ministry of (EPLs) No. 7028 and 7029 by the Ministry of Mines and Energy Environment and Tourism (MET) upon submission of an (MME). The tenure of these licences is from 13 June 2018, as per Environmental Assessment Report (EAR) and draft Environmental agreement with the Ministry of Mines and Energy. The earth data of Management Plan (EMP). the covered area is prospective with regards to three groups of Under the Environmental Management Act (EMA) (2007) and its commodities, upon which detailed prospecting and exploration 2012 EIA Regulations, the proposed prospecting and exploration activities will be conducted. activities are listed activities that require an Environmental Clearance - Base Metals and Rare Metals (main target) Certificate (ECC) from the Department of Environmental Affairs (DEA) - Industrial Minerals of the Ministry of Environment and Tourism (MET). The relevant

- Precious Metals listed activities as per EIA regulations are:

The tenements are situated near Witvlei Settlement in the Omaheke • 3.1 The construction of facilities for any process or activities Region, covering a combined total area of 39,008.2746 Ha. The which requires a license, right of other forms of authorization, covered area is located within the Kalahari Copperbelt, 55 km west and the renewal of a license, right or other form of of Gobabis. The locality map is shown under Figure 1. Occurrences of authorization, in terms of the Minerals (Prospecting and copper mineralization in the area have been explored since the Mining Act, 1992).

1970s, re-activated in the 1980s, but then ceased due to low prices • 3.2 other forms of mining or extraction of any natural for copper ore on the world market. Aloe Investments Two Hundred resources whether regulated by law or not. and Thirty-Seven (Pty) plans to conduct prospecting and exploration • 3.3 Resource extraction, manipulation, conservation and activities leading to the estimation and delineation of the target related activities.

Consequently, Aloe Investments Two Hundred and Thirty-Seven (Pty) 2 PURPOSE OF THIS DOCUMENT Ltd appointed Excel Dynamic Solutions (Pty) Ltd, an independent The purpose of this document is to provide background information team of Environmental Consultants to conduct the required EA to interested and affected parties (I&APs) of the project, thus process and submit the ECC application to the Environmental providing an opportunity for them (I&APs) to receive information, Commissioner on their behalf. comment and raise issues regarding the environmental authorization process.

3 I&AP’S/ STAKEHOLDERS

Communities, neighbors, government representatives, community leaders, churches, non-governmental organizations are being invited to participate in the EA Public Participation process by means of published advertisements, notices and written correspondence.

Figure 1: Location of the EPL no. 7028 and 7029 near Witvlei settlement, in the Omaheke Region

4 NEED AND DESIRABILTY OF THE ACTIVITY well as the results of the past exploration activities. Based on technical report which covered literature review of all available Mining has been the backbone of the Namibian economy for geological data sets pertaining to previous exploration activities in decades. Participation of local communities in mining and the surroundings area, EPL 7028 and 7029 have a potential to host exploration sector does not only create employment and increase stratabound copper-silver mineralization. The objective of the revenue, but also contribute to the GDP of the country, which can planned prospecting and exploration is to delineate the mineral help achieve a balance between the creation and distribution of (copper) deposits and determine whether the deposits are wealth. Additionally, mining forms the core of some of Namibia’s economically viable mining resources. The scoping process will development plans, namely: National Development Plan 5 (NDP5) identify sensitive environmental features that might be affected by and Harambee Prosperity Plan (HPP). These plans are benchmarks the proposed prospecting and exploration activities. The level and on the ideals of Vision 2030. Successful exploration work can lead to magnitude of planned exploration work is not clear at this stage. mining activities on the two EPLs, 7028 and 7029 that would feed into However, both invasive and non-invasive exploration activities are the mentioned development plans. expected to take place upon issuance of an environmental clearance certificate. Non-invasive activities include geological field mapping,

5 PROJECT DESCRIPTION geophysical survey work, airborne and ground based surveys. Invasive activities involve soil and rock sampling, trenching and The prospecting and exploration activities entail the following three drilling. mineral commodity groups: (i) Base and rare metals, (ii) industrial 5.1 Accessibility minerals, and (iii) precious metals. Base metal (i.e. copper) is the main target for the planned exploration work. The selection of the The Witvlei Property is situated about 150 km east of Windhoek via potential mineralization model and exploration targets has been B6 Motorway and just about 3.3 km from the village of Witvlei which specially selected based on the regional and likely local geology as is a small village with one school, one clinic, one petrol station (Figure

1) and a police station. Windhoek is the social, economic, political, 5.3 Infrastructure and cultural centre of the country. Most of the commercial industry, The EPL 7028 and 7029 are situated in a desirable location when it governmental offices, and educational institutions are comes to infrastructure due to the proximity to Windhoek, the capital headquartered in Windhoek. To the east of Witvlei and about 52 km city. There is direct access by roads to Licenses, railway, and on B6 Motorway is the regional capital of the Omaheke Region, commercial ports. The B6 motorway which form part of the Trans- Gobabis. This a small town and is best known as cattle country. Kalahari Corridor runs next to EPL 7028 and EPL 7029. The Windhoek 5.2 Water Supply Hosea Kutako International Airport is between 80 km of both EPL 7028 and EPL 7029. Moreover, the rail service in Namibia is provided Water required for exploration activities will be obtained from by TransNamib. This railway system of tracks runs through EPL 7029 existing boreholes, or from approved water sources, through water and the station is located in Windhoek with connections to other abstraction permits. In accordance with the Water Resources locations. Electricity is supplied by Namibia Power Corporation Management Act, 2004, (Act No. 24 of 2004) and in view of the arid (NamPower). Communication from the EPLs is accomplished via nature of the Namibian environment, the disposal of wastewater as mobile phone, radio, satellite phone or over the internet using a well as all other type of waste is strictly controlled. In most cases and satellite/mobile network. in particular wastewater is disposed of in evaporation ponds because no effluent may be discharged into the ephemeral, dry river beds in the interior of Namibia. The reclamation, re-use and recycling of waste is encouraged whenever an industry applies for a waste water disposal permit.

6 ENVIRONMENTAL ASSESSMENT • Inform Interested and Affected Parties (I&APs) and relevant authorities about the mining activities and to provide them This EA process is conducted according to the provisions laid out in with a reasonable opportunity to participate during the EA the Environmental Management Act (No 7 of 2007) and its’ process. Environmental Impact Assessment Regulations (2012). The primary objective of the EA will be to identify potential negative impacts that • Assess the significance of issues and concerns raised. may be associated with the proposed activity, assess them and • Compile a report addressing all identified issues and recommend practical and effective mitigation measures that will be potential impacts related to various aspects of the activity. implemented by Aloe Investments Two Hundred and Thirty Seven • Compile an Environmental Management Plan (EMP) which (Pty) Ltd and their contractor(s) to minimize these impacts, if they includes impact mitigation measures. cannot be avoided altogether, while maximizing positive impacts. The

EA process serves primarily to inform the public and relevant authorities about the proposed project and to determine any impacts. The project duration is 4 months.

The main objectives of this EA are to:

• Comply with Namibia’s Environmental Management Act (2007) and its EIA regulations (2012). We are here • Identify potential impacts associated with the proposed Activity.

6.1 Environmental and Social Baseline 6.1.2 Physiography and Local Geology

The proposed prospecting and exploration activities will be The EPLs are in the region of the Khomas Hochland Plateau undertaken in a specific environmental and social conditions. The characterized by a rolling hill in the west with many summit heights summary of selected environmental and social baseline information reflecting old land surfaces, and falling off to the east as it approaches pertaining to the exploration area is given below. the Kalahari Desert. The Witvlei area is relatively flat with elevation ranges from 1480 to 1526 metres AMSL. Vegetation on the Witvlei 6.1.1 Climate and Vegetation area within which EPLs are found comprises the Camelthorn Savanna, The average annual precipitation in Windhoek and the surrounding an area of grassland with an upper layer of large shrubs and/or trees areas is 360 mm. The central plateau, which has an average elevation which are dominantly Camelthorn. Geologically, the Witvlei-Gobabis of approximately 1,600 metres above mean sea level (“AMSL”), has area has preserved Witvlei Group consisting of a mixed coarse- to temperature ranges from 6 to 20 degrees Celsius in July, to 17 to 29 fine-grained siliciclastic and carbonate strata deposited in deep to degrees Celsius in January. The location of the EPLs in the eastern shallow marine, and locally non-marine, settings along the post-rift part of Khomas Region means that seasonal rainfall begins slightly continental margin of the Kalahari Craton prior to the onset of earlier but is of roughly the same magnitude as that recorded for foreland basin sedimentation recorded by the overlying terminal Windhoek. In general, for exploration stage projects, certain field Neoproterozoic–Cambrian Nama Group. No direct age constrains activities can be carried out year-round; however, movement of exist for the Witvlei Group, but it post-dates ca. 800 Ma rift-related heavy equipment such as drill rigs is problematic during the rainy rocks and pre-dates the ca. 548 Ma base of the Nama Group, thereby season due to deteriorated road conditions. Drilling is typically placing it as Cryogenian to Ediacaran in age suspended during the rainy season from December through to March 6.2 Potential Impacts or April. The following potential impacts have been identified so far for the

surrounding towns, settlements and property:

Positive: The potential impacts listed above were pre-identified. More potential impacts will be identified as the EA process progresses i.e. • Creation of jobs to the locals. upon site visit and consultation with the public. All impacts and public • Helps boost local economic growth. concerns/comments will be incorporated and addressed in the • Open up other investment opportunities. Environmental Assessment Report.

• Contribution to regional economic development.

Negative: 6.3 Public Consultation

• Generation of dust from the prospecting and exploration Public consultation is an important part of EA process. During the activities and access gravel road. consultation process, interested or affected members of the public are given an opportunity to find out more about the activity and raise • Possible destruction of faunal habitats as well as removal of any issues or concerns pertaining to the environmental assessment. vegetation that may be encountered within the target areas. To comment or receive further information on the project, please • Visual impact (scars) on landscape that will, because of low register with Excel Dynamic Solutions (Pty) Ltd (contact details below) rainfall, remain so for a very long time if not rehabilitated. as an Interested and Affected Party (I&AP). • Potential health and safety risks associated with mishandling All registered I&APs will be kept informed throughout the various of handheld mining equipment. stages of the project and will be provided the opportunity to • Environmental pollution. comment on the Scoping Report.

I hereby wish to register as an Interested and Affected Party (I&AP) for the

EPL 7028 & 7029 EA process Contact: Mr. Kai Kleingunther Tel: +264 61 259 530 Name: Fax: +264 886 560 836 Email: [email protected] ______

______Public meeting details Organization: Date: 25 September 2019 ______

Venue: To be communicated to registered I&APs ______

Time: 11:00 Postal address: ______

______

Email: ______

Phone #: ______

Fax #: ______

My initial comments, issues or concerns are:

______Organization: ______Email: ______Phone #: ______

______Fax #: ______Please return details to: Mr. Kai Kleingunther ______P O Box 997154, Maerua Mall, Windhoek ______

______

Other individuals, stakeholders, organizations or entities that should be registered are:

Name: ______

10 APPENDIX F: NEWSPAPER ADVERTS (THE NAMIBIAN AND NEW ERA) Newspaper Adverts (The Namibian and New Era) notifying the public about the Environmental Assesment Process

APPENDIX G: MINUTES OF THE PUBLIC MEETING (EPL 7028 & 7029) Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

Public Meeting Minutes

Date: 02 October 2019

Locality: Haodadi Community Hall, Omataura, Witvlei, Omaheke Region

Methodology:

The visited public members were given an opportunity to give their comments and concerns on the proposed exploration project. These concerns and comments were noted down and are presented in the table below:

No. Name of person Organization Comment/issue Name of person Response commented responded Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029 1 H. Muisoor CEO: Witvlei Village The settlement is faced with water N. Tjelos as the EAP Noted. At this stage the Council challenges. Where will the exploration team exploring company has

get their water from? indicated that only RC

drilling will be employed.

No water is required for

RC drilling. However, should it come to light

that diamond drilling would be required; the

exploring company will be advised to consider

carting (transporting)

water from sources with

sufficient supply or from

elsewhere outside the

exploration area. We will

also address the water

scarcity issue in the

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

environmental scoping report.

Exploration crew will be Where will the exploration crew be housed? N. Tjelos as the EAP accommodated in

Witvlei or Dordabis Settlement or any

nearby available place i.e. farms. Exploration

will take place during the day time only and staff will be commuting to exploration site from the

accommodation

town/place.

There were previous exploration teams that N. Tjelos as the EAP Point noted. never delivered on their promises

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

2 S. Gawases Witvlei resident Will the project help support community N. Tjelos as the EAP Questioned is noted. members in need of housing, build schools or Community support will

support existing service provision entities? be emphasized in the

Scoping Report.

Exploration team should consider community N. Tjelos as the EAP services providers instead of sourcing goods Noted. from other towns and regions, especially if

they are available in Witvlei

Project welcomed because unemployment is N. Tjelos as the EAP Noted. high

Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

3 V. Van Wyk Resident My concern is that companies come with their N. Tjelos as the EAP Concern is noted. The own employees instead of considering issue of local community members participation in the project will be addressed and emphasized in the scoping report. Where the required skills are available locally, priority should be given to local workers.

4 M. Jourbert Resident/ former Damaging of roads, fences and other N. Tjelos as the EAP Noted. Mitigation exploration project properties especially those belonging to measures will be manager farmers addressed in the environmental scoping report and incorporate it in the environmental management plan (EMP

5 V. Horaes Literacy Promoter Consultants must come back to us once the N. Tjelos as the EAP Another meeting will be study is completed organized by the consultant through the Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

office of the CEO of the Witvlei Village Council for updating the public on assessment findings and the way forward.

6 A. OaiB Resident Drilling activities can be noisy. What N. Tjelos as the EAP Mitigation measures will measures will be taken to ensure there is no be addressed in the noise disturbance to the community environmental scoping report and incorporate it in the environmental management plan (EMP)

7 M. Soreseb Witvlei resident How long is the project going to take? N. Tjelos as the EAP According to the information provided by the exploring firm, the ground geophysical survey program may last several months and will be done in stages on different parts of the property (EPL 7028 and Aloe Investments Two Hundred and Thirty-Seven (Pty) Ltd EA: EPL 7028 &7029

7029) depending on prospecting results. RC drilling is anticipated to last 3-4 months on each of the two licences, EPL 7028 and 7029. A two- year exploration program is envisaged.

8 M. Joubert Resident/ former There has been exploration work in the past N. Tjelos as the EAP Noted. We will definitely exploration project which most farmers are familiar with. I am appreciate your support manager willing to assist with reaching out to farmers. and your knowledge

Remark: Many of the public members were in support of the Environmental Assessment being conducted prior to exploration because the community is in search for economic opportunities.

APPENDIX H: PUBLIC MEETING ATTENDANCE REGISTER

APPENDIX I: COPY OF THE MINERAL LICENSES CERTIFICATES FOR EPL 7028, 7029, 7030 & 7071