Environmental Assessment for the Proposed Development of a Lodge Near Kongola, Zambezi Region

Home , B8 road (Namibia), Kongola

Resilient Environmental Solutions cc P. O. Box 90709, Windhoek 76 Dr Frans Indongo St, Windhoek West

Environmental Assessment for the Proposed Development of a Lodge near Kongola, Zambezi Region

Final Scoping Report

18 June 2019

Proponent: Kwando Lodges (Pty) Ltd PO Box 86491 Eros Windhoek

Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Executive Summary

Introduction

Kwando Lodges (Pty) Ltd (the Proponent) intends to construct and operate a lodge near Kongola in the Zambezi Region.

The tourism industry is one of the fastest growing industries in Namibia. The tourism sector provides a significant number of jobs nationally addressing a key Namibian developmental challenge – unemployment. The Proponent, based on market research, has identified the need for increased accommodation capacity for the upper-middle and up-market segments of the market. It is therefore necessary and desirable to develop the proposed lodge.

Public Consultation

The first round of public consultation took place from 7 March 2019 to 28 March 2019. The main issues raised during the first round of public consultation are as follows:

• Procedures for recruitment of labour during construction and operation. • Liability for injuries sustained by the Proponent’s employees while on duty. The second round of public consultation took place from 27 May 2019 to 10 June 2019 One concern was raised – i.e. that there may be archaeological or historical heritage materials at the proposed site.

Based on the outcome of the public meeting and emails received during the first and second rounds of public consultation, it can be concluded that no issues with “red flag” implications were raised/identified. Conclusions and Recommendations

The positive impacts arising from establishment of the proposed lodge are beneficial to the local economy and Namibia’s tourism industry.

The negative impacts from the development are significant enough to warrant mitigation, but none of them are likely to seriously damage or degrade any local resources. All negative impacts can be reduced to manageable levels by implementation of the mitigation measures as laid out in the Environmental Management Plan. The mitigation recommendations for the proposed lodge are based on accepted good practices in the tourism industry (Eco Awards, 2005), and can be implemented without incurring significant costs.

The proposed development of the lodge near Kongola is unlikely to have significant negative impacts on the environment (social and biophysical), and there are no reasons to withhold an Environmental Clearance Certificate. The mitigation measures proposed in this report and the Environmental Management Plan should be carried out and monitored.

ii Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Table of Contents

Executive Summary ...... ii

List of Figures and Tables ...... v

List of Abbreviations and Acronyms ...... vii

List of Appendices ...... viii

Glossary ...... ix

1 Introduction ...... 1

1.1 Project Background ...... 1

1.2 Need and Desirability ...... 1

1.3 Terms of Reference ...... 2

1.4 Environmental Assessment Process ...... 2

1.4.1 Registration of Application for Environmental Clearance Certification ...... 2

1.4.2 The Scoping Phase ...... 3

1.4.3 Specialist Input ...... 3

1.5 Assumptions ...... 4

2 Project Team ...... 5

2.1 John Pallett ...... 5

2.2 Sheldon Husselmann ...... 5

3 Project Description ...... 6

3.1 Project Location ...... 6

3.2 Project Overview ...... 6

3.3 Electrical Infrastructure ...... 7

3.3.1 Power Line Infrastructure ...... 7

3.3.2 Solar Power Plant ...... 10

3.4 Construction Phase ...... 14

3.4.1 Construction Workforce and Duration...... 14

3.4.2 Construction Services and Utilities ...... 14

3.5 Operation Phase ...... 14

iii Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

3.5.1 Operation Phase Activities ...... 14

3.5.2 Operation Workforce ...... 15

3.5.3 Operation Phase Services and Utilities ...... 15

3.6 No Action Alternative ...... 15

4 Legislation Relevant to the Project ...... 16

4.1 The Environmental Management Act (7 of 2007) and Regulations (2012) ...... 16

4.2 The Water Act (54 of 1956) ...... 16

4.3 The Water Resources Management Act (11 of 2013) ...... 17

4.4 Labour Act (11 of 2007) ...... 17

4.5 Namibia Tourism Board Act (21 of 2000) ...... 17

4.6 Forest Act (12 of 2001) ...... 17

4.7 Nature Conservation Ordinance (No. 4 of 1975) ...... 18

4.8 Roads Ordinance (No. 17 of 1972) ...... 18

4.9 National Heritage Act (No. 27 of 2004) ...... 18

5 Description of the Receiving Environment ...... 19

5.1 Biophysical Environment ...... 19

5.1.1 Climate ...... 19

5.1.2 Geology, Topography and Soils ...... 19

5.1.3 Hydrogeology ...... 20

5.1.4 Biodiversity ...... 20

5.2 Socio-Economic Environment ...... 21

5.2.1 Kongola Constituency and Project Site ...... 21

5.2.2 Archaeology and Heritage Resources ...... 22

5.2.3 Visual Characteristics ...... 23

6 Public Consultation...... 24

6.1 First Round of Public Consultation ...... 24

6.1.1 Public Consultation Activities ...... 24

6.1.2 Comments Received and Responses Provided ...... 25

iv Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

6.2 Second round of public consultation ...... 26

6.3 Public Consultation Outcome ...... 27

7 Impact Assessment...... 28

7.1 Assessment Method ...... 28

7.2 Potential Impacts ...... 31

7.2.1 Planning and Design Phase Considerations ...... 31

7.2.2 Construction Phase ...... 34

7.2.3 Operation Phase ...... 40

7.2.4 Cumulative Impacts ...... 47

8 Conclusions and Recommendations ...... 48

8.1 Conclusions ...... 48

8.2 Recommendations ...... 48

9 References ...... 49

List of Figures and Tables

Figure 3-1: Example 33kV power line with A-frame ...... 8

Figure 3-2: Layout of proposed power line cutline and servitude ...... 9

Figure 3-3: Proposed project location ...... 11

Figure 3-4: Map displaying key infrastructure ...... 12

Figure 3-5: Site map of proposed lodge facilities ...... 13

Figure 5-1: Remains of a SADF military structure ...... 23

Figure 7-1: Examples of power line marking devices made by Performed Line Products - Bird Flight Diverter (left) and Viper Live Bird Flapper (right) ...... 32

Figure 7-2: Example of "gapping" a pole earth wire to reduce contact between wire and ground, except during lightning strikes (left) and example of use of LDPE pipe on jumpers to insulate selected live components of transformers and switch gear ...... 33

v Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Table 6-1: Comments received and responses provided during the first round of public consultation ...... 25

Table 6-2: Comments received and responses provided during the second round of public consultation ...... 26

Table 7-1: Criteria applied to each potential impact ...... 29

Table 7-2: Potential impacts expected during the construction phase ...... 34

Table 7-3: Assessment of the impact of employment creation and skills transfer ...... 34

Table 7-4: Assessment of the impact of waste generation ...... 35

Table 7-5: Assessment of the impact of soil and groundwater pollution ...... 36

Table 7-6: Assessment of the impact of health and safety of workers on-site ...... 37

Table 7-7: Assessment of the impact of disturbance and poaching of animals ...... 38

Table 7-8: Assessment of the impact of vegetation clearing ...... 40

Table 7-9: Potential impacts expected during the operation phase ...... 41

Table 7-10: Assessment of the impact of increased tourism and economic diversification 41

Table 7-11: Assessment of the impact of wastewater treatment system on groundwater . 42

Table 7-12: Assessment of the impact of night lights at the lodge sites...... 44

Table 7-13: Assessment of the visual impact of the proposed lodge ...... 44

Table 7-14: Assessment of the impact of soil and groundwater pollution ...... 46

vi Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

List of Abbreviations and Acronyms

CV Curriculum Vitae

DEA Department of Environmental Affairs

EA Environmental Assessment

EAP Environmental Assessment Practitioner

ECC Environmental Clearance Certificate

EIA Environmental Impact Assessment

EMA Environmental Management Act

EMP Environmental Management Plan

GG Government Gazette

GIS Geographic information system

GN Government notice

I&AP Interested and Affected Party

kV Kilo volt

kW Kilo watt

KAZA TFCA Kavango Zambezi Transfrontier Conservation Area

MAWF Ministry of Agriculture, Water and Forestry

MET Ministry of Environment and Tourism

NORED Namibia Northern Regional Electricity Distributor

PLAN People’s Liberation Army of Namibia

PV Photovoltaic

SADF South African Defence Force

vii Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

List of Appendices

Appendix A: Application for Environmental Clearance Certificate Appendix B: Environmental Management Plan Appendix C: Email correspondence with groundwater specialist Appendix D: CV of groundwater specialist Appendix E: CVs of EAPs responsible for the Environmental Assessment

Appendix F: Public Consultation

1st Round of Public Consultation Appendix F1: Register of Interested and Affected Parties Appendix F2: Notification email sent to I&APs Appendix F3: Background Information Document Appendix F4: Notification letters to relevant ministries Appendix F5: Newspaper notices Appendix F6: EA public notice board Appendix F7: Minutes of public meeting Appendix F8: Email correspondence with I&APs

2nd Round of Public Consultation Appendix F9: Second notification email to I&APs Appendix F10: Email correspondence with NHC

viii Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Glossary

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

Environment - As defined in 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, 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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1 Introduction

This chapter of the report provides a background and motivation to the project; the study’s terms of reference; purpose of this report; the assumptions applicable to this study; and an outline of the remainder of the report.

1.1 Project Background

RETURN Africa Pty Ltd, through its Namibian subsidiary, Kwando Lodges (Pty) Ltd, (the Proponent) intends to construct and operate a tourist accommodation facilities adjacent to the Kwando River approximately 7 km northwest of Kongola in the Kongola Constituency of the Zambezi Region (known hereafter as the project) (see Figure 3-3).

The Proponent signed a 25-year concession operator contract with Kwando Conservancy on 5th February 2019. Previous organisations have operated at various times during the past 25 years within the concession area. These include the Ministry of Defence, the Ministry of Environment and Tourism (MET), the Integrated Rural Development and Nature Conservation (IRDNC) and most recently a concession operator. Old dilapidated structures from some of these previous operations have remained on-site until the present. The previous concession operator unsuccessfully attempted to develop tourist accommodation facilities within the concession area and subsequently the agreement between the MET and the operator was terminated.

1.2 Need and Desirability

Statistics provided by the Hospitality Association of Namibia indicates growing demand for accommodation across most markets and types of accommodation, with average room occupancies in northern Namibia at approximately 60% in recent years. Based on anecdotal information available to the Proponent it can be inferred that there is a shortage of quality accommodation near key attractions such as the Kavango River, Kwando River, Zambezi River, and Chobe Rivers. While some operators trading at the 3-star mid-market appear to be responding to this demand, there appears to be a gap in the 4-5-star upper-middle and up- markets. It is therefore both necessary and desirable to develop the proposed lodge.

1 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

1.3 Terms of Reference

Resilient Environmental Solutions cc was appointed by the Proponent to undertake an Environmental Assessment (EA) for the purpose of applying for an Environmental Clearance Certificate (ECC) for the project.

No formal Terms of Reference (ToR) were provided by the Proponent. Therefore, the ToR for conducting this EA were taken to be the requirements of the Environmental Management Act (EMA) (No. 7 of 2007) and its Environmental Impact Assessment (EIA) Regulations (see Chapter 4 – Legislation Relevant to the Project).

This EA has been conducted with the aim of obtaining an ECC only. Any additional permits or licenses and/or approvals that are required (see Chapter 4 – Legislation Relevant to the Project) for any other purpose associated with the project should be applied for by the Proponent.

1.4 Environmental Assessment Process

The steps followed as part of this EA process are:

1. Registration of application for an ECC; and 2. Carrying out the scoping phase of the EA process as prescribed by the EIA Regulations. 1.4.1 Registration of Application for Environmental Clearance Certification

The first step was to identify the listed activities which the proposed project entails, as stipulated in the ‘List of Activities that may not be undertaken without an Environmental Clearance Certificate’ (GN. No. 29 of 2012). These activities are listed below.

ENERGY GENERATION, TRANSMISSION AND STORAGE ACTIVITIES

1. The construction of facilities for -

(b) the transmission and supply of electricity.

TOURISM DEVELOPMENT ACTIVITIES

6. The construction of resorts, lodges, hotels or other tourism and hospitality facilities.

WATER RESOURCE DEVELOPMENTS

8.1 The abstraction of ground or surface water for industrial or commercial purposes.

8.6 Construction of industrial and domestic wastewater treatment plants and related pipeline

2 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019 systems.

In accordance with Section 32 of the EMA, applications for an ECC should be submitted to the relevant Competent Authority. The Competent Authority is defined as that authority having the jurisdiction to approve or permit a particular listed activity in accordance with the relevant national legislation. The Ministry of Environment and Tourism (MET) was identified as the Competent Authority. Therefore, the application for an ECC was submitted on 7 March 2019 to the MET (Appendix A), as prescribed by Regulation 6 (Form 1 of Annexure 1) of the EIA Regulations (GN. No. 30 of 2012), as provided for under Section 56 of the EMA. 1.4.2 The Scoping Phase

After submitting an application for an ECC the scoping phase commences, culminating in the production of a scoping report (i.e. this report), which includes all the findings of the scoping phase. This report includes the following:

• Details of the Environmental Assessment Practitioner that carried out the assessment (Chapter 2); • A description of the proposed project (including alternatives considered) (Chapter 3); • Legislative provisions that have relevance to the proposed project (Chapter 4); • A description of the existing biophysical and social conditions of the receiving environment (Chapter 5); • A description of the public consultation process followed (as described in Regulations 7 and 21 of the EIA Regulations) (Chapter 6); • A description and assessment of significance of identified potential impacts (positive and negative) associated with the proposed project (Chapter 7); and • Management and mitigation measures required to avoid or minimise the potential negative impacts as outlined in the Environmental Management Plan (EMP) (Appendix B). 1.4.3 Specialist Input

Specialist input was sought from a qualified and experienced geohydrologist regarding the impact of the proposed discharge of wastewater from the septic tank system (see Appendix C for email correspondence).

Mr Greg Christelis was appointed to undertake a desktop investigation (i.e. based on existing/available information) on the impact of the proposed wastewater discharge. Mr Christelis is a qualified geohydrologist with more than 20 years of experience as a practitioner (see Appendix D for CV).

The findings of this study are addressed in Chapter 7 – Impact Assessment.

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1.5 Assumptions

The following assumptions apply to this EA:

• It is assumed that the information provided by the Proponent is correct and that all necessary information has been disclosed. • It is assumed that there will be no significant changes to the proposed project (see Chapter 3) or the affected environment (see Chapter 5) between the compilation of this report and implementation of the proposed project that could substantially influence findings and recommendations with respect to mitigation and management.

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2 Project Team

This EIA project is undertaken by Independent Environmental Consultants (IEC). The IEC team consists of John Pallett and Sheldon Husselmann, both of whom have significant experience conducting EIAs (scoping and assessment level) within the Namibian environmental context.

2.1 John Pallett

John Pallett is a certified Environmental Assessment Practitioner (EAP), with qualifications in geology (BSc) and zoology (BSc Honours). He specialises in providing environmental advice and evaluating environmental issues, particularly through Environmental Impact Assessments (EIAs) and Strategic EAs (SEAs), for the benefit of managers, decision-makers and the lay public. He has been affiliated to the Southern African Association for Impact Assessment (SAIEA) since 2008, and worked for the Desert Research Foundation of Namibia – Environmental Evaluation Associates of Namibia (DRFN-EEAN) for 14 years up to 2008. See CV (Appendix E1).

2.2 Sheldon Husselmann

Sheldon Husselmann is the holder of BSc, BSc (Honours) and MSc in Environmental and Geographical Science (2010, 2011 and 2016 respectively).

Sheldon has more than 7 years of experience as an EAP. During this time he has gained an understanding of all aspects (including public consultation) of the EA process and led many EAs (including public consultation). Find attached his CV (see Appendix E2).

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3 Project Description

3.1 Project Location

As stated in Chapter 1, the project consists of the construction and operation of tourist accommodation facilities. The proposed facilities are located within the Kwando Core Area of Bwabwata National Park, approximately 3km north of the Susuwe Park Management Station and 7km northwest of Kongola (see Figure 3-3).

3.2 Project Overview

The main project components and associated infrastructure are as follows:

• Main lodge with main area (consisting of a dining area, bar, curio shop, public toilets, kitchen, swimming pool, tea and refreshment station, an inside and outside buffet area among other facilities) with 12 guest rooms (a total capacity of 28 guests) (see Figure 3-5. The main lodge area has an estimated total footprint of 1,332m2. • Eight self-catering rooms, located either east (near campsite) or west of the park road (see Figure 3-5), and campsite comprising two large campsites (for groups), eight smaller campsites (see Figure 3-5) for general area within which campsites will be located). The campsites and self-catering units (option east of the park road) will be served by a camp reception area, kiosk and bar, while the option for the self-catering units west of the park road will be served by the main area for the chalets. Each set of campsites will have washing and toilet facilities. The self-catering rooms and campsite will have an estimated total footprint of 2,053m2.

• Staff accommodation, to cater for up to 40 staff, and support infrastructure (consisting of storerooms, workshop area, and laundry room). The staff accommodation and support infrastructure have an estimated total footprint of 1,130m2. • Rehabilitation of existing single-lane tracks (approximate total distance of 45 km) and extension of existing network of single-lane tracks (approximate distance 40 km). Sections of tracks that are prone to flooding and erosion may be upgraded in places (involving raising the road, installing drainage and surfacing with compacted gravel). Existing borrow pits, with valid Environmental Clearance Certificates (ECCs), will be used for this purpose. • Water for construction and operation of the proposed lodge will be sourced from a new solar-powered borehole located on-site approximately 100 m to the northwest of the existing water storage tower (see Figure 3-5). The estimated upper limit (peak use) for the rate of abstraction will be 6,000 litres/day during construction and 5,000 to 10,000 litres/day during operation. Bulk water storage will be developed at a high point

6 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

to be determined and will consist of four 10,000 litre tanks. The restoration of an existing water storage tower platform (see Figure 3-5) is one option. • All sewage (i.e. generated by all accommodation facilities for guests and staff) will be treated with a single three-chambered septic tank system with sufficient capacity to handle the projected average and peak wastewater flow volumes, designed according to recognised standards (e.g. the South African National Standard). The wastewater after passing through the septic tank chambers will be reused for various activities (e.g. feeding artificially sustained wet areas within the river floodplain, watering a small garden etc.) and/or will be discharged underground via a soakaway designed according to recognised standards. • Electricity will be supplied using either solar installations with battery storage or an above ground or below ground 2.5 – 3km 33kV power line connected to the Namibia Northern Regional Electricity Distributor’s (NORED) distribution grid (see Figure 3-4). A diesel generator will be used as a backup electricity source in all three instances. • An existing airstrip, currently used communally by the MET and existing tourism operators in the area, located approximately 3 km southwest of the site (see Figure 3-4), will be used by some guests as a means of transport to the lodge. Current number of flights are estimated at 1 per week and is estimated to increase by 2 flights/week as a result of the proposed lodge activity. • Generally, no fencing will be used in the concession area. A security fence will be erected around the staff village.

3.3 Electrical Infrastructure

As stated above, the Proponent intends to use either solar power or conventional grid-tied power (above or below ground). This decision is yet to be finalised and therefore all three options have been described and assessed as part of this EA process. All three options will include a backup diesel generator. 3.3.1 Power Line Infrastructure

3.3.1.1 Overhead Power Line

The proposed 33kV power line will be supported by wooden monopole structures, each measuring approximately 13 metres in height, buried to a depth of 2 m (see Figure 3-1). The span width between the wooden monopole structures will be approximately 100-120m.

7 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

A three-phase electrical system will be installed – i.e. three (3) conductors (see Figure 3-1 for an example of a 33kV power line). The conductors will be arranged on an A-frame (Figure 3-1) to add extra height to the conductors in order to avoid interactions with large mammals.

Figure 3-1: Example 33kV power line with A-frame

8 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

The distance from the lowest conductor to the ground at the pole will be approximately 9.45 m, which should provide sufficient clearance to avoid interactions with large mammals (i.e. giraffes and elephants).

The Proponent will commission and oversee the design and construction of the proposed power line, after which NORED will take responsibility for the operation and maintenance thereof.

A servitude (possibly 6 m or more) might be registered by NORED for the proposed power line. The power line will be a minimum of 11 m from the edge of all existing roads to ensure that it does not fall onto a road in the unlikely event of collapse toward a road. Six metres either side of the power line centreline will be cleared of vegetation (see Figure 3-2).

This vegetation clearance area will probably be maintained (i.e. regularly cleared of vegetation) on annual basis by NORED.

Figure 3-2: Layout of proposed power line cutline and servitude

3.3.1.2 Underground Power Line and Solar Plant

The proposed underground power line will probably be a 33kV line and will follow the same route alignment proposed for the overhead power line (see Figure 3-4). The cable will be approximately 25 mm in diameter and will be laid at a depth of approximately 800 mm. A trench with approximate dimensions – 800 mm (depth) and 800 mm (width), will be excavated for the laying of the power line. The power line will cross the B8 road via a culvert to the east of the turnoff to the MET tourist reception area (see Figure 3-4). A minimum of 0.5 m either side of the power line centreline will be cleared of vegetation.

A small solar power plant (in the order of approximately 100 m2) might be constructed as part of the underground power line option to allow power generated to feed back into NORED power grid.

The Proponent will commission and oversee the design and construction of the proposed power line. The Proponent will also be responsible for the operation and maintenance of the proposed underground power line.

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The vegetation clearance area (minimum of 0.5 m either side of the power line centreline) will probably be maintained (i.e. regularly cleared of vegetation) on annual basis by the Proponent. 3.3.2 Solar Power Plant

The proposed photovoltaic (PV) solar power plant will have an installed PV module capacity of approximately 49.5 kilowatt (kW) peak and an average energy yield of approximately 92,000 kW hours/year. The solar system will be fitted with a 48 kilovolt ampere lithium ion battery pack.

The solar panels will be mounted on roof structures where the majority of the power will be required – i.e. the main lodge area (Figure 3-4). The total area required for the solar panels is approximately 200 m2.

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Figure 3-3: Proposed project location

11 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Figure 3-4: Map displaying key infrastructure

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Figure 3-5: Site map of proposed lodge facilities

13 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

3.4 Construction Phase 3.4.1 Construction Workforce and Duration

There will be approximately 25 workers on-site, increasing temporarily to about 35 when sub- contracted teams are also on site. The estimated duration of the construction period is approximately 10-months.

Existing, old park management structures in the concession area will be cleaned and renovated to accommodate the workforce during construction.

All three power supply options (i.e. overhead and underground power line or solar power) will require a relatively small team of approximately six workers and approximately one truck and utility vehicle (4X4). The timeline for the construction of either of the power supply options (approximately one to two weeks) will overlap with the 10-months construction period. In both cases the construction workforce will reside in a camping setup on-site.

3.4.2 Construction Services and Utilities

The services and utilities required during the construction phase include:

• Water – approximately 6,000 litres of water per day during peak use, sourced from the new borehole, as stated previously. • Fuel – only a small amount of fuel (for generators) will be stored on site as there is a fuel station situated in Kongola. • Electricity – electricity will be provided by generators supplied by the appointed contractor. • Toilets – pit latrines will be erected by the contractor. • Solid waste – will be collected in a secure central place, removed from the park and disposed of at the nearest waste management site (Kongola). A few large construction vehicles (e.g. trucks etc.), utility vehicles (4X4) and some construction equipment (e.g. cement mixers, jackhammers etc.) will be used, and in some instances cleaned and maintained, on-site during the construction phase.

3.5 Operation Phase

3.5.1 Operation Phase Activities

The Proponent’s management company, RETURN Africa (Pty) Ltd, will manage the operation of the proposed lodge. The following activities will take place on site:

• Game drives in the Kwando Core Area (half and full-day). • Boat trips on the Kwando River (see Figure 3-5 for boat launch location).

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• Canoeing. • Guided walks. • Fishing (outside of the park). • Cultural activities, including visits to local villages, traditional dancing, arts and crafts. • General hospitality services (restaurant, reception and administration, laundry etc.). • General maintenance works. 3.5.2 Operation Workforce

The lodge operations will require approximately 40 permanent employees. All of the lodge workforce will be accommodated on-site in the staff accommodation. 3.5.3 Operation Phase Services and Utilities

The water, wastewater and electricity requirements for the operational phase have been detailed under Section 3.2 – Project Overview above. The remainder of the services requirements and other operational management activities are as follows:

• Road access – an unproclaimed park road will be used to gain access for the proposed lodge to the B8. • Solid waste management – will be carried out as proposed during the construction phase.

3.6 No Action Alternative

If the proposed lodge development does not take place the following advantages are likely:

• Lower risk of groundwater pollution owing to relatively lower volumes of wastewater generated. • Less pressure on existing groundwater resources owing to relatively lower water abstraction rates. • Less habitat disturbance, owing to human activity (e.g. vegetation clearance, movement of people etc.). If the proposed lodge development does not take place the following disadvantages are likely:

• Loss of potential permanent employment for a few individuals and their households. • Economic opportunity cost for tourism sector in the project area. • Habitat disturbance, owing to human activity (e.g. vegetation clearance, movement of people etc.). The potential disadvantages regarding wastewater are easily mitigated. Groundwater resources in the project area are not currently under strain.

Therefore, the no-action alternative is less desirable than the development taking place.

15 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

4 Legislation Relevant to the Project

The legislative and regulatory framework relevant to the proposed lodge is described below.

4.1 The Environmental Management Act (7 of 2007) and Regulations (2012)

The Environmental Management Act (EMA) gives effect to Article 95(l) of the Namibian Constitution by establishing general principles for the management of the natural and social environment. Environmental Assessments (EAs) and consultations with communities and relevant national and local authorities are provided for, to monitor the development of projects that potentially have an impact on the environment. It provides a broad definition to the term “environment” to include all biological and physical resources, as well as social, archaeological, aesthetic, cultural, historic, economic and palaeontological values. For any activities or projects which have or will have an environmental impact, an Environmental Clearance Certificate (ECC) is required.

The Regulations provide a list of projects requiring an ECC under Section 27 of the Act. Various activities that will take place as part of the proposed project (as set out in Section 1.4 above) trigger the need for an ECC.

Section 40(1) stipulates that an ECC remains valid for a period not exceeding three years, subject to cancellation or suspension.

4.2 The Water Act (54 of 1956)

The Water Act remains in force until the new Water Resources Management Act of 2013 comes into force. This Act governs the protection, allocation and conservation of all water resources, the implementation of water supply infrastructure and water schemes, and water pollution. This Act makes the Department of Water Affairs responsible for the use, allocation, control and conservation of Namibia’s surface- and groundwater resources.

The Water Act contains provisions regarding the prevention of water pollution in Section 22. A distinction is made between public and private water. A person who has control of land on which a substance might cause water pollution, is required to take steps to prevent such substances from causing water pollution (Ruppel & Ruppel-Schlichting, 2016).

Water abstraction permits under this act are required in water control areas. The project does not fall within a water control area defined under this act.

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4.3 The Water Resources Management Act (11 of 2013)

The Water Resources Management Act is not yet in force as its Regulations have not been promulgated. It provides for the management, protection, development, use and conservation of water resources; and for the regulation and monitoring of water services.

The objectives of this Act are to ensure that the water resources of Namibia are managed, developed, used, conserved and protected in a manner consistent with, or conducive to, the fundamental principles of sustainable management of water resources. Of special note are two principles:

(k) prevention of water pollution and implementation of the principle that a person disposing of effluent or waste has a duty of care to prevent pollution;

(l) a polluter is liable to pay all costs to clean up any intentional or accidental spill of pollutants.

4.4 Labour Act (11 of 2007)

The Labour Act of 2007 and Government Notice 156 of 1997: Labour Act, 1992: Regulations Relating to the Health and Safety of Employees at Work, governs working conditions of employees. These regulations are prescribed for among others safety relating to hazardous substances, exposure limits and physical hazards. Special consideration must be given to:

• Chapter 3: Welfare and Facilities at Work-Places • Chapter 4: Safety of Machinery • Chapter 5: Hazardous Substances • Chapter 6: Physical Hazards and general provision

4.5 Namibia Tourism Board Act (21 of 2000)

This act makes provision for the registration and grading of accommodation establishments; and for the registration of businesses falling within a regulated sector; and to provide for matters incidental thereto. The Proponent should ensure that the proposed lodge development complies with all the relevant provisions of this act.

4.6 Forest Act (12 of 2001)

This Act provides for the general protection of the environment.

Permits are required for the removal of protected plants species as well as any vegetation removed within 100 m of a watercourse.

17 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

4.7 Nature Conservation Ordinance (No. 4 of 1975)

This ordinance makes provision for the protection of indigenous flora and fauna.

Permits are required for the removal of protected plants species listed under this ordinance.

4.8 Roads Ordinance (No. 17 of 1972)

This ordinance, in general, provides for the control of activity along proclaimed roads in Namibia.

Matters pertaining to the width of proclaimed roads and road reserve boundaries, which are to be kept free of obstructions and infringements, are stipulated in Section 3.1. Provisions relating specifically to infringements and obstructions on and interference with proclaimed roads are stipulated in Section 37.1.

4.9 National Heritage Act (No. 27 of 2004)

The National Heritage Act provides for the protection and conservation of places and objects of heritage significance and the registration of such places and objects. This Act also establishes the National Heritage Council and a National Heritage Register.

Section 55(3) states that “all archaeological and palaeontological [sic] objects and meteorites are the property of the State”. The term ‘archaeological’ is defined under Section 1 of this Act, in relation to a place or object, as:

(a) any remains of human habitation or occupation that are 50 or more years old found on or beneath the surface on land or in the sea.

(b) rock art, being any form of painting, engraving or other representation on a fixed rock surface or loose rock or stone which is 50 or more years old.

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5 Description of the Receiving Environment

5.1 Biophysical Environment

5.1.1 Climate

The Zambezi Region has higher rainfall, less evaporation and warmer winters than the rest of Namibia, and the climate is classified as sub-humid (Mendelsohn, et al., 2003).

Rainfall averages about 700 mm per year in the wetter north-east, and about 500 mm in the south of Zambezi Region. The climate can be divided into two main seasons – a dry season between April and November, and a shorter wet season which stretches from November to early April. Rainfall, as in the rest of Namibia, is highly variable, with standard deviation values from 30 – 40% (Mendelsohn & Roberts, 1997)

Temperatures are moderate during summer months in the Zambezi Region mostly due to cloudy conditions in these months. The highest temperatures are between September to November when there is less cloud cover and average daily maximums of 32-35 °C can be reached. In the winter months, the region has a more moderate winter than the rest of Namibia with maximum daily temperature of between 18-25 °C and minimum temperatures of 5 °C. Frost is unusual in the Zambezi region, but may occur in some years in low-lying river valleys, such as the Kwando (Mendelsohn & Roberts, 1997).

The highest rate of evaporation takes place during September to October when it is hot, dry and clouds are sparse. About 2,500mm water evaporates in an average year, which is over four times the volume of water normally provided by rain (Mendelsohn & Roberts, 1997).

5.1.2 Geology, Topography and Soils

The Zambezi Region is relatively flat and Kongola lies at an altitude of about 1,000 m above sea level. The region is covered in thick deposits of Kalahari sand, with very little of the underlying geology exposed. The extensive Kalahari sands and the Zambezi, Kwando and Chobe Rivers with their associated floodplains, channels and deposits are the two major features which shape the landscape (Mendelsohn & Roberts, 1997).

Kongola and the vicinity of the proposed lodge are situated close to the Kwando River. The river channel itself follows a meandering pattern with occasional oxbow lakes, over a wide floodplain. The floodplain is flat and is dominated by grasslands and old river channels. River waters flood over these areas when good rains further upstream in Angola cause river levels to rise.

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Zambezi Region is dominated by Kalahari Sands called arenosols soils. Clay-loam soils called fluvisols are found fringeing the larger river courses; these are relatively nutrient-rich soils which support the vegetation along the river banks (Mendelsohn & Roberts, 1997).

5.1.3 Hydrogeology

Zambezi Region is topographically featureless and almost completely flat, which is what makes its hydrology so unusual. The Kwando is a relatively small river, with mean annual runoff about 1,200 Mm3/a, which is less than 3% of the annual runoff of the Zambezi River at Victoria Falls (Schlettwein, et al., 1990). The Kwando is linked to the Zambezi River via the Linyanti Swamp, Lake Liambezi and the Chobe River which joins the Zambezi River at Kazungula. When the Kwando River is in flood, water pushes towards the Zambezi. When the Zambezi is in flood, the flow is reversed and water is pushed up the Chobe to Liambezi.

Groundwater quality in much of Zambezi Region is generally good, especially within 5 – 20 km from the rivers, which recharge the aquifers. But the quality tends to deteriorate rapidly away from the rivers and with increasing depth (Christelis & Struckmeier, 2001).

The regional groundwater flow direction is generally to the southeast, while locally (i.e. near the proposed site) it is generally toward the southwest – i.e. away from the Kwando River, which appears to act as a source for groundwater recharge (see Appendix C). 5.1.4 Biodiversity

5.1.4.1 Flora

The proposed camp is located in the Kwando River valley, within the broad-leaved savannah biome. Specifically, the concession area lies in the ecotone between the Kwando River floodplains and the Kalahari woodlands. The Kwando River and associated wetland provide a meandering eastern boundary of the concession area.

The floodplains are flooded annually or less frequently depending on their height in relation to the main Kwando River channel. They consist of reedbeds and open flooded grasslands, with higher, drier areas supporting grasses and trees, and lower, wetter areas marked by dense tall reeds, sedges and papyrus beds.

The tree component is diverse with the following being recorded during the site visit: Acacia nigrescens, Acacia luderitzii, Acacia erioloba, Acacia sieberana, Philentoptera violacea, Zizyphus mucronata, Syzygium cordatum, Combretum imberbe, Combretum herorense, Teriminalia sericea, Peltophorum africanum, Garcinia livingstonei, Ficus sycamororous and Sclerocarya birrea. Smaller trees and the scrub layer include Acacia hebeclada, Combretum mossambicensis, Diospyros lycioides, Grewia sp., Croton gratissimus, Croton megalobotrys,

20 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Baphia massaiensis, Phyllanthus reticulatus, Dichrostachys cinerea and Euclea divinorum. There is no evidence of presence of any endangered plant species, and all trees species are common in similar habitats within Bwabwata National Park (BNP).

5.1.4.2 Fauna

Wildlife in the surrounding floodplains, Kwando system and the Kalahari woodlands is exceptional and includes elephant, buffalo, reedbuck, lechwe, hippo, wildebeest, giraffe, impala, zebra, roan and sable. Large predators include leopard, wild dog, lion and spotted hyena. Many of the large mammals in this environment depend on being able to move freely around the broader landscape of the Kavango-Zambezi Trans-Frontier Conservation Area (KAZA TFCA), which includes parts of Botswana, Zambia and Angola. The wetlands of the Kwando River support a rich diversity of birds, including several species listed as threatened by the International Union for Conservation of Nature (IUCN).

Wildlife numbers are generally rising in Zambezi Region as a result of the facilitation of transboundary movements through KAZA and the growing shift to diversify livelihoods towards wildlife, due to the improving benefits that rural communities can receive from this resource.

5.2 Socio-Economic Environment

5.2.1 Kongola Constituency and Project Site

5.2.1.1 Demographic Profile

The population of Zambezi Region in the 2011 census was 90,596 people, with 31% of them in urban areas (Namibia Statistics Agency, 2014). The average population density of the region was 6.1 persons per km² in 2011, which is much higher than the national average of 2.6 persons per km², indicating possible land use pressures within the region. However, the population density of Kongola Constituency is the lowest in the Region, at 1.4 persons per km2, due to the fact that much of the Constituency consists of Bwabwata National Park and the Zambezi State Forest.

5.2.1.2 Land Use and Economic Profile

Kongola is a typically rural constituency with 41% of household income derived from farming activities (Ministry of Lands and Resettlement, 2015). According to the household income and expenses survey, carried out by the NSA (2012), 57% of the Kongola Constituency

21 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019 population is dependent upon subsistence farming. This comprises crop farming as the dominant agriculture activity, with livestock farming being the second largest agricultural activity.

The economically active section makes up 63.5% of the Kongola Constituency population (NSA, 2012). The inactive population comprises students, homemakers and pension recipients, while the economically active population is divided into the unemployed and employed population.

Many communities are fortunate to have additional livelihood activities coming from the life- sustaining river and floodplain systems such as along the Kwando River (MLR, 2015). For the communities living in proximity to water, fishing and home-based industries such as collection of reeds from the rivers are important, while in all parts of Zambezi there is strong reliance on indigenous plant products for food and medicinal purposes.

5.2.1.3 Infrastructure

The area is served by the main tarred road (B8) linking Kongola and Katima Mulilo to the east, with Divundu and Rundu to the west. A gravel road, maintained by the MET, provides access to the project site.

Power within the wider project area is distributed by NORED. Lodges in the area make use of solar power in combination with backup diesel generators.

5.2.2 Archaeology and Heritage Resources

According to the Southern African Institute for Environmental Assessment (2015, p. 69) the “Zambezi Region has a relatively short archaeological sequence representing the introduction of agricultural resettlements to the area within the past two thousand years”.

According to Boden (2009) the Zambezi region gained significant strategic importance during the 1960s. The Zambezi region became the main infiltration route for the People’s Liberation Army of Namibia (PLAN) subsequent to the start of the South West African People’s Organisation’s armed struggle in 1966 (Boden, 2009). The PLAN fighters would cross the border into Namibia from Zambia, which had gained independence in 1964. The Zambezi region became a no access military zone in 1974 with the South African Defence Force (SADF) taking control of the area (Boden, 2009). During the early 1970s military structures were erected by the SADF in the wider project area most, notably the “Fort Doppies” (Namibia Tourism Board, No date; Boden, 2009) located approximately 15km southwest of the proposed project site.

22 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Figure 5-1: Remains of a SADF military structure

According Mr Simon Mayes (2019), a former SADF soldier, MET employee and Integrated Rural Development and Nature Conservation staff member based at Susuwe, the SADF Navy constructed a military camp within the footprint of the proposed lodge. This camp was known as ‘Fort St Michel’ (and subsequently the former Susuwe MET station) and was reportedly constructed in the mid-1980s and is therefore younger than ‘Fort Doppies’ (located south of the B8 as stated above), which was built between 1972 and 1974 (Mayes, 2019). In light of the approximate age of the military structures (i.e. close to 50 years old) located within approximately 15km of the proposed project site, the likelihood of archaeological objects (as defined by the National Heritage Act – see Chapter 4 – Legislation Relevant to the Project) occurring within the wider project area is possible. 5.2.3 Visual Characteristics

The project area is mostly flat, with tall dense vegetation away from the floodplain of the Kwando River and less tall vegetation within the river floodplains. Views are therefore mostly unobscured toward the river and obscured while moving between the thick tall vegetation away from the floodplains. Landscape viewing can take place during various activities such as canoeing, and 4x4 trails. High points in the topography are used to take advantage of such views.

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6 Public Consultation

Public consultation is an important aspect of an EA process. During public consultation, potential impacts that the proposed project may have on the receiving environment, are identified. Consultation with Interested and Affected Parties (I&APs), representing both state and non-state interests, enables transparent decision-making.

This chapter describes the details of the public consultation process that was followed and the I&APs that were notified of the study being undertaken. It also includes the main issues and concerns raised during the public consultation process and comments received on the Background Information Document (BID) distributed during the first round of public consultation.

Public consultation for the purposes of this project was done as prescribed by Regulations 21 to 24 of the Environmental Impact Assessment Regulations (GN. 30 of 2012).

6.1 First Round of Public Consultation

Engagement with I&APs as part of the first round of public consultation commenced on 7 March 2019 and concluded on 28 March 2019. During the first round of consultation, I&APs and authorities were given an opportunity to register and submit comments on the proposed project. 6.1.1 Public Consultation Activities

Activities undertaken to date to ensure effective and adequate I&AP involvement, are as follows:

• A register of I&APs was compiled and maintained (Appendix F1). A total of 74 I&APs were included in the database. • A notification email (Appendix F2) with the BID (Appendix F3) was distributed to all registered I&APs on 12 March 2019 or on later dates as they were registered. • Notification letters were hand delivered on 8 March 2019 to the relevant national ministries situated in Windhoek (Appendix F4). These were MET (neighbour to the project), and MAWF (for input re water abstraction and wastewater treatment). • Public notices announcing the commencement of the EA and an invitation to register as an I&AP were placed in “New Era” and “The Namibian” on 7 and 14 March 2019 (Appendix F5). • A notice board (with the dimensions 60cm x 42cm) was placed at the MET Tourist Reception building located near the turnoff to the B8 tarred road at the start of the access road to the site (Appendix F6).

24 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

• A public meeting was held on 19 March 2019 at Kwandu Conservancy office (located approximately 5km north of Kongola on the western side of the D3502) with the local residents to facilitate comments and inputs from this local community. The minutes are recorded in Appendix F7, together with the attendance register for the meeting, and the content of the presentation that was given.

6.1.2 Comments Received and Responses Provided

All comments and feedback received from I&APs are presented in Table 6-1 below. The email trails with individual I&APs are shown in Appendix F8.

Table 6-1: Comments received and responses provided during the first round of public consultation

No. Name Comment / Issue Response

1 Public Concern was expressed that Proponent: In keeping with the meeting at Kwando Lodges (Pty) Ltd would agreement governing the Kwandu repeat the disappointment proposed lodge development, Conservancy caused by the previous Kwando Lodges (Pty) Ltd has 19 Mar-19 proponent who was awarded a obtained a bank guarantee, which concession to build a lodge will pay out in the event that the within the concession area but contractual obligations with failed to do so. respect to the proposed lodge development are not met.

2 Public Concern was expressed that the Proponent: No restriction of any meeting at activities associated with the of the neighbouring community’s Kwandu local community’s movement activities are intended by Kwando Conservancy and livelihood – i.e. fishing and Lodges (Pty) Ltd beyond the 19 Mar-19 collecting of reeds/grass among boundaries of the concession area, others, might be hindered by which is located within a national the proposed project activities. park.

3 Public Concern expressed about the Proponent: Kwando Lodges (Pty) meeting at strategy/procedures for the Ltd and its management company, Kwandu recruitment of labour for the Return Africa (Pty) Ltd, will Conservancy construction and operation develop and implement a 19 Mar-19 staffing requirements. recruitment policy in consultation with the Kwando Conservancy committee. It is the intention of

25 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

No. Name Comment / Issue Response

the proponent to employ as many people from the Conservancy as possible.

4 Public Concern was expressed about Proponent: Lodge operation staff meeting at the liability for injuries sustained will be covered in terms of Kwandu by appointed lodge staff while insurance for injuries sustained Conservancy on-duty and/or residing at the while on-duty and/or residing at 19 Mar-19 staff accommodation area. the staff accommodation area.

No more comments received.

6.2 Second round of public consultation

Engagement with registered I&APs for review of the Draft Scoping Report lasted from 27 May to 10 June 2019.

• The Draft Scoping Report was sent to all registered I&APs by email on 27 May 2019, for those with email access (Appendix F9). • A hard copy report was couriered to the Kwando Conservancy, where the Chairperson, Mr Brilliant Musiwa, agreed to let conservancy members know that it was available for inspection. Only one response was received (see Table 6-2 below and Appendix F10). This was from the National Heritage Council, and was resolved in cooperation with the Council.

Table 6-2: Comments received and responses provided during the second round of public consultation

No. Name Comment / Issue Response

5. Dr Alma Concern that there may be RES: A chance find procedure was Nankela, archaeological or historical included in the Scoping Report. National heritage materials at the site. The NH Council will pronounce on Heritage the need for a site visit, which if Council necessary will take place before construction commences.

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6.3 Public Consultation Outcome

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7 Impact Assessment

The proposed project is expected to have impacts on the immediate and surrounding receiving socio-economic and biophysical environment. An understanding of these impacts, together with effective mitigation measures, can help to minimise or preferably avoid such impacts.

The purpose of this chapter is to identify potential impacts that the project is expected to have on the receiving environment and determine their significance. Some impacts might be insignificant while others might need special attention or even further investigation.

This chapter provides a description and assessment of potential impacts associated with the project. Mitigation measures, where appropriate, are recommended. These are aimed at avoiding, minimising or mitigating negative impacts and enhancing potential benefits. The significance of potential impacts without and with enhancement is also provided.

7.1 Assessment Method

The identified impacts are assessed according to a synthesis of criteria required by the integrated environmental management procedure. This entails the establishment of the expected impact’s extent (spatial scale), duration (time scale), magnitude (intensity), probability, and status, in combination providing the expected significance (see Table 7-1).

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Table 7-1: Criteria applied to each potential impact

CRITERIA CATEGORY

Impact This is a description of the expected impact.

Nature Positive: The activity will have an environmental (social or Describes the type of biophysical) benefit. impact. Neutral: The activity will have no effect. Negative: The activity will have an environmentally (social or biophysical) harmful effect.

Extent Site Specific: Expanding only as far as the activity itself (on-site) The area affected by the Small: Restricted to the site’s immediate environment within 1 km impact. of the site (limited) Medium: Within 5 km of the site Large: Beyond 5 km of the site (regional)

Duration Temporary: < 1 year Predicts the lifetime of the Short-term: 1 – 5 years impact. Medium term: 5 – 15 years Long-term: >15 years (impact will stop after the operational or running life of the activity, either due to natural causes or by human interference) Permanent: Impact will be where mitigation or moderation by natural causes or by human interference will not occur in a particular means or in a particular time period that the impact can be considered temporary.

Magnitude Very low: Affects the environment in such a way that natural and/or Describes the scale/size of social functions/processes are not affected. the impact. Low: Natural and/or social functions/processes are slightly altered. Medium: Natural and/or social functions/processes are notably altered in a modified way. High: Natural and/or social functions/processes are severely altered and may temporarily or permanently cease.

Probability of Occurrence Improbable: Not at all likely. Low probability: Possible but not very likely

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CRITERIA CATEGORY

Describes the probability of Probable: Distinct possibility. the impact actually Highly probable: Most likely to happen. occurring. Definite: Impact will occur regardless of any prevention measures.

Degree of Confidence in Unsure/Low: Little confidence regarding information available. Predictions Medium: Moderate confidence regarding information available. States the degree of High: High confidence regarding information available. confidence in predictions based on availability of information and specialist knowledge

Significance No change: A potential concern which was found to have no impact The impact on each when evaluated. component is determined Very low: Impacts will be site-specific and temporary with no by a combination of the mitigation necessary. above criteria. Low: The impacts will have a minor influence on the project and/or environment. These impacts require some thought to adjustment of the project design where achievable, or alternative mitigation measures. Moderate: Impacts will be experienced in the local and surrounding areas for the life span of the development and may result in long term changes. The impact can be lessened or improved by an amendment in the project design or implementation of effective mitigation measures. High: Impacts have a high magnitude and will be experienced regionally for at least the life span of the development, or will be irreversible. The impacts could have the no-go proposition on portions of the development in spite of any mitigation measures that could be implemented.

Significance is determined through a synthesis of impact characteristics as described in Table 7-1 above. It provides an indication of the importance of the impact in terms of both tangible and intangible characteristics. The significance of the impact “without mitigation” is the prime determinant of the nature and degree of mitigation required. Where the impact is positive, significance is noted as “positive”.

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7.2 Potential Impacts

7.2.1 Planning and Design Phase Considerations

The planning phase is the current phase within which the proposed project is, the phase where conceptual designs and plans are drafted for discussion and evaluation which will result in the final designs and plans for implementation. Issues to be considered during the planning phase are not necessarily assessed according to the assessment criteria laid out in Table 7-1 above.

7.2.1.1 Power Lines and Bird Interactions

The proposed project is located within a national park, which forms part of the wider Kavango-Zambezi (KAZA) Transfrontier Conservation Area (TFCA). KAZA TFCA is evidence of the internationally significant conservation value of the area within which the project is located. Several birds listed as threatened by the International Union for Conservation of Nature (IUCN) are expected to be resident or migrant in the project area.

Collisions with Power Line Structures

A collision occurs when a bird in mid-flight does not see the overhead cables or structures until it is too late to take evasive action. These impacts could take place on any parts of the power line, but are more likely in sections where the line is located near flight corridors, such as a perennial river. Collisions may also take place on stay wires (e.g. on poles at bend points or transformer poles), for instance when a bird is flushed from its position on the ground. Collisions occur mainly during the operational phase but may take place even during the construction phase, once the conductors have been strung but not energised.

Recommendation

In light of the potential impact associated with bird collisions with power line structures the following mitigation measures are recommended for the entire length of the power line:

• The top conductor should be marked by using a combination of small, alternating black and white Bird Flight Diverters (made by Preformed Line Products (PLP); and "Viper" Live Bird Flappers (also made by PLP) (see Figure 7-1). • A spacing of 5 m between markers should be used. The following monitoring initiatives should be conducted by the Proponent, in collaboration with and with the support of NORED and the NamPower/ Namibia Nature Foundation (NNF) Strategic Partnership:

• Ensure that the entire line is monitored not more than three months between inspections for any signs of bird mortalities.

31 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

• All observed bird mortalities should be reported immediately to the NamPower/NNF Strategic Partnership for further action. • Monitor bird nesting and perching activities on power line structures and follow up if outages occur.

Figure 7-1: Examples of power line marking devices made by Performed Line Products - Bird Flight Diverter (left) and Viper Live Bird Flapper (right)

Electrocution of Birds on Power Line Structures

An electrocution occurs when a bird is perched or attempts to perch on an electrical structure and causes an electrical short circuit by physically bridging the air gap between live components and/or live and earthed components. The proposed monopole typically has relatively close clearances, which increases the potential for electrocutions should a large or medium-sized bird touch two or more live components (or a live and an earthed component) simultaneously, especially if the structure and/or bird is wet or damp. A large bird sitting on an earthed transformer or switchgear pole would similarly be at risk to electrocution.

Recommendation

In light of the potential impact associated with bird electrocutions on power line structures the following mitigation measures are recommended1:

• The earth wire on each power line pole should be "gapped", i.e. an air space safety gap should be included in the earth wire running along the pole (see Figure 7-2 below for example). The gap should be wide enough to avoid being permanently active, but close enough to allow lightning strikes to bridge it. This mitigation also applies to poles used for transformer and switchgear structures.

1 NamPower may be consulted for details on electrocution mitigation.

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• Transformer structures should be designed in such a way that they are not attractive as bird perches/nesting sites. Selected live components (e.g. central jumpers/droppers running to transformers or switchgears) should be insulated (e.g. using black polyvinyl chloride (PVC) piping or low density polyethylene pipe (LDPE)) (see Figure 7-2 below for example). • Monitoring as described under the collisions section above should be undertaken for this impact as well.

7.2.1.2 Impact on Heritage Resources

The remains of military structures, constructed by the South African Defence Force in the early 1970s, occur within the project site (see Section 5.2.2 – Archaeology and Heritage Resources). These structures might be considered significant from an archaeological or heritage point of view. Therefore, the following is recommended:

• A representative from the National Heritage Council should be allowed to inspect the proposed project site prior to the start of construction to survey the project footprint for potential objects of heritage/archaeological significance. • The National Heritage Council’s ‘chance finds procedure’ should be included in the Environmental Management Plan. This procedure lays our clearly the steps to follow

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in the event that an object of heritage or archaeological significance is unearthed during construction works (e.g. excavations etc.). 7.2.2 Construction Phase

Some of the potential environmental impacts (biophysical and social), both negative and positive, are outlined below, followed by suggested mitigation measures.

Table 7-2 below presents the potential impacts expected to occur during the construction phase of the project, while Table 7-3 to Table 7-8 present the detailed assessment and outcome of each of the key impacts listed in Table 7-2.

Table 7-2: Potential impacts expected during the construction phase

Aspect Potential Impacts

Socio-economic Employment creation and skills transfer (Positive) environment Waste generation

Health and safety of workers on-site

Biophysical Soil and groundwater pollution environment Disturbance and poaching of animals

Clearing of vegetation

7.2.2.1 Employment and Skills Transfer

The construction activities for the lodge facilities will provide a several Namibian individuals either from the areas surrounding the project, or beyond, with temporary semi- and unskilled jobs. The income generated will benefit the individuals’ households. Furthermore, these activities will result in the improvement in skills and therefore improved employability for those people.

Table 7-3 below presents an assessment of the impact associated with employment creation and skills transfer.

Table 7-3: Assessment of the impact of employment creation and skills transfer

Criteria Description

Employment creation (unskilled, semi-skilled and skilled posts, ranging Potential impact from temporary to long-term)

Positive impact. Employment opportunities will be created during the Nature construction and operational phases

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Criteria Description

Extent Local to regional

Duration Temporary to long-term

Magnitude Low

Probability Probable

Significance Low-medium

Where possible, Namibian citizens from the local area should be Synergies or preferentially employed for the unskilled labour. enhancement Equal opportunities should be provided for both men and women. measures A recruitment policy should be developed in consultation with the Kwandu Conservancy Committee Significance (with Low-medium enhancements)

Confidence level High

7.2.2.2 Waste Generation

Construction activities and the presence of people working and living on the site, will generate waste. Such waste includes domestic (household) waste and sewerage, building rubble, and hazardous substances such as fuels, oils and paints. If not managed appropriately, these could cause the area to look untidy and dirty, and organic waste could attract wild animals (e.g. jackals, crows) that might become problem individuals. This impact is assessed in Table 7-4 below

Table 7-4: Assessment of the impact of waste generation

Criteria Description

Poorly managed waste could become problematic, with litter and rubbish Potential impact lying around, substances causing pollution, and possibly some organic waste attracting scavenging animals that could become a nuisance.

Negative impact through health risks and spoiling the aesthetic beauty of Nature the natural environment.

Extent Local

Duration Temporary but possibly for longer if there is pollution.

Magnitude Low

35 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Criteria Description

Probability Probable

Significance Low-medium

Waste disposal procedures should be included in the induction of all staff working on site. Facilities for appropriate disposal should be put in place, such as adequate and functional ablutions and sewage handling systems, Mitigation measures provision and regular cleaning of rubbish bins, waste separation and recycling procedures, and other measures as stipulated in the EMP. Animal-proof waste holding areas should be created for temporary storage of waste until transportation to the nearest waste facility.

Significance (with Low mitigations)

Confidence level Medium-High

7.2.2.3 Soil and Groundwater Pollution

Construction involves use of hazardous and corrosive substances such as hydrocarbon fuels and oils, paints and cement. Although the quantities used will be relatively small, these pose a threat from spills and careless disposal, and can cause small-scale contamination of soil and groundwater.

Wastewater will be generated by the construction workforce at the temporary accommodation facilities. If not managed well, this may pose a small scale pollution threat to surface and groundwater.

This impact is assessed in Table 7-5 below.

Table 7-5: Assessment of the impact of soil and groundwater pollution

Criteria Description

Wastewater from toilets used by construction workers at the temporary accommodation facilities may contaminate groundwater if not well managed. Potential impact Use of hazardous and corrosive substances carries a risk of spills and careless dumping, which would pollute the soil and possibly contaminate groundwater.

36 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Criteria Description

Negative impact on biophysical resources, possibly also putting human Nature health at risk.

Extent Local

Duration Temporary

Magnitude Low

Probability Probable

Significance Low-medium

Open defecation should be discouraged. The code of practice on the building site should include the following specifications: • No dispensing of fuel or refilling motors outside of the designated areas. Mitigation measures • Fuel for machinery should be stored in a steel fuel tank with a bunded impermeable surface below. Measures must be in place to prevent run-off and seepage into the soil. • Spillages of potentially harmful substances must be cleaned immediately and disposed of at the nearest hazardous waste management facility. Significance (with Low mitigations)

Confidence level Medium-High

7.2.2.4 Health and Safety of Workers On-site

The project area is rich in wildlife. Large mammals such as, hippo, elephant, giraffe, various antelope species as well as predators such as lions and leopards are expected to move through the project site. Several snake species (including poisonous ones) are expected to occur on-site. The possibility of construction workers on-site being injured or killed as a result of interaction with wildlife in the area is a possibility.

This impact is assessed in Table 7-6 below.

Table 7-6: Assessment of the impact of health and safety of workers on-site

Criteria Description

Construction staff brought on to the site during the construction phase Potential impact might be injured or killed due to interactions with wildlife in the area.

37 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Criteria Description

Nature Negative impact

Extent Local

Duration Temporary

Magnitude Low-high

Probability Probable

Significance Low-medium

All staff on site, including contract workers, should receive general health and safety induction and on-going training. This should include issues of environmental awareness. All construction staff should be sensitised to the presence of large and potentially dangerous mammals and should be Mitigation measures trained on what to do in situations when encountered. At least one or two members of staff should receive training on how to handle snakes. This will ensure that snakes can be safely removed from site when necessary.

Significance (with Low mitigations)

Confidence level Medium-High

7.2.2.5 Disturbance and Poaching of Animals

The project area is rich in wildlife. There are plenty of trees in the project area which may serve as potential nesting trees for large raptors. Therefore, the potential for disturbance (e.g. to breeding individuals) exists.

Large mammals such as hippo, elephant, giraffe, various antelope species as well as predators such as lions and leopards are expected to move through the project site. Several snake species (including poisonous ones) are expected to occur on-site. Conscientious patrolling and alert behaviour by management can usually detect poaching if this is happening. This impact is assessed in Table 7-7 below.

Table 7-7: Assessment of the impact of disturbance and poaching of animals

Criteria Description

Construction staff brought on to the site during the construction phase Potential impact could get involved in illegal trapping or other poaching of local wildlife. If the behaviour is not detected and stopped early, then it could also

38 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Criteria Description extend to become a more long-lasting problem when the lodge is operational and permanent staff are installed.

Nature Negative impact

Extent Local

Duration Temporary but possibly extending longer if not controlled.

Magnitude Low

Probability Probable

Significance Low-medium

All staff on site, including contract workers, should receive induction training on the overall policy of conservation that Proponent promotes. This should include issues of environmental awareness. All construction staff should be sensitised to the presence of large and potentially dangerous mammals and should be trained on what to do in situations when encountered. The Proponent should stay alert for signs of poaching such as snares in the veld, evidence of slaughtering at the workers quarters or where workers are active, or suspicious signs of covering up evidence. Mitigation measures Any member of staff or contract worker should be expelled from site immediately if found guilty of poaching. At least one or two members of staff should receive training on how to handle snakes. This will ensure that snakes can be safely removed from site when necessary as opposed to being killed. Large loose rocks should be placed for at least 1 m radius around the base of power line poles to discourage elephants and other large herbivores from rubbing themselves against these poles, which could risk power lines collapsing and electrocuting these mammals.

Significance (with Low mitigations)

Confidence level Medium-High

7.2.2.6 Clearing of Vegetation

Construction activity (laydown areas, movement of equipment, materials and vehicles, excavations etc.) will result in the clearing of vegetation where these activities occur.

39 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Some of this vegetation clearance is unavoidable. For example, excavating the pits for septic tanks and digging of building foundations. No vegetation clearance is necessary beyond construction areas. This impact is assessed in Table 7-8 below.

Table 7-8: Assessment of the impact of vegetation clearing

Criteria Description

Construction areas will be cleared of plants, leaving open areas prone to Potential impact erosion and scars on the landscape. Minimisation of clearing/construction footprint is essential.

Nature Negative impact

Extent Local

Medium-term to long-term. The impact lasts as long as it takes for Duration disturbed areas to recover.

Magnitude Low

Probability Probable

Significance Low

As already intended by the Proponent, the lightest ecological footprint is intended.

Movement of vehicles and machinery must be restricted to existing roads and tracks to prevent unnecessary damage to vegetation. Mitigation measures Where possible, rehabilitation and restoration should be carried out in keeping with the natural vegetation and the ambience of the surroundings. The necessary permits should be obtained from the nearest forestry office for removal of protected species.

Significance (with Very low mitigations)

Confidence level High

7.2.3 Operation Phase

Table 7-9 below presents the potential impacts expected to occur during the operational phase of the project, while Table 7-10 to Table 7-14 present the detailed assessment and outcome of the impacts listed in Table 7-9 that are unique to the operation phase. Impacts of a similar nature to those pertaining to the construction phase are not evaluated.

40 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Table 7-9: Potential impacts expected during the operation phase

Aspect Potential Impacts Comment

Socio- Employment creation Similar in nature to the construction phase equivalent economic and skills transfer impact (see Table 7-3 above). Job opportunities would environment (Positive) however be permanent/long-term.

Diversification of local Addressed below. economy (Positive)

Waste generation Impact of wastewater treatment plant on groundwater addressed below. Solid waste will be managed as stated in Section 3.5.3 – Operation Phase Services and Utilities.

Health and Safety of Similar in nature to the construction phase equivalent Workers impact (see Table 7-6 above).

Light pollution Addressed below.

Visual impact Addressed below.

Biophysical Soil, ground and surface Addressed below. environment water pollution

7.2.3.1 Growth of the Tourism Sector and Diversification of the Local Economy

The establishment of lodge facilities will increase the number of tourism beds in the overall area and serve to increase the number of visitors and associated tourist activity. This will help to grow the tourism industry in Namibia. The lodge will also increase the economic activity in the area.

Table 7-10 below presents an assessment of the impact associated with increased tourism and economic diversification.

Table 7-10: Assessment of the impact of increased tourism and economic diversification

Criteria Description

Potential impact Increased tourism will help to grow and diversify the economy.

Nature Positive impact

Extent Local to regional

Duration Long-term

Magnitude Low

41 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Criteria Description

Probability Probable

Significance Low

Synergies or enhancement Where possible, local Namibian citizens should be offered measures employment or training opportunities.

Significance (with Low-medium enhancements)

Confidence level High

7.2.3.2 Impact of Wastewater Treatment Plant on Groundwater

As stated in Chapter 3 – Project Description, the proposed wastewater treatment system consists of a three-chamber septic tank system and a final discharge of effluent underground via a soakaway and/or reuse of treated wastewater.

The proposed wastewater treatment plant and its discharge point will be located more than 350 m “downstream” (i.e. in terms of groundwater flows) of the nearest borehole (i.e. the proposed borehole to serve the project water needs). In light of this information the probability of contamination of the water supply from the proposed borehole is considered to be low.

The impact and possible mitigations are assessed in Table 7-12 below.

Table 7-11: Assessment of the impact of wastewater treatment system on groundwater

Criteria Description

Wastewater generated during operation may contaminate Activity groundwater if not well managed.

Negative impact on groundwater resources, possibly also putting Nature human health at risk.

Extent Local

Duration Long-term (for the duration of the project)

Magnitude Medium

Probability Improbable

Significance Low

42 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Criteria Description

Wastewater treatment system should have sufficient capacity to handle the average and maximum expected volumes of wastewater. The wastewater treatment plant components should be designed according to recognised standards (e.g. South African National Standards). Discharge of treated effluent onto the river floodplain should take the findings of the geohydrologist input (see Appendix C) into consideration. Optimise the siting of the borehole using the knowledge of groundwater flow directions (Appendix C) – i.e. site the borehole as Mitigation measures far as practicably possible to the northwest of the current proposed site (i.e. the existing water storage tanks). Site the wastewater treatment plant as far southeast of the proposed location (currently -17.764°, 23.343°) as practicably possible (moving the wastewater treatment plant onto the floodplain is undesirable). A yield test (24 hours is recommended) should be carried out by a suitably qualified and experienced geohydrologist in order to determine the sustainable yield of the borehole. Furthermore, the borehole should not be pumped at rates beyond the sustainable yield in order to ensure that groundwater flow directions are not altered/induced toward the borehole.

Significance (with Low-none enhancements)

Confidence level High

7.2.3.3 Light Pollution

The proposed lodge will be illuminated at night. Strong lights at night tend to decrease the visibility of the night sky, which is not desirable. Also, lights attract insects which has the impact of reducing insect abundance in other dark areas, creating a ‘vacuum effect’ for animals such as nightjars which feed on insects at night (Gaston, et al., 2013). The impact and possible mitigations are assessed in Table 7-12 below.

43 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Table 7-12: Assessment of the impact of night lights at the lodge sites.

Criteria Description

Lights to illuminate the lodge areas could deteriorate the quality of Activity the night sky views of tourists, and could negatively impact on food availability for night-hunting insect eaters such as nightjars.

Negative impact, depending on the strength and orientation of the Nature lights. Flood lights tend to disperse much light upwards into the night sky, creating a ‘glow effect’ and reducing visibility of stars.

Extent Local

Duration For as long as the lodge is operational.

Magnitude Low

Probability Highly Probable

Significance Low

Reduce the area and intensity of flood lighting. Orientate outdoor and pathway lights downwards and reduce the Mitigation measures intensity of lighting to the minimum. Switch unnecessary lights off after bed-time.

Significance (with Low enhancements)

Confidence level High

7.2.3.4 Visual Impact

Landscape viewing is a prominent tourist activity along the open floodplains along the Kwando River. Therefore, any buildings which protrude from the horizon (whether because of height or inappropriate siting) as well as building textures and/or colours which contrast with the surrounding environment may constitute a visual impact. The impact and possible mitigations are assessed in Table 7-13 below.

Table 7-13: Assessment of the visual impact of the proposed lodge

Criteria Description

Activity Visual impact associated with visibility of proposed lodge buildings

Nature Negative impact

44 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Criteria Description

Extent Small to medium

Duration For as long as the lodge is operational.

Magnitude Low-medium

Probability Probable

Significance Low-medium

Use building shapes that do not contrast too much with the surroundings and orientate roof pitches so that they are in parallel with rather than at 90 degrees to the horizon. Use colours that are sympathetic with the environment. No reflective materials should be used. Mitigation measures Use natural materials (e.g. poles and thatch) as much as possible, especially rocks from the area. If corrugated iron is used for the roof, paint it a colour which blends with the surrounding environment. Place/position solar panels, water tanks and other prominent features in such a way that makes them invisible/less visible from nearby roads

Significance (with Low enhancements)

Confidence level High

7.2.3.5 Soil and Groundwater Pollution

Some of the general maintenance activities during the operation phase of the proposed lodge involves use of hazardous and corrosive substances such as hydrocarbon fuels and oils, paints and cement. Although the quantities used will be relatively small, these pose a threat from spills and careless disposal, and can cause small-scale contamination of soil and groundwater.

Wastewater will be generated by the lodge operator’s staff at the staff village as well as by the guests at the accommodation facilities. If not managed well, this may pose a pollution threat to surface and groundwater.

This impact is assessed in Table 7-14 below.

45 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Table 7-14: Assessment of the impact of soil and groundwater pollution

Criteria Description

Wastewater from toilets used by the lodge’s operational staff and guests may contaminate groundwater if not well managed. Potential impact Use of hazardous and corrosive substances carries a risk of spills and careless dumping, which would pollute the soil and possibly contaminate surface and groundwater.

Negative impact on biophysical resources, possibly also putting human Nature health at risk.

Extent Local

Duration Medium-long-term (for the duration of the lodge operation)

Magnitude Low

Probability Probable

Significance Low-medium

Wastewater treatment system should be installed as specified in Chapter 3 – Project Description. The wastewater treatment system should have sufficient capacity to handle the maximum expected volumes of wastewater from all sources (i.e. staff village, guest accommodation, main area, etc.). The code of practice on the building site should include the following specifications: Mitigation measures • No dispensing of fuel or refilling motors outside of the designated areas. • Fuel for machinery should be stored in a steel fuel tank with a bunded impermeable surface below. Measures must be in place to prevent run-off and seepage into the soil. • Spillages of potentially harmful substances must be cleaned immediately and disposed of at the nearest hazardous waste management facility. Significance (with Low mitigations)

Confidence level Medium-High

46 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

7.2.4 Cumulative Impacts

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

Some of the impacts of the lodge could combine with similar impacts from other developments in the vicinity, creating a greater or more severe impact than noted in this assessment. Such cumulative impacts include:

• Increased volumes of waste, that might exceed the capacity for managed disposal at the nearest landfill site. • Increased light pollution. • Impact on sense of place from higher volumes of tourists. Waste management impacts and light pollution can be addressed through careful management and collaboration with neighbours and thorough implementation of the measures listed in the EMP.

47 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

8 Conclusions and Recommendations

This chapter presents the conclusions of the scoping phase of the Environmental Assessment EA conducted and the recommendations for consideration by the Proponent and relevant authorities. The conclusions and recommendations presented are based on the impact assessment presented in Chapter 7 above.

8.1 Conclusions

Kwando Lodges (Pty) Ltd (the Proponent) intends to construct and operate a lodge near Kongola in the Zambezi Region.

The positive impacts arising from establishment of the proposed lodge are beneficial to the local economy and Namibia’s tourism industry.

The negative impacts from the proposed development are significant enough to warrant mitigation measures, but none of them are likely to seriously damage or degrade any local resources. All the negative impacts can be reduced to manageable levels by implementation of the mitigation measures as laid out in the Environmental Management Plan (Appendix B). The mitigation suggestions for the proposed lodge are based on accepted good practices in the tourism industry (Eco Awards, 2005), and can be implemented without incurring significant costs.

8.2 Recommendations

The proposed development of a lodge near Kongola is unlikely to have significant negative impacts on the environment (social and biophysical), and there are no reasons to withhold an Environmental Clearance Certificate. The mitigation measures proposed in this report and the Environmental Management Plan should be carried out and monitored.

48 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

9 References

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Eco Awards, 2005. Good Practices Handbook. Windhoek: Namibia Nature Foundation.

Gaston, K., Bennie, J., Davies, T. & Hopkins, J., 2013. The ecological impacts of nighttime light pollution: a mechanistic appraisal. Biological Reviews, p. https://doi.org/10.1111/brv.12036.

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Schlettwein, C. H. G., Simmons, R. E., MacDonald, A. & Grobler, H. J. W., 1990. Flora, fauna and conservation of East Caprivi wetlands. Madoqua, 17(2), pp. 67-76.

49 Environmental Assessment – Proposed Lodge near Kongola, Zambezi Region Final Scoping Report – June 2019

Southern African Institute for Environmental Assessment, 2015. Strategic Environmental Assessment of the Zambezi Integrated Regional Land Use Plan, Windhoek: Ministry of Land Reform.