SODALITE MINING PROJECT ENVIRONMENTAL IMPACT ASSESSMENT FOR MINING OF BLUE SODALITE DIMENSION STONE, RARE EARTH ELEMENTS AND IRON ORE, NEAR OTJIMUHAKA, WITHIN MINING LICENCE 40 & MINING CLAIMS 68664, 70783, 70784, 70113, 70114, 70119, EPUPA CONSTITUENCY, KUNENE REGION SCOPING REPORT WITH ASSESMENT Prepared by Philip Hooks April 2021 Project: Environmental Impact Assessment for mining of blue sodalite dimension stone and other minerals, near Otjimuhaka, within Mining Licence (ML) 40, Epupa Constituency, Kunene Region Report: Final Report for Submission to MEFT, version 6 Version/Date: 24 April 2021 Prepared for: KNL of Namibia (Pty) Ltd Cite this Hooks, P.N., 2020. Final Scoping Report with Assessment for mining of blue document as: sodalite dimension stone, Rare Earth Elements and Iron Ore, near Otjimuhaka, within Mining Licence (ML) 40 & Mining claims 68664, 70783, 70784, 70113, 70114, 70119, Epupa Constituency, Kunene Region KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 EXECUTIVE SUMMARY KNL of Namibia (Pty) Ltd, (hereafter referred to as KNL or the Proponent) is a wholly owned Namibian company, which holds the mineral rights as granted with ML40, issued by the Ministry of Mines and Energy on 24 April 1997. KNL plans to continue mining sodalite as ornamental and dimension stones and also start mining and processing of other minerals within Mining Licence 40 (ML40) and within nearby Mining Claims 68664, 70783, 70784, 70113, 70114, 70119 that the proponent currently has rights too. All mineral rights are located at the northern border of Namibia. in the Kunene Region. The proponent appointed Philip Hooks, an independent Environmental Assessment Practitioner (EAP), to undertake the assessment and compile this scoping assessment report and Environmental Management Plan (EMP) in support of the application. The curriculum vita of the EAP is provided in Appendix A. From 1997 to 2006 the company developed dimension stone quarries within ML40 together with the related mining and processing infrastructure at the accessory works area of the ML. Since 2017 no blocks of dimension stone have been extracted. Plans to expand the mining to iron-titanium ore and to rare earth minerals have been drawn up. The accessory works area will be expanded to accommodate the processing of these additional ores. The Terms of Reference for the proposed project is based on the requirements set out by the Environmental Management Act (EMA) (2007) and its EA Regulations (2012). Mining will take place within the licences, which cover approximately 730ha and which lies roughly 130 km north of Opuwo and about 2.5 km south-west of the Namibian-Angolan border, marked by the river Kunene (see the map below). The ML40 area is situated 4 km south-west of the settlement Otjimuhaka (previously Swartbooisdrif) (see Figure 2 in the report). The proposed activity focuses on the specific resources of sodalite, iron ore and rare earth mineralisation. The activities will be undertaken in phases as follows: ➢ The construction phase activities ➢ The operational phase activities 1 KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 ➢ Decommissioning phase activities Operation will entail mining, i.e., drilling and blasting of rock outcrops and also open cast mining with diamond cutting equipment to extract industrial size blocks of dimension stone. Mining techniques will make use of modern equipment such as excavators, diamond wire saw, circular diamond cutting machines, compressor driven drill rigs, jack hammers and dump trucks. Open cast mining will be established according to good industry practice procedure. KNL wants to establish central processing facilities for dimension stone, iron ore and for rare earth mineralisation, all of which occur within the Mining Licences and to some extend also on other surrounding mineral licences. Blocks of dimension stone, lumps of ornamental stone or concentrates of base and rare earth metal products are to be transported as bulk cargo as well as in bagged form. The viability of any mining operation, just like most industries, is particularly sensitive to the logistics concerned with getting the product to market. Different options are presently being investigated for the transport of the products to the harbour of Walvis Bay. Bulk bags on low-bed trucks or bulk road transport with loads up to 67 tons are envisaged to take the products on the public road infrastructure from the mine site to the harbour of Walvis Bay. Various studies have been undertaken to support the usage of such trucks including road wear analyses, modelling of a tractor-trailer design, bridge assessments. Product will be transported on a continuous basis. At a maximum monthly production of 5,000t a total of 139 truckloads at 36 t would be required. That is 5 trucks each day. The product would be transported along the gravel road to Ruacana and thereafter along the tar roads to the port of Walvis Bay. The mining licence is situated in a remote rural area. The physical and biological environment is aesthetically beautiful. There are obvious signs of degradation by previous mining activities and the effects of the current drought exacerbate the difficulty that the communities experience in living off the land. The mining operations take place on communal land. Due respect is given to the communities that use the area for subsistence living. The Ovahimba people are semi-nomadic and may come near the mining operations from time to time. Good community relations are imperative for the successful running of the mine. Public safety is of utmost importance. Decommissioning activities will include the removal of infrastructure, preparation of final landforms for closure and to rehabilitate roads where necessary. However, ongoing rehabilitation and landscaping should be conducted as the mining operations proceed. Shaping of the excavated area not only to accommodate rehabilitation efforts, but also in terms of safety, should be conducted according to a rehabilitation plan. In accordance with the Environmental Management Act, the proponent is required to make funds accessible which will specifically be available and allocated for rehabilitation efforts. This fund should continually be available during the life of mine yet also be sufficient to cover the decommissioning activities as required. The potential impacts associated with sodalite mining are specifically outlined in the environmental impact assessment chapter and incude the potential impacts on personnel working at the mine and the public who might reside near the mine. If purely looking at the available rock material within the mining licence, the estimated mining lifespan could be more than 50 years. However, for this assignment an estimated mining lifespan of up to 25 years is considered. The life of mine for the operations has been based on the expected demand and the size of the resource. However, this may vary significantly as the demand may fluctuate. Public Participation Public consultation was thorough, and the communities were well informed about the project. This was done through newspaper adverts for two consecutive weeks in The Namibian and Die Republikein (21st and 28th of July 2020) as well as face to face meetings with the public and relevant authorities. The stakeholders had an opportunity to ask questions and raise their various concerns. Upon completion of this report and drafting of the environmental management plan the Interested and 2 KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 Affected Parties have had further opportunity to provide input during the public review period. During the public review period (21st March to 19th April 2021) the community and regional stakeholders were engaged in a second round of face to face meetings (29th and 30th March 2021) to give feedback on the outcomes of the studies and impact assessments. All the documentary evidence for public participation is given in Appendices B to H. The following table lists the main issues that were raised in the first and second phase of the public participation process. Responses are given and references are made to the various sections and documents that provide answers the questions that were raised during the first and second round of meetings. These are the main points or concerns. Other issues are recorded in the minutes of the public meetings in Appendix G. Theme Issues & Responses (First Round of Meetings) Issue: Various requests for infrastructure improvement, provision of training, Corporate Social Responsibility programmes and other benefits to flow from the proposed mine to the local community and conservancy. Benefits to the local 1 Response: Section 6.7 and Table 28 deals with socio economic community impacts. Direct and indirect benefits are discussed in these sections. The proponent will make the final decision on what type of social responsibility project (s) could be funded or developed. The results of the NBRI botanical survey will feed valuable conservation status of plant species back to the conservancy for promoting the special endemism of the area. Issue: Concerns about local people being negatively impacted, by e.g. the tailings dams, dust, radiation, contamination of groundwater, and solid wastes. Mine infrastructure, 2 processes and Response: Section 4.5.1.2, Section 4.5.1.3, Section 4.5.1.4, Section developments 4.5.1.6, Section 6.3 and, Table 17, Table 18, Table 20, Table 21, Table 24, and Table 23 discuss each of these matters in detail. The EMP will provide the legal responsibilities for these aspects. Issue: Concerns about the deterioration of the roads that will be used by heavy vehicles, and its impact on tourism. 3 Negative impacts on roads Response: Section 4.5.1.5 and Section 4.5.2.2 and, Table 17, Table 22, and Table 29 provides decriptions of how the proponent will tackle these issues. The roads and bridges will maintain their integrity under the payloads planned and the frequency of trips.