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September 2021
Environmental Scoping Assessment (ESA) for the
Proposed Mining Activities of Base & Rare Metals on
Mining Claims No. 72051 – 72060 located Southwest of
Khorixas in the Kunene Region, Namibia
ENVIRONMENTAL ASSESSMENT REPORT – Final
ECC Application Reference: APP- 002914
Author(s): Mr. Silas David
Reviewer: Ms. Rose Mtuleni
Company: Excel Dynamic Solutions (Pty)
Ltd
Telephone: +264 (0) 61 259 530
Fax2email: +264 (0) 886 560 836
Email: [email protected]
Client: David Simon Lamberth
Contact person: David Simon Lamberth
Cellphone: +264 (81) 2535435
Postal Address: P.O Box 84,
Keetmanshoop, Namibia
Email: [email protected]
David Simon Lamberth EA: MCs No. 72051 - 72060
i
EXECUTIVE SUMMARY
David Simon Lamberth (hereinafter referred to as The Proponent), intends to conduct mining
activities on ten (10) Mining Claims (MCs) No. 72051 – 72060, located near Khorixas in the
Kunene Region. The application for the MCs was lodged on 05 August 2020. The target
commodity for the MCs is Base & Rare Metals. The MCs are located about 35 km southwest of
Khorixas, and covers a combined surface area of 163.0424 hectares (ha).
Project Description
The mining activities, resources, method, and processes required for the project have been
described and presented herein. The project activities will commence upon an issuance of an
ECC. The operational phase is anticipated to last for about 10 years.
Planned Mining Methods
The Proponent intends to adopt a systematic mining activity of the following:
Non-invasive techniques Detailed prospecting mapping. No ground geophysical
surveys are planned for the project.
Invasive techniques: Trenching and pitting, open pit mining.
The Proponent plans to conduct a staged mining approach with three phases including the Pre-
Development Phase, Operation and Maintenance Phase, and the Decommissioning and
Rehabilitation Phase.
The MCs No. 72051 - 72060 are MCs are accessible via the C39 main road from Khorixas which
is connected to the C35 road, leading to the MCs sites.
Water for the mining works in the MCs will be obtained from the Braunfels farm boreholes and/ or
off-site Khorixas municipal source or any other approved water sources, through sustainable
abstraction from the local borehole. Estimated monthly water consumption are at 3000 liters.
Power required during the operation phase will be provided from solar energy and diesel
generator.
Security is to be supplied on a 24-hour basis at a project material storage space and/or camp site.
David Simon Lamberth EA: MCs No. 72051 - 72060
ii
This project will employ at least 5 - 10 skilled and semi-skilled workers. Staff will be
accommodated in tents and home sourced casual labour near the sites.
Environmental Impacts
In order to avoid and minimize (where impacts cannot be avoided) the identified project impacts,
mitigation measures were recommended. The significant identified potential impacts for the
project phases are summarized below. These impacts can be reduced or minimized by
implementing the mitigation measures given under the impact assessment chapter and
management actions provided in the Draft EMP.
Disturbance to Pastoral Systems: Mining activities on the MCs may affect animal husbandry in
the project areas, and disturbance of livestock grazing land can lead to loss of livelihoods and
household level income.
Land degradation and loss of biodiversity: Mining activities on MCs may cause land
degradation, which, depending on the severity, could have a highly negative impact on the
biodiversity of the area, and lead to habitat loss for a diversity of flora and fauna. Disturbance to
soils may leave the naturally exposed soils on the sites vulnerable to erosion, aggravated by the
relatively low vegetation cover on the MCs.
Dust Generation: Dust emanating from mining activities and vehicular access to site may
compromise the air quality in the area. The hot and dry environment, coupled with loose and in
some places, sandy nature of the substrate and low vegetation cover may cause ambient fugitive
dust levels.
Waste Generation: Waste generation during the operational phase may cause surface water,
groundwater, soil, as well as land pollution, if the waste produced during operations are not
handled and disposed of in a responsible way.
Visual Impact (Scars) on Landscape: Mining activities on the MCs may cause aesthetic
damage to the landscape. Any scars on the landscape may contrast the surrounding landscape,
potentially becoming a visual nuisance.
Occupational Health and Safety Risks: Improper handling of operational materials and
equipment may cause health and safety risks i.e. injuries to workers. Covid-19 safety measures
are to be always observed during operations on site.
David Simon Lamberth EA: MCs No. 72051 - 72060
iii
Disturbance to archaeological Impact: Heritage and/or archaeological resources may be
impacted through unintentional destruction or damage. There are no known archaeological or
heritage sites on the MCs. However, any discoveries on the MCs should be reported to the
National Heritage Council.
Noise and Vibrations: Noise and vibrations produced by operational equipment may be a
nuisance to neighbours. Excessive noise can also be a health risk to site workers. The equipment
planned for use on site is of medium size and the noise level is bound to be limited to the site
only. Therefore, the impact likelihood is minimal.
Potential impact on soil and water resources (water abstraction and pollution): Over-
abstraction and use of water resources may impact the water availability in the project area.
Improper handling, containment and management of liquid waste (hazardous and effluent/
wastewater) may lead to soil and eventual water resources pollution.
Conclusion
The potential positive and negative impacts stemming from the proposed small-scale mining
activities on MCs 72051 - 72060 were identified, assessed and mitigation measures made thereof.
The mitigation measures and recommendations provided in this EA report and management
action plans provided in the draft EMP, can be deemed sufficient to avoid and/or reduce the risks
to acceptable levels.
Disclaimer
EDS warrants that the findings and conclusion contained herein were accomplished in
accordance with the methodologies set forth in the Scope of Work and Environmental
Management Act (EMA) of 2007. These methodologies are described as representing good
customary practice for conducting an Environmental Impact Assessment of a property for the
purpose of identifying recognized environmental conditions. There is a possibility that even with
the proper application of these methodologies there may exist on the subject property conditions
that could not be identified within the scope of the assessment, or which were not reasonably
identifiable from the available information. The Consultant believes that the information obtained
from the record review and during the public consultation processes concerning the proposed
mining work is reliable. However, the Consultant cannot and does not warrant or guarantee that
David Simon Lamberth EA: MCs No. 72051 - 72060
iv
the information provided by the other sources is accurate or complete. The conclusions and
findings set forth in this report are strictly limited in time and scope to the date of the evaluations.
No other warranties are implied or expressed.
Some of the information provided in this report is based upon personal interviews, and research
of available documents, records, and maps held by the appropriate government and private
agencies. This report is subject to the limitations of historical documentation, availability, and
accuracy of pertinent records and the personal recollections of those persons contacted.
COVID-19 Influences:
COVID-19 has changed the way the world thinks, acts, and does business. The pandemic has
forced a comprehensive review of business practices, a higher level of engagement with
technology to offset the constraints due to social distancing, restrictive travel, and a focus on
social responsibility. The Consultant had to change very little in the way they operate and provide
public consultation services.
Limitations
Although the Consultant operated with limited travel during the environmental assessment to
comply with the measures and regulations put in place to curb the spread of Covid-19, various
platforms were used to communicate the project information. These platforms included emails,
registered mails, Project site notices and newspaper adverts.
During assessment, the consulting team continuously practices social distancing, wearing of
facemasks and regular washing/sanitizing of hands.
David Simon Lamberth EA: MCs No. 72051 - 72060
v David Simon Lamberth: MCs No. 72051 - 72060
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...................................................................................................................... i
LIST OF FIGURES ............................................................................................................................. vii
LIST OF TABLES...............................................................................................................................viii
LIST OF APPENDICES .....................................................................................................................viii
LIST OF ABBREVIATIONS ............................................................................................................... ix
1 INTRODUCTION ......................................................................................................................... 13
1.1 Project Background ......................................................................................................... 13
1.2 Terms of Reference and Scope of Works ..................................................................... 15
1.3 The Need for the Proposed Project ............................................................................... 15
2 PROJECT DESCRIPTION: PROPOSED MINING ACTIVITIES ............................................ 16
2.1 Pre-development Phase (Prospecting) .......................................................................... 16
2.2 Operational and Maintenance Phase ............................................................................ 16
2.3 Decommissioning and Rehabilitation Phase ................................................................. 18
3 PROJECT ALTERNATIVES ...................................................................................................... 19
3.1 Types of Alternatives Considered .................................................................................. 19
3.1.1 The "No-go" Alternative ............................................................................................... 19
3.1.2 Mining Location ............................................................................................................ 20
4 LEGAL FRAMEWORK: LEGISLATION, POLICIES AND GUIDELINES ............................... 20
4.1 The Environmental Management Act (No. 7 of 2007) .................................................. 20
4.2 Other crucial legal requirements governing the proposed project ............................... 21
4.3 International Policies, Principles, Standards, Treaties and Conventions ................... 27
5 ENVIRONMENTAL BASELINE ................................................................................................. 31
5.1 Climate.............................................................................................................................. 31
5.1.1 Rainfall .............................................................................................................................. 31
5.1.2 Temperature ..................................................................................................................... 32
5.1.3 Winds ............................................................................................................................ 33
5.1.4 Relative Humidity ............................................................................................................. 35
5.2 Topography ...................................................................................................................... 35
5.3 Geology and Soil ............................................................................................................. 37
5.4 Hydrogeology and Water Resources ............................................................................. 41
5.5 Terrestrial Biodiversity: Flora and Fauna....................................................................... 43
David Simon Lamberth EA: MCs No. 72051 - 72060
vi David Simon Lamberth: MCs No. 72051 - 72060
5.6 Heritage and Archaeology .............................................................................................. 46
5.7 Surrounding Land Uses .................................................................................................. 47
5.8 Socio-Economic Status ................................................................................................... 49
6 PUBLIC CONSULTATION PROCESS ..................................................................................... 54
6.1 Pre-identified and Registered Interested and Affected Parties (I&APs) ..................... 54
6.2 Communication with I&APs ............................................................................................ 55
7 IMPACT IDENTIFICATION, ASSESSMENT AND MITIGATION MEASURES ..................... 58
7.1 Impact Identification ........................................................................................................ 58
7.2 Impact Assessment Methodology .................................................................................. 59
7.2.1 Extent (spatial scale) ................................................................................................... 60
7.2.2 Duration ........................................................................................................................ 60
7.2.3 Intensity, Magnitude / severity .................................................................................... 61
7.2.4 Probability of occurrence ............................................................................................. 61
7.2.5 Significance .................................................................................................................. 62
7.3 Assessment of Potential Negative Impacts ................................................................... 63
7.3.1 Disturbance to the Pastoral System ........................................................................... 63
7.3.2 Land Degradation and Loss of Biodiversity ............................................................... 64
7.3.3 Air Quality ..................................................................................................................... 65
7.3.4 Waste Generation ........................................................................................................ 66
7.3.5 Visual Impact (Scars) on Landscape ......................................................................... 67
7.3.6 Occupational Health and Safety Risks....................................................................... 68
7.3.7 Disturbance to Heritage/Archaeological resources................................................... 69
7.3.8 Noise and vibrations .................................................................................................... 70
7.3.9 Impacts associated with closure and decommissioning of mining works ............... 71
8 RECOMMENDATIONS AND CONCLUSIONS ........................................................................ 73
8.1 Recommendations ........................................................................................................... 73
8.2 Conclusion........................................................................................................................ 73
9 REFERENCES ............................................................................................................................ 74
David Simon Lamberth EA: MCs No. 72051 - 72060
vii David Simon Lamberth: MCs No. 72051 - 72060
LIST OF FIGURES
Figure 1: Location of the MCs No. 72051 - 72060 located near Khorixas in the Kunene Region
13
Figure 2: 2a and 2b show the visual project site picture taken during site visit (Photo: David,
2021). ................................................................................................................................................... 14
Figure 3: A graph showing average rainfall patterns for the project (Source: https://en.climate-
data.org/). 32
Figure 4: A graph showing average temperature patterns (Source: https://en.climate-
data.org/). 33
Figure 5: A graph showing average wind speed (Source: https://en.climate-data.org/). ........... 34
Figure 6: Wind frequency Rose and Wind power density graph for the project area (source:
https://globalwindatlas.info/) .............................................................................................................. 35
Figure 7: A graph showing average humidity patterns (Source: https://en.climate-data.org/). . 35
Figure 8: (8a) The landscape map, (9b) Elevation 3D Model and (9c) a section graph for the
project area ......................................................................................................................................... 37
Figure 9: General geology map for the MCs ................................................................................. 38
Figure 10: Rock types found within the MCs with presence of copper (Photo: David, 2021) . 39
Figure 11: The dominant soil types found within the MCs.......................................................... 40
Figure 12: The Lithic Leptosols dominant soil found within the project area (Photo: David,
2021). 40
Figure 13: The hydrology map of MCs 72051 - 72060 ............................................................... 41
Figure 14: Groundwater Drought Risk map around the project area. ....................................... 42
Figure 15: Vegetation map around the MCs ................................................................................ 44 Figure 16: Pictures of Colophespemum Mopane plant species on the MCs area (Photo:
David, 2021). 44
Figure 17: Maps of fauna density around the project area. ............................................................ 45
Figure 18: Animals evidence around the Braunfels farm and within the MCs (Photo: David,
2021). ................................................................................................................................................... 46
Figure 19: Sites of Lithic artifacts around and within the MCs....................................................... 47
Figure 20: Shows archaeological lithic artifacts captured during the site visits around and within
the MCs (Photo: David,2021). ........................................................................................................... 48
Figure 21: Land use (farms) within and surrounding the MCs (source:
https://maps.landfolio.com/Namibia/) ................................................................................................ 49
Figure 22: The population structure of the region covered by the MCs (Source: Namibia
Statistic Agency website). .................................................................................................................. 50
Figure 23: Tourism accommodation found around the MCs area (Source:
https://digitalnamibia.nsa.org.na/) ..................................................................................................... 51
Figure 24: Mines found around the vicinity of the project area (Source:
https://digitalnamibia.nsa.org.na/) ..................................................................................................... 52
Figure 25: Services and Infrastructures found around the project area (Source:
https://digitalnamibia.nsa.org.na/) ..................................................................................................... 53
Figure 26: Livestock map around the project area (Source: https://digitalnamibia.nsa.org.na/ )
53
David Simon Lamberth EA: MCs No. 72051 - 72060
viii David Simon Lamberth: MCs No. 72051 - 72060
Figure 27: Public notices placed at Braunfels Agricultural school and at the C39 road from
Khorixas to the MCs area. ................................................................................................................. 56
Figure 28: Public meeting held on the 24th of August 2021 (Photo: Roland,2021) .................. 57
LIST OF TABLES
Table 1: Applicable local, national and international standards, policies and guidelines
governing the proposed development .............................................................................................. 21
Table 2: International Policies, Principles, Standards, Treaties and Convention applicable to
the project 27
Table 3: Summary of Interested and Affected Parties (I&APs) .................................................. 54
Table 4: Summary of main issues and comments received during the public meeting
engagements ...................................................................................................................................... 57
Table 5: Extent or spatial impact rating ........................................................................................ 60
Table 6: Duration impact rating ..................................................................................................... 60
Table 7: Intensity, magnitude or severity impact rating ............................................................... 61
Table 8: Probability of occurrence impact rating.......................................................................... 61
Table 9: Significance rating scale ................................................................................................. 62
Table 10: Assessment of the impacts of small-scale mining activities on the Pastoral system
64
Table 11: Assessment of the impacts of small-scale mining activities on biodiversity ........... 65
Table 12: Assessment of the impacts of small-scale mining activities on air quality .............. 65
Table 13: Assessment of waste generation impact ................................................................... 66
Table 14: Assessment of small-scale mining activities on the landscape ............................... 68
Table 15: Assessment of the impacts of Small-scale mining activities on health and safety 68
Table 16: Assessment of the impacts of Small-scale mining activities on archaeological sites
69
Table 17: Assessment of the impacts of noise from small-scale mining activities operation . 70
Table 18: Assessment of the impacts of closure and rehabilitation ......................................... 71
LIST OF APPENDICES
Appendix A: Copy of the Environmental Clearance Certificate (ECC) Application Form 1
Appendix B: Environmental Management Plan (EMP)
Appendix C: Curricula Vitae (CV) for the Environmental Assessment Practitioner (EAP)
David Simon Lamberth EA: MCs No. 72051 - 72060
ix David Simon Lamberth: MCs No. 72051 - 72060
Appendix D: List of Interested and Affected Parties (I&APs)
Appendix E: Background Information Document (BID)
Appendix F: EIA Notification in the newspapers (New Era and the Namibian)
Appendix G: Meeting Minutes
Appendix H: Copy of Mineral license
Appendix I: Copy of Consent letter from Traditional Authority
Appendix J: Archaeology Report
LIST OF ABBREVIATIONS
Abbreviation Meaning
AMSL Above Mean Sea Level
BID Background Information Document
CV Curriculum Vitae
DEA Department of Environmental Affairs
EA Environmental Assessment
EAP Environmental Assessment Practitioner
ECC Environmental Clearance Certificate
EDS Excel Dynamic Solutions
EIA Environmental Impact Assessment
EMA Environmental Management Act
EMP Environmental Management Plan
MCs Mining Claims
GG Government Gazette
GN Government Notice
I&APs Interested and Affected Parties
David Simon Lamberth EA: MCs No. 72051 - 72060
x David Simon Lamberth: MCs No. 72051 - 72060
Abbreviation Meaning
MEFT Ministry of Environment, Forestry and Tourism
MME Ministry of Mines and Energy
PPE Personal Protective Equipment
Reg Regulation
S Section
TOR Terms of Reference
KEY TERMS
Alternative A possible course of action, in place of another that would meet the
same purpose and need of the proposal.
Baseline Work done to collect and interpret information on the condition/trends of
the existing environment.
Biophysical That part of the environment that does not originate with human activities
(e.g. biological, physical and chemical processes).
Cumulative
Impacts/Effects
Assessment
In relation to an activity, means the impact of an activity that in it may not
be significant but may become significant when added to the existing and
potential impacts eventuating from similar or diverse activities or
undertakings in the area.
Decision-maker The person(s) entrusted with the responsibility for allocating resources or
granting approval to a proposal.
Ecological Processes Processes which play an essential part in maintaining ecosystem integrity.
Four fundamental ecological processes are the cycling of water, the
cycling of nutrients, the flow of energy and biological diversity (as an
expression of evolution).
David Simon Lamberth EA: MCs No. 72051 - 72060
xi David Simon Lamberth: MCs No. 72051 - 72060
Environment As defined in Environmental Management Act - the complex of natural and
anthropogenic factors and elements that are mutually interrelated and
affect the ecological equilibrium and the quality of life, including – (a) the
natural environment that is land, water and air; all organic and inorganic
matter and living organisms and (b) the human environment that is the
landscape and natural, cultural, historical, aesthetic, economic and social
heritage and values.
Environmental
Management Plan
As defined in the EIA Regulations (Section 8(j)), a plan that describes how
activities that may have significant environments effects are to be
mitigated, controlled and monitored.
Interested and Affected
Party (I&AP)
In relation to the assessment of a listed activity includes - (a) any person,
group of persons or organization 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.
Fauna All of the animals found in a given area.
Flora All of the plants found in a given area.
Mitigation The purposeful implementation of decisions or activities that are designed
to reduce the undesirable impacts of a proposed action on the affected
environment.
Monitoring Activity involving repeated observation, according to a pre-determined
schedule, of one or more elements of the environment to detect their
characteristics (status and trends).
David Simon Lamberth EA: MCs No. 72051 - 72060
xii David Simon Lamberth: MCs No. 72051 - 72060
Nomadic Pastoralism Nomadic pastoralists live in societies in which the husbandry of grazing
animals is viewed as an ideal way of making a living and the regular
movement of all or part of the society is considered a normal and natural
part of life. Pastoral nomadism is commonly found where climatic
conditions produce seasonal pastures but cannot support sustained
agriculture.
Proponent Organization (private or public sector) or individual intending to implement
a development proposal.
Public
Consultation/Involvement
A range of techniques that can be used to inform, consult or interact with
stakeholders affected by the proposed activities.
Protected Area Refers to a protected area that is proclaimed in the Government Gazette
according to the Nature Conservation Ordinance number 4 of 1975, as
amended
Scoping An early and open activity to identify the impacts that are most likely to be
significant and require specialized investigation during the EIA work. Can,
also be used to identify alternative project designs/sites to be assessed,
obtain local knowledge of site and surroundings and prepare a plan for
public involvement. The results of scoping are frequently used to prepare
a Terms of Reference for the specialized input into full EIA.
Terms of Reference (ToR) Written requirements governing full EIA input and implementation,
consultations to be held, data to be produced and form/contents of the EIA
report. Often produced as an output from scoping.
David Simon Lamberth EA: MCs No. 72051 - 72060
13 David Simon Lamberth: MCs No. 72051 - 72060
1 INTRODUCTION
1.1 Project Background
David Simon Lamberth (hereinafter referred to as The Proponent) is the holder of ten Mining
Claims (MCs) 72051 - 72060, granted by the Ministry of Mines and Energy (MME). The Proponent
intends to acquire an Environmental Clearance Certificate (ECC) in order to conduct mining
activities on the MCs. The Proponent focuses on the acquisition, mining and development of
targeted commodities (i.e. Base & Rare Metals). The locality of the proposed MCs sites
(coordinate: -20.489, 15.178) is shown in Figure 1 below. The application for the MCs has been
lodged.
Figure 1: Location of the MCs No. 72051 - 72060 located near Khorixas in the Kunene Region
David Simon Lamberth EA: MCs No. 72051 - 72060
14 David Simon Lamberth: MCs No. 72051 - 72060
Figure 2 (2a & 2b) below shows pictures of the project site (MCs), that was taken during the site
visit on the 24th August 2021.
Figure 2: 2a and 2b show the visual project site picture taken during site visit (Photo: David, 2021).
Section 27 (1) of the Environmental Management Act (EMA) (No. 7 of 2007) and its 2012
Environmental Impact Assessment (EIA) regulations, provides a list of activities that may not be
carried out without an Environmental Impact Assessment (EIA) being undertaken and an
Environmental Clearance Certificate (ECC) obtained. Mining activities are among the activities
that may not occur without an ECC. Therefore, for the mining activities on the MCs to commence,
the Proponent is required to submit an Environmental Assessment Report (EAR) and draft
Environmental Management Plan (EMP) to the Ministry of Environment, Forestry and Tourism
(MEFT). Once the MEFT evaluates the EAR and EMP, an approval may then be issued or denied.
If issued, the Proponent may only then, commence mining activities.
The Proponent has appointed, thereupon, Excel Dynamic Solutions (Pty) Ltd (EDS, Consultant
or Environmental Assessment Practitioner (EAP) hereafter), an independent team of
(a) Visual project site (MCs) taken from the
east from the MCs (red)
Mining Claims Site
(b) Visual project site (MCs) taken on top of
MC No. 72053
David Simon Lamberth EA: MCs No. 72051 - 72060
15 David Simon Lamberth: MCs No. 72051 - 72060
Environmental Consultants to conduct the required Environmental Assessment (EA) process and
submit to the Ministry of Environment, Forestry and Tourism (MEFT) on their behalf.
1.2 Terms of Reference and Scope of Works
There were no formal Terms of Reference (ToR) provided to EDS by the Proponent. The
consultant, instead, relied on the requirements of the Environmental Management Act (No. 7 of
2007) (EMA) and its Environmental Impact Assessment (EIA) Regulations (GN. No. 30 of 2012)
to conduct the study.
To satisfy the requirements of the EMA and its 2012 EIA Regulations, the Proponent appointed
EDS, to conduct the required EA process on their (Proponent’s) behalf. The findings of the EA
process are presented into this report and together with the draft EMP - (Appendix B) will be
submitted as part of the requirements for the approval of the mining activities on the MCs to the
Environmental Commissioner at the Department of Environmental Affairs (DEA), MEFT and the
Ministry of Mines and Energy (MME) as the Competent Authority of the proposed project and its
related activities.
The EIA project is headed by Mr. Nerson Tjelos, a qualified and experienced Geoscientist and
experienced EAP. The consultation process and reporting was conducted by Mr. Silas David, and
reviewed by Ms. Fredrika Shagama. The CV for Mr. Tjelos is presented in Appendix C.
1.3 The Need for the Proposed Project
The mining sector forms a vital part of some of Namibia’s development plans, namely: Vision
2030, National Development Plan 5 (NDP5) and Harambee Prosperity Plan (HPP). Similarly,
mining activities in Namibia contribute to the increasing global demand for minerals, and for
national prosperity. Partaking of local individuals/groups in the mining sector would enhance the
already existing mining activities in the Kunene Region. Not only enhancing mining activities, but
also improve livelihoods through income generation to the mining claim owners as well as
providing employment opportunities to the locals (to generate income for themselves and their
families). The targeted resources would contribute greatly to the generation of foreign currency
David Simon Lamberth EA: MCs No. 72051 - 72060
16 David Simon Lamberth: MCs No. 72051 - 72060
and positively contribute to the national GDP. This in turn, can support the aim of achieving a
balance between the establishment and dissemination of wealth.
2 PROJECT DESCRIPTION: PROPOSED MINING ACTIVITIES
2.1 Pre-development Phase (Prospecting)
The prospecting phase includes reconnaissance and mapping to identify prospective
lithostratigraphic packages. In addition, literature review, fieldwork (lithological (soil/rock) mapping
and sampling) will be conducted to verify desktop work.
2.2 Operational and Maintenance Phase
During this phase, Base & Rare metals ore will be extracted from the pits and undertaking related
activities on site. The Proponent has highlighted that both invasive and non-invasive activities are
expected to take place. Non-invasive activities include detailed prospecting mapping. No ground
geophysical surveys are planned for the project. While invasive activities involve trenching and
pitting, open pit mining.
A 10 years’ mining period is predicted. The selection of the potential mineralization model and
mineral targets will be based on the local geology, trenching, and assay results of the samples
collected. No explosives will be used during the operational phase.
Other aspects of the mining operations include:
2.2.1 Accessibility to Sites
The MCs are accessible via the C39 main road from Khorixas, which is connected to the C35
road, leading to the MCs sites.
2.2.2 Material and Equipment
The input required for the mining program in terms of vehicles and equipment includes two (4X4)
vehicles, Earthmoving Equipment (excavator, dozer) compressor, water tanks, and a power
generator. Equipment will be stored, and vehicles will be parked at a designated area near the
accommodation site or a storage site established within the MCs area.
2.2.3 Human Resources
David Simon Lamberth EA: MCs No. 72051 - 72060
17 David Simon Lamberth: MCs No. 72051 - 72060
The project will employ about 5 - 10 people, semi-skilled and skilled, including a site manager.
2.2.4 Personnel Accommodation
The mining crew will be accommodated in Khorixas, or a campsite will be set up for the crew near
the MCs site. If the accommodation camp is to be set up on a farm, necessary arrangements will
be made with the farm/land owner(s). Mining activities will take place during daytime only and
staff will commute to the site from their place of accommodation.
Workers who will be sourced from the vicinity of the site area/ farms will be commuting from their
homes to the work sites. However, should the commuting turn out to be unfeasible for the working
schedules, those local workers would be expected to be housed in temporary camps with others
for the duration of the project or per their work shifts. The temporary site camps will only be set
up upon reaching agreement and signed with and by the landowners/local authorities and/or
occupiers of land.
2.2.5 Services and Infrastructure
Water: Water for the operational phase will be obtained from the nearest existing boreholes
and/or off-site Khorixas municipal source or any other approved water sources, through water
abstraction permits. Estimated monthly water consumptions are at 3000 liters, which includes
water for drinking, sanitation, cooking, dust control, as well as washing equipment.
Power supply: Power required during the operation phase will be provided from solar energy
and diesel-generators.
Fuel (diesel for generators and other equipment): The fuel (diesel) required for mining will be
stored in jerry cans placed on plastic sheeting to avoid contamination of the ground.
2.2.7 Waste Management
The site will be equipped with secured waste bins for each type of waste (i.e., domestic,
hazardous, and recyclable). Depending on the amount generated, waste will be sorted and
collected weekly or monthly and taken to the Khorixas landfill site or any nearby certified dumpsite.
An agreement will need to be reached with different waste management facility operators/owners
and authorization or permits will be obtained prior to utilizing these facilities.
Sanitation and human waste: long drop system ablution facilities will be used, and the sewage
will periodically be taken to the nearest treatment facility.
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Hazardous waste: Drip trays and spill control kits will be made available on site to ensure that
oil/fuel spills and leaks from vehicles and equipment are captured on time and contained correctly
before polluting the site.
Mining Waste: These are topsoil and waste rocks removed to access the target materials.
Solid Waste: general solid waste (food waste, plastic, paper, etc.) and solid waste (used
equipment components, discard/waste rock samples etc.) will be generated by the mining
activities.
Liquid waste: Wastewater will be transported to the nearest suitable local authority wastewater
treatment facility, upon agreement with the Khorixas Town Council. Fuel/oil spills will be discarded
to the nearest approved and appropriate waste facility.
2.2.7 Health and safety
Adequate and appropriate Personal Protective Equipment (PPE) will be provided to every project
personnel while on and working at site. A minimum of two first aid kits will be readily available on
site to attend to potential minor injuries.
Fire management: A minimum of basic firefighting equipment, i.e., two fire extinguishers will be
readily available in vehicles, at the working sites and camps.
2.2.8 Project Site Security
Temporary storage areas for operational equipment, material and machines will be erected the
MCs sites. Security will be supplied on a 24-hour basis at the delegated sites for storage. A
temporary support fence surrounding the storage site will be constructed to ensure people and
domestic animals are not put at risk.
2.3 Decommissioning and Rehabilitation Phase
Mining activities on MCs No. 72051 - 72060 will eventually come to an end. Unfavourable
economic situations or depletion of the target resource(s) may lead the Proponent to cease
operational activities, in some cases, before predicted closure. In the event of decommissioning,
the sites will be rehabilitated. Decommissioning and rehabilitation are primarily performed through
a decommissioning and rehabilitation plan which consists of safety, health, environmental and
contingency aspects. Therefore, it is of best practice for the Proponent to ensure the project
activities are decommissioned in an environmentally friendly manner.
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3 PROJECT ALTERNATIVES
Alternatives are defined as the “different means of meeting the general purpose and requirements
of the activity” (EMA, 2007). This section will highlight the different ways in which the project can
be undertaken and to identify the option that will be the most practical, but least damaging to the
environment.
Once the alternatives have been established, these are examined by asking the following three
questions:
What alternatives are technically and economically feasible?
What are the environmental effects associated with the feasible alternatives?
What is the rationale for selecting the preferred alternative?
The alternatives considered for the proposed development are discussed in the following
subsections.
3.1 Types of Alternatives Considered
3.1.1 The "No-go" Alternative
The “no action” alternative implies that the status quo remains, and nothing happens. Should the
proposal of mining activities on the MCs, be discontinued, none of the potential impacts (positive
and negative) identified would occur. If the proposed project is to be discontinued, the current
land use for the proposed site will remain unchanged.
This option was considered and a comparative assessment of the environmental and socio-
economic impacts of the “no action” alternative was undertaken to establish what benefits might
be lost if the project is not implemented. The key loses that may never be realized if the proposed
project does not go ahead include:
Loss of foreign direct investment.
About 5 - 10 job opportunities for community members will not be realized.
No realization of local businesses supports through the procurement of consumable items
such as Personal Protective Equipment (PPE), machinery spare parts, lubricants, etc.
Loss of potential income to local and national government through land lease fees, license
lease fees and various tax structures.
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Improved geological understanding of the site area regarding the targeted commodities.
Socio-economic benefits such as skills acquisition to local community members would be
not realized.
Considering the above losses, the “no-action/go” alternative was not considered a viable option
for this project.
3.1.2 Mining Location
The location intended for small-scale mining activities are dependent on the geological setting
and economic geology of the area. Therefore, finding an alternative location for the planned
activities is not possible. The targeted mineralization is area specific, which means mineral
extraction targets are primarily determined by the geology (host rocks) and the tectonic
environment of the site (ore forming mechanism).
4 LEGAL FRAMEWORK: LEGISLATION, POLICIES AND GUIDELINES
A review of applicable and relevant Namibian legislation, policies, and guidelines to the proposed
development is given in this section. This review serves to inform the project Proponent,
Interested and Affected Parties, and the decision-makers at the DEA of the requirements and
expectations, as laid out in terms of these instruments, to be fulfilled to establish the proposed
small-scale mining activities.
4.1 The Environmental Management Act (No. 7 of 2007)
This EIA was carried out according to the Environmental Management Act (EMA) and its
Environmental Impact Assessment (EIA) Regulations (GG No. 4878 GN No. 30).
The EMA has stipulated requirements to complete the required documentation in order to obtain
an Environmental Clearance Certificate (ECC) for permission to undertake certain listed activities.
These activities are listed under the following Regulations:
3.1 The construction of facilities for any process or activities which requires a license, right
of other forms of authorization, and the renewal of a license, right or other form of
authorization, in terms of the Minerals (Prospecting and Mining Act, 1992).
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3.2 other forms of mining or extraction of any natural resources whether regulated by law
or not.
3.3 Resource extraction, manipulation, conservation, and related activities.
The Environmental Impact Assessment (EIA) Regulations GN 28-30 (GG 4878) detail
requirements for public consultation within a given environmental assessment process (GN 30
S21). The EIA regulations also outline the required details of a Scoping Report (GN 30 S8) and
an Assessment Report (GN 30 S15).
4.2 Other crucial legal requirements governing the proposed project Other legal obligations that are relevant to the proposed activities of MCs No. 72051 - 72060 and
related activities are presented in Table 1.
Table 1: Applicable local, national and international standards, policies and guidelines governing the proposed development
Legislation/Policy/
Guideline
Relevant Provisions Implications for this project
United Nation
Convention to
Combat
Desertification 1992
The convention objective is to forge a global
partnership to reverse and prevent
desertification/land degradation and to
mitigate the effects of drought in affected areas
to support poverty reduction and
environmental sustainability
United Nation Convention
The Constitution of
the Republic of
Namibia, 1990 as
amended
The Constitution of the Republic of Namibia
(1990 as amended) addresses matters relating
to environmental protection and sustainable
development. Article 91(c) defines the
functions of the
Ombudsman to include:
By implementing the
environmental management
plan, the establishment will be in
conformant to the constitution in
terms of environmental
management and sustainability.
Ecological sustainability will be
main priority for the proposed
development.
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Legislation/Policy/
Guideline
Relevant Provisions Implications for this project
“…the duty to investigate complaints
concerning the over-utilisation of living natural
resources, the irrational exploitation of non-
renewable resources, the degradation and
destruction of ecosystems and failure to
protect the beauty and character of Namibia…”
Article 95(l) commits the state to actively
promoting and maintaining the welfare of the
people by adopting policies aimed at the:
“…Natural resources situated in the soil and on
the subsoil, the internal waters, in the sea, in
the continental shelf, and in the exclusive
economic zone are property of the State.”
Nature
Conservation
Amendment Act,
No. 3 of 2017
National Parks are established and gazetted in
accordance with the Nature Conservation
Ordinance, 1975 (4 of 1975), as amended. The
Ordinance provides a legal framework with
regards to the permission of entering a state
protected area, as well as requirements for
individuals damaging objects (geological,
ethnological, archaeological, and historical)
within a protected area. Though the Ordinance
does not specifically refer to mining as an
activity within a protected area (PA) or
recreational area (RA), it does restrict access
to PA’s and prohibits certain acts therein as
well as the purposes for which permission to
enter game parks and nature reserves may be
granted.
The Proponent will be required
to enhance the conservation of
biodiversity and the
maintenance of the ecological
integrity of protected areas and
other State land
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Legislation/Policy/
Guideline
Relevant Provisions Implications for this project
The Parks and
Wildlife
Management Bill of
2008
Aims to provide a regulatory framework for the
protection, conservation, and rehabilitation of
species and ecosystems, the sustainable use
and sustainable management of indigenous
biological resources, and the management of
protected areas, to conserve biodiversity and
to contribute to national development.
Minerals
(Prospecting and
Mining) Act (No. 33
of 1992)
Section 52 requires mineral license holders to
enter into a written agreement with affected
landowners before exercising rights conferred
upon the license holder.
Section 52(1) mineral licence holder may not
exercise his/her rights in any town or village,
on or in a proclaimed road, land utilised for
cultivation, within 100m of any water resource
(borehole, dam, spring, drinking trough etc.)
and boreholes, or no operations in municipal
areas, etc.), which should individually be
checked to ensure compliance.
Section 54 requires written notice to be
submitted to the Mining Commissioner if the
holder of a mineral license intends to abandon
the mineral license area.
Section 68 stipulates that an application for
Mining Claims (MCs) shall contain the
particulars of the condition of, and any existing
damage to, the environment in the area to
which the application relates and an estimate
of the effect which the proposed prospecting
operations may have on the environment and
the proposed steps to be taken to prevent or
minimize any such effect.
The Proponent should enter into
a written agreement with
landowners before carrying out
small-scale mining activities on
their land.
The Proponent should carry out
an assessment of the impact on
the receiving environment.
The Proponent should include
as part of their application for the
MCs, measures by which they
will rehabilitate the areas where
they intend to carry out mining
activities.
The Proponent may not carry
out small-scale mining activities
within the areas limited by
Section 52 (1) of this Act.
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Legislation/Policy/
Guideline
Relevant Provisions Implications for this project
Section 91 requires that rehabilitation
measures should be included in an application
for a mineral license.
Mine Health &
Safety Regulations,
10th Draft
Makes provision for the health and safety of
persons employed or otherwise present in
mineral licenses area. These deal with among
other matters; clothing and devices; design,
use, operation, supervision, and control of
machinery; fencing and guards; and safety
measures during repairs and maintenance.
The Proponent should comply
with all these regulations with
respect to their employees.
Petroleum Products
and Energy Act (No.
13 of 1990)
Regulations (2001)
Regulation 3(2)(b) states that “No person shall
possess [sic] or store any fuel except under
authority of a licence or a certificate, excluding
a person who possesses or stores such fuel in
a quantity of 600 litres or less in any container
kept at a place outside a local authority area”
The Proponent should obtain
the necessary authorisation
from the MME for the storage of
fuel on-site.
The Regional
Councils Act (No.
22 of 1992)
This Act sets out the conditions under which
Regional Councils must be elected and
administer each delineated region. From a
land use and project planning point of view,
their duties include, as described in section 28
“to undertake the planning of the development
of the region for which it has been established
with a view to physical, social and economic
characteristics, urbanisation patterns, natural
resources, economic development potential,
infrastructure, land utilisation pattern and
sensitivity of the natural environment.
The relevant Regional Councils
are I&APs and must be
consulted during the
Environmental Assessment
(EA) process. The project site
falls under the Kunene Regional
Council; therefore, they should
be consulted.
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Legislation/Policy/
Guideline
Relevant Provisions Implications for this project
Local Authorities
Act No. 23 of 1992
To provide for the determination, for purposes
of local government, of local authority councils;
the establishment of such local authority
councils; and to define the powers, duties and
functions of local authority councils; and to
provide for incidental matters.
The Khorixas Town Council is
the responsible Local Authority
of the area therefore they should
be consulted.
Water Act 54 of
1956
The Water Resources Management Act 11 of
2013 is presently without regulations;
therefore, the Water Act No 54 of 1956 is still
in force:
Prohibits the pollution of water and implements
the principle that a person disposing of effluent
or waste has a duly of care to prevent pollution
(S3 (k)).
Provides for control and protection of
groundwater (S66 (1), (d (ii)).
Liability of clean-up costs after
closure/abandonment of an activity (S3 (l)). (l)).
The protection (both quality and
quantity/abstraction) of water
resources should be a priority.
Water Resources
Management Act
(No 11 of 2013)
The Act provides for the management,
protection, development, use and
conservation of water resources; and provides
for the regulation and monitoring of water
services and to provide for incidental matters.
The objects of this Act are to:
Ensure that the water resources of Namibia
are managed, developed, used, conserved,
and protected in a manner consistent with, or
conducive to, the fundamental principles set
out in Section 66 - protection of aquifers,
Subsection 1 (d) (iii) provide for preventing the
contamination of the aquifer and water
pollution control (Section 68).
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Legislation/Policy/
Guideline
Relevant Provisions Implications for this project
National Heritage
Act No. 27 of 2004
To provide for the protection and conservation
of places and objects of heritage significance
and the registration of such places and objects;
to establish a National Heritage Council; to
establish a National Heritage Register; and to
provide for incidental matters.
The Proponent should ensure
compliance with these Acts
requirements. The necessary
management measures and
related permitting requirements
must be taken. This done by the
consulting with the National
Heritage Council of Namibia. The National
Monuments Act
(No. 28 of 1969)
The Act enables the proclamation of national
monuments and protects archaeological sites.
Soil Conservation
Act (No 76 of 1969)
The Act makes provision for the prevention
and control of soil erosion and the protection,
improvement and conservation of soil,
vegetation and water supply sources and
resources, through directives declared by the
Minister.
Duty of care must be applied to
soil conservation and
management measures must be
included in the EMP.
Public Health Act
(No. 36 of 1919)
Section 119 states that “no person shall cause
a nuisance or shall suffer to exist on any land
or premises owned or occupied by him or of
which he is in charge any nuisance or other
condition liable to be injurious or dangerous to
health.”
The Proponent and all its
employees should ensure
compliance with the provisions
of these legal instruments.
Health and Safety
Regulations GN
156/1997 (GG
1617)
Details various requirements regarding health
and safety of labourers.
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Legislation/Policy/
Guideline
Relevant Provisions Implications for this project
Road Traffic and
Transport Act, No.
22 of
1999
The Act provides for the establishment of the
Transportation Commission of Namibia; for the
control of traffic on public roads, the licensing
of drivers, the registration and licensing of
vehicles, the control and regulation of road
transport across Namibia's borders; and for
matters incidental thereto. Should the
Proponent wish to undertake activities
involving road transportation or access onto
existing roads, the relevant permits will be
required.
Mitigation measures should be
provided for, if the roads and
traffic impact cannot be avoided,
the relevant permits must be
applied for.
Labour Act (No. 6 of
1992)
Ministry of Labour (MOL) is aimed at ensuring
harmonious labour relations through
promoting social justice, occupational health
and safety and enhanced labour market
services for the benefit of all Namibians. This
ministry insures effective implementation of the
Labour Act no. 6 of 1992.
The Proponent should ensure
that the prospecting and small-
scale mining activities do not
compromise the safety and
welfare of workers.
4.3 International Policies, Principles, Standards, Treaties and Conventions The international policies, principles, standards, treaties, and conventions applicable to the project
are as listed in Table 2 below.
Table 2: International Policies, Principles, Standards, Treaties and Convention applicable to the project
STATUTE PROVISIONS PROJECT IMPLICATIONS
Equator Principles
A financial industry
benchmark for
determining, assessing,
and managing
environmental and social
The Principles apply to all new project
financings globally across all sectors.
Principle 1: Review and Categorization
Principle 2: Environmental and Social
Assessment
Principle 3: Applicable Environmental and
Social Standards
These principles are an
attempt to: ‘…encourage the
development of socially
responsible projects, which
subscribe to appropriately
responsible environmental
management practices with
a minimum negative impact
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STATUTE PROVISIONS PROJECT IMPLICATIONS
risk in projects (August
2013). The Equator
Principles have been
developed in conjunction
with the International
Finance Corporation
(IFC), to establish an
International Standard
with which companies
must comply with to
apply for approved
funding by Equator
Principles Financial
Institutions (EPFIs).
Principle 4: Environmental and Social
Management System and Equator Principles
Action Plan
Principle 5: Stakeholder Engagement
Principle 6: Grievance Mechanism
Principle 7: Independent Review
Principle 8: Covenants
Principle 9: Independent Monitoring and
Reporting
Principle 10: Reporting and Transparency
on project-affected
ecosystems and
community-based
upliftment and empowering
interactions.’
The International Finance
Corporation (IFC)
Performance Standards
The International Finance Corporation’s
(IFC) Sustainability Framework articulates
the Corporation’s strategic commitment to
sustainable development and is an integral
part of IFC’s approach to risk management.
The Sustainability Framework comprises
IFC’s Policy and Performance Standards on
Environmental and Social Sustainability, and
IFC’s Access to Information Policy. The
Policy on Environmental and Social
Sustainability describes IFC’s commitments,
roles, and responsibilities related to
environmental and social sustainability.
As of 28 October 2018, there are ten (10)
Performance Standards (Performance
Standards on Environmental and Social
Sustainability) that the IFC requires a project
Proponents to meet throughout the life of an
investment. These standard requirements
are briefly described below.
The Performance Standards
are directed towards clients,
providing guidance on how
to identify risks and impacts,
and are designed to help
avoid, mitigate, and manage
risks and impacts as a way
of doing business in a
sustainable way, including
stakeholder engagement
and disclosure obligations of
the Client (Borrower) in
relation to project-level
activities. In the case of its
direct investments
(including project and
corporate finance provided
through financial
intermediaries), IFC
requires its clients to apply
the Performance Standards
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STATUTE PROVISIONS PROJECT IMPLICATIONS
Performance Standard 1: Assessment and
Management of Environmental and Social
Risks and Impacts
Performance Standard 2: Labour and
Working Conditions
Performance Standard 3: Resource
Efficient and Pollution Prevention and
Management
Performance Standard 4: Community
Health and Safety
Performance Standard 5: Land Acquisition,
Restrictions on Land Use, and Involuntary
Resettlement
Performance Standard 6: Biodiversity
Conservation and Sustainable Management
of Living Natural Resources
Performance Standard 7: Indigenous
Peoples/Sub-Saharan African Historically
Undeserved Traditional Local Communities
Performance Standard 8: Cultural Heritage
Performance Standard 9: Financial
Intermediaries (FIs)
Performance Standard 10: Stakeholder
Engagement and Information
A full description of the IFC Standards can be
obtained from
http://www.worldbank.org/en/projects-
operations/environmental-and-social-
framework/brief/environmental-and-social-
standards?cq_ck=1522164538151#ess1
to manage environmental
and social risks and impacts
so that development
opportunities are enhanced.
IFC uses the Sustainability
Framework along with other
strategies, policies, and
initiatives to direct the
business activities of the
Corporation to achieve its
overall development
objectives.
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STATUTE PROVISIONS PROJECT IMPLICATIONS
The United Nations
Convention to Combat
Desertification (UNCCD)
1992
Addresses land degradation in arid regions
with the purpose to contribute to the
conservation and sustainable use of
biodiversity and the mitigation of climate
change.
The convention objective is to forge a global
partnership to reverse and prevent
desertification/land degradation and to
mitigate the effects of drought in affected
areas to support poverty reduction and
environmental sustainability.
The project activities should
not be such that they
contribute to desertification.
Convention on Biological
Diversity 1992
Regulate or manage biological resources
important for the conservation of biological
diversity whether within or outside protected
areas, with a view to ensuring their
conservation and sustainable use.
Promote the protection of ecosystems,
natural habitats, and the maintenance of
viable populations of species in natural
surroundings.
Removal of vegetation
cover and destruction of
natural habitats should be
avoided and where not
possible minimised.
Stockholm Declaration on
the Human
Environment, Stockholm
(1972)
It recognizes the need for: “a common
outlook and common principles to inspire
and guide the people of the world in the
preservation and enhancement of the human
environment.
Protection of natural
resources and prevention of
any form of pollution.
Relevant international Treaties and Protocols ratified by the Namibian Government
Convention on International Trade and Endangered Species of Wild Fauna and Flora
(CITES), 1973.
Convention on Biological Diversity, 1992.
World Heritage Convention, 1972.
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5 ENVIRONMENTAL BASELINE
The proposed small-scale mining programme will be undertaken in specific environmental and
social conditions. Understanding the pre-project conditions of the environment will aid in laying
down background information of the status quo and allow future projections of environmental
conditions after proposed works on the MCs. This also helps the EAP in identifying the sensitive
environmental features that may need to be protected through the recommendations and effective
implementation of mitigation measures provided. A summary of selected biophysical and social
baseline information about the prospecting area is given below.
The baseline information presented below is sourced from a variety of sources including reports
of studies conducted in the Kunene Region, as well as those done in the surrounding areas.
Further information was obtained by the Consultant during the site visit.
5.1 Climate
Climate play a crucial part in mining activities, as it has a major effect on the mining activity of the
MCs. Climatic conditions determine the appropriate and/or inappropriate times to conduct
operational activities on the MCs.
5.1.1 Rainfall
The highest amount of rainfall in the Khorixas area is usually experienced in February which may
reach an average of approximately 150 mm. Little to no rainfall periods are recorded from May to
September with an average of 0 – 3 mm as indicated in Figure 3.
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Figure 3: A graph showing average rainfall patterns for the project (Source: https://en.climate-data.org/).
5.1.2 Temperature Khorixas has distinct temperature seasons and the temperature varies during the year. The month
of October is the warmest with an average temperature of 30 oC at noon. July is the coldest month
with an average temperature of 8 – 10 oC at night. Figure 4.
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Figure 4: A graph showing average temperature patterns (Source: https://en.climate-data.org/).
5.1.3 Winds Primarily, south easterly, southerly, easterly and northerly airflows are common in Khorixas area.
The Khorixas area is subject to erratic winds and considerable discrepancies in spite of short
distance due the varying terrains. The graph below depicts the wind patterns in the area. The
highest wind speeds are attained in October as shown in Figure 5.
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Figure 5: A graph showing average wind speed (Source: https://en.climate-data.org/).
Figure 6 below shows the wind rose and concurrently the wind power density around the project
area.
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Figure 6: Wind frequency Rose and Wind power density graph for the project area (source: https://globalwindatlas.info/)
5.1.4 Relative Humidity The relative humidity during the least humid months of the year, i.e. September, is around 20%
and the most humid month is February with about 45% humidity. Namibia has a low humidity in
general, and the lack of moisture in the air has a major impact on its climate by reducing cloud
cover and rain increases the rate of evaporation (Mendelsohn, 2002). Figure 7 depicts the
humidity patterns in the Khorixas area.
Figure 7: A graph showing average humidity patterns (Source: https://en.climate-data.org/).
5.2 Topography
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The MCs No. 72051 - 72060 located within the Central-western Plains which is characterized as
an area of dissection and erosional cutbacks (Mendelsohn, 2003). The MCs lie in an elevation
range between 2, 300 m and 2, 600 m above mean sea level (AMSL). These figures were
obtained from a DTM along a cross-section line that cuts through the project area from northwest
to southeast direction. Figures 8a, 8b, and 8c below show the landscape map, Elevation Model,
and the Section graph, respectively.
(a)
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37 David Simon Lamberth: MCs No. 72051 - 72060
(b)
(c)
Figure 8: (8a) The landscape map, (9b) Elevation 3D Model and (9c) a section graph for the project area
5.3 Geology and Soil
Geology
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38 David Simon Lamberth: MCs No. 72051 - 72060
The MCs area are underlain by the Palaeoproterozoic metamorphic rock of the Huab
Metamorphic Complex, which outcrop as an inlier of the Congo Craton surrounded by stratified
rocks of the Damara Orogen. The metamorphic basement was intruded at ca 750 Ma by alkaline
silicate rocks and carbonatites of the Lofdal Carbonatite complex. The complex comprises an
early silicate intrusive assemblage ranging from soviet through dolomitic and ankeritie
carbonatitie. The entire complex comprises a central intrusive core characterized by a number of
plugs of nepheline syenite and Carbonatite with associated hydrothermal alteration, in which
phonolite and Carbonatite dykes related to the intrusive plugs have exploited pre-existing
structures in the basement that were re-activated during Neoproterozoic tectonism. Furthermore,
these carbonatite dykes are widely mineralized with rare earth elements. These carbonatite dykes
are widely mineralized with rare earth elements. The total area affected by carbonatitic dykes and
associated alteration and mineralization is more than 200 km2 (Miller, 2008). The general
geological map for the site is shown in Figure 9 and Figure 10 shows the rock types found within
the MCs.
Figure 9: General geology map for the MCs
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39 David Simon Lamberth: MCs No. 72051 - 72060
Figure 10: Rock types found within the MCs with presence of copper (Photo: David, 2021)
Soil:
The MCs are covered by the Leptosols which form in an actively eroding landscape, especially in
the hilly or undulating areas like the one around the MCs. These soils are characterised by their
limited depth caused by the presence of a continuous hard-rock, highly calcareous or cemented
layer within 30 cm of the surface. The Leptosols are, therefore, the shallowest soils to be found
around the MCs and they often contain a lot of gravel. As a result, their water-holding capacity is
low, and vegetation in areas in which they occur is often subject to drought. The rate of water run-
off and water erosion can be high when heavy rains falls (Mendelsohn, 2003). Figures 11 and
12 show the dominant soil within the project area.
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40 David Simon Lamberth: MCs No. 72051 - 72060
Figure 11: The dominant soil types found within the MCs.
Figure 12: The Lithic Leptosols dominant soil found within the project area (Photo: David, 2021).
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41 David Simon Lamberth: MCs No. 72051 - 72060
5.4 Hydrogeology and Water Resources
Hydrogeology
The MCs lie within the moderately productive but variable (porous and fractured) aquifer, there
are no river streams that run through the MCs. Figure 13 shows the Hydrology map of the project
area.
Figure 13: The hydrology map of MCs 72051 - 72060
MCs are in an area prone to a moderate groundwater drought risks. Figure 14 below shows the
maps of areas at risk to groundwater drought within the project area.
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42 David Simon Lamberth: MCs No. 72051 - 72060
Figure 14: Groundwater Drought Risk map around the project area.
Groundwater availability
The MCs are found in a hydrogeological setting that can be described as an aquitard, aquiclude
aquifer (Christelis & Struckmeier, 2001). This aquifer type is generally considered very
unproductive and deep. The groundwater potential of this rock unit is generally low, to locally
moderate; it improves as one goes further east, in the direction of increasing precipitation. Other
thick groundwater calcrete deposits in the Khorixas area, known as the Ugab terraces, are drained
by the Ugab River itself and contain little groundwater. Mudstones and shales of the Chuos
Formation are found between the Otavi Group dolomites. The groundwater potential of this unit
is very limited but the dolomite in contact with the Chuos is karstified at the contact plains and
provides high-yielding boreholes.
Groundwater quality and Vulnerability
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43 David Simon Lamberth: MCs No. 72051 - 72060
Groundwater in most parts of the Khorixas area is expected to be saline and the depth to water
table at the site is expected to be not less than 2m below surface (Christelis & Struckmeier, 2001).
The groundwater vulnerability of the area covered by MCs is not studied in detail. However, to
protect the aquifer against pollution it is essential to constrain mining works, effluent discharge
and waste disposal practices. In practice it is also necessary to define groundwater protection
strategies which accept trade-offs between competing interests. Thus, instead of applying
universal controls over planned mining work and effluent discharge, it is more cost-effective to
utilize the natural contaminant attenuation capacity of the strata overlying the aquifer, when
defining the level of control required to protect groundwater quality (Christelis et al., 2016).
Aquifer pollution vulnerability mapping over more extensive areas is required before
commencement of the mining project to provide the general information needed for planning
purposes. This will be performed before mining commences if an economic discovery is made.
Such mapping will be followed by an inventory of subsurface contaminant load at a more detailed
scale, at least within the more vulnerable areas.
5.5 Terrestrial Biodiversity: Flora and Fauna
Flora
In terms of important plant species, the MCs are covered by the Colophespemum mopane also
commonly known as the mopane tree. Colophospermum mopane is a small to medium-sized
deciduous, spineless tree, often with a thin, V-shaped crown; it usually grows from 4 - 18 metres
tall but exceptionally can reach up to 30 metres. The tree produces one or more straight boles
that can be 50 - 100cm in diameter. When growing in drier areas, the plant is more shrub-like,
with more branches. A useful multi-purpose tree, it is often harvested from the wild for its medicinal
uses and also for a wide range of commodities. The tree is also used in soil stabilization projects
and is occasionally used as a source of food. Mopane is an important tree as an ecological
dominant and fodder plant for many animals, particularly elephants. The pendulous leaves fold
their single pair of leaflets together in hot sun and afford little shade, the large tracts of woodland
being infamous for their monotony and lack of shade. (Ken, 2021). Figure 15 below shows tree
species around the MCs and Figure 16 shows the picture of the tree species found within and
around the MCs from the site walk-over.
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44 David Simon Lamberth: MCs No. 72051 - 72060
Figure 15: Vegetation map around the MCs
Figure 16: Pictures of Colophespemum Mopane plant species on the MCs area (Photo: David, 2021).
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45 David Simon Lamberth: MCs No. 72051 - 72060
Fauna
The MCs area is mainly dominated by Dorper sheep and cattle, the number of Dorper sheep
within the MCs area per square kilometres lies in a range of 0 – 10; and number of cattle per
square kilometres lies in a range between 1 and 10. In addition, some of the animals that can be
found in the project area also include the kudu, springbok, horses and domestic pigs. Figure 17
below shows maps of the density of dominant fauna around the MCs area and Figure 18, shows
animal evident and pictures acquired during site visit on the 24th August 2021.
Figure 17: Maps of fauna density around the project area.
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46 David Simon Lamberth: MCs No. 72051 - 72060
5.6 Heritage and Archaeology
Figure 18: Animals evidence around the Braunfels farm and within the MCs (Photo: David, 2021).
Archaeology
There are some known nationally or locally recognized archaeological sites recorded within the
MCs area. The area surrounding the project sites has evidence of lithic artefacts. In the event of
an archaeological discovery during the small-scale mining works, the procedures outlined in the
National Heritage Act, No. 27 of 2004 are to be followed. Section 55 (4) of the National Heritage
Act, No. 27 of 2004, requires that any archaeological or paleontological object or meteorite
discovered are reported to the National Heritage Council as soon as practicable. Figure 19 shows
the sites identified with archaeological lithic artefacts within and around the MCs, and the pictures
Pigs
Wild animal dug
Wild animal tracks
horse
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47 David Simon Lamberth: MCs No. 72051 - 72060
in Figure 20 show archaeological rock tools (lithic artefacts) observed during the site visit on the
24th August 2021. Archaeology report for the MCs is attached in Appendix J.
Figure 19: Sites of Lithic artifacts around and within the MCs.
5.7 Surrounding Land Uses
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48 David Simon Lamberth: MCs No. 72051 - 72060
Figure 20: Shows archaeological lithic artifacts captured during the site visits around and within the MCs (Photo: David,2021).
Land use
The MCs falls within 100% of farmland as shown in Figure 21. The Proponent is required to
secure signed agreements with the affected farm/land owners, to gain access to the areas of
interest for prospecting and small-scale mining investigations as per Section 52 of the Minerals
(Prospecting and Mining) Act No. 33 of 1992 and Section 2.2.3 of the Minerals Policy of Namibia.
1. Section 52 (1) The holder of mineral licence shall not exercise any rights conferred upon
such holder by this Act or under any terms and conditions of such mineral licence –
(a) In, on or under any and until such time as such holder has entered into an
agreement in writing with the owner of such land containing terms and conditions
relating to the payment of compensation, or the owner of such land has in writing
waked any right to such compensation and has submitted a copy of such agreement
or waiver to the Commissioner.
Section 2.2.3 of the Draft Minerals Policy of Namibia states that the Licence Holder and/or
mineral explorers currently must negotiate a contract with landowners to gain access for or
mining purposes.
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49 David Simon Lamberth: MCs No. 72051 - 72060
Figure 21: Land use (farms) within and surrounding the MCs (source: https://maps.landfolio.com/Namibia/)
5.8 Socio-Economic Status
Demography
According to statistics of the last national census conducted in 2011, the population of Kunene
Region is 86, 856. (Namibia Statistics Agency, 2011). Figure 22 below shows the population
structure of the Kunene Region.
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50 David Simon Lamberth: MCs No. 72051 - 72060
Figure 22: The population structure of the region covered by the MCs (Source: Namibia Statistic Agency website).
Tourism
Generally, Kunene's rugged landscape and ancient traditional diversity and practices make
tourism a key economic sector for the region. The region offers geo-tourism, eco-tourism and
adventure tourism. 46% of the nation's conservancies are in the Kunene Region, hosting wildlife
such as desert elephants, rhinos, lions and giraffes. Kunene is home to some of the most stunning
tourism sites in Namibia. A number of attractions to be found in the region include the Petrified
Forest, the Epupa Falls, the Skeleton Coast and the Swartbooi Graves. The Hartmann's &
Maneuflus valleys, Steep van Zyl's pass, Hoarusib & Hoanib Rivers, and Sesfontein are some of
the land marks in the Kunene Region. The culture, numerous wild animals, conservancies and
national parks make the region an investor's dream (Kunene Regional Council, 2019). There are
few tourism facilities surrounding the MCs, the only tourism facility in the vicinity of the project
area is the Vingerklip lodge. Figure 23 shows the tourism accommodation around the project
area
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51 David Simon Lamberth: MCs No. 72051 - 72060
Figure 23: Tourism accommodation found around the MCs area (Source: https://digitalnamibia.nsa.org.na/)
Mining
Mining operations are highly held activities in the Kunene Region and provides livelihood to
several the region’s residents. There are already existing active mining licenses around the
vicinity of the MCs. Figure 24 below shows active mining licenses around the vicinity of the
project area.
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52 David Simon Lamberth: MCs No. 72051 - 72060
Figure 24: Mines found around the vicinity of the project area (Source: https://digitalnamibia.nsa.org.na/)
Infrastructure and Services
The vicinity of the project area has basic infrastructures which are necessary for transportation
(i.e., national road), and covers satisfactory telecommunication coverages (i.e.,3G Universal
Mobile Telecommunication System (UMTS) and 2G Global System for Mobile Communication
(GSM)). Among many other infrastructures are schools, police station and clinics around the
vicinity of the project area. Figure 25 below shows some of the infrastructure and services found
around the project area.
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53 David Simon Lamberth: MCs No. 72051 - 72060
Figure 25: Services and Infrastructures found around the project area (Source: https://digitalnamibia.nsa.org.na/)
Farming
Farming around the MCs mainly consists of livestock farming. The MCs area is dominated by
livestock that range between 1 – 19 per square kilometers. Figure 26 below shows a livestock
density map.
Figure 26: Livestock map around the project area (Source: https://digitalnamibia.nsa.org.na/ )
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54 David Simon Lamberth: MCs No. 72051 - 72060
6 PUBLIC CONSULTATION PROCESS
Public consultation forms an important component of an Environmental Assessment (EA)
process. It provides potential Interested and Affected Parties (I&APs) with an opportunity to
comment on and raise any issues related to the project for consideration as part of the
assessment process. The public consultation process assists the Environmental Assessment
Practitioner (EAP) in identifying all potential impacts and to what extent further investigations are
necessary. Public consultation can also aid in the process of identifying possible mitigation
measures. Public consultation for this project has been done under the EMA and its EIA
Regulations.
6.1 Pre-identified and Registered Interested and Affected Parties (I&APs)
The Consultant identified relevant and applicable national, regional, and local authorities, local
leaders, and other interested members of the public. Pre-identified I&APs were contacted directly,
while other parties who contacted the Consultant after project advertisement notices in the
newspapers, were registered as I&APs upon their request. Newspaper advertisements of the
proposed mining activities were placed in two widely read national newspapers in the region (The
Namibian Newspaper and New Era Newspaper). The project advertisement/announcement ran
for two consecutive weeks inviting members of the public to register as I&APs and submit their
comments and concerns. The summary of pre-identified and registered I&APs is listed in Table
3 below and the complete list of I&APs is provided in Appendix D.
Table 3: Summary of Interested and Affected Parties (I&APs)
National (Ministries and State-Owned Enterprises)
Ministry of Environment, Forestry and Tourism
Ministry of Mines and Energy
Ministry of Health and Social Services
Ministry of Agriculture, Water and Land Reform
Regional, Local and Traditional Authorities
Kunene Regional Council
Khorixas Constituency
Braunfels Association
!Khoro-Goreb Conservancy
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/Gaio Daman Traditional Authority
General Public
Interested members of the public & landowners
Farm owners
Namibia Community Based Tourism Association
Members of the Braunfels Community (farmers, residents, and others)
6.2 Communication with I&APs
Regulation 21 of the EIA Regulations details the steps to be taken during a public consultation
process and these have been used in guiding this process. Communication with I&APs with
regards to the proposed development was facilitated through the following means and in this
order:
A Background Information Document (BID) containing brief information about the
proposed facility was compiled (Appendix E) and hand delivered to relevant Authoritative
Ministries, and upon request to all new registered Interested and Affected parties (I&APs);
Project Environmental Assessment notices were published in The Namibian newspaper
(23 June 2021 and 30 June 2021) and New Era (23 June 2021 and 30 June 2021)
(Appendix F), briefly explaining the activity and its locality, inviting members of the public
to register as I&APs and submit their comments/concerns.
Public notices were placed in Khorixas (Figure 27) to inform members of the public of the
EIA process and register as I&APs, as well as submit comments.
A public meeting was scheduled and held on 24 August 2021 at the project site at 11:30
(actual starting time was 13h30 due to mechanical issues). Some photos taken during the
public meeting are shown in Figure 28.
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56 David Simon Lamberth: MCs No. 72051 - 72060
Figure 27: Public notices placed at Braunfels Agricultural school and at the C39 road from Khorixas to the MCs area.
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57 David Simon Lamberth: MCs No. 72051 - 72060
Figure 28: Public meeting held on the 24th of August 2021 (Photo: Roland,2021)
Issues that were raised by the I&APs were recorded and incorporated in the environmental report
and EMP. The issues raised during the public meeting are summarized and presented in Table
4 below. The meeting minutes by EDS are attached under Appendix G.
Table 4: Summary of main issues and comments received during the public meeting engagements
Issues Concerns
Provision of assistance to the community When the project activities start in the area,
would the Proponent offer things like
transportation to the community members in
need
Provision of service to the community Will the Proponent assist the community with
services like power, water, roads, when the
mining operations starts
Impact of pollution There is vegetation and river running below the
mountain hosting the mining claims. Will they not
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be affected by potential chemicals from the
project operations?
Impact of fauna (wildlife) There is wildlife around and or within the mining
claims. Will these animals be relocated?
Unequal/unfair distribution of opportunities in
the community
The community usually welcomes
developments but when these take off, the local
leaders always choose their preferred people.
Community benefits The community will need to see development
and that they also benefit from the resources.
Health and Safety concerns If for instance there is reckless activities done on
the mining claims and the debris from explosives
hurt someone on the farms.
7 IMPACT IDENTIFICATION, ASSESSMENT AND MITIGATION
MEASURES
7.1 Impact Identification
Proposed developments/activities are usually associated with different potential positive and/or
negative impacts. For an environmental assessment, although positive impacts are
acknowledged, the focus is placed mainly on the negative impacts. This is done to ensure that
these impacts are addressed by providing adequate mitigation measures such that an impact’s
significance is brought under control, while maximizing the positive impacts of the development.
The potential positive and negative impacts that have been identified for the proposed prospecting
activities are listed as follow:
Positive impacts:
Potential for creation of temporary employment for locals, especially the non-skilled
labourers.
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Boost to local and regional economic development, i.e., economic diversification.
May activate other investment opportunities in the Regions.
Contribution to regional economic development.
Negative impacts:
Existing pastoral systems may be disturbed.
Land degradation and Biodiversity Loss.
Air Pollution
Generation of waste
Visual impacts (scars) on landscape
Potential occupational health and safety risks
Possible disturbance to heritage/archaeological resources
Vibrations and noise from operational works
Impacts associate with closure and decommissioning of mining works.
7.2 Impact Assessment Methodology
The Environmental Assessment is primarily a process used to ensure that potential impacts that
may occur from project activity are identified and addressed with environmentally cautious
approaches and legal compliance. The impact assessment method used for this project is in
accordance with Namibia’s Environmental Management Legislation (Environmental Management
Act No. 7 of 2007) and its Regulations of 2012, as well as the International Finance Corporation
(IFC) Performance Standards.
The identified impacts were assessed in terms of probability (likelihood of occurring), scale/extent
(spatial scale), magnitude (severity) and duration (temporal scale) as presented in Table 5, Table
6, Table 7 and Table 8.
In order to enable a scientific approach to the determination of the environmental significance, a
numerical value is linked to each rating scale. This methodology ensures uniformity and that
potential impacts can be addressed in a standard manner so that a wide range of impacts are
comparable. It is assumed that an assessment of the significance of a potential impact is a good
indicator of the risk associated with such an impact. The following process will be applied to each
potential impact:
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Provision of a brief explanation of the impact.
Assessment of the pre-mitigation significance of the impact; and
Description of recommended mitigation measures.
The recommended mitigation measures prescribed for each of the potential impacts contribute
towards the attainment of environmentally sustainable operational conditions of the project for
various features of the biophysical and social environment. The following criteria were applied in
this impact assessment:
7.2.1 Extent (spatial scale)
Extent is an indication of the physical and spatial scale of the impact. Table 5 shows rating of
impact in terms of extent of spatial scale.
Table 5: Extent or spatial impact rating
Low (1) Low/Medium (2) Medium (3) Medium/High (4) High (5)
Impact is localized
within the site
boundary: Site only
Impact is beyond
the site boundary:
Local
Impacts felt within
adjacent
biophysical and
social
environments:
Regional
Impact widespread
far beyond site
boundary: Regional
Impact extend
National or over
international
boundaries
7.2.2 Duration
Duration refers to the timeframe over which the impact is expected to occur, measured in
relation to the lifetime of the project. Table 6 shows the rating of impact in terms of duration.
Table 6: Duration impact rating
Low (1) Low/Medium (2) Medium (3) Medium/High (4) High (5)
Immediate
mitigating
measures,
immediate
progress
Impact is quickly
reversible, short
term impacts (0-5
years)
Reversible over
time; medium term
(5-15 years)
Impact is long-term Long term; beyond
closure;
permanent;
irreplaceable or
irretrievable
commitment of
resources
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7.2.3 Intensity, Magnitude / severity
Intensity refers to the degree or magnitude to which the impact alters the functioning of an element
of the environment. The magnitude of alteration can either be positive or negative. These ratings
were also taken into consideration during the assessment of severity. Table 7 shows the rating
of impact in terms of intensity, magnitude or severity.
Table 7: Intensity, magnitude or severity impact rating
Type of
criteria
Negative
H-
(10)
M/H-
(8)
M-
(6)
M/L-
(4)
L-
(2)
Qualitative Very high
deterioration,
high quantity
of deaths,
injury of illness
/ total loss of
habitat, total
alteration of
ecological
processes,
extinction of
rare species
Substantial
deterioration,
death, illness
or injury, loss of
habitat /
diversity or
resource,
severe
alteration or
disturbance of
important
processes
Moderate
deterioration,
discomfort,
partial loss of
habitat /
biodiversity or
resource,
moderate
alteration
Low
deterioration,
slight
noticeable
alteration in
habitat and
biodiversity.
Little loss in
species
numbers
Minor
deterioration,
nuisance or
irritation, minor
change in
species /
habitat /
diversity or
resource, no or
very little quality
deterioration.
7.2.4 Probability of occurrence
Probability describes the likelihood of the impacts actually occurring. This determination is based
on previous experience with similar projects and/or based on professional judgment. Table 8
shows impact rating in terms of probability of occurrence.
Table 8: Probability of occurrence impact rating
Low (1) Medium/Low (2) Medium (3) Medium/High (4) High (5)
Improbable; low
likelihood;
seldom. No
known risk or
vulnerability to
natural or
induced hazards.
Likely to occur
from time to time.
Low risk or
vulnerability to
natural or induced
hazards
Possible, distinct
possibility, frequent.
Low to medium risk
or vulnerability to
natural or induced
hazards.
Probable if
mitigating measures
are not
implemented.
Medium risk of
vulnerability to
natural or induced
hazards.
Definite (regardless
of preventative
measures), highly
likely, continuous.
High risk or
vulnerability to
natural or induced
hazards.
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7.2.5 Significance
Impact significance is determined through a synthesis of the above impact characteristics. The
significance of the impact “without mitigation” is the main determinant of the nature and degree of
mitigation required. As stated in the introduction to this section, for this assessment, the
significance of the impact without prescribed mitigation actions is measured.
Once the above factors (Table 5, Table 6, Table 7 and Table 8) have been ranked for each
potential impact, the impact significance of each is assessed using the following formula:
SIGNIFICANCE POINTS (SP) = (MAGNITUDE + DURATION + SCALE) X PROBABILITY
The maximum value per potential impact is 100 significance points (SP). Potential impacts were
rated as high, moderate or low significance, based on the following significance rating scale
(Table 9).
Table 9: Significance rating scale
Significance Environmental Significance Points Colour Code
High (positive) >60 H
Medium (positive) 30 to 60 M
Low (positive) <30 L
Neutral 0 N
Low (negative) >-30 L
Medium (negative) -30 to -60 M
High (negative) >-60 H
Positive (+) – Beneficial impact
Negative (-) – Deleterious/ adverse Impact
Neutral – Impacts are neither beneficial nor adverse.
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For an impact with a significance rating of high (-ve), mitigation measures are recommended to
reduce the impact to a medium (-ve) or low (-ve) significance rating, provided that the impact with
a medium significance rating can be sufficiently controlled with the recommended mitigation
measures. To maintain a low or medium significance rating, monitoring is recommended for a
period to enable the confirmation of the significance of the impact as low or medium and under
control.
The assessment of the operational phases is done for pre-mitigation and post-mitigation.
The risk/impact assessment is driven by three factors:
Source: The cause or source of the contamination.
Pathway: The route taken by the source to reach a given receptor
Receptor: A person, animal, plant, eco-system, property, or a controlled water source. If
contamination is to cause harm or impact, it must reach a receptor.
A pollutant linkage occurs when a source, pathway and receptor exist together. Mitigation
measures aim firstly, avoid risk and if the risk cannot be avoided, mitigation measures to minimize
the impact are recommended. Once mitigation measures have been applied, the identified risk
would reduce to lower significance (Booth, 2011).
The potential negative impacts stemming from the proposed activities of MCs are described,
assessed and mitigation measures provided thereof. Further mitigation measures in a form of
management action plans are provided in the Draft Environmental Management Plan.
7.3 Assessment of Potential Negative Impacts
The main potential negative impacts associated with the operation and maintenance phase of the
proposed project were identified and assessed below:
7.3.1 Disturbance to the Pastoral System
As an aspect of local culture, pastoral farming is vital. It serves as a livelihood for local
communities because they depend greatly on livestock farming for subsistence and commercial
purposes.
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The effect of small-scale mining works on the land may hinder animal husbandry in the area and
its surroundings. Mining works may disturb grazing pastures for local livestock, and if operational
methods occur over a wider spatial extent, the project area might experience loss of its pastoral
system over time. Losing grazing pastures for livestock minimizes the amounts of livestock and
overall farming activity in the area, and lead to loss of livelihoods and household level income.
Under the status quo, the impact can be considered of a low significance rating. With the
implementation of appropriate mitigation measures, the rating will be reduced to a lower
significance. The impact is assessed in Table 10 below.
Table 10: Assessment of the impacts of small-scale mining activities on the Pastoral system
Mitigations and recommendation to lower the possibility of disturbance and loss of the Pastoral system
Any unnecessary removal or destruction of grazing land, due to Small-scale mining
activities should be avoided.
Vegetation found on the site, but not in the targeted MCs areas should not be removed
but left to preserve biodiversity and grazing land.
Workers should refrain from driving off road and creating unnecessary tracks that may
contribute to soil erosion and loss of grazing land.
Environmental awareness on the importance of the preservation of grazing land for local
livestock should be provided to the workers.
7.3.2 Land Degradation and Loss of Biodiversity
Mining activities and earthworks done to uncover the mineral bearing rock units could result in
land degradation. This would lead to habitat loss for a diversity of flora and fauna ranging from
microorganisms to large animals and trees. Endemic species are most severely affected since
even the slightest disruption in their habitat can results in extinction or put them at high risk of
being wiped out. Under the status, the impact can be considered to be of a medium significance
rating. With the implementation of appropriate mitigation measures, the rating will be reduced to
a low significance rating. The impact is assessed in Table 11 below.
Mitigation
Status
Extent Duration Intensity Probability Significance
Pre
mitigation
L/M: -2 M: -2 M: -3 L/M: -2 L: -6
Post
mitigation
L: -1 L: -1 L/M: -2 L: -1 L: -4
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Table 11: Assessment of the impacts of small-scale mining activities on biodiversity
Mitigation
Status
Extent Duration Intensity Probability Significance
Pre
mitigation
M: -3 M: -3 M/L: -2 M/H: 4 M: -32
Post
mitigation
L/M: -2 L/M: -2 M/L: -2 L/M: 2 L: -12
Mitigations and recommendation to minimize the loss of biodiversity
Plant species found on the site, but not in the targeted areas should not be removed but
left to preserve biodiversity on the site.
Protected plant species such as the mopane tree should not be removed on the site.
Shrubs or trees found along mining spots on sites should not be unnecessarily removed.
Care should be taken when extracting mineral species without destroying the vegetation.
Workers should refrain from killing or snaring animals’ species (big or small) that may be
found on the site.
Environmental awareness on the importance of biodiversity preservation should be
provided to the workers.
7.3.3 Air Quality
Dust, fumes, and gases emanating from vehicles transporting operational equipment and supplies
(such as water) to and from site (time-to-time) may compromise the air quality in the area.
Vehicular movements create dust even though it is not always so severe. The hot and dry
environment, loose and in some places, sandy nature of the substrate and relatively low
vegetation cover causes ambient fugitive dust levels. Additionally, mining activities carried out as
part of the operations would contribute to the dust levels in the air. The medium significance of
this impact can be reduced to a low significance rating by properly implementing mitigation
measures. The impact is assessed in Table 12 below.
Table 12: Assessment of the impacts of small-scale mining activities on air quality
Mitigation
Status
Extent Duration Intensity Probability Significance
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Pre
mitigation
L/M - 2 L/M - 2 L/M- 4 L/M - 2 M – 16
Post
mitigation
L - 1 L - 1 L- 2 L - 1 L - 4
Mitigations and recommendation to minimize air pollution
Mining vehicles should not drive at a speed more than 60 km/h to avoid dust generation
around the area.
The Proponent should ensure that the operational schedule is limited to the given number
of days of the week, and not every day. This will keep the vehicle-related dust level minimal
in the area.
Operational vehicles must not be left idling on site when not in use, in order to minimize
gas emissions. A reasonable amount of water should be used on gravel roads, using
regular water sprays on gravel routes and near MCs sites to suppress the dust that may
be emanating from certain mining activity on the MCs.
7.3.4 Waste Generation
During the operational phase, domestic and general waste is produced on site. If the generated
waste is not disposed of in a responsible way, land pollution may occur on the MCs or around the
sites. The MCs are in an area of moderate sensitivity to groundwater pollution. Improper handling,
storage, and disposal of hydrocarbon products on site may lead to soil and groundwater
contamination, in case of spills and leakages. Therefore, the operational programme needs to
have appropriate waste management for the site. To prevent these issues, biodegradable and
non-biodegradable wastes must be stored in separate containers and collected regularly for
disposal at a recognized landfill/dump site. Any hazardous waste that may have an impact on the
animals, vegetation, water resources and the general environment should be handled cautiously.
Without any mitigation measures, the general impact of waste generation has a medium
significance. The impact will reduce to low significance, upon implementing the mitigation
measures. The assessment of this impact is given in Table 13.
Table 13: Assessment of waste generation impact
Mitigation
Status
Extent Duration Intensity Probability Significance
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Pre
mitigation
L/M - 2 L/M - 2 M/L - 3 L/M - 2 M – 14
Post
mitigation
L - 1 L - 1 L - 2 L/M - 2 L - 8
Mitigations and recommendation to waste management
Workers should be sensitized to dispose of waste in a responsible manner and not litter.
After each daily works, the Site Manager or Safety Health and Environment Officer on site
should ensure that there is no waste left on site.
All domestic and general waste produced daily should be contained until such that time it
can be transported to designated waste sites.
No waste may be buried or burned on site or anywhere else.
The mining site should be equipped with separate waste bins for hazardous and
general/domestic waste.
Sewage waste should be stored as per the guidelines of the provided ablution facilities
and regularly disposed of at the nearest waste/wastewater treatment facility.
Oil spills should be taken care of by removing and treating soils affected by the spill.
A penalty system for irresponsible disposal of waste on site and anywhere in the area
should be implemented.
Careful storage and handling of hydrocarbons on site is essential.
Potential contaminants such as hydrocarbons and wastewater should be safely contained
on site and disposed of in accordance with municipal wastewater discharge standards, in
order to prevent contamination of surrounding soils and eventually groundwater.
An emergency plan should be available for major/minor spills at the site during operation
activities (with consideration of air, groundwater, soil, and surface water) and during the
transportation of the products(s) to the sites.
7.3.5 Visual Impact (Scars) on Landscape
Mining activities have the potential to cause aesthetic damage to the environment as they usually
leave scars on the local landscape. It is a vital to acknowledge that during prospecting phase,
certain measures will need to be taken into consideration regarding the visual aspect. Currently,
the visual impact can be rated as medium and can be reduced to low significance upon effectively
implementing the measures. The assessment of this impact is presented in Table 14.
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Table 14: Assessment of small-scale mining activities on the landscape
Extent Duration Intensity Probability Significance
Pre
mitigation
M/H - 4 M - 3 M - 6 M - 3 M – 39
Post
mitigation
L - 1 L - 1 M/L - 4 M/L -2 L - 12
Mitigations and recommendation to minimize visual impact
The Proponent should consider the implementation of continuous rehabilitation
programme, by using overburden waste rocks or soils to visually maintain the landscape’s
natural setting.
The Proponent should not create unnecessary routes or tracks, which lead to landscape
scarring on site.
7.3.6 Occupational Health and Safety Risks
As the number of global cases of the Corona Virus (Covid -19) continues to increase, the mining
activities are suspected to slow down to keep cases low. However, safety measures can be
implemented to allow such works to continue. Improper handling of operational materials and
equipment may also cause occupational health and safety risks such as injuries to workers. The
impact is probable and has a medium significance rating. However, with adequate mitigation
measures, the impact rating will be reduced to low. This impact is assessed in Table 15 below
and mitigation measures provided.
Table 15: Assessment of the impacts of Small-scale mining activities on health and safety
Mitigation
Status
Extent Duration Intensity Probability Significance
Pre
mitigation
M - 3 M - 3 M - 3 M/H - 4 M – 36
Post
mitigation
L/M - 2 L/M - 2 L - 2 L/M - 2 L - 12
Mitigations and recommendation to minimize health and safety issues
Workers should be tested before-hand for high fever and other Covid-19 symptoms prior
to commencement of operational activities.
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As part of their induction, the workers should be provided with an awareness training of
the risks of mishandling equipment and materials on site.
When working on site, employees should be properly equipped with personal protective
equipment (PPE) such as coveralls, masks, gloves, safety boots, earplugs, safety glasses,
and hard hats.
No employee should be allowed to consume alcohol or other intoxicants prior to and during
working hours as this may lead to mishandling of equipment which results into injuries and
other health and safety risks.
Employees should not be allowed on site if under the influence of alcohol or any other
intoxicants.
7.3.7 Disturbance to Heritage/Archaeological resources
During operations, historical resources may be impacted through inadvertent destruction or
damage. This may include the excavation of subsurface graves or other archaeological objects.
There was information provided about known heritage or site of significant cultural values within
the MCs or in the vicinity. Therefore, this impact can be rated as high significance because there
are known presence of archaeological items, however mitigation measures and management
actions are put in place to manage such cases. Upon implementation of the necessary measures,
the impact significance will be reduced to a much lower rating. The impact is assessed in Table
16.
Table 16: Assessment of the impacts of Small-scale mining activities on archaeological sites
Mitigation
Status
Extent Duration Intensity Probability Significance
Pre
mitigation
M - 3 M - 3 M/H - 8 M/H - 4 L – 56
Post
mitigation
L - 1 L- 1 M - 3 M/L -3 L - 15
Mitigations and recommendation to minimize impact on archaeological sites
Contractors working on the site should be made aware of items protected under the
National Heritage Act, 2004 (Act No. 27 of 2004).
Any items protected under the definition of heritage found during mining works should be
reported to the National Heritage Council.
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The Proponent should consider having a qualified archaeologist on standby/call during the
operational phase, to assist in the event of any archaeological discoveries.
Identified graves or any archaeological significant objects on the site should not be
disturbed but are to be reported to the project Environmental officer or National Heritage
Council.
Detailed field survey should be carried out if suspected archaeological resources or major
natural cavities/shelters have been unearthed during operations.
7.3.8 Noise and vibrations
Mining works may be a nuisance to surrounding communities due to the noise produced by the
activity. Excessive noise and vibrations can be a health risk to workers on site and to neighboring
farms. The operational equipment used on site is of medium size and the noise level is bound to
be limited to the site only, therefore, the impact likelihood is minimal. Without any mitigation, the
impact is rated as of medium significance. To change the impact significance from the pre-
mitigation significance to low rating, the mitigation measures should be implemented. This impact
is assessed in Table 17 below.
Table 17: Assessment of the impacts of noise from small-scale mining activities operation
Mitigation
Status
Extent Duration Intensity Probability Significance
Pre
mitigation
L/M - 2 L/M - 2 M - 6 M/H - 3 M – 30
Post
mitigation
L - 1 L/M - 2 L - 2 L/M -2 L - 10
Mitigations and recommendation to noise
Noise from operations’ vehicles and equipment on the sites should be kept at acceptable
levels.
The operational times should be set such that no mining activity is carried out during the
night or very early in the mornings.
Operational hours should be restricted to between 08h00 and 17h00 to avoid noise and
vibrations generated by operational equipment and the movement of vehicles before or
after hours.
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When operating any operational machinery onsite, workers should be equipped with
personal protective equipment (PPE) such as earplugs to reduce exposure to excessive
noise.
7.3.9 Impacts associated with closure and decommissioning of mining works
Identified impacts associated with the closure of the mining program include loss of employment
by workers, and missed opportunity for further contribution to the national economy (revenue and
royalties’ payments). Another concern that stems from mining program closure is the rehabilitation
of the sites.
Rehabilitation of the site is a vital step in completing the process of mining on the MCs. If no
rehabilitation is carried out after operations, the sites would experience detrimental effects. Any
biodiversity loss and land degradation experienced on the sites may not be restored and the
landscape will remain scarred. The impacts associated with rehabilitation are assessed in Table
18.
Table 18: Assessment of the impacts of closure and rehabilitation
Mitigation
Status
Extent Duration Intensity Probability Significance
Pre
mitigation
M - 3 M/H - 4 M- 6 M/H - 4 M – 52
Post
mitigation
L/M - 2 L/M - 2 L/M - 4 L/M - 2 L - 16
Mitigations and recommendation for rehabilitation
Revegetation of bare areas with species consistent with surrounding vegetation;
Necessary landscaping of mining areas will be undertaken upon completion and closure
of mining activity on the MCs.
Dismantling and removal of campsites and associated infrastructures from the project site
and area
Carrying away of operational equipment and vehicles
Clean up of site working areas and transporting the generated waste to the nearby
approved waste management facility (as per agreement with the facility operator/owner).
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Backfilling of pits and trenches in such a way that subsoil is replaced first, and topsoil
replaces last.
Levelling of stockpiled topsoil. This will be done to ensure that the disturbed land sites are
left close to their original state as much as possible.
7.3.10. Impact on Employment Opportunities and Economic Contribution
Should the MCs program come to an end, workers may lose their jobs and source of income. The
operational program has a defined timeframe, which the workers should be made aware of in
advance. Additionally, if no valuable commodities are discovered during operation, there will be
no further opportunities from this project to contribute to national level royalties and regional level
economic development, and there is no mitigation measure expected from the Proponents side
in this regard. This impact can be rated as of medium significance. The impact significance of
unemployment can be reduced from a medium to a low significance, by implementing mitigation
measures. The impact of loss of employment for the workers is assessed in Table 19 below.
Table 19: Assessment of the impacts of MCs activities closure on employment
Mitigation
Status
Extent Duration Intensity Probability Significance
Pre
mitigation
L/M - 2 M - 3 M - 6 M/H - 4 M – 44
Post
mitigation
L/M - 2 L/M - 2 L/M - 4 L/M - 2 L - 16
Mitigations and recommendation to minimize joblessness
The Proponent should inform the employees on time, of its intentions to cease the
operational works and the expected date of such closure. This will provide the employees
with enough time to search for work elsewhere.
The Proponent should raise awareness of the possibilities for work in a similar or another
industrial sector.
The Proponent should offer counselling to the employees who will be losing jobs.
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8 RECOMMENDATIONS AND CONCLUSIONS
8.1 Recommendations The key potential impacts associated with the proposed program and its associated activities on
MCs were identified and assessed. It is found that most of the identified potential negative impacts
are rated as medium significant. Therefore, to reduce the general significance of the project from
medium to low, it is recommended that the Proponent effectively implements the mitigation
measures, and continuously monitors their implementation, to maintain an overall low
significance. The negative impacts identified in this study can be avoided and minimised (where
impacts cannot be avoided) by implementing the mitigation measures given under section 7 of
this EA report, as well as those provided in the management action and monitoring plans provided
in the Draft EMP.
Excel Dynamic Solutions (Pty) Ltd is, therefore, confident that these measures are sufficient, and
thus recommends that the Proponent should be granted an ECC, to enable operational works on
the MCs.
8.2 Conclusion
The potential positive and negative impacts stemming from the proposed small-scale mining
activities were identified, assessed and mitigation measures made thereof. The mitigation
measures recommended in this report and management action plans provided in the draft EMP,
can be deemed sufficient to avoid and/or reduce (where impact avoidance impossible) the risks
to acceptable levels.
However, an approval should be granted on condition that the provided management measures
and action plans are effectively implemented and monitored on site. Monitoring of the
environmental components described in the impact assessment should be conducted by the
Proponent and applicable Competent Authority. This is to ensure that all potential impacts
identified in this study and other impacts that might arise during implementation are properly
identified in time and addressed. Lastly, should a written approval be issued, the Proponent will
be expected to be compliant with the conditions as well as legal requirements governing the
mining activities on the MCs and related activities.
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