Environmental Scoping Assessment (ESA) for the Proposed

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]

mailto:[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.


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.


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


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.


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


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


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:


Figure 25: Services and Infrastructures found around the project area (Source:


Figure 26: Livestock map around the project area (Source: https://digitalnamibia.nsa.org.na/ )

53


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)


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


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).


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).


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.


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



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



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



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



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.



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.



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.



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).



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.



Legislation/Policy/

Guideline


“…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



Legislation/Policy/

Guideline


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.



Legislation/Policy/

Guideline


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.



Legislation/Policy/

Guideline


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).



Legislation/Policy/

Guideline


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.



Legislation/Policy/

Guideline


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




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




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.

http://www.worldbank.org/en/projects-operations/environmental-and-social-framework/brief/environmental-and-social-standards?cq_ck=1522164538151#ess1







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.



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.



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.



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.



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.



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

https://globalwindatlas.info/



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)



(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



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



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.



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).



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.



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



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.



Figure 15: Vegetation map around the MCs

Figure 16: Pictures of Colophespemum Mopane plant species on the MCs area (Photo: David, 2021).



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.



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



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



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.



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.



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



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.



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.

https://digitalnamibia.nsa.org.na/



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/ )




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



/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.



Figure 27: Public notices placed at Braunfels Agricultural school and at the C39 road from Khorixas to the MCs area.



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



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.



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:



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



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.



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.



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.



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



Table 11: Assessment of the impacts of small-scale mining activities on biodiversity

Mitigation

Status


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




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




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.



Table 14: Assessment of small-scale mining activities on the landscape


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


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.



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


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.



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


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.



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


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).



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


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.



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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Documents

Environmental Scoping Assessment (ESA) for the Proposed