22
Please return this completed document (with all requested details) to: Name: Amy Coetzer Telephone: 081 344 1159 Organization: Private Fax: Designation: Cartographer Email: [email protected] Postal address/City: P.O. Box 3060, Swakopmund My interest in this project: I am currently busy with my BSC Information Systems and Geography Degree. My main subjects are Environmental Impact assessments and it will be interesting to follow the progress of this project. Comments and matters of concern: My concerns are if enough baseline studies & information are available to effectively determine what the final impact will be on the environment. But I understand that specialist studies will be conducted. I am also interested in the proposed and planned rehabilitation plan. Also I would like to see to what National and International standards, treaties and legislation this project will comply to. I would also like to see how this project will be different from the Saldhanna dredging project. I would also like to see what the studies results are on how this will influence the whaling and dolphin migration routes. I am also interested in how water as a scarce resource and water quality will be managed. I am also interested in the whole EIA process, the scoping etc and how it will be executed. I am also interested in the land footprint. I am also interested in the mining license awarding process and if it is dependant on the EIA outcome as it was a prerequisite for other projects in the Erongo Area. Signature: Electronically signed Date: 15/11/2011 Sandpiper Phosphate Project Registration and Comments I request to be registered as an Interested and Affected Party in respect of the proposed project. Please ensure that I receive all updates of information and that I am invited to the meetings, as well as kept fully informed of the Environmental Impact Assessment (EIA) process.

Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: [email protected]

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Page 1: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Please return this completed document (with all requested details) to:

Name: Amy Coetzer Telephone: 081 344 1159

Organization: Private Fax:

Designation: Cartographer Email: [email protected]

Postal address/City: P.O. Box 3060, Swakopmund

My interest in this project: I am currently busy with my BSC Information Systems and Geography

Degree. My main subjects are Environmental Impact assessments and it will be interesting to

follow the progress of this project.

Comments and matters of concern:

My concerns are if enough baseline studies & information are available to effectively determine what

the final impact will be on the environment. But I understand that specialist studies will be conducted.

I am also interested in the proposed and planned rehabilitation plan. Also I would like to see to what

National and International standards, treaties and legislation this project will comply to. I would also

like to see how this project will be different from the Saldhanna dredging project. I would also like to

see what the studies results are on how this will influence the whaling and dolphin migration routes.

I am also interested in how water as a scarce resource and water quality will be managed. I am also

interested in the whole EIA process, the scoping etc and how it will be executed. I am also interested in the

land footprint. I am also interested in the mining license awarding process and if it is dependant on the EIA

outcome as it was a prerequisite for other projects in the Erongo Area.

Signature: Electronically signed Date: 15/11/2011

Sandpiper Phosphate Project

Registration and Comments

I request to be registered as an Interested and Affected Party in respect of the proposed project. Please ensure that I

receive all updates of information and that I am invited to the meetings, as well as kept fully informed of the

Environmental Impact Assessment (EIA) process.

Page 2: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085

Organization: Earthlife Namibia Fax: 061 2305213

Designation: Chair Email: [email protected]

Postal address/City: PO Box 24892 Windhoek

My interest in this project:

Environmental and social impacts through phosphate mining

Comments and matters of concern:

Although Namibia needs industrial development this should not sacrifice the balance of the environment and the

health of the workers and residents.

Sustainable development should be the driver of industrial projects

Date:

23 Nov 2011

Page 3: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Name: David Russell Telephone: 081-2335748

Organization: Namibian Confederation of Fishing

Associations, represented by David Russell Fisheries

Consultancy

Fax: 061-243692

Designation: Fisheries Consultant Email: [email protected]

Postal address/City: PO Box 9562, Windhoek

My interest in this project:

To ensure the Namibian fishing industry is not adversely affected by the Sandpiper Phosphate Project.

Comments and matters of concern:

The Namibian fishing industry is a renewable resource that is a significant player in the Namibian economy, providing

many jobs as well as significant foreign exchange earnings for the country. That the phosphate project does not

impact on the sustainability of individual commercial fisheries within the Namibian fishing industry. Concerns include

any impact on fish breeding grounds, and that the mining operations do not result in ecosystem degradation

negatively impacting specific fisheries. Fisheries are also becoming more accountable internationally from an

ecosystem perspective including avoiding significant impacts on benthic fauna.

As representative of the Confederation of Fishing Associations, David Russell will liaise with the chairmen of each of

the Namibian fishing associations to provide any concerns detailed by individual associations, as the EIA process

unfolds

Date:

14 September

2011

Page 4: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Name: Francois Friend Telephone: +27 82 5548900

Organization: SI Anlytics (Pty) Ltd Fax: +27 11 4447806

Designation: Director Email: [email protected]

Postal address/City: PO Box 141, Melrose Arch, 2076, South Africa

My interest in this project:

Environmental in general and association with Walvis Bay

Comments and matters of concern:

Water management/treatment and dust challenges

Date:

1 December 2011

Page 5: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Name: Heidi Skrypzeck Telephone: 064-4101000

Organization: Ministry of Fisheries & Marine Resources Fax: 064-404385

Designation: SFB Email: [email protected]

Postal address/City: PO Box 912, Swakopmund

My interest in this project:

Protecting renewable resource of Namibia for the future

Comments and matters of concern:

Pollution, destroying keystone species of the marine ecosystem, The independent reviewer should be appointed by

the GRN

Date: 24 November 2011

Page 6: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Name: Laurica Keis Telephone:

Organization: Min. Agriculture,Water and Forestry Fax:

Designation: Assistant Hydrologist Email:

Postal address/City: P O Box 62667,Katutura,Windhoek

My interest in this project:

Interested in what will be done with the waste water from the land-based part of the project.

Comments and matters of concern:

Phosphate is a kind of a fertilizer, what measures will be done to prevent it from polluting our ground water and

eventually our dams.

Date: 25

November 2011

Page 7: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Name: Willem Derks, Pieter Louw

Telephone:

081 1280508 , 081 1294641

Organization: Namibia Stevedoring Services

Fax: +264 64 206748

Designation: MD , Mngr Business Development

Email: [email protected] [email protected]

Postal address/City: P O Box 1400, Walvis Bay

My interest in this project: We are a stevedoring service provider in the Port of Walvis Bay to importers and

exporters as well as a majority of fishing companies.

Comments and matters of concern: Our concern is the impact on the environment (land) and fishing resources.

The area where the pipeline is proposed is sensitive. A Topnaar area, with Springbok and other animals and a huge,

important historical site.

Date: 19 January

2012

Page 8: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Name: Tim Eiman Telephone: 064 2082339

Organization: NAMPORT Fax:064 2082373

Designation: Coordinator EMS/QMS Email: [email protected]

Postal address/City: Namport Walvis bay

My interest in this project: Environmental impacts on the marine ecosystem.

The public sometimes questions Namport on these issues. I need more background information in order to respond

to these questions.

Comments and matters of concern:

The impact of Phosphate mining on the live stocks in the Benguella Current Large marine ecosystem?

Date: 23

November 2011

To: Carla Saayman Socio-Economic Practitioner at Enviro Dynamics cc

Fax: +264 61 307-437 Tel: +264 61 223-336 Email: [email protected]

Address: PO Box 4039; Windhoek; Namibia

Page 9: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Sent: Fri 2011/12/09 03:49 PM

Dear Carla

Re: Namibian Marine Phosphate Land Based Activities EIA Scoping Report BID document

Regarding excess water from the buffer ponds being returned to the sea, is there any risk of returning heavy

metals, radioactive elements, microbiological contaminants etc to the sea? There are juvenile fish breeding

grounds nearby, as well as oyster and mussel filter feeding aquaculture farms.

The same applies for sediment impacts of shell waste on marine life off Walvis Bay, both in terms of juvenile

fish habitat, and possible aquaculture impacts as the species farmed are primarily filter feeders.

The buffer ponds are below sea level, and flooding risks from the Kuiseb River need to be considered.

The onshore processing plant appears to be defined as light industry by the Municipality, which is surprising to

us, considering the proposal that it will process 3 million tonnes of final product annually. It is situated very

near to Walvis Bay from an environmental impact perspective, in terms of noise, dust, odours, leaching and

possible radiation risks etc.?

From an EIA perspective, consideration should also be given now to the positioning of the Processing Plant and

the future Phosphoric Acid Plant which is potentially 2-3 years away. Do these facilities need to be close

together, and from an environmental impact perspective, is the Phosphoric Acid Plant likely to be considered

light industry?

The slime tailings should be situated such that there is no risk of leaching into Walvis Bay’s limited

groundwater resource. Also, there should be no risk of health hazards from the slime tailings, both during the

lifetime of the mining operation, and after the operation closes. Consideration should be given to

rehabilitating tailings at the end of the mining operation so that they are not an eyesore to the public.

We understand the mining operation will utilize a quarter to a third of Walvis Bay’s electricity requirements –

this needs NAMPOWER giving an assurance that they will be able to cope with the added electricity demand.

Will NAMPORT be able to cope with the additional load of handling 3 million tonnes of final product, both in

terms of traffic congestion getting it to the port, and shipping the product out? NAMPORT is also in the middle

of Walvis Bay, so the environmental impacts of product stockpiles need to be carefully looked at.

Thank you for the opportunity to give you feedback.

Best regards

David Russell

For Confederation of Namibian Fishing Associations.

Page 10: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

From: Herman Deysel [mailto:[email protected]]

Sent: 23 November 2011 02:16 PM

To: Carla

Subject: RE: Background Information Document- NMP Land-based activities

Carla,

I will not be able to attend but I would like to raise one question.

October is an off month for fishing due to the spawning of hake.

Since the dredging will be in the spawning grounds will dredging continue in October?

Regards

Herman

Page 11: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

From: Herman Neethling [mailto:[email protected]]

Sent: 25 November 2011 08:45 AM

To: [email protected]

Subject: mining problems

Hi Sigi

I know you make your money from these guys and you have to protect your and their interests.

When these guys loosen the sand with dredging where do all these sand go ??? This go straight to the beach

and our trips where we drive to sandwich harbour are closing so with this disturbance these rates will increase

rapidly and we will lose business as well the Sandwich lagoon which are of importance as a Ramsar site and

place off importance.

Also the pollution factors and the dangers of other materials coming to the shore.

What about the fishing sector around Meob bay? Previous places show where to much activity start fish

moves away even place in Angola where they drill for oil use to be lots of fish now in areas where no drilling

plenty.

The area they will drill will only last for a while then they have to move to a new site closer to Walvis or even

Swakop?

This project is only for own interests and not all the facts can be prove without the real thing happening then

so much cost was put into the project that nothing will stop this . Maybe we must contact the Green Peace to

look also into this matter and hear what they have to say. What can you lose rather save than sorry or I got my

money deal with the rest.

The area the Walvis municipality gave to these guys are also in one of the biggest grave yards of the Topnaar

people and part of their history will also go with these project.

I sound negative but this is just a few factors I take in consideration and if your study prove this will be fine we

will be happy, but if not will you gave back all money you make and publicly apologise to the Namibian people

and environment.

Where the environment are damage this damage are forever ask Walvis Bay were they rerouted a river and

now we have a dune problem.

Hope you have a fine day and everything will go good at least few more people will have work and hopefully

the fishing sector will go on in the same area otherwise a few more will lose their jobs.

Greetings

Kind Regards

Herman Neethling

Page 12: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

From: Joh Henschel [mailto:[email protected]]

Sent: 12 December 2011 10:15 AM

To: [email protected]

Cc: Stephanie van Zyl

Subject: NMP EIA

Dear Carla,

I realise that the deadline for comments on the NMP project scoping was on Friday. I do have one more

comment, not sure if this can be incorporated.

My comment concerns the Design and Location of Holding Pond (current location implies many different

impacts). Alternatives should be investigated, e.g., a) Holding Pond on a moored platform in the Bay; b)

Holding Pond at Processing Plant, mining ship discharges slurry from harbour anchorage and it is pumped

inland from there.

Regards,

Dr Joh Henschel

EnviroMEND

___________________________________________________-

Dear Jeremy,

The NMP project has, to my mind, a problem in that they have not demonstrated that their design is the only

possible way to go ahead. The location of the Holding Pond has huge implications, far far bigger than the

physical footprint. It puts a straightjacket around the lagoon (which is already partly in place with the road of

the salt works, but that is partial, and the kind of barrier that will come into place with the NMP. In the email

below you I copy you an additional point sent (late) to Envirodynamics this morning. This is what I first wrote

to Ecodynamics, but then did not send, as I realise they only want brief points, not tomes explaining all

background at great length:

“The fact that this industry will require a Holding Pond and a Processing Plant hugely influences the nature of

the terrestrial design, and makes the footprint enormous (far more than the actual area occupied by the

facilities). The current design locates them far apart from each other, and requires a design of a connection

between them right across the terrestrial side of the Ramsar Site, which disrupts the land-marine resource

exchange between lagoon and land (this is a fundamentally important principle). So I would like to suggest that

alternative locations and designs be considered. Perhaps the following, but not limited to my suggestions for

alternative designs and locations of the Holding Pond: Design-wise, one could perhaps think of a moored

floating platform somewhere in the Bay, where the slurry is processed before being pumped to the processing

plant onshore. An alternative location for a terrestrial holding pond: Why can the Holding Pond not be at the

Processing Plant, the mining ship comes into the harbour and all slurry is pumped to the processing plant,

where all pre- and full processing is done.”

Page 13: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

My background to this. On a postdoc for 2 years I specifically addressed the enormous effects of adjacent

water and land ecosystems. Although I was looking specifically at (European) rivers and shore ecosystems, and

how shore-based infrastructure (roads, pathways, cultivated fields, factories, housing, you name it…) placed a

straightjacket on these systems by stifling allochthonous flow of resources, it a principle with wide relevance.

Key examples come from productive marine systems and their adjacent land systems, particularly desert areas

(the best work of this nature is from islands and land-shore of Baja California). Some work along these lines

was initiated in Namibia (by Gary Polis, who drowned in Baja California before getting beyond the initial

investigation in Namibia). Land to shore allochthony is expected to be of enormous importance for the Namib

Desert, but we just don’t know how important yet (i.e. scientifically quantified, mechanisms understood etc).

The vectors include wind-blown material, some of the abundant shore flies flying inland or their predators

moving inland and dying there, birds feeding in the lagoon and pooping inland, likewise hyenas/jackals etc,

plus the cascading effects of terrestrial foodwebs thus enriched, in turn affecting yet other adjacent foodwebs

further inland etc.

My concern about placing infrastructure all the way along the Walvis lagoon along its terrestrial side is

therefore not a pipe-dream. It is important to understand the implications of possibly disrupting an important

process. This cannot be done by merely taking an inventory of what species occur where and considering them

only in their respective compartment. I would therefore suggest that in the EIA for the currently-planned

location of the Holding Pond thoroughly investigate this process by conducting field research on the specific

question of the marine-land connection (outputs best as peer-reviewed scientific publication).

Best regards,

Joh Henschel

Page 14: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

From: Mark R. Stanton [mailto:[email protected]]

Sent: 23 November 2011 12:23 PM

To: 'Carla'

Subject: RE: Background Information Document- NMP Land-based activities

Hi Carla

A quick query noting this document. Is the aim to do separate EIA’s for the marine based and land based

activities?

Kind regards

Mark R. Stanton

_____________________________________________________________________________

From: Carla [mailto:[email protected]]

Sent: 23 November 2011 12:48 PM

To: 'Mark R. Stanton'

Subject: RE: Background Information Document- NMP Land-based activities

Good day Mark

Yes, separate EIA processes are being undertaken for the marine and land-based activities. This issue has also

been raised at the Windhoek Public Meeting. You can view the minutes of this meeting on the Enviro

Dynamics website.

Kind Regards,

Carla Saayman

______________________________________________________________________________

Sent: Thu 2011/11/24 11:26 AM

Page 15: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Thanks for the feedback Carla.

Unfortunately your strategic document will not be the document (or in this case 2 documents each with half

the project!) that will be reviewed and either approved or rejected by MET… The sole aim of an EIA.

Kind regards

Mark R. Stanton

Eco Aqua

40 Riverside Avenue

P.O. Box 8291

Swakopmund

Namibia

Page 16: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Comments and concerns regarding the proposed Sandpiper Marine Phosphate Project – Terrestrial

Component Directorate Resource Management & Aquaculture, MFMR 9 December 2011

The following document lists the concerns of the Ministry of Fisheries & Marine Resources (MFMR) regarding

the land-based operations of Namibia Marine Phosphates (NMP) and possible impacts or implications to the

marine ecosystem following the presentation of NMP’s planned activities during the scoping meetings on 29

November and 1 December 2011.

The MFMR has already submitted numerous comments following the presentation of the marine component

of the project (29 September 2011), which includes the operations right up to the dredging vessel connecting

to a moored pipeline 1.5km offshore and to the south of Walvis Bay. Concerns regarding possible spillages

during the connection to the offshore pipeline and pumping of sediment ashore have been mentioned during

the marine EIA scoping, particularly in view of the area south of Walvis Bay past Sandwich Harbour being the

main spawning and nursery area for various fish species including the kabeljou and West Coast steenbras.

However some of these points also apply to the terrestrial EIA scoping component as NMP plans to pump

some of the sediment enriched seawater back to the sea from the beach (see below).

The proposed land-based operations are in close proximity to the RAMSAR site (lagoons), Sandwich Harbour,

Saltpans and Oyster farms (Donkey Bay, Aquaparks and Patrysberg) which would be affected by effluents

through seepage, spills, or current movement into the bay area or via Donkey Bay.

Excess seawater to be pumped back to sea:

Apparently around 4.5 (first year) to 14 million cubic metres (m3) of seawater (per year from third year

onwards) will be returned to sea either via the mooring pipeline or via a pipe to the beach. This is mainly

seawater used to resuspend the sediment so as to transport it through the pipelines. Concern about the water

quality of this seawater:

It may have high microbiological contamination due to decomposition of the organic matter in the buffer

pond. Thus it may affect product quality of the local fisheries and of the mariculture industry in Walvis Bay as

well as the salt works due to possible transfer to Walvis Bay area either via Donkey Bay or via currents carrying

this seawater into the Walvis Bay area. These industries are reliant on unpolluted water!

It may have increased trace/heavy metal concentration due to release of metals from sediments in changed

redox potential, pH or salinity of seawater leading to bioaccumulation of heavy metals in the foodweb and

affect fish larval survival etc.

It would contain fine suspended sediments which may lead to increased turbidity in the area where this water

is being released into sea and consequent effects on the marine ecosystem due to reduced light, possible fish

gill clogging, etc.

It may have an increased concentration of dissolved nutrients due to the high concentration of the sediment

pore water nutrients which may lead to increased number of local phytoplankton blooms (encourage harmful

algae blooms) and consequent effects on the local marine ecosystem as well as possible transfer to Walvis Bay

area either via Donkey Bay or via currents carrying this seawater into the Walvis Bay area.

Sewage water

Some treated sewage water will be used at the concentration plant to rinse out salt from the phosphate ore.

NMP is considering returning this water with the seawater to the buffer pond and from there to the sea.

MFMR is concerned that the treated sewage water still has high microbiological contamination that may

compromise the quality of fisheries, mariculture and salt products if returned to the sea. Thus NMP should

ensure that the treated sewage water should be kept separate from the seawater and rather be returned to

the sewage works. However, this would eventually lead to salination of the sewage work ponds. Nonetheless,

this water may not be returned to the sea. Alternative disposal must be found.

Buffer pond & Tailings pond

Page 17: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Concern of seepage of heavy metals and salts into the groundwater as the Walvis Bay water table is very

shallow and the ground is very porous. The ponds should be properly lined. The Department of Water Affairs

should be consulted on suitability of pond sites and acceptable lining of ponds.

Seepage or breakage of the buffer pond may lead to contamination of the salt works and/or the sea. This may

be a concern especially during Kuiseb River flood periods as the area south of the salt works (and north of the

buffer pond) is the shallowest area and, thus, where the Kuiseb River water tends to accumulate.

Shell stockpile

The shell grit removed from the sediment will be stockpiled and may be spread along the beach to be washed

back to sea. It must be investigated how this may affect the intertidal ecosystem. It should also be

stated/determined how thick a layer of shells would be spread over the beach area. Sedimentation of areas

e.g. Sandwich harbour could take place due to the shell grit being deposited/released at the low mark of the

beach area and the reversible nature of the inshore currents.

Increased shipping activity

The increased shipping activity in the vicinity of the mooring buoy and to the Walvis Bay harbour is likely to

affect the fish, marine mammals, turtles and seabirds in the area. Also spillage of material during harbour

loading activities may affect the water quality in the Bay.

The submerged pipeline with mooring will restrict ski boats & fishing boats access & activities.

Vehicle access

Restrictions on land to vehicle access to beach and areas further south (e.g. Sandwich Bay) due to the buffer

pond and pipe line. Sandwich Harbour is a prime birding area and an important destination for tour operators

to this area.

Beach linefish activity

Fishing activity along the beach south of Walvis Bay may increase due to increased human activity/presence in

a nature reserve area. If people do not have a fishing permit then ‘illegal fishing’ would increase. Concern that

people will not adhere to closed fishing seasons. This is a very important shore angling area especially for

Walvis Bay residents and any infrastructure (pipes, ponds and roads) will adversely affect angling activities

from the shore.

Seabirds

The local seabird population may be affected if the water is contaminated in the buffer and or tailings ponds.

Some recommendations for the EIA study

To indicate the flocculent, its volumes, chemical structure and chemical interactions with seawater to be used

in the tailings and the effect of this on the marine environment.

To indicate the volumes and concentrations of microbiological, heavy metal and dissolved nutrients within the

excess water to be pumped into the sea and the effect of this on the marine environment

Mitigating measures to prevent seepage from all ponds, groundwater contamination and breakage of all pond

walls

Mitigation measures for potential effects of global climate change (e.g. increased sea storms, higher rain fall,

floods etc).

Mitigating measures for solid waste disposal of the ship at mooring site

Page 18: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

Appropriate pollution contingency plans for spills during slurry transfer process and shipping

Management plan for ballast water of vessels to transport/ship final product

The corrosive effect of hydrogen sulphide, the effect of wave exposure and biofouling on the pipeline/s and

moorings (infrastructure maintenance).

Cumulative effects of harbour activities in combination with operational phases of this phosphate mining

project

Consider the international, regional and national legislative framework and documents. All ministerial

stakeholders must be consulted.

Since the environmental impact on the Lagoon/Ramsar/Sandwhich harbour/mariculture farms/Saltpans sites

cannot be excluded, the impact of contamination (heavy metals, nutrients and microbiological) and sediment

deposition need to be addressed in the EIA of which hydrodynamic modeling should be a compulsory

component

The independent/external reviewer and the specialists should ideally not be chosen by the proponent but

rather be appointed by MET.

Some Laws and regulations that should be noted and adhered to:

Set of Water and Sediment Quality Guidelines for the coastal zone of the BCLME

National Shellfish Sanitation Programme (in the process of being gazetted)

Effluent permit from the Department of Water Affairs

Page 19: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

From: Peter Cunningham [mailto:[email protected]]

Sent: 23 November 2011 12:19 PM

To: Carla

Subject: Re: Background Information Document- NMP Land-based activities

Dear Carla

See below some comments:

Holding pond

- How affect access to Sandwich Harbour?

- Area is important for roosting marine birds

- Salsola hummocks in area are an important habitat to a variety of wildlife

Pipeline

- Salsola hummocks in area are an important habitat to a variety of wildlife

- Temporary pools after Kuiseb River floods are also important bird habitat

- How affect water flow during flood events?

- Pipeline and movement of ungulates in delta area - e.g. springbok frequent this site - and ostrich (See Swakop

South pipeline report with findings on animal movement I did for Norman)

Processing plant

- Sewerage works are important bird feeding/roosting site

- Sewerage works have a recently established bird hide and associated infrastructure - how affect this?

- Prevailing winds are SW - dust & noise pollution issues!?

Regards

Peter Cunningham

Page 20: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

From: Royden Stanton [mailto:[email protected]]

Sent: 08 December 2011 09:37 AM

To: [email protected]; Carla

Cc: Stephan Anderson; Gregory Swartz; [email protected]

Subject: FW: Namibian Marine Phosphate - Land Based Operation Scoping

Importance: High

Dear Stephanie

We hereby wish to formally request that the following concerns, with regard to the Namibia Marine Phosphate

proposed development, be addressed to our satisfaction.

1) Seawater Quality:

Seawater is the raw material for our operation and as such we are obviously extremely concerned at any

possible contamination thereof. This concern is not limited to the chemical pollution but also encompasses

detrimental changes to the microorganisms as well.

Please note that this concern relates not only to the land based operation but particularly to the marine

operation as well.

2) Buffer Pond:

a) Detailed chemical analysis (including heavy metals) as well as microbial content of the product to be stored

in the buffer pond is required.

b) Anticipated radioactivity of product stored.

c) What measures are to be taken to prevent seepage from the buffer pond?

d) What measures are to be taken to prevent wall breakages of the buffer pond and what how will this be

dealt with should it occur.

e) What measures are to be taken to protect the buffer pond from flooding of the Kuiseb River.

f) How many people will be required to be transported to pond area during operations?

g) Will they stay on site or transported daily?

1. If transport required daily what route to be used?

j) Mode of transport to be used for these people?

3) Effluent / Waste Matter:

a) The volume, and chemical analysis (including heavy metals, acidity and radioactive elements) and microbial

content of any effluent and or waste material, inclusive of shell grit, returned to the sea is required.

Page 21: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

b) Anticipated temperature of effluent returned to ocean required.

c) Details of any flocculants, biocides and any additive utilized in process is required.

d) A detailed model of the pollution plume by an appropriate specialist would also be required.

e) Anticipated radioactivity levels of effluent and any stored waste required.

4) Powerline:

How will power be supplied to the buffer pond and any booster pump stations?

5) Pipeline:

a) Routing: Please note that whilst it has been agreed in principal, that the pipeline may be routed through our

mining licence area, the exact routing thereof has yet to be agreed.

b) How will blockages in the slurry line be rectified?

c) How would effluent in the pipeline be handled during pipeline maintenance?

d) Road construction – would this entail any setting up of construction camps within our area? From where

would the road building material be sourced?

e) What effect will the pipeline have on the movement of the sand dunes? This needs to be modeled to

ascertain whether it would increase the deposition of Aeolian sand into our ponds.

f) What measures are to be taken to ensure that the pipeline will be adequately protected during a possible

flood of the Kuiseb River?

6) Port Operation:

a) Dust Control:

Assurance is required that the dust generated from the handling of the product in the port will not cause

contamination of the salt stored in the port.

What is the chemical analysis of the final product?

MSDS of the final product required.

b) It was mentioned that the product is highly reactive when applied as a fertilizer to soil. What effect will this

have on salt?

c) What storage and loading facilities are to be utilized in the port for the export of the product?

7) Environment:

a) Bird life – water attracts birds, how will this be handled at the buffer pond?

b) Will the buffer pond contain any substances that may be detrimental / toxic to the birdlife?

Page 22: Sandpiper Phosphate Project · 2012. 5. 8. · Name: Bertchen Kohrs Telephone: 061 2279/ 081 2938085 Organization: Earthlife Namibia Fax: 061 2305213 Designation: Chair Email: earthl@iway.na

c) Envisaged policy towards bird life; control over employees?

Regards

Royden Stanton

Managing Director

Salt & Chemicals (Pty) Ltd

Walvis Bay Salt Refiners (Pty) Ltd

e) What effect will the pipeline have on the movement of the sand dunes? This needs to be modeled to

ascertain whether it would increase the deposition of Aeolian sand into our ponds.

f) What measures are to be taken to ensure that the pipeline will be adequately protected during a possible

flood of the Kuiseb River?

6) Port Operation:

a) Dust Control:

Assurance is required that the dust generated from the handling of the product in the port will not cause

contamination of the salt stored in the port.

What is the chemical analysis of the final product?

MSDS of the final product required.

b) It was mentioned that the product is highly reactive when applied as a fertilizer to soil. What effect will this

have on salt?

c) What storage and loading facilities are to be utilized in the port for the export of the product?

7) Environment:

a) Bird life – water attracts birds, how will this be handled at the buffer pond?

b) Will the buffer pond contain any substances that may be detrimental / toxic to the birdlife?

c) Envisaged policy towards bird life; control over employees?

Regards

Royden