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APPENDIX M

ENVIRONMENTAL MANAGEMENT PLAN

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TABLE OF CONTENTS

1. INTRODUCTION .................................................................................................................. 2

1.1. What is an Environmental Management Plan (EMP)? ......................................... 2

1.2. What are the legal implications and my obligations under this Plan? .............. 2

2. GENERAL REQUIREMENTS FOR THE EMP ......................................................................... 3

2.1. EMP ADMINISTRATION ............................................................................................... 3

2.2. ROLES AND RESPONSIBILITIES .................................................................................... 3

2.2.1. Environmental Control Officer (ECO) .............................................................. 3

2.2.2. City of Windhoek ................................................................................................ 4

2.2.3. Ministry of Health and Social Services ............................................................. 4

2.2.4. Communications Regulatory Authority of Namibia (CRAN) ....................... 4

3. MANAGEMENT REQUIREMENTS ....................................................................................... 7

3.1. Planning and Design Phase ..................................................................................... 7

3.2. Construction Phase ................................................................................................. 10

3.3. Operation, Maintenance and Monitoring........................................................... 12

4. FUTURE COMMUNICATION WITH THE PUBLIC ............................................................... 13

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1. INTRODUCTION

With the increasing growth in the use of mobile communication in Windhoek, service

providers such as MTC are under pressure to continuously expand their networks.

MTC argues that by providing additional capacity in areas that suffer from

congestion or poor coverage, the quality of the service provided is greatly

enhanced. It is for this reason that MTC intends to construct five 3G Mini Base

Transceiver Stations (BTS) in Ludwigsdorf, Windhoek.

In accordance with the Environmental Management Act (2007) and its Regulations

(2012) an Environmental Impact Assessment (EIA) is required for the “construction of

masts of any material or type and of any height, including those used for

telecommunication broadcasting and radio transmission”.

Enviro Dynamics cc was appointed by AGA Technical Services on behalf of Mobile

Telecommunication (MTC) to conduct an environmental impact assessment (EIA)

and develop an Environmental Management Plan (EMP) for the proposed project.

1.1. WHAT IS AN ENVIRONMENTAL MANAGEMENT PLAN (EMP)?

An EMP is simply a list of management actions needed to ensure that negative

environmental and social impacts of the project are avoided or minimised. It assigns

responsibilities and will be used as a checklist to monitor compliance at the site, both

by the City of Windhoek and the Developer.

1.2. WHAT ARE THE LEGAL IMPLICATIONS AND MY OBLIGATIONS

UNDER THIS PLAN?

This EMP with all its contents will be submitted to the Directorate of Environmental

Affairs (DEA) in the Ministry of Environment and Tourism (MET). The implementation of

an EMP is required in terms of the Environmental Management Act of 2007. The MET

will issue a pro-forma environmental contract to the Developer. The Environmental

Contract places the Developer under a legal obligation to adhere to the

recommendations in the EMP.

The EMP, once approved, therefore becomes a legally binding document and each

role-player identified in the EMP is required to abide to the conditions stipulated in it.

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2. GENERAL REQUIREMENTS FOR THE EMP

2.1. EMP ADMINISTRATION

During construction and operation this EMP shall form an integral part of each

process and all personnel should be aware of the specifications contained in this

document. A copy of the EMP shall be kept at the site office at all times and all

senior personnel shall be expected to familiarize themselves with the contents of this

document.

2.2. ROLES AND RESPONSIBILITIES

The entire responsibility of implementing the EMP and ensuring sound environmental

management during each phase of the project will fall on the developer (MTC). The

developer will need to identify an Environmental Control Officer (ECO), who can be

an existing employee within the company to which these tasks are assigned. The

responsibilities of such a person are contained below:

2.2.1. ENVIRONMENTAL CONTROL OFFICER (ECO)

The ECO will be a competent person identified by the developer to fulfil the role as

the representative to monitor and review the on-site environmental management

and implementation of this EMP by the developer. This person will be someone from

the developer’s staff that will be taking on additional responsibilities on the project

and should be appointed during the planning phase of the project. The ECO will be

required to be on site on a daily basis and his/her duties will include the following:

Ensuring that the necessary environmental authorizations and permits have

been obtained.

Maintaining open and direct lines of communication between the

developer and Interested and Affected Parties (I&APs) with regard to

environmental matters.

Regular site inspections of all construction areas with regard to compliance

with the EMP.

Monitoring and verifying adherence to the EMP, monitoring and verifying

that environmental impacts are kept to a minimum.

Taking appropriate action if the specifications are not followed.

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Assisting the developer in finding environmentally responsible solutions to

problems.

Monitoring the undertaking by the developer of environmental awareness

training for all new personnel coming onto site.

Advising on the removal of person(s) and/or equipment not complying with

the specifications.

Auditing the implementation of the EMP and compliance with authorization

on a monthly basis.

Undertaking a continual review of the EMP and recommending additions

and/or changes to the document.

2.2.2. CITY OF WINDHOEK

According to the Windhoek BTS Policy (2008) all telecommunication infrastructure

that falls within the jurisdiction of the City of Windhoek should be monitored by the

City (Strategic Executive: Planning, Urbanisation and Environment) on a regular and

random basis. This is to ensure compliance with the policy and the conditions of

approval, and to verify the sharing and co-location consideration as brought

forward by the service provider.

2.2.3. MINISTRY OF HEALTH AND SOCIAL SERVICES

MoHSS are required to inspect at such intervals as may be necessary any radiation

source in order to assess radiation safety conditions and other requirements imposed

by or under the Act (Section 33 of the Atomic Energy and Radiation Protection Act).

2.2.4. COMMUNICATIONS REGULATORY AUTHORITY OF NAMIBIA (CRAN)

Under Section 50 and 80 of the Communications Bill (2009) CRAN are required to

investigate all technical aspects of the proposed sites e.g. electromagnetic

interference with existing services, infrastructure sharing, future of the site and site

management and maintenance.

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3. MANAGEMENT REQUIREMENTS

3.1. PLANNING AND DESIGN PHASE

ASPECT OBJECTIVE MITIGATION MEASURE RESPONSIBILITY

Implementation of the

EMP for the duration of the

project.

To appoint an ECO The Developer must appoint an ECO to take responsibility for the

implementation for all provisions of this EMP.

The ECO shall report on a regular basis to the developer the status of

the implementation of all provisions of the EMP.

The ECO shall liaise with all stakeholders and neighbours. After being

appointed the ECO should introduce him/herself to the neighbours,

explaining that all complaints regarding the construction/operation

(e.g. dust, noise, workforce related complaints etc.) should be

directed to him/her.

The ECO should be involved in any decisions that are taken on site. This

should include activities that are to be undertaken during the

construction phase.

ECO to keep

record of all

communication.

Radiation To ensure that emissions from

towers adhere to internationally

accepted guidelines.

The field exposure strength associated with the sites should at all times

remain within the limits endorsed by the Atomic Energy and Radiation

Protection Act 5 of 2005 (i.e. ICNIRP, 2009).

Should multiple antennae be located on the facility, the total

Electromagnetic Radiation frequency (EMR) exposure from all

antennae should fall within the ICNIRP public exposure guidelines limits

MTC

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ASPECT OBJECTIVE MITIGATION MEASURE RESPONSIBILITY

All efforts should be made to provide coverage with the lowest

amount of power.

Communication To ensure transparency on the

part of the project proponent

regarding new developments and

plans for this current project as

well as provision of sufficient

access to information for all

The public should be informed as to what the ICNIRP guideline limits for

radiation emissions are and presented proof of how MTC intends to

stay within them. Open channels of communication should be

maintained where no information is withheld from the public.

If MTC intends to upgrade the current network from 3G to 4G in the

future:

o The registered stakeholders of this project should be notified of

this intent;

o A new radiation assessment should be undertaken;

o The assessment report should be circulated to the registered

stakeholders of this project for review; and

o The results of this study should then be sent to the City of

Windhoek who reserves the right to grant or refuse approval.

MTC

Health and safety To ensure the health and safety of

the neighbouring residents and

public

To avoid the BTS structures from becoming an access point to

neighbouring erven, no BTS may be erected directly next to a precast

fence. In stead it should be located at least 2 meters from the nearest

property line.

ECO

Contractor

Visual Impact To reduce as far as possible the

visual impact associated with the

towers to be constructed.

MTC should use camouflage to minimise the impact of the

development on the environment. The aim should be for the BTS to

blend into the landscape.

o The poles should be left galvanized and not painted.

MTC

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ASPECT OBJECTIVE MITIGATION MEASURE RESPONSIBILITY

Careful consideration should be given to screening and planting.

Towers should be designed so as to resemble street lights as close as

possible.

Where practically possible – consider placing the BTS structure

underground.

Environmental Awareness To ensure that all working on this

project (lead personnel and

construction workers) are well

informed and understand the

provisions of the EMP.

Before construction starts, all those working on the project must be made

aware of their responsibilities to ensure that impacts such as safety and

potential pollution are taken care of. This must include an induction

program.

ER

Contractor

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3.2. CONSTRUCTION PHASE

ASPECT OBJECTIVE MITIGATION MEASURE RESPONSIBILITY

Waste management Ensure that all waste is managed

in a manner that is sustainable

and does not cause a nuisance to

any member of the public.

Keep the construction site clean. Obtain bins to store waste in and

then empty the bins on a daily basis. The ECO should ensure that the

construction site is left free from litter at the end of the working day.

Any spillages from harmful substances or chemicals should be cleaned

up immediately and the contaminated soil stored in a sealed

container to be disposed of at the Kupferberg landfill site. No

contaminated soil may be dumped on actively growing vegetation or

open ground.

Cement may not be mixed on open ground. A concrete mixer should

be used and any mixing outside of the mixer should be done in a

wheelbarrow or on a metal sheet provided for this purpose.

ER

Contractor

Disruption of traffic Construction vehicles Vehicles should not be allowed to block the traffic of the affected

streets.

All traffic regulations should be adhered to:

o No parking 5m from an intersection;

o No parking more than 45cm from the edge of the road;

o No parking in such a way as to obstruct any private or public

vehicular entrance

In the event that any sidewalk paving needs to be disturbed to

accommodate the tower, immediately after construction such paving

will need to be restored to its original condition.

ECO

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ASPECT OBJECTIVE MITIGATION MEASURE RESPONSIBILITY

Health and safety To ensure the health and safety of

the neighbouring residents and

public

Construction workers may not wander onto unauthorised areas,

including properties adjacent to the construction site.

Sufficient road-warning signage as well as advance warning signage

should be placed around the site. These should be readily visible.

ECO

Contractor

To ensure the health and safety of

those working on site by adhering

to the relevant Health and Safety

regulations (August 1997)

Construction workers should be provided with toilet facilities and

drinking water.

The developer must adhere to the regulations pertaining to Health

and Safety, including the provision of protective clothing.

Safety clothing related to specific construction activities e.g. hard

hats, dust masks or gloves, etc. should always be available at the site.

ECO

Contractor

Construction noise To minimize the disturbance

caused by construction noise

Limit construction activities that could cause noise during normal

working hours. Construction activities should be discontinued during

night time (20h00 to 17h00) unless permission is obtained from the City

of Windhoek and surrounding neighbours.

ECO

Contractor

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3.3. OPERATION, MAINTENANCE AND MONITORING

ASPECT OBJECTIVE MITIGATION MEASURE RESPONSIBILITY

Littering or pollution during

maintenance

Avoiding pollution or littering on

site when maintaining the

equipment.

When doing maintenance to the equipment, MTC staff should ensure that

all litter and equipment is removed from the site, when leaving.

MTC

Radiation Complying to national and

international standards

MTC should regularly review the radiation output of the towers to

ensure that they comply with ICNIRP guidelines, or other nationally or

internationally accepted standards/ guidelines.

Random, compliance monitoring should be undertaken by an

independent consultant to ensure that the towers are operating at

levels within the ICNIRP stipulated limits.

Should new radiation emission standards/ guidelines be approved

either by CRAN or by the WHO, MTC will need to revise their output

levels to ensure that they comply with the new standards.

MTC

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4. FUTURE COMMUNICATION WITH T HE PUBLIC

During our study it became clear that the proposed construction of BTS sites is

received under conditions of extreme distrust and cynicism both between MTC and

the public. Table below indicates some of the perceptions expressed during the EIA

process:

Table 1: Common themes of perceptions.

When communicating with the public, it is important for MTC to:

1. Recognise that there is value in communicating with concerned members of the

public;

2. Recognise that particular skills are necessary for communicating effectively;

3. Address community concerns where this involves no- or low-cost action.

PUBLIC’S PERCEPTION MTC’S PERCEPTION

It is difficult for the public to determine

whether or not radiofrequency transmission

facilities are safe when there appear to be

conflicting opinions amongst scientific experts

on whether or not there are health effects.

MTC is of the opinion that the public need to

be educated about health effects in relation

to radiofrequency transmission facilities. It is

however, difficult for MTC to correct

misinformation, as it is perceived as having a

vested interest. Any specialist in the field that

are payed by MTC to communicate with the

public are perceived as biased.

MTC argues that people do not understand

that it is actually in MTC’s own business

interests to minimise exposures.

The public argues that BTS facilities should not

be developed unless they are proved to be

totally safe.

There is a perception that applicants are not

always honest about the options or the

technological constraints.

The public argues that decisions are not

always made by independent, impartial

decision-makers.

Insufficient monitoring of transmission facilities

is occurring. Some members of the public are

concerned that they do not have enough

information on emission levels from existing

sites.

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Based on this, the following recommendations are made:

that MTC compiles an Infrastructure Related Communications Plan, which, as

a minimum include:

o an outline of an “information campaign” that informs the public of

unbiased progress in EMF radiation and public health research. This will

provide an opportunity to discuss information about how technology

works, why there is scientific uncertainty and how this can be

managed, and the potential for adverse health effects from the

proposed facility. It will also provide a chance for concerned residents

to articulate their fears.

o a communications plan where the public can raise their concerns and

provide input in future projects.

A community consultation Plan which in consultation with the public:

o Aids in determining which communication strategies work when

informing the public of a specific project and which not,

o And that prescribes specific timeframes for informing the public of a

proposed project, prior to the initiation of the public participation

process described in the Environmental Management Act, Act 7 of

2007.

In addition it is also important for MTC to nominate one contact person who is

honest, trustworthy and who will treat community members with respect with whom

the public can communicate. This person should have experience in risk

communication, listens to people, has integrity and is able to communicate

information about the proposal in simple language (i.e. without being too technical

or defensive).

Although these final recommendations might not resolve the current concerns of the

residents in Ludwigsdorf, it could provide clarity in future, thereby resolving some

other concerns.