ELIZABETH BAY OPTIMISATION STUDY - Pisces Optimisation Study Amendment... · This report was...

Pisces Environmental Services

ELIZABETH BAY OPTIMISATION STUDY

AMENDMENT TO THE ENVIRONMENTAL IMPACT ASSESSMENT AND ENVIRONMENTAL MANAGEMENT PLAN

FOR THE ELIZABETH BAY MINE EXTENSION PROJECT

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

Volume I

O D W BN I A M O N D S E U I L D

A

This report was compiled by: Andrea Pulfrich1

with contributions by: Stephanie van Zyl2, Rob Simmons3, Jessica Kemper4,

Justine Braby5, Ingrid Wiesel6, Antje Burke7 & Dieter Noli8

Affiliation: 1 Pisces Environmental Services (Pty) Ltd, PO Box 31228, Tokai 7966, South Africa, Tel: + 27 21 782

9553, [email protected].

2 Enviro Dynamics; P O Box 20837, Windhoek, Namibia, Tel: + 264 61 223336, [email protected].

3 Percy Fitzpatrick Institute of African Ornithology, University of Cape Town, Private Bay Rondebosch

7701, South Africa, Tel: + 27 21 650 3310, [email protected].

4 African Penguin Conservation Project, c/o MFMR, Lüderitz, Namibia, [email protected].

5 Animal Demography Unit, University of Cape Town, Private Bay Rondebosch 7701, South Africa,

[email protected].

6 Brown Hyena Research Project, P. O. Box 739, 204 Ring Street, Lüderitz, Namibia, Tel.: + 264 (0)63

202114, [email protected]

7 EnviroScience, PO Box 90230, Windhoek, Namibia, Tel: + 264 61 211-729, [email protected].

8 Kolmanskop Train Company, Tel: 021-7944999, [email protected]

Namdeb Diamond Corporation

Environmental Impact Assessment Amendment for the Elizabeth Bay Mine Optimisation Study

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT (EMPR)

May 2010 ix

EXECUTIVE SUMMARY

Background Pisces Environmental Services (Pty) Ltd was appointed by Namdeb Diamond Corporation (Pty) Ltd to undertake an Amendment to the Elizabeth Bay Mine Resource Extension Environmental Impact Assessment (EIA) to cover proposed mining of the Southern Resource Area on the accreted beach. The study has been undertaken in accordance with Namibian Environmental legislation. This document serves as the Environmental Management Programme Report (EMPR) and provides an assessment of the risks to, and impacts on, the receiving environment likely to result from mining the Southern Resource Area in the Elizabeth Bay Mining Licence Area ML-45. It also proposes mitigation measures and regulatory procedures to be incorporated into Namdeb’s Environmental Management Plan to ensure that the effects of the identified risks and impacts on the environment are minimised. Public Participation Process To ensure that all possible biophysical and socio-economic impacts are investigated, a comprehensive and structured public participation process was pursued as part of the EIA-Amendment. The Public Participation Process was designed to fulfil the following:

• Identify potential high and medium risks to the environment associated with the proposed mining operations in the Elizabeth Bay Southern Resource Area during an initial Specialist Inception Workshop.

• Identify Interested and Affected Parties (I&APs) outside the scientific professionals. • Inform officials, stakeholders and the affected public about the project. This was achieved by:

o Registering the project with the Authorities by submission of a detailed Project Proposal. o Distributing Background Information Documents (BIDs). o Advertising the project in Namibian newspapers. o Holding a Public Meeting in Lüderitz. o Compiling and distributing a Scoping Report.

• Provide opportunities for I&APs to offer comment on the Scoping Report and input into the EIA-Amendment.

• Act as the interface between the I&APs and the specialist team. • Provide the vehicle through which the project can be submitted to the Authorities for an

Environmental Clearance Certificate. • Keep the I&APs informed of the progress of the study to its conclusion.

All the issues and potential impacts identified during the environmental scoping process are either addressed by the relevant specialist studies, or in the impact assessment that forms part of this report.




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Statutory Requirements Compilation of this EIA-Amendment was guided by a number of statutory and legal requirements. Of the national policies, the most important are Namibia’s Environmental Assessment Policy, the Minerals Agreement between Namdeb and the Government of Namibia, and the National White Paper on Coastal Management. Appropriate National legislation includes the Minerals (Prospecting and Mining) Act of 1992, the Marine Resources Act of 2000, and the Environmental Management Act of 2007, amongst others. Project Description Namdeb currently holds seven diamond mining licences covering both land and sea areas on and adjacent to the southern coast of Namibia. The Elizabeth Bay Mine Optimisation Study is located in Mining Licence 45 south of Lüderitz. At Elizabeth Bay high grade aeolian deflation deposits are accessible relatively close to the surface and diamonds have been mined here since German colonial times. As part of the Elizabeth Bay Mine Resource Extension Project initiated in 2003, recent sampling operations have identified viable diamond deposits below the accreted southern portion of the beach. The extension of mining operations to include the additional deposit would enable Namdeb to meet its objective of acquiring maximum sustainability to 2020 when the ML-45 mining licence expires. The Elizabeth Bay Mine Optimisation Study was initiated in September 2009 with the principal objective of determining and developing the optimal mining and treatment solution for both the current resource and the southern resource below the accreted beach. The current mining area is located in a north-south trending valley extending northwards from Elizabeth Bay. The areas to be targetted as part of the Elizabeth Bay Optimisation Study include the nine mine extensions identified during the Resource Extension Project, as well as the new Southern Resource Area on the accreted southern portion of the EBay beach. The target ores in the Southern Resource Area are covered by overburden sands of varying thickness, ranging from a minimum of 5 m of aeolian dune sand in the north to 16 m of waterlogged beach sands in the accreted southern portion. Various trade-offs for mining and treatment were considered (see Alternatives described below). The preferred solution includes the following approach for treating the mined ores:

• Repairing the existing EBay Treatment Plant to treat only <6 mm material and uncoupling the Primary crushing product and Secondary liberation section in the short-term until the appropriate liberation circuit is defined.

• Implementation of a wet infield screening (WIFS) plant to pre-treat material from the mining area. This will involve setting up a remote plant located on the beach in close proximity to the mining area. Three possible locations (Sites A, B and C) for the remote plant are being considered (see Figure I), of which Site A is the preferred option as it is situated on bedrock in a previously mined out area and is above sea level.

• The wet infield screening plant would size the remaining material into three separate products for stockpiling. The 1.4 - 6 mm fraction run of mine material will be loaded and hauled to the EBay Treatment Plant for processing through the DMS section. The liberation




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of the oversize material is an essential component for the success of this project and will be stockpiled for either crushing at the EBay Treatment Plant or crushing at the remote plant.

Approaches currently being considered for overburden stripping and mining are:

• Upgrading the dredger currently operational at Site 11/12, to economically strip overburden material up to a safety margin of 2 m above the ore-body. The stripped overburden material will be discharged onto the beach thereby constructing a seawall. The dredger will be converted from the current diesel engines to being electrically driven thus reducing running costs and potential environmental disasters resulting from hydrocarbon spills.

• Once stripping is complete the paddocks will be dewatered to allow access to the conventional mining fleet to remove the remaining overburden, the cemented material and the ore. Different options for primary breakage of cemented materials are also being considered such as drilling and blasting, or the implementation of a larger loading tool and surface miner. The dredger may also be implemented to assist with rehabilitation after cessation of mining.

Figure I: The Elizabeth Bay area showing the Southern Resource Area in relation to the current mining area. The three site-options for locating the WIFS plant are indicated (red polygons).




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Project Alternatives Various alternative mining and treatment approaches to the Elizabeth Bay Optimisation Study were considered as illustrated below:

Mining Trade-offs

Option 1 Option 2

Overburden Stripping and Seawall Construction

(Conventional stripping using

hydraulic excavators and

articulated dump trucks)

Overburden Stripping and Seawall Construction

(using purpose-built dredger)

De-watering and Dry-Mining

(using a fleet of 14 vehicles)

Dry-Mining

(de-watering

and

conventional

dry-mining)

Dredging

(Wet-mining

with the

cutter-head

dredger)

Treatment Trade-offs

Option 1 Option 2 Option 3

EBay Plant (transport of mined ores to and

treatment in existing plant)

Wet Infield Screening Plant (pre-treat in on-site Wet Infield

Screening Plant and further

treatment in existing plant or

remote independent plant)

Remote Treatment Plant

(on-site treatment of mined

ores in remote plant)

No Project Alternative The project does not go ahead

The Affected Biophysical Environment On the southern Namibian coastline, sediments of Orange River origin are transported northwards by wave energy focused by the strong southerly winds characteristic of the area. The rocky headlands and ridges concentrate the sands into deflation zones from where they are guided along Aeolian Transport Corridors until they accumulate in a train of large barchan dunes leading to the main Namib sand sea. Elizabeth Bay represents a drowned trough filled with Tertiary clay, sand and




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grit whose aeolian deflation caused the concentration of diamonds that are currently being mined in the area. The climate of the southern Namibian coastline is arid with strong predominantly southerly winds and frequent occurrence of fog along the coast. The coastline is strongly influenced by the Benguela Current, whose major feature is coastal upwelling. The coastline experiences strong wave action, with Elizabeth Bay being one of the few embayments where relatively sheltered conditions can be expected. Tides are semi-diurnal, with a typical tidal variation of ~1 m and a maximum tidal variation of approximately 2 m. Nearshore waters are typically turbid, with concentrations of suspended particulate matter varying both spatially and temporally. Superimposed on the suspended fine fraction, is the northward littoral drift of coarser bedload sediments, parallel to the coastline. Mining of the Southern Resource Area will primarily influence marine systems as most of the target area is the accreted southern portion of the beach. Terrestrial areas affected by the mining activities are restricted to a small strip of hummock dunes along the northern edge of the Southern Resource Area. The dune field biotope supports distinct faunal assemblages comprising mainly insects. The coastal dune hummocks are also prime habitat for the desert rain frog. Larger mammals found in the area include brown hyaena, black-backed jackal, gemsbok and springbok. Biogeographically, the coastline falls into the cold temperate Namaqua Province. The coastline around Elizabeth Bay predominantly comprises rocky shores punctuated by numerous small bays and sandy beaches. The benthic communities within these habitats are generally ubiquitous throughout the southern African West Coast region, being particular only to substratum type, wave exposure and/or height on the shore. The community structure of the subtidal reef benthos is typical of the southern African West Coast kelp bed environment, with the key predator being the commercially important rock lobster. The surf-zone and outer turbulent zone habitats of the bay supports a diversity of fish species, which seem to benefit from the turbidity plume produced by the discharged tailings. Marine mammals occurring in the area include the Cape fur seal and the endemic Benguela (Heaviside’s) dolphin. Elizabeth Bay has recently been identified as a particularly important location for Souther Right whales. Coastal and seabirds occurring in the area include amongst others Damara Terns, African Penguins, African Black Oystercatchers and various cormorant species. Although the Elizabeth Bay area has experienced several generations of terrestrial diamond mining it now falls into the Namibian Islands’ Marine Protected Area. The biological communities typifying the coastal and marine systems in the area are relatively hardy and well-adapted to pulsed natural perturbations, and thus recover comparatively rapidly from extreme conditions. Natural disturbance events characterising the area include natural sediment inputs during Orange River floods and Berg-wind events, high organic input following plankton blooms, development of low oxygen water near the seabed, which in turn can lead to sulphur eruptions.




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The Affected Socio-Economic Environment Mining dominates Namibia's heavy industry, which is also the major export earning sector, with diamonds dominating the country’s mineral production. The country’s mining sector generated N$ 6.5 billion during 2007 contributing 12.4% towards the GDP. The diamond mining industry delivered N$ 3.1 billion of this total. Employment creation has dwindled in the mining sector since 1995 as large established mines’ ability to create employment diminishes. Namdeb land operations reduced its workforce by about 1,700 employees between 1995 and 2001, and by another 1,400 between 2003 and 2010 due to the global economic meltdown. Despite this, Namdeb recorded extraordinary performance with over 2 million carats mined in the 2007/2008 financial year. With the main diamond market of the United States suddenly contracting, the world diamond industry correspondingly faced an oversupply, and Namdeb and De Beers Marine Namibia were obliged to suspend production and to introduce severe cost cutting measures. Namdeb’s mining licences are located in the Karas Region, which is Namibia’s largest region but also the least densely populated. The mines in the region attract workers from outside the Karas Region, which often leads to extended family structures of people migrating there not only to work in the formal sector, but to provide services through the informal sector to the employed and their families. The closest settlement to Elizabeth Bay is the coastal town of Lüderitz, situated some 30 km northwards. The population of the town is estimated at over 25,000. People come to this town because of the possibilities of working in the fishing industry, but employment opportunities are limited. The main forms of livelihood are full-time salaried work in the fishing and associated industries, Namdeb, the Town Council, Government, domestic work, small business enterprises, piecework and state pensions. Those without work live on handouts from family and friends, and activities of sex work and drug sales are also reported. The economy of Lüderitz has historically been dominated by the fishing industry, although tourism has increased in importance over the past few years. Namdeb’s workforce, which is 96% Namibian, comes from all regions throughout Namibia. The revenue received from this company through income, taxes and royalties, therefore benefits the entire country. In 2008, Namdeb’s total staff complement was 3,104 employees consisting of 2,493 permanent employees, 512 fixed-term contractors and 99 temporary staff. Namdeb’s Northern Coastal Areas comprise the Pocket Beaches, the EBay Mine and the Contractor Treatment Facility (CTF) in Lüderitz, which in 2008 together had a total staff complement of 320. This figure dropped to 63 for the EBay Mine and CTF during the recent downsizing efforts and treatment of x-ray tailings, and was been further reduced to <25 in early 2010. Namdeb employees are of the best remunerated in the industry and enjoy excellent benefits and free social services, accommodation and related infrastructural services. Namdeb has all the required policies in place as far as best practice health and safety, emergency response, training and development, social responsibility, corporate accountability, environmental management and other corporate responsibility matters are concerned.




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Namdeb’s overall economic contribution to Namibia, Karas and the southwestern coastal area of Namibia is significant. If downscaling at Namdeb continues as initiated in 2009, without new projects to extend the Life of Mine, significant and long-term socio-economic consequences will ensue. Environmental Impact Assessment Five specialist studies were undertaken to address issues identified during the specialist workshop and public participation process: 1) the potential impacts of mining operations on the accreted beach and the discharge of fines from treatment plants on seabird feeding and nesting in the area (particularly Damara Terns, shorebirds and African Penguins), 2) the potential impacts of beach mining operations and sediment discharges on sandy-beach and rocky-shore habitats and their associated communities, 3) the potential impacts of beach mining operations on brown hyenas in the area, and 4) a re-evaluation of potential socio-economic impacts of the Elizabeth Bay Mine Optimisation Study, particularly following the cessation of run of mine treatment and technical challenges at the mine during 2009, and 5) a specialist statement on the potential risks to archaeological and paleontological sites in the proposed mining area. The specialists appointed to undertake each of these studies were required to provide a description of the baseline conditions, as well as a description and assessment of the potential impacts of the proposed project on that specific environment. The impacts were assessed according to their extent, duration, intensity, probability of occurrence and status. These criteria were used to describe the impacts as having either a low, moderate or high significance. Set definitions of each of these criteria were provided in the terms of reference for each specialist to ensure consistency in their evaluations. The specialists were required to suggest achievable mitigation measures to either eliminate or reduce the effects of negative impacts and enhance the positive impacts. Although no highly significant positive impacts were identified, the following positive aspects of medium significance were identified:

• Employment through development of the Elizabeth Bay Optimisation Study. • Training and skills transfer to Namibians as a result of the project. • Provision of social services to employees of the Elizabeth Bay Optimisation Study. • Payment of taxes and royalties to the state. • Boost to local economies.

Ten highly significant negative aspects were identified:

• Smothering of invertebrate beach macrofauna during seawall construction, changes in sand-particle size resulting in changes in beach morphodynamics and associated decrease in faunal diversity (Definite).

• Smothering of invertebrate beach macrofauna, changes in sand-particle size resulting in changes in beach morphodynamics and associated changes in macrofaunal community structure as a result of mobilisation and re-deposition of eroded seawall sediments and discharged tailings (Definite).

• Smothering of rocky intertidal habitats and associated biota through beach accretion and deposition of sediments mobilised during seawall erosion (Definite).




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• Smothering of subtidal reef habitats and associated biota through beach accretion and deposition of sediments mobilised during seawall erosion, with potential declines in rock lobster abundance due to reduction of available food sources (Definite).

• Sedimentation effects on kelp and macroalgal assemblages resulting in changes in community structure and reduction in kelp-bed habitat, with associated effects on rock lobster abundance and recruitment (Definite).

• Direct loss of foraging and breeding habitats for shorebirds through seawall construction (Definite).

• Mining operations and seawall construction affecting the brown hyena territory boundary on the southern end of the beach (Highly probable).

• Mining excavations, overburden stripping and overburden dumps resulting in artificial land-forms that do not fit into the natural environment (Definite).

• Increased traffic associated with mining of the Southern Resource Area may lead to more brown hyena road-kills (Improbable to probable).

• The socio-economic impacts of the ‘no project’ alternative (Definite). Aspects assessed with medium significance are:

• Mining operations and seawall construction resulting in disturbance of brown hyenas that frequent the EBay beach (Definite).

• Mining operations and seawall construction resulting in the loss of beach area as a potential food source for brown hyenas (Probable).

• Turbidity generated by seawall construction and tailings discharges reducing the feeding habitat and efficiency for seabirds, especially for species targeting specific areas (Highly probable to Definite).

• Shoreline accretion potentially resulting in localised changes in hydrographical conditions leading to increased deposition or erosion in other parts of the bay (Highly Probable).

• Effects on archaeology – wrecks and buried terrestrial artifacts (Unknown but Improbable). • Creation of ore stockpiles and discard of oversize and product tailings from land-based

treatment facilities (Definite). • Production of dust during transport of ores and/or concentrate (Probable). • Depletion of non-renewable resources through increased consumption of electricity

(Definite). Results of the impact assessment suggest that with appropriate mitigation and management there is no reason that the project should not go ahead. Summary of Key Mitigation Measures Proposed mitigation measures that will bring these aspects, with the exception of the ’no-go’ option, to acceptable levels are:

• Develop the mine plan to ensure that mining proceeds systematically and efficiently from one end of the target area to the next, and that the target area (and any potential southward extensions identified during mining) is mined to completion in as short a time as possible. To allow impacted communities to recover to a condition where they are




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functionally equivalent to the original condition, target areas should preferably not be re-visited for at least five years, if at all. Efficient, high intensity mining methods are thus preferable to repeated, smaller scale operations.

• Initiate rehabilitation as soon as mining is complete in an area, and identify what rehabilitation can be undertaken whilst mining is in progress. Rehabilitation should involve breaching or partial levelling of seawalls to facilitate more rapid natural erosion by the sea, removal of cross-walls to create a more natural land-form, back-filling excavations from the land-ward side using oversize tailings and discards and restoring the beach profile and coastal topography to that resembling the pre-mining situation. No accumulations of overburden or tailings should be left above the high water mark.

• If technically and economically feasible, consideration should be given to engineering solutions that reduce the volumes of fine tailings discharged: for example, the installation of a degrit and/or thickening process to reduce the overall volumes of sediments discharged, as well as reducing the volume of the coarse fraction. Alternatively, investigate options of discharging fines onto the salt pan behind the Elizabeth Bay beach at various locations, or disposal further out to sea through a pipeline.

• Co-ordinate seawall construction at Elizabeth Bay with that elsewhere in the Namibian Islands’ MPA to ensure that no more than two seawalls are active at any one time within Zone 2 (rock-lobster sanctuary and landbased mining) of the MPA.

• Seawalls should be designed, constructed and maintained in such a way as to minimise erosion.

• Beach mining should avoid the favoured roosting and foraging areas of the Damara Terns at the north-west end of the bay.

• Rehabilitate terrestrial impacts on completion of operations by removal of all equipment, flattening or removal of all tailings mounds, backfilling of mined-out voids as far as possible, flattening of seawalls, rehabilitation of vegetation and tracks. The dredge pond is also to be back-filled, unless it has been agreed with MFMR and MET that the pond will definitely be used for future aquaculture ventures.

• Render mining sites acceptable and safe over the long term. Maximise the potential future use of the site by developing a ‘walkaway’ solution.

• Enforce strict speed limits, and in high-risk areas ensure adequate signage, and raise awareness of drivers of collision risks with wildlife.

Since the loss and/or disturbance of organisms in the mining area due to the removal of sediments, construction of seawalls, and discharge of tailings is an unavoidable impact of mining operations, there can be no mitigation. Likewise, impacts to adjacent reef communities through beach accretion and sediment mobilisation are unavoidable when mining in the vicinity of rocky outcrops. However, potential impacts can be minimised by using tailings to back-fill mined-out areas as far as possible. The mitigation measures proposed for shipwreck material or other archaeological artifacts (including shell middens) encountered in the course of mining or land-based processing operations are:




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• Immediately inform the Project Manager and Environment Manager who will inform the Namibian National Monuments Council and the Namibian Geological Survey.

• Retain artifacts recovered and where possible take photographs of them. Note the date, time, location and types of artifacts found in the Operator’s logbook.

• Contract an archaeologist to survey the site (if feasible). • Avoid mining within 500 m from the centre of the site until the area has been surveyed and

clearance to continue activities has been obtained from the National Monuments Council. Mitigation measures recommended to ensure that impacts associated with land-based operations are minimised include:

• Stockpile ores for further treatment only in previously disturbed areas. • Discard headfeed tailings only on existing dumps. • Re-use tailings for backfilling excavations, for dust control around offices. • Confine tailings dumps to mineral processing areas. • Decrease slopes and round edges of tailings dumps to facilitate natural ‘landscaping’ by

wind. • Ensure that stringent safety and waste management practices are in place at all times. • Control dust by wetting haul roads with grey water whenever necessary. • Conserve renewable and non-renewable resources wherever possible by implementing

suitable savings measures. Summary of Monitoring Recommendations Recommendations for well-structured baseline and monitoring surveys of key aspects are summarised below.

• Early morning brown hyena spoor counts on the beach before/during/after construction/mining or use of camera traps to detect changes in brown hyena activity in the affected area.

• The use of camera traps to establish an ID catalogue of resident hyenas and to determine brown hyena abundance and activity and changes therein, as well as to detect changes in home range locations; alternatively GPS telemetry of brown hyenas of the EBay clan and the southern hyena clan.

• Count washed-up carrion along the beach before and during construction of the plant site and seawall, during mining and after mining is completed. Increased beach carrion monitoring should take place before the start of the seal pupping season in November, during the peak pupping season in December, and after the peak of the pupping season in January, when most seal pup mortalities have already taken place and less carrion washes ashore. Counts should also take the weather/ocean conditions into account (wind, swell), as they influence the amount of carrion washed up.

• Report all road mortalities to Namdeb, Ministry of Environment and Tourism and the Brown Hyena Research Project immediately.

• In collaboration with MFMR consider supporting/initiating a shorebird monitoring programme (including feeding yield assessments) in key areas such as Elizabeth Bay, Grosse Bucht, Guano Bay and other areas in the Sperrgebiet that are likely to support high densities of




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shorebirds to assess the effects of mining operations, and the effects of sediment accretion on shorebird diversity and abundance. The extent of drift kelp on the beach should also be quantified (from historical aerial photos) and compared with present.

• Consider supporting a programme equipping individual penguins (and cormorants) with GPS loggers to gather data on feeding tracks and foraging “hot spots”. In a region such as Elizabeth Bay, which is thought to be an important foraging area for African Penguins from Possession Island, such a project (in combination with diet and breeding success studies) should commenced before mining operations begin and continue at least for the duration of mining activities, and some months thereafter to investigate (a) their use of Elizabeth Bay as a key foraging area and (b) the effect of turbidity on their foraging behaviour there.

• Initiate monitoring of bird mortalities resulting from collisions with power lines in Elizabeth Bay, with a control area for existing lines in the Sperrgebiet. Give special attention to night-flying flamingos, pelicans if they occur, and flocks of shorebirds.

• In collaboration with MFMR’s research technicians on Possession Island, consider monitoring the potential changes in bird behaviour, including the incidence of nest abandonment, during blasting operations at EBay.

• Continue annual monitoring of all intertidal and subtidal sites, for at least as long as mining remains in operation, and thereafter to determine the rate of recovery. The rocky intertidal surveys should be conducted between March and May each year to avoid seasonal effects confounding the results, and should be done at times of the month when the spring tides are sufficiently low to enable reliable sampling of low-shore quadrats. Five transects should be surveyed at each sampling site.

• Maintain sampling at a set of reference sites that can act as suitable controls for the full duration of the monitoring studies. These sites should not have been disturbed by mining activity within at least the previous five years, and should be representative of different wave exposures. The reference sites should be set aside as “marine protected areas” and be respected by the mining company (i.e. no mining of any nature and no removal of marine life should take place there for the duration of the monitoring).

• Monitoring of the Elizabeth Bay beach macrofaunal communities should continue annually for at least as long as mining operations in the Southern Resource Area and tailings discharges continue and thereafter, until communities in the impacted areas show evidence of having recovered to within 80% of levels at suitable ‘reference’ sites (bioequivalence tests) over a minimum of at least two successive years. However, following each survey the status of the beach should be re-assessed and the sampling programme revised to reflect both changes in the impacted communities as well as changes to the mining plan.

• Develop a programme to monitor changes in beach width at the extreme southern and northern ends of the beach, to assess the rate of sand inundation of intertidal reef habitats. This could be undertaken by regular photography from pre-determined positions, by Airborne Laser Survey or Differential GPS survey of the high water mark to assess the rate of beach accretion and to validate results from the proposed shoreline modelling study. Concurrently monitor seasonal and storm-induced sand movements and deposition at unmined/reference sites to allow adequate assessment of natural variability versus mining-related effects.

• Monitor the production of waste and the amount of waste that is recycled. Frequently assess the integrity of all waste storage containers.

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