Namdeb Centre, 10 Dr. Frans - Goveia.met.gov.na/screening/444_app_00444_final_emp... · Namdeb...

APP-00444 DBMN EIA and EMP Report i Lüderitz Logistic Shore Base-August 2019

APP-00444 Final Environmental Management Plan (EMP) Report to Support the Application for

Environmental Clearance Certificate (ECC) for the Proposed Upgrading of the Lüderitz Logistics

Shore Base (LLSB) in the Port of Lüderitz, Lüderitz //Karas Region, Southern Namibia

De Beers Marine Namibia (Pty) Ltd Namdeb Centre, 10 Dr. Frans Indongo Street

P.O. Box 23016

WINDHOEK, NAMIBIA

APP-00444 DBMN EIA and EMP Report ii Lüderitz Logistic Shore Base-August 2019

CLIENT / PROPONENT / OFFSHORE OPERATOR INFORMATION

De Beers Marine Namibia (Pty) Ltd Address: 4th Floor, Namdeb Centre

10 Dr. Frans Indongo Street WINDHOEK, NAMIBIA.

Responsible Person: Chief Executive Officer

Tel No.: +264 61 297 8000 Fax No.: +264 61 297 8100

Contact Person: Environmental Manager

Tel No.: + 264 61 297 8215 Fax No.: + 264 61 297 8120

Environmental Management Plan (EMP) Report Prepared By

Risk-Based Solutions (RBS) CC WINDHOEK, NAMIBIA, JUNE 2019

CITATION: Risk-Based Solutions (RBS), 2019. Final Environmental Management Plan (EMP) to Support the Application for Environmental Clearance Certificate (ECC) for the Proposed Upgrading of the Lüderitz Logistics Shore Base (Lüderitz Port), //Karas Region, Southern Namibia by De Beers Marine Namibia (DBMN) (Pty) Ltd, Windhoek, Namibia

APP-00444 DBMN EIA and EMP Report iii Lüderitz Logistic Shore Base-August 2019

PROPONENT, LISTED ACTIVITIES

AND RELATED INFORMATION SUMMARY

PROPONENT

De Beers Marine Namibia (DBMN) (Pty) Ltd

ADDRESS OF THE PROPONENT

De Beers Marine Namibia (Pty) Ltd

Namdeb Centre, 10 Dr. Frans Indongo Street P.O. Box 23016

WINDHOEK, NAMIBIA

PROPOSED PROJECT

Upgrading of the Lüderitz Logistics Shore Base (Lüderitz Port),

De Beers Marine Namibia (DBMN) (Pty) Ltd

PROJECT LOCATION

Lüderitz, //Karas Region, Southern Namibia (Latitude: -26° 38' 53.02" S, Longitude: 15° 09' 33.98" E)

X: -26.64806, Y: 15.15944

ENVIRONMENTAL CONSULTANTS

Risk-Based Solutions (RBS) CC (Consulting Arm of Foresight Group Namibia (FGN) (Pty) Ltd)

41 Feld Street Ausspannplatz Cnr of Lazarett and Feld Street

P. O. Box 1839, WINDHOEK, NAMIBIA Tel: +264 - 61- 306058; Fax: +264 - 61- 306059

Cell: + 264-811413229; Email: [email protected] Global Office / URL: www.rbs.com.na

ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

Dr. Sindila Mwiya PhD, PG Cert, MPhil, BEng (Hons), Pr Eng

mailto:[email protected]

http://www.rbs.com.na/

APP-00444 DBMN EIA and EMP Report iv Lüderitz Logistic Shore Base-August 2019

APP-00444 DBMN EIA and EMP Report v Lüderitz Logistic Shore Base-August 2019

STATEMENT OF QUALIFICATIONS / SUMMARY CV /PROFILE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) DR. SINDILA MWIYA

Dr. Sindila Mwiya has more than eighteen (18) years of direct technical industry experience in Environmental Assessment (SEA, EIA, EMP, EMS), Energy (Renewable and Non-renewable energy sources), onshore and offshore resources (minerals, oil, gas and water) exploration / prospecting, recovery and utilisation, covering general and specialist technical exploration and recovery support, Health, Safety and Environment (HSE) permitting for Geophysical Surveys such as 2D and 3D Seismic and Gravity Surveys for mining and petroleum (oil and gas) operations support, through to engineering planning, layout, designing, logistical support, recovery, production / operations, compliance monitoring, rehabilitation, closure and aftercare projects lifecycles. Through his companies, Risk-Based Solutions (RBS) CC and Foresight Group Namibia (FGN) (Pty) Ltd , which he founded, he has undertaken more than 200 projects for local, regional (SADC) and international clients. He continue to work for global reputable resources (petroleum and mining / minerals) and energy companies such as BW Offshore (Singapore), Shell Namibia B. V. Limited (Namibia/ the Netherlands), Tullow Oil (UK), Debmarine (DBMN) (Namibia), Reconnaissance Energy Africa Ltd (ReconAfrica) (UK/Canada), Osino Resource Corporation (Canada/Germany/ Namibia), Desert Lion Energy Corporation (Canada/ Australia), Petrobras Oil and Gas (Brazil) / BP (UK), REPSOL (Spain), ACREP (Namibia/Angola), Preview Energy Resources (UK), HRT Africa (Brazil / USA), Chariot Oil and Gas Exploration (UK), Serica Energy (UK), Eco (Atlantic) Oil and Gas (Canada / USA), ION GeoVentures (USA), PGS UK Exploration (UK), TGS-Nopec (UK), Maurel & Prom (France), GeoPartners (UK), PetroSA Equatorial Guinea (South Africa / Equatorial Guinea), Preview Energy Resources (Namibia / UK), Sintezneftegaz Namibia LTD (Russia), INA Namibia (INA INDUSTRIJA NAFTE d.d) (Croatia), Namibia Underwater Technologies (NUTAM) (Namibia), InnoSun Holding (Pty) Ltd (Namibia / France) and OLC Northern Sun Energy (Pty) Ltd (USA /Namibia). Dr. Sindila Mwiya is highly qualified with extensive experience in petroleum, mining, renewable energy (Solar, Wind, Biomass, Geothermal and Hydropower), Non Renewable energy (Coal, Petroleum, and Natural Gas), applied environmental assessment, management and monitoring (Scoping, EIA, EMP, EMP, EMS) and overall industry specific HSE, cleaner production programmes, geoenvironmental, geological and geotechnical engineering specialist fields. Dr. Sindila Mwiya has undertaken and continue to undertake and manage high value projects on behalf of global and local resources and energy companies. Currently, (2019-2021) Dr. Sindila Mwiya is responsible for permitting planning through to operational and completion compliance monitoring, HSE and engineering technical support for multiple major upstream petroleum, minerals, mining and manufacturing operations in different parts of the World including Namibia. He continue to worked as an International Consultant, national Environmental Assessment Practitioner (EAP), Engineering / Technical Consultant (RBS / FGN), Project Manager, Programme Advisor for the Department of Natural and Applied Sciences, Namibia University of Science and Technology (NUST) and has worked as a Lecturer, University of Namibia (UNAM), External Examiner/ Moderator, NUST, National (Namibia) Technical Advisor (Directorate of Environmental Affairs, Ministry of Environment and Tourism / DANIDA – Cleaner Production Component) and Chief Geologist for Engineering and Environment Division, Geological Survey of Namibia, Ministry of Mines and Energy and a Field-Based Geotechnician (Specialised in Magnetics, Seismic, Gravity and Electromagnetics Exploration and Survey Methods) under the Federal Institute for Geoscience and Natural Resources (BGR) German Mineral Exploration Promotion Project to Namibia, Geophysics Division, Geological Survey of Namibia, Ministry of Mines and Energy. He has supervised and continue to support a number of MScs and PhDs research programmes and has been a reviewer on international, national and regional researches, plans, programmes and projects with the objective to ensure substantial local skills development pivotal to the national socioeconomic development through the promotion of sustainable natural resources coexistence developmental and resources recovery approaches, utilisation, management and for development policies, plans, programmes and projects financed by governments, private investors and donor organisations. Since 2006 until 2017, he has provided extensive technical support to the Department of Environmental Affairs (DEA), Ministry of Environment and Tourism (MET) through GIZ and continued to play a significant role in the amendments of the Namibian Environmental Management Act, 2007, (Act No. 7 of 2007), preparation of new Strategic Environmental Assessment (SEA) Regulations, preparation of the updated Environmental Impact Assessment (EIA) Regulations as well as the preparation of the new SEA and EIA Guidelines and Procedures all aimed at promoting effective environmental assessment and management practices in Namibia. Among his academic achievements, Dr Sindila Mwiya is a holder of a PhD (Geoenvironmental Engineering and Artificial Intelligence) – Research Thesis: Development of a Knowledge-Based System Methodology (KBSM) for the Design of Solid Waste Disposal Sites in Arid and Semiarid Environments focusing on Namibia, MPhil/PG Cert and BEng (Hons) (Engineering Geology and Geotechnics), qualifications from the University of Portsmouth, School of Earth and Environmental Sciences, United Kingdom. During the 2004 Namibia National Science Awards, organised by the Namibian Ministry of Education, and held in Windhoek, Dr. Sindila Mwiya was awarded the Geologist of the Year for 2004, in the professional category. Furthermore, as part of his professional career recognition, Dr. Sindila Mwiya is a life member of the Geological Society of Namibia, Consulting member of the Hydrogeological Society of Namibia and a Professional Engineer registered with the Engineering Council of Namibia. WINDHOEK, AUGUST 2019

APP-00444 DBMN EIA and EMP Report vi Lüderitz Logistic Shore Base-August 2019

CONTENT LIST

NON TECHNICAL SUMMARY ........................................................................................................................... VIII

1. BACKGROUND ......................................................................................................................................... - 1 -

1.1 OVERVIEW ................................................................................................................................................ - 1 - 1.2 PROJECT LOCATION .................................................................................................................................. - 1 - 1.3 OPERATIONAL ARRANGEMENTS ................................................................................................................. - 1 - 1.4 PROJECT MOTIVATION .............................................................................................................................. - 1 - 1.5 PURPOSE OF THIS EMP REPORT ............................................................................................................... - 7 - 1.6 STRUCTURE OF THE REPORT ..................................................................................................................... - 7 -

2. APPROACH AND METHODS ................................................................................................................... - 8 -

2.1 OVERVIEW ................................................................................................................................................ - 8 - 2.2 TERMS OF REFERENCE FOR THIS REPORT .................................................................................................. - 8 - 2.3 ENVIRONMENTAL ASSESSMENT PROCESS .................................................................................................. - 9 -

2.3.1 Summary of the Approach ............................................................................................................ - 9 - 2.3.2 Assumptions and Limitations ...................................................................................................... - 10 -

2.4 PUBLIC AND STAKEHOLDERS CONSULTATION PROCESS ............................................................................ - 10 - 2.4.1 Overview ..................................................................................................................................... - 10 - 2.4.2 Objective of Conducting Public and Stakeholder Consultation Process .................................... - 11 - 2.4.3 Consultation Activities, Timing and Outcomes ........................................................................... - 11 -

2.5 IMPACT ASSESSMENT AND MANAGEMENT CRITERIA .................................................................................. - 16 - 2.5.1 Environmental Impact Assessment Rankings ............................................................................ - 16 - 2.5.2 Environmental Management Plan (EMP) Framework ................................................................ - 17 - 2.2.3 DBMN Environmental Management System (EMS) ................................................................... - 17 -

3. EMP FRAMEWORK ................................................................................................................................ - 19 -

3.1 OVERVIEW .............................................................................................................................................. - 19 - 3.2 EMP FOR UPGRADING OF LÜDERITZ LOGISTIC SHORE BASE (LLSB) ......................................................... - 19 -

4. ENVIRONMENTAL PERFORMANCE MONITORING ............................................................................ - 29 -

4.1 OVERVIEW .............................................................................................................................................. - 29 - 4.2 ENVIRONMENTAL MONITORING PLAN ....................................................................................................... - 29 -

4.2.1 Objectives of the Monitoring Plan ............................................................................................... - 29 - 4.3 MONITORING QUALITY CONTROL MEASURES ............................................................................................ - 30 -

4.3.1 DBMN Marine Scientific Advisory Committee ............................................................................. - 30 - 4.3.2 EMS Auditing .............................................................................................................................. - 30 - 4.3.3 Environmental Performance Monitoring Report.......................................................................... - 30 -

5. CONCLUSIONS AND RECOMMENDATIONS ....................................................................................... - 31 -

5.1 CONCLUSIONS ........................................................................................................................................ - 31 - 5.2 RECOMMENDATIONS ............................................................................................................................... - 31 -

APP-00444 DBMN EIA and EMP Report vii Lüderitz Logistic Shore Base-August 2019

List of Figures

Figure 1.1: Regional location of the Lüderitz Logistics Shore Base (Port of Lüderitz). .......... - 2 - Figure 1.2: Detailed location of the Lüderitz Logistic Shore Base (Port of Lüderitz). ............. - 3 - Figure 1.3: Shareholding structure, operational companies and license areas with

respect to Namdeb Holdings (Pty) Ltd, DBMN (Pty) Ltd and Namdeb Diamond Corporation (Pty) Ltd. .......................................................................... - 5 -

Figure 1.4: Illustration of DBMN logistical arrangements linking Windhoek (HQ), Oranjemund Airport (Logistics Aviation Base), Offshore Operations (ML 47 Mining and Exploration), Cape Town and the Port of Lüderitz (Logistics Shore Bases)................................................................................................................ - 6 -

Figure 2.1: Summary of the environmental assessment process in Namibia. ....................... - 8 - Figure 2.2: Copy of the 1st Public Notice was published in the Confidente Weekly

Newspaper 8th – 14th August 2019. .................................................................. - 13 - Figure 2.3: Copy of the 2nd Public Notice that was published in the Windhoek Observer

Weekly Newspaper dated Friday, 16th August 2019. ........................................ - 14 - Figure 2.4: Copy of the 3rd Public Notice that was published in the Namibian Daily

Newspaper dated Thursday, 22nd August 2019. ............................................... - 15 - Figure 2.5: Illustration of environmental assessment, management and monitoring as

part of the overall ISO 14001 Environmental Management System adopted by DBMN. ........................................................................................................ - 18 -

List of Tables Table 2.1: Summary of the proposed activities, alternatives and key issues considered

during the Environmental Assessment (EA) process covering EIA and EMP phases. .............................................................................................................. - 9 -

Table 2.2: Summary of the Interested and Affected Parties (I&APs) consultation activties undertaken during the month August 2019. ........................................ - 12 -

Table 2.3: Definition of impact assessment categories. .................................................... - 16 - Table 2.4: The criteria used to determine the significance rating of the impact(s). ............ - 17 - Table 3.1: General company procedures for EMP implementation in line with DBMN

operations and EMS. ........................................................................................ - 20 - Table 3.2: Implementation of the Environmental, Health and Safety (HSE) management

systems, procedures and operational requirements. ........................................ - 23 - Table 3.3: Protection of the coastal and marine fauna and birds due to increased

activities within the Port Area due to DBMN and other operators. .................... - 24 - Table 3.4: Enhancement of the socioeconomic issues. ..................................................... - 24 - Table 3.5: Alignment of the Mine closure and sustainability of the LLSB developed

infrastructure. ................................................................................................... - 27 -

List of Plates Plate 1.1: The Port and Town of Lüderitz showing the outline of the DBMN Logistics

Shore Base Area (RBS Geotagged Imaged Series, 2019). ................................ - 4 -

APP-00444 DBMN EIA and EMP Report viii Lüderitz Logistic Shore Base-August 2019

NON TECHNICAL SUMMARY Debmarine Namibia (“DBMN”) is proposing to upgrade the supporting infrastructure on its 8700 m2

currently rented logistics shore base space situated inside the Port of Lüderitz in the //Karas Region in southern Namibia. The proposed supporting infrastructure upgrades of the Lüderitz Logistics Shore Base (LLSB) will cover the following areas / activities:

(i) Civil construction;

(ii) Fence and concrete ring beam; (iii) Engineered layers and hardstand; (iv) Services (sewer, water, fire hydrants, electrical installation); (v) Oil containments, and; (vi) Security detail (Security Gate House with gate for vehicles and pedestrian).

The proposed activities are listed in the Environmental Management Act, 2007, (Act No. 7 of 2007) and the Environmental Impact Assessment (EIA) Regulations 30 of 2012 and cannot be undertaken without an Environmental Clearance Certificate (ECC). The environmental assessment process inclusive of the preparation of this EMP Report has been undertaken in accordance with the provisions of the Environmental Impact Assessment (EIA) Regulations No. 30 of 2012 and the Environmental Management Act, 2007 as well as international best practices. The following key project alternatives have been considered as part of the EIA Process: Project location and the no-action alternative, other coastal and marine users and potential user conflicts, influence on the ecosystem function, services, use values and non-use or passive. Public and stakeholders consultations process has been undertaken during the month of August 2019. Public notices were published in the Confidente Weekly Newspaper dated 8th-14th August 2019, the Windhoek Observer Weekly Newspapers dated Friday 16th August 2019 and the Namibian Daily Newspaper dated Thursday 22nd August 2019. Despite the public notices published in the local newspapers, no stakeholder registration or written comments / inputs or objection were received during the consultation period. The climate of the southern Namibian coastline and indeed that of the project location is arid with typically low, unpredictable winter rains, strong predominantly southerly or south-westerly winds and frequent fogy events. The proposed logistic shore base (Port of Lüderitz) fails within the Lüderitz Municipal Townlands. The area surrounding the Town and Port of Lüderitz is well protected with the Tsau //Khaeb (Sperrgebiet) National Park towards the south, the Namib-Naukluft Park towards the north of Lüderitz and the western marine environment area falling within the Namibian Islands' Marine Protected Area (NIMPA). It is estimated that at least 30 reptile, 4 amphibian, 30 mammal and 95 bird species (breeding residents) are known to or expected to occur in the general/immediate Lüderitz area of which a high proportion are endemic species. It is estimated that at least 15 to 22 species of larger trees and shrubs (>1m) (Curtis and Mannheimer 2005 and Mannheimer and Curtis 2009) and at least 5 to 14 (approximately 18 species) grasses (Burke 2003, Mannheimer et al. 2008, Müller 1984, Müller 2007 and Van Oudshoorn 1999) occur in the general Lüderitz area. The local economy is centred on the utilisation of the clean sheltered waters for aquaculture purposes and tourism development such as sailing, kiting, fishing and whale watching. The Port of Lüderitz is an important fishing, mining/energy supply and minor import/export port. Based on the results of the project screening process, Environmental Scoping evaluation of the key issues and the impact assessment undertaken in this report, it’s likely that the proposed project activities no significant impacts / influences on the receiving environment (physical, biological and socioeconomic). In line with DBMN risk assessment matrix, a rating criteria for the impact assessment have been standardised to include set definitions with the allocation of the assessment ranking categories been based on quantifiable criteria which can be measured. The allocated ranks refer to the resultant impact (e.g. habitat area affected, or time that the result of the impact will last), and not of the

APP-00444 DBMN EIA and EMP Report ix Lüderitz Logistic Shore Base-August 2019

cause thereof (e.g. the airport area being upgraded, or time of active impact). Detailed assessment table with management intervention measures are provided in this report In accordance with the results of the impact and risk assessments for the proposed upgrading of the Lüderitz Logistics Shores Base (Port of Lüderitz) as detailed in EIA Report, detailed Environmental Management Plan (EMP) have been prepared covering the following components as presented in Table 3.1 – 3.5:

(i) General company procedures for EMP implementation in line with DBMN operations and EMS (Table 3.1);

(ii) Implementation of the Environmental, Health and Safety (HSE) management systems,

procedures and operational requirements (Table 3.2);

(iii) Protection of the coastal and marine fauna and birds due to increased activities within the Port Area due to DBMN and other operators (Table 3.3);

(iv) Enhancement of the socioeconomic components (Table 3.4), and;

(v) Alignment of Mine Closure and sustainability of the Lüderitz Logistics Shores Base

infrastructure developed (Table 3.5). Based on the results of the Environmental Impact Assessment (EIA) and this Environmental Management Plan (EMP) report, it’s hereby recommended that the proponent (DBMN) be issued with an Environmental Clearance Certificate (ECC) for the proposed upgrading of the Lüderitz Logistics Shore Base (LLSB) in the Port of Lüderitz, Lüderitz, //Karas Region, South Namibia. The proposed Lüderitz Logistics Shores Base area falls within already exiting and operational industrial port area and the site is not pristine. Workers must use Personal Protective Clothing / Equipment at all times, site equipment / vehicles movement procedures and protocols and all the related activities shall be undertaken in accordance with the Namibian Port Authority (NamPort) corporate requirements, environmental standards and management systems. Mitigation measures have been prepared to be implemented by DBMN with respect to the impacts ranked as having either a “high” or “medium” significant impacts on the receiving environment. The Environmental Performance Monitoring activities shall be undertaken during the preconstruction, construction and operational stages of the proposed upgrading of the Lüderitz Logistics Shores Base with bi-annual monitoring reports submitted to the Environmental Commissioner in the Ministry of Environment and Tourism.

APP-00444 DBMN EIA and EMP Report - 1 - Lüderitz Logistic Shore Base-August 2019

1. BACKGROUND

1.1 Overview Debmarine Namibia (“DBMN”) is proposing to upgrade the supporting infrastructure for its logistics shore base spaces situated inside the Port of Lüderitz in the //Karas Region in southern Namibia (Fig. 1.1). The Port of Lüderitz is located 254 nautical miles south of the Port of Walvis Bay along Namibia’s southern coastline and caters for all the business and cargo in the southern part of the country, and further provides access to markets in the Northern Cape of South Africa.

1.2 Project Location The Port of Lüderitz, (Logistic shore base for DBMN) is located in the //Karas Region in southern Namibia (Figs. 1.1 and 1.2 and Plate 1.1). According to Namibia Port Authority (NamPort), the southern Namibia strategic coastline location of the port make it’s a key export and import hub offering excellent logistical services and links to other towns in Namibia and South Africa. It serves as an important base for the fishing industry and the offshore diamond and mining industries. According to NamPort, for the fruit industry’s exports to Europe, particularly grapes from Aussenkehr and from the Northern Cape Province, shipping from Lüderitz saves more than 2 days in delivery time (www.namport.com.na). With a new 500m quay, two recently-acquired 60-tonne Haulers and one 45-tonne Reach Stacker, the port can provide efficient and safe cargo handling facilities for importers and exporters.

1.3 Operational Arrangements Namdeb Diamond Corporation (Pty) Ltd (Namdeb) and DBMN are 100% subsidiaries of Namdeb Holdings (Pty) Ltd (Fig. 1.3). Namdeb Holdings (Pty) Ltd which is 50% owned by the Republic of Namibia and the remaining 50% held by the De Beers Group through De Beers Namibia Holdings (Pty) Ltd, holds all land-based and marine exclusive prospecting licences and mining licences. Namdeb and DBMN perform contractual land-based and marine prospecting and mining operations respectively for Namdeb Holdings (Pty) Ltd (Figs. 1.3). Fig. 1.4 illustrates DBMN operational logistical arrangements linking Windhoek (the Headquarters), Oranjemund Airport (Logistics Aviation Base), offshore operations (ML 47 Mining and Exploration location), Cape Town and the Port of Lüderitz (Logistics Shore Bases).

1.4 Project Motivation DBMN uses the Port of Lüderitz as the logistic shore base for vessels maintenance operations and handling of all supply items to and from the vessels in the MLA No. 47. The company is currently renting about 8700 m2 of land inside the Port of Lüderitz from NamPort for logistic operations. However, due to the envisaged increase in operations, DBMN is proposing to upgrade the supporting infrastructure for its logistic shore base space. The upgraded logistics shore base infrastructure within the Port of Lüderitz will greatly support the envisaged increased operations by DBMN and ensure efficient, secure and effective handling of all supply items to and from the vessels. In addition, all vessels maintenance operations and associated activities will results in increased local socioeconomic benefits to the people and town of Lüderitz. The socioeconomic benefits include land rental and port fees payable to NamPort, direct and indirect jobs and services and purchase of local supplies.


Figure 1.1: Regional location of the Lüderitz Logistics Shore Base (Port of Lüderitz).


Figure 1.2: Detailed location of the Lüderitz Logistic Shore Base (Port of Lüderitz)

(Source: www.openstreetmap.org).

http://www.openstreetmap.org/


Plate 1.1: The Port and Town of Lüderitz showing the outline of the DBMN Logistics Shore Base Area (RBS Geotagged Imaged Series, 2019).


Figure 1.3: Shareholding structure, operational companies and license areas with

respect to Namdeb Holdings (Pty) Ltd, DBMN (Pty) Ltd and Namdeb Diamond Corporation (Pty) Ltd (Source: DBMN, 2018).


Figure 1.4: Illustration of DBMN logistical arrangements linking Windhoek (HQ), Oranjemund Airport (Logistics Aviation Base), Offshore

Operations (ML 47 Mining and Exploration), Cape Town and the Port of Lüderitz (Logistics Shore Bases).


1.5 Purpose of this EMP Report This report has been prepared in order to support the application for the Environmental Clearance Certificate (ECC) for DBMN (Proponent) proposed upgrading of the Lüderitz Logistics Shore Base (LLSB) inside the Port of Lüderitz. The preparation of this report took into consideration the provisions of the following key documents:

Environmental Management Act, (Act No. 7 of 2007);

Environmental Impact Assessment (EIA) Regulations, 2012;

DBMN Environmental Management System, Environmental and Sustainability Policies as well as all other related operational and contractual obligations, and;

NamPort Environmental Management Systems, operational and corporate requirements and standards.

1.6 Structure of the Report

The following is the summary structure outline of this EMP report: Section 1: Background covering the proposed project location;

Section 2: Approach and Methods summarises the approach and methodology adopted

in the preparation of the report;

Section 3: Environmental Management Plan (EMP) Frameworks detailing key mitigation measures

Section 4: Environmental Performance Monitoring outlining the performance monitoring

and reporting requirements;

Section 5: Conclusions and Recommendations - Summary of the findings and way forward.

ANNEXES:


ENVIRONMENTAL ASSESSMENT

Submission of

Project

Proposal

Register Project

with DEA/MET

Classification of

Proposal

Terms of Reference

Development of ProposalNotify Interested and Affected Parties (I&APs);

Establish policy, legal and administrative

requirements; Consult relevant Ministries/I&APs;

Identify alternatives and issues

Scoping

Public Participation

Draft Scoping Report (SR)

Submit Draft SR to

Authorities & I&APs

DEA/MET to issue

Record of

Decision (RoD)

InvestigationSpecialist Studies

Report

Draft Environmental Impact

Assessment (EIA) & Environmental

Management Plan (EMP)

Submit Draft EIA &

EMP to

Authorities & I&APs

Finalize EIA &

EMP and submit to

DEA/MET

DEA/MET

to issue RoD

Finalize SR and

submit to DEA/MET

Implement, Monitor

and Audit

ApprovedNot Approved

APPEAL

Significant Impact

2. APPROACH AND METHODS

2.1 Overview The preparation of this EMP report has taken into considerations the provisions of the Environmental Impact Assessment (EIA) Regulations No. 30 of 2012 gazetted under the Environmental Management Act, (EMA), 2007, (Act No. 7 of 2007) and DBMN Corporate and environmental requirements and policies. The EMP has been prepared in line with the January 2015 Ministry of Environment and Tourism (MET) Environmental Assessment Reporting Guideline. Fig. 2.1 summarises the Environmental Assessment process in Namibia as adopted for this project.

Figure 2.1: Summary of the environmental assessment process in Namibia.

2.2 Terms of Reference for this Report Summary of the proposed activities, alternatives and key issues considered during the Environmental Assessment (EA) process covering EIA and EMP stages are provided in Table 2.1 (Annex 1).


Table 2.1: Summary of the proposed activities, alternatives and key issues considered during the Environmental Assessment (EA) process covering EIA and EMP phases.

PROPOSED PROJECT

ACTIVITIES

ALTERNATIVES CONSIDERED

KEY ISSUES TO BE EVALUATED AND ASSESSED WITH ENVIRONMENTAL MANAGEMENT PLAN (EMP) /

MITIGATION MEASURES PREPARED

(i) Preconstruction:

Planning, designing and permitting; Mobilisation and implementation;

Site access plan and surveying;

Determination of locally available construction materials (sand / gravel) excavations, and;

Demolition / excavations and erection of security and safety zones.

(ii) Construction:

Soil / ground preparation and supporting Infrastructure construction;

Foundation excavations and building;

Structural development / Actual construction;

Supporting infrastructure (internal access, energy requirements, water supply, waste water management and solid waste management).

(iii) Operational:

Day to day running of the Lüderitz Logistic Shore Base by DBMN supporting the Port of Lüderitz (NamPort) and the Town of Lüderitz and surrounding areas and generating liquid and solid waste, noise, dusty, interact with local people, visitors, wild life and the broader natural receiving environment.

(i) Location of the proposed Logistic Shore Base (Cape Town, Walvis Bay or Lüderitz) and the actual site location within the Port of Lüderitz as well as the actual location / placement of the various infrastructures within the allocated land

(ii) Other Alternative Land Uses: Conservation and Tourism

(iii) Ecosystem Function

(What the Ecosystem Does

(iv) Ecosystem Services (v) Use Values (vi) Non-Use, or Passive

Use

(vii) The No-Action Alternative

(viii) Others to be identified

during the public consultation process

Potential land use conflicts / opportunities for coexistence between proposed activities and other existing land uses such as conservation, tourism and urban development

Physical Environment

1. Land and marine water pollution 2. Disturbance / disruption of the

surrounding Lüderitz area including the supporting infrastructure

3. Visual and land degradation 4. Air quality, noise and dust 5. Increased local resource use

(energy and water) 6. Refuelling spillages and accidents 7. Solid and liquid waste

management 8. Climate change influences.

Biological Environment

1. Disruption / disturbance of the coastal and marine habitats within the Lüderitz Logistic Shore Base (Port of Lüderitz) developmental and surrounding areas (Lüderitz Town)

2. Disturbance of coastal and marine fauna and birds

3. Protected areas and resources 4. Ecosystem functions, services,

use values and non-use or passive use.

Socioeconomic, cultural and archaeological environment

1. Local, regional and national socioeconomic settings

2. Tourism and recreation 3. Cultural, biological and

archaeological resources

Environmental Management Plan (EMP) Providing Mitigation Measures and Monitoring Plan

Mitigation shall focus on the following in order of preference: 1. Enhancement, e.g. provision of

new habitats; 2. Avoidance, e.g. alternative /

sensitive design to avoid effects on ecological receptors;

3. Reduction, e.g. limitation of effects on receptors through design changes; and

4. Compensation, e.g. community benefits such as a water well being provided.

2.3 Environmental Assessment Process

2.3.1 Summary of the Approach

The following assessment steps as recommended in the Scoping Report/ BID were implemented (Annex 1):

(i) Project screening process was undertaken in July 2019;

(ii) A Draft Environmental Scoping Report / Background Information Document (BID) prepared in August 2019;


(iii) The Project was registered with the Environmental Commissioner in the Ministry of

Environment and Tourism through the Ministry Work and Transport (Competent Authority) in August 2019 under the application No. APP-00444;

(iv) During the month August 2019 public / stakeholders notices were published in the local

newspapers;

(v) Preparation of the Final Scoping Report / BID, Draft EIA and EMP Reports was undertaken during the month of August 2019;

(vi) The final EIA and EMP Reports were finalised and submitted to the Environmental

Commissioner in the Ministry of Environment and Tourism (MET) through the Competent Authority Ministry Work and (Transport) by the week starting 2nd September 2019.

2.3.2 Assumptions and Limitations

The following assumptions and limitations underpin the methodology and approach that has been adopted for this study, the overall outcomes and recommendations thereof:

The proposed activities, plans, maps, site boundary / coordinates, appropriate data sets guidelines received from the proponent, project partners, regulators are assumed to be current and valid at the time of compilation of the Scoping, EIA and EMP reports;

The impact assessment outcomes, mitigation measures and recommendations provided are

valid for the entire duration of the proposed activities covering the preconstruction, construction and operational stages;

A precautionary approach has been adopted in instances where baseline information was

insufficient or unavailable or site-specific mitigation measures cannot be provided, and;

Mandatory timeframes as provided for in the Environmental Impact Assessment (EIA) Regulations No. 30 of 2012 and the Environmental Management Act, (EMA), 2007, (Act No. 7 of 2007) have been observed and will apply to the review and provision of the Records of Decisions by the Competent Authority and the Environmental Commissioner.

2.4 Public and Stakeholders Consultation Process

2.4.1 Overview

During the consultations process Draft Scoping, EIA and EMP Reports as well as the Public Notices published in the local newspapers have been the key sources of information for the public and all the stakeholders. Although a written commenting is sufficient to meet the legal requirements, it might in certain cases be appropriate to convene public meetings, especially for activities which might affect intensively the interests of stakeholders. If meetings are held for public commenting, smaller, focused meetings may be preferable to ensure adequate time for comment, rather than larger meetings where few people have the opportunity to speak. There is a variety of ways to gather opinion from the more vulnerable groups and ensure that they can meaningfully participate, e.g. use of community representatives such as councillors and traditional authority leadership, interviews and meetings. Beside the public review of the reports, there are other stages, which are relevant for consultation. During the review process the Office of the Environmental Commissioners (OEC) has the right to convene a further public hearing. Taking this into account, public consultation is more a cross-cutting process during the whole environmental assessment process rather than a particular step linked to the specific stage of the assessment. The scoping report / ToR included provisions on the concrete public consultation measures implemented as part of the assessment process.


2.4.2 Objective of Conducting Public and Stakeholder Consultation Process

The overall objectives of conducting public and stakeholder consultation process is to inform, identify and request Interested and Affected Parties (I&APs) to submit written inputs, comments or objections about the proposed project activities, disclose the Terms of Reference, the assessment and management reports.

2.4.3 Consultation Activities, Timing and Outcomes

The type of activities undertaken during the implementation of the Scoping, EIA and EMP consultation processes and details of the entire process are provided in Table 2.2. Risk-Based Solutions (RBS) had the overall responsibilities for implementing the stakeholder consultation process as part of the Scoping, EIA and EMP process as was required by the regulations as well as DBMN corporate requirements. The RBS staff members led by Dr. Vita Stankevica supported by Ms. Christine Links and Ms. Meriam Kauyama were responsible for the implementation of the consultation process. Stakeholder communications as well as drafting of all technical reports, document and letters were being managed by Dr. Sindila Mwiya, the Projects Director. DBMN provided all the applicable proposed project specific information such as the site boundary, drawings and design and engineering specifications. In line with the provisions of the regulations, the public notices have been published in the Confidente Weekly Newspaper dated 8th- 14th August 2019 (Fig. 2.2), the Windhoek Observer Weekly Newspapers dated Friday 16th August 2019 (Fig. 2.3) and the Namibian Daily Newspaper dated Thursday 22nd August 2019) (Fig. 2.4). Deadline for registration and submission of written objections, comments, inputs to the environmental assessment process is the 30th August 2019. Despite the publication of highly visible (half page) public notices in the three (3) newspapers as shown in Figs. 2.2-2.4, no written I&APs / stakeholders registrations or written objections, comments or inputs were received during and after the consultation period undertaken for the month of August 2019.


Table 2.2: Summary of the Interested and Affected Parties (I&APs) consultation activties undertaken during the month August 2019.

SCOPING, EIA AND EMP PROJECT CONSULTATION ACTIVITIES

SCOPING STAGE INFORMATION TO DISCLOSED

RESPONSIBILITY

ACTIVITIES TIMING

July 2019

Aug 2019

Sep 2019

Oct 2019

1. Project screening

2. Prepared Summarised Background Information Document (BID) and Posters

3. Prepared Public Advert and published in the Local Newspapers

4. Opened a Stakeholder Register (no registration received)

5. Registered the project with the Environmental Commissioner in the Ministry of Environment and Tourism via Ministry of Works and Transport

6. Published Public Advert / Notice to in the Local Newspapers: Note:

Published to at least three newspaper circulated widely in Namibia

Twenty (21) days for input period from the date of 1st publication

7. Prepare Final Scoping/ BID, Draft EIA and EMP Report

8. Updated and finalized the Draft EIA and EMP Reports as was applicable

9. Submitted the Application for ECC to the Environmental Commissioner supported by the final EIA and EMP Reports

1. Background Information Document (BID) summarising the proposed project

2. Draft Scoping Report with Terms of Reference (ToR) for EIA and EMP

3. Draft EIA and EMP Reports

Risk-Based Solutions (RBS) will undertake the activities on behalf of DBMN

DBMN will provide all the applicable proposed project specific information such as the site location and the type of activities to be undertaken.


Figure 2.2: Copy of the 1st Public Notice was published in the Confidente Weekly Newspaper 8th – 14th August 2019.


Figure 2.3: Copy of the 2nd Public Notice that was published in the Windhoek Observer Weekly Newspaper dated Friday, 16th August 2019.


Figure 2.4: Copy of the 3rd Public Notice that was published in the Namibian Daily Newspaper dated Thursday, 22nd August 2019.


2.5 Impact Assessment and Management Criteria 2.5.1 Environmental Impact Assessment Rankings

To ensure consistency in the evaluation of environmental impacts associated with DBMN’s activities for all of their operations, the rating criteria for the impact assessment for the proposed LLSB has been standardised to include a set definitions applied in the risk assessment (Table 2.3). To the extent possible, allocation to rank categories is based on quantifiable criteria which can be measured as detailed in Table 2.3. Furthermore, when evaluating impacts, the allocated ranks refer to the resultant impact (e.g. habitat area affected, or time that the result of the impact will last), and not of the cause thereof (e.g. time of active impact). Each activity has been assessed with respect to the type of effect that the aspect will have on the relevant component of the receiving environment (physical, biological and socioeconomic components) and includes “what will be affected and how?” The criteria used to determine the significance rating of the impact(s) is detailed in Table 2.4. Table 2.3: Definition of impact assessment categories.

Rating Definition of Rating

Status of the Impact – in terms of meeting the objective of maintaining a healthy environment.

Positive The impact benefits the environment

Negative The impact results in a cost to the environment

Neutral The impact has no effect

Probability – the likelihood of the impact occurring

Negligible Possibility negligible

Improbable Possibility very low

Probable Distinct possibility

Highly Probable Most likely

Definite Impact will occur regardless of preventive measures

Degree of confidence in predictions – in terms of basing the assessment on available information

Low Assessment based on extrapolated data

Medium Information base available but lacking

High Information base comparatively reliable

Extent – the area over which the impact will be experienced

Site specific Confined to within < 1 km of the project

Local Confined to the study area or within 5 km of the project

Regional Confined to the region, i.e. > 5 km but < National

National Nationally

International Beyond the borders of Namibia

Duration – the time frame for which the impact will be experienced

Very short Less than 2 years

Short-term 2 to 5 years

Medium-term 6 to 15 years

Long-term More than 15 years

Permanent Generations

Intensity – the magnitude of the impact in relation to the sensitivity of the receiving environment

Negligible Natural functions and processes are negligibly altered due to adaptation by the receptor(s) to high natural environmental variability

Mild Natural functions and processes continue albeit in a modified way that does not appear to

have a significant disruptive effect (i.e. changes are temporary)

Moderate Natural functions and processes continue albeit in a modified way that does appear to have a

noticeable disruptive effect (i.e. changes are permanent)

Severe Natural functions or processes are altered to the extent that they temporarily cease resulting in severe deterioration of the impacted environment

Very Severe Natural functions or processes permanently cease or are completely disrupted


Table 2.4: The criteria used to determine the significance rating of the impact(s).

Low: Where the impact will have a negligible influence on the environment and no modifications or mitigations are necessary for the given project description. This would be allocated to impacts of any severity/ magnitude, if at a local scale/ extent and of temporary duration/time.

Medium: Where the impact could have an influence on the environment, which will require modification of the project design and/or alternative mitigation. This would be allocated to impacts of moderate severity, locally to regionally, and in the short term.

High:

Where the impact could have a significant influence on the environment and, in the event of a negative impact, the activity(ies) causing it should not be permitted without substantial mitigation and management, and pro-active rehabilitation commitments (i.e. there could be a ‘no-go’ implication for the project). This would be allocated to impacts of severe magnitude, locally over the medium-term, and/or of severe magnitude regionally and beyond.

2.5.2 Environmental Management Plan (EMP) Framework

Environmental management plans have only been developed to ameliorate aspects / risks of medium to high significance identified through the impact assessment. In line with DBMN environmental management system, management plans included in this report are divided into two (2) categories and these are:

(i) Strategic management plans which form part of this EMP report and range from 2 years up to the end of the life of the mine, and;

(ii) Short term plans concerned with day-to-day operations, which include areas such as codes of practice, specific responsibilities and monitoring which are integrated separately into the Environmental Management System.

The overall focus of the EMP framework has been to development mitigation measures appropriate for each activity with medium to high significant impact on the receiving environment. Mitigation is the purposeful implementation of decisions or activities designed to reduce the undesirable impacts of a proposed action on the affected environment. A hierarchy of methods for mitigating significant adverse effects that adopted in order of preference are:

(i) Enhancement, e.g. provision of new habitats;

(ii) Avoidance, e.g. sensitive design to avoid effects on ecological receptors;

(iii) Reduction, e.g. limitation of effects on receptors through design changes, and;

(iv) Compensation, e.g. community benefits.

2.2.3 DBMN Environmental Management System (EMS)

This EMP report shall be integrated in the DBMN’s ISO 14001 Environmental Management Systems (EMSs). Fig. 2.5 shows the EMP as part of the overall ISO 14001 EMS. The implementation of Environmental Management System (EMS) of DBMN is guided by the following policies:

DBMN's Environmental Policy;

DBMN’s Sustainability Statement Policy;

De Beers Group Environmental Policy;

De Beers Group Occupational Health Policy, and;

De Beers Group Safety Policy.


Figure 2.5: Illustration of environmental assessment, management and monitoring as part of the overall ISO 14001 Environmental Management

System adopted by DBMN.


3. EMP FRAMEWORK

3.1 Overview DBMN's environmental management plan outlines how the company intends to manage all its activities associated with the proposed upgrading of the Lüderitz Logistic Shore Base (LLSB) in the Port of Lüderitz that will significantly impact on the environment, or that may potentially be of high risk in the short and long-terms. Through the implementing this EMP, DBMN will minimise and maximise the negative and positive effects respectively, of its operations on the receiving environment directly or indirectly linked to the LLSB (Port of Lüderitz). DBMN’s commitments to responsible and sound environmental management of all their activities are reflected in the company’s Environmental Policy, ISO 14001 Environmental Management System (EMS) and in the Safety, Health, Environmental and Security Policy. DBMN operates a certified ISO 14001 EMS which is certified by the South African Bureau of Standards and ongoing surveillance audits ensure compliance to these requirements. A summary of DBMN's EMS is presented in this document in the form of the Company's Environmental Manual with all the applicable legislation, regulations and policies with respect to the EMP. It is envisaged that the Environmental Management Plan for the upgrading of the LLSB (Port of Lüderitz) can be successfully integrated with DBMN’s ISO 14001 Environmental Management System (EMS) for effective monitoring.

3.2 EMP for Upgrading of Lüderitz Logistic Shore Base (LLSB) In accordance with the results of the impact and risk assessment for the proposed upgrading of the LLSB (Port of Lüderitz) as detailed in the EIA Report, detailed Environmental Management Plan (EMP) have been prepared covering the following components as presented in Table 3.1 – 3.5:

(i) General company procedures for EMP implementation in line with DBMN operations and EMS (Table 3.1);

(ii) Implementation of the Environmental, Health and Safety (HSE) management systems,

procedures and operational requirements (Table 3.2);

(iii) Protection of the coastal and marine fauna and birds due to increased activities within the Port Area due to DBMN and other operators (Table 3.3);

(iv) Enhancement of the socioeconomic components (Table 3.4), and;

(v) Alignment of Mine Closure and sustainability of the Lüderitz Logistics Shores Base

infrastructure developed (Table 3.5). Each of the EMP Table 3.1 – 3.5 framework covers aspect, impact description, risk / gain ranking, action plans and control measures, responsible person(s), timing, management objectives and applicable regulations.


Table 3.1: General company procedures for EMP implementation in line with DBMN operations and EMS.

# ASPECT IMPACT

DESCRIPTION

RISK / GAIN

RANKING ACTION PLANS AND CONTROL MEASURES

MANAGEMENT OBJECTIVES

RESPONSIBLE PERSON(S)

TIMING

1.1

Implementation of the environmental management policy and procedure

Improved Environmental Management and Awareness

High

Define the roles and authorities of staff members (and any specialist consultants) responsible for implementation of the various facets of this EMP.

Address training needs of staff required to implement specialised aspects of the EMP.

Maintain records of plans, decisions, data collected, communications made, emergency responses, etc., which document the implementation of the EMP.

The EMP process is

employed, so that

operations are

conducted in an

environmentally

responsible manner

All action plans

outlined in this EMP

are achieved,

including continued

consultation with all

stakeholders and

compilation of

Performance

Assessments

ISO 14001 certified

Environmental

Management

Systems are

maintained for all

certified areas of

activities

An ethic of

environmental

responsibility is

Environmental Manager

Ongoing

1.2

Awareness and Internal communication about the EMP

High

All personnel will be made aware of the contents of DBMN’s Environmental Policy Statements.

All personnel who are in a position to make decisions or take actions that will influence environmental protection and management will be made aware of the contents, and their respective responsibilities for implementation, of the EMP.


Ongoing

1.3 Instructions to all staff, including contractors

High

Provide instructions and appropriate training to all staff about aspects of the EMP that affect their specific work, including hydrocarbon pollution prevention and clean-up, general waste management, protection of natural resources, and rehabilitation.

Conduct an environmental awareness and sensitivity of the coastal and marine environment around the Port of Lüderitz.

Prior to working in the area all contractors must undergo an environmental and safety induction with daily debriefings.

Incorporate environmental aspects and management interventions applicable to particular outsourced tasks into contracts and performance appraisals to improve environmental awareness and performance, and specify penalties for non-compliance.

Report all environmental incidents as specified in the Company Procedures.


Ongoing

1.4

EMP Monitoring and Performance Assessments

High Undertake to conduct EMP monitoring on a

continuous basis using the mechanism of DBMN’s ISO14001 Environmental Management System.


First due 6 months after EMP


# ASPECT IMPACT

DESCRIPTION

RISK / GAIN




TIMING


Undertake formal EMP performance assessments every 6 months to check progress in meeting the objectives and targets of this EMP,

Compile and submit EMP Performance Assessment Reports to the Ministries of Environment & NamPort containing as a minimum the following information:

o Information regarding the period applicable to the assessment

o Scope of the assessment

o Procedure used for the assessment

o Interpreted information gained from monitoring

o Evaluation criteria used

o Results of the assessment

o Recommendations on how and when non-compliances or deficiencies will be rectified.

Submit revised and amended Environmental Management Programme Reports to NamPort and the Environmental Commissioner: Environment and Tourism as and when required / as provided for in the Environmental Clearance Certificate (ECC) Conditions.

Request MET and NamPort to respond to the submitted reports within 4 months; beyond which time it will be assumed to have been accepted as is.

instilled in all staff and

contract workers

Adequate provision is

planned and made for

rehabilitation and

restoration of impacts

approval date


# ASPECT IMPACT

DESCRIPTION

RISK / GAIN




TIMING

1.5 EMP Updates


High

On an ongoing basis, assess the applicability of actions and activities required by the EMP, identify and address all new environmental issues arising from changed operations and/or communications with interested parties, through updates to the EMP if/where necessary.

Communicate and consult with I&APs through appropriate fora to inform them of proposed changes and address any concerns.

Amend and update this EMP, if required and submit to Ministry of Mines and Energy and Ministry of Environment and Tourism (Department of Environmental Affairs) for approval.

Request for responds to the submitted report within 4 months.


Ongoing

1.6 Communications with stakeholders

Improved stakeholder relationships

High

Maintain an up-to-date I&AP database.

Maintain open communication with the relevant stakeholders listed in DBMN database informing them of proposed changes to the EMP, addressing any issues of concerns that may arise, maintain records of communications, and where relevant, address their needs.

Participate actively in appropriate fora to share information and co-operate with other stakeholders and resource managers in the marine environment.


Ongoing

1.7

Pecuniary provision/ allocation of environmental management funding

Improved Environmental Management

High

Allocate operational costs to maintain an ISO14001 system and to meet EMP objectives, including all associated requirements, e.g. funding of research and monitoring to understand, and where possible, mitigate impacts.


Ongoing

Maintain Protection and Indemnity (P&I) Insurance Cover of US$ 700 million to allow for clean-ups in the event of oil spills, and unlimited (P&I) Insurance Cover for other eventualities.

Business Planning Manager

Ongoing


Table 3.2: Implementation of the Environmental, Health and Safety (HSE) management systems, procedures and operational requirements.

# ASPECT IMPACT

DESCRIPTION RISK / GAIN RANKING

ACTION PLANS AND CONTROL MEASURES MANAGEMENT OBJECTIVES


TIMING

2.1

Maintain Environmental Management System (EMS)

Improved Environmental Management

High

Ensure that all requirements of the Company’s ISO14001 Environmental Management System are met, including compliance with legislation, environmental awareness training, environmental monitoring, waste management and pollution control and NamPort requirements.

Ensure that external Surveillance and re-certification Audits are conducted by an accredited ISO14001 certifying body.

Submit copies of External Audit Reports with Environmental Performance Reports

An ISO14001 certified Environmental Management System for all areas of the company’s activities is maintained

There is compliance with national and international maritime and NamPort requirements

There is compliance with all national standards related to or associated with the operations of the an LLSB in the Port of Lüderitz such as environment, water, air quality, waste management, pollution management and all applicable components as may be required by NamPort the Lüderitz Town Council


Ongoing

2.2 Integration of Environmental Management

High

Include environmental management in DBMN’s Strategic Long-term Business Plan, by integrating environmental management linked to the operations of the LLSB

Integration of future mine operations with the proposed LLSB long-term sustainability


Ongoing

2.3

Establishment and review of Environmental Risks and Improved Environmental Performance

High

Develop a set of environmental risks (using standard risk assessment methodology), to be reviewed and, where necessary, updated in line with Environmental Aspects Procedure.

Adopt a more results-driven research and monitoring approach, focusing attention specifically on fauna, flora and biodiversity related impacts of potentially medium and high risk, and how best to mitigate for these.

Improve on performance reporting by determining key indicator species by which recovery rates of impacted areas can be determined more effectively.


Environmental Scientist

Ongoing

2.4 Maintain Safety Management System (SMS)

Improved Health and Safety

High Maintain high safety standards for the operations of the

LLSB

Chief Safety Officer

Ongoing

2.5

Comply with the national and international requirements and operational standards

Improved Health and Safety

High Ensure compliance with the national and international

maritime, NamPort and Lüderitz Town Council requirements

Operations Manager

Ongoing

2.5

Comply with all other applicable national regulations operational standards

Improved Environmental Management, Health and Safety

High

Ensure compliance with all other national legislations, regulations and NamPort and Lüderitz Town Council requirements and standards


Ongoing


Table 3.3: Protection of the coastal and marine fauna and birds due to increased activities within the Port Area due to DBMN and other operators.

# ASPECT IMPACT DESCRIPTION RISK / GAIN RANKING

ACTION PLANS AND CONTROL MEASURES



TIMING

4.1

Increased activities within the Port Area due to DBMN and other operators

Disturbance of coastal and marine fauna and birds

Medium

Ensure that all operations are undertaken in accordance with the provisions of this EMP, NamPort and DBMN procedures and EMSs requirements and protocols

Disturbance of

coastal and

marine fauna

and birds is

minimised

Environmental Managers for NamPort and DBMN

Ongoing

Ongoing

Table 3.4: Enhancement of the socioeconomic issues.

# ASPECT IMPACT

DESCRIPTION

RISK / GAIN




TIMING

4.1 Environmental Communication

Improved Environmental Awareness

High

Improve stakeholder relationships by maintaining open communication with relevant I&APs on issues that may arise, and where relevant, address their needs.

Keep a record of all communications with I&APs, the points raised, and how these points have been addressed.

Economic benefits to people of Namibia optimised, where feasible

A balance between economic, social and environmental responsibilities is struck

Opportunities provided for local business, industrial relations promoted, and contribution to socioeconomic stability

Training and development

Environmental Manager(s) and Contracted Consultants

Done as part of Public Scoping

Environmental Manager(s)

Ongoing

Report to the relevant stakeholder on new activities with potential environmental impacts.


Ongoing

Publicise and make available information on DBMN’s environmental monitoring programmes and environmental performance.


Ongoing

Where feasible, comply with the local development objectives, spatial development framework and integrated development planning of the area, and promote co-operative governance and integrated decision-making.

Environmental Manager (s)

Ongoing

4.2 Employment

Boosts Namibian economy and development of skills

High

Continue to increase number of Namibians employed by De Beers Marine Namibia, and to provide them with training to develop skills.

Maintain LLSB operations and infrastructure.

Outsource services where possible.

Include local Small and Micro enterprise service providers in the tendering process for supplies and services, giving preference to companies with a labour-intensive focus and Black Economic Empowerment

Human Resources Manager

Ongoing


# ASPECT IMPACT

DESCRIPTION

RISK / GAIN




TIMING

(BEE) companies.

Where possible, develop and support Small and Micro Enterprises, in order to provide employment opportunities.

opportunities provided for all staff

Relevant stakeholders consulted on a regular basis

Good working and living conditions for DBMN employees promoted and maintained

4.3

Contribution to Oranjemund Lüderitz communities and //Karas Region

Medium to

High

Minimise net loss of employment opportunities either within DBMN or via potential contracts.

Give hiring priority to suitably qualified or experienced local Namibian citizens, as positions become available.


Ongoing

Within the resources available to DBMN, support appropriate initiatives to improve community welfare, particularly in the Town of Lüderitz.

Ensure that DBMN’ s wellness programme covers all workers in the area.

Consider expanding some wellness programme interventions to sub-contractors.

Financial Manager


Ongoing

4.4 Taxes / royalties

Contribution to national economy

High

Pay all applicable taxes and royalties to the government as required.

Pursue targets and standards set out in the DBMN Strategic Business Plan.

Maintain or increase current level of production.

Internally track the efficiency to ensure maintenance of profits.

Financial Manager Ongoing

4.5

Training and skills transfer

Contribution to Namibian training, education and research

High

Continue to provide employees with training to develop skills by:

o Addressing training needs of all staff required to implement specialised aspects of LLSB.

o Conducting environmental awareness and health and safety awareness programmes.

Incorporate environmental aspects and management interventions applicable to particular outsourced tasks into contracts and performance appraisals to improve environmental awareness and performance.

Emergency preparedness and response teams/contractors are to train employees and contractors on appropriate skills.



Ongoing

4.6 Research and development

Technological advancements in exploration, diamond recovery and LLSB operational systems

High Continue to develop prospecting, diamond recovery and

metallurgical technologies for marine diamond recovery long-term sustainability

Operations Manager

Ongoing


# ASPECT IMPACT

DESCRIPTION

RISK / GAIN




TIMING

4.7

Sponsorships of research, education and community projects

Improved environmental knowledge/awareness of the region

High

Where possible, sponsor Namibian research and education to contribute to public understanding of relevant environmental issues and environmental management practices e.g. invite scientists to participate in environmental surveys and share knowledge on findings including contributions to biodiversity.

Continue with regular activities initiated by other parties such as NamPort and Lüderitz Town Council and Non-Governmental Organisations (NGOs) and civil society initiatives involving school children) in different areas, including those areas outside DBMN’s responsibility (e.g. clean-up campaign).

Provide social contributions to research, educational and community projects in Lüderitz and the //Karas Region.

Environmental Scientist


Ongoing


Table 3.5: Alignment of the Mine closure and sustainability of the LLSB developed infrastructure.

# ASPECT IMPACT DESCRIPTION

RISK / GAIN RANKING



TIMING

5.1

Closure of DBMN Operations including the LLSB

Termination of all contributions to the economy including taxes, employment, support to secondary industries

High

As an interdisciplinary initiative between all involved DBMN internal and external stakeholders, undertake to develop a Rehabilitation and Closure Plan, which gives attention to:

o Approximate dates of progressive or partial closure applications,

o Objectives of closure planning, o Relevant decommissioning and rehabilitation monitoring

programmes, o Financial provisioning for mine closure, o Provisioning for the development of a social and labour

plan for closure, o Identification of end use of the LLSB, o Rehabilitation actions required to obtain end use of the

LLSB, o Human resources and community plan of action, o Communication strategy, and o Actions required for sustainability.

All closure objectives outlined in the rehabilitation and closure plan, and in the social and labour plan, are met

Ensure that the LLSB infrastructures are all in good working condition before handover to NamPort at mine closure in order to ensure that the LLSB infrastructure continue contributing to socioeconomic development of Lüderitz, //Karas Region and Namibia


Operations Manager

Ongoing

5.2 Closure Planning

Improved management of closure and rehabilitation

High

Ensure that closure planning continues throughout the life of the operation.

Gather relevant information throughout the life of mine to ensure that environmental risks are quantified and managed proactively.

Make provision as part of ongoing environmental management for post-mining surveys of selected areas to demonstrate recovery (3-5 year intervals).

Ensure that Safety and Health requirements are complied with.


Operations Manager

Ongoing

5.3 Closure Certificate


High

When DBMN intend closing operations, a final EMP performance assessment should be conducted to ensure that:

o The requirements of the relevant legislation have been complied with;

o The research and monitoring that has been conducted (including the total area disturbed) is summarised;

o The closure objectives as described in the closure plan have been met; and


On Closure


# ASPECT IMPACT DESCRIPTION

RISK / GAIN RANKING



TIMING

o All residual and latent environmental impacts and the risks thereof occurring have been identified, quantified and arrangements for the management thereof have been finalised.

When applying for closure, submit the following documentation to the Lüderitz Port Captain (NamPort), Executive Directors (EDs) at the Ministry of Works and Transport and the Ministry of Environment and Tourism:

o The Closure Plan

o An Environmental Risk Report

o The Final Performance Assessment Report

An application form to transfer environmental responsibilities and liabilities, if such transfer has been applied for.

5.4 Financial Provisioning


High

Ensure that requirements in terms of financial provision for remediation of environmental damage are met by:

Allocate operational costs to maintain an ISO14001 system and to meet EMP objectives, ensuring that potential environmental impacts are integrally managed or monitored in such a way as to prevent or minimise them.

Maintain adequate Protection and Indemnity (P&I) Insurance Cover to allow for cleanups in the event of oil spills and other eventualities.

Allocate operational costs to monitor and demonstrate natural recovery of the seabed through pre- and post-mining benthic faunal and seabed surveys.

Provide sufficient funds for a post-closure environmental survey before the handover of the LLSB infrastructure to NamPort.

Financial Manager

Ongoing


4. ENVIRONMENTAL PERFORMANCE MONITORING

4.1 Overview As per the provisions of the EMP, the environmental performance monitoring activities are recommended to be undertaken during the preconstruction, construction and operational stages of the proposed LLSB infrastructure development because this approach makes it possible to identify unpredicted effects and take the necessary precautions to eliminate the likely negative impacts before the effects become significant. The following is summary of the environmental performance monitoring to be undertaken:

Monitoring Plan: Environmental monitoring is partly in-house (data collection during preconstruction, construction and operational) and outsource (employ a consultant) to undertake the assessment and recommend measures to be implemented in line with the DBMN and NamPort EMSs requirements;

Implementation of the EMP: The implementation of the EMP monitoring plan by DBMN shall be focused on collecting and analysing the required datasets and propose recommendations on what needs to be done for both the long-term and short (day to day) monitoring operations. The EMP implementation shall be undertaken as an in-house activity in line with the DBMN and NamPort EMSs requirements;

EMP Auditing: Compliance auditing of the EMP implementation and monitoring thereof is a key component of the environmental performance monitoring and management system. The EMP auditing is an internal activity that shall be often supported by an external consultants as may be required and linked to the EMSs monitoring and auditing requirements, and;

EMS Auditing: Personnel within DBMN are responsible for the management of these impacts through regular environmental audits to evaluate compliance and effectiveness of the company's EMS to the ISO 14001 standard, as well as compliance with NamPort operational requirements and statutory requirements. This includes both internal audits and external surveillance audits linked to NamPort requirements.

4.2 Environmental Monitoring Plan

4.2.1 Objectives of the Monitoring Plan

The main objectives of the monitoring plan are the following:

Verify of the correct application of the monitoring measures as presented in the Environmental Management Plan (EMP);

Establish a monitoring program for the most relevant environmental data sets, parameters,

identifying the monitoring activities and frequencies;

Identify the impacts foreseen by the project and any unforeseen deviations, allowing for the implementation of corrective measures as needed;

Provide assurance to stakeholders requirements with respect to environmental and social

performance;

Check the overall effectiveness of the operational procedures in protecting the receiving environment;

Comply with regulations, standards and conditions, and;


Compare actual impacts with those predicted in the EIA Report and thereby aim to improve the

assessment and monitoring processes.

4.3 Monitoring Quality Control Measures

4.3.1 DBMN Marine Scientific Advisory Committee

The Marine Scientific Advisory Committee (MSAC) has been set up to provide advice to DBMN regarding the environmental impacts of marine diamond recovery and the associated monitoring programme and ensure that this advice is based on the best available scientific information at any given time. The MSAC shall provide guidance on the monitoring measures and improvements thereof with respect to the LLSB operations.

4.3.2 EMS Auditing

DBMN is committed to conducting regular environmental audits to evaluate compliance and effectiveness of the Company's EMS to the ISO 14001 standard, as well as compliance with applicable legal and other operational requirements. This includes both internal audits and external surveillance and certification audits. The following four (4) tier system of environmental auditing has been implemented at DBMN and applicable to the operations of the LLSB:

(i) Internal area environmental audits (conducted by the environmental monitors on either a monthly or quarterly basis);

(ii) Environmental management team audits (conducted by members of the Environmental

Management Team for each area);

(iii) Environmental surveillance audits (conducted by external auditors once a year); and;

(iv) National Occupational Safety Association (NOSA) grading audits, which deal with environmental protection, emergency procedures, drills and equipment as well as accident reporting and investigation.

4.3.3 Environmental Performance Monitoring Report

Based on the results of the ongoing environmental monitoring activities and in accordance with the provisions and conditions of the Environmental Clearance Certificate (ECC), Environmental Performance Monitoring Reports shall be compiled and submitted to the Environmental Commissioner, Department of Environmental Affairs, Ministry of Environment and Tourism and Ministry of Works and Transport / NamPort, demonstrating compliance with the EMP, legal and other operational requirements, and ongoing assessment of risks / aspects.


5. CONCLUSIONS AND RECOMMENDATIONS

5.1 Conclusions The proposed Lüderitz Logistics Shores Base (LLSB) area falls within the NamPort operated Port of Lüderitz which is an industrial area of the Town of Lüderitz. The proposed LLSB site allocated by NamPort to DBMN for the development of the LLSB infrastructure is not pristine. Based on the low sensitivity of the receiving environment (physical, biological and socioeconomic) and the low /negligible and medium to high negative and positive impacts results respectively, it’s hereby concluded that the proposed upgrading of the LLSB shall go-ahead and will coexists with other port operations and the receiving environment.

5.2 Recommendations Based on the results of this Environmental Management Plan (EIA) report, it’s hereby recommended that the proponent (DBMN) be issued with an Environmental Clearance Certificate (ECC) for the proposed upgrading of the Lüderitz Logistics Shore Base (LLSB) in the Port of Lüderitz, Lüderitz, //Karas Region, South Namibia. Mitigation measures / appropriate management intervention measures to be implemented by DBMN with respect to the impacts ranked as having either a “high” or “medium” significance are provided in the EMP Section of this Report covering the preconstruction, construction and operational phases of the proposed LLSB infrastructure development. Occupational Health and Safety (OHS) is key components of the LLSB and Port of Lüderitz safe operations. Workers must use Personal Protective Clothing / Equipment at all times, site equipment / vehicles movement procedures and protocols and all the related activities shall be undertaken in accordance with DBMN and NamPort corporates requirements, environmental standards and management systems. The Environmental Performance Monitoring activities shall be undertaken by DBMN Environmental Manager during the preconstruction, construction and operational stages of the proposed upgrading of the Lüderitz Logistics Shores Base with bi-annual monitoring reports submitted to the Environmental Commissioner in the Ministry of Environment and Tourism, Executive Director (ED) in the Ministry of Works and Transport and Lüderitz Port Captain.

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