32 Chap 8 March 2011
32 Chap 8 March 2011
32 Chap 8 March 2011
8.1
Introduction
Since SEA is driven by the concept of sustainability, the logical consequence of an SEA should be
guidance on how sustainability principles can be mainstreamed throughout the life cycle of activities
and projects. This guidance is provided through the Strategic Environmental Management Plan
(SEMP) which will be overseen by a broad-based SEMP Steering Committee and managed by a
dedicated SEMP office (see section 8.3 below).
The SEMP is an over-arching framework and roadmap for addressing the cumulative impacts of a
suite of existing and potential developments. The manner in which this is achieved is by setting limits
of environmental quality (i.e. performance targets) that need to be achieved by the proponents of
individual projects. In situations where a SEMP exists, individual EMPs prepared for each mine or
project, will need to incorporate all relevant environmental management specifications (Figure 8.1).
Thus, the SEMP does not remove the obligation from a developer for conducting a project-specific
Environmental Impact Assessment (EIA) and abiding by a site-specific Environmental Management
Plan (EMP). On the contrary, all projects listed in the Environmental Management Act (EMA) of
2007, must undergo an EIA prior to authorisation and implementation. Moreover, each project has a
number of permit obligations that must be met for the developer to be in full compliance with the law.
Figure 8.1: Planning hierarchy from strategic to project levels (source: modified from DEAT 2002)
For the Erongo Region to achieve its vision of producing an environmentally-friendly uranium
brand, there needs to be a concerted and sustained effort by all stakeholders to commit to the EQOs
and the recommendations made in this SEA. Of course, this commitment requires the bottom line,
or in this case triple bottom line, to be articulated in precise and practical terms.
Knowing what needs to be done, and what can realistically be done to avoid or reduce negative
impacts, enhance benefits and maintain good governance, required months of research, extensive
public participation and careful analysis of issues and options. Having done this, the SEA team
identified 15 Environmental Quality Objectives (EQOs) that are a collective proxy for measuring the
extent to which the Uranium Rush is moving the Erongo Region towards or away from a desired
future state. There are 30 desired outcomes, 43 targets and 118 indicators spread across the EQOs
(Figure 8.3).
An EQO is typically a non-enforceable goal, which specifies a target for environmental quality which,
it is hoped, will be met in a particular environment. If EQOs are set by regulation, they are usually
referred to as Environmental Quality Standards. For the purposes of the Uranium Rush SEA, we use
the term EQO, whether the objective is defined by society, policy, law or International
Agreement(s).
Figure 8.3: The structure of the SEMP and the public disclosure process
In some cases, EQOs are a vague form of generally desirable objectives, but in other cases, they might
be concrete quantitative measures. Wherever possible, they should be acceptable to all key
stakeholders, quantifiable, verifiable and outcomes oriented.
Implicit within all EQOs is a minimum management objective that any changes to the environment
must be within acceptable limits and that pro-active intervention will be triggered by the responsible
party to avoid unwanted changes that breach a specified threshold. Whilst many of the EQOs are
interrelated and thus difficult to compartmentalise, they are arranged under broad themes for purposes
of illustration (Figure 8.4).
The EQOs are not presented in order of priority all are equally important.
Throughout this SEA, stakeholders repeatedly asked who will manage the Uranium Rush? This is a
valid question given that Namibia has a shortage of skills generally, and especially at management
level.
The best way for Namibia to manage the Uranium Rush is for decision makers at all levels to enter
into meaningful partnerships with each other, so that the country can utilise all available skills.
However, it is recommended that Government take overall responsibility for implementing the SEMP,
through a close partnership between MME and MET. There thus needs to be a broad-based steering
committee that oversees the functioning of an office to administer the SEMP (hereafter referred to as
the SEMP office), that should be based both in Swakopmund and Windhoek (Figure 8.5).
The SEMP office needs only a small number of full-time staff members, who will manage all the
monitoring, communication and reporting. The SEMP office must collate the data required to assess
the key performance indicators listed in the EQOs (see section 8.4) and compile the annual SEMP
report. Data for many of the indicators are already being collected by various institutions for various
purposes (e.g. tourist satisfaction surveys, wildlife monitoring, infrastructure inspections), but more
work may be required to set up new monitoring programmes and establish the necessary sampling and
reporting protocols (radiation, groundwater and air quality). Therefore the SEMP office will have to
manage field work programmes with support from specialist institutions such as Gobabeb, GSN and
DWA. Tasks such as questionnaire surveys could be conducted by students or tour operators, etc.
Ideally, the work could be done efficiently and cost-effectively, but the quality and integrity of data
must not be compromised.
Seed funds for capacity building in MME have been secured through the current BGR-GSN Project
for Technical Cooperation. MME, MAWF and MET will need to integrate their specific tasks into
their strategic plans. It is expected that the uranium industry will contribute towards funding the
SEMP office in the future, and that the Chamber of Mines will facilitate this.
It is recommended that the SEMP Steering Committee meets twice per annum, early in the year
(February) and then again in October. The first meeting will approve the annual work plan, while the
second meeting will review the draft SEMP report. After this meeting, the SEMP office will be in a
position to finalise the report so that it can be released to the public by end November each year.
The proposed Terms of Reference for the SEMP Steering Committee are as follows:
Voluntarily serve the SEMP process (i.e. no salary, sitting allowance, per diem, etc.);
Advise GRN on SEMP and Uranium Rush progress and dynamics (i.e. refine/adjust
scenarios).
Through MME
Figure
8.6:
Using
a
precautionary approach to
managing strategic impacts in
relation to the limits of
acceptable change (Source:
adapted from Binedel and
Brownlie, 2007)
Data source: List who provided the data, and the locality of the data (for future reference). The data
do not need to be in the SEMP report they could be bound into a separate report.
Public consultation and input:
o
List the extent to which communications or submissions were received from the public.
Space permitting, letters/faxes/emails or SMSs can be attached, or at least referenced.
List dates, venues, agendas and minutes of meetings held (if any).
As illustrated in Figure 8.4, the following 15 EQOs are grouped according to the following themes:
Since the EQOs are a synthesis of the content and analysis provided in Chapter 7, the reader is
referred to Chapter 7 for more detailed background information. The EQOs presented below provide
the key targets and indicators, together with the relevant organisation(s) responsible for the
implementation of the actions required to meet the targets. The sources of the data needed for
monitoring are also indicated.
1. Income and
economic
opportunities
from the
Uranium Rush
are optimised
GRN budget
documents
(estimates of
income)
GRN
accountabilit
y report (e.g.
show any
deviations on
default rates)
Mine and
MME annual
reports
Mine and
CoM annual
reports
MTI
Mines
Chamber of Mines
must provide
encouragement
MTI
There are other indicators relevant to this EQO that are not included here, such as minimising opportunity costs, coinvesting in infrastructure, etc. They are omitted because they are covered by other EQOs.
Aim of this EQO: To maximize the sustainable contribution mines can make post closure to
society and the region, and to minimize the social, economic and biophysical impacts of mine closure.
Desired outcome
1. Companies
have approved
closure plans in
place which
ensure that
there are no
significant
post-closure
long term
negative socioeconomic,
health and
biodiversity
effects from the
mine. These
plans should
address
planned as well
as premature
closure.
Data sources
Mine closure
plans
MME
Data sources
Mines
MME
Mine closure
plan
Mines in
conjunction with the
Financial
audit reports
Data sources
Indicators:
Closure cost estimations
contained in the closure
plan
Financial audit reports of
the closure fund.
3. The
Government
has appropriate
mechanisms in
place to
approve mine
closure plans,
financial
instruments
chosen for
implementation
and to effect
relinquishment
back to the
state.
Target:
Adequate regulations
applicable to mine closure
are contained in the
relevant legislation.
Indicators:
Mine closure regulations
are adequate to govern:
review and approval
of mine closure plans;
financial guarantees
and sureties;
implementation
review,
relinquishment and
transfer of liabilities
to the subsequent land
owner.
MME
Regulations
to the
Minerals Act
1. Disease rates
amongst the
public and
employees of
the mining and
associated
industries are
not increased
as a result of
the Uranium
Rush
No measurable increase,
directly or indirectly
attributable to uranium
mining and its support
industries in the incidence
rates of the following:
Industrial lung
disease
(including
pneumoconiosis)
Lung cancer
Data Source
Individual
mines
Chamber of
mines
Namibian
Cancer
Register
Road
accidents
statistics
Industrial
induced renal
damage
HIV/ AIDS
Tuberculosis
Industrial
dermatitis.
No increase in road
accidents directly
attributable to Uranium
mining and its support
industries.
Indicators:
Public dose assessments
produced by each mine
project
Measured change in
absorbed radiation dose of
uranium mine workers and
medical professionals
(designated radiation
workers)
Measured change in the
incidence rate of industrial
diseases amongst uranium
mine workers.
Measured change in the
incidence rate of diseases
scientifically attributed to
radiation amongst members
of the public, uranium mine
workers and medical
personnel
Measured change in the
rate of road accidents in
Erongo Region directly
attributable to uranium
mining
Data Source
2. Improved
Healthcare
Facilities and
Services4 are
able to meet
the increased
demand for
healthcare
resulting from
the Uranium
Rush
Data Source
National and
local statistics
Indicators:
Number of available
qualified healthcare
personnel: 2.5 per 1,000
Number of available
registered healthcare
facilities: 1 per 1,000
Number of available
ambulances: 1 per 20,000
Number of Medical
Practitioners: 1 per 1,000
Number of Dental
Practitioners: 1 per 2,000
Number of nurses: 2.5 per
1,000
Pharmacists: 1 per 2,000 of
population
4There is no consensus on the ideal number of healthcare workers per 1000 of population, which differs from region to
region depending on a large number of fundamental factors. The figures stated here are based on the consensus opinion of
the group of local medical practitioners in Erongo Region.
Desired Outcome
1. Annual
radiation
exposures to
the public via
air are not
significantly
increased as a
result of the
Uranium
Rush
2. Annual
human
exposures to
particulate
concentration
s are
acceptable
(IFC
Standard)
Target:
More accurate public dose
assessments shall demonstrate
that the cumulative radiation
dose to members of the public
does not exceed 1 mSv/a, or
that the dose to members of the
public does not exceed 0.25
mSv/a for contributions from
any single operation.
Indicators to be monitored in
air:
Radon exhalation rates
from ground through
continuous monitoring.
Gross alpha/beta-analysis
and determination of
uranium and thorium by
NAA within the inhalable
(PM10) fraction of air
filters
Gross alpha/beta-analysis
and determination of
uranium and thorium by
NAA within dust fallout
samples.
Target:
Ambient PM10 concentrations
at public locations should not
exceed the required target/limit
to be set for the Erongo Region
for both annual and 24-hour
averages. The target/limit
should be based on
international guidelines but
should consider local
environmental, social and
economic conditions.
Indicators:
Ambient PM10
monitoring (g/m3) at
Mine
radiation
management
reports (that
are sent to
the NRPA)
Road authorities
must maintain
national transport
infrastructure
DWA and
NRPA
verification
reports
Transport
Authority
reports
MME
Annual
Reports
Chamber of
Mines
annual
reports
Mine air
quality
management
reports
MME
Annual
Reports
Chamber of
Mines
annual
reports
Erongo
PM10 and
dust fallout
monitoring
The Ministry of
Health and Social
Services must
ensure compliance
with air quality
requirements from
the mines
Data
Sources
MME must
implement and
operate PM10
samplers at
identified receptors
Desired Outcome
Mitigation measures to be
implemented by mines at
all major dust generating
sources such as haul
roads, materials transfer
points and crushing
operations. The best
practical dust suppression
methods should be
implemented and
monitored.
Calibration of PM10
samplers and
meteorological station as
per manufacturers
Data
Sources
database
Desired Outcome
Data
Sources
specification.
Use of accredited
laboratories in the
analysis of PM10 sample
filters.
Develop a monitoring
database providing
information on measured
PM10 concentrations.
This information should
be available to the public
in a format that is both
scientifically sound and
understandable.
3. Nuisance dust Target:
resulting from Dust fallout levels at
the Uranium
residences in towns should not
Rush is
exceed the recommended limit
within
of 600 mg/m2/day.
acceptable
Indicators:
thresholds
Continuous dust fallout
measurements
(mg/m2/day) on a regional
scale e.g. maintain
existing SEA dust fallout
network.
Mines must implement a
dust fallout network,
measuring dust fallout at
main dust generating
sources and mine license
boundaries.
Other performance targets:
Mitigation measures to be
implemented by mines at
all major dust generating
sources such as haul
roads, materials transfer
points and crushing
operations. The best
practical dust suppression
The Ministry of
Health and Social
Services must
ensure compliance
with air quality
requirements by the
mines
Mine air
quality
management
reports
MME
Annual
Reports
Chamber of
Mines
annual
reports
Erongo
PM10 and
dust fallout
monitoring
database
Desired Outcome
Use of accredited
laboratories in the
analysis of dust fallout.
Develop a monitoring
database providing
information on measured
dust fallout levels. This
information should be
available to the public in a
format that is both
scientific sound and
understandable.
Data
Sources
1. Improved
quality of
school
education
2. Increased
availability of
technical skills
in Erongo
Data Source
The aforementioned
institutions bursaries
from the GRN and
Private Sector,
especially the uranium
industry. NTA training
levy to be utilised by
the VTCs
Namibia
Training
Authority
Polytechnic of
Namibia,
UNAM
Directorate of
National
Examinations
and
Assessment,
MoE.
SACMEQ
reports
1. Mainly locals
Mines
are employed
2. Existing,
proclaimed
towns are
supported
Indicators:
During operational phase all
companies to comply with
their employment equity target
(certificate)
Target: Most employees are
housed in proclaimed towns
Indicators:
Mines do not create mineonly townships or suburbs
There are no on-site hostels
during the operational
phase of a mine
Mines, supported by
the municipalities
Data source
Mines HR
department,
via
Chamber of
Mines
Municipalities
EQO 7: WATER
FUNCTIONING
AVAILABILITY,
QUALITY
AND
HYDROLOGICAL
Aim of this EQO: To ensure that the public have the same or better access to water in future as they
have currently, and that the integrity of all aquifers remains consistent with the existing natural and
operational conditions (baseline). This requires that both the quantity and quality of groundwater are
not adversely affected by prospecting and mining activities.
Desired outcome
1. Water for
urban and
rural
communities
is of
acceptable
quality
2. The natural
environment,
urban and
rural
communities
have access to
adequate
water
Data source
DWA
Mines & other
developers
NamWater
Farmers
Basin Management
Committees (BMCs)
Municipalities
Land
owner(s)
DWA
Mining
Companies
Public
Accredited
laboratory test
reports
It is acknowledged that groundwater in some areas is naturally brackish or saline and does not conform to the national water
quality standards
6
It is specifically recommended that no groundwater be used for any mining operations, other than water made available
through pit dewatering
3. Water for
industrial
purposes is
available and
reliable
Data source
NamWater
LAs
NCCI
NamWater, with
collaboration by
industry, DWA, LAs
1. The paucity of
biodiversity
data for the
Central
Namib is
addressed
2. The
ecological
integrity of
the central
Namib is
maintained
MME
MET application of
Environmental
Management Act
Mines SEMP office
to be involved in
verification MET
and MME must
enforce
Mines, in
collaboration with
infrastructure utilities
such as NamWater,
NamPower, Roads
Authority,
Electricity and water
tariff regulating
authorities
Data source
MET
Mines
Gobabeb
EMA (2007)
compliance
figures
Mines
provide
information
SEMP office
and MET to
verify
Feasibility
studies and
plans
EIAs
Data source
3. Mining
industry
becomes a
conservation
partner
Data source
SEMP office
with input from
stakeholders
4. No species7
become
extinct
because of the
Uranium Rush
5. No secondary
impacts occur
6. Water quality
and quantity
does not
decrease to
the extent that
it negatively
affects
biodiversity
Data source
MET with
input from
Honorary
Wardens and the
SEMP office.
Farmers and
conservancies
will also be
sources of
information.
MET responsible,
but need technical
support from DWA,
NGOs and specialist
institutions (e.g.
Gobabeb) and
funding from mines
and other
proponents.
MET
DWA
Mines
Gobabeb
There is incomplete knowledge of Namib biodiversity, and it is therefore not possible to know exactly what species occur
and where.
Figure 8.7: Red and yellow flag areas based on ecological criteria
1. Central Namib is
accessible to the
public (within the
regulations of the
National Park)
Party
responsible for
implementation
MME to agree
on red flag
areas
MET
(implement
Park
Management
Plans)
NHC
Developers
must comply
MME and
MET must
enforce
COM must
encourage
best practice.
8
9
These are the places regarded as commonly used for recreation by locals.
Listed means the activity is required to have an EIA under the Environmental Management Act of 2007.
Data source
MME - proof
of withdrawal
will be a GRN
announcement
and a map
The public
at least 100
coastal
residents who
own a 4x4
vehicle must
be sampled
randomly in
an annual
public survey
NHC
EIA report
and specialist
study
EMP report
Closure plan
Proof of funds
available for
closure,
decommission
ing and
rehabilitation
The DEA
must keep a
copy of above
reports and
specialist
studies.
1. Uranium
Rush does
not significantly
reduce the
visual
attracttiveness of
the Central
Namib
Responsible Party
for EQO
implementation
Developers to
commission EIAs
and implement
EMPs. DEA must
ensure quality of
both.
Mining companies
and MET must
plan mitigation and
alternative tourism
routes
Collaboration
between tour
companies and
mines to diversify
tourism (geology
etc.).
Data source
EIA reports look
for visual impact
specialist study, EMP
report and
decommissioning and
restoration plan, with
funds.
Tour operators at
least 70% (randomly
selected) operators
working in the
Swakopmund/Walvis
area must be sampled
annually.
As above.
2. Areas of
significant
natural
beauty or
sense of
place10 are
afforded
proper
protection
(without
undermining
existing
legal rights).
Responsible Party
for EQO
implementation
MME
MET appropriate
revision of
Protected Area &
Wildlife Bill needs
to be made and the
Bill needs to be
passed and
implemented
MET needs to
manage and
monitor other
sectors that impact
these red and
yellow areas,
notably recreation,
tourism,
infrastructure
projects,
aquaculture and
urban
development.
SEMP Office
National Heritage
Council (NHC).
Data source
MME
10
In this case, sense of place takes into account natural beauty, biodiversity, heritage value, tourism value and environmental
vulnerability.
1. The integrity of
archaeo-logical
and palaeontological heritage
resources is not
unduly
compromised by
the Uranium Rush
Target and
indicators
performance Party
Data
responsible for source
implementation
Target: Mining industry and
National Heritage
Mining
associated service providers
Council and
companies and
avoid impacts to
National Museum
other
archaeological resources, and
as repositories of
developers
where impacts are
data and
must
unavoidable, mitigation,
materials.
commission
restoration and /or offsetting
and pay for
are achieved.
the
Indicators:
assessment.
All mining and related
developments are subject
to archaeological
assessment
No unauthorised impact
occurs
Mining companies adhere
to local and international
standards of
archaeological assessment.
2. Integration of
archaeological and
environmental
knowledge in a
balanced working
model of Namib
Target: Development of a
general research framework
to identify gaps in scientific
knowledge.
Indicators:
National Heritage
Mining
Council and
companies and
National Museum
other
as repositories of
developers
data and
Chamber
of
materials.
Mines
must
encourage
Best Practice
Gap analysis and
National
research
research
framework
institutions
(National
Local and
Heritage Council).
foreign
scientists
11
This EQO and the related thematic study are limited in their scope, to the material record of past human activity in the
relevant part of the Erongo Region. The most severe impacts of mining activity affect the pre-colonial and early colonial
archaeological record, most of which is undocumented and therefore at greater risk than sites and other remains mainly in
urban areas and other formal settlements. In general use, and in terms of the National Heritage Act (27 of 2004) heritage
has a broader meaning which goes beyond the scope of this assignment, to include the intangible cultural values of living
communities, the architectural heritage, and numerous other manifestations of cultural activity such as museums, memorials
and places of interest.
Desert
environmental
processes.
Target and
indicators
performance Party
Data
responsible for source
implementation
concerned
Research in progress,
with the
Working model of Namib
development
desert developed
of
Model providing
environmental
information to guide
monitoring.
decision making about
development in the Namib
Development of
As above.
Diachronic model
diachronic models to
(National
determine the effects of
Heritage Council).
climatic and other
environmental changes.
Data
source
Independent
audit.
Independent
auditors
Waste site
operators.
Site manifests
Water and air
quality
monitoring
data
Municipal
records:
budgets and
staffing of
3 Recycling is
common
practice in the
central Namib.
Data
source
waste
management
departments.
Mines
SMEs (recycling)
Municipalities.
Mines
Municipalities.
Mines
Data
source
Roads Authority
Independent
survey report
(SEMP Office)
NAMPOL
where accidents
are reported
2. Traffic
flows
optimally
and safely.
Roads Authority
NAMPOL
Mines
Traffic census
(Traffic officials
and SEMP office)
4. Walvis
Bay
Harbour is
efficient
and safe
5. Electricity
is
available
and
reliable
Data
source
TransNamib
Namport
Mines
Namport
Namport
NamPower and
MME, in
collaboration with
REDs and LAs
Feasibility studies
NCCI
NamPower
ECB, in collaboration
with NamPower,
REDs and LAs
ECB
Responsible Party
for EQO
implementation
Data source
1. Prospecting and
MME
Parastatals
Individual
mines.
MME
Parastatals
Physical
inspection
MME
MET
MAWF
Other GRN
Civil Society
involvement
required.
As before
EIA and EMP
reports
EIA/EMP
RoDs
Court cases.
mining avoids
environmenttally high value,
sensitive areas.
2. Good
governance is
maintained in
the issuing of
mineral
licences.
________________________________________________
[12]
3. Prospecting and
mining
activities are
properly
monitored.
No evidence of corruption in
the allocation of mineral
licences
No prospecting, mining or
major infrastructure projects
are permitted (anywhere)
before full EIAs are
completed and approved.
Minimum EIA standards as in
the EMA and regulations, are
adhered to, including:
o Clear TORs
o Use of
independent
consultants
o Public
consultation
o Specialist studies
o Consideration of
alternatives
o Avoid and/or
minimise adverse
impacts
o Include an EMP
and closure and
restoration plan
o Professional
review of EIA
and EMP.
Target: Post-implementation
monitoring is regular, efficient
and outcomes-based
Indicators:
GRN agencies (notably
MME, MET, MAWF,
MHSS) inspect active mines
at least once per annum, and
closed mines at least once
every 3 years
Honorary conservators are
appointed by MET to assist
with monitoring, including of
unauthorised secondary (offmine) activities such as
offroad driving, poaching and
littering.
Above agencies take accurate
and consistent measurements
of key indicators
International agencies
regularly inspect mines and
provide independent opinion
needed from
MET and other
GRN agencies.
Civil Society
involvement
required.
CoM to provide
support.
GRN reports
Consultant
reports
SEMP report.
4. Noncompliance is
rectified.
MME to take
the lead
support needed
from MET and
other GRN
agencies
CoM to
encourage best
practice.
GRN reports
and correspondence
SEMP report.
Figure 8.8: Decision-making process for EPLs in red and yellow flag areas
Figure 8.9: Decision-making process for MLs in red and yellow flag areas
Data source
Professional
journals (e.g.
Mining
Weekly)
Relevant
websites
Foreign travel
agencies and
tourism
operators
SEMP annual
report
Environmental
Commissioner
s Office
National
Radiation
Protection
Authority
MoHSS
Geological
Survey of
Namibia/MME
Ministry of
Labour
Tax Authority/
Ministry of
Finance
Ministry of
Foreign Affairs
IAEA
Tourism
operators
Tourists
Members of the
public.