ecc -95 129 rep 01 d environmental management...

ECC-95-129-REP-01-D

ENVIRONMENTAL MANAGEMENT PLAN

MOONRAKER OUTDOOR ADVENTURES RESTCAMP (PTY) LTD

KHOMAS REGION, NAMIBIA

PREPARED FOR

AUGUST 2019

ENVIRONMENTAL MANAGEMENT PLAN MOONRAKER OUTDOOR ADVENTURES REST CAMP (PTY) LTD

AUGUST 2019 PAGE 1 OF 46

ECC DOCUMENT CONTROL - ECC-95-129-REP-01-D

TITLE AND APPROVAL PAGE

Project Name: Environmental Management Plan – Moonraker Outdoor Adventures Rest Camp (Pty)

Ltd

ECC Reference: ECC-95-129-REP-01-D

Client Name: Moonraker Outdoor Adventures Rest Camp (Pty) Ltd

Ministry Reference: N/A

Status of Report: Final Submission to Government

Date of issue: August 2019

Review Period N/A

Environmental Compliance Consultancy Contact Details:

We welcome any enquiries regarding this document and its content please contact:

Stephan Bezuidenhout Jessica Mooney

Environmental Consultant & Practitioner Environmental Consultant & Practitioner

Tel: +264 81 699 7608 Tel: +264 81 699 7608

Email: [email protected] Email: [email protected]

www.eccenvironmental.com www.eccenvironmental.com

Confidentiality

Environmental Compliance Consultancy Notice: This document is confidential. If you are not the intended recipient, you

must not disclose or use the information contained in it. If you have received this document in error, please notify us

immediately by return email and delete the document and any attachments. Any personal views or opinions expressed

by the writer may not necessarily reflect the views or opinions of Environmental Compliance Consultancy.

Please note at ECC we care about lessening our footprint on the environment, therefore all documents are

printed double sided.

mailto:[email protected]


http://www.eccenvironmental.com/

http://www.eccenvironmental.com/


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TABLE OF CONTENTS

1 INTRODUCTION .............................................................................................................................. 6

1.1 MOONRAKER OUTDOOR ADVENTURES REST CAMP (PTY) LTD BACKGROUND ................................................... 6

1.2 THE PROPONENT OF THE PROJECT ............................................................................................................ 8

1.3 ENVIRONMENTAL REGULATORY REQUIREMENTS ......................................................................................... 8

1.4 PURPOSE AND SCOPE OF THIS REPORT ....................................................................................................... 8

1.5 DOCUMENT HIERARCHY ........................................................................................................................... 8

1.6 OBJECTIVES ........................................................................................................................................... 9

1.7 ENVIRONMENTAL POLICY ........................................................................................................................ 9

1.8 MANAGEMENT OF THIS EMP ................................................................................................................... 9

1.9 LIMITATIONS, UNCERTAINTIES AND ASSUMPTIONS OF THIS EMP ................................................................... 9

1.10 ENVIRONMENTAL CONSULTANCY .............................................................................................................. 9

2 ENVIRONMENTAL MANAGEMENT FRAMEWORK ........................................................................... 11

2.1 ENVIRONMENTAL OBJECTIVES AND TARGET .............................................................................................. 11

2.2 ORGANISATIONAL STRUCTURE, ROLES AND RESPONSIBILITIES ...................................................................... 11

2.3 ENVIRONMENTAL OFFICER ................................................................................................................... 11

2.4 CONTRACTORS ..................................................................................................................................... 12

2.5 REGISTER OF ENVIRONMENTAL RISKS AND ISSUES ...................................................................................... 13

3 COMMUNICATIONS AND TRAINING .............................................................................................. 16

3.1 COMMUNICATIONS .............................................................................................................................. 16

3.2 COMPLAINTS HANDLING AND RECORDING................................................................................................ 16

3.3 TRAINING AND AWARENESS ................................................................................................................... 16

4 INCIDENT REPORTING ................................................................................................................... 18

4.1 ENVIRONMENTAL EMERGENCY AND RESPONSE ......................................................................................... 18

4.2 MINOR INCIDENT OR “NEAR MISS” ......................................................................................................... 18

4.3 SERIOUS INCIDENT ................................................................................................................................ 18

4.4 INCIDENT REPORT AND CLOSE OUT ......................................................................................................... 19

5 COMPLIANCE AND ENFORCEMENT ................................................................................................ 20

5.1 ENVIRONMENTAL INSPECTIONS & COMPLIANCE MONITORING .................................................................... 20

5.2 REPORTING ......................................................................................................................................... 20


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5.3 NON-COMPLIANCE ............................................................................................................................... 20

5.4 DISCIPLINARY ACTION ........................................................................................................................... 20

6 ENVIRONMENTAL MANAGEMENT MEASURES ............................................................................... 21

6.1 WATER PERMITS AND LICENCE ............................................................................................................... 21

6.2 WASTEWATER DISCHARGE PERMIT ......................................................................................................... 21

7 SURFACE AND GROUNDWATER MANAGEMENT PLAN ................................................................... 22

7.1 INTRODUCTION .................................................................................................................................... 22

7.2 OBJECTIVES ......................................................................................................................................... 22

7.3 RESPONSIBILITIES ................................................................................................................................. 22

7.4 SURFACE AND GROUNDWATER MANAGEMENT MEASURES ......................................................................... 22

7.5 SURFACE AND GROUNDWATER QUALITY MONITORING PROGRAMME ........................................................... 23

8 WASTE MANAGEMENT PLAN ........................................................................................................ 24

8.1 INTRODUCTION .................................................................................................................................... 24

8.2 OBJECTIVES ......................................................................................................................................... 24

8.3 ROLES AND RESPONSIBILITIES ................................................................................................................. 24

8.4 SOLID WASTE ...................................................................................................................................... 24

8.5 WASTE DISPOSAL MONITORING ............................................................................................................. 25

9 CONCLUSION AND WAY FORWARD ............................................................................................... 26

APPENDIX A: MOONRAKER OUTDOOR ADVENTURES RESTCAMP (PTY) LTD HOUSE PHOTOS .................. 27

APPENDIX B: APPLICATION FOR A WASTEWATER DISCHARGE LICENCE .................................................. 29

APPENDIX C: TEMPLATE FOR MONITORING .......................................................................................... 36

APPENDIX D: COMPLAINTS REGISTER TEMPLATE .................................................................................. 42

APPENDIX E: MONTHLY INTERNAL COMPLIANCE CERTIFICATE ............................................................... 43


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TABLES

TABLE 1 - THE PROPONENT DETAILS ................................................................................................................................. 8

TABLE 2 – KEY ROLES AND RESPONSIBILITIES ................................................................................................................. 12

TABLE 3 - OPERATION: ENVIRONMENTAL RISKS AND ISSUES, MITIGATION AND MONITORING MEASURES .............. 14

TABLE 4 - EMERGENCY SERVICES CONTACT TELEPHONE NUMBERS .............................................................................. 18

TABLE 5 - WATER QUALITY MITIGATION MEASURES ..................................................................................................... 23

TABLE 6 – WASTE MITIGATION MEASURES .................................................................................................................... 25

FIGURES

FIGURE 1 - LOCALITY MAP OF MOONRAKER OUTDOOR ADVENTURES REST CAMP (PTY) LTD PROJECT ....................... 7

FIGURE 2 AERIEL VIEW OF WOODEN CABINS AT MOONRAKER OUTDOOR ADVENTURES RESTCAMP (PTY) ............... 27

FIGURE 3 ZOOMED IN VIEW OF MOONRAKER'S WOODEN CABIN ................................................................................. 27

FIGURE 4 MOUNTAIN VISUAL VIEW FROM A WOODEN CABIN ..................................................................................... 28

FIGURE 5 SPOTTED HORSES SEEN AT A WATER POINT ................................................................................................... 28


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DEFINITIONS AND ABBREVIATIONS

ECC Environmental Compliance Consultancy

EMA Environmental Management Act EMP Environmental Management Plan

MAWF Ministry of Agriculture Water and Forestry

MET Ministry of Environment and Tourism

MSDS Material Safety Data Sheet




1 INTRODUCTION

1.1 MOONRAKER OUTDOOR ADVENTURES REST CAMP (PTY) LTD BACKGROUND

Environmental Compliance Consultancy (ECC) has compiled this Environmental Management Plan (EMP) in accordance

with the Environmental Management Act, 2007 on behalf of Moonraker Outdoor Adventures Rest Camp (Pty) Ltd.

Moonraker Outdoor Adventures Rest Camp (Pty) Ltd (herein referred to as the ‘proponent’) is presently operating on

an outpost farmstead of Farm Finkenstein which lies 1.94 km east of the Auas Mountain range, in Khomas Region.

Farm Finkenstein, located at coordinates 22.573980° S and 17.254511°E lies east of Windhoek just past the Finkenstein

Estate on the southern side of the National B6 Road between Windhoek and Gobabis (refer to figure 1). Farm

Finkenstein has a total area extent of 4994 hectares of which Moonraker Outdoor Adventures Rest Camp (Pty) Ltd,

occupies 2000 hectares of the farm.

The renovated farmstead, Farm Finkenstein, previously used for farming, has been restored and today consists of 12

(twelve) wooden cabins with a capacity to accommodate 10-30 guests per day.

The rest camp provides a range of services and activities extending from outdoor adventures such as hospitality

management training, educational tours, animal husbandry facilities, self-catering open-door kitchen and swimming

pool. Other activities offered include hiking, mule trails and mountain biking, via different routes of up to 60km in the

wilderness area (located on the southern portion of the proposed development where tracks have been restored and

maintained to have the least possible impact on the environment).




FIGURE 1 - LOCALITY MAP OF MOONRAKER OUTDOOR ADVENTURES REST CAMP (PTY) LTD PROJECT


MOONRAKER OUTDOOR ADVENTURES REST CAMP (PTY) LTD

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1.2 THE PROPONENT OF THE PROJECT

The proponent details are provided in Table 1.

TABLE 1 - THE PROPONENT DETAILS

NAME POSTAL ADDRESS EMAIL ADDRESS TELEPHONE

Manfred Goldbeck &

Bernhardt Fincke

PO Box 80205, Windhoek

[email protected]

Tel: +264 (0) 61 427 021

1.3 ENVIRONMENTAL REGULATORY REQUIREMENTS

The farmstead predates the implementation and development of the Environmental Management Act (EMA) 2007.

Facilities predating the EMA are required to ensure potential environmental impacts are minimised and managed,

through the development and implementation a site-specific Environmental Management Plans (EMP).

The application for an environmental clearance certificate, as set out in the instruction from the Ministry of Environment

and Tourism (MET) and the Windhoek Municipality, is for facilities predating the EMA require an application for an

environmental clearance in the form of an official application (Form 1) supported with the site’s environmental

management plan (this document).

1.4 PURPOSE AND SCOPE OF THIS REPORT

This EMP is a site-specific plan developed to ensure that appropriate environmental management practices are followed

during the operational phase of the project. This EMP has been prepared to address environmental risks associated

with the operation of the rest camp.

This EMP is a live document and shall be reviewed at predetermined intervals, and/or updated to reflect material

changes to the operations and to allow continual improvement for the environment and community management on

the rest camp. All personnel working on the project will be legally required to comply with the standards set out in this

EMP.

The scope of this EMP includes the duration of the operation of the rest camp. The proponent shall be responsible for

each phase of the project and the implementation of this EMP.

1.5 DOCUMENT HIERARCHY

In terms of the Namibian Environmental Impact Assessment (EIA) Regulations (Government Notice (GN) 28, 29, and 30

promulgated on 6 February 2012) enacted in terms of the Namibian Environmental Management Act (Act no. 7 of 2007)

(EMA), the proposed activity requires an Environmental Management Plan.

This EMP has been developed to assist Moonraker Outdoor Adventures Rest Camp (Pty) Ltd during the operations of its

project. Where there is any conflict between the provisions of this EMP and any obligations under their respective

contracts, including statutory requirements (such as licences, project approval conditions, permits, standards,

guidelines and relevant laws), the contract and statutory requirements are to take precedence.

In the event of any real or perceived ambiguity between elements of this EMP, and/or statutory requirements, the

proponent shall first gain clarification prior to implementing that element of the EMP over which the ambiguity is

identified.



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1.6 OBJECTIVES

The objective of this environmental management plan is to address environmental issues on premises and to detail the

environmental management framework, practices and procedures that will be followed during the operations of the

project with the aim of minimising potential environmental impacts and ensuring that statutory requirements and other

obligations are fulfilled. The plan will therefore have as a main objective the reduction or mitigation of environmental

consequences resulting from the operations and actions during the printing period.

This Environmental Management Plan forms part of the Environmental Management System adopted and

implemented. This Environmental Management Plan should be viewed in addition to the required compliance to the

Disaster Environmental Management Plan.

This Environmental Management Plan will form part of the Environmental Management System that will be

implemented permanently and will be reviewed from time to time. The Environmental Management System that will

be implemented will be based on the ISO 14001 Environmental Management System.

1.7 ENVIRONMENTAL POLICY

The Environmental Policy of Moonraker Outdoor Adventures Rest Camp (Pty) Ltd is as follows:

Moonraker Outdoor Adventures Rest Camp’s personnel are committed to environmental management principles and

to conduct all operations in such a way as to minimize the impact upon the natural environment, to ensure the

compliance with all applicable laws and to aim for continuous improvements. This will be achieved through the

understanding by all personnel of the Moonraker Outdoor Adventures Rest Camp’s Environmental Management System

and their role in it, coupled with effective monitoring and control systems.

1.8 MANAGEMENT OF THIS EMP

The proponent will hold the environmental clearance certificate for the rest camp and shall be responsible for the

implementation and management of this EMP. The implementation and management of this EMP and thus the

monitoring of compliance shall be undertaken through daily duties or activities and monthly inspections, incorporated

into the daily tasks for the employees at the rest camp.

1.9 LIMITATIONS, UNCERTAINTIES AND ASSUMPTIONS OF THIS EMP

This EMP does not include measures for compliance with statutory occupational health and safety requirements.

Where there is any conflict between the provisions of this EMP and any contractor’s obligations under their respective

contracts, including statutory requirements (such as licences, project approval conditions, permits, standards,

guidelines and relevant laws), the contract and statutory requirements are to take precedence.

1.10 ENVIRONMENTAL CONSULTANCY

Environmental Compliance Consultancy (ECC), a Namibian consultancy registration number 2013/11401, has prepared

this EMP on behalf of the proponent. ECC operates exclusively in the environmental, social, health and safety fields for

clients across Southern Africa, in the public and private sector. ECC is independent of the proponent and has no vested

or financial interest in the project expect for fair remuneration for professional services rendered. All compliance and

regulatory requirements regarding this document should be forwarded by email or posted to the following address:



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Environmental Compliance Consultancy

PO BOX 91193

Klein Windhoek, Namibia

Tel: +264 81 669 7608

Email: [email protected]




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2 ENVIRONMENTAL MANAGEMENT FRAMEWORK This EMP provides measures, guidelines and procedures for managing and mitigating potential environmental impacts.

The EMP also indicates monitoring and reporting guidelines and sets responsibilities for those carrying out management

and mitigation measures.

2.1 ENVIRONMENTAL OBJECTIVES AND TARGET

Environmental protection is the responsibility of management and if the management is environmentally aware, it

motivates all employees and their associated business partners, customers and suppliers to think and act in a more

environmentally responsible manner. Environmental objectives and targets have been developed so that activities of

Moonraker Outdoor Adventure Rest Camp can minimise potential impacts on the environment, as far as reasonably

practicable.

Environmental objectives for the project are as follows:

- Zero pollution incidents

- Sustainable resource use

- Application of the waste management hierarchy

- Protect local flora and fauna, and

- Use natural resources effectively and efficiently

- Capitalize on presence of rest camp for biodiversity management, and

- Ensure that company Environmental policies and the EMP are well understood by management and staff.

2.2 ORGANISATIONAL STRUCTURE, ROLES AND RESPONSIBILITIES

The proponent shall be responsible for:

- Ensuring all members involved in the operations of Moonraker Outdoor Adventures Rest Camp (PTY) LTD,

comply with the procedures set out in this EMP

- Ensuring that all personnel are provided with adequate training, supervision and instruction to fulfil this

requirement

- Ensuring that any personnel allocated specific environmental responsibilities are notified of their

appointment and confirm that their responsibilities are clearly understood, and

- The proponent shall be responsible for ensuring and demonstrating that all personnel employed by them are

compliant with this EMP, and meet the responsibilities listed above.

2.3 ENVIRONMENTAL OFFICER

Moonraker secures the services of an Environmental officer who is responsible for the implementation of the EMP for

the project. The Environmental officer will be available, as required, throughout the operations of the project and is

responsible for the following roles:

- Maintaining and aiding in the implementation of this EMP



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- Undertaking environmental monitoring and ensuring statutory compliance with government agencies and legislation

- Maintaining environmental records including environmental monitoring data, complaints and environmental incident reports

- Ensuring that best environmental practice is undertaken throughout the operations of the rest camp

- Provisioning of environmental awareness/management training and inductions, and

- Timely distribution of any relevant environmental documentation, including revisions to this EMP, to all staff.

The key personnel and environmental responsibilities are presented in TABLE 2. TABLE 2 – KEY ROLES AND RESPONSIBILITIES

ROLE RESPONSIBILITY & DUTIES

Proponent − Responsible for ensuring compliance with this EMP

− Ensuring employees understand and comply with the requirements of this EMP

− Ensuring that all personnel are provided with enough training, supervision and instruction to fulfil this requirement

− Ensuring compliance with this EMP including overseeing the day to day activities during operations, and routine and non-routine maintenance works during operations

− Ensure the environmental policy is communicated to all personnel

− Responsible for providing the required resources (including financial and technical) to complete any required tasks

− Responsible for the management, maintenance and revisions of this EMP

− Maintain a community issues and concern register, and keep records of complaints

− Maintain an up to date register(s) of employees who have completed the site induction

− Ensuring that best environmental practice is undertaken throughout the operations of the rest camp, and

− Report any non-compliance or accidents to the relevant authority.

Environmental

officer

− Maintaining and aiding in the implementation of this EMP

− Undertaking environmental monitoring and ensuring statutory compliance with

government agencies and legislation

− Maintaining environmental records including environmental monitoring data,

complaints and environmental incident reports

− Ensuring that best environmental practice is undertaken throughout the operations of

the rest camp

− Provisioning of environmental awareness/management training and inductions, and

− Timely distribution of any relevant environmental documentation, including revisions to this EMP, to all staff.

Employees /

Contractor

employees

− Responsible for being compliant with and adhering to this EMP at all times

− Ensuring they have undertaken a site induction and are conversant with the requirements of this EMP, and

− Reporting of any operations and conditions that deviate from the EMP or any non-compliant issues or accidents to the proponent.

2.4 CONTRACTORS



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In the event where contractors are hired by Moonraker Outdoor Adventures Rest Camp (Pty) Ltd during the operation

or maintenance activities, the said contractors shall be compliant with this EMP, and shall be responsible for the

following:

− Undertaking activities in accordance with this EMP as well as relevant policies, procedures, management

plans, statutory requirements, and contract requirements

− Implementing appropriate environmental and safety management measures

− Reporting of environmental issues, including actual or potential environmental incidents and hazards, to the

proponent, and

− Ensuring appropriate corrective or remedial action is taken to address all environmental hazards and

incidents reported by employees and subcontractors.

2.5 REGISTER OF ENVIRONMENTAL RISKS AND ISSUES

A high-level environmental review of the project. A schedule of environmental commitments and risks has been

produced in Table 3, which details deliverables including measures identified for the prevention of pollution or damage

to the environment.



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TABLE 3 - OPERATION: ENVIRONMENTAL RISKS AND ISSUES, MITIGATION AND MONITORING MEASURES

ASPECT POTENTIAL IMPACTS MANAGEMENT/MITIGATION MEASURES MONITORING

REQUIREMENTS RESPONSIBILITY

Water

management and

wastewater

Effects on natural resources

− Minimise the consumption of water used in the project’s operations

− Recycle wastewater, where possible

− Monitoring of wastewater discharges should be conducted on a regular basis

− Ensure that all fuels are stored and managed to reduce risk of spillages (i.e engine oils and batteries)

- Daily observations - Weekly inspections

Lodge management

Waste

management

Environmental pollution

(littering and poor storage

of waste)

− Training and toolbox talks

− Implement the waste management hierarchy across site: “Avoid, reuse, recycle, then disposal”.

− Good housekeeping across site

− Waste storage facilities should be properly maintained

− Waste storage areas shall always be kept clean and tidy

− Waste shall be removed on a regular basis to avoid pests and bad odours, and

− It is unlikely that hazardous material and wastes will be produced, however in the event that they do, they shall be managed in a safe and responsible manner so as to prevent contamination of soils, pollution of water and/or harm to people or animals as a result of the use of these materials. Hazardous and non-hazardous waste shall always be stored separately.

- Daily observations - Weekly inspections

Lodge management

Energy Environmental

degradation

− All technical equipment must be maintained regularly & inspections documented, and

− Install low-energy light bulbs in suitable places.

- Daily observations - Monthly monitoring

Lodge management



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ASPECT POTENTIAL IMPACTS MANAGEMENT/MITIGATION MEASURES MONITORING

REQUIREMENTS RESPONSIBILITY

Fauna Animals on site - Ensure that mule trails, walking and biking trails do not

unduly disturb wildlife

Daily observations Lodge management

Noise Disturbance to wildlife - Noise restrictions must be in place during operations of the rest camp

-


Light Disturbance to wildlife - Night-time light sources must be directed away from waterholes


Housekeeping, &

Laundry

detergents

Spill of chemicals

- All the chemicals / detergents should be kept locked in a separate room, and

- All product descriptions and specifications should be made available for chemicals including the Material Safety Data Sheet (MSDS), and

- All chemicals must be disposed of appropriately.


Social Job creation, and kills

development

- Maximize local employment and local business opportunities to promote and improve the local economy

- Enhance the use of local labour and local skills as far as reasonably possible. Where the required skills do not occur locally, and where appropriate and applicable, ensure that relevant local individuals are trained, and

- Ensure that goods and services are sourced from the local and regional economy as far as reasonably possible.

N/A - N/A



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3 COMMUNICATIONS AND TRAINING In order to ensure potential risks and impacts are minimised it is vital that personnel are appropriately informed and

trained to ensure risks are mitigated. It is also important that regular communications are maintained with stakeholders

(if applicable) and made aware of potential impacts and how to minimise or avoid them. This section sets out the

framework for communication and training in relation to the EMP.

3.1 COMMUNICATIONS

During operations the proponent shall communicate site wide environmental issues to all personnel through the

following means (as and when required):

- Site induction

- Audits and site inspections

- Toolbox talks, including instruction on incident response procedures, and

- Key project specific environmental issues briefings.

3.2 COMPLAINTS HANDLING AND RECORDING

The proponent shall maintain a complaint’s register (example attached as Appendix D) that will detail the name and

contact details of the complainant, date and time of the complaint, nature of complaint, action taken to resolve issues,

and date of complaint handover. The proponent shall be responsible for nominating the correct personnel to

coordinate and resolve the issue.

Any complaints received verbally shall be recorded as per above and the information shall be given to the proponent

who is overall responsible for the management of complaints and will provide a written response to the complainant.

The workforce shall be informed about the complaints register, its location and the person responsible, in order to refer

residents or the general public who wish to lodge a complaint. The complainant shall be informed in writing of the

results of the investigation and action to be taken to rectify or address the matter(s). Where no action is taken, the

reasons why are to be recorded in the register.

The complaints register shall be kept for the rest camp and will be available for government or public review upon

request.

3.3 TRAINING AND AWARENESS

All employees of the proponent shall be competent to perform tasks that have the potential to cause an environmental

impact. Competence is defined in terms of appropriate education, training and experience.

All personnel shall be inducted with specific environment and social awareness training. The environment and social

awareness training shall ensure that personnel are familiar with the principles of this EMP, the environment and social

aspects and impacts associated with their activities, the procedures in place to control these impacts and the

consequences of departure from these procedures. The proponent shall ensure a register of completed training is

maintained. The site induction should include, but not limited to the following:

- A general site-specific induction that outlines:

o What is meant by “environment” and the EMP

o What are the environmental risks of this project

o Why the environment needs to be protected and conserved

o How operational activities can impact on the environment

o What can be done to mitigate against such impacts?



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- The inductee’s role and responsibilities with respect to implementing the EMP

- The site environmental rules

- Details of how to deal with, and who to contact, in the event of environmental problems should they occur

- The potential consequences of non-compliance with this EMP and relevant statutory requirements, and

- The role of responsible people for the project.



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4 INCIDENT REPORTING The proponent must have an accident and incident reporting system that covers all applicable statutory requirements.

The section below sets out the minimum requirements for incident reporting and should be used as a basis for incident

reporting, in the event that no incident reporting system exists.

4.1 ENVIRONMENTAL EMERGENCY AND RESPONSE

The proponent will be the primary contact person in the event of an environmental emergency. The proponent has the

authority and independence to request reasonable steps be taken to avoid or minimise unintended or adverse

environmental impacts, and failing the effectiveness of such steps, to direct that relevant actions be ceased immediately

should an adverse environmental impact be anticipated.

In the event of an incident that requires the emergency services, the services that should be contacted are listed in

TABLE 4.

TABLE 4 - EMERGENCY SERVICES CONTACT TELEPHONE NUMBERS

TOWN AMBULANCE POLICE FIRE BRIGADE

WINDHOEK +264 61 211 111 +264 61 10111 +264 61 211 111

For large-scale spills and other significant environmental incidents, the fire services shall be contacted as required and

the Ministry of Environment and Tourism (MET) office informed of the incident (telephone +264 61 284 2111). All

correspondence with MET should be undertaken by the project manager.

For the clean-up of smaller spills, the relevant Material Safety Data Sheet (MSDS) should be obtained and be consulted

to determine the appropriate clean-up procedure. Basic spill response training will be provided as part of the site

environmental induction, spill response equipment, including relevant MSDS copies, will be provided in areas where

potentially environmentally hazardous chemicals may be used.

All environmental incidents, regardless of their size or significance, should be recorded and reported to either the PM.

4.2 MINOR INCIDENT OR “NEAR MISS”

Any incident or “near miss” involving the proponent, a nominated representative, any contractor, or its subcontractors

or any third party’s personnel, property, plant or equipment, must be

1) Orally reported to the manager or the managers nominated representative:

a. immediately and without delay

b. regardless of whether or not injury to personnel has occurred

c. or property or equipment has been damaged.

2) Written up and handed to the manager or the managers nominated representative by the end of the shift.

The written report should:

a. state all known facts and conditions at the time of the incident and

include a preliminary assessment of the most likely potential consequences of the incident under the current

circumstances

4.3 SERIOUS INCIDENT



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For any serious incident involving a fatality, or permanent disability, the incident scene must be left untouched until

witnessed by a representative of the Police. This requirement does not preclude immediate first aid being administered

and the location being made safe.

4.4 INCIDENT REPORT AND CLOSE OUT

The manager must investigate the cause of all work accidents and significant incidents and must provide the results of

the investigation and recommendations on how to prevent a recurrence of such incidents. A formal root-cause

investigation process should be followed.



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5 COMPLIANCE AND ENFORCEMENT

5.1 ENVIRONMENTAL INSPECTIONS & COMPLIANCE MONITORING

Annual inspections and audits of the rest camp will be managed and undertaken by the proponent. All infrastructure

will be inspected to ensure the equipment are operating as per specification; no damage has been caused; and no leaks

or spills have occurred. Any non-conformance shall be recorded, including the following details: brief description of

non-conformance; the reason for the non-conformance; the responsible party; the result (consequence); and the

corrective action taken and any necessary follow up measures required.

5.2 REPORTING

There shall be a requirement to ensure that any incident or non-compliance, including any environmental issues, any

faulty or malfunction of equipment that perform an environmental function or accident, is reported to the proponent.

5.3 NON-COMPLIANCE

Where it has been identified that work is not compliant with this EMP, the proponent shall ensure corrective actions

are implemented so that the work returns to being compliant as soon as possible. In instances where the requirements

of the EMP are not upheld, a non-conformance and corrective action notice shall be produced (refer to Appendix E).

The notice shall be generated by the environmental officer during the inspections and the proponent shall be

responsible for ensuring a corrective action plan is established and implemented to address the identified shortcoming.

A non-compliance event / situation, for example, is considered if:

- There is evidence of contravention of this EMP and associated indicators or objectives

- The proponent has failed to comply with corrective or other instructions issued by an authority, or

- The proponent fails to respond to complaints from the public.

5.4 DISCIPLINARY ACTION

This EMP is a legally binding document and non-compliance with it shall result in disciplinary action being taken against

the perpetrator/s. Such action may take the form of (but is not limited to):

- Fines / penalties

- Legal action

- Monetary penalties imposed by the proponent on the contractor

- Withdrawal of licence/s, and

- Suspension of work.

The disciplinary action shall be determined according to the nature and extend of the transgression / non-compliance,

and penalties are to be weighed against the severity of the incident.



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6 ENVIRONMENTAL MANAGEMENT MEASURES

6.1 WATER PERMITS AND LICENCE

The Water Act No. 54 of 1956 governs the use of water resources in Namibia and is the enforceable piece of legislation

for water related matters. The Water Resources Management Act (2013), passed but pending regulations (not

enforced), provides an improved framework for managing water resources based on the principles of integrated water

resource management, while not enforced it is considered best practice to adhere to the stipulations while ensuring

compliance to the Water Act of 1956 is also maintained.

Should water not be sourced directly from the City of Windhoek (for example from a private borehole), a licence to

abstract water is required in terms of the Water Act. Moonraker Outdoor Adventures Rest Camp (Pty) Ltd makes use of

two boreholes of which water abstraction permits will be applied for.

6.2 WASTEWATER DISCHARGE PERMIT

A discharge permit will be applied for at the Ministry of Agriculture Water and Forestry for the operations of the

wastewater treatment system and the discharge of treated effluent to the environment. The proponent is required to

ensure that non-hazardous wastewater is correctly connected into the appropriate wastewater system and that no

hazardous waste is disposed in the wastewater system. In the event that the project takes it upon itself to discharge

effluent via another means the proponent must ensure that all documentation, permits and measures are in place

before discharge occurs, including obtaining the relevant effluent discharge permit in terms of the Water Act to be

applied for at the Ministry of Agriculture Water and Forestry (MAWF). The proponent discharges domestic effluent via

French drain system which is sealed hereby ensuring not to contaminate the ground water.

In order to obtain an effluent wastewater, permit the proponent should have the following information and complete

the application form contained in Appendix B:

- Specification of the treatment system (type of technology)

- Description of major activities resulting in effluent generation

- List of contaminants (analysis of effluent samples)

- Effluent quality

- Points of discharge

- Show the present average quantities of incoming water, recycled water, final outflow, and

- Where final effluent discharged.

A number of potential environmental impacts may occur during the operations of the facilities. Potential impacts are

managed through individual management plans that have been developed to minimise these impacts and provide a

management framework for the Proponent. A summary of each management plan is provided below:

- Surface and Ground Water Quality Management Plan - Surface water and Groundwater management

measures including controls and measures to avoid contamination of water sources.

- Waste Management Plan - Procedures for the appropriate management of waste materials.



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7 SURFACE AND GROUNDWATER MANAGEMENT PLAN

7.1 INTRODUCTION

Chemical and waste spills must be contained so as not to contaminate the soil or groundwater. Any contact with

groundwater must be treated with exceptional care and reported immediately, so as to minimize the potential for

contamination of an aquifer. It is important to limit the potential for wastewater seepage to groundwater.

This Surface and Groundwater Management Plan outlines appropriate surface and groundwater water management

measures, monitoring programs and reporting procedures to be implemented.

7.2 OBJECTIVES

This Surface and Groundwater Management Plan has been prepared to minimise potential impacts on surface and

groundwater resulting from the operations of the project. It is important to report any contact with or contamination

of groundwater to the environmental officer as soon as possible.

7.3 RESPONSIBILITIES

WORKFORCE AND ALL CONTRACTORS

- Required to take all reasonable measures to prevent the discharge of sediments and pollutants from the site

in to surface and groundwater sources. Report any contact with groundwater to the manager.

7.4 SURFACE AND GROUNDWATER MANAGEMENT MEASURES

The Surface and Groundwater Management measures are designed to minimise the runoff of sediment-laden or

polluted water into the surrounding environment. Operational activities that could potentially alter natural surface

water and groundwater quality include:

- Chemical spills

- Refuelling

- Seepage of wastewater into groundwater

- Poor resource stewardship practices.

The following requirements are to be met to ensure that groundwater is not contaminated:

- All potentially contaminated runoff is to be directed to an adequately sized siltation basin before assessing

the quality and gaining authority for discharged to the environment.

- Oil and chemicals must be safely stored and removed.

- Any contact with groundwater must be treated with exceptional care and reported immediately, so as to

minimize the potential for contamination of an aquifer.

- If any groundwater is intersected operations must be temporarily stopped, the hole (with the water) must be

photographed and further instruction sought from the proponent and the environmental officer.



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TABLE 5 - WATER QUALITY MITIGATION MEASURES

7.5 SURFACE AND GROUNDWATER QUALITY MONITORING PROGRAMME

Every effort must be made throughout ss to preserve the quality of surface water sources that the project may impact.

Containment of waste and chemicals and the correct disposal thereof must be of an acceptable standard. Personnel

must report any unusual conditions and intersection with groundwater immediately to the lodge management. A

photographic record should be kept for future comparison (e.g. during maintenance and/or repair work).

ASPECT MITIGATION MEASURE RESPONSIBILITY

Pollution control measures.

Visual monitoring and photographic record of any surface and/or groundwater intersected

Lodge Management

Visual monitoring during rainfall events for runoff of polluted water

Lodge Management

Vehicles and machinery are to be regularly serviced to minimise oil and fuel leaks.

Lodge Management

Chemicals, oil and fuel must be stored securely to prevent any accidental spills.

Lodge Management

Sewage and Grey water

Ensure wastewater systems are connected into the appreciate municipal wastewater system

Lodge Management



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8 WASTE MANAGEMENT PLAN

8.1 INTRODUCTION

The activities at the project will generate both solid and liquid waste. The potential types of waste generated at the

project are typical for domestic home operations. Operational waste will include chemical waste such as spent dye and

inks, hydrocarbon waste from servicing of vehicles etc, that must be handled by registered waste disposal units.

8.2 OBJECTIVES

This Waste Management Plan has been prepared to ensure the proper storage, transport, treatment and disposal of

waste and where possible will follow the waste hierarchy, which encourages waste avoidance and waste reduction

followed by reuse, recycling and reclamation, before waste treatment and waste disposal.

8.3 ROLES AND RESPONSIBILITIES

WORKFORCE AND ALL CONTRACTORS

- Required to ensure that all waste generated during operational activities is removed and disposed of accordingly including providing evidence in the form of waste transfer receipts for the waste moved off site

- Ensure no windblown rubbish pollutes the environment, and

- Remove waste on a regular basis to prevent vermin.

8.4 SOLID WASTE

The project has a recycling system in place whereby reducing its impacts associated with solid waste generation. Where possible the proponent will implement measures to reduce, reuse and recycle waste generated as part of the operations of the project. Waste will be controlled through prevention and mitigation measures as follows:

- Reduce, reuse and recycle where possible

- Storage of domestic waste on site may result in the attraction of unwanted scavengers and should be removed as soon as is feasible

- Solid waste shall be stored in an appointed area in covered, tip-proof metal drums/skips for collection and disposal, and

- Chemical contaminated solids have the potential to cause contamination to the soil, ground and/or surface water, thus correct storage and disposal methods are required.



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TABLE 6 – WASTE MITIGATION MEASURES

8.5 WASTE DISPOSAL MONITORING

Certificates providing the safe disposal of waste from a permitted waste disposal site must be provided to the manager upon request.

ASPECT MITIGATION MEASURE RESPONSIBILITY

Environmental Contamination from liquid waste

Hydrocarbon and chemical contaminated solids must be storage

correctly and disposed of by registered companies.

Lodge Management

Safe disposal certificates must be kept and provided to the

Project manager on request.

Lodge management

Littering and Environmental Contamination from waste

No littering by workers shall be allowed. Lodge management

All litter on and around the project should be picked up and placed in the bins provided.

Lodge management

The site should be kept tidy and free of litter at all times. All domestic and general waste produced on a daily basis should be cleaned and contained daily.

Lodge management

No solid waste landfill will be established at the site. Lodge management

No waste shall be burned or buried anywhere unless when advised to do so by the local Municipality.

Lodge management

Recycling bins will be provided in appropriate areas to enable waste and refuse to be sorted for recycling and re-use. Bins must be baboon proof.

Lodge management

All solid waste must be collected, recycled where possible, and otherwise disposed of to an accredited waste disposal site.

Lodge management

All rubble is to be removed from the site to an approved disposal site. Burying of rubble on site is prohibited.

Lodge management



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9 CONCLUSION AND WAY FORWARD

This EMP:

A. Has been prepared pursuant to a contract with the proponent

B. Has been prepared based on information provided to ECC up to July 2019

C. Is for the sole use of the proponent, for the sole purpose of an EMP

D. Must not be used (1) by any person other than the proponent or (2) for a purpose other than an EMP, and

E. Must not be copied without the prior written permission of ECC.

ECC has prepared the EMP on the basis of information provided by the proponent.



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APPENDIX A: MOONRAKER OUTDOOR ADVENTURES RESTCAMP (PTY)

LTD HOUSE PHOTOS

FIGURE 2 AERIEL VIEW OF WOODEN CABINS AT MOONRAKER OUTDOOR ADVENTURES RESTCAMP (PTY)

FIGURE 3 ZOOMED IN VIEW OF MOONRAKER'S WOODEN CABIN



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FIGURE 5 A DONKEY AND HORSE AT A WATER POINT

FIGURE 4 MOUNTAIN VISUAL VIEW FROM A WOODEN CABIN



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APPENDIX B: APPLICATION FOR A WASTEWATER DISCHARGE LICENCE



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APPENDIX C: TEMPLATE FOR MONITORINGINSPECTION DATE: ______________________________________________

INSPECTION COMPLETED BY: ______________________________________

SUMMARY OF ACTIVITIES OCCURRING:

______________________________________________________________

______________________________________________________________

______________________________________________________________

______________________________________________________________

______________________________________________________________



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Ref No.

Item Requirements Responsibility Compliant Notes / Action Taken / Corrective Action

Required

1 Operations of mechanical equipment and engines

- Are regular checks of all

equipment conducted routinely?

- Are spill kits available?

Lodge Management Yes No N/A

2 Production and effluent

discharge

- Is the domestic effluent

discharged off into approved

systems?

- If not, are regular water quality

samples taken to ensure the

treated wastewater complies to

the prescribed general standards

as set out in the Water Resources

Management Act, 2004 (Act No.

24 of 2004)?

- Lodge

Management

- or

Environmental

officer

Yes No N/A



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Ref No.


Required

3 Solid waste generation

- Has the waste management plan

and the application of the waste

management hierarchy

implemented?

- Are suitable collection points in

place for waste collection at the

rest camp?

- Is waste collected regularly and

transported correctly?

- Is hazardous waste such as waste

oil/lubricant stored in a hazardous

waste storage area and disposed

of by accredited hazardous waste

handlers such as City of

Windhoek, Rent A Drum and Kleen

Technologies and Kleen Tech, City

of Windhoek.?

Lodge Management Yes No N/A



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Ref No.


Required

4 Noise

- Is the rest camp avoiding noise

generating activities at night?

- Are procedures for receiving

complaints from nearby land users

or residents in place and

mitigation measures implemented

should operational activities

generate excessive noise?

- Are vehicles and equipment kept

in good working order to avoid

and to minimize noise impact?

Lodge management Yes No N/A

5 Support Game Counts

- Is an annual game count on the

proclaimed 2,001 hectare area

conducted at least twice per

annum?

Lodge management Yes No N/A

6 Pest Control - Is pest infestation /control done? Lodge management

7 Bush encroachment control

- Is the monthly schedule dedicated

to deal with bushes and shrubs

encroaching species conducted?

Lodge management



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Ref No.


Required

8 Wildlife interactions

- Are the personnel and guides

trained?

- Is environmental awareness

provided to guests and tourist?

- Are walking and biking trails setup

in such a way that wildlife is not

disturbed?

- Are the trails monitored on a daily

basis?

- Are any poaching activities are

reported to MET?

Lodge Management

Yes No N/A

9 Maintenance or renovations

- Is the Waste Management Plan

implemented?

- Are there suitable collection

points for the waste on rest

camp?

- Is waste collected daily

transported in suitable containers

- Are spill kits available?

- Lodge management

- or Environmental Officer

Yes No N/A



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Ref No.


Required

10 Lighting /energy

- Are energy efficient light bulbs

installed?

- - Is unnecessary lighting avoided

where possible?

- - Are lights switched off at night

- Is staff trained so they are aware

of the need to save energy?

- Is solar power system maintained?

- Lodge Management

- or Maintenance Yes No N/A



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APPENDIX D: COMPLAINTS REGISTER TEMPLATE

NAME CONTACT DETAILS

DATE AND

LOCATION OF

COMPLIANT

NATURE OF

COMPLIANT

ACTION TAKEN TO

RESOLVE

NOMINATED PERSON TO

RESOLVE ISSUE (Signature)

DATE OF RESOLUTION/

CLOSED OUT

COMPLAINT



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APPENDIX E: MONTHLY INTERNAL COMPLIANCE CERTIFICATE FOR THE PERIOD ………… TO …………

MANAGEMENT REPRESENTATIVE: SIGN:

ENVIRONMENTAL OFFICER: SIGN:

Date of Submission:

Key activities on site during the month:

NON-CONFORMANCE: Area of activity:

Reason:



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Responsible party:

Results:

Correction action taken:

Intended follow-up:

GOOD PERFORMANCE: Description of activity or action in which the area/person went beyond compliance towards responsible care for the environment:



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ADDITIONAL COMMENTS:

ecc -95 129 rep 01 d environmental management...

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