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ESIA for the proposed development of the Gergarub Mine 1 Enviro Dynamics cc February 2014 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) FOR THE PROPOSED DEVELOPMENT OF THE GERGARUB MINE DRAFT SCOPING REPORT FEBRUARY 2014 GERGARUB PROJECT

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Page 1: GERGARUB PROJECT ENVIRONMENTAL AND … effects, heritage loss, and resource demand. However, the overriding concern in the Rosh Pinah community is the uncertainty around the future

ESIA for the proposed development of the Gergarub Mine 1

Enviro Dynamics cc

February 2014

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA)

FOR THE PROPOSED DEVELOPMENT OF THE GERGARUB MINE

DRAFT SCOPING REPORT

FEBRUARY 2014

GERGARUB PROJECT

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February 2014

COPYRIGHT © Enviro Dynamics 2014, All Rights Reserved

PROJECT NAME Gergarub Project

STAGE OF REPORT Draft Scoping Report for Public Review

CLIENT

Skorpion Mining Company (Pty) Ltd

Enquiries: Mr J. Kamfer

Tel: +264 63 271 2382

Email: [email protected]

SPECIALIST CONSULTANT

Enviro Dynamics cc

Enquiries: Ms. S. van Zyl

Tel: +264 61 223 336

Email: [email protected]

DATE OF RELEASE February 2014

CONTRIBUTORS TO THE

REPORT

Narrative: Stephanie van Zyl, Charlotte Cronje, Coleen

Mannheimer, John Kinahan, John Irish, Mark Zunckel,

Brett Williams, Carla Saayman, Desmond Visser, Gerrit

Viviers, Bruce Engelsman.

Maps: Eddy Kuliwoye

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DECLARATION

I hereby declare that I:

(a) have knowledge of, and experience in conducting specialist assessments, including

knowledge of the Environmental Management Act (Act 7 of 2007)and the

Regulations and Guidelines that have relevance to the proposed activity;

(b) perform the work relating to the application in an objective manner, even if this

results in views and findings that are not favourable to the applicant;

(c) comply with the abovementioned Act, its Regulations, Guidelines and other

applicable laws.

I also declare that there is, to my knowledge, no information in my possession that

reasonably has or may have the potential of influencing –

(i) any decision to be taken with respect to the application in terms of the Act and its

Regulations; or

(ii) the objectivity of this report, plan or document prepared in terms of the Act and its

Regulations.

Stephanie van Zyl

Environmental Assessment Practitioner

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EXECUTIVE SUMMARY

Introduction

Skorpion Mining Company (Pty) Ltd in joint venture with Rosh Pinah Zinc Corporation

is currently considering the economic viability of mining a zinc, lead and silver

deposit named Gergarub. The deposit is located near Rosh Pinah in southern

Namibia.

Location of the Gergarub Deposit

Legal requirement

According to the Namibian Environmental Management Act (Act 7 of 2007) and its

Regulations (2012), as well as international standards such as those of the

International Finance Corporation, an Environmental and Social Impact Assessment

(ESIA) is required for the project. Enviro Dynamics cc is conducting the ESIA parallel

to and in close collaboration with the feasibility study currently underway.

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This report

The ESIA is now concluding its scoping phase with this scoping report. The purpose of

the scoping process was to identify the key issues to be investigated and to refine

the Terms of Reference for the specialist studies. The document includes the

following:

a project description;

a summary of the environment regulatory framework of the project;

an overview of the socio-economic and bio-physical environment of the

project;

an account of the public consultation and disclosure process undertaken in

Rosh Pinah and Windhoek;

a list of the key issues identified with a preliminary risk assessment;

the specialist studies to be undertaken with their Terms of Reference; and

the way forward.

Community and stakeholder concern

It is clear that the community recognises the biophysical sensitivity of the area.

Further investigations therefore need to be conducted to find ways of limiting visual

impact, habitat and biodiversity loss, water pollution, dust and its health and

ecological effects, heritage loss, and resource demand.

However, the overriding concern in the Rosh Pinah community is the uncertainty

around the future vitality of the town. The existing mines have a limited life, which

brings about insecurity in peoples’ minds about their future employment. Another

area of concern involves the ability of the existing town structure to absorb the

additional need for land, housing, infrastructure and social services such as

schooling, health care, and security. Not only should the additional workers and

their families be accommodated, but the incoming job seekers are likely to exceed

available employment opportunities. If these people settle in Rosh Pinah, the

shortfall of available housing, services and infrastructure is likely to grow.

The specialists now need to work out the details of these concerns in the coming

months. The table below provides a summary of the Terms of Reference of the

specialists that will be conducting these investigations.

The ESIA lead team will ensure that the specialists receive the details reports of the

inputs provided during public consultation so that all concerns are properly covered.

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Specialist studies

Key issues to be investigated, specialists assigned and their main Terms of Reference.

THEME / STUDY AREA SPECIALIST TERMS OF REFERENCE

Ecology Dr John Irish - Biodata Coleen Mannheimer

Focus on the biodiversity by studying

changes in the study area due to:

change in the distribution and ration of

endemic, range-restricted endemic and

potentially threatened species;

change in the ecological functioning of

the area;

cumulative and related effects of

change that the project may add to the

ecology; and

impacts on priority ecosystem services.

Groundwater Supply and Quality

Desmond Visser - SRK Pierre Botha - Geo Pollution Technologies

Establish pre-development baseline

conditions and aquifer characteristics.

Identify potential sources, pathways and

receptors for groundwater contamination.

Study expected changes in the:

groundwater quality and movement

due to the infrastructure, facilities and

activities of the project, particularly the

tailing storage facility; and

groundwater supply due to operations of

the mine, particularly pit/mine

dewatering.

The following model will be used:

MODflow groundwater equation.

Geochemistry Richard O’Brien - SRK

Study the geochemical composition of the

material to be disposed of at the proposed

tailings storage facility so that chemical

changes to the receiving environment,

including soils and groundwater, may be

determined.

Air Quality Dr Mark Zunckel - uMOYA-NILU

Focus on air quality by studying changes in

the receiving environment by:

identifying baseline conditions,

potentially sensitive receptors, process

and dust emissions of the proposed

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THEME / STUDY AREA SPECIALIST TERMS OF REFERENCE

construction and mining activities;

modelling the expected downwind air

conditions created by the project

infrastructure, facilities and activities;

and

determining the impact on climate

change due to possible Greenhouse

Gas Emissions.

The following approach will be used during

this study:

US-EPA emission factors will be used;

Ambient concentrations of coarse and

fine (PM10) particulates will be estimated

using the US-EPA and IFC approved

SCREEN 3 model for default meteorology

and the estimated emissions from the

tailings dam, waster rock dump and the

mine activities (dumping and vehicles).

The predicted concentrations will be

plotted as line graphs and on maps and

compared with WHO ambient air quality

guidelines.

Noise Brett Williams - Safetech

Focus on noise by studying changes in the

receiving environment by:

identifying baseline conditions,

potentially sensitive receptors, and

emissions expected from construction,

process and mining activities; and

modelling the noise conditions created

by the construction and operation of the

project infrastructure and facilities.

The following models will be used:

SANS 10103:2008 Version 6 - The

measurement and rating of

environmental noise with respect to

annoyance and to speech

communication;

SANS 10328, Methods for environmental

noise impact assessments; and

SANS 10357, The calculation of sound

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THEME / STUDY AREA SPECIALIST TERMS OF REFERENCE

propagation by the CONCAWE method.

Visual Change Norman van Zyl - Enviro Dynamics

Focus on visual changes in the receiving

environment by:

identifying potentially sensitive receptors,

baseline visual resource conditions and

visual sources generated by the project

infrastructure, facilities and activities;

generating a visual inventory to

determine the value of the views from

the various visual receptors; and

modelling the visibility of the project

infrastructure, facilities and activities from

significant views.

The following model will be used:

US Army Corps of Engineers (Henderson,

1988) Visual Resources Assessment

Procedure (VRAP).

Socio-economic Impact Carla Saayman - Enviro Dynamics

Focus on the socio-economic environment

by studying changes in the:

various forms of land-use;

tourism, traditional livelihood,

commercial farming and mining

industries;

social and economic conditions at local,

regional and national levels; and

sustainability of Rosh Pinah which

includes project-induced influx, pressure

on infrastructure and services, social

conflicts for opportunities and social

closure.

Health Impact Rietta Oosthuizen - CSIR

Consider the changes in the community

health and wellbeing by:

creating a baseline community health

and well-being profile by identifying the

communities of concern in the Rosh

Pinah area;

determine the status quo of the factors

that may influence their vulnerability to

the environmental exposure as a result of

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THEME / STUDY AREA SPECIALIST TERMS OF REFERENCE

the development including aspects such

as existing diseases, other exposures

such as domestic fuel use, lack of

services such as water and sanitation,

low educational status, unemployment

etc. In addition, determine existing

factors that assist in better coping with

environmental exposure such as access

to health care, high education level, low

unemployment etc.

evaluate the risks and impacts to the

health and safety of the affected

communitites during the project life-

cycle and establish preventive and

control measures consistent with good

international industry practice such as

the World Bank Group Environmental,

Health and Safety (EHS) Guidelines or

other internationally recognised sources.

The HIA approach is a practical and multi-

disciplinary process, combining a range of

qualitative and quantitative evidence in a

decision-making framework (Lock, 2000).

Archaeology Dr John Kinahan - QRS Namibia

Focus on the archaeological landscape of

the study area by:

conducting an overview of the project

area to identify sensitive areas to avoid

(completed to guide the planning

process); and

a detailed survey of the area affected

by the proposed footprint of all the

facilities, including infrastructure of the

mine, to identify archaeological sites

that require mitigation.

Restoration Dr Theo Wassenaar - African Wilderness Restoration

Develop a concept restoration plan for the

mine which fits the ecological make-up of

the area in consultation with the mine

management.

In addition to these specific Terms of Reference, they will also be tasked:

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to investigate mitigation options for the impacts (during construction,

operation, decommissioning and post closure phase) identified;

to use recent environmental and social baseline data at an appropriate level

of detail (IFC PS 1);

to include an assessment of whether the impacts can be mitigated or

controlled to acceptable levels;

to use a combination of local legislation augmented with international

standards where needed;

to complete their studies in line with the Performance Standards of the

International Finance Corporation, the fulfilling of which is important to

achieve a bankable Feasibility Study;

to determine all cumulative impacts that may result due to the proposed

development; and

to conduct an alternatives assessment.

The way forward

This Draft Scoping Report will be circulated to the authorities and the public

for comment. These comments will be a) incorporated into the report and b)

carried forward for consideration in the remaining phases of the ESIA process.

The Draft Scoping Report will be submitted to the Directorate of

Environmental Affairs (DEA) within the Ministry of Environment and Tourism

(MET) after comments received from the public have been incorporated.

The specialist studies have been commissioned, as outlined above (this is the

full investigation phase).

These specialist studies will form the basis for the Draft Environmental and

Social Impact Assessment Report and will inform the environmental

considerations of the bankable Feasibility Study Process.

The Draft Environmental and Social Impact Assessment Report will again be

shared with the community and the authorities, using a similar process as for

the draft scoping report. However, a feedback meeting will be held at the

time.

Once the documents have been submitted, there will once again be an

opportunity to submit comments to the Directorate of Environmental Affairs,

the process which will be specifically explained then.

The consultant will furthermore recommend a grievance mechanism for

including any complaints that may arise during the implementation of the

project to be included in the Environmental and Social Management Plan

(the document spelling out the management actions which are required to

implement the recommendations of this assessment).

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ....................................................................................................... iii

TABLE OF CONTENTS ........................................................................................................... x

TABLES AND FIGURES ....................................................................................................... xiii

APPENDICES ...................................................................................................................... xv

GLOSSARY ....................................................................................................................... xvi

ABBREVIATIONS AND ACRONYMS ............................................................................... xviii

1 BACKGROUND............................................................................................................. 1

1.1 Introduction ....................................................................................................... 1

1.2 Terms Of Reference ......................................................................................... 2

1.3 Methodology .................................................................................................... 3

1.4 Report Outline ................................................................................................... 6

2 PROJECT DESCRIPTION ................................................................................................ 7

2.1 Background ...................................................................................................... 7

2.2 Site Locality ....................................................................................................... 8

2.3 Description of the Gergarub deposit .......................................................... 10

2.4 Mining and Processing .................................................................................. 14

2.5 Infrastructure Requirements .......................................................................... 17

2.5.1 Power Supply .................................................................................................. 17

2.5.2 Water Supply ................................................................................................... 17

2.5.3 Housing and Employment ............................................................................. 19

2.5.4 National Road................................................................................................. 20

2.5.5 Tailings Storage Facility .................................................................................. 20

2.5.6 Proposed site layout: underground vs. open-pit scenarios ...................... 24

2.5.7 Mine infrastructure requirements at Gergarub .......................................... 24

2.5.8 Processing and concentrator infrastructure requirements at

Gergarub ......................................................................................................... 25

2.5.9 Waste Rock ..................................................................................................... 25

2.5.10 Logistics ............................................................................................................ 25

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2.5.11 Development Schedule ................................................................................ 26

2.6 Assumptions and Limitations ......................................................................... 26

3 LEGAL AND REGULATORY REQUIREMENTS ............................................................... 28

4 THE RECEIVING ENVIRONMENT ................................................................................. 47

4.1 Overview ......................................................................................................... 47

4.2 The Biophysical Environment ........................................................................ 49

4.2.1 Climate and Air Quality ................................................................................. 49

4.2.2 Surface water ................................................................................................. 50

4.2.3 Groundwater .................................................................................................. 51

4.2.4 Biodiversity ....................................................................................................... 52

4.2.5 Noise ................................................................................................................. 56

4.3 The Socio-Economic Environment ............................................................... 57

4.3.1 Introduction ..................................................................................................... 57

4.3.2 Regional overview ......................................................................................... 57

4.3.3 Overview of Rosh Pinah ................................................................................. 57

4.3.4 Archaeology ................................................................................................... 61

4.3.5 Visual Resources ............................................................................................. 62

5 Stakeholder Engagement ........................................................................................ 64

5.1 Introduction ..................................................................................................... 64

5.2 Policy and legal Requirements .................................................................... 65

5.3 The stakeholders ............................................................................................. 65

5.4 Approach ........................................................................................................ 67

5.5 The meetings to date .................................................................................... 69

5.6 Public Feedback ............................................................................................ 75

5.7 Public concern ............................................................................................... 75

6 IMPACT ASSESSMENT ................................................................................................. 80

6.1 Mitigation hierarchy ....................................................................................... 80

6.2 Methodology Employed for the Impact Assessment ................................ 81

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6.3 Assessment of Impacts .................................................................................. 83

7 CONCLUSIONS AND RECOMMENDATIONS ............................................................. 90

7.1 Introduction ..................................................................................................... 90

7.2 Specialist studies ............................................................................................. 91

8 REFERENCES ............................................................................................................... 96

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TABLES AND FIGURES

Figure 1: Location of the Gergarub Project ................................................................... 1

Figure 2: The ESIA Process .................................................................................................. 5

Figure 3: SHG Zinc Ingots ................................................................................................... 7

Figure 4: Site Locality in the Region and in relation to nearby farms and

Sperrgebiet National Park. ................................................................................ 9

Figure 5: Illustration of continental rifting and position of Rosh Pinah Graben

which was filled with sediment and volcanic material and

subsequently deformed (adapted from Alchin et. al, 2005) ..................... 10

Figure 6: Diagram indicating the Gariep belt in relation with the basement

(Borg et. al, 2003, Pilote et. al, 2011) .............................................................. 11

Figure 7: Resource estimation process .......................................................................... 12

Figure 8: A 3D representation of the Gergarub deposit ............................................. 13

Figure 9: Typical process of mining and processing zinc ore ..................................... 14

Figure 10: Bord and Pillar Mining Method ....................................................................... 15

Figure 11: Typical Concentration Process ....................................................................... 16

Figure 12: Proposed Gergarub infrastructure and processing plant ........................... 19

Figure 13: Map showing the three investigated locations for the TSF in

relation to other landmarks. ............................................................................ 20

Figure 14: Gergarub infrastructure, processing plant, life zones,

archaeological sites and prevailing wind direction. ................................... 23

Figure 15: Eastern part of the ESIA study area ................................................................ 48

Figure 16: Major surface drainage patterns within the ESIA study area. .................... 50

Figure 17: Life zones identified in the study area ........................................................... 53

Figure 18: Typical contrasting view east of the C13 ...................................................... 63

Figure 19: Posters put up in the RoshSkor offices ............................................................ 68

Figure 20: Venue for the Public Meeting in Rosh Pinah................................................. 69

Figure 21: Mitigation hierarchy applied. ......................................................................... 80

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Table 1: Concentrator utility consumption .................................................................. 16

Table 2: Current total water supply and usage .......................................................... 18

Table 3: Future total water supply and usage ............................................................. 18

Table 4: Major advantages and disadvantages of Site 3 ......................................... 21

Table 5: Legal and Regulatory Requirements ............................................................. 29

Table 6: Vulnerability ratings .......................................................................................... 47

Table 7: Climate Related Sensitivities ........................................................................... 49

Table 8: Surface water related sensitivities .................................................................. 51

Table 9: Groundwater related sensitivities ................................................................... 52

Table 10: Life zone sensitivity scoring .............................................................................. 54

Table 11: Biodiversity Related Sensitivities ...................................................................... 55

Table 12: Noise related sensitivities ................................................................................. 56

Table 13: Socio-economic sensitivities in the project area. ........................................ 60

Table 14: Types of archaeological findings ................................................................... 62

Table 15: Archaeological sensitivities in the study area .............................................. 62

Table 16: Visual resources and their sensitivities ............................................................ 63

Table 17: Summary of Stakeholders at National, Regional and Local Level ............ 66

Table 18: Notifications Placed in Press............................................................................ 68

Table 19: Summary of the meetings conducted .......................................................... 71

Table 20: Summary of issues resulting from the Public Participation process ........... 76

Table 21: Definitions of each of the Criteria used to determine the

significance of impacts ................................................................................... 81

Table 22: Definitions of the various significance ratings ............................................... 82

Table 23: Impact assessment of the proposed project ............................................... 83

Table 24: Key issues to be investigated, specialists assigned and their main

Terms of Reference........................................................................................... 91

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APPENDICES

APPENDIX A Stakeholder Engagement Plan

APPENDIX B Stakeholder Engagement Policy and Legal Requirements

APPENDIX C Stakeholder List

APPENDIX D Newspaper Notices

APPENDIX E 1. Minutes of Windhoek Meeting

2. Minutes of Rosh Pinah Meeting

3. Presentation

APPENDIX F Issues and Responses Trail

APPENDIX G CV: Stephanie van Zyl

APPENDIX H IFC Performance Standards and Namibian Regulation: Gap Analysis

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GLOSSARY

BACKFILLING The refilling of an excavated hole.

BALL MILL A ball mill is a type of grinder used to grind materials

into extremely fine powder by balls.

CUT AND FILL STOPING Cut and fill stoping is a mining method used in steeply

dipping or irregular ore zones.

CYCLONES (HYDRO-CYCLONES) Machinery that enhances centrifugal forces to

separate solids from liquids or to classify coarser or

greater mass particles from finer or lesser mass solids.

ENDEMIC Only occurring naturally in a specific area.

FELSIC Enriched in the lighter elements such as silicon, oxygen,

aluminium, sodium, and potassium.

INTERGRANULAR Occurring along the boundaries between crystals or

grains of a material.

MAFIC Describing rocks, such as silicate minerals, magmas,

and volcanic and intrusive igneous rocks, which

contain relatively high concentrations of magnesium

and iron.

OROGENIC Landscapes that have been shaped owing to the

forces and events that led to structural deformation of

the earth’s lithosphere caused by the collision of the

tectonic plates.

PARASTATAL Owned or controlled wholly or partly by the

government.

RETICULATION Network of pipelines or powerlines.

RETROVIRAL Any of an association of viruses that contain RNA and

reverse transcriptase, including the virus that causes

AIDS.

RHYOLITE Rhyolite is an igneous, volcanic rock of felsic

composition.

SLURRY Slurry is the thick mixture of water and an insoluble

substance.

SEMI-AUTOGENOUS GRINDING The self-grinding of the ores in a Semi-Autogenous

Grinding mill with the aid of small balls (the same

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technique used in ball mills).

SPECIAL HIGH GRADE ZINC INGOTS Zinc Ingots that have a relative purity of 99.995%, which

can only be reached through refining.

STEPPED BORD AND PILLAR Stepped bord and pillar method is a variant of the

room and pillar method where mined material is

extracted across a horizontal plane, creating bords

(alleys) and pillars.

TAXA Taxa are any unit used in the science of biological

classification, or taxonomy to distinguish levels of

hierarchy.

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ABBREVIATIONS AND ACRONYMS

AIDS Acquired Immunodeficiency Syndrome

BID Background Information Document

dB Decibel

DOTS Directly Observed Therapy, Short-course

EMP Environmental Management Plan

EP Equator Principles

EPL Exclusive Prospecting License

ESIA Environmental and Social Impact Assessment

ESMP Environmental and Social Management Plan

ha Hectare

HIV Human Immunodeficiency Virus

I&APs Interested and Affected Parties

IFC International Finance Corporation

JORC Joint Ore Reserves Committee

kWh Kilowatt Hour

MBGL Metres Below Ground Level

MD Maximum Demand

Mℓ Megalitre

MOA Memorandum Of Agreement

MVA Megavolt Ampere

MW Megawatt

Normal Cubic Metre

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PS Performance Standards

RPZC Rosh Pinah Zinc Corporation

SAG Semi-Autogenous Grinding

SHG Special High Grade

TB Tuberculosis

TOR Terms of Reference

TSF Tailings Storage Facility

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Figure 1: Location of the Gergarub Project

1 BACKGROUND

1.1 INTRODUCTION

Skorpion Mining Company (Pty) Ltd is currently managing a feasibility study to

investigate the economic viability of mining a zinc, lead and silver deposit named

Gergarub. The deposit is located near Rosh Pinah in southern Namibia (Figure 1).

The Gergarub development will be undertaken by Skorpion Mining Company in joint

venture with Rosh Pinah Zinc Corporation based on their Memorandum of

Agreement (MOA, 2005) and other subsequent agreements concluded between

them.

According to the Environmental Management Act (Act 7 of 2007) and its

Regulations (2012), as well as international standards such as those of the

International Finance Corporation, an Environmental and Social Impact Assessment

(ESIA) is required for the project.

Enviro Dynamics cc was consequently appointed to conduct an ESIA for the

development of the Gergarub Mine. The ESIA is being conducted parallel to and in

close collaboration with the feasibility study currently underway.

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1.2 TERMS OF REFERENCE

This ESIA is being conducted in accordance with Namibia’s Environmental

Management Legislation (Environmental Management Act, 2007) and its

Regulations (2012). The Skorpion Zinc Mining Company also subscribes to the

requirements of the Equator Principles (EP), International Finance Corporation (IFC)

and Vedanta’s Sustainability Framework (policies and guidelines), therefore this ESIA

process is designed and is being carried out to fulfil their Performance Standards and

corporate internal standards.

The EP’s and IFC PS’s broaden the suite of studies that are now done for ESIA’s. These

additional measures include amongst others labour and working conditions,

emergency preparedness and response, grievance mechanisms, occupational

health and safety, pollution prevention, critical habitats and ecosystem services.

Appendix H contains a table describing the linkages and gaps between IFC

Standards and Namibian Legislation. The table thus indicates how Performance

Standards are to be complied with during this study.

Under the EP and based on the IFC’s categorisation process, all projects must be

categorised depending on their environmental and social risk. The Gergarub

project falls under Category A, which include projects “with potential significant and

adverse social or environmental impacts which are diverse”. More details about

legislative requirements for this ESIA process and this project are provided in

Section 3.

The Terms of Reference for this study, as received from Skorpion Mining Company, is

quoted as follows:

“Environmental Scoping

A 3rd party consultant must identify a comprehensive list of potential

environmental impacts and conduct a qualitative

environmental risk assessment and prepare a detailed report

with a summary of major risks. The work must include the

following:

Evaluate and compare the risks associated with various project

alternatives;

Review the potential for any aspect of the project to create an

unacceptable environmental risk;

Prepare an Environmental Scoping Report detailing studies that

will be required taking the project forward. This needs to be

aligned with the project schedule provided by the lead

consultant; and

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Obtain input from Authorities and Interested and Affected

Parties (I&APs) during this phase regarding potential

environmental impacts, the records of which shall be

integrated with the Scoping Report.

Public participation shall be conducted to satisfy the requirements of

the Environmental Management Regulations (2012) of Namibia, and

will demonstrate that Authorities and Interested and Affected Parties

(I&APs) were provided with a reasonable opportunity to provide

input into each phase of the process. The 3rd party consultant must

design a public consultation and disclosure plan which shall be the

basis for consultation during the environmental process.

Environmental Impact Assessment (EIA)

Review and update the application national and international

statutory requirements, treaties and planning directives for the

area and ensure that they are made applicable to the project

and future operations;

List any specific approvals, permits or licenses that are required

and carry these over to the Environmental Management Plan,

which will provide a schedule for obtaining the necessary

approvals;

Commence baseline studies and any necessary investigations;

Conduct the Impact Assessment according to an agreed upon

methodology to be used by all specialists;

Prepare a draft Environmental Impact Assessment Report, the

contents of which should satisfy the requirements of the

Environmental Management Regulations (2012); and

The Report should include an Environmental Management

Plan, including a permit application schedule, schedule for

implementation of mitigation measures, resources required,

cost estimates, monitoring program, ongoing stakeholder

engagement, rehabilitation (concurrent for operations and for

closure) and closure plan.”

1.3 METHODOLOGY

The Environmental and Social Impact Assessment (ESIA) is being carried out as a

process in close consultation with the Feasibility Study Team. Feedback is constantly

given so that environmental concerns may be considered and catered for as the

design of the project progresses. The Team has therefore adopted a proactive

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approach in dealing with potential environmental and social areas of concern,

rather than a reactive one.

The Feasibility Study involves a step referred to as the Optimisation Phase, during

which the best alternatives are considered by all specialists on the broader Feasibility

Team. The ESIA Team is very much part of this phase to ensure that environmental

and social considerations are considered during optimisation of all alternatives. In

order to site facilities responsibly, the Team conducted baseline study of the area to

determine sensitivities. These sensitivities informed the large site selection process.

More details on this work are provided in Section 4.

The ESIA process followed may be best described by means of Figure 2 below. The

formal process, according to prescribed legislation, commences with a scoping

phase. The scoping process is used for project familiarisation followed by the

identification of key concerns through interaction with relevant stakeholders. Enviro

Dynamics has now completed this scoping phase. This Scoping Report contains the

findings of scoping and it sets the course of action for the full investigation phase,

which is to follow.

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The main steps required within the process in order to achieve environmental

clearance from the Environmental Commission are as follows:

Scoping

Identify Interested and Affected Parties (I&APs);

Announce the ESIA process / registration of I&APs;

Distribution of the Background Information Document (BID);

Public and stakeholder consultation through electronic means, and public

and focal meetings;

Prepare a draft Scoping Report;

Public review of the draft Scoping Report; and

Prepare final Scoping Report and submit to the Environmental Commissioner.

Appeal ?

Environmental and Social Assessment

Specialists Analyse Impacts

Mitigation Measures

Environmental and Social Impact Report

Decision

Implementation

Environmental

Management Plan

Scoping

Key Issues

Scope of ESIA

Scoping Report

Figure 2: The ESIA Process

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Specialist Studies

Conduct specialist studies to address issues identified during the scoping

phase.

Assessment of Impacts

Establish the environmental risk of the overall project, its alternatives and

various components;

Establish mitigation protocols;

Prepare the draft ESIA Report and Environmental and Social Management

Plan;

Public review of draft ESIA and ESMP;

Prepare the final ESIA and ESMP and submit to the Environmental

Commissioner;

Await decision of the authorities; and

Communicate the decision to I&APs and Skorpion Mining Company.

1.4 REPORT OUTLINE

This Scoping Report provides the following information:

A brief introduction to the project, its ESIA requirements, and the Terms of

Reference (TOR) for this ESIA process (Section 1);

A project overview, with particular emphasis on those aspects which are

expected to interact with the biophysical and socio-economic environments

of Rosh Pinah and the Region (Section 2);

A legal review including the key regulatory requirements which affect

environmental and social performance (Section 3);

The findings of the public consultation and disclosure process followed so far

(Section 4);

An overview of the environment in which this project will be implemented,

focusing on sensitivities (Section 5); and

Key potential impacts and the way forward for the ESIA process (Section 6).

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2 PROJECT DESCRIPTION

2.1 BACKGROUND

Skorpion Zinc Mine

Skorpion Zinc Mine is located 25 km north-west of the town Rosh Pinah in southern

Namibia. Oxidized zinc ore, containing zinc oxides, zinc carbonates as well as zinc

silicates is mined from an open pit. It is then processed and refined in a world class

refinery operation at Namzinc refinery where 100 % beneficiation is done into special

high grade (SHG) zinc ingots on site. These ingots are ready for shipping to be used

abroad (Figure 3).

Skorpion recently completed a drilling programme in its open pit which resulted in

the lifespan of the Skorpion Mine being extended from 2015 to 2016/17. Regional

exploration for additional zinc deposits is continually undertaken.

Discovery of the Gergarub deposit

Even though no additional zinc oxides were revealed during exploration, the

Gergarub zinc sulfide deposit was discovered in 2008 by Skorpion Zinc in Exclusive

Prospecting License (EPL) 2616.

Figure 3: SHG Zinc Ingots

Oxide ( O2- ): An oxide is a chemical compound that contains at least one oxygen atom and

one other element in its chemical formula.

Sulfide ( S2=): A sulfide is a chemical compound that contains at least one sulphur atom and

one other element in its chemical formula.

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The bankable feasibility study is currently in an optimising phase and is therefore

investigating all possible extraction methods. Both underground mining, which

probably will be the predominant method, and open pit mining methods are being

evaluated and further studies will be conducted to assess viability.

2.2 SITE LOCALITY

Gergarub is located on the farm Spitskop 111, along the C13 road between Rosh

Pinah and Aus within the Oranjemund Constituency (Figure 4). It lies approximately

10km south-east of Skorpion Zinc Mine and 15km north-west of Rosh Pinah Mine.

West of the town lies Diamond Area 1, a diamond mining area controlled by

Namdeb. This area lies within the Sperrgebiet, which is a national park. The east is

predominantly a small stock farming area. Farms are large due to the low carrying

capacity of the land.

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Figure 4: Site Locality in the Region and in relation to nearby farms and Sperrgebiet National Park.

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2.3 DESCRIPTION OF THE GERGARUB DEPOSIT

The following is a preliminary project description based on information available at

the time when the information was shared with the public during consultation. The

content hereof will be refined as the results of the Feasibility Study become

available. The ESIA report (available in the first term of 2014) shall contain the final

project description and the final environmental and social impact assessment will be

based on the final information.

Depth

The deposit was discovered beneath 60 to 100 m of alluvial cover and extends to a

depth of approximately 530 m.

Regional Geology

The Gergarub Project is located within the Gariep belt, one of the most prominent

geological features of southwestern Namibia. This belt was formed during the closure

of the Adamastor Ocean as part of the formation of Gondwana and the closure

occurred about 750 million years ago when the cratons of the Congo, Kalahari and

Rio de la Plata collided (Figure 5).

The Gariep belt includes various lithologies which consist mainly of volcanic and

oceanic sediments that were formed during the rifting phase when the opening of

the Adamastor Ocean occurred. The Gariep complex consists of the Marmora

Terrane to the west and Port Nolloth Zone to the east which hosts the Gergarub

deposit.

Figure 5: Illustration of continental rifting and position of Rosh Pinah Graben which was filled with

sediment and volcanic material and subsequently deformed (adapted from Alchin et. al,

2005)

The lithologies of the Port Nolloth Zone were formed in a NNW-SSE trending graben

which was active from about 750 million years ago to about 550 million years ago.

The Port Nolloth Zone consists of the older Stinkfontein sub-group and the younger

Hilda subgroup (Figure 6). The Stinkfontein subgroup contains volcanic units which

are interpreted as the early stages of rifting.

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These are overlain by the three units of the Hilda subgroup, Kaigas, Rosh Pinah and

Picklehaube formations, which record sedimentation and volcanism in an actively

rifting graben setting.

The Gergarub deposit is situated within the Rosh Pinah Formation, which hosts a

major base metal ore province with two active zinc mines, Skorpion and Rosh Pinah.

The Rosh Pinah Formation consists of repetitive sedimentary cycles of sandstones

and mudstones, indicating rapid deposition with intermittent quiet periods.

Local Geology

The Gergarub succession, determined via diamond drill cores, is made up of ten

distinct geological units which have all been influenced by metamorphism. This

metamorphism occurred as a consequence of the closure of the Adamastor Ocean

basin. The main geological unit consist of Greywackes, a variety of sandstone, that

are fine to medium grained. The zinc minerals that will be mined occur in sulfide

zones.

Resource estimate

Resource estimation involves approximating the value and significance of a

resource and determining its size, extent and nature.

In order of increasing geological confidence, resource estimation can be sub-

divided into two categories: inferred and indicated (Figure 7).

Figure 6: Diagram indicating the Gariep belt in relation

with the basement (Borg et. al, 2003, Pilote et. al,

2011)

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Figure 7: Resource estimation process

Gergarub is divided into 5 zones and their deposits are individually estimated in

terms of grade and tonnage. A large percentage of the resources in these zones

are classified in the “indicated” level of confidence. Zones 2 and 3 are considered

to be the heart of the project and contain approximately 12 million tonnes of ore.

Figure 8 below is a three-dimensional (3D) projection of what the deposit looks like

underground. All five zones are shown and each is represented by a different

colour.

INFERRED INDICATED

RESOURCE ESTIMATION

Inferred: An ‘Inferred Mineral Resource’ is that part of a Mineral

Resource for which tonnage, grade and mineral content can

be estimated with a low level of confidence. It is inferred

from geological evidence and assumed but not verified

geological and/or grade continuity. It is based on

information gathered through appropriate techniques from

locations such as outcrops, trenches, pits, workings and drill

holes which may be limited or of uncertain quality and

reliability.

Indicated: An ‘Indicated Mineral Resource’ is that part of a Mineral

Resource for which tonnage, densities, shape, physical

characteristics, grade and mineral content can be estimated

with a reasonable level of confidence. It is based on

exploration, sampling and testing information gathered

through appropriate techniques from locations such as

outcrops, trenches, pits, workings and drill holes. The locations

are too widely or inappropriately spaced to confirm

geological and/or grade continuity but are spaced closely

enough for continuity to be assumed.

*Source: JORC

INCREASING LEVEL OF GEOLOGICAL CONFIDENCE

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The Australian Joint Ore Reserves Committee (JORC) Code provides a mandatory

system for the classification of minerals exploration results, mineral resources and ore

reserves in public reports according to the levels of confidence in geological

knowledge and technical and economic considerations.

Present JORC-compliant resource estimate for Gergarub:

Total: 17.45 million tonnes Zinc

Average grade: 8.6 % Zinc

Cut-off grade: 4 % Zinc

Future potential exists to further extend this resource to:

Total: 18 -22 million tonnes Zinc

Average grade: 8.5 % Zn and 2.3 % Lead

This will be sufficient to produce 1.29 million tonnes of ore per annum, for at least

15 years.

ORE GRADING

Average grade: On a global scale, Zinc ores typically contains

5% – 15% Zn on average.

Cut- off grade: Refers to the level of mineral in an ore where it is no longer economically

feasible to mine it.

Figure 8: A 3D representation of the Gergarub deposit

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Mining Concentrating Refining

2.4 MINING AND PROCESSING

At the Gergarub deposit, zinc mineralised ore will be mined and processed to

concentrates. All possible processing options are being evaluated to maximise the

beneficiation and local value addition. Concentrates will potentially be transported

to the nearby refinery, Namzinc, to be refined (Figure 9).

Currently, Skorpion has a refinery that treats only zinc oxides. A refinery conversion

project has been initiated that will enable Skorpion Zinc to treat sulfide concentrates

and dispose of the tailings in a responsible manner.

Mining method

As feasibility studies are still underway, it has not yet been determined whether

underground or conventional open pit mining or a combination will be

implemented.

Should underground mining be opted for a combination of mining methods are

required due to the depth and complex geometry of the orebodies. Stepped bord

and pillar mining (Figure 10) and cut-and-fill stoping are both viable options. The text

box below describes these mining methods in greater detail.

If open pit mining is implemented the depth of the pit is estimated to reach 450m.

Trucks and loaders will be used within the pit to mine the ore and it will then be

hauled to the concentrator.

Figure 9: Typical process of mining and processing zinc ore

GERGARUB MINE SKORPION REFINERY

or WORLD MARKET

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Mining methods

Stepped bord and pillar

is a variant of the room and pillar method where mined material is

extracted across a horizontal plane, creating bords (alleys) and

pillars. The pillars are larger in size than the bord (see Figure 10). The

bords are extracted underground leaving the pillars to carry the

weight. When the bord resources have been exhausted the pillars

are then mined causing the roof to strategically collapse.

Cut and fill stoping

is a method used in steeply dipping or irregular ore zones. The ore is

mined in horizontal or slightly inclined slices, and then filled with

waste rock, sand or tailings.

Concentrator

To concentrate the ore it is first crushed. The purpose of this is to separate the

minerals that contain the valuable zinc from the host rock that is non-valuable. Final

consensus concerning the crushing circuit to be applied has not been reached yet;

two circuits are currently being considered:

A 3 stage crushing and a single stage ball milling circuit; or a

Primary crusher plus a combination of a semi-autogenous grinding (SAG) and

a ball mill.

Trade off studies will be undertaken considering the advantages and disadvantages

of both options. Environmental impacts will also be considered.

Both processes incorporate crushing, milling and size classification circuits. Once the

product is sufficiently milled, process water is added forming slurry which is

Figure 10: Bord and Pillar Mining Method

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Table 1: Concentrator utility consumption

transferred to a set of cyclones by a slurry pump. The cyclone overflow is fed to

flotation cells.

The next process is flotation. Air and reagents are added to the slurry, forming froth.

The ore attaches itself to the bubbles, floats upward and overflows into launders. In

this way, the ore is removed via the froth and separated from the slurry. Lead ore is

removed via an initial flotation stage and followed by the removal of zinc ore in a

subsequent flotation stage. The material that does not float is referred to as the

tailings.

Following flotation, the separated ore is dewatered by using thickeners, flocculants

and filters to separate solids and water. The filtered concentrate is then ready to be

transported to the refinery.

A summary of the abovementioned process is illustrated in Figure 11 below.

The estimated consumption per utility used in the concentration process is described

below in Table 1.

UTILITY ESTIMATED TOTAL CONSUMPTION

Raw water 0.75 m3/ton fed to the grinding mill

Electricity 22.8 kWh/ton_ore

Instrument air 500 Nm3/h

Plant air <660 Nm3/h

Figure 11: Typical Concentration Process

Inputs:

Host rock

Crushing Grinding Flotation

Inputs:

Air and reagents

Outputs:

Lead ore; Zinc ore; tailings

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Concentrator outputs

The main outputs from the concentrator will be:

Zinc concentrate – approximately 150,000 tonnes per annum dry concentrate

Lead concentrate – approximately 30,000 tonnes per annum

Tailings – approximately 750,000 tonnes per annum tailings (to be disposed of

at the planned new tailings storage facility at the mine)

2.5 INFRASTRUCTURE REQUIREMENTS

The impacts of all infrastructure to be developed within the ESIA study area (Figure 4)

is considered in this ESIA. This includes the relevant proposed power and water

supply lines.

2.5.1 Power Supply

Nampower has been approached regarding power supply to Gergarub. It has

been decided that:

The existing Obib Transmission Station should be used.

In addition, new 66 kV lines from Obib to a new site location and distribution

station should be constructed.

The total distance of the new lines are approximately 9 km. From the new distribution

station the 11 kV reticulation is fed.

The current Rosh Pinah township supply point must be upgraded to 10 MVA in order

to accommodate for the increase in power demand due to the increase in housing

requirements with the development. The existing reticulation line must be extended

and minisubs installed to supply the new houses.

Energy consumption will increase by ±300 MWh/day and the monthly Maximum

Demand (MD) could increase up to 20MW. The proposed power line route is shown

in Figure 12.

2.5.2 Water Supply

At present the town of Rosh Pinah, Skorpion Zinc Mine as well as Namzinc Refinery is

supplied with water from the Orange River by NamWater. Table 2 below shows the

current collective water usage.

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Table 2: Current total water supply and usage

CURRENT WATER SUPPLY AND USAGE

Current water supply 14 Mℓ of water per day

Current water usage 8.5 Mℓ of water per day

Total spare capacity 5.5 Mℓ of water per day

Skorpion Zinc is planning future developments that will increase their water usage.

This will in turn increase the total water consumption as indicated in Table 3.

Table 3: Future total water supply and usage

FUTURE WATER SUPPLY AND USAGE

Future water supply 14 Mℓ of water per day

Future water usage 11.5 Mℓ of water per day

Total spare capacity 3.5 Mℓ of water per day

Gergarub Mine and concentrator will tentatively require 4 Mℓ of water per day,

necessitating an increase in pumping and filtration capacity.

New water supply infrastructure would be required for:

The new housing units in Rosh Pinah;

The extension of the existing water line to the new supply points for Gergarub.

The planned water line extension and infrastructure layout is shown below

(Figure 12).

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Figure 12: Proposed Gergarub infrastructure and processing plant

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2.5.3 Housing and Employment

It is estimated that 450 employment opportunities will be created at the new mine. It

has not yet been determined what the ratio of local to foreign employees will be but

it can be assumed that most of the workforce will be from Namibia.

Accommodation for the additional workforce will be provided in Rosh Pinah.

A study is currently underway to determine housing and accompanying

infrastructure options that will be feasible. The ongoing feasibility study will

determine how many housing units will be required. The ESIA includes consideration

of the impacts related to housing and employment, for example potential increased

influx of employment seekers and increased pressure on services.

2.5.4 National Road

The location of the zinc deposit, if mined, necessitates the re-alignment of the C13

national road. The most likely route is shown in Figure 12. Other options as well as

variations of the current one will be considered.

2.5.5 Tailings Storage Facility

In order to adequately deal with discarded process residue, the development of a

tailings storage facility (TSF) is proposed in close vicinity to the envisaged mine.

A viable location for the concentrator TSF at Gergarub was determined by

identifying and assessing three possible locations (Figure 13).

Figure 13: Map showing the three investigated locations for the TSF in relation to other landmarks.

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Table 4: Major advantages and disadvantages of Site 3

Site selection criteria described in SANS 0286:1998 (Code of Practice for Mine

Residue) were used to determine which site would be suitable for the construction of

the facility.

The criteria included considerations for:

1. Economics;

2. Environmental Impact;

3. Hazard and Risk;

4. Resource Utilisation; and

5. Technical Viability.

A ranking methodology was followed where the sites were each qualitatively

evaluated with respect to the criteria above and then scored accordingly.

It was determined that Site 3 is the preferred location as it had the highest overall

score and outscored the other 2 sites in environmental as well as engineering and

economic risk considerations. Site 1 in particular will pose a high risk should the

structure fail as it is located immediately adjacent to the mining and plant complex.

Table 4 summarises the major advantages and disadvantages associated with the

preferred location, Site 3.

MAJOR ADVANTAGES MAJOR DISADVANTAGES

Located downwind from the main road: low

dust and noise impact

Lower visual impact on road users than

other sites

Low social and environmental impact

should TSF fail

Minimal interference with surface

infrastructure

No mining under facility

Most favourable site layout

High biodiversity impact

Possible impact on downstream groundwater

users

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TSF Design Measures

Designs for Site 3 will be commissioned shortly. TSF’s are usually designed taking into

account:

1. The storage volume requirement

2. Physical and chemical characteristics of the residue

3. Transport and deposition methods

4. Containment method

5. Potential pollution content and release mechanisms

6. Location of the environmental receptors

7. Understanding of the pathway between pollution sources and receptors

Both surface and underground tailings storage scenarios are currently being

considered. The preferred option depends on the finalisation of the mining and

extraction processes. If stored on surface, a footprint area measuring 90 ha is

required for a total storage height measuring 30-35 m.

Risks associated with visual impact, wind direction (i.e. dust and habitat destruction)

and tailings dam break can be largely avoided by underground placement. Design

measures that can provide mitigation of associated risks arising from surface

placement include the following:

Dust suppression techniques. Mannheimer and Irish (2012) determined that a

unique habitat downwind of the TSF (succulent shrub plain, Figure 14 and

Figure 17) would likely deteriorate as a result of the deposition of wind-blown

fine material if not addressed.

Capping and lining systems. If capping and lining do not adequately address

the risks, residue “fixing” by cementation is an alternative.

Slurry transfer and deposition methods are to be determined by considering

wind strength and direction, water availability and visual impact of the

residue transport method.

Appropriate design techniques are required for the volume and

concentration of potential pollutants and mechanisms that may cause and

aid pollution mobility.

Aesthetic design so as to maximise the TSF’s rehabilitation potential. Also

blend TSF with surrounding landscapes by considering various architectural

designs (shapes).

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Figure 14: Gergarub infrastructure, processing plant, life zones, archaeological sites and prevailing wind direction.

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TAILINGS SURFACE STORAGE INFRASTRUCTURE REQUIREMENTS

Roads for access to the TSF

Power supply to pump water to the plant

A booster pump station to transport residue from the plant to the TSF

Waste rock (possibly for impoundment purposes)

Tailings storage facility

Pollution control dam, paddocks and evaporation dam

Return and delivery pipelines/conveyors

Storm-water control measures

Seepage control measures

Underdrainage

A TSF water balance to minimise the loss of water (mainly due to evaporationn

and seepage)

2.5.6 Proposed site layout: underground vs. open-pit scenarios

The proposed site layout for open pit and underground mining scenarios are

indicated in Figure 12. These layouts are indicative, since the various facilities for

both scenarios are still being investigated and locations have not yet been fixed.

For the open pit scenario, the processing plant site (which includes the

concentrator) and mining office sites still need to be identified. A combination of

mining scenarios may be opted for, i.e. underground and open pit, in which case

the site layout will be affected accordingly.

2.5.7 Mine infrastructure requirements at Gergarub

The following facilities are needed:

A trackless mobile equipment and machinery workshop, parking and tyre bay

A main surface workshop

General engineering workshop facilities

Offices on surface for the administration of the mining operations

Additional housing: to be built in Rosh Pinah

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2.5.8 Processing and concentrator infrastructure requirements at Gergarub

The infrastructure and bulk services needed at the concentrator are as follows:

Operational offices, change rooms and ablution facilities

Concentrator stores and workshop

A new sewage plant closer to the Gergarub development, with the sewage

purification system for the operating phase based on a staff complement of

400 persons in the production area over a 24 hour period

Communications

o Existing communications infrastructure is already 7 years old and

operating at maximum capacity

o Existing data link to be upgraded.

2.5.9 Waste Rock

A possibility exists for waste rock to be used as part of the TSF’s containment but is

dependent on the mechanical properties of the tailings. Waste rock might also be

used during backfilling but is dependent on which mining method is used. The

quantity and relative impact of sourcing waste rock forms part of design

optimisation at this stage.

2.5.10 Logistics

Skorpion Mining Company has commissioned a logistics study for the project. The

study will consider:

1. inbound logistics, i.e. transport of supplies “from the supplier to the mine”;

2. outbound logistics i.e. transport of the products of Gergarub

mine/concentrator “from the mine to the customer”. The concentrate to be

produced at Gergarub Mine is:

2.1 Zinc: 150,000 tonnes of Zinc Concentrate per annum, which must be

transported either:

From Gergarub Mine to Skorpion Zinc (Trucks, conveyors,

pumps etc.)

or

From Gergarub Mine to port of Lüderitz (Truck, rail or

combination)

or

From Gergarub Mine to port of Walvisbay if Lüderitz cannot be

used.

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2.2 Lead: 30,000 tonnes of Lead concentrate per annum, which must be

transported either:

From Gergarub Mine to port of Lüderitz (via truck, rail or

combination)

or

From Gergarub Mine to port of Walvisbay if Lüderitz cannot be

used.

A separate study considering transport alternatives for road, rail and port, including

all infrastructures required, must be evaluated by the feasibility team but does not

form part of an ESIA. The logistics study will include a human resource transport plan

to transfer staff from Rosh Pinah to Gergarub Mine and back.

2.5.11 Development Schedule

The Feasibility Study currently underway is scheduled for completion in the first

quarter of 2014 and the ESIA will be completed shortly thereafter so that all relevant

information can be incorporated into the study.

Once all the necessary permits are in place, construction may commence later in

2014. Following a three year ramp-up, the Gergarub Mine will reach full capacity in

2018. The total life of mine is estimated to be approximately 15 years.

The next section contains the findings of the legal review that was conducted for this

project. Environmental and social legal implications have been studied and they

are summarised in table format.

2.6 ASSUMPTIONS AND LIMITATIONS

As the project is still in the feasibility stage some information gaps exist. The following

still need to be determined during the feasibilty study:

1. Whether Gergarub will be an underground or an open pit mine;

2. The final infrastructure layout according to the preferred mining method;

3. Whether waste rock will be used as part of the TSF’s containment and/or

backfilling;

4. The preferred road re-alignment route;

5. The TSF’s deposition and storage method to be implemented;

6. Whether the TSF will be capped or lined;

7. The details of the housing scheme.

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It is important that all components of the project go forward with a solid measure of

consideration given to all possible alternatives. Economic, financial, technical,

environmental and social consideration need to be considered for all alternatives.

At this stage the siting of the TSF has been considered to this extent (see 2.5.5).

However other alternatives yet to be considered include those listed above. A full

alternatives assessment also covering these areas will therefore be included in the

ESIA document.

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3 LEGAL AND REGULATORY REQUIREMENTS

A summary of all pertinent international and national standards, guidelines, policies

and laws that are of relevance to the Gergarub Project is presented in Table 5

below. The column entitled “Application to the Gergarub Project” provide an

indication of the relevance of each legal instrument to this project. During the full

investigation phase these legal requirements will be studied in further detail.

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Table 5: Legal and Regulatory Requirements

THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

INTERNATIONAL LEGISLATION, TREATIES, STANDARDS AND GUIDELINES

INTERNATIONAL

FINANCE

CORPORATION

The International Finance Corporation (IFC)

developed Policy and Performance Standards

(PS) on Environmental and Social Sustainability.

It describes IFC’s commitment, roles and

responsibilities related to environmental and

social sustainability.

Eight PS’s were developed and are designed

to help avoid, manage and mitigate risks and

impacts and promotes doing business in a

sustainable way, including stakeholder

engagement and disclosure obligations of the

client in relation to project-level activities.

PS’s broaden the suite of studies that are now

done for ESIA’s. Appendix H contains a table

describing the gaps and linkages between IFC

PS’s and Namibian Acts and Regulations.

Skorpion Mining Company subscribes

to IFC Standards and has made these

an integral part of the TORs for this

ESIA.

These principles are being

applied to all spheres of the

ESIA and will be addressed

in the specialist studies

during the full investigation

phase.

Stakeholder Engagement is

being conducted in

accordance with IFC

Standards.

Appendix H.

EQUATOR

PRINCIPLES

The Equator Principles (10 in total) were

developed in order to ensure that the projects

that are financed by the Equator Principles

If international funding is sought from

an Equator Principles Financial

Institution, then Skorpion Mining

These principles will apply

generally to all specialist

studies and the overall ESIA

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

Financial Institutions are developed in a

manner that is socially responsible and reflect

sound environmental management practices:

Principle 1: requires a project that is

proposed for financing be

categorised according to the

magnitude of its potential impacts;

Principle 2: requires that a social and

environmental assessment be

conducted;

Principle 3: requires adherence to

applicable International Finance

Corporation (IFC) performance

standards and Environmental Health

and Safety guidelines;

Principle 4: requires the development

of an Action Plan and Environmental

Management System informed by

the assessments conducted;

Principle 5: requires public

participation and transparency;

Principle 6: requires the setting up of

a compensation mechanism where

grievances are unavoidable;

Company will have to demonstrate its

adherence to these requirements.

process.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

Principle 7: requires the independent

review of the assessments

conducted;

Principle 8: requires the borrower of

category A and B projects to commit

in writing that (among other

agreements) they will comply to all

relevant laws, both social and

environmental, laid out by the host

country;

Principle 9: requires that category A

and B projects be subject to ongoing

environmental monitoring and

reporting; and

Principle 10: requires annual public

reports regarding the

implementation of these principles.

CONVENTION

ON BIOLOGICAL

DIVERSITY RIO

DE JANEIRO

(1992)

Details the preservation of rare and endemic

species, Namibia is a signatory to this

convention. Ratified by Namibia in 1997.

Article 14 requires that EIAs are carried out for

projects that are likely to adversely affect

biological diversity, avoid or minimize such

effects, and where appropriate, allow for

Sites which are likely to affect

biological diversity to be identified

and assessed and the impacts

avoided or minimized.

The area under study is of

high biodiversity

importance and needs to

be considered in detail in

specialist studies.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

public participation.

THE

CONVENTION

ON

INTERNATIONAL

TRADE IN

ENDANGERED

SPECIES (CITES)

OF 1973

Ratified by Namibia in 1990 the CITES regulates

trade in endangered species, through listing in

appendices

Relevant appendices include 1-2

Vulnerable and threatened species

will be identified and assessed and

the impacts avoided or minimised.

Biodiversity studies

CLIMATE

CHANGE

United Nations Framework Convention on

Climate Change (UNFCCC) (1994), ratified by

Namibia in 1995

Sets an overall framework for

intergovernmental efforts to address

the challenge posed by climate

change. It recognizes that the

climate system is a shared resource

whose stability can be affected by

industrial and other emissions of

carbon dioxide and other

greenhouse gases. Under the

Consider how this project could

potentially affect and be affected by

Climate Change.

Consider management

strategies for the EMP.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

Convention, governments:

gather and share information on

greenhouse gas emissions, national

policies and best practices

launch national strategies for

addressing greenhouse gas emissions

and adapting to expected impacts,

including the provision of financial

and technological support to

developing countries cooperate in

preparing for adaptation to the

impacts of climate change.

NOISE

STANDARDS

SANS (South African National Standards)

10103:2008 Version 6 -The measurement and

rating of environmental noise with respect to

annoyance and to speech communication.

SANS 10328, Methods for environmental noise

impact assessments.

SANS 10357, the calculation of sound

propagation by the CONCAWE method.

World Bank Guidelines on Pollution Prevention

International Finance Corporation – 2007

General EHS Guidelines: Environmental Noise.

In the absence of local legislation

with respect to noise, the specialist

will use the SANS and other standards

for his assessment.

The necessary management actions

need to be included in the EMP.

Noise Impact study.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

AIR QUALITY

GUIDELINES

World Health Organisation ambient air quality

guidelines and World Bank Group EHS

Guidelines.

In the absence of Namibian

standards for air quality, the WHO

and EHS guidelines will be used by

the specialist.

The necessary management actions

need to be included in the EMP.

Air Quality study.

WATER QUALITY

GUIDELINES

The South African Department of Water Affairs

uses a Draft set of water quality standards for

effluent to be discharged or disposed of in

areas with potential for drinking water source

contamination; international rivers and dams

and in water management and other areas.

These are used as their standard under the

Water Resources Management Act. South

Africa is the only African country with an official

set of water quality guidelines for discharges

from land-based sources.

The World Health Organisation (WHO)

Guidelines for drinking water are the

international reference point for standard

setting and drinking-water safety.

A set of water quality objectives need

to be compiled for this project which

would best protect the receiving

environment.

In the absence of Namibian

Regulations, the South African

standards and WHO guidelines need

to be implemented.

The necessary management actions

need to be included in the EMP.

Hydrogeology study.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

NAMIBIAN NATIONAL LEGISLATION

NAMIBIAN

CONSTITUTION

General human rights (Articles 5-25) – e.g.

eliminates discrimination of any kind, and the

principles that underpin them (Article 95)

Article 95(l) of the Constitution of the Republic

of Namibia:

“maintenance of ecosystems,

essential ecological processes and

biological diversity of Namibia and

utilization of living natural resources

on a sustainable basis for the benefit

of all Namibians, both present and

future”.

Ensure these principles are enshrined

in the Processes of this ESIA and its

documentation.

These provisions and

principles apply to the ESIA

process as a whole as well

as to the specialist studies

GENERAL

ENVIRONMENTA

L AND SOCIAL

PROTECTION

AND SOCIAL

AND

ENVIRONMENTA

L ASSESSMENT

Environmental Management Act (EMA) 7 of

2007:

Requires that projects with significant

environmental impact are subject to

an environmental assessment

process (Section 27).

Requires for adequate public

participation during the

Conduct public participation as part

of the ESIA process as described in

the act and regulations.

Conduct an ESIA which covers all the

components of the project which are

listed in Schedule 5 of the EMA (2007)

and the Regulations (2012)., as well as

the under Section 50 of the Minerals

The Public Consultation and

Disclosure (Section 5)

The principles and relevant

provisions from the EMA

and its regulations apply to

the ESIA process as a

whole.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

AND

MANAGEMENT

SYSTEMS

environmental assessment process

for interested and affected parties to

voice their opinions about a project

(Section 2(b-c)).

According to Section 5(4) a person

may not discard waste as defined in

Section 5(1)(b) in any way other than

at a disposal site declared by the

Minister of Environment and Tourism

or in a manner prescribed by the

Minister.

EMA Regulations GN 28-30 (GG 4878) (February

2012):

Listed activities requiring an

Environmental Clearance Certificate

(GN No 29):

o The construction of facilities for

waste sites, treatment of waste

and disposal of waste (2.1);

o The import, processing, use and

recycling, temporary storage,

transit or export of waste (2.3);

o The construction of facilities for

(Prospecting and Mining) Act no 33 of

1992.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

any process or activities which

requires a licence, right or other

form of authorisation, and the

renewal of a licence, right or

other form of authorisation, in

terms of the Minerals (Prospecting

and Mining Act), 1992 (3.1);

o Construction of dams, reservoirs,

levees and weirs (8.5);

o Construction of industrial and

domestic wastewater treatment

plants and related pipeline

systems (8.6);

o Any process or activity which

requires a permit, licence or other

form of authorisation, or the

modification of or changes to

existing facilities for any process

or activity which requires an

amendment of an existing

permit, licence or authorisation or

which requires a new permit,

licence or authorisation in terms

of a law governing the

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

generation or release of

emissions, pollution, effluent or

waste (9.2); and

o Construction of oil, water, gas

and petrochemical and other

bulk supply pipelines (10.1(a)).

Public consultation process (GN No

30 s21)

Requirements for what should be

included in an ESIA report (GN No 30

s15))

Minerals (Prospecting and Mining) Act No 33 of

1992

Section 50(i) requires “an

environmental impact assessment

indicating the extent of any pollution

of the environment before any

prospecting operations or mining

operations are being carried out and

an estimate of any pollution, if any,

likely to be caused by such

prospecting operations or mining

operations”. Even though this refers

to the mining activities of the

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

operation, “accessory works” are

mentioned under the definitions of

the Act, and may be interpreted as

the processing activities of the

operation, even though not explicitly

required as such in the act.

WASTE

MANAGEMENT

LEGISLATION

Hazardous Substances Ordinance 14 of 1974:

Control of substances which may

cause injury or ill-health or death of

human beings because of their toxic,

corrosive, irritant, strongly sensitizing

or flammable nature.

Pollution Control and Waste Management Bill:

Aims to prevent and regulate the

discharge of pollutants to air, water,

land, and will regulate noise, dust

and odour pollution. Further aims are

to establish a system of waste

planning and management, and to

enable Namibia to comply with its

obligations under international law.

Consider waste management options

for the Gergarub Project.

Identify hazardous substances

disposed of during construction and

operation and identify practical

handling and disposal options.

Waste management options are to

be considered and included in the

EMP.

Hydrogeology study; and

EMP.

BIODIVERSITY Article 95 of the Constitution of the Republic of Identify the existence of any Terrestrial Biodiversity study

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

INSTRUMENTS Namibia:

“maintenance of ecosystems,

essential ecological processes and

biological diversity of Namibia and

utilization of living natural resources

on a sustainable basis for the benefit

of all Namibians, both present and

future”.

Forest Act 27 of 2004:

Provision for the protection of various

plant species.

Section 22(1): It is unlawful for any

person to “cut, destroy or remove

any living tree, bush or shrub growing

within 100 metres from a river, stream

or watercourse on land that is not

part of a surveyed erf or a local

authority area without a licence.

Nature Conservation Ordinance 4 of 1975:

Protects inter alia nature reserves,

conservancies, the hunting and

protection of wild animals, and the

protection of indigenous plants.

protected plants and habitats of

conservation concern to be

addressed in the ESIA.

List applicable biodiversity

compliance issues in the EMP.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

Prohibits disturbance or destruction of

the eggs of huntable game birds or

protected birds without a permit.

Requires a permit for picking (the

definition of “picking” includes

damage or destroy) protected plants

without a permit.

Preservation of Trees and Forests

Ordinance:

Protection to tree species.

HERITAGE National Heritage Act (2004):

All heritage resources to be identified

and either protected or

removed/mitigated with a permit

from the National Monuments

Council, before any development

may take place. Heritage

assessments undertaken as part of

the environmental assessment

process. Even though this is the key

instrument protecting heritage, the

Nature Conservation Ordinance

(1975) also affords protection to

Identify areas with archaeological

potential. Conduct further

archaeological assessment if

required.

Archaeology study.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

archaeological material in National

Parks.

LABOUR,

WORKING

CONDITIONS

AND

EMPLOYMENT

Labour Act (1992):

Health and Safety Regulations (none

in force yet) (s135).

Minimum wages and working

conditions including health and

safety measures (s39-47).

Affirmative Action (Employment) Act 29 of

1998.

Article 9 of the Namibian Constitution.

Include a requirement in the EMP that

these regulations are to be adhered

to.

Ensure that minimum wage and

working conditions are stipulated in

the contract.

EMP

PUBLIC HEALTH Public Health Act 36 of 1919:

Provides for the prevention of

pollution of public water supplies.

Identify sites where potential pollution

may occur, introduce mitigation

measures where needed.

The necessary compliance measures

are to be included in the EMP.

Hydrogeology study; EMP

CIVIL AVIATION Annex 14 to the Convention on International

Civil Aviation (Namibia is a signatory):

Chapter 4: Obstacle restrictions and

removal

Chapter 6: Visual aids and

The Civil Aviation Authority of

Namibia needs to be consulted to

establish the need for further civil

aviation assessment.

EMP

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

identification of obstacles.

WATER

RESOURCE

MANAGEMENT

The Water Resources Management Act (2004)

is presently without regulations; therefore the

Water Act No 54 of 1956 is still in force.

A permit application in terms of

Sections 21(1) and 21(2) of the Water

Act is required for the disposal of

industrial or domestic waste water

and effluent.

Section 23 (1): Prohibits the pollution

of underground and surface water

bodies.

Section 23 (2): Liability of clean up

costs after closure/ abandonment of

an activity.

Protection from surface and

underground water pollution.

Obligation not to pollute surface

water bodies.

The following permits are required in

terms of the Water Act:

water abstraction permits;

domestic effluent discharge

permits (site offices, construction

camp); industrial effluent discharge

permits;

water use for dust suppression; and

water reticulation permits

(pipelines).

Hydrogeology study

SOIL Soil Conservation Act 76 of 1969:

Consolidates and amends laws relating to the

combating and prevention of soil erosion, the

conservation, improvement and manner of use

of the soil and vegetation and the protection

Soil and water resources need to be

protected in accordance with this act.

Hydrogeology study

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

of the water sources of Namibia.

TRADITIONAL

AUTHORITIES

Traditional Authorities Act, 25 of 2000

Provides for the establishment of

traditional authorities and defines

their powers, duties and obligations.

The role and powers of the traditional

authorities in the decision-making

process of this project needs to be

considered.

Socio-economic study

NATIONAL, REGIONAL AND LOCAL PLANNING FRAMEWORK

NATIONAL

PLANNING

Vision 2030

To be a prosperous industrialised

country by 2030, developed by our

people, and enjoying peace,

harmony and political stability.

National Development Plan 3 (NDP3)

2007/2008 – 2011/2012

Based on the Vision 2030, and

provides the long term development

framework for the country to achieve

it. The main vehicle to translate the

Vision 2030 into action. Includes

policy directions and is based on

Ensure that the project outcome

supports these objectives and that

any negative influences on it are

addressed in the ESIA.

Socio-economic study.

Generally applicable to the

whole ESIA process.

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THEME INSTRUMENT AND CONTENTS APPLICATION TO THE GERGARUB PROJECT ADDRESSED IN

eight key result areas, each

corresponding to the main eight

objectives of Vision 2030, under the

themes Competitive economy,

Infrastructure, Productive utilisation of

natural resources and environmental

sustainability, productive and

competitive human resources and

institutions, knowledge based

economy and technology, quality of

life, equality and social welfare,

peace, security and political stability

and regional and international

stability and integration.

CORPORATE ENVIRONMENTAL AND SOCIAL POLICIES

VEDANTA AND

SKORPION ZINC

Believe in sustainable development and are

committed to effective management of

health, safety, environment and community

development as an integral part of their

business.

Ensure that the project outcome

supports these objectives.

Generally applicable to the

whole ESIA process.

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It is clear from the legal instruments listed that the protection of the Rosh Pinah and

immediate environment of the Gergarub Project is comprehensively provided for.

Some of these instruments are however not well enforced, are unregulated, or there

is a lack up-to-date standards to account for the most recent developments. Where

national laws lack regulation and standards, they have been augmented with

relevant international ones. Article 144 of the Constitution makes provision for the

incorporation of international law, of which Namibia is a signatory, into national

legislation. The main message derived from this legal review is that the spirit of these

laws is to provide for a more sustainable form of development for Namibia in general

and, more specifically, the Rosh Pinah area. This does not guarantee development

that will be free from any environmental impacts, but rather the reasonable co-

existence of various national goals to ensure socio-economic progress supported by

sustainable resource use.

It is important that the provisions listed here be made part of not only the ESIA

process, but beyond during implementation so that the Rosh Pinah community may

be the proud receptors of this mine.

Section 4 to follow provides an overview of the public consultation process and its

outcome so far, which is being undertaken for this ESIA.

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4 THE RECEIVING ENVIRONMENT

It is necessary to describe the environment of the project in its current status so that

sensitivities may be identified. It has been done here at a scoping level, to the

degree necessary to identify vulnerable characteristics and potential impacts.

It is important to note that the term environmental contains all the natural as well as

all human elements. In this section we have divided the description into biophysical

and socio-economic elements although the interrelatedness between them should

be stressed.

Each environmental characteristic contains an indication of its vulnerability or of

those elements within the system that are particularly vulnerable.

Vulnerability refers to the degree to which an environmental feature can be

maintained amidst external pressures. This vulnerability is described in this section

according to the ratings described below (Table 6).

Table 6: Vulnerability ratings

VULNERABILITY RATING CRITERIA

LOW The environmental feature is robust and has good ability to

withstand negative effects without being adversely affected.

MEDIUM The environmental feature can withstand negative effects without

being adversely affected in a moderate way.

HIGH The environmental feature is highly susceptible to suffer harm and

lacks the ability to withstand negative effects.

4.1 OVERVIEW

The Gergarub deposit lies in the Karas Region which border the Atlantic Ocean to

the west and the Northern Cape Province of South Africa to the south. The Orange

River is the main water source of the area and forms the border here between

Namibian and South Africa.

The region is predominantly a small stock farming area. Irrigation farming along the

Orange River has increased significantly in the last two decades. The region also

hosts the Lüderitz harbour, an important port for the export of refined and unrefined

minerals.

The region is hyper arid with low average rainfall and high temperate (Figure 15). It

receives the majority of its moist from the coast in the form of fog originating across

the Benguela Current. The Succulent Karoo Biome ecosystem is maintained by this

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air movement from the coast and is a biodiversity hotspot. The area is near the

Sperrgebiet, and the Richtersveld Transfrontier National Park. It is also located along

the tourist route to these parks.

The closest town to the deposit is Rosh Pinah, an unproclaimed mining town whose

economy mainly revolves around the two nearby existing mines, Skorpion Zinc and

Rosh Pinah Zinc.

Figure 15: Eastern part of the ESIA study area

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4.2 THE BIOPHYSICAL ENVIRONMENT

4.2.1 Climate and Air Quality

The climate is extremely arid and the ecosystem is driven by air movement. Most of

the air movement in the area is dominated by southerly winds, which reach average

speeds of approximately 20 km/h. The area receives less than 100mm annual rainfall

occurring mainly during the summer (October to February).

Due to the close proximity of the Atlantic Ocean and its cold Benguela current, fog

is recorded between 50 to 75 days per year. The average maximum temperature

ranges between 28 ˚C and 30 ˚C, with an average minimum temperature of 6 ˚C to

8 ˚C. The combination of climatic conditions creates an ecology which is generally

very sensitive and susceptible to change.

The current state of air quality near the proposed mine site is very good. There are

no sources of air pollution other than windblown dust and emissions for vehicles

passing on the C13, and both are negligible.

The closest sources of air pollution are those from mining and processing at Skorpion

Zinc, approximately 9 km north-northwest of the Gergarub Mine site. With the

prevailing southerly wind it is unlikely that these emissions will affect air quality at

Gergarub.

Rosh Pinah is located approximately 10 km south of the proposed Gergarub Mine.

The main sources of emissions at Rosh Pinah result from the Rosh Pinah Zinc Mine and

the windblown dust from the tailings dam south of the town. Emission from mining

and the tailings dam contribute to particulate concentrations but the contribution

from vehicles will be negligibly small. The relative distance of Gergarub from Rosh

Pinah and its protected location from the southerly wind behind topographical

features will ensure that the mine site is not affected by the sources at Rosh Pinah.

Table 7: Climate Related Sensitivities

SENSITIVITY VULNERABILITY POTENTIAL IMPACT

Aridity High - water sources are of high

value for human consumption

and the ecology. Recovery

potential of the entire ecosystem

is generally low.

Water consumption,

footprint, impact on

livelihoods, water pollution.

Predominant southwesterly

wind (areas downwind of

it)

High – because of arid

conditions, low recovery

potential, paucity of water

resources.

Dust and noise impact on

downwind receptors.

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4.2.2 Surface water

The prominant natural surface water in the area is the Orange River located

approximately 40km south-east of the study area. The Orange River forms the

border between Namibia and South Africa and drains into the Atlantic Ocean at

Alexander Bay. Any surface water impacts on the Orange River would have

potential international implications. The drainage channel/basin dominating the

study area drains southwards to the Orange River, but relatively permeable surface

soils will negate most surface water reaching the Orange River. Potential

contaminants within surface water (and emanating from the mine) are therefore

likely to pose a greater risk to groundwater than to the Orange River.

In the localized area of the proposed Gergarub Mine development, surface water

channels consist of a myriad of small non-perrenial drainage paths randomly

draining over the site and converge only where man made culverts are constructed

under existing roads.

The water supplied to Rosh Pinah Zinc Corporation, Skorpion Zinc and Rosh Pinah

Town is abstracted with pump sets in a vertical water tower and pumped to a water

treatment plant for purification before it is distributed for domestic use to Rosh Pinah

residents. There is also a raw water pipeline from the abstraction tower to the

Skorpion Mine.

Existing surface water drainage channels within the study terrain is shown on the

map (Figure 16). Surface run-off speed and volume is often greatly enhanced

during the sparse rainfall events.

Figure 16: Major surface drainage patterns within the ESIA study area.

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Table 8 highlights the sensitivities that can be expected relating to surface water.

Table 8: Surface water related sensitivities

SENSITIVITY VULNERABILITY POTENTIAL IMPACT

Water resource The Orange River is the only

surface water resource,

which is already under

pressure. Moderate.

Reduced water available to

the environment or to other

receptors.

On-site drainage High vulnerability – stream

diversion can cause severe

erosion.

Erosion and loss of topsoil or

flooding of infrastructure or

loss of contributions to the

Orange River as a result of

damming of tributaries.

4.2.3 Groundwater

The study area is situated in a valley fault zone, the Zebrafontein Fault, within the

Gariep Orogenic Belt. Groundwater here can be found in two types of aquifers or

groundwater reservoirs, namely:

a primary aquifer in which groundwater flows in openings and void space

between grains and weathered rocks. This aquifer is expected to be of limited

extent and is only formed in the deeper parts of the loose rock debris filled

valley where the debris obtained thicknesses in excess of ~80 m below ground

level (mbgl). It is unconfined, meaning that water seeps directly into this

aquifer from the ground surface above it.

a fractured-rock aquifer (also known as a secondary aquifer) formed by

openings in the otherwise solid bedrock. These openings have been formed

by the structural deformation of the rocks by e.g. faults and folds. This aquifer

is semi-confined which means water can seep into this aquifer from directly

above or from farther away due to an impermeable layer obstructing

seepage from above.

The depth to groundwater in the mining area ranges from ~80 to ~85 mbgl.

Groundwater flow is generally down the valley in a southerly direction. The faults

occurring in the study area, e.g. the Zebrafontein Fault, are likely to form preferential

flow paths for groundwater movement.

The groundwater exploitation potential of the study area is expected to be very low

due to an extremely low rainfall and recharge potential.

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Groundwater is the sole source of water supply to the farms in the study area where

small volumes (estimated at <10 m3/day/borehole) are abstracted from seven

boreholes for stock watering and household use.

Table 9 highlights the sensitivities that can be expected relating to groundwater.

Table 9: Groundwater related sensitivities

SENSITIVITY VULNERABILITY POTENTIAL IMPACT

Groundwater supply High Depletion of groundwater

resource by mine

dewatering. Groundwater is

the sole source of water

supply to the neighbouring

farmers

Groundwater quality High Deterioration of

groundwater quality by

pollution from the mining

activities.

4.2.4 Biodiversity

The Gergarub study area lies within a very sensitive ecological area next to the

Sperrgebiet and close to the Richtersveld Transfrontier National Park in remote

southern Namibia. It is also located along the tourist route to these parks.

The landscape surrounding the deposit is part of the northern section of the

Succulent Karoo biome which is regarded as a global biodiversity hotspot (Myers, et

al, 2000), and is thus important in global as well as regional and national terms. This

makes only absolutely unavoidable damage acceptable. It is extremely sensitive in

terms of near-endemic, endemic and protected plant and animal species and

widely recognised as an important area of both diversity and endemism (Van Wyk &

Smith 2001, Barnard 1998, Hilliard 1994).

Four major life zones have been identified in the study area (indicated in Figure 17).

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These life zones have been assessed for overall ecological sensitivity based on

expected diversity, occurrence of species of conservation concern, extent of

habitat and recovery potential (Table 10).

Sensitivity of the various habitats was scored using ratings of 1 to 4 for the following

aspects:

1. Species diversity: (1 = low, 4 = high)

2. Occurrence of species of conservation concern: (1 = low, 4 = high)

3. Extent of habitat: (4 = less, 1 = more)

4. Recovery potential: (4 = low, 1 = high)

The higher the total score is for each life zone, the more sensitive it is (Table 10).

Figure 17: Life zones identified in the study area

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Mountains and hills were rated with the highest sensitivity. Such elevated areas are

known to harbour many plant species of conservation concern, making them

sensitive to environmental disturbance. Many of the plant species tend to

congregate in small patches of suitable habitat, such as on moisture-gathering

south-west-facing slopes that are in shade for part of the day or on quartz outcrops.

The mountain habitat has an equally diverse, endemic and range-restricted fauna

highlighting the need to maintain the integrity of this life zone.

Succulent plains were rated with high sensitivity, primarily on the basis of plant

diversity, although parallel faunal diversity is expected. The succulents are found

primarily on the south western slopes where fog gathers during part of the day. It is

only in these situations that the unique succulent plains occur in Namibia. This makes

them a highly restricted habitat (Table 11).

Consolidated stony-gravelly plains were rated with medium sensitivity. Although an

unusually dense concentration of Hoodia gordonii is present within this life zone to

the west of the current drill camp, the faunal component is composed of relatively

generalist taxa.

Pure sandy-gravelly plains were given the lowest sensitivity which can be ascribed to

their highest restoration potential. These plains are known to harbour relatively high

plant diversity and the faunal component is on par with that of the stony-gravelly

plains.

LIFE ZONE DIVERSITY PRESENCE

OF SPECIES

OF

CONCERN

EXTENT OF

LIFE ZONE

RECOVERY

POTENTIAL

TOTAL

SANDY-GRAVELLY

PLAINS 2 3 1 1 7

STONY-GRAVELLY

PLAINS 3 2 2 1 8

SUCCULENT PLAINS 1 1 4 3 9

MOUNTAINS,KOPPIES,

ROCKY OUTCROPS

AND FOOTSLOPES

4 4 3 4 15

Table 10: Life zone sensitivity scoring

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Table 11: Biodiversity Related Sensitivities

SENSITIVITY VULNERABILITY POTENTIAL IMPACT

Sandy gravelly plains Low – generalist taxa, high

recovery potential

Loss of habitat due to

landtake

Plant destruction due to

dust deposition

Stony gravelly plains Medium – high recovery

potential but relatively

diverse taxa

Loss of habitat due to

landtake

Plant destruction due to

dust deposition

Succulent plains High – diverse taxa,

restricted.

Loss of habitat due to

landtake

Plant destruction due to

dust deposition

Mountains, koppies and

footslopes

High – highly diverse and

endemic taxa, restricted

habitat

Plant destruction due to

dust deposition

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4.2.5 Noise

The following is based on personal observation by B. Williams (2013) during a site

reconnaissance trip.

The study area was surveyed and the closest sensitive human noise receptors that

were identified are the residents on the nearby farms and the residents at Rosh Pinah

town 10 km away. There are several hills or mountains between the proposed mine

and the town.

The ambient day-noise was measured at the site and varies between 37 -38 dB(A)

which is very low in relation to SANS and EHS guidelines The main road connecting

Rosh Pinah and Aus, the C13, passes through the proposed mining area. The road

noise is the largest noise contributor at present and it is envisaged that the mine

activities will have little additional impact. This will be confirmed in the detailed study

phase. The noise impact is anticipated to be low (Table 12).

Table 12: Noise related sensitivities

SENSITIVITY VULNERABILITY POTENTIAL IMPACT

Sensitive noise receptors –

Nearby farm residents

Low to medium Noise due to construction

and operation of mine and

increase in road traffic.

Rosh Pinah residents Low Noise due to an increase in

road traffic

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4.3 THE SOCIO-ECONOMIC ENVIRONMENT

4.3.1 Introduction

The mining town, Rosh Pinah, was established in 1970 and has since provided

accommodation for those employed at the Rosh Pinah Zinc Corporation and later

also the employees of the Skorpion Zinc mine.

Since it is the town closest to the proposed Gergarub Mine, this section of the report

provides a brief overview of the receiving socio-economic environment of Rosh

Pinah and nearby surrounds.

4.3.2 Regional overview

According to the 2011 Housing and Population Census, the population of the Karas

Region has grown from 29,329 people in 2001 to an estimated 77,421 people in 2011

(National Planning Commision, 2012). This reflects a growth rate of approximately

1.1 % which is lower than the national average of 1.4 %. An estimated 60 % of the

people living in Karas were born there which reflects the large number of migrants

from other areas.

Mining is a major economic activity of the Karas Region. Not only has it been key in

sustaining towns such as Oranjemund and Rosh Pinah, but remittances have been

generated and distributed to other parts of Namibia, and a significant contribution

has been made to the national economy through the payment of royalties and

taxes. Other economic activities include inputs from fishing, livestock farming,

tourism, the port of Lüderitz and services to a lesser extent (Enviro Dynamics, 2010).

4.3.3 Overview of Rosh Pinah

Population and growth

Rosh Pinah has an estimated population of 7,000 people (Saayman, 2013. Pers.

Comm.). Approximately half of this population resides in the formal township area,

whereas the other half lives in the informal settlement area known as Tutungeni.

The formal town primarily only expands as either of the two mines develop and

appoint additional employees. With the presence of the two mines, the town is

subject to an influx of job seekers. This is however seen to be minimal and is evident

in the fact that the town boundaries have not been expanded within the last

decade (Saayman, 2013. Pers. Comm.).

People often come to Rosh Pinah in search of employment opportunities, but since

there is limited employment opportunities apart from at the mines, and the natural

environment is arid and cannot sustain livelihoods, these job seekers relocate

eventually.

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The population size of Tutungeni is thus dynamic, growing and decreasing again

over time. This settlement is also regulated by RoskSkor and new residents should

apply there for land occupation and access to services. Backyard squatting in

Tutungeni is also limited.

Housing and Services

The majority of the houses in the formal town area is owned by the two mining

companies who provide housing to their employees. Different types of housing are

available to the employees and are allocated to them based on their grading at

the mine. Skorpion Zinc also has a shift workers village where some of their

employees reside. During their off-cycle, these shift workers are transported back to

their homes in places such as Keetmanshoop amongst others. Since the town has

not yet been proclaimed, a Title Deed cannot be obtained for the erven, only a

contract between the interested party and RoshSkor. Hence, few of the erven in the

town are occupied by private people who are not employed at either of the mines.

Many of the houses in Tutengeni consist of corrugated iron or small brick structures.

Approximately 75 % of the houses have electricity (Saayman, 2013. Pers. Comm.).

There are 25 communal water points and a number of communal toilets that area

cleaned daily by RoshSkor.

Roshskor is a Joint Venture between the Rosh Pinah Zinc Corporation (RPZC) and

Skorpion Zinc. This organisation is responsible for managing the town and the

provision of services. They maintain the infrastructure while providing water,

electricity, sewerage systems and waste removal services. Water, electricity, the

road infrastructure in town and especially the sewerage system has reached its full

capacity and can only sufficiently deal with the existing load (Saayman, 2013. Pers.

Comm.).

Economics and Employment

The economy of Rosh Pinah greatly revolves around the two mines. The mines are

the main employers in the town and the shops serve either its employees or meet the

needs of the mines itself. Not only do these mines stimulate the economic activities

of Rosh Pinah, but they also contribute to the economy of the country.

Since the greater majority of the formal town residents are employed at either of the

two mines, the unemployment rate is very low. This is however higher in the informal

settlement area and it is estimated that 40% of the Tutungeni residents are

unemployed (Saayman, 2013. Pers. Comm.). Those living in Tutungeni are not

directly employed at the mines, but some work as domestic workers at the houses of

those employed at the mines, or at some of the business in town. The relatives of

some of the mine workers, especially of the shift workers, often reside in this area

too. Considering the arid natural environment, the people cannot rely on natural

resources for sustaining their livelihoods.

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Surrounding land uses

A number of different land uses surrounds the proposed project area. This includes

the following:

Farming: Gergarub is located on Farm Spitzkop 111, a privately owned farm

which is neighboured by a number of commercial farms. Activities including

farming with livestock as well as game. Limited tourism, mainly hunting is also

accommodated.

Conservation and Tourism: Rosh Pinah is situated between two conservation

areas namely the Sperrgebiet National Park and the Ai-Ais/Richtersveld

Transfrontier Park. Even though Rosh Pinah is not a tourist destination itself, it is

frequented by tourists passing through en-route to another destination such

as the Fish River Canyon. The contrasting geological features of the area

provide visually stimulating scenes to passing tourists (Fish Eagle Productions,

2012).

Mining: The Skorpion Zinc mine and its associated infrastructure is located

across the road from the proposed project area. A number of drilling and

exploration activities can also be found in the area.

Road users: The C13 National Road traverses the proposed site. This road is

used by visitors, tourists and Rosh Pinah residents. The employees of Skorpion

Zinc make use of this road daily.

Health Sector

Rosh Pinah currently has one private clinic in town, a State clinic in the

neighbourhood Bethel and a Satellite State Clinic in Tutungeni. The latter mainly

acts as a distribution point for tuberculosis treatment known as DOTS. The private

clinic, Sidadi, provides both primary and occupational health are services. The

majority of the employees from the two mines make use of its services, whereas the

Tutungeni community mainly visit the State Clinic in Bethel.

In 2012, Skorpion Zinc in partnership with the Namibian Government upgraded the

facilities of the State Clinic. This clinic oversees an estimated 1,700 patients daily

resulting in pressure on available staff, services and infrastructure (Movirongo, 2011).

With regards to HIV/AIDS, Sidadi currently has on record 169 positive cases, whereas

there are currently more than 500 people on anti-retroviral treatment at the State

Clinic. The TB cases are much lower with only 3-4 positive cases at Sidadi per year

and 12 at the State Clinic. Respiratory diseases including asthma are not common.

Key Sensitivities

Based on this baseline information, the following key sensitivities that need further

investigation have been identified (Table 13).

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SENSITIVITY VULNERABILITY POTENTIAL IMPACT

High unemployment

rate. The majority of

people are dependent

on the mine. Skorpion

Zinc is reaching its end of

Life-of-Mine (LoM), which

will further add to the

unemployment in town.

High A number of people can benefit

from job creation, whether it is

new employees or re-

employment of some.

Since Rosh Pinah is an

open mining town, it is

faced with the issue of

job seekers. This is

however a dynamic

process and not the

biggest issue at this stage.

Settlement in Tutungeni is

managed by RoshSkor in

the sense that they have

to apply there for access

to services.

High The news of the development of

a new mine can contribute to an

existing trend of influx of job

seekers to Rosh Pinah. Even

though this is a dynamic process,

it might be a problem especially

during the initial implementation

period of the project. This could

lead to a new informal settlement

being established by job seekers

on state land outside the area

managed by RoshSkor.

Available services have

reached full capacity.

The state clinic and

schools have already

exceeded their capacity.

Roshkor is not in a position

to take in more

management functions

without an extension of

the staff complement.

High An influx of job seekers and

employees can add to existing

pressures on available services.

Inability of Roshkor to handle the

additional institutional

requirements.

Increased or maintained

dependency on the mining

fraternity for jobs.

The economy of the

region and town is mainly

dependent on mining

activities. It also

contributes to the

national economy.

High A new mine can contribute to

Namibian economy while

sustaining and stimulating the

economic activities of the Karas

Region and Rosh Pinah town,

especially in the event of one

mine reaching its end of life of

mine.

Table 13: Socio-economic sensitivities in the project area.

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SENSITIVITY VULNERABILITY POTENTIAL IMPACT

The town is sustained by

the surrounding mining

activities which make it

vulnerable to mine

closures. Skorpion Zinc is

reaching its end of LoM.

High The proposed project, if

implemented, will add to

sustaining the town and its

economic activities, especially

since Skorpion Zinc mine is

reaching is end of LoM.

The majority of the town’s

people are employed at

the mines who also

provides them with

housing and the basic

services.

High A new mine can contribute to

sustaining the existing

dependency syndrome as some

people might be re-employed at

this new mine, while others will be

unemployed and without housing.

The surrounding land uses

includes farming, tourism,

mining and road users.

Medium Changes to the surrounding land

uses can result in conflict.

More than 669 people

are HIV positive in Rosh

Pinah. This is almost 10 %

of the population

estimated at 7,000

people.

Medium An influx of job seekers and

employees can contribute to the

spreading of disease. This will add

to the existing pressure on health

care facilities.

Rosh Pinah struggles with

dust, especially from the

tailings dam near town.

This is thought to cause

respiratory infections or

allergies.

Medium The new project can add to the

dust experienced in town and the

consequent infections should it

not be properly managed.

4.3.4 Archaeology

Specialist studies have determined that the Gergarub deposit is located within an

area of high archaeological sensitivity. Seventeen sites have been identified within

the project area (Kinahan, 2013) as shown in Figure 14.

These sites can be divided into different types as indicated by Table 14 below.

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TYPE OF FINDING DETAIL

Rock Shelters 5 sites possibly contain stratified archaeological deposits

The high concentration of rock shelters is very significant

Various Surface Scatters Stone artefact debris; ostrich eggshell; other remains

Stone Features Includes 2 suspected grave sites

The following Archaeological sensitivities have been identified (Table 15):

SENSITIVITY VULNERABILITY POTENTIAL IMPACT

Rock shelters on the hill

north-west of the deposit

High Footprint (site layout

incorporates these

sensitivities)

Other sites Medium Footprint of activities,

ongoing operations (site

layout incorporates these

sensitivities)

4.3.5 Visual Resources

The following visual receptors were identified:

Tourist activities in the valley that is located on the farm Spitzkop.

Users of the C13, due to the fact that it has become a tourist route.

Users of the road to the Skorpion Zinc Mine.

The following visual landscapes exist in the study area:

The valley east of the C13 with the mountain range north-east to south-east of

the valley.

The valley west of the C13 with the mountain ranges west and north of the

valley.

Both visual landscapes are locally valued for above average visual quality. Both the

visual landscapes consist of distinct views that combine long flat valley sight

distances with strong contrasting mountain views. The lack of protruding vegetation

in both the valley and mountains further highlight the contrasting perception.

Project activity may be evident and begin to attract attention. Structures,

operations, and user activities should remain subordinate to the existing visual

Table 14: Types of archaeological findings

Table 15: Archaeological sensitivities in the study area

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resources. Form, line, colour, texture, scale, and composition should be compatible

to the characteristics of the existing resource.

Figure 18 provides a typical view of the landscape east of the C13 road.

There are very little contributing factors to the visual landscape focus. Little pollution

is currently evident and there are no historical landmarks in the study area. Wildlife is

not a major element but is evident in the study area.

The major industrial and human detractions to the value of the two landscapes are:

the C13 road and the road to the Skorpion mine

the various 400kv, 66 kv and 33kv transmission lines that traverse the visual

landscape to the west of the C13 road.

The presence of the farm infrastructure such as fencing and tracks are considered as

visual vernacular in this case and not detracting from the quality of the views

(Table 16).

Table 16: Visual resources and their sensitivities

SENSITIVITY VULNERABILITY POTENTIAL IMPACT

Visual landscape contrast

between the plain and the

mountains

High Any industrial or mining

activity will reduce the

quality of the visual

landscape, especially with

regards to the tailings

storage facility.

Figure 18: Typical contrasting view east of the C13

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‘Public Participation is a process in which potential

interested and affected parties (I&APs) are given an

opportunity to comment on, or raise issues relevant

to, specific matters’.

~Namibian Environmental Management Act (2007)

5 STAKEHOLDER ENGAGEMENT

5.1 INTRODUCTION

Not only is stakeholder engagement, or public consultation, a requirement of the

Namibian environmental legislation, but is deemed as a good practice principle

upheld under the Equator Principles (EP) and the International Finance Corporation’s

(IFC) Sustainability Framework.

Stakeholder engagement is characterised by dialogue and two-way

communication. It creates a platform whereby the consultant can share the project

information with the interested and affected parties (I&APs), while providing them

with a platform to convey their concerns with regards to the proposed

development. This in turn assists the consultant in defining the parameters of the

study and identifies issues that

need further investigation with

regards to both the natural and

the socio-economic environments

in which the proposed project will

be implemented.

A Stakeholder Engagement Plan

was formulated prior to the role-out

of the Environmental and Social Assessment process, indicating how the consultant set

out to ensure consultation with the I&APs that is 1) meaningful and 2) allows

reasonable access to the project information that is appropriate and technically not

too difficult. This plan can be viewed in Appendix A.

This section of the document reports on the following:

The stakeholders and the identification process;

Approach followed with regards to disseminating the information;

The meetings to date;

The feedback process;

Summary of all the issues raised to date.

Not only is this stakeholder engagement process guided by best practice principles

and international requirements, but also adheres to National legislation. The

Vedanta Technical Standards have also been taken into consideration.

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‘An interested and affected party is (a) any person,

group of persons or organization interested in or

affected by an activity; and (b) any organ of state

that may have jurisdiction over any aspect of the

activity’

~Environmental Management Regulations (2010).

5.2 POLICY AND LEGAL REQUIREMENTS

The public consultation process prescribes to certain national and international

legislation. The tables in Appendix B (Tables 1, 2 and 3) outline the legislation and

policies that guide this process.

As previously mentioned, this public consultation process is also guided by best

practice international principles, particularly the IFC Performance Standards. The

key requirements as listed by the IFC which include stakeholder identification,

community engagement and the disclosure of information are presented in the

table below.

In addition to the national and international guidelines, this consultation process also

considers the corporate policies of Vedanta to which Skorpion Zinc currently

subscribes. Key principles and objectives of these standards are summarized in the

table below.

5.3 THE STAKEHOLDERS

While considering the definition

of an I&AP, the following

approach was followed in order

to ensure all potential I&AP’s

were identified and given an

opportunity to participate in this

Environmental and Social

Assessment process:

Available baseline information on the area was studied in order to

understand the environment in which the proposed project will be

implemented.

Maps and site visits assisted with the identification of surrounding land users.

Preliminary potential impacts were identified and overlaid with the above

information. Based on this, a number of stakeholders were identified who

could potentially be affected or interested in this project.

This was further augmented by the consultant’s previous working experience

in Rosh Pinah.

The existing Enviro Dynamics database was used as a basis for the

stakeholders list and updated where necessary.

In addition, notices were placed in the press inviting people to register as

I&APs.

The details of those that registered or attended the meetings were added to

the stakeholders list.

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The stakeholders identified at national, regional and local level include

representatives from the government, business and academic environment, as well

as the public. In an attempt to ensure that women are included in this process,

existing women groups in the area were also added to the stakeholders list. A

summary of the stakeholders list is presented in Table 17. The complete stakeholders

list can be viewed in Appendix C.

It should be noted that there are no minority tribal or nomadic groups residing in the

proximity of the proposed project area as it is located on a commercial farm and

not within a communal farming area. IFC PS 8 is therefore not relevant to this project.

However, since the proposed project is located in the Karas Region and the Nama

Traditional Authority area, the latter authority has been added to the stakeholders

list in order to ensure they are informed and provided with an opportunity to

participate in the process.

Table 17: Summary of Stakeholders at National, Regional and Local Level

Level Description

National

Institutional Stakeholders

Ministry of Mines and Energy

Ministry of Environment and Tourism

Ministry of Trade and Industry

Ministry of Agriculture, Water and Forestry

Ministry of Health and Social Services

Ministry of Works and Transport

Ministry of Regional, Local Government and Housing, and Rural

Development

Regional

Institutional Stakeholders

Ministry of Environment and Tourism

Ministry of Regional, Local Government and Housing, and Rural

Development

Ministry of Works and Transport

Karas Regional Council

Local

Formal representative institutions of the Rosh Pinah communities

Constituency Councillor

Nama Traditional Leadership

RoshSkor (Town Management Company)

Potential affected parties

Surrounding Exclusive Prospecting Licence (EPLs) Owners

Farmers

Potential interested parties

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Level Description

Namibian Chamber of Commerce and Industry

Businesses and other mine in Rosh Pinah

Tourism Industry

NGOs

Specialists

General Rosh Pinah Communities, including women and residents of the

informal area known as Tutungeni

5.4 APPROACH

The consultant set out to ensure that the public consultation process conducted is

meaningful and efficient, and that the following objectives of the PCDP are met:

“To ensure that all I&APs are included in the consultation and disclosure

process and that communication channels used are efficient;

to ensure that the information disclosed about the proposed project is

appropriate and not technically too complicated;

to ensure that adequate and timely information is provided to the I&APs; and

to ensure that all I&APs are given sufficient opportunity to voice their opinions

and concerns.”

To achieve these objectives, various methods for communication and consultation

with the different stakeholder groups were employed. This included the following:

Meetings: Meetings are deemed as an effective tool for sharing the project

information, while soliciting the inputs of the attendees. They also provide an

opportunity to ask questions for clarification purposes. Two meetings were

conducted, one with the authorities and public in Rosh Pinah, and one with

the authorities based in Windhoek.

Newspaper notices: Notices were placed in three different newspapers with

a national circulation, over two consecutive weeks. It briefly explained the

project and its locality while also inviting people to register as I&APs, clearly

indicating their interest in the project (see Table 18 below). The detail of the

public meeting in Rosh Pinah was also included in this notice. These

newspaper notices are attached as Appendix D.

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DATE NATIONAL NEWSPAPER CIRCULATION

04-11-2013 Republikein Afrikaans Newspaper, National

28-10-2013

04-11-2013

The Namibian English Newspaper, National

31-10-2013 Informante English Newspaper, National, free

copies are circulated.

Intranet: Both mines circulated the newspaper notice via their intranet, which

is accessible to all their staff.

Community newsletters: The newspaper notice was also circulated

electronically via the ‘Community Notice Board’, which serves as a

community newsletter.

Posters: Posters were put up in town

and in Tutungeni providing information

on the proposed project, while inviting

the community to the public meeting

(Figure 19). Both English and Afrikaans

posters were used.

Megaphone: Representatives from

Skorpion Zinc advertised the meeting by

driving around the neighbourhoods and

announcing it over a megaphone. This

assisted the team in ensuring that the lower income level people as well as

those that are illiterate, were also informed about the meeting.

Background Information Document (BID): Two BIDs were compiled, one that

is more technical in nature that was circulated to the higher level

stakeholders, and one that is less complicated. The latter was sent to the

general community members and placed at key places in Tutungeni. This

provided the community with an opportunity to familiarise themselves with

the project information prior to the public meeting.

Fax and E-mails: Invitations to the meetings were circulated via fax and e-

mail. The BID was also electronically sent to those who have access to

internet.

Focal meetings: Subsequent to the public meeting in Rosh Pinah, the socio-

economic specialist also consulted with a number of focal groups which

includes women in Tutungeni. Focal meetings were also conducted with

Figure 19: Posters put up in the RoshSkor

offices

Table 18: Notifications Placed in Press

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representatives from both the private and state health service providers,

RoshSkor, the local police, Hoeksteen Combined School as well as the

Skorpion Zinc mine.

By implementing these various methods of communication, the consultant set out to

have reached the key I&APs and provide them with an opportunity to participate in

the EA process.

5.5 THE MEETINGS TO DATE

As mentioned, two large meetings were held, namely one in Windhoek and one in

Rosh Pinah.

Since the majority of the ministries and parastatals have their headquarters in

Windhoek, an authorities meeting was conducted there in order to ensure

accessibility to the relevant organs of state. National, local and regional authorities

were invited to attend the meeting. It was noted that this is a difficult time of year

for the representatives to attend such gatherings and as such the meeting was not

well attended. We are in continual communication with key stakeholders and are

confident that their concerns are adequately reflected. Further meetings with key

stakeholders will be set up during the course of the ESIA to ensure that all issues are

considered and addressed.

With respect to the Rosh Pinah meeting, the public as well as local and regional

authorities were invited to attend this meeting. The meeting was held at the

Skorpion SportsPark in a marquee tent (Figure 20).

Figure 20: Venue for the Public Meeting in Rosh Pinah

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This venue is known and accessible to the whole Rosh Pinah community, and is

located across the road from the lower income area, Tutungeni. Thus no transport

was needed as it was within walking distance from this community. Round tables

were set up in the tent instead of a classroom type set-up, so that interaction and

community could be encouraged. The meeting was conducted in both English and

Afrikaans in order to ensure that all the attendees could understand the information

provided. Maps, diagrams and pictures were used in the presentation in order to

orientate and visually present key aspects on the proposed project. By doing so, the

illiterate were also considered in the manner that the information was presented.

Both the meetings were facilitated by representatives from Enviro Dynamics. A

representative from Skorpion Zinc provided an overview of the project details and

answered questions to the extent possible. Attendees were given an opportunity to

ask questions for clarification purposes on the technical details of the project, and

later on they could raise any issue or concern. The minutes of both these meetings

may be viewed in Appendix E.

Table 19 below provides a summary of the meetings conducted.

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Table 19: Summary of the meetings conducted

OBJECTIVES THE MEETING MAIN ISSUES RAISED PHOTO

NATIONAL LEVEL

Windhoek: To engage with

relevant authorities that have

jurisdiction over the area in order

to solicit their ideas and concerns

about the project. To assist the

consultant in defining the

parameters for the study in terms

of issues to explore.

Held on Thursday, 21 November

2013 in Windhoek at the Ministry

of Mines and Energy Auditorium.

Attended by representatives from

the Namibian Chamber of

Commerce and Industry, the

Namibian Competition

Commission and NamWater.

Possible impacts associated with

the tailings, the availability and

cost of electricity, need for

upgrading of water infrastructure,

need for housing and town

development, pressure on existing

services, possible increase in

crime associated with and influx

of job seekers, increase in traffic

and ability of road infrastructure

to handle this. Positive impacts

such as job creation and the

need for training and

development were also raised.

REGIONAL AND LOCAL LEVEL

Rosh Pinah: To consult with the

regional and local authorities who

have jurisdiction over the areas

where the proposed project will

be implemented. A platform was

also created for the public

whereby the concerns of

Held at the SportsPark in Rosh

Pinah on Tuesday, 12 November

2013.

The meeting was attended by

more than 300 people. The

attendees included farmers,

The road rerouting, visual impact

caused by tailings dam and the

mine especially if is open pit,

ownership of the farm vs.

ownership of the ore body,

benefits to the Region and local

community, job creation which

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OBJECTIVES THE MEETING MAIN ISSUES RAISED PHOTO

individuals, groups or local

communities could be conveyed

and the parameters for the study

in terms of issues to explore can

be developed.

To facilitate transparency with the

public which aids in building

good rapport, while identifying

potential challenges brought

about by the proposed project,

along with possible solutions.

members of the public,

employees from the Rosh Pinah

Zinc Corporation and Skorpion

Zinc mines, contractors and

consultants and SMEs, the private

and state health care sector,

Swapo political party

representatives, other mining

companies such as Namdeb and

NamZinc. Local businesses from

the town were also represented

along with the education sector.

should include women and youth,

training and development, role of

local SMEs and contractors, dust,

underground water levels and

quality, influx of job seekers and

associated increased pressure on

existing services and crime rates,

increased traffic, impact on

vegetation, need for housing and

town development. Proper

compensation for injuries or

disabilities caused at the

workplace and the contribution

to the spreading of HIV/AIDS were

also noted.

FOCAL MEETINGS AT LOCAL LEVEL

RoshSkor: To determine the main

challenges faced in terms of

public service delivery and better

understand the socio-economic

environment of the town.

The meeting was held on

Wednesday, 13 November 2013

at the RoshSkor Offices in Rosh

Pinah with the Manager.

To handle additional pressures

caused by an influx of people

there has to be an upgrading of

water, electricity and sewerage

infrastructure as existing

infrastructure has reached its

capacity limits. Road

infrastructure will also have to be

expanded in the town as new

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OBJECTIVES THE MEETING MAIN ISSUES RAISED PHOTO

houses are built. Proclamation of

the town is the responsibility of the

government and not RoshSkor.

Private Health Care Service

Providers: To determine the

services provided, gather health

baseline and identify existing

challenges faced.

The separate meetings were held

on Wednesday, 13 November

2013 at the Sidadi clinic: one with

the general manager and one

with a doctor.

An on-site clinic will contribute to

the sustainability of the project,

while limiting additional pressures

on available services in town.

Duplication of services can be

costly.

Police Station in Rosh Pinah:

determine existing crimes and

challenges faced.

A short meeting was held with a

sergeant at the police station on

14 November 2013.

Alcohol and related crime such as

violence or misbehaviour

constitutes the majority of the

crimes. The number of shebeens

in Tutungeni contributes to the

problem. Burglaries occur mainly

in the town. Limited

accommodation available.

Hoeksteen Combined School: to

determine existing status quo and

consider possible challenges.

On Thursday, 14 November 2013,

the consultant met with two Head

of Department Teachers at

Hoeksteen Combined School.

Existing school facilities is under

pressure and a platoon system is

already followed. Limited number

of teachers available due to

remoteness of Rosh Pinah and

limited housing available.

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OBJECTIVES THE MEETING MAIN ISSUES RAISED PHOTO

State Clinic in Bet-El: To

determine the services provided,

gather health baseline

information and identify existing

challenges faced.

The consultant met with the Sister

in charge at the State Clinic on 14

November 2013.

Influx of job seekers, shortage of

staff, need for the satellite clinic in

Tutungeni to become

operational. Injuries caused by

violent drunken behaviour a big

problem. Need for the status of

the clinic to be elevated to a

hospital before more staff can be

employed.

Women in Tutungeni: To consult

with women about the project,

their concerns and challenges

faced.

A group of women was visited in

Tutungeni on 14 November 2013.

Need for employment and

training opportunities, lack of

recognition of needs of women,

alcohol abuse and, influx creates

competition for employment and

services, need for proclamation of

town, need for open market.

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5.6 PUBLIC FEEDBACK

Continuous public input and feedback is an important component of the public

consultation process, as it also assists in transparency and building good relations. A

comments period was allowed from 28 October to 22 November 2013, providing

I&APs the chance to submit any questions or comments on the BID as well as

information presented at the meetings.

This Draft Scoping Report which also includes a summary of the public participation

process and an Issues and Responses Trail, is being made available to the I&APs for

their review and comment in the following ways:

Enviro Dynamics website: the report is uploaded onto the Enviro Dynamics

website where those who have access to internet can review it.

Emails: the link to the website is e-mailed to those who have such an address.

Hard copies: hard copies of the report are placed at key places in Rosh

Pinah where those who do not have access to the internet, can review it.

Executive Summary: since some might be more comfortable with Afrikaans,

the executive summary has been translated into Afrikaans and hard copies

also made available.

A two weeks comments period is allowed for during which I&APs can peruse the

document and submit any comments they have in writing. These comments are

then collated into a Comments and Responses Trail indicating where and how these

comments received were incorporated into the Final Scoping Report. The

comments period is from 5 February to 19 February 2014. A similar process will be

followed for the next phase of the project, which is the Environmental Impact

Assessment (EIA) phase.

5.7 PUBLIC CONCERN

The issues that were raised during the above consultation forums, as well as in

writing, have all been collated in the Issues and Responses Trail (see Appendix F).

These issues will further be considered in the full impact assessment phase which will

be a separate document. The key concerns and issues raised by the I&APs are

summarized in Table 20 below. This table is directly related to Table 24 that indicates

in which reports these issues shall be addressed.

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Table 20: Summary of issues resulting from the Public Participation process

SUMMARY OF ISSUES

PUBLIC CONSULTATION PROCESS

NOISE Noise pollution caused by mining

activities and increased vehicle

movement.

AIR QUALITY Contribution to the existing problem of

dust in Rosh Pinah.

Dust pollution from a possible open pit

mine of highest concern.

VISUAL RESOURCES Change in visual amenity of the area due

to:

o Tailings that are higher than

the surrounding mountains

and hills;

o An open pit mine.

BIODIVERSITY AND HABITAT Possible impact of dust on vegetation.

Possible need for the relocation of some

vegetation.

GEO-HYDROLOGY Possible impact on groundwater levels

and quality which will affect other water

users especially the neighbouring farms.

SOCIO-ECONOMIC General concern about sustainability of

the town. What will sustain the local

economy and livelihoods if the existing

mines close?

The Region and the community of Rosh

Pinah should benefit from the proposed

project, and not only an individual or the

mining company.

Preference should be given to Namibian

contractors should they be qualified to

do the work.

Need for job creation of both skilled and

unskilled workers.

Women should also be included in the

recruitment process.

The community should be well informed

about the recruitment process.

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Need for training and development. The

youth and women should be included in

this process.

Possible employment of local SME’s in

order for locals to benefit from the

project.

The recruitment process of the SME’s

should also be monitored to ensure that

they adhere to the requirements set out in

the tender.

Need for an open market during

recruitment.

Crime rates can increase due to an influx

of job seekers.

Need for further assistance to be

provided to the Hoeksteen school as part

of the new mine’s corporate social

responsibility.

HEALTH AND SAFETY Contribution to the spreading of HIV/AIDS.

Need for contractors to also be included

in the HIV Action Plans, and not only the

permanent employees of the new mine.

Need for proper compensation in the

event of injuries.

Possibility of an on-site clinic providing

primary and occupational health care

services which will limit possible additional

impacts on the health care services in

Rosh Pinah.

Contribution to the existing problem of

dust and consequent health impacts

such as infections caused by the existing

tailings dam in town. i.e. cumulative

impact of tailings dams on health.

INFRASTRUCTURE AND SERVICES Ability of NamPower to meet additional

electricity demand of the new mine and

employees by 2017.

Feasibility of the project in light of possible

escalation of electricity costs.

In order to meet the increased demand

for water, a new pipeline will have to be

installed from the Orange River to the

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town.

Possible increase in traffic on the C13

Road.

Influx of job seekers and new employees

will add to the existing pressure on

services in both the town and Tutungeni

such as:

o Sewerage system;

o Waste removal;

o Water;

o Schools;

o Housing;

o Electricity.

The need for the proclamation of the

town which can result in people owning

their own houses and business erven to

be developed by private companies.

Industrial and business erven are needed

to cater for secondary businesses and

industries attracted to the town.

LEGAL PROCESS The need for proper and fair negotiations

with the owner of Farm Spitzkop 111

before the project can be implemented.

The mining company first has to establish

ownership of the land before they can

mine the ore body.

Concerns about the possibility of the

project not being implemented due to

disputes between Rosh Pinah Zinc

Corporation and Skorpion Zinc, which in

turn can deprive the community of

possible benefits such as employment.

Need for government to intervene in

order to resolve the dispute.

EIA PROCESS The 7-day period for appeals to the

Environmental Commissioner is too short.

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Feedback is a crucial step to ensure stakeholders are afforded an opportunity to

ensure that their comments have all been incorporated into this report. The

contents of this scoping report will therefore be made available electronically as

well as in hard copy format at venues that are accessible.

The subsequent report, namely the draft ESIA Report will be made available in similar

manner and will be accompanied by feedback meetings. The public will once

again receive the opportunity to consider whether their concerns were sufficiently

addressed and will be able to make comments. These comments will be recorded

and responded to and this will be made public.

Once the documents have been submitted to the Directorate of Environmental

Affairs, there is an opportunity to submit objections and appeals to that Ministry too.

This exact process will be explained exactly once the final submission is made.

A grievance mechanism is also required for the community to lodge complaints

once the project is being implemented. A mechanism for this will be put in place in

the Environmental and Social Management Plan and the public is welcomed to

make suggestions to this effect.

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Avoidance at source

Reduce/repair on site

Compensate

6 IMPACT ASSESSMENT

All potential impacts have been identified to this end. This section provides a

preliminary assessment of those impacts in order to determine their potential

significance at a preliminary stage, keeping in mind that there are still many

unknowns. Ratings are therefore on the conservative side. All those impacts which

are potentially significant, either because of a lack of information to make a

decision or because of the sensitivity of the area, are listed here and will have to be

investigated in further detail.

A preliminary impact assessment is applied during the scoping process in order to

arrive at the key potential impacts which require further investigation. This is the

purpose of this section, namely to consider all the potential concerns raised by I&APs

and the sensitivities of the site. They are screened here so that those issues which

require further investigation are separated from those for which solutions are already

available and for which sufficient information is available to make a valid

assessment.

Issues which are not part of the scope of the ESIA process, but which were raised at

the meetings, e.g. legal disputes and questions around the feasibility of the project

have been recorded and noted by the Skorpion Mining Company, but are not

addressed further as potential impacts.

6.1 MITIGATION HIERARCHY

A mitigation hierarchy is being employed for this project (Figure 21 below). The best

way to minimise an unwanted impact is to avoid it. This simple truth of often

overlooked as projects go through their planning and development stages. For this

reason all facilities of the project are constantly scrutinised for the best sustainable

alternatives and solutions, whilst also considering technical, economic and financial

constraints.

Figure 21: Mitigation hierarchy applied.

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The second option would be to reduce/ repair (i.e. mitigate) the impact on site while

the last resort would be to compensate a particular community, group of individuals

or person, if the impact cannot be either avoided or mitigated to acceptable levels.

6.2 METHODOLOGY EMPLOYED FOR THE IMPACT ASSESSMENT

The Namibian Regulations require “a description of the significance of any

significant effects, including cumulative effects that may occur as a result of the

undertaking of the activity”.

A risk assessment has been conducted using information available about the

environment and the project coupled with potential mitigation options. The risk

assessment provides a preliminary high level indication of the significance of the

potential impacts identified. The methodology used for the assessment is as follows

(Table 21):

Table 21: Definitions of each of the Criteria used to determine the significance of impacts

DESCRIPTION

NATURE Reviews the type of effect that the proposed activity will have on

the relevant component of the environment and includes “what will

be affected and how?”

EXTENT Geographic area. Indicates whether the impact will be within a

limited area (on site where construction is to take place); local

(limited to within 25km of the area); regional (limited to ~200km

radius); national (limited to the coastline of Namibia); or

international (extending beyond Namibia’s boarders).

DURATION Whether the impact will be temporary (during construction only),

short term (1-5 years), medium term (5-10 years), long term (longer

than 10 years, but will cease after operation) or permanent.

INTENSITY Establishes whether the magnitude of the impact is destructive or

innocuous and whether or not it exceeds set standards, and is

described as none (no impact); low (where natural/ social

environmental functions and processes are negligibly affected);

medium (where the environment continues to function but in a

noticeably modified manner); or high (where environmental

functions and processes are altered such that they temporarily or

permanently cease and/or exceed legal standards/requirements).

PROBABILITY Considers the likelihood of the impact occurring and is described as

uncertain, improbable (low likelihood), probable (distinct

possibility), highly probable (most likely) or definite (impact will

occur regardless of prevention measures).

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SIGNIFICANCE Significance is given before and after mitigation. Low if the impact

will not have an influence on the decision or require to be

significantly accommodated in the project design, Medium if the

impact could have an influence on the environment which will

require modification of the project design or alternative mitigation

(the route can be used, but with deviations or mitigation) High

where it could have a “no-go” implication regardless of any

possible mitigation (an alternative should be used).

STATUS OF THE IMPACT A statement of whether the impact is positive (a benefit), negative

(a cost), or neutral. Indicate in each case who is likely to benefit

and who is likely to bear the costs of each impact.

DEGREE OF

CONFIDENCE IN

PREDICTIONS

Is based on the availability of specialist knowledge and other

information.

The application of the above criteria to determine the significance of potential

impacts uses a balanced combination of duration, extent, and intensity/magnitude,

modified by probability, cumulative effects, and confidence. Significance is

described as follows (Table 22):

Table 22: Definitions of the various significance ratings

SIGNIFICANCE RATING CRITERIA

LOW Where the impact will have a negligible influence on the

environment and no modifications or mitigations are necessary for

the given development 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 development design and/or

alternative mitigation. This would be allocated to impacts of

moderate severity/magnitude, 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 (i.e. there could be

a ‘no-go’ implication for the development, regardless of any

possible mitigation). This would be allocated to impacts of high

magnitude, locally for longer than a month, and/or of high

magnitude regionally and beyond.

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6.3 ASSESSMENT OF IMPACTS

Table 23: Impact assessment of the proposed project

POTENTIAL IMPACT CAUSED BY STATUS/

NATURE EXTENT DURATION INTENSITY PROBABILITY

DEGREE OF

CONFIDENCE

SIGNIFICANCE

PRE-

MITIGATION

MITIGATION/

ENHANCEMENT

POST-

MITIGATION

Economic gain

(i.e. to all levels

of society, e.g.

gender, skilled,

unskilled, local to

national

benefitting

optimally and

appropriately)

sustaining the

economy of the

town, the vitality

of its people into

the future and the

contribution to

the national

economy.

Employment and

contracting

during

construction,

operation and

decommissioning.

Positive National Long term High Definite Medium Medium Recruitment

management

process structured

to benefit all.

Good

communication

and ongoing

consultation

Training and

development

process.

High

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POTENTIAL IMPACT CAUSED BY STATUS/

NATURE EXTENT DURATION INTENSITY PROBABILITY

DEGREE OF

CONFIDENCE

SIGNIFICANCE

PRE-

MITIGATION

MITIGATION/

ENHANCEMENT

POST-

MITIGATION

Increase in living

standards due to

employment

creation

Recruitment

during

construction and

staff during

operation.

Positive National Long term High Probable Low Medium As above. Medium to

high.

Increased

pressure on

services

(infrastructure,

schools, clinics,

housing, etc.) in

Rosh Pinah

Increased influx of

job seekers and

their families to

Rosh Pinah.

Increased number

of people in need

for services.

Negative. Local Long term. High Definite Medium High Strengthen

management of

the town.

Resources to

additional housing

and services.

Medium.

Increased crime

and social ills

Increased influx of

job seekers and

their families to

Rosh Pinah.

Negative Local Long term Medium Probable Medium Medium Increased

resources at police

station.

Medium to

Low

Increased

HIV/AIDS and

other

communicable

diseases.

Influx of job-

seekers,

construction

workers and shift

working.

Negative National Long term High Highly

probable

Medium High HIV/AIDS

management

plans implemented

throughout the

entire workforce

Medium

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POTENTIAL IMPACT CAUSED BY STATUS/

NATURE EXTENT DURATION INTENSITY PROBABILITY

DEGREE OF

CONFIDENCE

SIGNIFICANCE

PRE-

MITIGATION

MITIGATION/

ENHANCEMENT

POST-

MITIGATION

and contractors.

Occurrence of

occupational

injuries.

Unsafe

construction work

procedures, lack

of safety

procedures, etc.

Negative National Permanent High Highly

probable

Medium Medium Continue with

current safety

standards.

Compensation

where warranted.

Medium to

low.

Land use conflict Reduced visual

impact, noise,

reduced water

quality.

Negative. Local Long term Medium Probable Medium High Design mitigations

for dust, noise,

water pollution,

etc.

High to

medium

(open pit)

Low to

medium

(underground)

Increased levels

of GHG due to

increased energy

demand which

could contribute

to climate

change.

Increased

pressure on

infrastructure

Increased energy

requirements for

construction but

particularly

operation phase

Negative National Long term High Definite Medium High Implement

technically and

financially feasible

and cost-effective

options to refuce

project related

GHG emissions.

Communications

with NamPower,

High to

medium

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POTENTIAL IMPACT CAUSED BY STATUS/

NATURE EXTENT DURATION INTENSITY PROBABILITY

DEGREE OF

CONFIDENCE

SIGNIFICANCE

PRE-

MITIGATION

MITIGATION/

ENHANCEMENT

POST-

MITIGATION

related to

increased as

energy demand

Increased water

demand and

pressure on the

resource.

Water

requirements for

the construction

period,

concentrator, dust

mitigation, etc.

Negative International Long term Medium Definite Medium Medium Water efficiency

introduced

Medium

Dust pollution

and resulting

effects including

health concerns,

deteriorating

habitat and

visual impact

Construction,

Operations

particularly in

open pit, haulage

of ore, tailings.

Negative Local Long term to

permanent

High Definite Medium High –

open pit.

High –

road

haulage

Medium –

tailings

Tailings design, dust

suppression, traffic

control

High – open

pit

Medium –

road haulage.

Medium to

low – tailings.

Loss of visual

amenity.

Tailings

Open pit,

Site facilities

Negative Local Permanent High Definite Medium High –

open pit

High -

tailings

Medium –

Underground,

Tailings design,

Road re-route to

consider visual

impact,

High to

medium– if

open pit

Medium to

low – tailings

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POTENTIAL IMPACT CAUSED BY STATUS/

NATURE EXTENT DURATION INTENSITY PROBABILITY

DEGREE OF

CONFIDENCE

SIGNIFICANCE

PRE-

MITIGATION

MITIGATION/

ENHANCEMENT

POST-

MITIGATION

site

facilities

Colour and

footprint of site

facilities

Medium to

low – site

facilities

Reduced

groundwater

quality affecting

users

Tailings, sewerage

treatment facility

Negative Regional Permanent High Probable Low High Tailings design Low

Reduced

groundwater

supply and

resulting impacts

on neighbouring

farms

Pit dewatering, Negative Regional Long term High Probable Low High Pit dewatering not

to exceed

abstraction limits

Undetermined

Increased

erosion

Placing facilities in

major drainage

lines

Negative Local Long term High Highly

probable

Medium High Design diversions,

water attenuation

techniques, etc.

according to

specialist

recommendations

Medium to

low.

Loss of

biodiversity and

Mine, tailings, site Negative National Long term to High Highly Medium High Keep footprint low,

dust suppression;

Open pit -

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POTENTIAL IMPACT CAUSED BY STATUS/

NATURE EXTENT DURATION INTENSITY PROBABILITY

DEGREE OF

CONFIDENCE

SIGNIFICANCE

PRE-

MITIGATION

MITIGATION/

ENHANCEMENT

POST-

MITIGATION

habitat footprint permanent probable rehabilitation;

design of tailings.

high

Loss of

archaeological

heritage

Footprint at

tailings,

infrastructure,

road re-

alignment.

Negative National Permanent Medium Probable Medium Medium Siting of facilities,

Site removal before

construction,

chance find

procedure.

Low.

Increased noise

levels.

Open pit,

haulage,

concentrator.

Negative Local Long term Low Definite Medium Low to

medium

Noise suppression

inside facility, limit

speed of trucks.

Low.

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It is clear from the risk assessment in Table 23 that most of the issues raised during

consultation and sensitivities identified from the baseline work conducted so far are

potentially significant. This is due to a combination of the sensitivity of the area and

the magnitude of the project. A conservative approach has been followed since

there are many unknowns at this stage. The significance ratings indicate the need

for further investigations, but also indicate the good potential for avoidance and

mitigation. The next section provides a summary of the studies that will be carried

out during the investigations phase.

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7 CONCLUSIONS AND RECOMMENDATIONS

7.1 INTRODUCTION

At this juncture, following extensive and fair opportunity for public and stakeholder

input, we are confident that all the concerns raised and sensitivities identified are

well documented and conveyed in this report.

It is clear that the community recognises the biophysical sensitivity of the area.

Further investigations therefore need to be conducted to find ways of limiting visual

impact, habitat and biodiversity loss, water pollution, dust and its health and

ecological effects, heritage loss, and resource demand.

However, the overriding factor of concern in the Rosh Pinah community is the

uncertainty around the future vitality of the town. The existing mines have a limited

life, which brings about insecurity in peoples’ minds about their future employment.

Another area of concern involves the ability of the existing town structure to absorb

the additional need for land, housing, infrastructure and social services such as

schooling, health care, and security. Not only should the additional workers and

their families be accommodated, but the incoming job seekers are likely to exceed

available employment opportunities. If these people settle in Rosh Pinah, the

shortfall of available housing, services and infrastructure is likely to grow.

The specialists now need to work out the details of these concerns in the coming

months. Table 24 below provides a summary of the Terms of Reference of the

specialists that will be conducting these investigations.

The ESIA lead team will ensure that the specialists receive the details reports of the

inputs provided during public consultation so that all concerns are properly covered.

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7.2 SPECIALIST STUDIES

THEME / STUDY AREA SPECIALIST TERMS OF REFERENCE

Ecology Dr John Irish - Biodata Coleen Mannheimer

Focus on the biodiversity by studying

changes in the study area due to:

change in the distribution and ration of

endemic, range-restricted endemic and

potentially threatened species;

change in the ecological functioning of

the area;

cumulative and related effects of

change that the project may add to the

ecology; and

impacts on priority ecosystem services

(IFC PS 6).

Groundwater Supply and Quality

Desmond Visser - SRK Pierre Botha - Geo Pollution Technologies

Establish pre-development baseline

conditions and aquifer characteristics.

Identify potential sources, pathways and

receptors for groundwater contamination.

Study expected changes in the:

groundwater quality and movement

due to the infrastructure, facilities and

activities of the project, particularly the

tailing storage facility; and

groundwater supply due to operations of

the mine, particularly pit/mine

dewatering.

The following model will be used:

MODflow groundwater equation.

Geochemistry Richard O’Brien - SRK

Study the geochemical composition of the

material to be disposed of at the proposed

tailings storage facility so that chemical

changes to the receiving environment,

including soils and groundwater, may be

determined.

Air Quality Dr Mark Zunckel - uMOYA-NILU

Focus on air quality by studying changes in

the receiving environment by:

identifying baseline conditions,

Table 24: Key issues to be investigated, specialists assigned and their main Terms of Reference.

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THEME / STUDY AREA SPECIALIST TERMS OF REFERENCE

potentially sensitive receptors, process

and dust emissions of the proposed

construction and mining activities;

modelling the expected downwind air

conditions created by the project

infrastructure, facilities and activities;

and

determining the impact on climate

change due to possible Greenhouse

Gas Emissions (IFC PS 3)

The following approach will be used during

this study:

US-EPA emission factors will be used;

Ambient concentrations of coarse and

fine (PM10) particulates will be estimated

using the US-EPA and IFC approved

SCREEN 3 model for default meteorology

and the estimated emissions from the

tailings dam, waster rock dump and the

mine activities (dumping and vehicles).

The predicted concentrations will be

plotted as line graphs and on maps and

compared with WHO ambient air quality

guidelines.

Noise Brett Williams - Safetech

Focus on noise by studying changes in the

receiving environment by:

identifying baseline conditions,

potentially sensitive receptors, and

emissions expected from construction,

process and mining activities; and

modelling the noise conditions created

by the construction and operation of the

project infrastructure and facilities.

The following models will be used:

SANS 10103:2008 Version 6 - The

measurement and rating of

environmental noise with respect to

annoyance and to speech

communication;

SANS 10328, Methods for environmental

noise impact assessments; and

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THEME / STUDY AREA SPECIALIST TERMS OF REFERENCE

SANS 10357, The calculation of sound

propagation by the CONCAWE method.

Visual Change Norman van Zyl - Enviro Dynamics

Focus on visual changes in the receiving

environment by:

identifying potentially sensitive receptors,

baseline visual resource conditions and

visual sources generated by the project

infrastructure, facilities and activities;

generating a visual inventory to

determine the value of the views from

the various visual receptors; and

modelling the visibility of the project

infrastructure, facilities and activities from

significant views.

The following model will be used:

US Army Corps of Engineers (Henderson,

1988) Visual Resources Assessment

Procedure (VRAP).

Socio-economic Impact Carla Saayman - Enviro Dynamics

Focus on the socio-economic environment

by studying changes in the:

various forms of land-use;

tourism, traditional livelihood,

commercial farming and mining

industries;

social and economic conditions at local,

regional and national levels; and

sustainability of Rosh Pinah which

includes project-induced influx, pressure

on infrastructure and services, social

conflicts for opportunities and social

closure.

Health Impact Rietta Oosthuizen - CSIR

Consider the changes in the community

health and wellbeing by:

creating a baseline community health

and well-being profile by identifying the

communities of concern in the Rosh

Pinah area;

determine the status quo of the factors

that may influence their vulnerability to

the environmental exposure as a result of

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THEME / STUDY AREA SPECIALIST TERMS OF REFERENCE

the development including aspects such

as existing diseases, other exposures

such as domestic fuel use, lack of

services such as water and sanitation,

low educational status, unemployment

etc. In addition, determine existing

factors that assist in better coping with

environmental exposure such as access

to health care, high education level, low

unemployment etc.

evaluate the risks and impacts to the

health and safety of the affected

communitites during the project life-

cycle and establish preventive and

control measures consistent with good

international industry practice such as

the World Bank Group Environmental,

Health and Safety (EHS) Guidelines or

other internationally recognised sources

(IFC PS 4).

The HIA approach is a practical and multi-

disciplinary process, combining a range of

qualitative and quantitative evidence in a

decision-making framework (Lock, 2000).

Archaeology Dr John Kinahan - QRS Namibia

Focus on the archaeological landscape of

the study area by:

conducting an overview of the project

area to identify sensitive areas to avoid

(completed to guide the planning

process); and

a detailed survey of the area affected

by the proposed footprint of all the

facilities, including infrastructure of the

mine, to identify archaeological sites

that require mitigation.

Restoration Dr Theo Wassenaar - African Wilderness Restoration

Develop a concept restoration plan for the

mine which fits the ecological make-up of

the area in consultation with the mine

management.

In addition to these specific Terms of Reference, they will also be tasked:

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to investigate mitigation options for the impacts (during construction,

operation, decommissioning and post closure phase) identified;

to use recent environmental and social baseline data at an appropriate level

of detail (IFC PS 1);

to include an assessment of whether the impacts can be mitigated or

controlled to acceptable levels;

to use a combination of local legislation augmented with international

standards where needed;

to complete their studies in line with the Performance Standards of the

International Finance Corporation, the fulfilling of which is important to

achieve a bankable Feasibility Study;

to determine all cumulative impacts that may result due to the proposed

development; and

to conduct an alternatives assessment.

The way forward

This Draft Scoping Report will be circulated to the authorities and the public

for comment. These comments will be a) incorporated into the report and b)

carried forward for consideration in the remaining phases of the ESIA process.

The Draft Scoping Report will be submitted to the Directorate of

Environmental Affairs (DEA) within the Ministry of Environment and Tourism

(MET) after comments received from the public have been incorporated.

The specialist studies have been commissioned, as outlined above (this is the

full investigation phase).

These specialist studies will form the basis for the Draft Environmental and

Social Impact Assessment Report and will inform the environmental

considerations of the bankable Feasibility Study Process.

The Draft Environmental and Social Impact Assessment Report will again be

shared with the community and the authorities, using a similar process as for

the draft scoping report. However, a feedback meeting will be held at the

time.

Once the documents have been submitted, there will once again be an

opportunity to submit comments to the Directorate of Environmental Affairs,

the process which will be specifically explained then.

The consultant will furthermore recommend a grievance mechanism for

including any complaints that may arise during the implementation of the

project to be included in the Environmental and Social Management Plan

(the document spelling out the management actions which are required to

implement the recommendations of this assessment).

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8 REFERENCES

Barnard, P. (ed.) (1998). Biological diversity in Namibia: a country study. Windhoek,

Namibian National Biodiversity Task Force.

Fish Eagle Productions. (2012). Rosh Pinah Info. Available at www.roshpinahinfo.co.za

(Accessed 21 July, 2013)

Fuls, H., Viviers, G., Thomas, R., & Mitchell, J. (2010). Skorpion Sulphides & Gergarub

Concept Study Report. Prepapred for Skorpion Zinc by Fuls, Viviers, Thomas, Mitchell

investigators on behalf of NAMZINC PTY (LTD) March 2010. pp. 17-31

Henderson, J. E. (Ed.). (1988). Visual Resource Assessment Procedure for US Army

Corps of Engineers. Vicksburg, Mississippi: US Army Engineer Waterways Experiment

Station.

Irish, J., & Mannheimer, C. A. (2013). Preliminary Environmental Zoning for the

Gergarub Project Area. Prepared for Skorpion Zinc by Irish and Mannheimer

Environmental Specialists on behalf of Enviro Dynamics February 2013.

Kinahan, J. (2013). Archaeological Baseline Survey for the Gergarub Zinc Project.

Prepared for Skorpion Zinc by Kinahan on behalf of Enviro Dynamics March 2013.

Movirongo, C. (2011). Press Release: A memorandum of understanding signed

between Skorpion Zinc and the Ministry of Health and Social Services. Rosh Pinah:

Skorpion Zinc.

Myers, N., Mittermeier, R., Mittermeier, C., Da Fonseca, G., & Kent, J. (2000).

Biodiversity Hotspots for conservation priorities. Archive Nature.com 403: 853-858.

Van Wyk, A., & Smith, G. (2001). Regions of Floristic Endemism in Southern Africa. A

Review with an Emphasis on Succulents. Hatfield: Umdaus Press.