proposed otjivalunda salt mining and soap production · 2013. 11. 15. · mining and soap...

ENVIRONMENTAL IMPACT ASSESSMENT REPORT FINAL 2013

PROPOSED OTJIVALUNDA SALT MINING AND SOAP PRODUCTION

O t j i v a l u n d a S a l t M i n i n g a n d S o a p P r o d u c t i o n

F i n a l E I A R e p o r t

P a g e i i

COPYRIGHT © GECKO NAMIBIA (PTY) (LTD), 2013. ALL RIGHTS RESERVED

PROJECT NAME Environmental Impact Assessment for the proposed Otjivalunda salt

mining and soap production facility

STAGE OF REPORT Final Environmental Impact Assessment (EIA) Report

CLIENT

Gecko Namibia (Pty) (Ltd)

Enquiries: Oliver Krappmann

Tel: (061) 305 444

E-Mail: [email protected]

LEAD CONSULTANT

Enviro Dynamics

Enquiries: Eloise Carstens

Tel: (061) 223-336

E-Mail: [email protected]

DATE OF RELEASE November 2013

CONTRIBUTORS TO THE REPORT Eloise Carstens, Carla Saayman, Celester Harker, Eddy Kuliwoye

Reviewer: Stephanie van Zyl

mailto:[email protected]

mailto:[email protected]



P a g e i i i

DECLARATION

I hereby declare that I do:

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

Act, these 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 Act, these 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 the

regulations; or

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

regulations.

Eloise Carstens

Environmental Assessment Practitioner (EAP)



P a g e i v

TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................ iv

LIST OF FIGURES AND TABLES .............................................................................................. vii

ACRONYMS & ABBREVIATIONS ........................................................................................... ix

DEFINITIONS ......................................................................................................................... xi

APPENDICES ....................................................................................................................... 12

1 INTRODUCTION ............................................................................................................. 1

1.1 BACKGROUND ........................................................................................................... 1

1.2 RATIONALE .................................................................................................................. 2

1.3 APPOINTED ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) ....................... 2

1.4 TERMS OF REFERENCE ................................................................................................ 2

1.5 WORK PLAN FOR STUDY ............................................................................................ 4

1.6 APPROACH TO THE STUDY ......................................................................................... 5

1.7 REPORT LAYOUT .......................................................................................................... 9

2 ASSESSMENT OF ALTERNATIVES .................................................................................. 10

2.1.1 THE NO-GO ALTERNATIVE ................................................................................ 10

2.1.2 ALTERNATIVE MINING SITE LOCATIONS .......................................................... 10

3 PROJECT DESCRIPTION: SALT MINING ...................................................................... 11

3.1 OVERVIEW OF THE PROJECT ................................................................................... 12

3.2 MINING: THE RESOURCE .......................................................................................... 12

3.3 MINING ACTIVITIES ................................................................................................... 14

3.3.1 MINING PROCESS: HALITE CRYSTALLIZATION AND HARVESTING ................ 17

3.3.2 MINING PROCESS: TRONA, BURKEITE AND THENARDITE .............................. 18

3.4 SITE ESTABLISHMENT AND INFRASTRUCTURE REQUIREMENTS ............................... 19

3.4.1 PROPOSED SITE LAYOUT AND ASSOCIATED SITE INFRASTRUCTURE ............ 19

3.4.2 SERVICE INFRASTRUCTURE REQUIREMENTS .................................................... 21

4 POLICY AND LEGAL FRAMEWORK ............................................................................. 23

5 DESCRIPTION OF THE RECEIVING ENVIRONMENT...................................................... 35

5.1 INTRODUCTION ......................................................................................................... 35



P a g e v

5.2 OVERVIEW OF THE PROJECT ENVIRONMENT ........................................................ 35

5.2.1 ENVIRONMENTAL FEATURES AT THE MINE ...................................................... 35

5.2.2 HABITATS AT THE MINING SITE .......................................................................... 37

5.3 AQUATIC FAUNA ...................................................................................................... 39

5.3.1 HABITAT PREFERENCES ..................................................................................... 39

5.3.2 ECOSYSTEM SERVICES ...................................................................................... 39

5.3.3 EXPECTED VS OBSERVED ORGANISMS .......................................................... 40

5.3.4 SENSITIVITIES ....................................................................................................... 43

5.4 BIRDS .......................................................................................................................... 44

5.4.1 HABITAT PREFERENCES ..................................................................................... 44

5.4.2 IMPORTANT BIRD AREAS (IBA) ......................................................................... 45

5.4.3 SENSITIVE BIRD SPECIES EXPECTED AT THE SITE .............................................. 45

5.4.4 SENSITIVITIES ....................................................................................................... 50

5.5 ARCHAEOLOGY ....................................................................................................... 50

5.5.1 CURRENT STATUS ............................................................................................... 50

5.5.2 HISTORICAL SIGNIFICANCE OF THE OTJIVALUNDA PANS ............................ 51

5.5.3 SENSITIVITIES ....................................................................................................... 51

5.6 CULTURAL SALT HARVESTING .................................................................................. 53

5.6.1 CULTURAL SIGNIFICANCE OF SALT HARVESTING .......................................... 53

5.6.2 ECONOMIC VALUE OF SALT HARVESTING .................................................... 54

5.6.3 SENSITIVITIES ....................................................................................................... 55

5.7 FUTURE PLANNED TOURISM ACTIVITIES IN THE CONSERVANCY .......................... 56

5.7.1 CHALLENGES AND OPPORTUNITIES IN THE CONSERVANCY ....................... 56

5.7.2 POSSIBLE FINANCIAL AND ECONOMIC OPPORTUNITIES ............................. 58

5.7.3 SENSITIVITIES ....................................................................................................... 59

6 PUBLIC CONSULTATION AND DISCLOSURE ................................................................ 61

6.1 INTRODUCTION ......................................................................................................... 61

6.2 PUBLIC CONCERN .................................................................................................... 61

6.3 PUBLIC FEEDBACK .................................................................................................... 64

7 ASSESSMENT OF IMPACTS .......................................................................................... 65



P a g e v i

7.1 IDENTIFICATION OF KEY ISSUES................................................................................ 65

7.2 METHODOLOGY EMPLOYED FOR THE IMPACT ASSESSMENT .............................. 67

7.3 ASSESSMENT OF IMPACTS ........................................................................................ 68

7.3.1 POTENTIAL IMPACT ON ENDEMIC AQUATIC FAUNA .................................... 68

7.3.2 POTENTIAL IMPACT ON ENDEMIC BIRD SPECIES ........................................... 73

7.3.3 LOSS OF OR DAMAGE TO ARCHAEOLOGICALLY SIGNIFICANT SITES ........ 77

7.3.4 LOSS OF CULTURAL SALT HARVESTING RITUALS............................................. 80

7.3.5 IMPACT ON FUTURE PLANNED TOURISM ACTIVITIES IN THE

CONSERVANCY ................................................................................................. 87

8 CONCLUSIONS AND RECOMMENDATIONS ............................................................... 90

8.1 SYNOPSIS OF THE FIVE KEY IMPACTS ...................................................................... 90

8.2 CONCLUSION ........................................................................................................... 91

9 REFERENCES ................................................................................................................ 94



P a g e v i i

LIST OF FIGURES AND TABLES

Figure 1: Locality of the various components of the proposed Ojtivalunda salt

mining and soap production project. ............................................................. 1

Figure 2: Diagrammatic summary of work plan. ............................................................ 4

Figure 3: Assessment of issues based on the availability of information to

address or mitigate it. ........................................................................................ 8

Figure 4: Location of the proposed mining sites. ......................................................... 11

Figure 5: Berm compartments of the Otjivalunda East and West Pan and the

position of the campsite and workshop area. ............................................. 15

Figure 6: Berms allow for the movement of vehicles to the various sections on

the pan............................................................................................................... 16

Figure 7: Illustration of the berm structure with trench and plastic liner. .................. 16

Figure 8: The crystallization of salt on the surface of the pan is a natural

process. This salt contains a mixture of sodium chlorite, sulphate

and carbonates. It is not a pure form of salt. .............................................. 17

Figure 9: Waterking floating dredger ............................................................................. 18

Figure 10: Proposed layout of the campsite and workshop at the Otjivalunda

pans. ................................................................................................................... 20

Figure 11: Landscape at the Otjivalunda East pan. ...................................................... 35

Figure 12: Habitats associated with the Otjivalunda west salt pan)

(Scott, 2013)- ..................................................................................................... 37

Figure 13: The “pan edge” habitat (Scott, 2013). .......................................................... 37

Figure 14: Grasslands habitat with drainage line on the edge of the mining

area. ................................................................................................................... 38

Figure 15: Otjivalunda Pans: Recent salt-mining earthworks on Pan 2 (Kinahan,

2013). .................................................................................................................. 52

Figure 16: Location of the Otjivalunda pans in relation to the Iipumbu ya

Tshilongo Conservancy and the Etosha National Park. .............................. 57

Figure 17: Proposed location for the development of an African safari lodge

close to the Narawanda gate........................................................................ 58



P a g e v i i i

Table 1: Potential issues identified during the first phase of the project.......................... 5

Table 2: Characteristics of the salts occurring at the Otjivalunda Pans. ....................... 12

Table 3: Composition and deposits of sodium salts at the two different pans. ............ 13

Table 4: Methods used to mine trona, burkeite and thenardite ore. ............................ 19

Table 5: Description of the infrastructure required at the campsite, workshop

and explosives magazine. .................................................................................... 21

Table 6: Description of the service/infrastructure requirements at the

Otjivalunda pans mining site. ............................................................................... 22

Table 7: Summary of the on-site conditions at the mining site. ...................................... 35

Table 8: Summary of findings from Irish (2013). .................................................................. 41

Table 9: Sensitivity of aquatic fauna in the project area. ................................................ 44

Table 10: Bird species likely to occur in the various habitats at the Otjivalunda

pans. ........................................................................................................................ 44

Table 11: Bird species and their habitat preferences at the Otjivalunda pans. ............ 47

Table 12: Environmental sensitivities related to birds ......................................................... 50

Table 13: Archaeological sensitivity in the project area ................................................... 51

Table 14: Summary of the uses of salt by the communities. ............................................. 54

Table 15: Value of Salt. ........................................................................................................... 55

Table 16: Sensitivities and potential impacts associated with cultural salt

harvesting. ............................................................................................................... 55

Table 17: Opportunities and challenges associated with tourism development

in the conservancy. ............................................................................................... 57

Table 18: Possible financial and economic returns of the lodge and associated

tourism activities (Humphrey & Brown, 2013). .................................................... 59

Table 19: Sensitivity associated with tourism development in the project area ............ 60

Table 20: Summary of issues raised during the consultation process .............................. 62

Table 21: Identification of key impacts associated with the various phases of

the project at the mining site. .............................................................................. 66

Table 22: Criteria for the assessment of impacts. ............................................................... 67



P a g e i x

ACRONYMS & ABBREVIATIONS

ADT Articulated Dump Truck

CBNRM Community Based Natural Resource Management

CO2 Carbon Dioxide

DEA Directorate of Environmental Affairs

DRFN Desert Research Foundation of Namibia

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

EMA Environmental Management Act

EMP Environmental Management Plan

EPL Exclusive Prospecting Licence

FOREX Foreign Exchange

GHG Greenhouse gasses

HRFA Human Resources, Finance and Administration

IBA Important Bird Area

I&AP Interested and Affected Parties

KVA Kilovolt-Ampere

MET Ministry of Environment and Tourism

MME Ministry of Mines and Energy

NACSO Namibian Association of CBNRM Support Organisations

NPC National Planning Commission

NORED Northern Regional Electricity Distributor

OUME Ondonga-Uukwambi Mining Enterprises

PVC Polyvinyl Chloride

QRS Quaternary Research Services

SADC Southern African Development Community

SIDA Swedish International Development Cooperation Agency



P a g e x

TOR Terms of Reference

UNFCCC United Nations Framework Convention on Climate Change



P a g e x i

DEFINITIONS

TERMINOLOGY DEFINITION

Berm

A raised barrier constructed to separated compartments on the pan that are in

different stages of the mining process. The berm is also used as a driving

surface for vehicles moving materials to and from the pan.

Brine Water saturated with or containing large amounts of a salt, especially sodium

chloride.

Caustic Ability of a material or product to burn, corrode or dissolve due to the chemical

reactions taking place.

Compartmentation The separation of a pan into different compartments or sections by using

impermeable membranes (berms) that isolates one section from the other.

Crystallisation

A separation process whereby a solid (e.g. salt) is dissolved in a liquid (e.g.

water) to make a solution. The solvent is then allowed to evaporate, leaving

behind a saturated solution. If the saturated solution is allowed to cool, crystals

will start to grow.

Dewatering The process of natural, chemical, or mechanical removal of water from sludge,

thereby reducing it to a damp solid with the lowest level of moisture possible.

Endoreic

An endoreic system is one where the water does not have an outflow. Any rain

or precipitation that falls in an endoreic system remains there, leaving the

system solely by infiltration or evaporation, which contributes to the

concentration of salts.

Ephemeral River that flows only for a short time, sometimes only hours, after periods of high

rainfall.

Evaporation Process whereby a liquid is turned into a vapour when heat is applied.

Purification Process of removing impurities

Saponification Saponification refers to the reaction between a fat (i.e. tallow or Tallow/PKO

mixture) and a hydroxide with water which results in liquid soap and glycerol.

Stockpile Accumulated reserve of a material e.g. heaps of unprocessed salts.

Stripping Removal of surface covering (e.g. soil) to get to underlying layers.

Tallow Hard fat obtained from parts of the bodies of cattle and sheep.

Trench A long, narrow excavation in the ground



P a g e 1 2

APPENDICES

Appendix A: Curriculum Vitae: Eloise Carstens

Appendix B: Aquatic Fauna Assessment

Appendix C: Bird Assessment

Appendix D: Archaeological Assessment

Appendix E: Cultural Heritage

Appendix F: Full project description

Appendix G: Conflict resolution

Appendix H: Environmental Management Plan (EMP)



P a g e 1

1 INTRODUCTION

1 .1 BACKGROUND

The Otjivalunda Salt Pans are located north of the Etosha National Park,

approximately 100 km south of Oshakati (Figure 1). These ephemeral lakes contain a

solid layer of various sodium salts beneath the surface. The resource is estimated to

be 5.2 million tons in extent, with a mine life of more than 50 years. Several mining

licences have been issued over the area from 1922 to 1991.

Recognizing the potential of this resource, Gecko Namibia entered into a joint

venture with the Ondonga and Uukwambi Traditional Authorities, which are

responsible for the area, to establish Ondonga-Uukwambi Mining Enterprises (OUME).

In 2010, the Ministry of Mines and Energy approved the Exclusive Prospecting Licence

(EPL 4365) of OUME. Under this licence, OUME is authorized to do prospecting

activities to verify the quantity and quality of the resource.

Figure 1: Locality of the various components of the proposed Ojtivalunda salt mining and soap

production project.



P a g e 2

1 .2 RAT IONALE

Sodium sulphate and sodium carbonates are the core products used in the

production of soap. Currently Namibia imports most of its soap & detergent products

from South Africa while 60-70 % of the content of a number of soap products are

found in the pans. To add value to the raw materials, OUME anticipates transporting

the raw sodium minerals from the pans to Uukwangula, where a production plant will

be established and purification takes place. A variety of products will be produced

at the plant, including household soap products, washing powder, and purified

chemicals.

The local production of washing powder and export of purified sodium sulphate are

both new industries in Namibia that will be created by this venture. The project is

expected to have a positive impact on the local and national economy through

employment creation, tax revenue and FOREX savings. The mineral reserves will not

only be mined in Namibia, but will add further value to the economy through local

beneficiation. This venture is planned in a part of Namibia that is otherwise

undeveloped and heavily reliant on subsistence farming.

1 .3 APPOINTED ENVIRONMEN TAL ASSESSMENT PRACT IT IONER

(EAP)

In accordance with the Environmental Management Act (2007) of Namibia (and its

regulations (2012)), an Environmental Assessment is required for

“The construction of facilities for any process or activities which requires a

license, right or other form of authorisation, and the renewal of a license,

right or other form of authorisation, in terms of the Minerals (Prospecting and

Mining Act), 1992.”

“Resource extraction, manipulation, conservation and related activities.”

For this reason, Gecko Namibia appointed Enviro Dynamics as independent

environmental consultants to conduct the Environmental Assessment on their behalf.

Eloise Carstens of Enviro Dynamics is the EAP who conducted the assessment. Her

CV is attached as APPENDIX A.

1 .4 TERMS OF REFERENCE

The Terms of Reference for the proposed project is based on the requirements set out

by the Environmental Management Act (2007) and its Regulations (February 2012).



P a g e 3

The process covered the following steps, which are reported on in this document as

follows:

Provide a detailed description of the proposed activity;

Identify all legislation and guidelines that have reference to the proposed

project;

Identify existing environmental (both bio-physical and socio-economic)

conditions of the area in order to determine their environmental sensitivity;

Inform Interested and Affected Parties (I&APs) and relevant authorities of the

details of the proposed development and provide them with a reasonable

opportunity to participate during the process;

Consider the potential environmental and social (including biological) impacts

of the development, and assess the significance of the identified impacts.

Outline management and mitigation measures in an Environmental

Management Plan (EMP) to minimize and/or mitigate potentially negative

impacts.



P a g e 4

1 .5 WORK PLAN FOR STUDY

In order to meet the requirements of the Terms of Reference for the EIA, the study

consists of four phases as indicated in Figure 2 below. This document elaborates on

environmental parameters identified during the previous phase (Scoping Process) as

requiring additional investigation by specialists in the various fields.

Figure 2: Diagrammatic

summary of work plan.

Phase 1: Scoping process

Introductions with Client.

Site visit.

I&AP and community meetings.

Issue identification and risk assessment.

Final scope and ToR for further studies.

Scoping Report.

Phase 2: Detailed Investigations/ Environmental

Impact Assessment

Appointment of specialists.

Specialist investigations and report writing.

Environmental Impact Assessment Report.

Phase 3: Environmental Management Plan

Ascribe specific mitigation measures to issues

identified in previous phase.

Phase 4: Submission of final report

Submit Draft reports to Client and I&APs.

Receive and incorporate comments.

Submit final EIA report and EMP to DEA.

Wide Public and I&AP Consultation

Comments on draft documents and

feedback

WE ARE HERE

NOW



P a g e 5

1 .6 APPROACH TO THE STUD Y

Key elements of the EIA team’s approach to the study are provided below:

Phase 1 –Scoping Process:

The proposed project was evaluated in terms of its potential impact on the social

and ecological environments. The following issues were identified (Table 1).

Table 1: Potential issues identified during the first phase of the project.

POTENTIAL IMPACT/ISSUE IS FURTHER WORK NEEDED?

GENERAL ISSUES

Insufficient communication No, communication plan stipulating methods and

frequency of communication included as part of the EMP.

Job creation No, optimisation provided in EMP.

Migration patterns No, mitigation/optimisation provided in EMP.

Increased pressure on national water

supply

No, mitigation provided in EMP.

Increased pressure on national electricity

supply


Increased pressure on Oshakati waste

disposal site


Air pollution No, mitigation provided in EMP.

MINING

Change in landscape at the pan No, rehabilitation measures prescribed in the EMP.

Dust creation No, dust suppression methods is prescribed in the EMP.

Habitat destruction and consequent loss

of wetland bird species.

Yes, assessment of sensitive bird species and the habitats

they occupy at the pans.

Habitat destruction and consequent loss

of endemic aquatic crustaceans

Yes, assessment of sensitive crustacean species and the

habitats they occupy at the pans.

Disturbance and poaching of wildlife in

the Etosha National Park or in the vicinity. No, mitigation measures are prescribed in the EMP.



P a g e 6


Destruction and/or damage to

vegetation

No, vegetation clearing measures are prescribed in the

EMP.

Potential groundwater pollution No, mitigation and monitoring measures are prescribed in

the EMP.

Loss of cultural salt harvesting rituals. Yes, assessment to ensure that the culture is not lost, was

required.

Loss of or damage to archaeologically

significant sites

Yes, assessment of potentially sensitive areas in the

proximity of the mining activities.

Stock theft No, mitigation measures prescribed in the EMP.

Impact on future planned tourism

activities in the conservancy.

Yes, assessment of potentially sensitive areas in the

proximity of the mining activities.

Health and safety of workers No, mitigation measures prescribed in the EMP.

TRANSPORT ROUTE

Increased pressure on local and national

road infrastructure No, mitigation measures prescribed in the EMP.

Track proliferation (road between mine

site and Onkani)

No, mitigation measures to limit track proliferation

prescribed in the EMP.

Destruction and/or damage to

vegetation.

No, vegetation clearing measures are prescribed in the

EMP.

Disturbance of wildlife and road kills. No, mitigation measures prescribed in the EMP.

Safety hazard of cattle sleeping or

walking in the road; road kills. No, mitigation measures prescribed in the EMP.

Dust and noise impact No, mitigation measures prescribed in the EMP.

Safety hazard for road users, pedestrians

and school children walking on the road. No, mitigation measures prescribed in the EMP.

PRODUCTION PLANT

Odours No. Odours may be controlled by scrubbing further

mitigation measures are prescribed in the EMP.

Creation of dust No. Dust emissions can be controlled by dry filters such as

filter bags. Further mitigation measures prescribed in EMP.



P a g e 7


Visual impact No, mitigation measures prescribed in the EMP.

Surface and groundwater pollution No. Mitigation measures to be specified in the EMP.

The identified issues were assessed based on the availability of information to address

or mitigate them:

Impacts for which sufficient information was available to make an assessment

were carried over to the Environmental Management Plan (EMP) at the end

of Phase 1.

Impacts of potentially high significance, but for which insufficient information

was available to complete the assessment, or for which no readily available

mitigation measures are known, were further assessed in Phase 2.

Figure 3 below shows how this process was applied.

Phase 2 – Detailed investigations & Environmental Impact Assessment:

Issues for which sufficient information was available, were concluded during scoping

and are not included here. In order to address the issues for which insufficient

information was available, specialists were appointed to undertake:

An aquatic fauna assessment (APPENDIX B)

A bird assessment (APPENDIX C)

An archaeological assessment (APPENDIX D)

A cultural heritage assessment (APPENDIX E)

A tourism assessment (internal investigation done by Enviro Dynamics)

The specialists were required to conduct site investigations in the study area and

identify key features of concern (the methodologies used are described in the

various assessment reports). These were then subjected to an environmental impact

assessment process.

Considering the information contained in Table 1, it was concluded that the main

issues (i.e. the issues requiring further investigation) are restricted to the mining phase

of the project. This is most likely due to the invasive and permanent nature of the

impacts on the receiving environment specific to the mining site.



P a g e 8

As such, the specialist investigations concentrated on potential impacts associated

with the mining activities. Their research findings are the focus of the rest of this

report. Therefore the rest of the report focuses on the pans.

Phase 3 – EMP:

Based on the management actions recommended by the consultant as well as the

mitigation measures prescribed by the specialists a management plan has been

compiled to minimize or avoid the potential impacts.

Issues identified during the scoping

phase.

Issues that require further

investigation or information to make

an assessment

Issues for which sufficient information

was available to make an

assessment

· Aquatic Fauna—John Irish

· Birds– Mike & Ann Scott

· Archaeology– John Kinahan

· Cultural Salt harvesting — Carla Saayman

· Tourism —Enviro Dynamics

Specialist investigations

Recommendations

ENVIRONMENTAL

MANAGEMENT PLAN (EMP)

EIA Report

PHASE 2:

EIA STUDY

PHASE 1:

SCOPING STUDY

Figure 3: Assessment of issues based on the availability of information to address or mitigate it.



P a g e 9

Phase 4 - Reporting:

The final step in the EIA process is to submit the draft reports to the client and I&APs

and to incorporate the comments into the final documents before submitting them

to the DEA in application for environmental clearance.

1 .7 REPORT LAYOUT

The layout of the report has been structured as follows:

Section 1: Introduction – the present section, providing the background to

the project, the Terms of Reference and the methodology followed for this

EIA.

Section 2: Assessment of alternatives – considers the alternatives available

on the project, including the no-go alternative.

Section 3: Project Description: Salt mining – Technical details of the mining

aspect of the project.

Section 4: Policy and legal framework – all relevant requirements from

applicable laws, regulations, and international conventions.

Section 5: Description of the Receiving Environment – a summary of the

biophysical and social environment that will either affect or be potentially

affected by the project activities.

Section 6: Public Consultation and Disclosure – a summary of the

consultation process undertaken with stakeholders and I&APs, and the

issues identified during this process.

Section 7: Assessment of impacts – an assessment of the bio-physical and

social impacts expected during construction and operation of the project.

Section 8: Conclusions and Recommendations

In the following Section the alternatives associated with the project are assessed.



P a g e 1 0

2 ASSESSMENT OF ALTERN ATIVES

2.1.1 THE NO-GO ALTERNATIVE

The no-go alternative assumes that the activity does not go ahead, implying a

continuation of the current situation or the status quo at the pans.

In choosing this alternative, the opportunity of locally produced soap products will

be lost and the resources currently available at the Otjivalunda pans will not be

utilised to its potential. In addition, Namibia will continue importing soap products

from South Africa. The production of pure sodium sulphate is another product in high

demand at manufacturing industries. At present, this product is imported from China

and Spain via South Africa.The local and national economy of Namibia also stands

to lose the benefit of employment creation, tax revenue and FOREX savings if the

alternative is selected. Furthermore, small business development opportunities (e.g.

benefits to cuca shops in the area) will be lost to local communities as well as the

benefits of becoming part of a possible infrastructure network (i.e. road

infrastructure) that this project will bring.

The no-go option is not considered as the preferred alternative in the proposal. It

does however represent the status quo of the area as described in the scoping

report and summarized in Section 5. This forms the basis against which the proposed

project has been compared in the Impact Assessment Phase (Section 7). Should the

proposed project not be granted environmental clearance, the no-go alternative

will prevail and the environment will remain as described in Section 5.

2.1.2 ALTERNATIVE MINING SITE LOCATIONS

In considering alternative locations for salt mining, two factors play a role: 1) the

deposit should be of a viable quantity and good quality salt and 2) the site needs to

be located within the EPL 4365 boundaries.

The Ngandjela pans are located about 40km from the Otjivalunda pans and are the

only other salt bearing pans in the area. According to NACSO (2009) the Ngandjela

Pans are the best known pans for the harvesting of high quality salt. However, these

are located outside the boundaries of EPL 4365. This means that OUME cannot

obtain access to them andtherefore they are eliminated as a potential alternative.

Alternatives in terms of mining schedules at the two Otjivalunda pans are however

still available.

Section 3 below provides the technical details of the project which form the basis on

which this assessment report has been written.



P a g e 1 1

3 PROJECT DESCRIPTION: SALT MINING

Salt mining will take place at the Otjivalunda East and West pans (Figure 4).

Figure 4: Location of the proposed mining sites.



P a g e 1 2

3 .1 OVERVIEW OF THE PROJ ECT

The activities associated with the proposed project include:

extraction of salt (halite, trona, burkeite and thenardite) from the Otjivalunda salt

pans,

the transport of raw materials to a production facility approximately 10 km west of

Oshakati, and

the production of soap and detergents at the production facility, and

the purification of sodium sulphate & sodium carbonates to chemical grade

Only a description of the resource extraction process is described in this report since

it was the focus of the specialist studies. However, a full project description is

provided in APPENDIX F.

3 .2 MINING: THE RESOURCE

The aim of this project is to mine the different sodium salts that occur at the

Otjivalunda pans (See Table 2 below):

Table 2: Characteristics of the salts occurring at the Otjivalunda Pans.

COMMON

NAME MOLECULAR FORMULA DESCRIPTION PICTURE

Halite NaCl

(Sodium chlorite)

Soluble in water.

Salty taste.

Suitable for human

consumption.

Used as table salt.

http://www.google.com.na/url?sa=i&source=imgres&cd=&cad=rja&docid=7gOO4VKb3dHuqM&tbnid=xPerEGnFXepayM:&ved=0CAwQjRwwAA&url=http://www.mydetoxfootbath.com/halite-ezp-30.html&ei=RJMsUfGFGYKstAb304BQ&psig=AFQjCNEfnIGj2nkk74qq7x4Q5mKymMYEcw&ust=1361962180440470



P a g e 1 3

COMMON

NAME MOLECULAR FORMULA DESCRIPTION PICTURE

Trona

(Also known as

soda ash)

Na3(CO3)(HCO3)•2H2O

(Sodium carbonate)

Used to control the

pH of products.

Used as a softening

agent in detergents.

Burkeite Na6(CO3)(SO4)2

(Sodium carbonate-

sulfate)

Completely soluble

in cold water.

Thenardite Na2SO4

(Sodium sulphate)

Used as a filler in

powdered laundry

detergents.

Used as a fining

agent in the glass

industry.

Used in textile

manufacturing.

The composition and thickness of the underground layer of solid salts (see Table 2)

differs between the Otjivalunda eastern and western pans (Table 3).

Table 3: Composition and deposits of sodium salts at the two different pans.

DEPOSIT OTJIVALUNDA EAST PAN OTJIVALUNDA WEST PAN

HALITE DEPOSIT 440 ha of the surface of the pan 280 ha of the surface of the pan.

SUBSURFACE COMPOSITION Trona, burkeite, thenardite Primarily thenardite

SUBSURFACE DEPOSIT ±3.5 million tons ±1.7 million tons

http://www.google.com.na/url?sa=i&source=imgres&cd=&cad=rja&docid=MgXlG7G_xPmjWM&tbnid=wx-ajVANs0i71M:&ved=0CAwQjRwwADhI&url=http://de.wikipedia.org/wiki/Trona_(Mineral)&ei=IMIsUcedHcHStAa4uYCQDQ&psig=AFQjCNF_6VfFYfaRF45vHVAHzujjGt49AQ&ust=1361974176591868



P a g e 1 4

During the wet season, a portion of the salts dissolves in the

water and is re-deposited during the dry season. The order

of re-deposition depends on the solubility of the salts.

The Minerals Policy of Namibia (2003) states that salt is a

renewable resource. The renewal is a timeous process and it

is estimated that, after mining activities have seized, it will

take 100s of years before the pan is back to its natural state.

3 .3 MINING ACTIVI T IES

The mining activities at the pan can only be conducted during the dry season. Work

could extend over a period of approximately 8 months, typically between April and

December (depending on the rainfall).

Sodium chlorite mining will predominantly take place at the Otjivalunda West pan.

The process can be summarized as follows: 1) compartmentation, 2) pumping of

brine, 3) evaporation & crystallisation of salt and 4) harvesting of salt.

Mining of the underground layers of salt encompasses four major processes, namely

1) compartmentation, 2) stripping, 3) dewatering and 4) excavation/mining of the

salt layer.

During the first phase (i.e. compartmentation) the pan is divided into different

operational sections or compartments (Figure 5). For separating one section from

another, berm structures are created.

The calcrete required for the construction of the berms will be excavated from the

outcrops on the sides of the pans using excavators. Where the material is too hard

for free-digging, blasting practices will be employed.



P a g e 1 5

Figure 5: Berm compartments of the Otjivalunda East and West Pan and the position of the campsite and workshop area.



P a g e 1 6

Berms are created by back-tipping the excavated calcrete material from the edge

to the middle of the pan. The material is then levelled and compacted to create a

driving surface for the earthmoving/mining equipment. The berm structures are

planned at 1 m above the surface and 5 m wide (on the top) to allow for the

movement of vehicles (Figure 6).

A small trench of approximately 600 mm is then excavated at the centre of the berm

through to the bottom of the underground salt ore body and 300 mm into the

bottom mud layer. The trench is lined with 1 mm PVC plastic liner that hydrologically

isolates the two sides of the trench from one another, inhibiting the flow of brine from

one compartment to the other. The trench is then backfilled with the originally

excavated material (Figure 7).

Figure 6: Berms allow for the movement of vehicles to the various sections on

the pan.

Figure 7: Illustration of the berm structure with trench and plastic liner.



P a g e 1 7

Since the hardness and the thickness of the ore deposit vary significantly, different

mining and purification processes are required for the sodium chlorite and sodium

sulphate/carbonate salts. Details of the envisaged mining process are described

below.

3.3.1 MINING PROCESS: HALITE CRYSTALLIZATION AND HARVESTING

Halite forms the top-most crust of the pan (See Figure 7 above). To produce salt of

sellable quality, brine (mixture of chlorites, carbonates and sulphates) needs to be

crystalized in a controlled fashion. This will be done by pumping surface brine with

diesel-driven pumps and lay-flat hosepipes from the Otjivalunda East pan to the

Western pan into pre-constructed shallow evaporation compartments.

The brine will be channelled through an initial stage of mud settling and pre-

evaporation. From here, it will be directed to flow through the second evaporation

stage and finally into the

crystalliser pond. Flow

between the various stages will

be controlled by sluice gates.

During the process, through

solar evaporation, the halite

will be concentrated to the

point where it crystalizes on the

floor of the crystallization pan

(Figure 8).

With time, the concentration of

the other ions (carbonates and

sulphates) in the solution will

increase to near saturation.

Before other sodium salts can start to crystallize, the remaining brine needs to be

flushed from the crystalliser pond back into the extent of the Otjivalunda West pan.

In takes approximately six months for the layer of crystallized sodium chloride to

reach a thickness sufficient to support the movement of heavy equipment, after

which the salt harvester will be deployed. It has a capacity of 250 tons per hour and

can cut a hard, re-crystallised salt layer down to a depth of up to 30 cm. The milled

salt is then transferred directly from the harvester to an Articulated Dump Truck (ADT),

Figure 8: The crystallization of salt on the surface of the

pan is a natural process. This salt contains a

mixture of sodium chlorite, sulphate and

carbonates. It is not a pure form of salt.

Monthly production requirement: 3 750 tons

Annual production target: 30 000 tons



P a g e 1 8

which would take the salt to the side of the crystallization pond to a stockpile for

drying.

3.3.2 MINING PROCESS: TRONA, BURKEITE AND THENARDITE

At the Otjivalunda East Pan, the sub-surface ore horizon consists of a variable mixture

of sodium sulphate, sodium carbonate and sodium bicarbonate with impurities of

sodium chlorite and clay. Each of the various salts has concentrated in certain

sections of the eastern pan:

Western section – trona

Middle and northern section – burkeite

Eastern and south-eastern section - thenardite

Surface brine from the eastern pan will be pumped to the western pan. Hence

drying is facilitated on the eastern pan, as certain compartments are compared for

mining.

The top mud layer of approximately 300 mm is liquefied with brine and washed off by

using a high-pressure nozzle spray system. The

mud water is then pumped from the

compartment to a settlement pond where mud

is allowed to settle and water can flow to a

sump. The settled mud is dried slightly until it

can be handled. It is then worked back into

the mined-out areas on the pan using

excavators and ADTs and levelled using a

bulldozer.

Once the exposed surface of the ore body has

dried out, any remaining mud is cleared off by

using a Waterking floating dredger (Figure 9),

excavator and bulldozer where possible.

Monthly production requirement: Maximum annual tonnages:

Trona 3 750 tons 30 000 tons

Burkeite 625 tons 5 000 tons

Thenardite 15 000 tons 120 000 tons

Figure 9: Waterking floating dredger



P a g e 1 9

In areas where the ore layer is too thin to support the equipment, hand labour will be

used. The cut and fill activities will be undertaken throughout the lifespan of the

project to ensure continuous rehabilitation of the mined-out areas.

Various methods are available to facilitate ore mining (Table 4). The method used

greatly depends on the hardness and thickness of the resource.

Table 4: Methods used to mine trona, burkeite and thenardite ore.

METHOD DESCRIPTION ORE THICKNESS

Free digging Use of an excavator or Waterking to lift

the ore body, breaking slabs off.

Thin to medium ore thickness

Hydraulic hammer Excavator fitted with a hydraulic

hammer to peck the ore until pieces

break off.

Thin to medium ore thickness

Blasting Failing the other methods, ore can be

drilled and blasted. Thick and dense ore

The mined salt ore will be stockpiled at strategic points along the sides of the pan

and close to the berm network on areas where vehicles can drive. ADTs will haul the

material to the processing slab, where it will be crushed, washed and deslimed using

a scrubber.

The final product is then stockpiled to be transported to the production facility.

3 .4 S ITE ESTABL ISHMENT A ND INFRASTRUCTURE REQUI REMENTS

3.4.1 PROPOSED SITE LAYOUT AND ASSOCIATED SITE INFRASTRUCTURE

Figure 10 below represents the proposed layout of the camp and workshop area at

the Otjivalunda pans.



P a g e 2 0

Figure 10: Proposed layout of the campsite and workshop at the Otjivalunda pans.



P a g e 2 1

The campsite facility and workshop area will consist of the components listed in

Table 5 below. In addition, Gecko also intends to construct a magazine where

explosive materials can safely be stored.

Table 5: Description of the infrastructure required at the campsite, workshop and explosives magazine.

3.4.2 SERVICE INFRASTRUCTURE REQUIREMENTS

Table 6 below indicates the service or infrastructure requirements of the envisaged

mining activities:

INFRASTRUCTURE DESCRIPTION

Camp site facility

2 x park homes on concrete slab

1 x kitchen

1 x diesel powered 30 KVA generator

6 x sleeping tents on concrete slab

1 x ablution facility with toilets and showers

Tank stand for 2 x 5000ℓ tanks

Plastic septic tank with French drain

Workshop facility

Concrete slab with workshop structure

Wash bay facility with oil trap

Storage shipping containers for spare parts, tyres, oils and lubricants

on concrete plinths

Oil disposal container with concrete floor and bund wall

Bunded fuel storage facility

Explosives magazine

2 x 200 case steel high explosive magazines

1 x 20 case steel accessory magazine

Material for safety fencing: 300 m of 2.4 m high fence with razor wire

on top and 1 x 4 m by 2.4 m high lockable gate with razor wire at the

top.

1 x earthed, single pole lightning projector



P a g e 2 2

Table 6: Description of the service/infrastructure requirements at the Otjivalunda pans mining site.

SERVICES REQUIREMENTS DESCRIPTION SERVICE POINT

RESOURCES

Water 10 000ℓ/week Water only for human consumption.

Any water needed for the mining

activities will be obtained from the

pan as brine.

Water from Oshakati

transported with a water truck

to the site.

Electricity Unknown Electricity will be provided by

means of diesel generators for the

general operation of the campsite.

Diesel generators.

Human

resources

40 people During the initial stages of site

establishment. Skilled and unskilled.

Accommodated on site.

N/A

25 people During full-scale mining. Skilled and

semi skilled. Accommodation on

site.

N/A

INFRASTRUCTURE

Waste

disposal

General waste

disposal.

General waste disposal.

Disposal of hazardous waste.

All waste products will be

transported to Oshakati for

disposal. West Coast Salvage

has a depot in Oshakati for

hazardous waste.

Wastewater General

wastewater

disposal.

General wastewater from e.g.

bathrooms and kitchen. Run-off

water from washing the trucks.

Septic tank with a French

drain. Overflow will be taken

to a reed bed.

Road

access

Access between

the two pans

and the main

transport route

Use existing tracks as far as possible.

New routes might be needed.

N/A

Based on the description of the proposed project components, it seems inevitable

that management principles are not only required to ensure the environmental

sustainability of the project, but are also required under various national laws. These

laws and their requirements are discussed in the section that follows.



P a g e 2 3

4 POLICY AND LEGAL FRAMEWORK

The environmental assessment procedure prescribes the review of applicable and relevant legislation, which serves to inform the

proponent of the legal requirements and permit applications to be fulfilled before operation of the proposed project commences.

The EIA team has studied the national policy and legislative framework as well as international conventions governing the activities

of this project. These applicable policies, laws and conventions, and their implications for this project are summarised below:

LEGISLATION/GUIDELINE/POLICY/AGREEMENT RELEVANT PROVISIONS APPLICATION TO PROJECT

Namibian Constitution First Amendment Act, 1998 Article 19: Every person shall be entitled to

enjoy, practise, profess, maintain and promote

any culture, language, tradition or religion

subject ….

Article 102: A Council of Traditional Leaders

shall be established to advise the President on

the control and utilization of communal land

and on all such other matters as may be

referred to by the President for advice.

The government ‘controls’ communal lands but the

people who live there have common law or natural

law property rights to the land that the government

must protect. Therefore, the community retains the

right to be consulted during this project.

EIA LEGISLATION

Environmental Management Act (7 of 2007) Requires for adequate public participation

during the environmental assessment process

for interested and affected parties to voice

their opinions about a project (Section 2(b-c)).

Requires the protection of Namibia’s cultural

and natural heritage, including its biological

diversity for the benefit of present and future

Follow the EIA process described in the act.

Conduct public participation as part of the EIA

process as described in the act.

An Environmental Clearance certificate is required

before the project can start.



P a g e 2 4


generations (Section 2(d)).

Requires that projects with significant

environmental impact are subject to an

environmental assessment process (Section 27).

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

2012)

Listed activities requiring an Environmental

Clearance Certificate (GN No 29 Annexure):

Section 2.1: “The import, processing, use and

recycling, temporary storage, transit and

export of waste.”

Section 3.1: “The construction of facilities for

any process or activities which requires a

license, right or other form of authorization, and

the renewal of a license, right or other form of

authorization, in terms of the Minerals

(Prospecting and Mining Act), 1992.”

Section 3.3: “Resource extraction,

manipulation, conservation and related

activities.”

Section 8.1: “The abstraction of ground or

surface water for industrial or commercial

purposes.”

Section 8.6: “Construction of industrial and

domestic wastewater treatment plants and

Conduct an EIA that covers all the components of

the project, listed in the regulations.



P a g e 2 5


related pipeline systems.”

Section 9.1: “The manufacturing, storage,

handling or processing of a hazardous

substance defined in the Hazardous

Substances Ordinance, 1974.”

REGIONAL AND TRADITIONAL AUTHORITIES ACT

Regional Councils Act No 22 of 1992 Section 28(1): The Regional Councils have the

power to undertake the planning of the

development of the region with due consideration

to the physical, social and economic

characteristics of such a region.

The Regional Council of the applicable regions,

namely the Oshana and the Omusati Regions, need

to be consulted during the public consultation

process.

Traditional Authorities Act No 25 of 2000 Section 3(1): ….The functions of a traditional

authority, in relation to the traditional community

which it leads, shall be to promote peace and

welfare amongst the members of that

community….to -

(c) uphold, promote, protect and preserve the

culture, language, tradition and traditional values

of that traditional community,

(d) preserve and maintain the cultural sites, works

of art and literary works of that traditional

community.

The customs and traditions of the local

communities need to be considered and

respected when implementing the project.

The traditional authority has the right to lease

land to any person or company provided that

the community is consulted in this regard.

The traditional authority has the right to establish

Trust Funds to manage funds on behalf of the

members of that traditional community,

provided that consent is obtained from the

community.



P a g e 2 6


Section 18(1): A traditional Authority may with the

consent of the member of its traditional

community acquire, purchase, lease, sell, or

otherwise hold or dispose of movable or

immovable property in trust for that traditional

community and shall have such rights in respect of

the acquisition and disposal of such property……

Section 18(3): A traditional authority may with the

consent of the members of its traditional

community establish a Community Trust Fund, to

be held in trust for the members of that traditional

community and towards which such members

may contribute for the purposes of –

(a) financing projects in that community which

promote and uplift the culture, preserve cultural

sites, works of art and literary works of that

community,

(b) meeting the administrative costs of running the

office of the traditional authority;

(c) meeting the costs of performing any of the

functions and duties of a traditional authority

under this Act;

(d) meeting any other costs that the traditional



P a g e 2 7


community may agree upon.

Section 18(4): A traditional authority shall, with the

consent of the members of its traditional

community, determine the manner in which and

the persons by whom the contribution

contemplated in subsection (3) shall be made, as

well as the amount of that contribution.

MINING LEGISLATION

Minerals Act No 33 of 1992 Section 48 (3): In order to enable the Minister to

consider any application referred to in section 47

the Minister may (b) require the person concerned

by notice in writing to (i) carry out or cause to be

carried out such environmental impact studies as

may be specified in the notice.

Section 54(2): If a reconnaissance area,

prospecting area, retention area or mining area is

abandoned…. The holder of the mineral licence to

which such area relates shall – (a) demolish any

accessory works erected or constructed by such

person in such area, except in so far as the owner

of the land retains such accessory, works on such

conditions as may mutually be agreed upon

Currently OUME is in possession of an Exclusive

Prospecting Licence (EPL 4365). This licence allows

them to do any prospecting activities on the

defined area, but not to mine the resource. To mine

the resources, OUME requires a Mining Licence. The

legislation requires that an EIA study is undertaken

prior to the approval of the Minister of the minerals

licence application.

Once mining is completed, the licence holder has

an obligation under the minerals licence to ensure

the rehabilitation of the mining site and accessory

works area.



P a g e 2 8


between such owner and person, and remove

from such land all debris and any other object

brought onto such land; (b) take all such steps as

may be necessary to remedy to the reasonable

satisfaction of the Minister any damage caused by

any prospecting operations and mining operations

carried on by such holder to the surface of, and

the environment on, the land in the area in

question.

ENVIRONMENTAL LEGISLATION

Forestry Act No 27 of 2004 Provision for the protection of various plant species Some species that occur in the area are protected

under the Forestry Act and a permit is therefore

required to remove the species (e.g. Colospermum

mopane).

The Nature Conservation Ordinance (1975) as

amended through the Nature Conservation

Amendment Act of 1996.

Chapter 11: Game Parks, Nature Reserves,

Conservancies and Wildlife Councils.

The legislation enables legally constituted

conservancies to:

Use and benefit from wildlife on communal

land in accordance with the Conservancy

Policy;

Propose recommendation for quotas for

The project is located in the Iipumbu ya Tshilongo

Conservancy and borders the Sheya Shuushona

Conservancy. Conservancies on communal land

are areas in which rural communities gain exclusive

rights to use, manage and benefit from the

consumptive and non-consumptive use of wildlife

within defined boundaries.

Conservancies must have a properly drawn up



P a g e 2 9


wildlife utilization and, in consultation with the

MET, decide on the form of utilization;

Enter into agreements with private companies

and establish tourism facilities within the

conservancy boundaries;

Have ownership over huntable game on

conservancies;

Apply for permits to use protected and

specially protected game;

Conduct trophy hunting and to buy and sell

game.

constitution and a management plan that spells out

the goals and objectives of the conservancy as well

as the management and utilization actions.

The Iipumbu ya Tshilongo Conservancy was

registered in May 2012 and thus do not have a

management plan yet. Conservancy members

retain the specific rights to wildlife. Outsiders’

specific right to wildlife in the conservancy is

however still determined by the conservancy

members.

National Heritage Act No 27 of 2004 To provide for the protection and conservation

of places and objects of heritage significance

and the registration of such places and objects

Establishes a body to govern matters relating to

places and objects of heritage significance –

National Heritage Council

Establishes a National Heritage Register

All heritage resources are to be identified and either

protected or removed/mitigated with a permit from

the National Monuments Council, before any

development may take place.

Water Resources Management Act, No 24 of 2004 Section 32(1) Unless this Act provides otherwise, a

person may not abstract or use water, except in

accordance with a licence issues under this Act.

(2) in this Part, “abstract water”, includes the

A combined licence for the abstraction and use of

brine water and the discharge of effluent from the

production plant is required (see Section 38 of the

Act).



P a g e 3 0


abstraction of brackish or marine water for any

purpose.

Section 56: Except as otherwise provided in this

Part, a person may not- (a) discharge any effluent

directly or indirectly to any water resource on or

under the ground, including through a borehole; or

(b) construct any effluent treatment facility or

disposal site above any aquifer, unless the

discharge of effluent or construction of the

treatment facility or disposal site is in compliance

with a permit…..

Convention on Wetlands of International

Importance (Ramsar) 1971

Etosha National Park is a proclaimed Ramsar site

receiving special protection status in terms of the

Convention.

Applies to the protection of habitat and

conservation of birds occurring in wetland areas.

Nature Conservation Ordinance of 1975, and the

Parks and Wildlife Bill

The Bill (currently a draft) will replace the Nature

Conservation Ordinance of 1975. The list of

Specially Protected Birds according to this Bill is

based on the Namibian Red Data Book, and the

Red Data categories.

The Ordinance and Bill apply to the conservation of

terrestrial birds in Namibia.

National Policy on Climate Change in Namibia, The aim of the policy is to promote the reduction

of harmful pollutants into the atmosphere.

“Namibia, like all other SADC members, has signed

The greenhouse gasses that will be emitted from the

production plant are carbon dioxide (CO2) and

water vapour. Although permits are not required for



P a g e 3 1


and ratified both the UNFCCC and the Kyoto

Protocol. As a non-Annex I Party to the Protocol,

Namibia is not bound by specific targets for GHG

emissions, however a number of global initiatives

are being implemented, through donor and other

support, to assist in the operationalization of the

UNFCCC.”

this, the aim of the policy is to decrease greenhouse

Gases (GHG) in order to reduce the potential

effects of global warming. Therefore, sustainable

low carbon development should be promoted

during this project by using the best available

technology and innovations.

World Bank OP and BP 4.11 of 2006 The OP and BP 4.11 guidelines in respect of

“Physical Cultural Resources” relate to project

screening, baseline surveys and mitigation

measures.

No regulations, or official procedures concerning

impact assessments have been formulated for the

implementation of the National Heritage Act. These

sections of the World Bank plans provide guidelines

as to how assessments should be undertaken.

International Convention of Biological Diversity,

1992

Namibia is a signatory to the convention, a legally

binding instrument for the global conservation and

sustainable use of biological diversity.

The agreement pertains to the conservation of

wetlands and their bird species.

HAZARDOUS MATERIALS LEGISLATION

Petroleum Products and Energy Act, No 13 of 1990

Petroleum Products and Energy Amendment Act,

No 29 of 1994

Storage of petroleum products Proponent needs to apply at MME for a consumer

installation certificate.



P a g e 3 2


Explosives Act No 26 of 1956 Provides for the control of manufacturing, storage,

sell, transport, importation, exportation and use of

explosives.

5(1) “No person shall keep, store or be in possession

of any unauthorized explosive unless it has been

manufactured as provided by sub-section (1) of

section three and is kept, stored or possessed in

such a manner and in such quantities as have

been approved in writing by an inspector.”

(9)(1)” No person shall use any blasting material-

(a) unless he is in possession of a permit issued by

or under the authority of an inspector; or

(b) unless he is, while using such blasting material,

under the immediate and constant supervision of a

person who is in possession of such a permit.”

A licenced inspector is required to visit the site to

assess its safety and to issue a permit.

LEGISLATION RELATING TO LAND ISSUES

Revised Compensation Policy and Guidelines for

communal land areas in Namibia, 2008

The policy spells out the compensation amounts

that must be paid out to communal landholders

should they be required to relocate their fields,

homesteads and other agricultural infrastructure. It

further rules that compensation must be paid to

land holders for the loss of fruit trees and a detailed

This policy is of particular relevance when

determining the transport route from the Otjivalunda

pans to the production plant at Uukwangula.

Should any homesteads or agricultural infrastructure

(including fences) be impacted by the project,

compensation will need to be paid out.



P a g e 3 3


basis for the calculation of compensation is

provided. It also provides for a disturbance

allowance.

Joint Venture Agreement between Gecko Caustic

and Ondonga-Uukwambi Mining Enterprises

(OUME)

The Ondonga-Uukwambi Mining enterprises

(OUME) (Pty) Ltd and Gecko Namibia (Gecko

Chemical Holdings (Proprietary) Limited hold

shares in the company Gecko Caustic (Pty)

Limited.

The issued share capital is held as follows:

OUME:

25% Ondonga Community Trust

25% Uukwambi Community Trust

50% Gecko

Gecko Caustic:

5% Ondonga and Uukwambi Community Trust

Funds

95% Gecko Namibia

The holder of the mineral rights over the

Otjivalunda area is Ondonga-Uukwambi

Mining enterprises (OUME) (Pty) Ltd.

OUME is a private company with limited liability and

5% free carry non-dilution shareholding. OUME is the

owner of the mineral rights. They do not have

ownership of the land and therefore are still subject

to any legislation relating to the land.



P a g e 3 4

These obligations will be considered during the EIA process, and the relevant permit

requirements will be spelt out in the EMP. The next section outlines the key

characteristics of the receiving environment, so that potential sensitivities may be

identified for further study.

.



P a g e 3 5

5 DESCRIPTION OF THE R ECEIVING ENVIRONMENT

5 .1 INTRODUCT ION

The legislation highlighted in the previous section emphasizes features of the

biophysical and social environment that may need specific protection during project

implementation. The collection of information on the receiving environments,

coupled with the issues identified during the consultation process ensure that enough

is known about the study area to make informed decisions with regard to planning,

construction and operation of the proposed project.

5 .2 OVERVIEW OF THE PROJ ECT ENVIRONMENT

5.2.1 ENVIRONMENTAL FEATURES AT THE MINE

During the scoping phase a full description of the receiving environment was

provided. These findings are summarized in

Table 7 below as an overview of the on-site conditions at the mine.

Table 7: Summary of the on-site conditions at the mining site.

FEATURE MINING SITE

BIOPHYSICAL ENVIRONMENT



P a g e 3 6

FEATURE MINING SITE

LANDSCAPE, GEOLOGY & SOIL Pan site is surrounded by higher ground, presumably palaeo dunes

(Figure 11). Soils on the pan are silt and clay whilst the surrounding

area has more sandy soils.

FAUNA Possibly sensitive aquatic crustaceans (Subsection 5.3) and wetland

bird species (Subsection 5.4).

FLORA None on the pan but some plant species do occur on higher

ground, primarily mopane shrubs.

SURFACE AND GROUNDWATER Locals dig wells to create shallow waterholes for their cattle.

SOCIO-ECONOMIC ENVIRONMENT

CATTLE POSTS AND GRAZING

LAND

A number of cattle posts and drinking holes are found in this area.

The land is used for grazing.

HOMESTEADS, SETTLEMENTS AND

VILLAGES

None

CROP FIELDS None

ETOSHA NATIONAL PARK The site is situated in close proximity to the northern fence of the

park.

ARCHAEOLOGICAL SITES Potential fossil remains (Subsection 5.5).

SALT HARVESTING Young men are sent to harvest salt, which is culturally significant

(Subsection 5.6).

CONSERVANCIES It is located in the Iipumbu ya Tshilongo conservancy and could

affect the tourism potential of the conservancy (Subsection 5.7)

Figure 11: Landscape at the Otjivalunda East

pan.



P a g e 3 7

FEATURE MINING SITE

SCHOOLS AND CHURCHES None

The rest of this section focuses on issues highlighted in bold. The other sensitivities

were concluded during scoping and are not included here.



P a g e 3 8

5.2.2 HABITATS AT THE MINING SITE

The following habitats were distinguished at the mining site –

Wetlands: After the rains, the salt and clay pans in the area fill with water

transforming them into wetlands with water of varying depths. The time it takes

before the pans are dry again, varies depending on local evaporation rates and

the depth of the water. The process usually takes several months.

Salt flats: As the wetlands dry up and start to recede the high salt content causes

crystallization, and salt flats with varying depths of salts start to form. This habitat is

corrosive in nature and only

specially adapted organisms can

survive the harsh conditions.

Pan edge: The interface between

the wetlands and the shore on the

pan edge is a muddy habitat that

shrinks as the water levels recede

(Figure 13).

Figure 13: The “pan edge” habitat (Scott, 2013).

E D C A/B

Figure 12: Habitats associated with the Otjivalunda west salt pan) (Scott,

2013)-

A/B – Wetlands (none present at during the field visit) / Salt flats

C – Pan edge/fluctuating water line

D – Flat grasslands with drainage lines

E – Sparse mopane shrublands



P a g e 3 9

Figure 14: Grasslands habitat with drainage line on

the edge of the mining area.

The habitat provides a natural corridor that is used by game (springbok, etc),

cattle and vehicles.

Grasslands with drainage lines: Flat

grasslands occur around the pans.

Small gullies drain from these areas

into the main pans, some showing

signs of trampling by cattle

(Figure 14).

Mopane shrublands: Woody species

comprise the sparse low mopane

shrubland habitat further afield from

the pans.

During the scoping study, the following sensitive components were identified as

requiring further investigation to determine the potential impact of the proposed

project:

Endemic aquatic crustaceans

Wetland bird species

Cultural salt harvesting rituals

Archaeologically significant sites

These components are discussed in the subsequent sections and are based on the

specialist investigations undertaken in April 2013. Their findings also form part of these

sections, specifying the sensitive habitats at the mining site where human

disturbance should be avoided or managed. Proposed mitigation measures

emanating from the assessment of the impacts are discussed in Section 7.



P a g e 4 0

5 .3 AQUAT IC FAUNA

5.3.1 HABITAT PREFERENCES

Based on the habitats identified in the previous section, the aquatic fauna

associated with the wetlands/salt flats habitats could be affected by the proposed

development. The Otjivalunda salt pans are categorized as ephemeral seasonal

wetlands that become increasingly salty as the surface water evaporates.

According to Irish (2013) the pan surface is unstable, changing rapidly in extent by

opening or crusting over in a matter of hours. This is presumably in response to subtle

differences in temperature, wind and humidity. Any insects that stay on the pan for

an extended time, particularly on hot days, are likely to die from heat stress and

dehydration, brought on by the absence of shelter, high reflectivity and desiccatory

nature of the pan surface. Therefore, the salt levels found in the pans are lethal for

many life forms.

Some organisms (e.g. Ephylidae flies and Staphyliidae) are able to relocate once

they are disturbed or conditions become unbearable whilst others are less mobile

and have therefore adapted very specific life cycles to tolerate hypersaline

environments. They are known as halophiles (salt-lovers) (Irish, 2013).

The Crustacea are the most common pan specialists in Namibia, and show high

levels of endemicity in some groups (Irish, 2013). They have resistant eggs that are

capable of withstanding long, dry periods in a dormant stage. Once the brine pools

start to dry out, the eggs are transported (through the differences in salt

concentrations) to the edge of the pool where it is embedded in the crust of the salt

layer. They hatch as soon as the pans fill after rain, rapidly grow to maturity and

reproduce. The habitat preferences of these organisms are therefore not restricted

to certain areas on the pan, but rather to edges of pools or puddles, due to the

continuous change in salt concentration levels.

5.3.2 ECOSYSTEM SERVICES

Aquatic fauna provide important ecosystem services on the pans. Apart from filling

a niche in the saline conditions, it also forms a vital link in the food web (Irish,2013).

Most of the micro-organisms are detritivores, feeding on and breaking down dead

plant or animal matter, returning essential nutrients to the ecosystem. In turn, these

organisms are food sources to not only each other (e.g. Staphylinidae) but also to

other faunal species such as birds particularly flamingos. The aquatic fauna of the

Otjivalunda salt pans therefore form part of an interconnected web and removing or

damaging this link could have uncertain but potentially negative consequences to



P a g e 4 1

the receiving environment.

5.3.3 EXPECTED VS OBSERVED ORGANISMS

Irish (2013) states that:

“the aquatic fauna of salt pans can be expected to show high levels of

habitat specificity because of the particular adaptations required to survive

there;

high habitat specificity will result in range-restricted distributions for salt pan

specific taxa, given that the potential distribution range of the species will be

absolutely limited by the extent of each salt pan;

the low mobility of the organisms involved will favour single pan endemism,

but this might be offset by their probable ability to disperse as dormant stages

in mud on the feet of water birds, therefore actual endemicity will more likely

be on a regional level and involve groups of relatively proximate pans that

are geographically isolated from similar pans elsewhere. In this case, a

proximate pan group might be all hypersaline environments in the Cuvelai

drainage.”



P a g e 4 2

Table 8: Summary of findings from Irish (2013).

AQUATIC ORGANISMS HYPERSALINE

ENVIRONMENTS

EXPECTED1

STATUS

OBSERVED

NAMIBIA CUVELAI OTJIVALUNDA E OTJIVALUNDA W CLAY PAN 1 CLAY PAN 2

Cru

sta

ce

a

Micro-

organisms Halophilic Global distribution None None None None

Ostracoda 43 species 19 species

13 endemic to

Namibia,

6 endemic to

Cuvelai

None None None None

Copepoda 17 species 2 species Not endemic None None None None

Notostraca 2 species 2 species Not endemic None None None None

Cladocera Unknown 19 species Unknown 1 endemic to

Namibia None None None None

Conchostraca 14 species 8 species Not endemic None None None None

Ephydridae Halophilic 15 species None

1 endemic to

Namibia

1 endemic to the

Namibian coast

None None None 9 larvae

1 Based on available literature.



P a g e 4 3

AQUATIC ORGANISMS HYPERSALINE

ENVIRONMENTS

EXPECTED1 STATUS OBSERVED

Hydraenidae Not exclusively

halophilic 8 species None

3 endemic to

Namibia None None None None

Hydracarina Unknown Unknown Unknown None None None None

Staphylinidae Prefers less

saline habitats

184

species Unknown Unknown 33 Individuals None 2 Individuals 4 Individuals

Gnaphosidae Prefers less

saline habitats Unknown Unknown Unknown None None 1 Individual None



P a g e 4 4

In his specialist study Irish (2013) researched historical data to determine the endemic

species likely to occur at the Otjivalunda salt pans. In addition, dry soil samples were

obtained during the site visit, let to hatch and the hatched individuals identified to

see whether the expected species did in fact occur at the pans.

Table 8 above provides a summary of the results (The detailed information is

contained in APPENDIX B). Irish (2013) draws the following conclusions:

“The Otjivalunda Pans have a high potential for sustaining range-restricted

endemic halophilic invertebrate taxa.

No Crustacea of any kind were either observed in open brine pools during

fieldwork, or hatched from the substrate samples. This might mean:

o halophilic Crustacea do not occur, or

o halophilic Crustacea are seasonally active, possibly in response to the

influx of rainwater into the pans, and sampling took place at an

unsuitable time, or

o halophilic Crustacea occur at very low population levels and were

missed by sampling, or

o hatching methodology used was unsuited to the hatching

requirements of halophilic Crustacea at Otjivalunda.

Sampling for the current project was inconclusive, possibly because it took

place at what is usually a seasonally suitable time, but in this case in a

particularly dry year.”

Based on these results, Irish (2013) recommended a follow up site visit following the

rainy season to verify his results and to conclusively determine whether endemic

crustaceans do occur on the Otjivalunda salt pans.

5.3.4 SENSITIVITIES

The sensitivity of the aquatic fauna in the proposed project area is presented in

Table 9 below:



P a g e 4 5

Table 9: Sensitivity of aquatic fauna in the project area.

ENVIRONMENTAL

FEATURE SENSITIVITY POTENTIAL IMPACT/ENHANCEMENT

Sensitive or endemic

fauna occurring on the

pan surface.

Integrity of the pan ecosystem. Loss of aquatic biodiversity on

the pan surface.

Potential loss of ecosystem

functions if this vital link is

removed.

Inability to rehabilitate the pan

surface to what it was before the

start of the project.

5 .4 BIRDS

5.4.1 HABITAT PREFERENCES

The habitats surrounding the Otjivalunda salt pans provides roosting, foraging and

breeding areas for a number of birds, including those migrating between southern

Africa and the northern hemisphere. According to Scott (2013) birds use these

habitats opportunistically, often on a seasonal basis. They move rapidly into areas

that have received rain and commence with breeding activities only when

conditions are suitable.

Scott (2013) states that because there appears to be no obvious difference between

the habitats of the eastern and western pans, the bird species are expected to be

similar on the pans.

Based on the habitat delineations provided in Subsection 5.2.2, the following bird

species are expected to inhabit the pan area:

Table 10: Bird species likely to occur in the various habitats at the Otjivalunda pans.

HABITAT TYPICAL BIRD SPECIES EXPECTED SUITABILITY FOR BIRDS

WETLANDS

Greater and lesser flamingo

Chestnut-banded Plover

Roosting and foraging

Nesting

SALT FLATS Salt-adapted species Niche for these species.

PAN EDGE Migratory waders and other Depends on the availability



P a g e 4 6

HABITAT TYPICAL BIRD SPECIES EXPECTED SUITABILITY FOR BIRDS

birds

Chestnut-banded Plover

of food and water.

Foraging, roosting and

breeding.

FLAT GRASSLANDS Kori and Ludwig Bustard,

korhaans and raptors.

Open habitat, suitable for

foraging, roosting and

breeding.

MOPANE SHRUBLAND Hornbills and raptors Woodier habitat suitable for

breeding.

5.4.2 IMPORTANT BIRD AREAS (IBA)

“IBAs are places of international significance for the conservation of birds at the

Global, Regional (Continental) or Sub-regional (southern African) level, selected

according to stringent criteria” (Scott, 2013).

The study area lies immediately north of the Etosha National Park and within the

Lipumbu Ya Tshilongo Conservancy, near several other communal conservancies.

Etosha National Park is both a designated Ramsar site (i.e. Wetland of International

Importance) and an Important Bird Area, being home to some 340 bird species.

According to Scott (2013) the area regularly supports a significant number of

Globally Threatened species, including Lesser Flamingo and Ludwig's Bustard. It also

regularly supports a significant number of species in restricted range/biome-restricted

assemblages, including Ludwig's Bustard. Furthermore Etosha holds, on a regular

basis, more than 1% of the biogeographic population of congregatory waterbird

species including Greater Flamingo and a salt specialist, the Chestnut-banded

Plover.

5.4.3 SENSITIVE BIRD SPECIES EXPECTED AT THE SITE

Scott (2013) states that of the 254 species recorded in the Otjivalunda study area, 24

(10%) are classed as threatened in Namibia, while four more (2%) are threatened in

southern Africa. Fifteen species are also Globally Threatened.

Sixty-eight (27%) of the bird species in the Otjivalunda study area are migrant (i.e.

undertake large-scale, regular seasonal movements) usually to the northern

hemisphere and back, while a large proportion (97 or 38%) are nomadic at some

stage of their lives (Scott, 2013). Abundance of nomadic species may vary

dramatically over time.



P a g e 4 7

The study area is home to one species (0.5%) that is near-endemic to Namibia,

namely Bradfield's Swift; a further 48 (8%) species are endemic/near-endemic to

southern Africa (APPENDIX C). Endemism (having a restricted distribution range) is a

factor that increases the vulnerability of a species to impacts such as disturbance

and habitat destruction (Table 11).

It should be noted that none of these birds were observed during the site visit

undertaken by Scott (2013). However, based on literature and available knowledge,

it is likely that they will occur either in the proximity of or at the Otjivalunda pans.



P a g e 4 8

Table 11: Bird species likely to occur and their potential habitat preferences at the Otjivalunda pans.

SPECIES STATUS SALINE ENVIRONMENT HABITAT BREEDING/ ROOSTING FEEDING

Chestnut-

banded

Plover

Near

threatened,

endemic to

Africa

Highly specialised and adapted

to saline habitats

Wetlands, salt flats

and pan edges.

Nests are typically scrapes in dry

sand or on hard salt crust on the

edge of salt pans.

Breeds April to May and less

frequently November to January.

Feeding ecology is unknown.

Lesser

Flamingo

Near

threatened,

Globally

threatened

Prefers more saline habitats than

Greater Flamingo typically, salt

pans, salt works and brackish

rivers.

Wetlands and salt

flats. Have been

recorded east of

the Otjivalunda salt

pans but not at the

pans itself.

Breeding in Etosha occurs typically

after annual rainfall exceeds

400 mm; egg laying usually begins in

January-February, starting within

weeks of the birds migrating to the

Pan.

Several thousand nests are made

far out on the salt pan.

Breeding is rarely successful.

Feeds day and night for up to 12.5

hr/24 hr, by wading in shallow water,

with bill upside-down, filtering

cyanobacteria from the surface, and

small diatoms from the bottom layers

Greater

flamingo

Near

threatened

Prefers less saline habitats than

Lesser Flamingo, typically

recently flooded salt pans.

Wetlands and salt

flats. Have been

recorded in the

Otjivalunda area

but not at the pans

themselves.

Breeding occurs in large, typically

mixed colonies on raised islands on

flooded salt pan at Etosha.

In Etosha, main rains occur February

and laying typically starts when

annual rains exceeds 400 mm.

It feeds by wading in shallow water

with bill upside down, filtering small

crustaceans and other invertebrates

from the water column and mud.

Mainly takes marine benthic

organisms such a molluscs, and

diatoms, and saline lake crustaceans



P a g e 4 9


such as fairy shrimps (e.g.

Branchinella spp) and brine flies

(Ephydra spp.)

Ludwig’s

Bustard

Near

endemic to

southern

Africa,

globally

threatened.

Prefers flat grasslands on sand

around the pans. Has been

recorded in the Otjivalunda Pan

area.

Flat grasslands. The breeding season spans from

August to December, with the

species nesting on bare ground with

a clutch of 2-3 eggs.

Bustards are nomadic, insectivorous

bird species that tend to follow

rainfall and seasonal changes in

food abundance, and may move

into the area following rain.

Kori Bustard Vulnerable,

threatened

in southern

Africa

Prefers flat grasslands on sand

around the pans. Have been

recorded at the Otjivalunda

pans.

Flat grasslands. Breeds from September to February.

Breeding is closely tied with rainfall,

and in drought years, may be

greatly reduced or not even occur.

Nests are created on the ground in

a shallow, unlined hollow, rather

than the typical scrape. The hollow

may almost completely covered by

the female when she's incubating.

Due to their ground location, nests

are often cryptic and difficult for a

human to find, unless stumbled onto

by chance.

Bustards are nomadic, insectivorous

bird species that tend to follow

rainfall and seasonal changes in

food abundance, and may move

into the area following rain.



P a g e 5 0


Southern

Ground

Hornbill

Vulnerable Prefers woodier areas around the

pans. It is probably not often

present any more due to the

increasing human presence.

Mopane shrubland One to three eggs are laid at the

beginning of the wet season in nests

in deep hollows in very old trees.

Large ground-dwelling species. They

forage on the ground, where they

feed on reptiles, frogs, snails, insects

and mammals up to the size of hares.

http://en.wikipedia.org/wiki/Wet_season



P a g e 5 1

5.4.4 SENSITIVITIES

Environmental sensitivities related to birds are described below in Table 12:

Table 12: Environmental sensitivities related to birds

ENVIRONMENTAL FEATURE SENSITIVITY POTENTIAL IMPACT

PAN EDGE Potential feeding/ breeding habitat

for Chestnut-banded Plover

Roosting areas for migrant birds

Feeding/ roosting/

breeding disturbance

Habitat destruction

GRASSLANDS ON SAND FLATS Grasslands and drainage lines /

shallow valleys provide food and

shelter to birds

Feeding/ roosting/


Habitat destruction

Poaching

WETLANDS Potential feeding/ breeding habitat

for flamingos and other migrant birds

Feeding/ roosting/


Habitat destruction

5 .5 ARCHAEOLOGY

5.5.1 CURRENT STATUS

The project is located in the Kalahari Sandveld and Mopane Shrubland. The area

comprises a number of low lying pans, enclosed within the complex scarp of

prevailing calcrete beneath a shallow surface layer of Kalahari sands. According to

Kinahan (2013) the locale is poorly explored in terms of archaeology, but the human

history is typical to the Oshiwambo-speaking people who have been resident there

for at least the past 1000 years.

Because of the low fertility of the soil, the area is not used for cultivation purposes but

due to the highly nutritious grass species (e.g. buffalo grass) occurring on the lime-

rich margins of the pans, it is utilized for grazing. The extreme saline surface of the

Otjivalunda pans has also been exploited by the locals as a source of salt since pre-

colonial times.



P a g e 5 2

5.5.2 HISTORICAL SIGNIFICANCE OF THE OTJIVALUNDA PANS

Previous studies done on the shorelines of the Etosha pan have provided evidence of

four periods of increased wetness where the outer shoreline of the Etosha pan mostly

likely extended to include most of the smaller neighbouring pans, including

Otjivalunda. The occurrence of semi permanent water within the basin would have

been associated with lake margin vegetation (e.g. extensive reed beds) and fauna

that no longer occur in the area today (e.g. buffalo, lechwe and crocodile)

(Kinahan, 2013).

During his assessment Kinahan (2013) could find no evidence of pre-colonial human

occupation at the Otjivalunda pans. Nor was he able to obtain information

regarding the intensity or duration of historical salt extraction activities on the pan.

He ascribes the absence of this information to the non-invasive traditional methods

of salt extraction on the pans.

Relics of more recent (within the last 50 years) salt mining activities at the Otjivalunda

East pan are more apparent from the series of earth groins and impoundments

(Figure 15). These are associated with mechanical assisted excavation, road-beds

and various spoil heaps. In addition to these, remains of a mining camp site are

located north of the pan in the form of five concrete platforms with timber post

stumps. Other remains include a dirt landing strip and a number of informal access

tracks.

5.5.3 SENSITIVITIES

The sensitivity of the archaeological significant sites in the proposed project area is

presented in Table 13 below:

Table 13: Archaeological sensitivity in the project area

ENVIRONMENTAL


Archaeological remains

in the vicinity of the

project area.

Integrity of the archaeological

heritage at the Otijvalunda Salt

pans.

Destruction of archaeological

heritage and compromised integrity

of the historical record of the area.



P a g e 5 3

Figure 15: Otjivalunda Pans: Recent salt-mining earthworks on Pan 2 (Kinahan, 2013).



P a g e 5 4

5 .6 CULTURAL SALT HARVES T ING

5.6.1 CULTURAL SIGNIFICANCE OF SALT HARVESTING

Historically local communities have been harvesting salt on a small scale for

domestic use and trade since the 18th century. During this time, once aspect of salt

harvesting has always stayed the same, i.e. salt has always been available at the

pans.

Salt harvesting forms part of an initiation ritual undertaken by some of the local

Oshiwambo communities. The process entails young boys, between 10 and 17 years

old going to the panto harvest salt by either donkey cart or vehicle during the dry

winter months. Upon their return they are welcomed by their elders with respect,

honouring them by preparing a feast of slaughtered chicken. Since they are then

seen as young men they are allowed to drink of the traditional alcoholic drinks. The

young men also receive a goat which signifies that they are seen as independent

and able to provide for their own future.

The communities within the Uukwambi traditional group make use of both the

Otjivalunda east and west salt pans. The eastern pan is mostly used for salt licks for

cattle whereas salt from the western pan is used for human consumption because:

The quality of the salt in the western pan is superior to that found in other salt

pans in the area, making it the best salt for human consumption;

It tastes different (and better) from table salt purchased in shops, as well as

that found in eastern and other pans;

There is more salt available for harvesting in the western pan than on the

eastern pan;

Shop bought salt is refined whereas salt from the eastern pan is more course;

This information has been passed on from generation to generation, thus they

have been taught that the western pan is traditionally the pan used for salt

harvesting.

Although the Otjivalunda east pan falls under the Ondongo traditional authority’s

jurisdiction, the pan is located too far away and preference is therefore given the

Ondangwa pan that is closer.



P a g e 5 5

5.6.2 ECONOMIC VALUE OF SALT HARVESTING

During her fieldwork, Saayman (2013) asked attendants to rank the various salt uses

according to importance. Whilst they mostly view the uses as equally important, the

uses can be grouped according to primary and secondary use as portrayed in

Table 14:

Table 14: Summary of the uses of salt by the communities.

USE ASPECT DESCRIPTION

PRIMARY

Food It is used to flavour food during the cooking process. It is

also used to dry meat.

Medicine Used as an ointment for skin ailments, coughing, small pox,

etc.

Bartering

Salt is exchanged for other commodities such as mahango

or meat. The exchange ratio depends on negotiations

between the two parties.

Payment It is also used as a form of payment for services provided. For

example, some of the traditional healers are paid with salt.

Selling

The communities located further away from the salt pans

also sell salt in order to generate an additional income. This

can be attributed to their proximity to the markets. Those

who live closer to the salt pans do not really sell salt as the

majority of the people have easy access to free salt at the

pans.

Tannery The salt is used to dry skins.

SECONDARY

Cattle lick

Salt are sometimes dug out in blocks from the Eastern Pan.

Alternatively, cCoarse salt from the Western Pan can be

mixed with the fodder.

Superstition Some of the older people believe that the placing of salt on

window sills will drive away evil spirits.

Preserving corpses

In instances where someone passes away and the people

have to wait on transport to take the body away, the

corpse is preserved in salt water.

The existing uses of salt and approximate going rate of salt for the different needs are

summarised in Table 15.



P a g e 5 6

Table 15: Value of Salt.

ASPECT VALUE

Food A 500 gram bag of salt can be purchased for N$5.00 at a local cuca shop.

Medicine A 500 gram bag of salt can be purchased for N$5.00 at a local cuca shop.

Coughing syrup and remedies for skin ailments will cost even more.

Bartering (for goods and

services)

The exchange rate for bartering of goods and services could not be

determined as it depends on the negations between the two parties. It

should be considered that the salt is obtained for free, thus increasing the

value it has when it comes to bartering.

Selling

In general, the salt is sold for N$5.00 per jam can. In one specific instance,

an income of N$3,000.00 has been generated during one harvesting

season.

Tannery N$45.00 per 50 kg bag of coarse salt.

Cattle lick

The approximate selling price of salt blocks for cattle lick is N$45.00 per

block (400 by 400 cm). Alternatively a 50 kg bag of coarse salt can be

purchased at N$45.00 per bag which can be mixed with the fodder.

(approximate going rate of salt at Agra).

Superstition Shop bought salt will not suffice in this case, only salt from the Otjivalunda

Pans.

Preserving corpses N$45.00 per 50 kg bag of coarse salt or N$5.00 for 500 grams of refined salt.

5.6.3 SENSITIVITIES

Based on the fieldwork findings and available information, the following key

sensitivities have been identified (Table 16).

Table 16: Sensitivities and potential impacts associated with cultural salt harvesting.

ASPECT SENSITIVITY POTENTIAL IMPACT

Cultural Significance

of salt harvesting

The harvesting of salt forms part of

a cultural initiation ritual for young

boys.

Should access to the salt pans be denied,

or the mineral completely be removed

over the lifespan of the proposed project,

an initiation ritual of great cultural value

will be lost.

Also, the sense of remoteness of the salt



P a g e 5 7

ASPECT SENSITIVITY POTENTIAL IMPACT

pans will be changed by the presence of

mining activities.

Economic Value

Salt is used for a number of

different purposes by the

communities and thus has

economic value.

Should the resource be completely

exploited, the local communities will be

faced with additional costs which can

aggravate poverty in the area. Also, a

source of income and bartering power

will be lost.

5 .7 FUTURE PLANNED TOURI SM ACT IV IT IES IN THE CO NSERVANCY

The proposed mining site and sections of the transport route falls within the Iipumbu

ya Tshilongo Conservancy which was registered in May 2012 and has an estimated

4,000 residents (Hazam, 2013). The conservancy is approximately 154 800 hectares in

size and is situated on the north central boundary of the Etosha National Park

(Figure 16).

Not only is the latter a landmark in terms of conservation in Namibia, it has also

become one of the country’s main tourist destinations.

In the recent feasibility study, Humphrey and Brown (2013) assessed the natural

resource base and human / cultural capital of the conservancy with a view to

develop and utilize these in a sustainable way. As part of their assessment they

considered the potential for an African safari lodge within the Conservancy,

providing access into Etosha National Park through the Narawandu Gate.

5.7.1 CHALLENGES AND OPPORTUNITIES IN THE CONSERVANCY

The main aim of developing conservancies is to improve the livelihoods of its

members. According to Humphrey and Brown (2013) the southern part of the

conservancy is relatively undeveloped. Coupled with the close proximity to the

Etosha National Park some opportunities for tourism development exist in the

conservancy (Table 17):



P a g e 5 8

Table 17: Opportunities and challenges associated with tourism development in the conservancy.

OPPORTUNITIES CHALLENGES

Cultural tourism opportunities:

o Traditional salt harvesting

o Cattle posts & kraals,

o Water pits

The southern section of the conservancy falls

within the current project’s EPL area.

Bird watching opportunities during the wet

season

The area is very remote and road access is

extremely limited.

Seasonal attraction in the surrounding areas

(e.g. Lake Oponono, Ekuma River, subsistence

fishing, etc.)

Currently the area has very little wildlife and

with the upgrade of the northern fence line,

the natural migration of wildlife such as zebra

and wildebeest will further be limited.

Re-introduction of wildlife into the area could

allow for the establishment of a mixed wildlife-

livestock grazing area.

Very limited fresh water available in the area.

The area has no natural water holes and little

ground water.

Figure 16: Location of the Otjivalunda pans in relation to the Iipumbu ya Tshilongo Conservancy and the

Etosha National Park.



P a g e 5 9

5.7.2 POSSIBLE FINANCIAL AND ECONOMIC OPPORTUNITIES

As part of their assessment, Humphrey and Brown (2013) considered the feasibility of

developing an African safari lodge in the southern extremities of the conservancy.

Two sites were identified as potentially suitable, of which one is located on the edge

of the Otjivalunda eastern pan (Figure 17).

Figure 17: Proposed location for the development of an African safari lodge close to the Narawanda gate.



P a g e 6 0

The Okanga Pan, situated approximately 9km north east of the Otjivalunda Pans,

also presents an opportunity for lodge development. While a section of the pan falls

within the EPL area, it is not currently earmarked for mining (Humphrey & Brown,

2013). The opportunity is therefore not limited to the Otjivalunda east pan. If the

lodge is to cater for an exclusive group of people, the remoteness of the Okanga

pan could be an added advantage, particularly if access can be provided by air

(i.e. a small airstrip).

Table 18 below depicts the potential financial and economic returns of such a

venture:

Table 18: Possible financial and economic returns of the lodge and associated tourism activities

(Humphrey & Brown, 2013).

Humpfrey and Brown (2013) concluded that such a project would be both financially

viable and moderately attractive for private investment, provided that an

experienced private partner can be found.

5.7.3 SENSITIVITIES

The sensitivity associated with the development of the proposed project in the

Iipumbu ya Tshilongo conservancy is presented in Table 19 below:

DESCRIPTION RETURNS

Annual business turnover at maturity N$ 12.3 million

After-tax net income N$ 1.3 million

Conservancy concession fee (fifth year of operation) N$ 738,000

Income from concession fees (over 20 year lifespan) N$ 19.6 million

Contribution to Government coffers in form of

corporate taxes (excluding park fees, VAT and PAYE)

over 20 years life.

N$ 19.1 million



P a g e 6 1

Table 19: Sensitivity associated with tourism development in the project area

ENVIRONMENTAL


Tourism opportunities in

the Iipumbu ya

Tshilongo conservancy.

Changes to the landscape and the

poaching or disturbance to wildlife

can affect the management

activities of the conservancy and

associated game-based tourism

opportunities.

A change in the sense of place of the

area due to the presence of mining

equipment and activities. Post-

mining the Otjivalunda Salt Pans will

be eliminated as a key visual and

cultural feature, should both pans be

mined.





P a g e 6 2

6 PUBLIC CONSULTATION AND DISCLOSURE

6 .1 INTRODUCT ION

Public participation forms an important component of an Environmental Impact

Assessment (EIA) as it provides potential interested and affected parties (I&APs) with

a platform whereby they can raise any issues or concerns relevant to the proposed

project. This assists the consultant in considering the full spectrum of potential

impacts and to what extent further investigations are needed.

In addition, the public participation process also grants I&APs an opportunity to

review and comment on all the documents produced throughout the EIA process.

This is done in accordance with both the Namibian Environmental Management Act

of 2007, as well as international best practice principals.

The consultation process followed during this project included consultation meetings

with the relevant authorities and the community. Thereafter a scoping report

containing the issues identified during the scoping process was circulated to

registered I&APs. More details on the public participation process and its findings

can be viewed in the Scoping Report for this project.

6 .2 PUBL IC CONCERN

The issues raised during the Public Consultation and Scoping Phase determined the

scope of the full Environmental Impact Assessment. These key concerns are listed

below in Table 20 and further assessed in Section 7.

Some of the issues raised could not be addressed by the Consultant. One such issue

was the serious objections made by some of the community members to this

proposed project relating to mining rights, ownership of the pans and shareholding

amongst others. This required an external conflict resolution process involving some

the government institutions and line ministries such as the Ministry of Mines and

Energy, the Oshana Regional Council, Traditional Authorities, and community

members along with OUME. The outcome of this process is summarized in a letter

from the Oshana Regional Council (APPENDIX G).



P a g e 6 3

Table 20: Summary of issues raised during the consultation process (as reflected in the minutes of the scoping report).

THEME

PUBLIC CONCERNS

SPECIALIST INVESTIGATION

MINING SITE

BIOPHYSICAL

ENVIRONMENT

Mining activities and associated noise might disturb game in the conservancies, causing it

to move away. Hence also adversely affecting the potential for tourism in the Iipumbu ya

Tshilongo conservancy.

Assessment of tourism potential

Chestnut-banded Plover Charadrius pallidus, a Near Threatened species, feed and breed

in saltpan areas, and may be disturbed by the mining activities as habitats also change.

Lesser Flamingo, Greater flamingo and Blue Cranes may be impacted by physical

disturbance and changes to habitat resulting from the activities of the proposed project.

Seasonal migratory birds might use the pans for breeding grounds and may be disturbed

by the proposed activities or changes in habitat brought about by the proposed project.

Soda ash may cause leg and feet sores/ulcers on wetland birds.

Any disturbance to the Etosha pan, which includes noise and chemical pollution, can

affect the flamingo breeding patterns, as well as the natural environment in general.

Bird Assessment

Aquatic invertebrates living in the pan may be destroyed during the mining process. Aquatic fauna Assessment

A number of strandlines of the mega-Etosha, dating 6000 ago, can be found in the area

along with fossil remains, which might be threatened by the activities of the proposed

project.

Archaeological Assessment

SOCIO-ECONOMIC The Iipumbu ya Thsilongo conservancy members should be compensated for the loss of

income as the mining activities may limit its tourism potential. Assessment of tourism potential



P a g e 6 4

THEME PUBLIC CONCERNS SPECIALIST INVESTIGATION

ENVIRONMENT Should the salt on the pans be totally mined or access to the saltpans be restricted, the

initiation ritual of collecting salt from the pans and its cultural significance, may be lost.

Mining activities may restrict the free use and access of salt from the pan by local

communities for domestic use.

Assessment cultural and economical

value of salt harvesting

GENERAL CONCERNS

COMMUNICATION

The Oshana Regional Council feels they should have been consulted prior to the

consultation meetings of the EIA process.

Some of the headmen at Onkani are concerned that they are only being consulted

during EIA process, and not prior to it.

Dealt with as part of the external

conflict resolution process.

SHAREHOLDING AND

ECONOMICS

A 5% shareholding by the traditional authorities might be insufficient taking into

consideration that the land belongs to them.

The Oshana Regional Council wishes to be a shareholder.



P a g e 6 5

6 .3 PUBL IC FEEDBACK

The Environmental Impact Assessment Report will be circulated in a similar fashion as

the Scoping Report:

It will be circulated to all I&APs for their comments, allowing for a two week

comments period.

For those that do not have internet access, copies of the report and executive

summary will be sent to the local and regional authorities’ offices.

A short summary of the findings will be translated into Oshiwambo and

announced over the radio, also mentioning the availability of the report at the

specific locations.

Feedback meetings will be conducted to ensure that the information

presented in the Report is communicated to, as well as understood by the

communities.

The comments received on the report will be collated into a Comments and

Responses Trail that include statements of how the comments were

considered and incorporated into the final report.

After incorporating the comments, the final version will be submitted to the

Directorate of Environmental Affairs in an application for environmental clearance.



P a g e 6 6

7 ASSESSMENT OF IMPACTS

7 .1 IDENT IF ICAT ION OF KE Y ISSUES

During the scoping phase of this project a screening process was applied as

explained in Subsection 1.6. All the potential issues identified are listed in Table 1.

Issues requiring further specialist investigation i.e. challenges for which adequate

information was unavailable to propose mitigation measures or make an assessment

of the extent of the potential impact are the subject of this section.

Five areas were identified for which data was unavailable in the scoping phase to

conclusively determine the impact or identify workable mitigation options.

Specialists were tasked to further investigate each of these areas:

Potential impact on endemic bird species

Potential impact on endemic aquatic fauna

Potential loss of cultural salt harvesting rituals

Potential loss of or damage to archaeologically significant sites

Potential impact on future planned tourism activities in the conservancy.

The findings from these investigations are summarized in Table 21 below and form the

focus of the rest of this Section.



P a g e 6 7

Table 21: Identification of key impacts associated with the various phases of the project at the mining site.

SPECIALIST

STUDY

POTENTIAL IMPACTS OF THE PROJECT AT THE MINING SITE

CONSTRUCTION OPERATION DECOMMISSIONING/REHABILITATION

AQUATIC

FAUNA

Loss of aquatic biodiversity on the pan

surface.

Potential loss of ecosystem functions.

Loss of aquatic biodiversity on the pan

surface.

Potential loss of ecosystem functions.

Inability to rehabilitate the pan surface to

what it was before the start of the

project.

BIRDS

Feeding/roosting/breeding disturbance

Habitat destruction

Poaching


Habitat destruction

Poaching


Poaching

ARCHAEOLOGY

Disturbance or destruction of existing

archaeological sites.

Destruction or damage to new

archaeological sites exposed during

construction work.

Disturbance or destruction of existing

archaeological sites.

None

CULTURAL

HERITAGE

Loss of cultural value of salt harvesting.

Loss of economical value of salt

harvesting.



harvesting.



harvesting.

TOURISM





Loss of or full potential for tourism

opportunities not reached due to

inadequate rehabilitation.



P a g e 6 8

7 .2 METHODOLOGY EMPLOYED FOR THE IMPACT ASSES SMENT

Each of the potential impacts listed above were assessed to determine the true

significance of the proposed project on the environment. The criteria used to

describe the significance of the impact on the particular environmental component

(i.e. aquatic fauna, birds, archaeology and cultural environment) are contained in

the Table 22 below:

Table 22: Criteria for the assessment 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 15 km of the area);

regional (limited to ~200 km radius); national (limited to within the borders of

Namibia); or international (extending beyond Namibia’s borders).

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).

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 route

should be used).



P a g e 6 9

DESCRIPTION

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.

7 .3 ASSESSMENT OF IMPACT S

7.3.1 POTENTIAL IMPACT ON ENDEMIC AQUATIC FAUNA

Significance of the Otjivalunda pans for aquatic fauna

According to available literature, Irish (2013) described a number of specially

adapted and consequently endemic aquatic fauna that are associated with

environments such as the Otjivalunda pans. However, following a field assessment

he could find no evidence of such species occurring at either of the two pans under

investigation.

Irish (2013) provides the following potential explanations:

halophilic Crustacea do not occur, or

halophilic Crustacea are seasonally active, possibly in response to the influx of

rainwater into the pans, and sampling took place at an unsuitable time, or

halophilic Crustacea occur at very low population levels and were missed by

sampling, or

hatching methodology used was unsuited to the hatching requirements of

halophilic Crustacea at Otjivalunda.

For this assessment, Irish (2013) worked under the assumption that halophilic

Crustacea do occur at the Otjivalunda pans.

The wetland habitat of the pans is of crucial importance for the survival of the

halophilic species. Whilst some species are able to relocate to more favourable

habitats once the pans start to dry out, other have adapted specific traits to survive

the hypersaline conditions. Most of these species have resistant eggs that are

capable of withstanding long, dry periods in a dormant stage. Once the brine pools

start to dry out, the eggs are transported (through the differences in salt

concentrations) to the edge of the pool where it is embedded in the crust of the salt



P a g e 7 0

layer. They hatch as soon as the pans fill after rain, rapidly grow to maturity and

reproduce. These organisms are restricted to the surface of the pans, with the

wetland/salt flats habitat the only niche that they occupy.

Availability of similar habitats in the area

Despite being unable to verify the occurrence of halophilic crustaceans on nearby

(similar) salt pans, Irish (2013) states that there is a high probability that range-

restricted endemic aquatic halophiles should occur in at least some of them. The

low mobility of the organisms favours single pan endemism, but they may still be able

to disperse as dormant stages in mud on the feet of water birds. According to Irish

(2013) actual endemicity will therefore more likely be on a regional level and involve

groups of relatively proximate pans that are geographically isolated from similar pans

elsewhere. In this case, a proximate pan group might be all hypersaline

environments in the Cuvelai drainage. However, the possibility of single pan

endemism cannot be excluded especially in cases where the chemical composition

of the pan is unique and the organisms are specifically adapted to it. This will either

be proven or disproven once a follow up site visit has been undertaken.

Expected significance of the mining impact

To determine the potential impact of the project, should both pans be mined

completely, Irish (2013) recommends that the precautionary principle be applied

until the status of the aquatic fauna can be verified. Although the possibility still exists

that no fauna occur on the pan, this would be extremely unusual. Irish (2013) states

that ecologically the eastern and western Otjivalunda pans are very similar and

therefore the organisms occurring at the pans are also expected to be comparable.

However, considering the unique composition of salts, completely exploiting the

Otjivalunda pans could present a fatal flaw in the project, since it could result in the

complete eradication of potentially endemic species (endemic to the Otjivalunda

pans).

Mitigation and ongoing monitoring and research

Sampling should be repeated once the pans have had rainwater influx.

At least 25% of the surface area of each pan should be left undeveloped until

the status of the aquatic fauna can verified.

Each no-go area should be self-contained and adjoining and include both

the pan edges and the pan interior. It should be located as far as possible

from the mining operations.



P a g e 7 1

No-go areas should be studied to determine the status of potential range-

restricted endemic aquatic fauna. The following should be established:

o Ability of the pan surface to be rehabilitated to conditions post mining;

o Ability of fauna to re-colonise the rehabilitated habitat.



P a g e 7 2

Summary


BEFORE MITIGATION AFTER MITIGATION BEFORE MITIGATION AFTER MITIGATION BEFORE MITIGATION AFTER MITIGATION

HABITAT DESTRUCTION AND CONSEQUENT LOSS OF POTENTIAL ENDEMIC AQUATIC FAUNA

EXTENT Local Site specific International

(potential taxon

extinction)

Local (if no

extinction occur)

Local Local

DURATION Permanent Long term Permanent Long term (project

duration)

Permanent Long term (assuming

successful functional

restoration;

otherwise

permanent)

INTENSITY Low Low High Medium High Medium

PROBABILITY Uncertain (depends

on status of aquatic

fauna)

Uncertain (depends


fauna)

Uncertain (depends


fauna)

Uncertain (depends


fauna)

Uncertain (depends


fauna)

Uncertain (depends


fauna)

STATUS Negative Negative Negative Negative Negative Positive (assuming

successful functional

restoration,

otherwise negative)



P a g e 7 3


DEGREE OF

CONFIDENCE IN

PREDICTIONS

Medium (can be

high if uncertainties

are eliminated)

Low (because of

uncertain status of

aquatic fauna)

Medium (can be


are eliminated)

Low (because of

uncertain status of

aquatic fauna)

Medium (can be


are eliminated)

Low, because of

uncertain status of

aquatic fauna and

uncertainty

regarding

rehabilitation

potential

SIGNIFICANCE Low Low Medium Medium-Low Medium Medium Positive (if

rehabilitation is

successful)



P a g e 7 4

7.3.2 POTENTIAL IMPACT ON ENDEMIC BIRD SPECIES

Significance of the Otjivalunda pans for birds

The Otjivalunda pans are located close to the Etosha National Park which is not only

a Ramsar site (i.e. a wetland of international importance) but also an Important Bird

Area, housing some 340 bird species (Scott, 2013).

Due to the close proximity of the Etosha wetland, the smaller pans north of the

National Park’s boundaries are known to also contain large numbers of bird species.

These species use pans opportunistically, often on a seasonal basis, moving rapidly

into the areas that have received rain and speedily commencing with breeding

activities when conditions are suitable. Of the 254 species likely to occur in the

Otjivalunda study area, 68 or 27% are migrant species that move seasonally to the

northern hemisphere and back. This signifies the importance of the Otjivalunda salt

pans as a rest site on their migratory route (Scott, 2013).

In addition to this, the Otjivalunda pans provide important habitats for the birds. The

wetlands, salt flats, pan edges, grasslands and mopane shrublands are used for

foraging, roosting, nesting and breeding (Scott, 2013). It is particularly the salt

adapted species, i.e. the Chestnut-Banded Plover that could be severely influenced

by the movement of vehicles on the salt flats and pan edges. According to Scott

(2013) this species lay their eggs in shallow scrapes on the pan edges, breeding from

April to May when salt mining would have commenced on the pans.


The Otijvalunda pans lie within the seasonal Cuvelai drainage system although they

are no longer connected to the main stream. The system includes a large number of

ephemeral salt and clay pans to the north and west of the Etosha pan. Similar pans

that are located close the study area include the Ngandjela pans to the west, the

Onanzi Pan north, the large Natukanaoka Pan and associated smaller pans to the

north-west and west and the Ondangwa Pan and Lyapeke Pan to the east (Scott,

2013). Birds use these pans opportunistically depending on the availability of water.

The pans’ ability to hold water also varies.


Scott (2013) states that since no obvious ecological differences exist between the

habitats of the eastern and western pans, the bird species are expected to be similar

on the pans.

The proposed project poses two potentially significant impacts to the bird species

that occur there namely physical disturbance and habitat destruction. In the case



P a g e 7 5

of physical disturbance, birds may simply leave the area and relocate to a nearby

suitable habitat. However, the concern lies with breeding and nesting birds.

Bustards are especially sensitive to disturbance during nesting periods, and may

easily desert the nest (Scott, 2013). The species create their nests on bare ground

and usually have a clutch of 2-3 eggs. Noise associated with blasting and

construction, especially in the grassland habitats could therefore pose a significant

risk to the species occurring in the immediate vicinity of the Otjivalunda pans.

Similarly, the Chestnut-banded Plover breeds on the pan edges. Their breeding

season is from April to May when some mining activities may already have started. It

usually takes another couple of months (i.e. the dry season when mining is likely to

occur) for them to rear the chicks until they fledge. Any movement of vehicles in the

pan edge habitat are therefore likely to have a severe impact on the species.

The second impact refers to potential habitat destruction. Based on the information

provided in this report, the most significant damage will be incurred on the

wetland/salt flats habitat, with secondary impacts associated with the pan edges

(associated with the movement of vehicles and people) and grassland habitats

(Scott, 2013). During the dry season, when mining activities will take place, the

occurrence of wetland bird species will be limited, but resident species such as the

bustards, Southern Ground Hornbill and the Chestnut-banded Plover may be

affected by the mining activities. Because similar habitats occur in the vicinity of the

pans, the impact of mining on bird species is expected to be both local and

temporary. Although birds will likely leave the area during construction and

operation, they may well return once activities have ceased.

The following conclusions can be drawn with regard to the potential impact of

mining:

Bird species will most likely leave the area during construction and mining

activities, returning only once activities have ceased.

Several suitable habitats are located in the area, and the impact is therefore

only expected to be local and temporary in nature.

The wetland bird species likely to occur at the Otjivalunda pans rely on water,

mud and a slightly saline environment. Therefore, as long as these features

remain at the pans, they are likely to return to the habitat even if it is altered

by mining.

After mining has ceased the wetland/salt flats habitat at both pans will be a

different kind of saline environment that might draw different bird species.

The pan edges are a significant habitat for the Chestnut-banded Plover.

Therefore if the habitat is destroyed by the proliferation of heavy vehicles,

changing the habitat into a disturbed, muddy shoreline, plovers may not

return to the area at all.



P a g e 7 6

The impacts associated with mining are likely to be much more severe if both

of the pans are mined at the same time.

Mitigation

Mining activities at the two pans should not be undertaken at the same time (i.e.

a phased approach is recommended where construction at one pan only

commences once the other has successfully been rehabilitated.

Because the field visit took place under unusually dry conditions, at least one visit

after the next good rains should be taken to ascertain the presence and usage of

the area by species such as Chestnut-banded Plover and flamingos.

Destruction of nesting habitats including the 1) grasslands with drainage lines, 2)

pan edges and 3) trees associated with the mopane shrubland should be

avoided.

A demarcated route should be followed, especially on the pans' edge (which is

likely to be inhabited by the Chestnut-banded plover), and off-road driving

should be prohibited.

Ongoing awareness should be promoted about the negative impacts of

disturbance, especially to breeding birds; and of poaching.

Monitoring

Monitoring should commence from the time of construction and should take

place on an ongoing basis until the mining site is decommissioned and

rehabilitated.

It should focus on any signs of bird mortalities resulting from the construction and

operation of the mine, and especially in the identified sensitive areas, namely

pan edges and grasslands.

While mining the eastern pan, comparisons should be made to the unutilized

western pan to determine the effects of disturbance.



P a g e 7 7

Summary



HABITAT DESTRUCTION AND PHYSICAL DISTURBANCE OF SENSITIVE BIRD SPECIES

EXTENT Site specific Site specific Site specific Site specific Site specific Site specific

DURATION

Long term (will

cease after

operation)

Long term Long term Long term Long Long

INTENSITY Medium Medium Medium Medium Medium Medium

PROBABILITY Definite Highly probable Definite Highly probable Definite Highly probable

STATUS Negative Negative Negative Negative Negative Negative

DEGREE OF

CONFIDENCE IN

PREDICTIONS

High High High High High High

SIGNIFICANCE Medium Low Medium Low Medium Low



P a g e 7 8

7.3.3 LOSS OF OR DAMAGE TO ARCHAEOLOGICALLY SIGNIFICANT SITES

Archaeological significance of the Otjivalunda pans

In his assessment, Kinahan (2013) identified two archaeologically sensitive

components. The first relates to historical salt harvesting activities at the Otjivalunda

pans, dating back to the 18th century. Secondly, historical shorelines have recently

been discovered around the Etosha Pan. These shorelines are indicative of a period

of semi-permanent water and extend to include the surrounding pans including the

Otjivalunda pans.


The archaeological significance of the project area is not restricted to either of the

Otjivalunda pans. The historical shorelines extend to most of the smaller

neighbouring pans and are therefore not limited to the Otjivalunda pans.

Additionally, the Nganjela pans to the west also contain high quality salt that has

been mined for hundreds of years by the locals. Similarly to the Otjivalunda pans,

the Ngandjela pans were also briefly mined during 1975-76 under a trial programme

of harvesting and marketing sodium salts by the former South West Africa Company

(Swaco). Remnant mining equipment still remains at these pans.


Damage to or disturbance of archaeological or palaeontological sites/remains may

affect Holocene sub-fossil breccias and related evidence, and/or remains of recent

precolonial human habitation. Such impacts would probably occur in the process of

earth-moving operations or sheet erosion following the removal of gravel lag and

scrub vegetation during earth-moving operations.

The impacts that may occur will however be highly limited, or site specific, albeit by

definition it will be permanent and irreversible. Given the fact that no evidence of

Holocene sub-fossil breccias or recent precolonial human habitation could be found

during the survey it can be concluded that the intensity of impacts and probability of

occurrence is expected to be low.

Mitigation

Kinahan (2013) concluded that the Otjivalunda project area has a relatively low

archaeological/palaeontological sensitivity. Nonetheless, areas of proposed

development activity are subject to heritage survey and assessment at the planning

stage. These surveys are based on surface indications alone, and it is therefore

possible that sites or items of heritage significance will be found in the course of



P a g e 7 9

development work. For this reason a “Chance Finds” procedure has been

recommended in the Environmental Management Plan (EMP).



P a g e 8 0

Summary



LOSS OF OR DAMAGE TO ARCHAEOLOGICALLY SIGNFICANT SITES

EXTENT Site specific Site specific Site specific Site specific Site specific Site specific

DURATION Permanent Permanent Permanent Permanent Permanent Permanent

INTENSITY Low Low Low Low Low Low

PROBABILITY Low Low Low Low Low Low


DEGREE OF

CONFIDENCE IN

PREDICTIONS

High High High High High High

SIGNIFICANCE Low Low Low Low Low Low



P a g e 8 1

7.3.4 LOSS OF CULTURAL SALT HARVESTING RITUALS

Cultural and economical significance of the Otjivalunda pans

Cultural salt harvesting has been practiced at the Otjivalunda west pan for centuries,

not only because of its superior taste and quality, but also since it plays an important

role in the initiation ritual for the transition from boy-manhood (Saayman, 2013). The

fact that there are no other initiation rituals that marks this transition from boy to man

further highlights the importance of salt harvesting as a cultural symbol amongst the

communities. As for the Eastern Pan, salt blocks are dug out which is used for cattle

lick. The salt from this pan is not used for human consumption and does not form

part of the cultural initiation process.

Salt harvesting contributes to the livelihoods of a number of communities in different

ways. For those who live closer to the salt pans, its economic value lies in the fact

that they can use it mainly in food, as medicine or for tannery. In addition, having

salt also provides them with bartering power where they exchange salt for goods or

services for example that of a traditional healer.


Other pans in the area that are used by the communities for salt harvesting include

the Ngandjela and Ngandjela east pans as well as the Ondangwa Pan. The

Ngandjela pans are viewed as the most famous and important salt pans in the area.

However, during the field assessment the interviewed communities indicated that salt

from the Otjivalunda pans are superior in taste and therefore preferred for human

consumption (Saayman, 2013).


The communities harvest the sodium chloride salt from the western pan. By

harvesting this specific salt on a large-scale for commercial purpose from the

Otjivalunda western pan, salt harvesting as a culturally significant activity will be

adversely impacted should the deposit be completely exploited. Since the

invesgitations by Saayman (2013) concluded that most boys use the pan for salt

harvesting, it will deprive the boys of future generations to undergo this initiation

ritual. The culture has however changed significantly over time and is likely to

change further.

The presence of mine workers at the salt pans will change the sense of place as the

young boys will not be alone at the salt pans, having to face the natural elements on

their own. This to some extent might change some of the appeal the pans have as a

remote destination that has to be conquered.



P a g e 8 2

The villages located closer to the salt pans are very remote and many only have a

small cuca shop. Considering the lack of employment opportunities and associated

cash income, along with the fact that they are mainly reliant on subsistence farming,

the costs of having to purchase salt rather than obtaining it for free from the salt

pans, will be high to these communities.

In general, the elimination of the pans as a result of commercial mining activities will

not only take away salt as a source of food and medicine, but it will also take away

a large proportion of the bartering power of communities already faced with

poverty and who are vulnerable to natural disasters such as drought. This will incur

extra costs to them which can further aggravate poverty in some of these areas. A

culture of bartering will have to make way for cash trade to a certain extent.

While this is also true for some of the communities that live further away from the salt

pans, it has been found that they also sell the salt in order to generate an income.

Thus, the selling of salt as a source of income will be adversely affected should

communities no longer be able to harvest salt at the Otjivalunda west salt pan for

free. This in turn will affect their sources of income.

Although the impact of commercial harvesting at the eastern pan and its impact on

the communities is expected to be low, the impact could be of moderate to high

significance on the western pan, especially if the pan is exploited completely.

Should OUME however succeed in preserving a section of the pan, the significance

can be reduced to low.

Mitigation

The Otjivalunda eastern and western pans should not be mined during the same

period or simultaneously, but mining activities should rather be implemented in

phases. The Otjivalunda western pan should be mined first for the next 10 years. At

that stage mining should be considered at the eastern pan. In order to minimize the

impact of large scale commercial harvesting on the cultural significant aspect, only

a portion of the Otjivalunda western pan should be mined. This may only be done

on the following conditions:

The area of the pan that will be mined should not interfere with the areas mined

by the local communities. The portion that is left unmined should be large

enough to sustain the cultural and economic activities of the communities. This is

expected to be between25% - 50% of the pan. This will also include the use of salt

for cattle lick.

A socio-cultural study should be repeated before mining is considered at the

western pan so that the changes in the salt harvesting and selling practices may



P a g e 8 3

be established and the impact of harvesting the salt from that pan commercially

may be tested again.

Sodium chloride should not be mined commercially at the western pan as it is the

main source of salt to the communities.

Mining activities at the western pan should take place as quickly as possible, i.e. it

should be maximum mining during a minimum period.

The mining techniques should be as unobtrusive, small and controlled as possible

when harvesting the trona, i.e. only tracts of the pan where the trona is located

should be mined.



P a g e 8 4

Summary

CONSTRUCTION OPERATION DECOMMISSIONING


LOSS OF CULTURAL SALT HARVESTING: WESTERN PAN

EXTENT N/A N/A Regional Regional Regional Regional

DURATION N/A N/A Long Term Temporary Long Term Long Term

INTENSITY N/A N/A High High High High

PROBABILITY N/A N/A Definite Definite Definite Definite

STATUS N/A N/A Negative Negative Negative Positive (salt pan will

be protected)

DEGREE OF

CONFIDENCE IN

PREDICTIONS

N/A N/A High High High High

SIGNIFICANCE N/A N/A Medium to High Low Medium High positive

LOSS OF CULTURAL SALT HARVESTING: EASTERN PAN




P a g e 8 5



INTENSITY N/A N/A Medium Medium Medium Medium


STATUS N/A N/A Negative Negative Negative Positive

DEGREE OF

CONFIDENCE IN

PREDICTIONS

N/A N/A High High High High (positive)

SIGNIFICANCE N/A N/A Low Low Low Low



LOSS OF ECONOMIC VALUE OF SALT HARVESTING: WESTERN PAN





P a g e 8 6


INTENSITY N/A N/A High Medium High High



DEGREE OF

CONFIDENCE IN

PREDICTIONS

N/A N/A High High High High Positive

SIGNIFICANCE N/A N/A Medium Low Medium Low

LOSS OF ECONOMIC VALUE OF SALT HARVESTING: EASTERN PAN



INTENSITY N/A N/A High Medium High High



DEGREE OF

CONFIDENCE IN

N/A N/A High High High High positive



P a g e 8 7


PREDICTIONS

SIGNIFICANCE N/A N/A Medium Low Medium Low



P a g e 8 8

7.3.5 IMPACT ON FUTURE PLANNED TOURISM ACTIVITIES IN THE CONSERVANCY

Significance of the Otjivalunda pans for tourism development

Because of the close proximity of the Iipumbu ya Tshilongo conservancy to the

Etosha National park, the southern section of the conservancy is expected to have a

moderate opportunity for tourism development. The recent feasibility study by

Humphrey & Brown (2013) investigated the viability of tourism ventures in the area.

Based on their findings, locating a safari lodge on the edge of the Otjivalunda east

pan would:

Provide easy access to the Narawandu gate (which is planned to be opened

for public access in the near future);

Provide a scenic view of the Otjivalunda pan,

Provide access to some of the cultural tourism activities in the area (e.g.

traditional salt harvesting, cattle posts, kraals and water pits);

Provide access to nearby bird watching spots.


A second location for the safari lodge also exists at the Okanga pan which is not

currently earmarked for any development or mining activities. If mining is to take

place at the Otjivalunda east pan, this location will be suitable for the construction of

a lodge.


The main concern is not so much with the development of a salt mine by OUME, but

more about salt mining in general in the area. Even if OUME does not develop the

Otjivalunda pans, the EPL rights may be taken up by another entity.

In their report Humphrey & Brown (2013) states that the viability of a lodge at

Otjivalunda east pan could be limited by the potential mining activities. It would

require a skilled and innovative tourism operator, as well as an experienced private

partner to successfully implement a tourism product in this area if mining activities do

continue.

Because tourism opportunities are limited to the southern extremities of the

conservancy (due to the proximity of the Etosha National Park), mining activities in

the same area could have animpact on the tourism potential of the conservancy.

An additional issue that contributes to the significance of the impact relates to the



P a g e 8 9

overlapping of the mining season with the peak tourism season. Both of these

activities are set to take place during the dry season.

Mitigation

The conservancy should request that the Ministry of Environment and Tourism:

Commission the opening of a second gate which would provide the

conservancy with concessional rights to the Natukanaoka Pan in Etosha;

Allow for the development of a new waterhole on the south-western side of

Natukanaoka Pan to which the Conservancy is granted exclusive rights.

Provide infrastructure inside Etosha National Park so that other nearby

attractions could be visited, thus allowing a circular route and creating an

exclusive entry point to the Park once the Narawandu Gate is opened to the

public;

Grant the conservancy exclusive tourism access to the Pan Point waterhole,

including the right to build and operate a hide.

This would increase the viability of a lodge at the Okanga Pan.

In addition, it is recommended that:

The Okanga Pan be considered the optimal location for the establishment of

a lodge.

The possibility of incorporating the mining site at the Otjivalunda East pan as a

point of interest be considered.

Mining activities at the two pans, not be undertaken at the same time (i.e. a

phased approach is recommended where construction at the western pan

only commences once the eastern pan has successfully been rehabilitated).



P a g e 9 0

Summary



IMPACT ON FUTURE PLANNED TOURISM ACTIVITIES IN THE CONSERVANCY

EXTENT Regional Local Regional Local Regional Site specific

DURATION Long term Temporary Long term Temporary Long term Temporary

INTENSITY Medium Medium Medium Medium Medium Low

PROBABILITY Definite Highly Probable Definite Highly Probable Definite Probable


DEGREE OF

CONFIDENCE IN

PREDICTIONS

Medium Medium Medium Medium Medium Medium

SIGNIFICANCE Medium Low Medium Medium-Low Medium Low



P a g e 9 1

8 CONCLUSIONS AND RECO MMENDATIONS

8 .1 SYNOPSIS OF THE F IVE KEY IMPACTS

The five key ecological and social impacts related to the proposed mine site at the

Otjivalunda pans can be summarised as follows:

Potential impact on endemic aquatic fauna: Although the presence of aquatic

crustaceans at the Otjivalunda pans could not be confirmed during his fieldwork,

Irish (2013) states it would be unusual if they did not occur there. Consequently

based on the precautionary principle, Irish (2013) commented that there is a high

probability of range-restricted, endemic aquatic halophiles occurring at both of

the pans. Therefore completely exploiting both pans could present a fatal flaw

in the project, because it would possibly result in the eradication of potentially

endemic species (Irish, 2013). Recommended mitigation measures include the

preservation of at least a section of both pans as a no-go area. Further

mitigation measures are prescribed in the EMP.

Potential impact on endemic bird species: Due to the close proximity of the

project area to the Etosha pan (both an IBA and Ramsar site) migratory bird

species are known to use the pans Otjivalunda pans as a rest stop on their

migratory path to the northern hemisphere (Scott, 2013). The main impacts

associated with the construction and operation of the mining activities relate to

physical disturbance and habitat destruction of birds. Since birds are mobile

they are expected to leave the area during construction and mining, returning

only once the activities have ceased (Scott, 2013). However, of particular

concern is the presence of Chestnut-banded Plovers occurring on the pan

edges. According to Scott (2013) this species may be severely affected by the

movement of heavy vehicles during breeding or chick rearing stages. As a

result, the potential significance of the impact is rated as medium. This can be

reduced through proper management and monitoring (e.g. avoiding certain

sections of the pan edges) as prescribed in the EMP.

Loss of or damage to archaeologically significant sites: Based on Kinahan’s

(2013) assessment two archaeologically significant components occur at the

Otjivalunda pans, namely past salt harvesting activities, historical shorelines

around the Etosha pan and more recent mining activities at the pans. These sites

are generally of low significance and the potential impacts that may occur are

expected to be highly limited or site specific. A “chance find” procedure is set

out in the EMP for use in the construction and operation phases, to cater for the

protection of existing sites and any new discoveries.



P a g e 9 2

Loss of cultural salt harvesting rituals: Saayman (2013) states that traditional salt

harvesting still has a strong cultural value to the Uukwambi community. It not

only represents the only initiation process from boy to young man, but also has a

significant economic value. The activities associated with industrial mining at the

eastern pan are not expected to exert a significant impact on the salt harvesting

culture, since the pan is not used for the initiation process and the salt are

perceived as less palatable. However, mining activities at the western pan

could potentially disrupt or affect the salt harvesting rituals especially if the entire

pan is exploited. By preserving sections at both pans and not exploiting the pans

at the same time may significantly reduce the impact. Mitigations are

prescribed in the EMP.

Impact on future planned tourism activities in the conservancy: According to

Humphrey and Brown (2013) the Iipumbu ya Tshilongo conservancy has a

moderate potential for the development of tourism. This rating is related firstly to

the close proximity to the Etosha National Park and secondly to the recent

decision by the Ministry of Environment and Tourism to open the Narawandu

gate to the public. Humphrey and Brown (2013) indicate two potential locations

for the establishment of an African Safari lodge, one of which is located on the

edge of the Otjivalunda east pan. Since other options also exist the potential

impact associated with the establishment of mining activities in a moderately

rated tourism potential area, the significance is expected to be medium. Should

the conservancy and OUME succeed in working towards a common goal; the

impact can be reduced to low. Mitigations measures are prescribed in the EMP.

8 .2 CONCLUS ION

The following conclusions can be drawn regarding the effect of the mining process

on the receiving environment:

The main consequence of the mining activities is that the pan surface will be

deeper. The dynamics of the pan (i.e. pooling, rain, evaporation) will most

likely not change.

Based on the absence of an outflow it can be concluded that the water

holding capacity of the pan has never been exceeded (pre-mining).

Therefore the volume of water reaching the pan will probably not change. In

other words, the volume of water on the pan surface post mining will not be

more than what it was prior to mining.



P a g e 9 3

If not completely exploited, salt will re-crystallize on the pan surface. The

resource may be less dense and distributed differently, but processes may still

be able to continue.

With these conclusions in mind, the environmental features most likely to be directly

affected by the salt mining activities on the salt flats, is 1) the effect on aquatic

fauna and 2) cultural salt harvesting. In both instances the primary source for their

survival is sodium chloride (i.e. salt). For this reason the following should apply:

Mining activities at the Otjivalunda east and west pan should not be

undertaken simultaneously. Instead it is recommended that a phased

approach be undertaken whereby the Otjivalunda east pan is mined first

whilst engaging in continuous rehabilitation and monitoring efforts to

determine the effectiveness of the recommended mitigation measures.

Approximately 25% of the eastern pan surface should be left as a no-go area.

Another restriction applies to the mining of sodium chloride – this resource (or

at least part of it) should be preserved to aid the rehabilitation process.

Once the eastern pan has been mined to full capacity, a follow-up cultural

salt harvesting assessment should be undertaken (according to the criteria

prescribed in the specialist report) to re-assess the situation at the western

pan. In other words, the extent to which the salt harvesting culture has

changed in the mean time and the extent to which potential new

development in the conservancy (e.g. the development of a lodge) have

affected the culture.

50% of the surface of the western pan should be declared a no-go zone by

OUME, but the percentage is to be reconsidered following the cultural

assessment in ten years time. This is to preserve the salt harvesting culture,

enabling the community to continue their activities albeit in an altered

manner. The aim at the western pan should be to obtain maximum salt

mining in the minimum amount of time. Continuous monitoring should be put

in place to establish the effect on birds and fauna.

Whilst sodium chloride mining could be allowed at the eastern pan, OUME

should refrain from mining it at the western pan. This, coupled with the

preservation of 50% of the surface area, will ensure that the disturbed areas on

the pan is naturally rehabilitated in the shortest of time, thereby limiting the

potential effect mining will have on the features dependent on the salt (i.e.

aquatic fauna and salt harvesting culture).



P a g e 9 4

OUME will be able to reduce most of the unwanted impacts of this project to

acceptable levels if they implement the proposed remedial measures. It is therefore

important that the measures prescribed in the EMP (Appendix H) are implemented

and monitored, otherwise the impacts identified will remain unacceptable.

It is therefore recommended that the project receive Environmental Clearance,

provided that the EMP be implemented.



P a g e 9 5

9 REFERENCES

Cunningham, T., Kinahan, J., Marsh, A., Stuart-Williams, V., Hubbard, D., Kreike, E., et

al. (1992). Oshanas: Sustaining people, environment and development in central

Owambo, Namibia. DRFN and SIDA.

Curtis, B. (1991). Freshwater macro-invertebrates of Namibia. Madoqua, 163-187.

Curtis, B., Roberts, K., Griffin, M., Bethune, S., Hay, C., & Kolberg, H. (1998). Species

richness and conservation of Namibian freshwater macro-invertebrates, fish and

amphibians. Biodiversity and Conservation, 447-466.

Department of Water Affairs. (1990). Regional Master Water Plan for the Owambo

Region. Windhoek: Ministry of Agriculture, Water and Rural Development.

Hazam, J. (2013, February 22). The Sheya Shuushona and Iipumbu ya Tshilongo

Conservancies. (C. Saayman, Interviewer)

Mendelsohn, J., El Obeid, S., & Roberts, C. (2000). A profile of north-central Namibia.

Windhoek: Gamsberg Macmillan Publishers.

Mendelsohn, J., Jarvis, A., Roberts, C., & Robertson, T. (2009). Atlas of Namibia: A

portrait of the land and its people. Cape Town, South Africa: Sunbird Publishers (PTY)

LTD.

National Planning Commision. (2012). Namibia 2011 Population and Housing Census

Preliminary Results. Windhoek: National Planning Commision.

National Planning Commission. (2004). 2001 Population and Housing Census: Oshana

Region Basic Analysis with Highlights. Windhoek: National Planning Commission.

National Planning Commission. (2004). 2001 Population and Housing Census: Omusati

Region Basic Analysis with Highlights. Windhoek: National Planning Commission.

Omusati Regional Council. (2010). Omusati Regional Council Corporate Profile.

Outapi: Government of Namibia.

Outapi Town Council. (2012). Investor's Guide. Outapi: Outapi Town Council.

World Bank. (1991). Industrialisation/Non-Metallic Minerals. Retrieved March 04, 2013,

from http://www.fdi.net

http://www.fdi.net/

proposed otjivalunda salt mining and soap production · 2013. 11. 15. · mining and soap...

Documents