Summary 
of 
Environmental Impact Assessment and Environmental Management Programme 

for the

Pocket Beach Areas 

October 2002

PREPARED FOR:

Namdeb Diamond Corporation (PTY) LTD		

Project background and study area

Namdeb plans to commission a number of small open cast diamond mines along the Namibian west coast to maintain current production levels. The targeted sites consist of sandy beach deposits spaced at several kilometre intervals. At present four sites (2, 3/4, 11 and 12) are considered for mining.

Diamonds have been mined in this restricted area for some 60 years.  Namdeb has a mining licence for this area and an existing, externally certified environmental management system.

Bio-geographically identified as one of the areas of high endemism in Namibia with a specialised succulent flora and many species of reptiles and insects only occurring in this part of the world, the entire area under investigation is of high conservation value. In addition, fascinating scenery, historic abandoned mining towns and other sites of special interest contribute to the considerable tourism potential of the area. Desert environments with an arid-adapted flora and fauna, old land surfaces that developed over millions of years and specialised habitats such as gypsum crusts and salt pans are extremely sensitive to disturbance.

Key characteristics of the environment are shown below:
 
 	Key characteristics	

Biophysical environment	
Climate	•	arid, coastal fog, strong southerly and south-westerly winds throughout the year, winter and summer rains are possible	
Terrestrial habitats	•	coastal and inland dunes, pans, rocky outcrops and gravel plains 	
Marine habitats	•	sandy shore and rocky headlands, high energy coastline	
Biota of conservation importance	•	seals, seabirds, brown hyena, southern Namib endemic flora and fauna 	
Natural resources of economic importance	•	rock lobster, fish 
•	diamonds	

Socio-economic environment	
Land and marine use	•	at present mining, seasonal rock lobster and other fishing, in future also tourism	
Archaeology	•	shell middens of early to late stone age	
History and culture	•	shipwrecks, historical mine sites 	
Local economy	•	fishing industry and large-scale and contractor based mining, as well as accompanying service infrastructure, provide the bulk of employment in the region	
Infrastructure	•	extensive network of rudimentary roads and tracks exists, some areas disturbed during earlier mining and sampling activities	
Population and access	•	lowest density of any region in Namibia
•	no permanent settlements near the mining sites
•	access restricted because of diamond security regulations	
Social problems	•	high levels of in-migration to Lüderitz
•	HIV/AIDS
•	alcohol abuse	

The harsh, arid environment implies that recovery of disturbed habitats and associated flora and fauna will be slow on land. 

On the marine side, intertidal fauna and flora are similar to other pristine west-coast environments in southern Africa, but harbour many biota indicative of the southern Namib biogeographic province. The high energy environment suggests that biota are adapted to recovering from natural disturbances (i.e. storms, wave action and sediment movement), but evidence is lacking whether or not additional disturbances imposed by mining could pose a threat to marine ecosystems. 

A concentration of archaeological sites in the vicinity of one of the sites to be mined (site 2) may indicate important finds that could be uncovered during the mining process.

Our approach

Environmental studies accompanied the pre-feasibility and feasibility phase of the project and consisted of: 
•	Baseline studies (1997-2001) 
•	Scoping (2001) 
•	Environmental Assessment and Management Programme (2001)
•	Review of Environmental Assessment and Management Programme (this report).

Public participation was included during the scoping and environmental assessment phase in 2001 in form of a) public meetings, b) distribution of an information document, c) a scoping report and d) distribution of summary of the environmental assessment. During this study, Interested and Affected Parties were informed through three newsletters at various stages of the project. Representatives of all line ministries received a complete EIA report for comments.

New aspects raised by Interested and Affected Parties during the current review of the EIA and scoping exercise associated with the proposed power line from Skorpion to serve the pocket beach areas were:

•	Co-ordination in infrastructure development between Kudu gas and pocket beach areas developments and
•	Strong resistance by the public to the development of a power line crossing prime wilderness area in the Sperrgebiet from Skorpion to Chameis.

Baseline studies had been undertaken in 1997 during the exploration phase of the project and included field surveys of land and marine habitats and associated biota, as well as archaeology. The current environmental study consisted of: 

•	Planning guidelines 
•	Marine specialist workshop  
•	Meeting with rock lobster association and
•	Environmental Impact Assessment and resulting Environmental Management Programme. 

The adopted vision for the project is: Namdeb will strive to ensure that, while generating economic benefits from the project, there will be no sign of its mining activities (including current and past infrastructure) or associated impacts within the Study Area, within a maximum period of 5 years from the end of mining each pocket beach.

The definition of the Study Area, from a biophysical perspective, is a 2 km wide strip along the coast, stretching from the existing security fence at Mining Area 1 in the south east, to 2 km north west of Bogenfels Arch. For marine aspects this is the area from the high water mark to 2 km out to sea, for terrestrial aspects from the high water mark to 2 km inland.  

To comply with the vision for the project, various sets of planning guidelines were provided to the mine planning team in the early phase of this environmental study. The impact assessment was based on the final mine plan, partially revised according to these guidelines. 

All biophysical environmental information was mapped and consolidated in a GIS system. This allowed spatial identification of environmentally sensitive areas and so facilitated the provision of planning guidelines, the prediction of potential impacts and development of appropriate management interventions. 

Environmental impacts associated with a potential of a power line route from Skorpion mine to Chameis (one of the options for power supply were not investigated in this study).

For the environmental assessment the following assumption had to be made:

•	Power supply will be provided by a power line from Oranjemund.

Environmentally sensitive areas

The following table lists habitats and areas of environmental importance.  

Habitat	Description	Species of conservation and/or economic importance 	Environmental aspects	
Freshwater springs and seeps	•	east of site 2
•	North-east of Baker’s Bay	Ostrich, gemsbok
springbok, Brown hyena, Jackal	•	only freshwater source for wildlife in an approximately 30 km radius 
•	archaeological sites nearby	
Seal colony	•	Lion’s Head	Cape fur seal	•	food source for larger predators
•	tourism value	
Bird breeding colonies	•	Marmora and Chameis pan
•	Sinclair and Plumpudding  islands 	Damara Tern
African Penguin
Bank Cormorant
Crowned Cormorant
Cape Gannet	•	habitat and breeding site of  red-listed bird species
•	tourism value	
Coastal dune hummocks	•	pockets along seaward side of mine sites 	Desert rain frog,
spiders, scorpions and solifuges (e.g.Ceroma inerme) 	•	habitat for Namib endemic reptiles, amphibians and small mammals
•	habitat for Namib endemic solifuge
•	breeding habitat for coastal birds	
Salt pans	•	south of site 2 (Chameis Pan)
•	north-east of site 3/4 (Marmora Pan)	Potentially endemic aquatic insects and crustaceans	•	breeding habitat for red data birds
•	potential of endemic aquatic insects 
•	tracks create lasting negative visual impact	
Sand plains 	•	Bay View production site	Succulent plants: e.g. Amphibolia rupis-arcuatae, Fenestraria rhopalophylla, 
Cephalophyllum ebracteatum	•	remnants of succulent Karoo vegetation
•	potential of endemic insects associated with pockets of succulent vegetation	
Rock outcrops 	•	throughout study area	Succulent plants: e.g.
Juttadinteria suavissima  Psammophora modesta	•	remnants of succulent Karoo vegetation
•	potential of endemic insects associated with pockets of succulents 	
Lichen fields	•	near Boegoeberg turn-off on main road	Dwarf succulents: e.g. many Crassulaceae	•	high lichen diversity
•	high diversity of protected dwarf succulents
•	potentially susceptible to dust  	
Gravel plains	•	east of site 2
•	Bogenfels turn-off	Dwarf shrubs: e.g. 
Marlothiella gummifera, Juttadinteria 	•	susceptible to tracks 
•	some southern Namib endemics	
Rocky shores	•	Green Precipice
•	Dernburg Bay
•	Lion’s Head		•	feeding habitat for seabirds
•	habitat for kelp beds  	
Sandy beaches	•	pocket beaches 1, 2, and 3/4	Giant pill bug (Tylos granulatus)	•	forage area for seabirds
•	habitat for sandy beach fauna and flora	
Kelp beds and reefs	•	rocky shore and nearshore reefs	Rock lobster	•	habitat for juvenile rock lobster, fish and benthic species	
Animal lairs and dens		Brown hyena, jackals	•	potential breeding site	
Historic, archaeological and fossil sites	•	throughout study area		•	potential excavation material 
•	historic and cultural  heritage 	

The project

The following activities and structures are associated with the different phases of the project (see table). Accompanying diagrams show the extent of the production sites, the position of infrastructure  and site layouts.  The life span of the project is estimated to be five years.

Prospecting and construction	
Vehicle access	Prospecting and surveying for road material and power line may require access to areas presently not serviced by tracks.  	
Clearing of vegetation	Infrastructure erected at Bay View production site requires clearing of vegetation.	
Construction	Construction activities require temporary accommodation and ablutions, work and storage areas for construction modules and materials as well as a waste disposal plan.	
Upgrading of roads	All existing access roads (8.3, 14 and 18 km) to the site from the main Lüderitz to Oranjemund road will be upgraded to 7 m width. The existing road between site 3/4, Baker’s Bay and Bogenfels will be paved (gravel hard cap) and re-aligned in some places.	
Borrow areas	Two existing borrow areas near site 2 and Baker’s Bay will be used for road material. A new one may be required near Bogenfels.	

Infrastructure	
Transport route for bucket wheel excavator 	The transport route for the bucket wheel excavator will follow the existing road from Oranjemund to Lüderitz to the Bogenfels turn-off. A re-alignment is required here to allow for the turning circle of the heavy equipment.	
Treatment and recovery plant	The treatment plant (scalping, screening, DMS) will be modular and movable, constructed and assembled off site and then transported to site.  The plant will be positioned next to the block being mined. A recovery plant will be placed at the northern side of a rocky outcrop at Bay View production site.	
Power lines	The 132 kV power line will largely follow existing roads from Oranjemund to Chameis and site 2.  The line will be on wooden poles.	
Telecommunications	An above-ground fibre optic line will be installed to Baker’s Bay, following existing tracks. Two new microwave towers are envisaged: one at Baker’s Bay, one at Bay View production site  	
Office and maintenance facilities	Vehicle and transport workshop, mechanical and electrical workshop, mining vehicles parking area, tank farm, office block with parking,  washbay, potable water reservoir, sewage treatment plant, interim waste disposal sites and main HT substation will be erected at Bay View production site.	
Desalination plant	A desalination plant will be positioned at Baker’s Bay.  It will use an existing concrete platform and ponds for seawater abstraction.  Brine disposal will be into the sea.  The plant will require 63 m3 seawater/day of which 40 % will be transformed into potable water, the remainder will be pumped back into the sea.	
Process water	Water from the dewatering operation will be used in the plant and fluidiser.	
Accommodation	Existing facilities at Baker’s Bay will be upgraded to accommodate approximately 100-150 people.  This will include 1-, 3- and 8-bedroom units, kitchen and mess, clinic, gymnasium, television rooms, interim waste disposal site and a recreation club.  A wooden fence will be erected around the accommodation area.	

Waste disposal	
Industrial waste	Oil, fuel and other liquid waste will be stored and collected in designated containers with bunding where appropriate (e.g. tank farm and oil storage).  Disposal will be at Mining Area 1 oil reclamation plant or transported to Lüderitz for recycling.  Scrap, building material and other industrial wastes will be collected, separated into recyclable and disposable material and trucked to Oranjemund for disposal at the managed waste site or further transport in case of recyclable material.	
Domestic waste	All domestic waste will be separated into recyclable and disposable material, collected and disposed at Oranjemund’s existing managed waste site or transported further for recycling.	
Sewage	Two sewage treatment plants using a combined filtering and microbial system (Lilliput) will be erected, one at Baker’s Bay, one at the production site. Disposal of the treated effluent will be into French drains. In case of failure, sewage will be transported to Oranjemund and disposed in the regular sewage system.	

Operation	
Site 11/12	Bucket wheel excavator, front end loaders and excavators will be used to mine site 11/12. This involves overburden stripping, excavation of diamond bearing gravel, infield screening and transport of concentrate to recovery. Overburden all deposits will be fluidised and disposed in the sea resulting in beach accretion. A seawall will be required to protect the mining activities. 	
Site 2 and 3/4	Both sites will be mined using the bucket wheel excavator and front end loaders. Overburden will be discharged onto the mined out area. Diamond bearing gravel will be pumped to a mobile Infield Screening Plant and DMS, oversize gravel will be discarded in mine void, undersize pumped onto beach. A seawall will be required at each site.	
Phasing of mining	Mining will start at site 11/12, then move to site 2 and eventually to site 3/4. Life of mine: approximately 5 years.	
Vehicle traffic	Steady, low level of traffic is expected between Bogenfels, Baker’s Bay and the production site. 	
Work  cycle	The mining activities are planned to operate on a continuous 24 hour operational shift basis.  A 2 week on, 2 week off cycle is envisaged at present.	
Human resources and recruitment	The work force will largely come from the existing skills base in Oranjemund, but some additional employment may be provided. 	
Services	Although the bulk of supplies will be provided through Namdeb’s procurement office, some purchases of consumables as well as services may be outsourced.  These include: cleaning, catering and transport services, building maintenance and rubber and tyre services.	

Environmental aspects and management guidelines

The table below provides a summary of the aspects that require management. All management guidelines will be implemented and incorporated in Namdeb’s Environmental Management System (EMS). For brevity only the main aspects are listed here, an impact assessment and more detailed guidelines are provided in the Environmental Assessment Report and Environmental Management Programme.
 
ACTIVITY	MANAGEMENT AND CLOSURE GUIDELINES	
Mining		
Dry mining	•	Back-fill as far as possible during the mining process.
•	Breach and flatten seawalls. 
•	Avoid sensitive areas for dumping and stockpiling.
•	Remove and store topsoil and plants where vegetation is affected.
•	Rehabilitate dump, potential void and stockpile areas.
•	Contour mined out areas to facilitate natural reshaping.	
Bucket wheel mining	•	Develop cumulative impact framework. 
•	Implement marine, Brown hyena and vegetation rehabilitation monitoring programme.
•	Back-fill as far as possible during the mining process.
•	Remove and store topsoil and plants where vegetation is affected. 
•	Breach seawall and contour mined areas.	
Infrastructure	
Borrow pits and quarries	•	Avoid sensitive areas.
•	If unavoidable, relocate plant species of conservation importance. 
•	Rehabilitate.
•	Position out of sight from finally remaining access routes.	
Power line	•	Use bird flappers on all west-east running lines and along Marmora pan.
•	Avoid sensitive areas for position of pylons and support structures.	
Waste disposal and littering	•	Waste management programme.
•	Environmental Awareness programme. 
•	Follow guidelines regarding storage and removal of oil/fuel spills.	
Sewage treatment	•	Provide for emergency diversion in case of failure of Lilliput system.	
Vehicle tracks	•	Prohibit off road driving.
•	Clearly demarcate track and gravel road network.
•	Rehabilitate tracks and close off redundant tracks.	
Vehicle traffic	•	Speed limits, speed bumps and warning signs in all wildlife corridors.
•	Implement strict penalties in case of wildlife casualties.	
Poaching and  collecting of firewood, plants and artefacts  	•	Prohibit fishing, hunting, collecting of plants, artefacts and firewood.
•	Lion’s Head to be declared “no-go” area.
•	Impose strict control and penalties.	
Clearing of vegetation 	•	Minimise “footprint”.
•	Remove and store topsoil and vegetation, where appropriate, prior to construction.
•	Rehabilitate.	
Archaeological sites	•	Relocate, store safely and re-construct archaeological sites that cannot be avoided during the mining operations.	

Our conclusion and key recommendations

In socio-economic terms the proposed project is designed to sustain rather than increase current production levels. This means Namdeb’s current workforce will be maintained and re-positioned and few new jobs will be created. However, increased expenditure associated with the construction phase of the project and services that could be outsourced are likely to positively benefit communities in Lüderitz, Oranjemund and Keetmanshoop. If the project does not go ahead there will be job losses within Namdeb’s current workforce, posing a negative socio-economic impact, unless people find other employment. 

The proposed project will largely result in negative, local environmental impacts on land and negative impacts of unknown extent and magnitude on marine ecosystems. In addition, both land and marine environment, could suffer from cumulative impacts of unknown magnitude as a result of current diamond mining operations to the south and possible future mining.

On land this affects populations of coastal endemic vegetation and associated fauna, as well as scenic areas in the vicinity of future tourism nodes (e.g. Bogenfels). In the marine environment this may affect food sources and habitat of commercially important species such rock lobster and fish. For these reasons the restoration of disturbed habitats on land and in the sea are fundamental and a vision and principles to achieve minimal disturbance and recovery of disturbed habitats have been adopted by this project. It is thus critical that the past practise of not actively rehabilitating disturbed areas and not adequately monitoring adverse impacts is reversed.

The following main recommendations arise from the vision, principles and environmental impact assessment for the Pocket Beach Areas Project:

Cumulative Impact Framework
•	A framework must be developed for the entire Namdeb licence areas to provide a context for each proposed mining activity (further detail in EIA). 
•	This framework must include current and anticipated marine mining and rock lobster activities. 	
	
Marine and land monitoring 
•	Implement the recommended marine monitoring programme to substantiate over time the magnitude of impacts and rate of recovery.
•	Implement the Brown hyena monitoring programme to quantify potential impacts on this key predator.
•	Prior to the commencement of mining finalise ecological baselines for the invertebrates and marine habitats.	
	
Land based rehabilitation
•	Facilitate recovery of disturbed land habitats by adopting ecological principles and replicating natural processes during restoration (further detail in EMP).
•	Monitor recovery of rehabilitated areas. 
•	Rehabilitate, wherever possible, throughout the operational phase.
•	Close and rehabilitate all tracks and infrastructure within the 5 km coastal strip between MA1 and 5 km north of Bogenfels Arch (not used by Namdeb or future land owner). 	
	
Socio-economic aspects
•	Outsource services and supply delivery, where possible, to small enterprises and local suppliers in Oranjemund, Lüderitz and Keetmanshoop.
•	Continue, if possible, to support local communities in Lüderitz and Keetmanshoop and improve their health and educational welfare. 
•	Publicise and make available information from environmental monitoring programmes.	

The Namibian government should set up an appropriate body to examine the desirability and feasibility of setting aside 20 % of the marine area and 10 % of the terrestrial areas as dedicated conservation areas.

The implementation of the EMP for the Pocket Beach Areas, is critical to the mitigation of the potentially significant impacts associated with the proposed mining activities. It is thus recommended that it is a condition of approval of this mining that:

•	The EMP is integrated with Namdeb’s Environmental Management System,
•	Namdeb retains its ISO 14001 certification,
•	Namdeb continues to report annually to its Environmental Steering Committee on its performance against the requirements of the EMP.

Antje Burke & John Raimondo, 28 October 2002