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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-1

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN AND


INDICATORS

8.1

Introduction

Since SEA is driven by the concept of sustainability, the logical consequence of an SEA should be
guidance on how sustainability principles can be mainstreamed throughout the life cycle of activities
and projects. This guidance is provided through the Strategic Environmental Management Plan
(SEMP) which will be overseen by a broad-based SEMP Steering Committee and managed by a
dedicated SEMP office (see section 8.3 below).
The SEMP is an over-arching framework and roadmap for addressing the cumulative impacts of a
suite of existing and potential developments. The manner in which this is achieved is by setting limits
of environmental quality (i.e. performance targets) that need to be achieved by the proponents of
individual projects. In situations where a SEMP exists, individual EMPs prepared for each mine or
project, will need to incorporate all relevant environmental management specifications (Figure 8.1).
Thus, the SEMP does not remove the obligation from a developer for conducting a project-specific
Environmental Impact Assessment (EIA) and abiding by a site-specific Environmental Management
Plan (EMP). On the contrary, all projects listed in the Environmental Management Act (EMA) of
2007, must undergo an EIA prior to authorisation and implementation. Moreover, each project has a
number of permit obligations that must be met for the developer to be in full compliance with the law.

Figure 8.1: Planning hierarchy from strategic to project levels (source: modified from DEAT 2002)

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-2


In most examples found in the literature, a SEMP follows a broad land use planning process or
Regional SEA, in which case it directs what should be allowed in an area and how it should be
implemented. However, the Central Namib Uranium Rush is neither a policy, plan nor programme,
but rather a collection of mining and related projects, each being conducted by individual companies
that are not related to each other, and in many cases, undertaken in isolation of each other. The SEA
will not stop any of these projects, as some (e.g. Rssing Uranium mine) have been in operation for
many decades and others are in an advanced stage of planning. However, since all projects need to
revise their implementation plans and strategies from time to time, the proponents will still benefit
from the SEA and the accompanying SEMP. In many cases, there are projects still at the prefeasibility stage, and some not yet identified. These newcomers will gain a great deal from the SEA
and SEMP. Thus, the SEMP is intended to guide both mining and other related industrial
developments in the Erongo Region so that they do not unnecessarily compromise the natural, social,
economic and physical environments.
In order to present a SEMP that is useful for guiding development along a sustainable pathway, the
SEA initially developed a good understanding of the forces and dynamics of the uranium industry,
and the extent to which mining has led to the development of other industries (e.g. chemical
production), the need for infrastructure (e.g. roads, pipelines and powerlines) and the need for other
resources (e.g. water, energy, labour and social infrastructure). In this way, it was possible to
understand the cumulative impacts of the Uranium Rush.
However, uranium mining is only one part of the picture. In the central Namib, there are other
industries that have individual and cumulative impacts, and many activities beyond the Erongo
Region and Namibia add to the multitude of positive and negative impacts that need to be managed.
Whether global, national or local, coupled or stand-alone, a multitude of activities and projects drive
the economy. It is important in the context of Namibia and the Erongo Regions relatively small
economy, to maintain and increase the diversity of investments so that the country can withstand
shocks such as the recent global economic crisis. Also, a diversified economy will be less vulnerable
when the Uranium Rush tails off or ceases altogether.

Figure 8.2: The


broad sequence of
activities that
culminated in SEMP
development

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-3


An understanding of the development drivers and the vulnerability of the receiving environment has
led to the identification of the responses needed at strategic levels particularly from high level
decision makers, be they government, parastatal, local authority or corporate. They are primarily
responsible for ensuring that public fears are addressed and aspirations are met, and that an enabling
environment is created for sustained growth and development. Similarly, developers are responsible
for implementing best practice, whether defined by local legislation or industry norms. Good practice
means doing more than the bare minimum. The uranium industry (and others) must contribute
willingly and generously to worthy community initiatives, co-invest in physical, social and human
development and help maintain ecological integrity. Paying taxes and royalties is the bare minimum;
best practice requires an extra effort.
Fundamental to the development of the SEMP was setting the Environmental Quality Objectives
(EQOs) to try and define the limits of acceptable change that can be tolerated due to the Uranium
Rush. As noted in Figure 8.2, and in Chapter 2, developing the EQOs required a combination of
public and expert opinion, scientific research and an examination of policy, ethical and legal
requirements. These informants constituted the input into the EQOs. The EQOs each articulate a
specific goal, provide a context, set standards and elaborate on a small number of key indicators that
need to be monitored. These collectively make up the SEMP (see section 8.4), which is the
framework within which individual projects need to be planned and implemented and within which a
number of institutions need to undertake certain actions. If the required investments are made (e.g.
physical and social infrastructure), institutions are strengthened and partnerships are forged,
governance is improved and individual projects are well planned and implemented, there is a good
chance that the Uranium Rush will contribute significantly to the goal of sustainable development of
the Erongo Region and Namibia. This is the desired outcome.
8.2

Vision, EQOs and indicators

For the Erongo Region to achieve its vision of producing an environmentally-friendly uranium
brand, there needs to be a concerted and sustained effort by all stakeholders to commit to the EQOs
and the recommendations made in this SEA. Of course, this commitment requires the bottom line,
or in this case triple bottom line, to be articulated in precise and practical terms.
Knowing what needs to be done, and what can realistically be done to avoid or reduce negative
impacts, enhance benefits and maintain good governance, required months of research, extensive
public participation and careful analysis of issues and options. Having done this, the SEA team
identified 15 Environmental Quality Objectives (EQOs) that are a collective proxy for measuring the
extent to which the Uranium Rush is moving the Erongo Region towards or away from a desired
future state. There are 30 desired outcomes, 43 targets and 118 indicators spread across the EQOs
(Figure 8.3).
An EQO is typically a non-enforceable goal, which specifies a target for environmental quality which,
it is hoped, will be met in a particular environment. If EQOs are set by regulation, they are usually
referred to as Environmental Quality Standards. For the purposes of the Uranium Rush SEA, we use
the term EQO, whether the objective is defined by society, policy, law or International
Agreement(s).

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-4

Figure 8.3: The structure of the SEMP and the public disclosure process
In some cases, EQOs are a vague form of generally desirable objectives, but in other cases, they might
be concrete quantitative measures. Wherever possible, they should be acceptable to all key
stakeholders, quantifiable, verifiable and outcomes oriented.
Implicit within all EQOs is a minimum management objective that any changes to the environment
must be within acceptable limits and that pro-active intervention will be triggered by the responsible
party to avoid unwanted changes that breach a specified threshold. Whilst many of the EQOs are
interrelated and thus difficult to compartmentalise, they are arranged under broad themes for purposes
of illustration (Figure 8.4).

Figure 8.4: The 15 EQOs clustered within broad themes1.

The EQOs are not presented in order of priority all are equally important.

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-5


8.3

Management, monitoring and reporting

Throughout this SEA, stakeholders repeatedly asked who will manage the Uranium Rush? This is a
valid question given that Namibia has a shortage of skills generally, and especially at management
level.
The best way for Namibia to manage the Uranium Rush is for decision makers at all levels to enter
into meaningful partnerships with each other, so that the country can utilise all available skills.
However, it is recommended that Government take overall responsibility for implementing the SEMP,
through a close partnership between MME and MET. There thus needs to be a broad-based steering
committee that oversees the functioning of an office to administer the SEMP (hereafter referred to as
the SEMP office), that should be based both in Swakopmund and Windhoek (Figure 8.5).
The SEMP office needs only a small number of full-time staff members, who will manage all the
monitoring, communication and reporting. The SEMP office must collate the data required to assess
the key performance indicators listed in the EQOs (see section 8.4) and compile the annual SEMP
report. Data for many of the indicators are already being collected by various institutions for various
purposes (e.g. tourist satisfaction surveys, wildlife monitoring, infrastructure inspections), but more
work may be required to set up new monitoring programmes and establish the necessary sampling and
reporting protocols (radiation, groundwater and air quality). Therefore the SEMP office will have to
manage field work programmes with support from specialist institutions such as Gobabeb, GSN and
DWA. Tasks such as questionnaire surveys could be conducted by students or tour operators, etc.
Ideally, the work could be done efficiently and cost-effectively, but the quality and integrity of data
must not be compromised.
Seed funds for capacity building in MME have been secured through the current BGR-GSN Project
for Technical Cooperation. MME, MAWF and MET will need to integrate their specific tasks into
their strategic plans. It is expected that the uranium industry will contribute towards funding the
SEMP office in the future, and that the Chamber of Mines will facilitate this.
It is recommended that the SEMP Steering Committee meets twice per annum, early in the year
(February) and then again in October. The first meeting will approve the annual work plan, while the
second meeting will review the draft SEMP report. After this meeting, the SEMP office will be in a
position to finalise the report so that it can be released to the public by end November each year.
The proposed Terms of Reference for the SEMP Steering Committee are as follows:

Voluntarily serve the SEMP process (i.e. no salary, sitting allowance, per diem, etc.);

Appoint/reappoint2 the SEMP coordinator and assistant (should be a 3-year contract,


renewable);

Approve annual work plan, responsibilities and budget;

Source funds for the budget;

Review and approve the annual SEMP report;

Advise GRN on SEMP and Uranium Rush progress and dynamics (i.e. refine/adjust
scenarios).

Through MME

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-6


The SEMP coordinator should be an institution, which is contracted by the GRN through the Steering
Committee, to develop and nurture partnerships, oversee monitoring and data gathering, and compile
the SEMP annual report.
Monitoring and auditing of the implementation of the plan or programme is required to assess
whether the sustainability criteria are being met and the guidelines are being adhered to. A
monitoring and auditing programme should be developed for this purpose. The sustainability
indicators, formulated as part of the SEA, are tools that can be used for monitoring the extent to which
the sustainability criteria are being met. Monitoring and auditing guides the adjustment of the plan
and projects, as well as the extent to which enabling investments are being made and institutions are
functioning adequately (Figure 8.6).

Figure 8.5: Proposed structure for the management of the SEMP

Figure
8.6:
Using
a
precautionary approach to
managing strategic impacts in
relation to the limits of
acceptable change (Source:
adapted from Binedel and
Brownlie, 2007)

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-7


The information obtained through monitoring and auditing is required for completion of an annual
SEMP report and refinement of the EQOs, their indicators and data gathering methods. It is important
that procedural arrangements are established and maintained to ensure that the monitoring system
runs effectively and that data from year to year are replicable, comparable and auditable. Also, it
should be noted that monitoring does not end with the collection of environmental information but
includes their evaluation, interpretation, reporting and recommendations for corrective action.
Information received through monitoring can be of assistance when considering appropriate remedial
action by the relevant stakeholders.
Thus, the SEMP office, with assistance from its many partners, must produce an annual SEMP report
that provides a clear indication of what targets are being exceeded, met or not met. The recommended
structure for the SEMP report is shown in Box1.

BOX 1: EXAMPLE OF THE TABLE OF CONTENTS FOR THE ANNUAL SEMP


REPORT
Title and period: e.g.
Uranium Rush SEMP Report, 2010
Compiled by (Name) and date completed
Inside page
Address of main author(s)
Citation (e.g. Uranium Rush SEMP Report, 2010. Published by the Government of the Republic of
Namibia, Ministry of Mines and Energy, Windhoek)
Disclaimers (if any)
Place where copies of the report may be obtained (e.g. GRN website)
Executive Summary (<5 pages, includes key findings, conclusions and recommendations)
Acknowledgements
Co-authors
Data gatherers and data providers
Sponsors
Steering Committee
EQOs and indicators (keep this succinct preferably < one page per indicator)
Name of EQO
Description of targets and indicators
Status of performance: Exceeded/met/not met/unsure
Assessment: Narrative report on status of performance include tables/graphs that illustrate the
most important trends. Key questions are:

What are the root causes for good/poor performance?

Are there lessons to be learnt?

Is there a need for modifying the indicator?

Do we need to improve/change monitoring methods?

Data source: List who provided the data, and the locality of the data (for future reference). The data
do not need to be in the SEMP report they could be bound into a separate report.
Public consultation and input:
o

List the extent to which communications or submissions were received from the public.
Space permitting, letters/faxes/emails or SMSs can be attached, or at least referenced.

List dates, venues, agendas and minutes of meetings held (if any).

Annexures (results, lab reports etc)

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-8


8.4

Environmental Quality Objectives

As illustrated in Figure 8.4, the following 15 EQOs are grouped according to the following themes:

Economic: EQO 1-2

Social: EQOs 3-6

Biophysical and ecological: EQOs 7-8

Sense of Place: EQOs 9-11, and

Governance and infrastructure: EQOs 13-15.

Since the EQOs are a synthesis of the content and analysis provided in Chapter 7, the reader is
referred to Chapter 7 for more detailed background information. The EQOs presented below provide
the key targets and indicators, together with the relevant organisation(s) responsible for the
implementation of the actions required to meet the targets. The sources of the data needed for
monitoring are also indicated.

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-9

EQO 1: SUSTAINABLE SOCIO-ECONOMIC DEVELOPMENT


Aim of this EQO: The Uranium Rush improves Namibia and the Erongo Regions sustainable
socio-economic development and outlook without undermining the growth potential of other sectors.
Desired outcome

Target3 and performance


indicators

Party responsible for Data source


implementation

1. Income and
economic
opportunities
from the
Uranium Rush
are optimised

Target: Contribution of mining


to the economy increases over
time
Indicators:
Royalties are paid in full by
mining companies
Corporate taxes are paid in
full by mines and
associated companies

Mines must pay the


royalties, taxes, and
other fees
MME & MoF must
ensure that payments
are done

GRN budget
documents
(estimates of
income)
GRN
accountabilit
y report (e.g.
show any
deviations on
default rates)
Mine and
MME annual
reports

Increasingly, inputs are


sourced locally rather than
imported

Mine and
CoM annual
reports

Uranium mines are not


granted EPZ status

MTI

Mines
Chamber of Mines
must provide
encouragement
MTI

There are other indicators relevant to this EQO that are not included here, such as minimising opportunity costs, coinvesting in infrastructure, etc. They are omitted because they are covered by other EQOs.

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-10

EQO 2: MINE CLOSURE AND FUTURE LAND USE

Aim of this EQO: To maximize the sustainable contribution mines can make post closure to
society and the region, and to minimize the social, economic and biophysical impacts of mine closure.
Desired outcome
1. Companies
have approved
closure plans in
place which
ensure that
there are no
significant
post-closure
long term
negative socioeconomic,
health and
biodiversity
effects from the
mine. These
plans should
address
planned as well
as premature
closure.

Performance targets and


Party responsible for
indicators
implementation
Target:
The planning process is
Mines
initiated early (in the
MME
feasibility study stage) to
ensure that reasonable
opportunities for post
closure development are
not prevented by
inappropriate mine design
and operations.
Mine closure plans need
to be based both on expert
and stakeholder input, and
consider site specific
risks, opportunities and
threats as well as
cumulative issues. These
must include
socioeconomic
opportunities for nearby
communities and the
workforce, demolition and
rehabilitation and post
closure monitoring and
maintenance.
The plan needs to contain
accepted and agreed
objectives, indicators and
implementation targets.
The plan needs to be
subjected to periodic
critical internal and
external review.
Closure plans must have
written GRN approval.
Indicators:
The contents of the plan
are consistent with the
IAEA guidelines,
Namibian regulations and
policies and the Namibian
Mine Closure Framework.

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Data sources

Mine closure
plans

MME

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-11


Desired outcome
2. Mines have
adequate
financial
resources to
close
operations
responsibly and
to maintain
adequate
aftercare.

Performance targets and


indicators
Target:
The financial provision for
mine closure needs to be
based on cost calculations
including:
employee costs
(retrenchment
provision, new
employment
opportunities, retraining costs);
social aspects
(sustainability of
associated
communities), an
exit strategy (that
is, the process by
which mines cease
to support
initiatives), social
transition (that is,
communities
receiving support
for transition to
new economic
activities);
demolition and
rehabilitation
costs
(infrastructure
break-down,
salvage and/or
disposal at the site
or transition to
end uses),
ecosystem
rehabilitation
costs of the site;
post closure
monitoring and
maintenance; and
project
management
(administration
and management
costs during the
decommissioning
period).
Companies, in conjunction
with regulators, need to

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Party responsible for


implementation

Data sources

Mines
MME

Mine closure
plan

Mines in
conjunction with the

Financial
audit reports

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-12


Desired outcome

Performance targets and


indicators
establish an independent
fund to provide adequate
financial resources to fully
implement closure.

Party responsible for


implementation
regulators

Data sources

Indicators:
Closure cost estimations
contained in the closure
plan
Financial audit reports of
the closure fund.
3. The
Government
has appropriate
mechanisms in
place to
approve mine
closure plans,
financial
instruments
chosen for
implementation
and to effect
relinquishment
back to the
state.

Target:
Adequate regulations
applicable to mine closure
are contained in the
relevant legislation.
Indicators:
Mine closure regulations
are adequate to govern:
review and approval
of mine closure plans;
financial guarantees
and sureties;
implementation
review,
relinquishment and
transfer of liabilities
to the subsequent land
owner.

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MME

Regulations
to the
Minerals Act

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-13

EQO 3: PUBLIC HEALTH


Aims of this EQO: Workers and the public do not suffer significant increased health risks from the
Uranium Rush
Desired Result

1. Disease rates
amongst the
public and
employees of
the mining and
associated
industries are
not increased
as a result of
the Uranium
Rush

Targets and Performance


Indicators
Targets:

Party responsible for


Implementation
Mines (which must
undertake regular
Increments in the
environmental and
concentrations of uranium,
health monitoring)
thorium and health-relevant
Chamber of Mines
nuclides of the uranium,
thorium and actinium decay Ministry of Mines and
chains such as Ra-226 and
Energy
Ra-228 (above respective
Ministry of Health and
background concentrations)
Social Services
in air and water (ground
Ministry of
and surface) that originate
Environment and
from uranium mines, must
Tourism
be constrained so that the
National Radiation
cumulative radiation dose
Protection Authority
to members of the public
does not exceed 1 mSv per Ministry of Works,
Transport and
annum above background.
Communications.

Dose limits for


practitioners working with
radiation sources, e.g. mine
employees, industrial
radiographers, medical
radiographers, radiologists
(doctors) do not exceed 20
mSv per annum averaged
over 5 years, i.e. 100 mSva
over a 5 year period with a
ceiling of 50 mSv per
annum in a single year.

No measurable increase,
directly or indirectly
attributable to uranium
mining and its support
industries in the incidence
rates of the following:

Industrial lung
disease
(including
pneumoconiosis)

Lung cancer

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Data Source

Individual
mines

Chamber of
mines

Namibian
Cancer
Register
Road
accidents
statistics

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-14


Desired Result

Targets and Performance


Indicators
Other industrial
related cancers

Industrial
induced renal
damage

HIV/ AIDS

Tuberculosis

Industrial
dermatitis.

No increase in road
accidents directly
attributable to Uranium
mining and its support
industries.
Indicators:
Public dose assessments
produced by each mine
project
Measured change in
absorbed radiation dose of
uranium mine workers and
medical professionals
(designated radiation
workers)
Measured change in the
incidence rate of industrial
diseases amongst uranium
mine workers.
Measured change in the
incidence rate of diseases
scientifically attributed to
radiation amongst members
of the public, uranium mine
workers and medical
personnel
Measured change in the
rate of road accidents in
Erongo Region directly
attributable to uranium
mining

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Party responsible for


Implementation

Data Source

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-15


Desired Result

2. Improved
Healthcare
Facilities and
Services4 are
able to meet
the increased
demand for
healthcare
resulting from
the Uranium
Rush

Targets and Performance


Indicators
Targets:
An increase in qualified
health workers available to
all in the Erongo Region,
reaching 2.5 per 1,000 of
the population by 2020
An increase in registered
healthcare facilities in
Erongo, available to all,
reaching 2.5 acute care
beds per 1,000 of the
population and 0.5 chronic
care beds per 1,000 by
2020
An increase in ambulances
in Erongo, reaching 1 per
20,000 by 2020

Party responsible for


Implementation
Ministry of Health and
Social Services
Private healthcare
providers

Data Source
National and
local statistics

Indicators:
Number of available
qualified healthcare
personnel: 2.5 per 1,000
Number of available
registered healthcare
facilities: 1 per 1,000
Number of available
ambulances: 1 per 20,000
Number of Medical
Practitioners: 1 per 1,000
Number of Dental
Practitioners: 1 per 2,000
Number of nurses: 2.5 per
1,000
Pharmacists: 1 per 2,000 of
population

4There is no consensus on the ideal number of healthcare workers per 1000 of population, which differs from region to

region depending on a large number of fundamental factors. The figures stated here are based on the consensus opinion of
the group of local medical practitioners in Erongo Region.

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STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-16

EQO 4: AIR QUALITY AND RADIATION MANAGEMENT


Aims of this EQO: Workers and the public do not suffer significant increased health risks as a
result of radiation exposure from the Uranium Rush

Desired Outcome

1. Annual
radiation
exposures to
the public via
air are not
significantly
increased as a
result of the
Uranium
Rush

2. Annual
human
exposures to
particulate
concentration
s are
acceptable
(IFC
Standard)

Target and performance


indicators

Party responsible for


implementing the EQO

Target:
More accurate public dose
assessments shall demonstrate
that the cumulative radiation
dose to members of the public
does not exceed 1 mSv/a, or
that the dose to members of the
public does not exceed 0.25
mSv/a for contributions from
any single operation.

Mines must prevent


contamination of
water and air and
must monitor air
quality

Indicators to be monitored in
air:
Radon exhalation rates
from ground through
continuous monitoring.
Gross alpha/beta-analysis
and determination of
uranium and thorium by
NAA within the inhalable
(PM10) fraction of air
filters
Gross alpha/beta-analysis
and determination of
uranium and thorium by
NAA within dust fallout
samples.
Target:
Ambient PM10 concentrations
at public locations should not
exceed the required target/limit
to be set for the Erongo Region
for both annual and 24-hour
averages. The target/limit
should be based on
international guidelines but
should consider local
environmental, social and
economic conditions.
Indicators:
Ambient PM10
monitoring (g/m3) at

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The NRPA must


ensure compliance
by the mines

Mine
radiation
management
reports (that
are sent to
the NRPA)

Road authorities
must maintain
national transport
infrastructure

DWA and
NRPA
verification
reports

Transport
Authority
reports

MME
Annual
Reports

Chamber of
Mines
annual
reports

Mine air
quality
management
reports

MME
Annual
Reports

Chamber of
Mines
annual
reports

Erongo
PM10 and
dust fallout
monitoring

MME, MHSS and


NRPA must ensure
that mines comply
with (or exceed)
permit requirements

Mines must monitor


and mitigate dust
generating sources

The Ministry of
Health and Social
Services must
ensure compliance
with air quality
requirements from
the mines

Data
Sources

MME must
implement and
operate PM10
samplers at
identified receptors

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-17

Desired Outcome

Target and performance


indicators

Swakomund, Walvis Bay,


Arandis, Goanikontes and
Henties Bay
Installation of an
accredited meteorological
station at Swakopmund
measuring hourly average
wind speed, wind
direction, temperature,
solar radiation, humidity
and rainfall.

Other performance targets:

Mitigation measures to be
implemented by mines at
all major dust generating
sources such as haul
roads, materials transfer
points and crushing
operations. The best
practical dust suppression
methods should be
implemented and
monitored.

PM10 samplers can be


implemented by
individual mines to track
progress with mitigation
measures. PM10 samplers
should not be placed close
to main dust generating
sources at the mine but
rather some distance away
within the main zone of
impact.

Public roads that will act


as main access routes to
mining operations should
be paved or changed into
salt roads. This will
reduce dust generation
from these roads.

Other monitoring objectives:

Calibration of PM10
samplers and
meteorological station as
per manufacturers

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Party responsible for


implementing the EQO

MME must have an


Erongo based
monitoring
programme that
provides overall
picture and this
must feed back to
the public and
individual mines

Data
Sources
database

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-18

Desired Outcome

Target and performance


indicators

Party responsible for


implementing the EQO

Data
Sources

specification.

Use of accredited
laboratories in the
analysis of PM10 sample
filters.

Quality checks must be


performed on
meteorological data
including span checks and
data availability.

Develop a monitoring
database providing
information on measured
PM10 concentrations.
This information should
be available to the public
in a format that is both
scientifically sound and
understandable.
3. Nuisance dust Target:
resulting from Dust fallout levels at
the Uranium
residences in towns should not
Rush is
exceed the recommended limit
within
of 600 mg/m2/day.
acceptable
Indicators:
thresholds
Continuous dust fallout
measurements
(mg/m2/day) on a regional
scale e.g. maintain
existing SEA dust fallout
network.
Mines must implement a
dust fallout network,
measuring dust fallout at
main dust generating
sources and mine license
boundaries.
Other performance targets:

Mitigation measures to be
implemented by mines at
all major dust generating
sources such as haul
roads, materials transfer
points and crushing
operations. The best
practical dust suppression

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Mines must monitor


and mitigate dust
generating sources

The Ministry of
Health and Social
Services must
ensure compliance
with air quality
requirements by the
mines

MME must continue


with the current dust
fallout network
Chamber of Mines
MME must have an
Erongo based
monitoring
programme that
provides overall
picture and this
must feed back to
the public and
individual mines

Mine air
quality
management
reports

MME
Annual
Reports

Chamber of
Mines
annual
reports

Erongo
PM10 and
dust fallout
monitoring
database

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-19

Desired Outcome

Target and performance


indicators
methods should be
implemented and
monitored through dust
fallout buckets at strategic
locations.

Public roads that will act


as main access routes to
mining operations should
be paved or changed into
salt roads. This will
reduce dust generation
from these roads.

Other monitoring objectives:

Use of accredited
laboratories in the
analysis of dust fallout.

Develop a monitoring
database providing
information on measured
dust fallout levels. This
information should be
available to the public in a
format that is both
scientific sound and
understandable.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Party responsible for


implementing the EQO

Data
Sources

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-20

EQO 5: EDUCATION AND SKILLS DEVELOPMENT OPPORTUNITIES


Aims of this EQO: In the Erongo Learning Region, people continue to have affordable and
improved access to basic, secondary and tertiary education, which enables them to develop and
improve skills and take advantage of economic opportunities.
Desired Result

1. Improved
quality of
school
education

2. Increased
availability of
technical skills
in Erongo

Target and performance


indicators
Target: Improved results
Indicators:
75% of grade 1 enrolments
complete grade 10
75% of grade 10 graduates
obtain a NSSC
National Examination
Results in Grade 10 and 12
in maths, English and
science is a D or better for
more than 50% of learners
from public (GRN) schools
Region improves
performance in reading and
mathematics
Target: More qualified artisans,
technicians, geologists,
accountants and engineers
Indicators:
Increasing number of
graduates from NIMT,
Polytechnic of Namibia,
proposed VTC facility in
Walvis Bay and UNAM
Every mine has/funds a
skills development
programme for employees
(3% of wage cost)
Each mine has 10% more
bursary holders than workpermit holders

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Party responsible for


implementation
MoE (Regional
Office)(under office of
the governor), assisted
by the Private Sector
(esp. uranium
industry)
Individual schools
assisted by the Private
Sector (esp. uranium
industry)

Data Source

The aforementioned
institutions bursaries
from the GRN and
Private Sector,
especially the uranium
industry. NTA training
levy to be utilised by
the VTCs

Namibia
Training
Authority
Polytechnic of
Namibia,
UNAM

Directorate of
National
Examinations
and
Assessment,
MoE.
SACMEQ
reports

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-21

EQO 6: SOCIAL COHESIVENESS AND DEMOGRAPHICS


Aim of this EQO: Promote local employment and integration of society.
Desired outcome

Target and performance


indicators

Responsible Party for


EQO implementation

1. Mainly locals

Target: Uranium companies


hire locally where possible

Mines

are employed

2. Existing,
proclaimed
towns are
supported

Indicators:
During operational phase all
companies to comply with
their employment equity target
(certificate)
Target: Most employees are
housed in proclaimed towns
Indicators:
Mines do not create mineonly townships or suburbs
There are no on-site hostels
during the operational
phase of a mine

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Mines, supported by
the municipalities

Data source

Mines HR
department,
via
Chamber of
Mines

Municipalities

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-22

EQO 7: WATER
FUNCTIONING

AVAILABILITY,

QUALITY

AND

HYDROLOGICAL

Aim of this EQO: To ensure that the public have the same or better access to water in future as they
have currently, and that the integrity of all aquifers remains consistent with the existing natural and
operational conditions (baseline). This requires that both the quantity and quality of groundwater are
not adversely affected by prospecting and mining activities.
Desired outcome

1. Water for
urban and
rural
communities
is of
acceptable
quality

2. The natural
environment,
urban and
rural
communities
have access to
adequate
water

Target and performance


indicators
Target: Uranium Rush does
not compromise community
access to water of appropriate
quality5, for:
Urban users
Rural communities
supplied by DWA
Commercial farmers (own
supplier)
Lower Swakop River small
holdings
Indicators:
Aesthetic/physical,
inorganic, radio-nuclide
and bacteriological
determinants conform with
minimum required quality
as prescribed in the
national water quality
standards.
Target: Uranium Rush does
not compromise surface and
groundwater movement6 and
availability
Indicators:
No unusual loss of wetland
and riparian vegetation
No unusual loss of
phreatophytes
Borehole levels fluctuate
within existing norms
Aquifer water will be made
available to domestic users
at approved NamWater
rates
All water supply

Responsible Party for


implementation
DWA
Mines & other
developers
Municipalities
SEMP office
NamWater

Data source

DWA
Mines & other
developers
NamWater
Farmers
Basin Management
Committees (BMCs)
Municipalities

Land
owner(s)
DWA
Mining
Companies
Public

Accredited
laboratory test
reports

It is acknowledged that groundwater in some areas is naturally brackish or saline and does not conform to the national water
quality standards
6
It is specifically recommended that no groundwater be used for any mining operations, other than water made available
through pit dewatering

SEA OF THE CENTRAL NAMIB URANIUM RUSH

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-23


Desired outcome

3. Water for
industrial
purposes is
available and
reliable

Target and performance


indicators
infrastructure is maintained
Disaster management plans
are in place and
implemented.
Target: Additional water
resources (notably desalinated
water) are developed to meet
industrial demand.
Indicators:
Desalinated water meets
mine demand by 2011
Industrial investors are not
lost because of water
unavailability
Water availability exceeds
99%

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Responsible Party for


implementation

Data source

NamWater
LAs
NCCI

NamWater, with
collaboration by
industry, DWA, LAs

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-24

EQO 8: ECOLOGICAL INTEGRITY


Aim of this EQO: The ecological integrity and diversity of fauna and flora of the central Namib is
not compromised by the Uranium Rush. Integrity in this case means that ecological processes are
maintained, key habitats are protected, rare and endangered and endemic species are not threatened.
All efforts are taken to avoid impacts to the Namib and where this is not possible, disturbed areas are
rehabilitated and restored to function after mining/development.
Desired Outcome

1. The paucity of
biodiversity
data for the
Central
Namib is
addressed

2. The
ecological
integrity of
the central
Namib is
maintained

Target and performance


indicators
Target: Biodiversity studies
and monitoring programmes
are initiated in order to develop
a better understanding of
biodiversity issues in the
central Namib
Indicators:
More research has been
undertaken and there is
continuous improvement in
the understanding of
biodiversity in the Namib.
A landscape assessment of
biodiversity in the Erongo
region is undertaken
The broadly defined red
and yellow flag areas
identified in the SEA have
been refined.
Studies on range restricted
endemics have been
conducted.
Target: The mining industry
and associated service
providers avoid impacts to
biodiversity and ecosystems,
and where impacts are
unavoidable, minimisation,
mitigation and/or restoration
and offsetting of impacts is
achieved.
Indicators:
Mining in protected areas is
avoided wherever possible
Important biodiversity
areas [red or yellow flag
areas (see Figure 8.7)] are
taken into consideration
when adjudicating
prospecting and mining
applications. As far as
possible these areas should

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Responsible Party for


implementation
MET responsible, but
need technical support
from NGOs and
specialist institutions
(e.g. Gobabeb) and
funding from mines and
other proponents

MME
MET application of
Environmental
Management Act
Mines SEMP office
to be involved in
verification MET
and MME must
enforce
Mines, in
collaboration with
infrastructure utilities
such as NamWater,
NamPower, Roads
Authority,
Electricity and water
tariff regulating
authorities

Data source

MET
Mines
Gobabeb

EMA (2007)
compliance
figures
Mines
provide
information
SEMP office
and MET to
verify
Feasibility
studies and
plans
EIAs

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-25


Desired Outcome

Target and performance


indicators
be avoided. If this is not
possible biodiversity
offsets must be sought to
offset losses occurring in
the area. If an offset is not
possible then the no-go
option should be explored.
GRN keeps a record of all
decisions made regarding
prospecting and mining
applications so that
applications denied on
biodiversity grounds are
not awarded in the future,
unless alternative
approaches are adopted to
avoid impact, mitigate or
offset the impact.
Mines have specific
programmes and projects to
actively avoid, mitigate,
restore or offset their
impacts, with impact
AVOIDANCE
predominating
Footprints of mines are
minimized
Infrastructure corridors are
carefully planned to avoid
ecologically sensitive
areas, and demonstrate:
consideration of
alternatives,
optimization of service
provision; and
commitment to the
green route
Mines share infrastructure
as much as possible, thus
minimizing infrastructure
proliferation
Infrastructure planning and
investment takes into
account future demand,
thus reducing the need for
additional impacts (e.g. 1
pipeline, not 3)

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Responsible Party for


implementation

Data source

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-26


Desired Outcome

3. Mining
industry
becomes a
conservation
partner

Target and performance


Responsible Party for
indicators
implementation
Target: Mines and associated
Mines through the
industries support conservation
SEMP office,
efforts in Namibia
stakeholders identify
Indicators:
priority actions
Mining companies
MET and mines for
(particularly those
the creation of offset
operating in the NNP)
areas (policy
partner with conservation
requirements, land
organisations to effectively
tenure etc.)
manage their biodiversity
impacts (both direct and
indirect)
Mining companies commit
to sustainable offset
initiatives to ensure a no
nett loss to biodiversity as
a result of their operations.
This will involve
partnering with long term
conservation partners
(GRN, NGOs and
communities)
Additional conservation
projects are supported (e.g.
wetland bird counts,
wildlife surveys, Namib
Bird Route, coastal
management, research,
public awareness) as part of
the companies social
responsibility programmes
Protection and management
of key biodiversity offset
areas is supported (e.g. NW
Kunene, Messum,
Spitzkoppe, Brandberg and
other special areas in
Namibia)

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Data source
SEMP office
with input from
stakeholders

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-27


Desired Outcome

4. No species7
become
extinct
because of the
Uranium Rush

5. No secondary
impacts occur

6. Water quality
and quantity
does not
decrease to
the extent that
it negatively
affects
biodiversity

Target and performance


indicators
Target: Authorisation to mine
is denied if the extinction of a
species is likely.
Indicators:
All EIAs must consider
extinction possibility, and
resources must be available
for reasonable
investigation.
GRN refuses project
authorization if extinction
likely.
Offroad driving, poaching,
illegal camping, littering by
mine personnel, are
explicitly prevented by
mining companies
Improved vigilance and
visibility of law
enforcement personnel,
with structured support
from civil society (e.g.
Honorary Wardens)
reduces park/conservation
transgressions.
Target: Water table levels, and
water quality standards are
described and ephemeral river
ecosystems are monitored to
ensure that these standards are
not compromised.
Indicators:
Regular monitoring of
indicator species in all
ephemeral rivers is in place
Results from monitoring are
fed back to regulators and
impacting companies so
that negative impacts on
riverine vegetation, springs
and pans can be dealt with
appropriately.

Responsible Party for


implementation
Mines (commission
and fund EIAs)
MET and MME
(support through
Inter-ministerial
Committee) that
approve/deny project
implementation
SEMP office to verify

Data source

Mines, with input


from MET
MET to control and
enforce, supported
by mines, who could
help to fund the Hon.
Wardens inside and
outside parks.

MET with
input from
Honorary
Wardens and the
SEMP office.
Farmers and
conservancies
will also be
sources of
information.

MET responsible,
but need technical
support from DWA,
NGOs and specialist
institutions (e.g.
Gobabeb) and
funding from mines
and other
proponents.

EIAs and RoDs

MET
DWA
Mines
Gobabeb

There is incomplete knowledge of Namib biodiversity, and it is therefore not possible to know exactly what species occur
and where.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-28

Figure 8.7: Red and yellow flag areas based on ecological criteria

SEA OF THE CENTRAL NAMIB URANIUM RUSH

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-29

EQO 9: PUBLIC ACCESS TO THE CENTRAL NAMIB


Aims of this EQO: To ensure that the Uranium Rush does not prevent the public from visiting the
usually accessible areas in the central Namib for personal recreation and enjoyment; and to identify
ways of avoiding conflicts between the need for public access and mining.
Desired result

Target and performance indicators

1. Central Namib is

Target: Uranium Rush does not result


in net loss of publicly accessible areas
Indicators:
Areas of importance for
recreation8 that are not yet
alienated by mining or
prospecting are declared red
flag for prospecting or mining.
These include: The WalvisSwakop dunes, Messum Crater,
Spitzkoppe (Gross and Klein),
Brandberg, the Ugab, Swakop,
Khan, Kuiseb and Swakop
Rivers, the coastal area between
the Ugab River Mouth and the
tidal mud banks south of
Sandwich Harbour (between
lower tide mark and the main
coastal road), the Welwitschia
Drive (can possibly be offset) and
Park campsites (can be offset).
All new listed developments9
undergo an EIA and EMP prior to
final design and implementation,
and in all cases, the issue of public
access is assessed in a specialist
report
All projects are closed,
decommissioned and rehabilitated
in such a way that addresses public
access needs.

accessible to the
public (within the
regulations of the
National Park)

Party
responsible for
implementation
MME to agree
on red flag
areas
MET
(implement
Park
Management
Plans)
NHC

Developers
must comply
MME and
MET must
enforce
COM must
encourage
best practice.

8
9

These are the places regarded as commonly used for recreation by locals.
Listed means the activity is required to have an EIA under the Environmental Management Act of 2007.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Data source
MME - proof
of withdrawal
will be a GRN
announcement
and a map
The public
at least 100
coastal
residents who
own a 4x4
vehicle must
be sampled
randomly in
an annual
public survey
NHC

EIA report
and specialist
study
EMP report
Closure plan
Proof of funds
available for
closure,
decommission
ing and
rehabilitation
The DEA
must keep a
copy of above
reports and
specialist
studies.

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-30

EQO 10: NATURAL BEAUTY OF THE NAMIB


Aim of this EQO: The natural beauty of the desert and its sense of place are not compromised
unduly by the Uranium Rush; and to identify ways of avoiding conflicts between the tourism industry
and prospecting/mining, so that both industries can coexist in the central Namib.
Desired
outcome

Target and performance


indicator

1. Uranium

Target: Direct and indirect


visual scarring from the
Uranium Rush is avoided or
kept within acceptable limits.
Indicators:
All developers commission
EIAs prior to final design,
and outcomes-based EMPs
guide implementation and
decommissioning. In all
cases, visual impacts and
sense of place are
addressed.

Rush does
not significantly
reduce the
visual
attracttiveness of
the Central
Namib

Tour operators continue to


regard areas such as the
dunes, the coastline, Moon
Landscape, Welwitschia
Flats, Swakop and Khan
River areas, and
Spitzkoppe
as a significant
component of their tour
package.
Tourists expectations are
met or exceeded more
than 80% of the time in
terms of their visual
experience in the central
Namib.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Responsible Party
for EQO
implementation
Developers to
commission EIAs
and implement
EMPs. DEA must
ensure quality of
both.
Mining companies
and MET must
plan mitigation and
alternative tourism
routes
Collaboration
between tour
companies and
mines to diversify
tourism (geology
etc.).

Data source
EIA reports look
for visual impact
specialist study, EMP
report and
decommissioning and
restoration plan, with
funds.

As above, but tour


operators, tourists
and the general
public must also
limit their
environmental
impacts.

Tour operators at
least 70% (randomly
selected) operators
working in the
Swakopmund/Walvis
area must be sampled
annually.

As above.

Tourists at least 200


tourists that
undertook a desert
excursion must be
sampled.

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-31


Desired
outcome

Target and performance


indicator

2. Areas of
significant
natural
beauty or
sense of
place10 are
afforded
proper
protection
(without
undermining
existing
legal rights).

Target: Improved protection


of red and yellow flag
listed areas.
Indicators:
MME recognizes and
respects red flag status
for areas regarded as being
significantly beautiful.
These include:
Coastal strip,
Major dunefields,
Moon Landscape,
Spitzkoppe,
Brandberg,
Messum crater,
Sandwich harbour,
westward flowing
rivers (notably Khan,
Swakop and Kuiseb)
MME recognizes and
respects yellow flag
status for areas regarded as
being scenically attractive.
These include:
Gravel plains,
Inselbergs (other than
those listed above),
River washes (other
than rivers listed
above),
Lichen fields.

Responsible Party
for EQO
implementation
MME
MET appropriate
revision of
Protected Area &
Wildlife Bill needs
to be made and the
Bill needs to be
passed and
implemented
MET needs to
manage and
monitor other
sectors that impact
these red and
yellow areas,
notably recreation,
tourism,
infrastructure
projects,
aquaculture and
urban
development.
SEMP Office
National Heritage
Council (NHC).

Data source
MME

10

In this case, sense of place takes into account natural beauty, biodiversity, heritage value, tourism value and environmental
vulnerability.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-32

EQO 11: HERITAGE RESOURCES


Aim of this EQO: Uranium exploration and mining - and all related infrastructure developments will have the least possible negative impact on archaeological heritage resources11. The degree of
impact will be determined on the basis of empirical data gathered by direct assessment of specific
projects, using established criteria of significance and vulnerability, and by means of explicit methods
of survey and description. In applying these principles, the negative impacts of mining activity in the
Erongo Region will be mitigated, and partly offset. Thus, survey, assessment and mitigation will
result in significant advances in knowledge of archaeological heritage resources, so that their
conservation status is improved and their use in research, education and tourism is placed on a secure
and sustainable footing.
Desired outcome

1. The integrity of
archaeo-logical
and palaeontological heritage
resources is not
unduly
compromised by
the Uranium Rush

Target and
indicators

performance Party
Data
responsible for source
implementation
Target: Mining industry and
National Heritage
Mining
associated service providers
Council and
companies and
avoid impacts to
National Museum
other
archaeological resources, and
as repositories of
developers
where impacts are
data and
must
unavoidable, mitigation,
materials.
commission
restoration and /or offsetting
and pay for
are achieved.
the
Indicators:
assessment.
All mining and related
developments are subject
to archaeological
assessment
No unauthorised impact
occurs
Mining companies adhere
to local and international
standards of
archaeological assessment.

2. Integration of
archaeological and
environmental
knowledge in a
balanced working
model of Namib

Target: Development of a
general research framework
to identify gaps in scientific
knowledge.
Indicators:

National Heritage
Mining
Council and
companies and
National Museum
other
as repositories of
developers
data and
Chamber
of
materials.
Mines
must
encourage
Best Practice
Gap analysis and
National
research
research
framework
institutions
(National
Local and
Heritage Council).
foreign
scientists

11

This EQO and the related thematic study are limited in their scope, to the material record of past human activity in the
relevant part of the Erongo Region. The most severe impacts of mining activity affect the pre-colonial and early colonial
archaeological record, most of which is undocumented and therefore at greater risk than sites and other remains mainly in
urban areas and other formal settlements. In general use, and in terms of the National Heritage Act (27 of 2004) heritage
has a broader meaning which goes beyond the scope of this assignment, to include the intangible cultural values of living
communities, the architectural heritage, and numerous other manifestations of cultural activity such as museums, memorials
and places of interest.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-33


Desired outcome

Desert
environmental
processes.

Target and
indicators

performance Party
Data
responsible for source
implementation
concerned
Research in progress,
with the
Working model of Namib
development
desert developed
of
Model providing
environmental
information to guide
monitoring.
decision making about
development in the Namib
Development of
As above.
Diachronic model
diachronic models to
(National
determine the effects of
Heritage Council).
climatic and other
environmental changes.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-34

EQO 12: WASTE MANAGEMENT


Aims of this EQO:
To ensure that there is sufficient capacity in the existing licensed waste disposal sites to
accommodate the amount of waste that will be generated by the mines without causing pollution
to the air, soil or water;
To ensure that the collection and disposal of waste is carried out in a safe, responsible and legallycompliant manner;
To ensure waste re-use and recycling is optimised;
To ensure that the recycling agencies have sufficient capacity to handle an increased waste
stream.
Desired outcome
1. Waste sites
have adequate
capacity.

2 Waste sites are


properly
managed

Targets and performance


indicators
Target: All sewage, nonhazardous and hazardous waste
sites are properly designed and
have sufficient capacity for next
20 years, taking into account the
expected volumes from
Scenario 3 mines and all
associated industries.
Indicators
Municipalities increase
capacity of sewage works
and waste sites based on
predicted volumes of waste
Independent audit proves
sufficient capacity of Walvis
Bay and Windhoek
hazardous waste sites; and
Swakopmund, Walvis Bay,
Arandis and Usakos nonhazardous waste sites with a
20 year life-span
All new waste sites undergo
an EIA prior to construction
and receive a licence to
operate.
Target: The management of
waste sites meets national
standards.
Indicators:
Waste site managers are
adequately trained
Site manifests which record
all wastes, volumes and
origins are kept.
Only hazardous waste
classes for which the sites
are licensed are accepted.
Water and air quality

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Responsible party for


implementation
Walvis Bay
Municipality, notably
the Water, Waste and
Environmental
Management
Department
Windhoek City
Council, notably the
Solid Waste
Management Division
MET compliance
monitoring and MHSS
through the Pollution
Control &
Management Act.

Data
source
Independent
audit.

Waste site operators


maintain their licence
to operate.
Staffing levels in the
solid waste
management
departments are
adequate.
Walvis Bay
Municipality: Water,
Waste and
Environmental
Management

Independent
auditors
Waste site
operators.
Site manifests
Water and air
quality
monitoring
data
Municipal
records:
budgets and
staffing of

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-35


Desired outcome

3 Recycling is
common
practice in the
central Namib.

Targets and performance


indicators
monitoring data show no
non-compliance readings.
Municipal budgets are
sufficient to comply with the
site licence requirements
relating to pollution control.

Indicator for tailings:


Tailings dams are designed
and managed in a way that
avoids pollution to the air,
soil or water.
Target: A sustainable waste
recycling system is operational
in the central Namib, servicing
the uranium mines and the
public.
Indicators:
A waste recycling depot
established.
Waste recycling operators
have sufficient capacity to
collect, transport and recycle
waste in a safe and
responsible manner
Volumes of waste disposed
to landfill per capita
decreases.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Responsible party for


implementation
Department
Windhoek City
Council: Solid Waste
Management Division
Swakopmund
Municipality: Health
Services
Arandis Town Council
Usakos Town Council:
Technical Department
Mines

Data
source
waste
management
departments.

Mines
SMEs (recycling)
Municipalities.

Mines
Municipalities.

Mines

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-36

EQO 13: RELIABLE INFRASTRUCTURE


Aim of this EQO: Key infrastructure is adequate and well maintained, thus enabling economic
development, public convenience and safety.
Desired
outcome
1. Roads in
Erongo are
adequate
for
Uranium
Rush and
other
traffic.

Targets and performance


indicators
Targets: Roads are designed for
maximum safety and are in good
condition
Indicators:
All key gravel roads (C28,
Moon landscape (D 1991)
Welwitschia drive,
Goanikontes (D 4570), Walvis
to Kuiseb (C 14 )) are graded
timeously to avoid
deterioration.
Unsurfaced roads carrying
>250 vehicles per day, need to
be tarred
The B2 tar road is free of potholes and crumbling verges
Road markings and signage
are in place and in good
condition
Accidents at intersections and
turn-offs decline from current
trends.

Responsible Party for


EQO implementation
Roads Authority

Data
source
Roads Authority
Independent
survey report
(SEMP Office)
NAMPOL
where accidents
are reported

2. Traffic
flows
optimally
and safely.

Targets: Roads are designated


for specific uses, thus reducing
inconvenience and enhancing
safety
Indicators:
D1984 (Swakopmund to
Walvis-Bay east of dunes) is
tarred and designated an
industrial vehicle route
90% of traffic on the B2
coastal road (between
Swakopmund and Walvis
Bay, west of the dunes) is
light vehicles (< 3 tons)
No industrial or mining traffic
on designated tourist routes.

Roads Authority
NAMPOL
Mines

Traffic census

SEA OF THE CENTRAL NAMIB URANIUM RUSH

(Traffic officials
and SEMP office)

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-37


Desired
outcome
3. Optimum
use of rail
infrastruct
ure.

4. Walvis
Bay
Harbour is
efficient
and safe

5. Electricity
is
available
and
reliable

Targets and performance


indicators
Target: Most bulk goods are
transported by rail
Indicators:
>80% of all bulk goods (all
reagents and diesel) delivered
to mines and associated
industries, are transported by
rail
Target: The harbour authorities
provide reliable, accessible and
convenient loading, offloading
and handling services
Indicators:
Average loading/offloading
rate for containers is >25
containers per hour
Average waiting time for
ships to obtain a berth is <12
hours
No oil/ chemicals/
contaminants/ sewerage spills
enter the Ramsar site
Target: The public do not suffer
disruptions in electricity supply as
a result of the Uranium Rush
Indicators:
No uranium and associated
industry investor is lost
because of electricity
unavailability, and planning is
in place to accommodate
other sectors
Electricity quality of supply
meets ECB standard
Electricity provision
(generation, distribution and
transmission) does not
compromise human health
Mines and associated
industries pursue renewable
power supply options as far
as possible

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Responsible Party for


EQO implementation
Mines and associated
industries, in
collaboration with
MWTC and
TransNamib

Data
source
TransNamib
Namport
Mines

Namport

Namport

NamPower and
MME, in
collaboration with
REDs and LAs

Feasibility studies
NCCI
NamPower

ECB, in collaboration
with NamPower,
REDs and LAs

ECB

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-38

EQO 14: INSTITUTIONAL FUNCTIONING


Aims of this EQO: Institutions that are responsible for managing the Uranium Rush provide
effective governance through good leadership, oversight and facilitation, so that all legal requirements
are met by all parties involved, either directly or indirectly, in prospecting and mining of uranium.
Desired outcome

Performance indicator and target

Responsible Party
for EQO
implementation

Data source

1. Prospecting and

Target: Sensitive areas in need of


protection, are not generally
available for prospecting or
mining
Indicators:
Declared red flag areas
undergo the required high
level of scrutiny before
mineral licenses are
considered (see other EQOs
for lists & Figures 8.8 and 8.9
for the required decision
making process)
Where possible, red flag areas
remain undisturbed by mining
or other developments that
have high impacts on
biodiversity, heritage and or
sense of place.
If development (especially
mining) is to take place in a
yellow flag area, strict
conditions are attached with
the approval certificate
No new powerlines, pipelines
or roads linked to the
Uranium Rush are routed
through red flag areas, and
preferably also not through
yellow flag areas.
Target: The defined process is
always followed in the allocation
of all kinds of mineral licences
and the establishment of
supporting infrastructures
Indicators:
Mineral licences12 are given
only after full consultation of,
and consensus within, the
Mineral Rights Committee
and the relevant status of
areas in question (red and
yellow flag areas)

MME
Parastatals
Individual
mines.

MME
Parastatals
Physical
inspection

MME
MET
MAWF
Other GRN
Civil Society
involvement
required.

As before
EIA and EMP
reports
EIA/EMP
RoDs
Court cases.

mining avoids
environmenttally high value,
sensitive areas.

2. Good
governance is
maintained in
the issuing of
mineral
licences.

________________________________________________
[12]

Meaning for uranium or any other minerals.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-39

3. Prospecting and
mining
activities are
properly
monitored.

No evidence of corruption in
the allocation of mineral
licences
No prospecting, mining or
major infrastructure projects
are permitted (anywhere)
before full EIAs are
completed and approved.
Minimum EIA standards as in
the EMA and regulations, are
adhered to, including:
o Clear TORs
o Use of
independent
consultants
o Public
consultation
o Specialist studies
o Consideration of
alternatives
o Avoid and/or
minimise adverse
impacts
o Include an EMP
and closure and
restoration plan
o Professional
review of EIA
and EMP.
Target: Post-implementation
monitoring is regular, efficient
and outcomes-based
Indicators:
GRN agencies (notably
MME, MET, MAWF,
MHSS) inspect active mines
at least once per annum, and
closed mines at least once
every 3 years
Honorary conservators are
appointed by MET to assist
with monitoring, including of
unauthorised secondary (offmine) activities such as
offroad driving, poaching and
littering.
Above agencies take accurate
and consistent measurements
of key indicators
International agencies
regularly inspect mines and
provide independent opinion

SEA OF THE CENTRAL NAMIB URANIUM RUSH

MME to take the


lead support

needed from
MET and other
GRN agencies.
Civil Society
involvement
required.
CoM to provide
support.

GRN reports
Consultant
reports
SEMP report.

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-40


on their performance
Results of monitoring
improve practice and are
disclosed to the public
through existing channels and
in an annual SEMP report, or
more regularly
Where appropriate, the public
are able to participate in
physical monitoring.
Through existing channels
and /or the SEMP office, the
public can report observations
of illegal activities or
unwanted impacts.
Target: Transgressions are noted
and acted upon timeously
Indicators:
The activities of proponents/
developers/ service providers
who have caused
unauthorised negative
impacts, are suspended, and
they are forced to remedy
impacts
If impacts are not remedied,
the operation is closed and
the project authorisation is
cancelled
Fines are issued for noncompliance
All incidences of noncompliance are publicised
through the media and noted
in the annual SEMP report.

4. Noncompliance is
rectified.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

MME to take
the lead
support needed
from MET and
other GRN
agencies
CoM to
encourage best
practice.

GRN reports
and correspondence
SEMP report.

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-41

Figure 8.8: Decision-making process for EPLs in red and yellow flag areas

Figure 8.9: Decision-making process for MLs in red and yellow flag areas

SEA OF THE CENTRAL NAMIB URANIUM RUSH

STRATEGIC ENVIRONMENTAL MANAGEMENT PLAN (SEMP) 8-42

EQO 15: NAMIBIAS IMAGE


Aim of this EQO: Namibias international image is maintained and enhanced, as the Namib
Uranium Province builds a good international reputation as a result of generally reliable, ethical,
trustworthy and responsible practices/behaviour and more specifically, because of environmentally,
socially and financially responsible uranium mining operations.
Anticipated
result
1. Namib
uranium is
regarded as a
green
product.

Targets and performance


indicators
Target: The Namib
Uranium Province is
regarded internationally as
an area where reliable,
trustworthy, ethical, and
environmentally, socially
and financially responsible
companies prospect and
mine for uranium.
Indicators:
No critical international
voices about the
operations and
performance of the
Namib Uranium Province
among any key
international stakeholders
(other than those
international stakeholders
opposed to uranium
mining and/or nuclear
power anyway, in
principle/on ideological
grounds)
There is no evidence of
unreliable, unethical
and/or environmentally,
socially and financially
irresponsible conduct by
operating uranium mines
or prospecting activities.

SEA OF THE CENTRAL NAMIB URANIUM RUSH

Responsible Party for


EQO implementation
GRN, especially
MME, MET MHSS
(National Radiation
Protection Authority)
and DWA
Mines
Chamber of Mines

Data source
Professional
journals (e.g.
Mining
Weekly)
Relevant
websites
Foreign travel
agencies and
tourism
operators
SEMP annual
report
Environmental
Commissioner
s Office
National
Radiation
Protection
Authority
MoHSS
Geological
Survey of
Namibia/MME
Ministry of
Labour
Tax Authority/
Ministry of
Finance
Ministry of
Foreign Affairs
IAEA
Tourism
operators
Tourists
Members of the
public.

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