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Environmental and Social Impact Assessment (ESIA) process for the proposed Offshore Exploration Drilling - Namibia Block 2913B Final Environmental Impact Report TOTAL E&P Namibia BV Project number: 60582294 May 2019

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Environmental and Social Impact

Assessment (ESIA) process for

the proposed Offshore

Exploration Drilling - Namibia

Block 2913B

Final Environmental Impact Report

TOTAL E&P Namibia BV

Project number: 60582294

May 2019

i

Quality information

Prepared by Checked by Approved by

Phindile Mashau Environmental Scientist

Nicola Liversage Director - Environment, Middle East

and Africa

Nicola Liversage Director - Environment, Middle East

and Africa

Revision History

Revision Revision date Details Authorized Name Organisation

01 2019-03-20 Technical Yes

Mr Jason Frederick TOTAL

Ms Monica Castro TOTAL

Dr Lima Maartens LM Environmental Consulting

Distribution List

# Hard Copies PDF Required Association / Company Name

1 1 (CD) Ministry of Environment and Tourism

1 1 (CD) Ministry of Mines and Energy

Environmental and Social Impact Assessment (ESIA) process for the proposed

Offshore Exploration Drilling - Namibia Block 2913B

Project number: 60582294

ii

Prepared for:

TOTAL E&P Namibia BV

5 Otto Nitzsche Strasse

Klein Windhoek

Windhoek

Namibia

Prepared by:

Phindile Mashau

Environmental Scientist

T: +27 12 421 3894

E: [email protected]

AECOM SA (Pty) Ltd

263A West Avenue

Centurion

Tshwane

0157

South Africa

T: +27(0) 12 421 3500

F: +27 (0)12 421 3501

aecom.com

© 2019 AECOM SA (Pty) Ltd. All Rights Reserved.

This document has been prepared by AECOM SA (Pty) Ltd (“AECOM”) for sole use of our client (the “Client”) in

accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed

between AECOM and the Client. Any information provided by third parties and referred to herein has not been

checked or verified by AECOM, unless otherwise expressly stated in the document. No third party may rely upon

this document without the prior and express written agreement of AECOM.

Environmental and Social Impact Assessment

(ESIA) process for the proposed Offshore Exploration Drilling - Namibia Block 2913B

Project number: 60582294

iii

NON-TECHNICAL SUMMARY

BACKGROUN D TO TH E PROJECT

TOTAL EP NAMIBIA B.V. (herein referred to as TOTAL) is undertaking an Environmental and Social Impact

Assessment (ESIA) process for the offshore exploration drilling activities in Block 2913B, Namibia.

TOTAL conducted a series of pre-application meetings with relevant authorities and subsequently submitted an

application for an Environment Clearance Certificate (ECC) to the Ministry of Mines and Energy (MME) for

recommendation to the Ministry of Environment and Tourism (MET).

The Project requires an assessment of the affected area as well as the surrounding environment (biophysical and

social). TOTAL has appointed AECOM Africa (Pty) Ltd (herein referred to as AECOM) as the independent

Environmental Assessment Practitioner (EAP) to undertake the ESIA process, in support of the required Namibian

legislative authorisations. TOTAL is undertaking the ESIA process in terms of the Environmental Management Act,

2007 and the Environmental Impact Assessment (EIA) Regulations 2012.

STUD Y AREA FOR TH E PROJECT

Exploration drilling will take place within offshore Block 2913B which is approximately 300 kilometres (km) off the

coast of Namibia from Lüderitz. The surface area of Block 2913B is approximately 8215 square kilometres (km2),

several wells may be drilled for exploration or appraisal purposes within this block. The expected well location(s) will

be influenced by the expected location of oil-bearing layer(s), and the desire to avoid shallow gas, which may pose

a safety hazard during drilling.

ESIA PROCESS

The ESIA process consists of two phases (Scoping and Impact Assessment), which is broken down into discrete

activities to ensure compliance with the EIA Regulations 2012.

Sco ping Phas e

The purpose of the Scoping Phase was to communicate the scope of the proposed Project to Interested and

Affected Parties (I&APs), to identify issues for consideration, and to develop the terms of reference for specialist

studies to be conducted in the Impact Assessment Phase.

At the end of the Scoping Phase, a Final Scoping Report (FSR) was prepared that outlined the key issues of concern

and the terms of reference for the specialist studies to address these issues.

Impact As s es s ment Phas e

Subsequent to the identification of anticipated impacts, specialist studies were conducted as part of the ESIA

process to assess the significance of these impacts. The specialist investigations conducted are:

Environmental Baseline Study / Assessment;

Meteorological and Oceanographic Study (MetOcean Study);

Marine Noise Assessment; and

Social Impact Assessment.

The specialist studies and other relevant information / assessments were integrated into this Draft ESIA Report and

Environmental and Social Management Plan (ESMP).

This Final ESIA and ESMP Report has been prepared in compliance with Section 15(2) of the EIA Regulations 2012.

STAKEH OLD ER CON SULTATION

Key stakeholders (MME, MET and Ministry of Fisheries and Maine Resources (MFMR)) were engaged from May 2018

with the intention to clarify the ESIA process and the authorities’ main concerns. Pre-application meetings with

relevant authorities were held in September 2018.

Environmental and Social Impact Assessment

(ESIA) process for the proposed Offshore Exploration Drilling - Namibia Block 2913B

Project number: 60582294

iv

The public consultation process commenced on 21 September 2018 and Public Open Days were conducted within

the 21-day period (21 September 2018 – 12 October 2018) subsequent to the initial announcement of the Project

application.

The Draft Scoping Report (DSR) was submitted for public review for a period of 21 days from 15 January 2019 to

04 February 2019. Once the public review period for the DSR concluded, the report was updated to a Final Scoping

Report (FSR) together with the Comment and Response Report (CRR). The FSR was submitted to the MME on 11

March 2019 after which AECOM proceeded with the ESIA Phase.

Subsequent to the submission approval of the FSR, a notification will be distributed to all registered I&APs informing

them of the submission of the FSR and the availability of the Draft ESIA Report. A period of 21 days will be available

for public review of this Draft ESIA Report, inclusive of the ESMP and specialist studies, from 01 April 2019 to 21

Apr il 2 0 1 9 . Electronic copies of the Draft ESIA Report will be made available on request.

Public Open Days to present the findings of the Draft ESIA Report were conducted on 0 9 April 2019 and 11 April

2 0 1 9 at Lüderitz and Oranjemund, respectively.

Should an ECC be issued, all registered I&APs will be notified of the decision and have t he opportunity to appeal the

decision should they not agree with the authorisation issued or any conditions of authorisation.

PROJECT OVERVIEW

A summary of the Project phases, anticipated activities, aspects and impacts is provided below:

A spect Potential Impact Ph ase A c tivities

Ge neration an d release of

air emissions

Physiological effects on marine fauna

Mobilisation

Operation

Demobilisation

Exhaust gas emissions produced by the combustion of gas or liquid fuels.

Fugitive emissions associated with leaking tubing, valves,

connections, flanges, open-ended lines, pump seals, compressor seals, pressure relief valves or tanks, and

hydrocarbon loading and unloading operations.

Vent or flaring off some of the oil and gas.

Incineration of waste.

Greenhouse gas

emissions

Discharge of waste to sea

Reduction of water quality

Mobilisation

Operation

Demobilisation

Normal vessel discharge.

Ballast water discharge.

Discharge of cuttings, drilling fluid or cement. Impacts on marine fauna and flora

Introduction of exotic marine species

Discharge of

c uttings, d ri lling fluid or

c e ment

Smothering of seabed

habitat and associated benthic fauna and flora

Operation Riserless drilling phase.

Cementing of well casing.

Discharge of cuttings overboard.

Physiological effects

on marine fauna and flora

Reduction of water

quality

Disturbance to th e seabed

an d

association

se d iments

Elimination or disturbance of benthic

fauna and flora

Planning

Operation

Pre-drilling surveys.

Penetration of the seabed by the drill bit.

Removal of the blowout preventer (BOP).

Reduction of water quality

Ge neration of m arine noise

Behavioural impact on marine fauna

Planning

Operation

Semi-submersible rig positioning.

Drilling.

Vertical seismic profile (VSP) Airgun Operations.

Demobilisation /

A bandonment

of

In frastructure

Increased habitat for marine fauna and

benthic organisms

Demobilisation Abandonment of infrastructure.

Environmental and Social Impact Assessment

(ESIA) process for the proposed Offshore Exploration Drilling - Namibia Block 2913B

Project number: 60582294

v

A spect Potential Impact Ph ase A c tivities

Re q uired workforce

Employment creation Mobilisation

Operation

Demobilisation

All Project activities.

Pro ject / f in ancial

sp end

Multiplier effect on the local economy

Mobilisation

Operation

Demobilisation

All Project activities, which involves capital and operational expenditure, especially expenditure on procurement of local

goods and services.

Pro ject /

f in ancial sp end

Fiscal impacts Mobilisation

Operation All Project activities which are necessary to ensure a functional

Project. The Project as a whole will pay royalty and taxes.

Re q uired

workforce

Presence of foreign

workforce

Mobilisation

Operation

Demobilisation

All Project activities.

Pro ject

ac tivities

Physical intrusion and

nuisance impacts

Mobilisation

Operation

Demobilisation

All Project activities. Most Project activities will contribute to

nuisance impacts.

Pro ject

p e rceptions

Stakeholder

opposition

Mobilisation

Operation All Project activities. Stakeholders usually form perceptions on

the Project as whole and not individual activities.

Demobilisation Decommissioning phase impacts

Demobilisation All Project activities.

Dri l l and support vessel

tran sit

Impact on Fishing Mobilisation

Operation

Demobilisation

Offshore activities.

BASELIN E EN VIRON MEN T

Air qua lit y and Wind

The offshore ambient air quality of Namibia is not generally recorded but considered to be largely free of man-made

pollutants, as Namibia overall does not have major industries. The wind generates the heavy and regular south-

westerly swells that impact on the coast on an oceanic scale, it equally locally contributes to the northward-flowing

longshore currents. The upwelling of deep, cool water along the Namibian coast is caused by the Benguela Sea

current. The prevalent winds in the Benguela Current Large Marine Ecosystem (BCLME) region are driven by the

South Atlantic subtropical areas of high pressure (i.e. anticyclone), the eastward moving mid-latitude cyclones south

of Southern Africa.

Bat hymet r y and Geo lo gy

The bathymetry of the survey block has been assessed from the analysis of the first return extracted from previous

seismic datasets. These show several deep-water bathymetric features across the block which are expected to

relate to geological features, where variability in seabed erosion have created defined boundaries in the bathymetr y

and potentially seabed erosion. This in turn may affect habitat types on both a localised and regional level.

Bio phys ica l Envir o nment

Numerous conservation areas and a Marine Protected Area (MPA) exist along the coastline of southern Namibia,

although none fall within the area of interest.

Seabed features such as the Orange Bank, Childs Bank and Tripp Seamount have been reported for adjacent

licence Blocks 2913A and 2914B. Features such as banks, knolls and seamounts (referred to collectively here as

‘seamounts’), which protrude into the water column, are subject to, and interact with, the water currents surrounding

them. Sensitive communities including gorgonians, octocorals and reef-building sponges have been reported to

occur on the continental shelf but are not likely to be found within Block 2913B.

Due to its offshore location, plankton abundance is expected to be low, with the major fish spawning and migration

routes occurring further inshore on the shelf. The dominant fish in the area would include the migratory large pelagic

species such as albacore tuna (Thunnus alalunga), yellowfin tuna (T. albacares), bigeye tuna (T. obesus), swordfish

(Xiphias gladius), and various shark species.

A good number of the breeding seabird species forage at sea with most birds being found relatively close inshore

(10-30 km), however the African Penguins have been recorded to explore as far as 60 km offshore.

Environmental and Social Impact Assessment

(ESIA) process for the proposed Offshore Exploration Drilling - Namibia Block 2913B

Project number: 60582294

vi

The closest marine mammal range to the proposed exploration site is the Resident Killer whale. The biggest threat

to these marine mammals is solid waste pollution, which consists mainly of plastic waste as w ell as discarded or lost

fishing gear.

Deep-water coral communities, some in the form of a reef whilst others remain solitary, may be present within the

survey area as these benthic filter-feeders generally occur at depths exceeding 150 metres (m). These animals add

structural complexity to otherwise uniform seabed habitats thereby creating areas of high biological diversity.

Severe dioxygen (O2) depletion can lead to the formation of hydrogen sulphide (H 2S) gas by anaerobic bacteria in

anoxic seabed muds. This can be released periodically from the muds as ‘sulphur eruptions’, causing upwelling of

anoxic water and formation of surface slicks of sulphur discoloured water.

So cia l Envir o nment

The economies of several towns along the coast of the //Karas region depend on marine based economic activities.

Block 2913B is located well offshore beyond the 1,000 m depth contour. Other users of the area inshore of the

Exploration Licence blocks include the commercial fishing industry, oil and gas licence holders , and Namibia’s

marine diamond mining concession holders. Other industrial uses include the intake of feed-water for fish

processing, mariculture or diamond-gravel treatment. However, as all these activities are located on the coast and

well inshore of the proposed survey area, none should be affected by exploration activities carried out within Block

2913B.

IMPACT ASSESSMEN T

The most significant environmental threat from offshore drilling operations is the risk of a major spill of crude oil

occurring either from a blow-out or loss of well control, which is highly unlikely with the implementation of all the

Project controls.

Offshore drilling operations carry an inherent risk of oil entering the marine environment because of an unplanned

oil spill event. Depending on the location and severity of an incident, oil could reach the coast. Reservoir

hydrocarbons, of which the exact composition is unknown, are a possible source of oil.

It was found that should an oil spill occur adjacent to the Project area, such a spil l would not reach the coast or any

conservation areas (SLR Environmental Consulting, 2017). Oil is predicted to travel in a north-westerly direction

away from the coast and thus no oil is predicted to reach the shoreline. As such, it is assumed that as Blo ck 2913B

is directly adjacent to the area studied in the SLR Environmental Consulting (2017) study, the same assumption can

be made. However, it is recommended that, prior to exploration activities commence, TOTAL develops an oil spill

management and rehabilitation plan.

CON CLUSION S AN D RECOMMEN D ATION S

The proposed would result in temporary and localised impacts on marine fauna and water quality, but it is considered

to be small and short-term under normal operating conditions. The area of interest is far removed from the

conservation area, the shore, and other sensitive receptors (e.g. key faunal breeding / feeding areas, bird or seal

colonies and nursery areas for commercial fish stocks).

Benthic communities in the area of interest are relatively ubiquitous, comprising fast-growing species that are able

to rapidly recruit into disturbed areas; thus being less susceptible to the effects of smothering. The disturbance of

benthic communities within the drill cuttings deposition footprint is considered negligible in relation to the available

area of similar habitat on and off the edge of the continental shelf in the Atlantic Offshore Bioregion. The potential

impact on the benthic fauna is considered to be localised and of short-term duration.

Government will accrue revenue, which will constitute a beneficial social impact by virtue of the fact that it will

increase the amount of money Government will have at its disposal to construct and maintain infrastructure,

implement development projects and render other services to its constituencies. TOTAL will be liable for an annual

petroleum licence area rental charge for exploration. During exploration, royalties would not apply and, as

exploration does not directly generate income, neither would direct taxes on company income / profits apply. There

would, however, be indirect benefits to the fiscus. These are likely to be relatively modest and should primarily take

the form of Value Added Tax (VAT) and income taxes levied on direct and indirect Project expenditure in Namibia as

discussed above. However, it would also be associated with moderate amounts of local expenditure leading to a

limited but positive impact on the balance of payments.

Environmental and Social Impact Assessment

(ESIA) process for the proposed Offshore Exploration Drilling - Namibia Block 2913B

Project number: 60582294

vii

Considering the relatively depressed economic base of towns where the Project wo uld be based, it is likely that the

Project will result in some, albeit limited, economic benefits through direct and multiplier effects stimulated by capital

expenditure during the mobilisation and drilling phases.

The proposed will require a workforce to mobilise the drill rig and equipment and therefore has the potential to

provide limited direct employment to people within the local study area during the mobilisation phase. It is expected

that many of these positions will only be needed for a relatively short period, and will largely involve skilled and semi-

skilled positions, with limited employment opportunities for unskilled individuals. However, the acquisition of new

skills during the mobilisation period could make individuals more employable in the future.

The fishing industry contributes to the economy of several of Namibia’s coastal towns, including Lüderitz. The

impact on fisheries and recreational fishing have not been determined; however, if activities result in a significant

negative impact on the feasibility of the fishing industry it would likely impact a considerable number of households

that are dependent on the sector for their livelihoods. Fishery studies undertaken for similar scenarios established

that it is unlikely for planned oil and gas exploration activities to have significant impacts on the fishing industry, if

appropriate mitigation is applied; however, exploration activities could in the case of unplanned events such as a

blow out from drilling and associated activities result in a low to medium impacts despite mitigation measures.

The most significant environmental threat from offshore drilling operations is the risk of a major spill of crude oil

occurring either from a blow-out or loss of well control, which is highly unlikely with the implementation of all the

Project controls. Offshore drilling operations carry an inherent risk of oil entering the marine environment because

of an unplanned oil spill event. Depending on the location and severity of an incident, oil could reach the coast.

Reservoir hydrocarbons, of which the exact composition is unknown, are a possible source of oil.

It was found that should an oil spill occur adjacent to the Project area, such a spill would not reach the coast or any

conservation areas (SLR Environmental Consulting, 2017). Oil is predicted to travel in a north-westerly direction

away from the coast and thus no oil is predicted to reach the shoreline. As such, it is assumed that as Block 2913B

is directly adjacent to the area studies in the SLR Environmental Consulting (2017) study, the same assumption can

be made.

However, it is recommended that, prior to exploration activities commencing, TOTAL develops an oil spill

management and rehabilitation plan. This plan is to be provided for authority and public comment.

Based on the findings of this ESIA, AECOM conclude that the generally low significant impacts with mitigation

associated with normal operations should support a positive decision and the issuing of an ECC for the proposed

Project.

Environmental and Social Impact Assessment

(ESIA) process for the proposed Offshore Exploration Drilling - Namibia Block 2913B

Project number: 60582294

viii

Table of Contents

1. Introduction ..................................................................................................................................................................................................................................15 1.1 Project Background ..............................................................................................................................................................................................15

1.2 Purpose of Study ....................................................................................................................................................................................................15 1.2.1 Namibia’s Oil and Gas Industry History and Policy Initiatives ..............................................................................................15

1.3 Purpose of the Environmental and Social Impact Assessment Report .....................................................................16 1.4 Structure of the Report ......................................................................................................................................................................................16

1.5 Project Team ...............................................................................................................................................................................................................17 1.5.1 The Applicant .............................................................................................................................................................................................................17

1.5.2 The Environmental Assessment Practitioner ..................................................................................................................................17 1.5.3 Summary of the Project Team ......................................................................................................................................................................18

1.6 Assumptions and Limitations .......................................................................................................................................................................19 2. Environmental and Social I mpact Assessment Process.......................................................................................................................20

2.1 Scoping Phase ..........................................................................................................................................................................................................21 2.2 Environmental and Social Impact Assessment Phase .............................................................................................................23

2.2.1 Specialist Investigations ...................................................................................................................................................................................23 2.2.2 Impact Assessment and Mitigation Measures ...............................................................................................................................24

2.2.3 Draft Environmental and Social Impact Assessment Report ..............................................................................................25 2.2.4 Environmental and Social Management Plan ..................................................................................................................................25

2.3 Final Environmental and Socia l Impact Report ...............................................................................................................................26 2.4 Decision-Making Phase ....................................................................................................................................................................................26

3. Policy, Regulatory and Administrative Framework......................................................................................................................................27 3.1 The Constitution of Namibia, 1990 ..........................................................................................................................................................27

3.2 Petroleum (Exploration and Production) Act, 1991 (Act No. 2 of 1991) and the Petroleum

(Exploration and Production) Amendment Act, 1993 (Act No. 2 of 1993)................................................................27 3.3 Environmental Management Act, 2007 (Act No. 7 of 2007) ................................................................................................27

3.4 Environmental Impact Assessment Regulations, 2012 ..........................................................................................................28 3.5 Additional Applicable Legislation ...............................................................................................................................................................28

3.6 International Laws and Conventions .......................................................................................................................................................32 3.7 Development Policies and Institutions ..................................................................................................................................................33

3.8 Project Policies and Standards ...................................................................................................................................................................34 3.8.1 TOTAL Group Code of Conduct ..................................................................................................................................................................34

3.8.2 TOTAL Group Ethics Charter .........................................................................................................................................................................34 4. Overview of the Project ......................................................................................................................................................................................................35

4.1 Project Location ......................................................................................................................................................................................................35 4.1.1 Area of Influence .....................................................................................................................................................................................................35

4.2 Project Schedule .....................................................................................................................................................................................................37 4.3 Main Project Co mponents ..............................................................................................................................................................................37

4.3.1 Onshore logistics base ......................................................................................................................................................................................37 4.3.2 Exploration Activities ...........................................................................................................................................................................................37

4.3.3 Drilling Process.........................................................................................................................................................................................................38 4.3.4 Crew Transfer .............................................................................................................................................................................................................42

4.4 Waste management .............................................................................................................................................................................................42 4.5 Description of Alternatives .............................................................................................................................................................................42

4.5.1 The ‘No Project’ Alternative ............................................................................................................................................................................42 4.5.2 Drilling Unit Options ..............................................................................................................................................................................................43

4.5.3 Onshore Base Location .....................................................................................................................................................................................43 5. Stakeholder Consultation Process ..........................................................................................................................................................................44

5.1 Stakeholder Identification and Analys is ...............................................................................................................................................44 5.1.1 Public Open Days ...................................................................................................................................................................................................45

5.1.2 Draft ESIA Report Review Perio d ...............................................................................................................................................................45

Environmental and Social Impact Assessment

(ESIA) process for the proposed Offshore Exploration Drilling - Namibia Block 2913B

Project number: 60582294

ix

5.1.3 Final ESIA Report.....................................................................................................................................................................................................45

5.2 Decision-making Phase ....................................................................................................................................................................................45 6. Baseline Environment ..........................................................................................................................................................................................................46

6.1 Physical Environment ..........................................................................................................................................................................................46 6.1.1 Climate ............................................................................................................................................................................................................................46

6.1.2 Air qualit y and Wind Patterns ........................................................................................................................................................................48 6.1.3 Bathymetr y and Geology .................................................................................................................................................................................50

6.1.4 Noise.................................................................................................................................................................................................................................51 6.2 Biophysica l Environment ..................................................................................................................................................................................52

6.2.1 Marine Habitats ........................................................................................................................................................................................................52 6.2.2 Fish .....................................................................................................................................................................................................................................54

6.2.3 Seabirds .........................................................................................................................................................................................................................56 6.2.4 Sea turtles ....................................................................................................................................................................................................................57

6.2.5 Marine Mammals .....................................................................................................................................................................................................57 6.2.6 Deep-water Coral Communities .................................................................................................................................................................59

6.2.7 Seamount Communities ...................................................................................................................................................................................59 6.2.8 Conservation Areas ..............................................................................................................................................................................................59

6.3 Social Environment ...............................................................................................................................................................................................61 6.3.1 Offs hore Economic Activities .......................................................................................................................................................................61

6.3.2 Administrative Context and Gover nance ............................................................................................................................................62 6.3.3 Demographics ..........................................................................................................................................................................................................63

6.3.4 Economic profile .....................................................................................................................................................................................................66 6.3.5 Employment and income .................................................................................................................................................................................66

6.3.6 Service delivery ........................................................................................................................................................................................................68 7. Environmental Impact Assess ment ........................................................................................................................................................................70

7.1 Impact / Activit y Screening .............................................................................................................................................................................70 7.2 Impacts on the Physical and Bio-physical Environment .........................................................................................................70

7.2.1 Release of Air Emissions ..................................................................................................................................................................................70 7.2.2 Discharge of Waste to Sea..............................................................................................................................................................................72

7.2.3 Disturbance to the Seabed / Seabed Sediments .........................................................................................................................78 7.2.4 Noise Generation ....................................................................................................................................................................................................79

7.2.5 Demobilisation and Infrastructure Abandonment .......................................................................................................................82 7.3 Impacts on the Socia l Environment .........................................................................................................................................................83

7.3.1 Employment creation during the mo bilisation phase................................................................................................................83 7.3.2 Multiplier effects on the local economy ...............................................................................................................................................84

7.3.3 Fiscal impact ...............................................................................................................................................................................................................85 7.3.4 Presence of project workforce ....................................................................................................................................................................86

7.3.5 Physical Intrusion and Nuisance Impact ..............................................................................................................................................87 7.3.6 Impacts on the fishing industry ...................................................................................................................................................................88

7.3.7 Impacts on Touris m ..............................................................................................................................................................................................88 7.3.8 Opposition because of perceived negative impacts.................................................................................................................89

7.3.9 Employment creation during the operational phase ..................................................................................................................90 7.3.10 Change in employment requirements during demo bilisation ............................................................................................91

7.4 Summary of Impacts ...........................................................................................................................................................................................91 7.5 Cumulative Impacts ..............................................................................................................................................................................................97

7.6 Unplanned Events ..................................................................................................................................................................................................97 8. Conclus ion ....................................................................................................................................................................................................................................99

9. References ................................................................................................................................................................................................................................ 101 Appendix A : Env ironmental Management Plan .......................................................................................................................................................... 105

Appendix B : Specialist Studies ................................................................................................................................................................................................ 106 B.1 Marine Noise Modelling ................................................................................................................................................................................. 107

B.2 Environmental Baseline Study ................................................................................................................................................................. 108

Environmental and Social Impact Assessment

(ESIA) process for the proposed Offshore Exploration Drilling - Namibia Block 2913B

Project number: 60582294

x

B.3 Social Impact Assessment ......................................................................................................................................................................... 109

Appendix C : Stakeho lder Database..................................................................................................................................................................................... 110 Appendix D : Scoping and ESIA Stakeholder Consultatio n ............................................................................................................................. 111

D.1 Authority Meeting Attendance Registers ........................................................................................................................................ 112 D.2 Site Notices ............................................................................................................................................................................................................. 113

D.3 Background Information Document .................................................................................................................................................... 114 D.4 Announcement Letters.................................................................................................................................................................................. 115

D.5 FGM Attendance Registers and Minutes ......................................................................................................................................... 116 D.6 Public Open Day Attendance Registers, Minutes and Information Presented .................................................. 117

D.7 Draft ESIA Public Open Day Notices ................................................................................................................................................... 118 Appendix E : Co mments and Response Report ......................................................................................................................................................... 119

Appendix F : I mpact / Activ ity Screening Results ..................................................................................................................................................... 120

Figures

Figure 2-1: Simplified Impact Assessment Process ......................................................................................................................................................20 Figure 2-2: Mitigation Hierarchy .....................................................................................................................................................................................................24 Figure 2-3: Impact Identification and Assessment Process ...................................................................................................................................25 Figure 4-1: Stages of a Petroleum Develo pment Project ..........................................................................................................................................35 Figure 4-2: Location of Exploration Block 2913B ............................................................................................................................................................36 Figure 4-3: Block 2913B in relation to other Exploration Licence Areas .......................................................................................................36 Figure 4-4: Example of Drilling Rig and Support Vessel ..............................................................................................................................................38 Figure 4-5: Schematic of drilling process ...............................................................................................................................................................................39 Figure 4-6: Drill ing fluid circulation process and solids control onboard rig ...............................................................................................40 Figure 6-1: The location of B lock 2913B in relation to neighbouring blocks 2913A and 2914B ..............................................46 Figure 6-2: Oranjemund average annual temperature (Source: National Oceanic and Atmospheric Administration

(2018)) .................................................................................................................................................................................................................................................................47 Figure 6-3: Oranjemund average annual precipitation (Source: National Oceanic and Atmospheric Administration,

2018) ....................................................................................................................................................................................................................................................................47 Figure 6-4: Oranjemund average daylight hours (Source: National Oceanic and Atmospheric Administration,

2018) ....................................................................................................................................................................................................................................................................47 Figure 6-5: Lüderitz average annual temperature (Source: National Oceanic and Atmospheric Administration,

2018) ....................................................................................................................................................................................................................................................................48 Figure 6-6: Lüderitz average annual precipitation (Source: National Oceanic and Atmospheric Administration,

2018) ....................................................................................................................................................................................................................................................................48 Figure 6-7: Lüderitz average daylight hours (Source: National Oceanic and Atmospheric Administration, 2018) .....48 Figure 6-8: The main features of the Benguela Current System (Source: Pisces Environmental Services (Pty) Ltd,

2018) ....................................................................................................................................................................................................................................................................49 Figure 6-9: Wind Speed vs Wind Direction data for the offshore area 28°29’ S; 15°16’E (Source: Pisces

Environmental Ser vices (Pty) Ltd, 2018) .................................................................................................................................................................................50 Figure 6-10: Expected Sediments within Block 2913B Offshore Namibia (Source: mo dified after Rogers, 1977) ....51 Figure 6-11: Photo of Seabed in Block 2913B...................................................................................................................................................................53 Figure 6-12: The Current System along West Coast of Namibia (Checkley et al ., 2009).................................................................53 Figure 6-13: Distribution of sardine (left) and distribution of both sardinella species (right) (Source: Benguela

Current Commission, 2012) ..............................................................................................................................................................................................................55 Figure 6-14: Sightings A: South African and Australian fur seal, B: Fin whale, C: Heviside Dolphin and D-E: ...................58 Figure 6-15: Distribution of marine species in the BCLME (Source: adapted from SLR Environmental Cons ulting,

2017) ....................................................................................................................................................................................................................................................................58 Figure 6-16: Conser vation areas along the Namibian Coast (Source: Holness et a l., 2014).........................................................60 Figure 6-17: Proposed Marine Protected Area a long the coast (Currie, Grobler, & Kemper, 2008) .........................................61 Figure 7-1: Maximum risk level on water column ..............................................................................................................................................................77

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Tables

Table 1-1: Structure and Content of the Draft ESIA Report .....................................................................................................................................17 Table 1-2: Practitioners and Specialists Contributing to ESIA Process .........................................................................................................18 Table 2-1: Potential Environmental and Socia l Impacts Identified during the Scoping Phase ....................................................21 Table 3-1: EIA Listed Activities relevant to the Project ................................................................................................................................................28 Table 3-2: Additional Applicable Laws and Regulations .............................................................................................................................................28 Table 3-3: Applicable Policies and P lans .................................................................................................................................................................................31 Table 3-4: International Treaties, Conventions and Protocols ...............................................................................................................................32 Table 4-1: Cuttings and mud volumes per phase ............................................................................................................................................................40 Table 4-2: Drilling fluids generic composition .....................................................................................................................................................................41 Table 4-3: Drilling fluids generic composition (Non-Aqueous Based Mud) .................................................................................................41 Table 5-1: Public Open Days Conducted ................................................................................................................................................................................45 Table 5-2: Venues for Draft Scoping Report ........................................................................................................................................................................45 Table 6-1: Red Data Fish Species (Davies et al ., 2014; Earth's Endangered Creatures, 2018) ....................................................55 Table 6-2: Red Date Seabird Species (Source: Davies et al., 2014; Benthic Solutions, 2019) .....................................................56 Table 6-3: Sea Turtles that may be present in the Study Area (Source: Benguela Curr ent Commission, 2012)...........57 Table 6-4: Marine mammal sightings .........................................................................................................................................................................................57 Table 6-5: Population size and distribution (Source: NSA, 2014; 2017a) ......................................................................................................64 Table 6-6: Household size and head of household (Source: NSA, 2014; 2017a) ...................................................................................64 Table 6-7: Gender and Age Distribution (Source: NSA, 2014; 2017a).............................................................................................................65 Table 6-8: Literacy by gender (15yrs>) (Source: NSA, 2016) ..................................................................................................................................65 Table 6-9: Regional literacy rural vs. urban (15yrs>), 2016 (Source: NSA, 2017a)..................................................................................65 Table 6-10: Highest level of education (20 yrs>) (Source: NSA, 2017a).........................................................................................................65 Table 6-11: Main industry of employed population aged 15 years-old and above by area, 2011-2016 (Source: NSA,

2014; 2017a,b) .............................................................................................................................................................................................................................................66 Table 6-12: Economic Activit y, 15 years and older, //Karas Region (Source: NSA, 2014; 2017a,b).........................................67 Table 6-13: Household main source of Income (Source: NSA, 2014; 2017a)...........................................................................................67 Table 6-14: Type of housing (Source: NSA, 2014; 2017a).........................................................................................................................................67 Table 6-15: Tenure status (Source: NSA, 2014; 2017a)...............................................................................................................................................67 Table 6-16: Sources of drinking and cooking water (Source: NSA, 2014; 2017a) .................................................................................68 Table 6-17: Access to sanitation (Source: NSA, 2014; 2017a) .............................................................................................................................69 Table 6-18: Energy used for cooking, lighting, and heating (Source: NSA, 2014; 2017a)................................................................69 Table 7-1: Physiological effects of a ir emissions on marine fauna ....................................................................................................................71 Table 7-2: Greenhouse gas emissions on glo bal war ming .......................................................................................................................................71 Table 7-3: Reduction of water qualit y due to normal discharge to sea ...........................................................................................................73 Table 7-4: Effect of normal discharge on marine fauna and flora........................................................................................................................74 Table 7-5: Reduction of water qualit y due to ballast discharge to sea ............................................................................................................75 Table 7-6: Reduction of water qualit y due to cuttings, drill ing fluid and cement .....................................................................................77 Table 7-7: Smothering of seabed due to discharge of cutting, drilling fluid and cement (affecting flora and fauna) .79 Table 7-8: Effects of marine noise on marine fauna .......................................................................................................................................................81 Table 7-9: D emobilisation / abandonment of infrastructure....................................................................................................................................82 Table 7-10: Employment creation.................................................................................................................................................................................................84 Table 7-11: Multiplier effects on the local economy ......................................................................................................................................................85 Table 7-12: Fiscal impact .....................................................................................................................................................................................................................86 Table 7-13: Presence of project workforce ...........................................................................................................................................................................86 Table 7-14: Physical intrusion and nuisance impacts ...................................................................................................................................................87 Table 7-15: Impact on the fishing industry ............................................................................................................................................................................88 Table 7-16: Impact on tourism .........................................................................................................................................................................................................89 Table 7-17: Opposition because of perceived negative impacts .......................................................................................................................89 Table 7-18: Employment creation during operation ......................................................................................................................................................90 Table 7-19: Change in employment requirements ..........................................................................................................................................................91 Table 7-20: Summary of Physical and Bio physica l Impacts ....................................................................................................................................92 Table 7-21: Summary of Socia l Impacts .................................................................................................................................................................................95

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Acronyms and Abbreviations

Acronym or

Abbreviation Description

AECOM AECOM Africa (Pty) Ltd

AIDS Acquired Immunodeficiency Syndrome

AoI Area of Influence

BCLME Benguela Current Large Marine Ecosystem

BOP Blowout preventer

BWM Ballast Water Management

CaCO3 Calcium carbonate

CLO Community Liaison Officer

CO Carbon monoxide

CO2 Carbon dioxide

COLREGs Convention on the International Regulations for Preventing Collisions at Sea

CR Critically Endangered

CRR Comment and Response Report

dB Decibel

DREAM Dose related Risk and Effect Assessment Model

DSR Draft Scoping Report

EAP Environmental Assessment Practitioner

EBS Environmental Baseline Study

ECC Environmental Clearance Certificate

ECO Environmental Control Officer

EHS Environmental Health and Safety

EHS Environment, Health and Safety

EIA Environmental Impact Assessment

EMA Environmental Management Act, 2007 (Act No. 7 of 2007)

EMS Environmental Management System

EN Endangered

ESDD Environmental and Social Due Diligence

ESIA Environmental and Social Impact Assessment

ESMP Environmental and Social Management Plan

FGMs Focus Group Meetings

FSR Final Scoping Report

GDP Gross Domestic Product

GG Government Gazette

GHG Greenhouse Gas

GIS Geographic Information Systems

GRN Government of the Republic of Namibia

H2S Hydrogen sulphide

HIV Human Immunodeficiency Virus

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Acronym or Abbreviation

Description

HVAC Heating, ventilation, and air conditioning

I&APs Interested and Affected Parties

IAIA International Association for Impact Assessment

IFC International Finance Corporation

IMCO Inter-Governmental Maritime Consultative Organization

IMO International Marine Organisation

km Kilometre

km2 Square kilometre

LCMs Lost circulation materials

m Metre

m2 Square metre

m3 Cubic metre

MARPOL International Convention for the Prevention of Pollution from Ships

mbmsl Meters below mean sea level

MET Ministry of Environment and Tourism

MFMR Ministry of Fisheries and Marine Resources

mm Millimetre

MME Ministry of Mines and Energy

MoHSS Ministry of Health and Social Services

MPA Marine Protected Area

ms Milliseconds

ms Milliseconds

MSDS Material Safety Data Sheet

NACOMA Namibian Coast Conservation and Management Project

NADF Non-aqueous drilling fluid

NAMCOR National Petroleum Corporation of Namibia

NamPort Namibian Ports Authority

NDP National Development Plan

NGP National Gender Policy

NMPCP (Namibian) National Marine Pollution Contingency Plan

NOx Oxides of Nitrogen

NSA Namibia Statistics Agency

O2 Oxygen

ODS Ozone Depleting Substance

OPRC International Convention on Oil Pollution Preparedness, Response and Co-operation

HNS Hazardous and Noxious Substances

OSCP Oil Spill Contingency Plan

OSPAR Convention for the Protection of the Marine Environment of the North -East Atlantic

PEC Predicted Environmental Concentration

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Acronym or Abbreviation

Description

PNEC Predicted No Effect Concentrations

PPE Personal Protective Equipment

PTS Permanent Threshold Shift

REACH Registration, Evaluation, Authorisation and Restriction of Chemicals

ROV Remotely Operated Vehicle

SABS South African Bureau of Standards

SACNASP South African Council for Natural Scientific Professions

SACW South Atlantic Central Water

SCP Stakeholder Consultation Process

SEA Strategic Environmental Assessment

SEL Sound Exposure Level

SIA Social Impact Assessment

SOLAS International Convention for the Safety of Life at Sea

SOPEP Shipboard Oil Pollution Emergency Plan

SOx Oxides of Sulphur

SPL Sound Pressure Level

SPRFMA South Pacific Regional Fisheries Management Authority

SWAPO South West Africa People's Organization

TB Tuberculosis

TCP Technical Co-operation Permit

ToR Terms of Reference

TOTAL TOTAL EP NAMIBIA B.V.

TTS Temporary Threshold Shift

UNCLOS United Nations Convention on the Law of the Sea

UNESCO United Nations Educational, Scientific and Cultural Organization

VAT Value Added Tax

VCT Voluntary Counselling and Testing

VOS Voluntary Observing Ship

VSP Vertical seismic profile

VU Vulnerable

WBM Water Based Mud

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1. Introduction

1.1 Project Background

TOTAL EP NAMIBIA B.V. (TOTAL), as operator and major (70%) shareholder, proposes to undertake offshore

exploration drilling activities in Block 2913B (the Project). The surface area of Block 2913B is approximately 8 ,215

square kilometres (km2), with several wells possibly to be drilled for exploration or appraisal purposes within this

block.

Exploration drilling will take place within offshore Block 2913B which is approximately 300 kilometres (km) off the

coast of Namibia from Lüderitz. Water depths in this area range from approximately 2 ,600 to 3,300 meters below

mean sea level (mbmsl). The well’s total depth is expected to be about 6,260 mbmsl. The duration of drilling

operations is expected to be approximately three (3) to six (6) months per well, anticipated to commence in the

second half 2019 and first half of 2020.

1.2 Purpose of Study

TOTAL holds an Exploration Licence under Block 2913B offshore and intends to implement the activities of the

exploration programme by drilling exploration and appraisal wells within the exploration licence area.

The main objectives of the proposed Project are to:

Confirm and specify the presence of hydrocarbon deposits; and

In case of discovery, further exploration and appraisal wells may be required to understand the characteristics

of the reservoir and its commercial interest.

Potential direct future benefits which could result from this Project include:

Contributing towards the need for economic activity development within the Lüderitz and Oranjemund areas;

Potential job opportunities; and

Potential contribution to science sharing relevant biodiversity benthos data.

More details of the proposed Project are provided in Section 4.

1.2.1 Namibia’s Oil and Gas Industry History and Policy Initiatives

The first Namibian oil and gas exploration wells were drilled in the 1960s, but it wasn’t until 1974 that the presence

of hydrocarbons was confirmed through the discovery of the Kudu Gas Field on the northern section of the Orange

Basin, directly west of Oranjemund. By 1991, fewer than ten hydrocarbon wells had been drilled in Namibia, with no

commercially viable reserves having been discovered (Light & Shimutwikeni, 1991).

Between 2010 and 2014, at least 13 wells were drilled in Namibia bringing the total number of offshore hydrocarbon

wells drilled in Namibian waters to 32. Of these, 15 have been exploratory wells, seven have been appraisal wells,

and a further ten have been drilled for scientific research (National Petroleum Corporation of Namibia (NAMCOR),

2017a). The collection of survey, seismic and aeromagnetic data has contributed to a substantial geological and

geophysical database for the country and has revealed the existence of four offshore frontier basins of interest to

explorers: The Orange, Lüderitz, Walvis and Namibe basins. Commercially viable petroleum reserves are yet to be

discovered in Namibia.

Policy advice is provided to Ministry of Mines and Energy (MME) by NAMCOR, a state-owned company which is also

responsible for promoting exploration and production in the country. NAMCOR also has “the mandate to carry out

reconnaissance, exploration and production operations either on its own or in partnership with other organisations

in the industry” (NAMCOR, 2017b). NAMCOR is actively engaged in identifying prospects and leads, as well as in

promoting and marketing the oil and gas potential of Namibia to local and international companies.

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1.3 Purpose of the Environmental and Social Impact Assessment

Report

AECOM Africa (Pty) Ltd (AECOM) was appointed by TOTAL as the independent Environmental Assessment

Practitioner (EAP) to conduct the Environmental and Social Impact Assessment (ESIA) process, in support of the

required Namibian legislative authorisations. More details of the ESIA Project team are provided in Section 1.5. The

ESIA to be conducted is intended to fulfil the Namibian EIA requirements, as well as TOTAL’s own internal standards

for ESIA investigations.

The purpose of this Draft ESIA and Environmental and Social Management Plan (ESMP) Report is to summarise:

A description of EAP that prepared the report;

A detailed description of the proposed activity;

A description of the need and desirability of the project and details of the alternatives that were investigated;

A description of the environment that may be affected;

A description of the Stakeholder Consultation Process (SCP) that was undertaken tote da;

Findings, recommendations and copies of specialist studies;

An indication of the method used to identify impact significance;

An assessment of specific information required by the competent authority;

A comparative assessment of all alternatives, where applicable;

An assessment of each potentially significant impact;

A description of any assumptions, uncertainties and gaps in knowledge;

An opinion on whether the activity should be authorised or not and, if it should be authorised, under what

conditions; and

An ESMP for the full lifecycle of the Project.

This Draft ESIA Report will be made available for public review for a period of 21 days. Subsequently, comments

from stakeholders will be incorporated into an updated Final ESIA Report. This repo rt will be submitted to the MME

as the competent authority, for review and recommendation to the Ministry of Environment and Tourism (MET) who

will make the final decision on the Application for the Environmental Clearance Certificate (ECC).

1.4 Structure of the Report

This report has been prepared in compliance with the Environmental Impact Assessment (EIA) Regulations, 2012.

The structure and content are outlined in Table 1-1 below.

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Table 1-1: Structure and Content of the Draft ESIA Report

Chapter Description

Chapter 1: Introduction

Chapter 2: Environmental and Social Impact Assessment Process

Chapter 3:

Policy, Regulatory and Administrative Framework

Chapter 4: Overview of the Project

Chapter 5: Stakeholder Consultation Process

Chapter 6: Baseline Environment

Chapter 7: Environmental Impact Assessment

Chapter 8: Conclusion

Chapter 9: References

1.5 Project Team

The team contributing to the undertaking of the ESIA process is indicated below.

1.5.1 The Applicant

Details of the Applicant for the ECC are:

Applicant Details

Applicant Company: TOTAL E&P Namibia B.V.

Business Registration: F/68916361

Correspondence Address: 5 Otto Nitzsche Strasse

Klein Windhoek

Windhoek

Namibia

Contact Person: Adewale Fayemi

Position of Contact Person: Managing Director TOTAL E and P Namibia

Telephone No: +256 204 91 6001

E-mail Address: [email protected]

1.5.2 The Environmental Assessment Practitioner

Details of the EAP are:

Environmental Assessment Practitioner Details

EAP: Ms Nicola Liversage

Representing Company: AECOM Africa (Pty) Ltd

Postal Address: P O Box 3173

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Environmental Assessment Practitioner Details

Pretoria

South Africa

0001

Telephone: +27 12 421 3500

E-mail Address: [email protected]

Nicola Liversage obtained an MSc degree in Geography from the University of Natal in 2003. She is a registered

professional scientist (Pri.Sci.Nat) in Environmental Science with the South African Council for Natural Scientific

Professions (SACNASP), a Green Star South Africa Accredited Professional with the Green Building Council of South

Africa for New Buildings and a member of the International Association for Impact Assessment South Africa (IAIAsa).

Nicola also sits on the impartiality committee of the South African Bureau of Standards (SABS).

Nicola has been involved in the environmental consulting industry since 2003 with previous experience in academia ,

conservation, and Geographic Information Systems (GIS) consulting, and with temporary and part time experience

in administration. She is an AECOM accredited and trained Project Manager with extensive experience in project

managing and directing numerous environmental projects across Africa for major infrastructure developments. She

has experience with local African legislative requirements as well as the World Bank Guidelines, Equator Principles

and International Finance Corporation (IFC) Performance Standards. Nicola’s technical expertise lies in str ategic

environmental assessment and advisory.

Nicola currently leads a team of Environmental Consultants covering Environmental and Social Due Diligence

(ESDD), bank and acquisition/divestment due diligence, Phase 1 and 2 site investigations, Environment, Health and

Safety (EHS) Audits, Phase 3 / full scale remediation, Environmental Control Officer (ECO) and Environmenta l

Monitoring, ESIA, Strategic Environmental Assessment (SEA), Public and Stakeholder Engagement, Environment in

Design, Feasibility and Site/Route determination, Environmental Management Systems (EMSs), Resettlement

Action Plans and Social Impact Assessments (SIAs).

1.5.3 Summary of the Project Team

A summary of the Project team of practitioners and specialists that will be contributing to the ES IA process is

presented in Table 1-2.

Table 1-2: Practitioners and Specialists Contributing to ESIA Process

Team Member Company / Organisation Responsibility

A p p l ic an t

Mr Jason Frederick TOTAL ESIA Project Manager

Ms Monica Castro TOTAL Social Specialist

ESIA Con sultan ts

Ms Irina Seledchikova AECOM Project Director

Ms Nicola Liversage AECOM Environmental Assessment Practitioner

Dr Lima Maartens LM Environmental Consulting Namibian ESIA Consultant

Ms Phindile Mashau AECOM Environmental Scientist

Sp e c ial ists

Mr Simon Redford Benthic Solutions Limited (BSL) Environmental Baseline Survey

Mr Colin O’Connor AECOM Marine Noise Modelling

Mr Jurie Erwee AECOM Social Specialist

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1.6 Assumptions and Limitations

The following assumptions, limitations and constraints associated with the Project have been identified for this ESIA

process:

The ESIA process is multi-disciplinary and is informed by the Project team. It is thus necessary to assume that

the information provided by the Project team is accurate and true, at the time it was sourced;

Data shown in the maps were supplied by various sources and were used as received. The data was not

verified; and

Regarding the SCP process, every effort was made to inform all possible interested and affected stakeholders.

Information presented by the stakeholders is presumed to be accurate and has been presented timeously.

Very limited information is available of the project area, so comparisons have been made with the neighbouring

exploration areas Block 2913A and 2914B and the Orange Basin Technical Co-operation Permit (TCP), which

lies offshore on the west coast of South Africa.

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2. Environmental and Social Impact Assessment Process

ESIA is a systematic approach to identifying the potential impacts of a project, and describing the mitigation,

management and monitoring measures that will be implemented to address these impacts. Ultimately, the results

of the ESIA will allow relevant organisations to make informed decisions about development proposals and allow

potentially affected stakeholders to participate in the process.

To ensure a robust and detailed impact assessment, the ESIA process has been structured over a series of

progressive and iterative stages. Stakeholders, the Project team, and the assessment team will all provide input to

these stages during the ESIA process.

Deciding whether impacts are within or outside of the scope of the ESIA is an important step towards ensuring that

the impact assessment is relevant and properly tailored to the project. Site-specific environmental and socio-

economic factors influence the nature and scale of potential impacts and can vary substantially between projects,

even when developments appear similar.

The impact assessment process has been summarised within Figure 2-1.

Figure 2-1: Simplified Impact Assessment Process

The steps identified in Figure 2-1 are much simplified but convey the general approach to an ESIA. Potential impacts

during the construction, operational and decommissioning phases of the project will be considered separately in

the ESIA. A summary of the key stages of the ESIA process is provided here:

Scr eening: An early exercise to identify how the Project might interact with the environment. Screening

focuses the ESIA on the most likely interactions and receptors and assists in incorporating environmental and

social considerations into project planning and design;

Bas eline Studies: A process to understand the existing social and environment context through desk-based

and field-based research so that impacts can be more accurately predicted, and to provide a baseline against

which changes can be measured. It is important to note that baseline studies continue during the Scoping

stage and beyond if necessary;

Sco ping: Utilises more detailed engineering data along with some preliminary baseline data and feedback from

stakeholders. The Scoping stage also identifies the topics and methodologies which will be included within

the main ESIA Report. The output of this phase is the Final Scoping Report (FSR);

Impact Assessment o f ESIA Repo r t (the subject of this document): predicts and assesses the expected

impacts of the project, based on the project description, baseline studies, feedback from stakeholders, and

professional expertise. The impact assessment categorises potential impacts based on their significance,

which may be rated as either No Impact, Low impact, Medium Impact, High Impact or Fatal Flaw significance.

This also includes the development of mitigation and management measures and the re-evaluation of the

impacts after measures are applied (i.e. residual impacts). The output of this phase is the ma in ESIA and ESMP

Report.

Mit igation, Management, and Monito r ing : Commitments relating to proposed mitigation measures in order to

avoid, reduce, compensate or offset adverse impacts, and enhance beneficial measures, will be contained in

the ESIA Report and the associated ESMP. The ESMP published with the ESIA will provide high level mitigation

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and monitoring measures and form the basis for the preparation of detailed management and implementatio n

plans covering certain activities of the mobilisation, operation and demobilisation phases, or potentially

affected receptors.

The ESIA and associated technical studies were undertaken in line with relevant Namibian legislation and other

applicable international standards (see Section 3).

The ESIA for this Project aim to address the impacts associated with the proposed exploration Project and provide

an assessment of the Project in terms of the biophysical, social and economic environments to assist the

environmental authorities (MME and MET) and TOTAL in making decisions regarding the design, commissioning,

exploration and abandoning (decommissioning) of the proposed Project.

Consistent with the Namibian EIA process, this ESIA process consists of three phases:

Scoping Phase (including the Plan of Study for the EIA);

EIA Phase (including the ESMP) – the current phase; and

Decision-Making Phase.

2.1 Scoping Phase

The main purpose of the Scoping Phase was to identify and investigate issues related to the Project and list

potentially significant impacts that require further assessment in the ESIA Phase.

Issues and impacts were identified by the project team using theoretical knowledge, experience on similar projects,

and consultation with I&APs and other key stakeholders (such as National, Regiona l and Local Government

Departments and Authorities). The Scoping Phase also identified the most appropriate means by which the

potential impacts were assessed.

Table 2-1 contains the impacts identified by the EAP, Project team, as well as those identified by registered I&APs

during the Scoping Phase. The table also indicates which activity to be conducted during the ESIA Phase will assess

the identified impact, and which ESIA deliverable will provide the impact assessment, associated significance and

recommended mitigation or enhancement measures.

Table 2-1: Potential Environmental and Social Impacts Identified during the Scoping Phase

Activities Aspect Impact Description

Air Emissions Air quality Physiological effect on marine fauna and contribution to global greenhouse gas

emissions. Emissions may be generated by exhaust gas, fugitive emissions

associated with leaking tubing, pumps and other equipment, vent or flaring of oil and

gas used during well testing.

Physical,

Biological and

Marine

Environment

Unplanned events

e.g. small

operational spill,

blowout

Offshore drilling operations carry an inherent risk of oil entering the marine

environment as a consequence of an unplanned oil spill event.

Biological

Environment

Discharge of waste

to sea

Different types of waste may be discharged to sea. These include: deck drainage,

machinery space drainage, sewage, galley waste, cooling water and the opening

and closing of the blowout preventer (BOP). The discharge of waste to sea could

create local reductions in water quality. Deck and machinery space drainage may

result in small volumes of oils, detergents, lubricants and grease, the toxicity of

which varies depending on their composition, being introduced into the marine

environment. Sewage and gallery waste would place a small organic and bacterial

loading on the marine environment, resulting in an increased biological oxygen

demand.

Traffic Support vessel

traffic interaction

The implementation of the safety zone around the drilling unit would effectively

exclude fishing vessels from accessing fishing grounds within 500 m of the drilling

unit. The abandonment of the wellhead on the seafloor would also pose an

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Activities Aspect Impact Description

with commercial

fishing

obstruction to any fishing activity directed towards the seabed (namely any

demersal and longline fisheries).

The exclusion of fisheries from the safety zone would effectively reduce fishing

grounds, which in turn could potentially result in a loss of catch and/or increased

fishing effort. The majority of fishing effort is directed inshore of the 1,000 m

isobaths, far inshore of the area of interest. Only one fishery, the large pelagic

longline sector, is in the vicinity of Block 2913B. None of the other fishing sectors

are expected to be affected by the proposed exclusion zone.

Traffic Support vessel

interaction with

recreational fishing

and tourism

The support vessel travelling from the port to the drilling unit may affect existing

recreational fishing, angling and boat trip routes, specifically from the southern

limits of Diaz Point to Grosse Bucht which is close to Lüderitz. The impact on these

routes could potentially lead to either an increase or a decrease in recreational

fishing and tourism. Facilities close to Diaz Point to Grosse Bucht could experience

a decrease in tourist accommodation capacity presuming that Project staff is

accommodated in that area.

Benthic

Environment

Physical

disturbance of the

seabed sediments

Drilling operations would result in the direct physical disturbance and removal of

sediments, as well as potential changes in sediment characteristics and condition.

Any benthic fauna present on the seabed and in the sediment in the disturbance

footprint would be either completely eliminated or may potentially be disturbed or

crushed. Resuspension of seabed sediments may also result in increased turbidity

near the seabed, potentially with physiological effects on benthic faunal

communities.

Marine

Environment

Noise Various sources of noise within the marine environment may be created: drilling

noise, propeller and positioning thrusters, well logging and testing noise, machinery

noise, and helicopter noise. Elevated noise levels could impact marine fauna.

Social Employment

creation

The proposed Project has the potential to create limited local employment

opportunities. Employment will likely improve the income and quality of life of those

individuals and families who benefit from employment.

Social Local procurement

of goods and

services

Several activities will require the purchase of equipment and services and could

generate several contracts, which could improve business for local suppliers.

Social Multiplier effect on

the local economy

The Project’s capital expenditure, as well as monthly wage bill and procurement

expenses, are expected to result in an injection of cash into the economy of the

broader Project area. Thus, the Project could result in several economic benefits for

local business communities through multiplier effects.

Social Nuisance impacts Project activities could result in an increase of the ambient noise due to the

helicopter transfers between the drilling unit and Oranjemund and restrict traffic and

movement patterns of local residents and commuters at the logistical base . These

impacts could thus result in a decrease in the quality of life. Nuisance impacts

generally results in a deterioration of sense of place, the magnitude of this impact

depends on several factors. One of these factors is the current state of the

landscape: The impact of a large and visible artificial structure on the sense of place

will be correspondingly larger than if the landscape already bears the marks of

development, similarly the baseline noise, traffic, air quality levels will determine how

communities will be receptive or can adapt to any changes. Another factor is the

meanings and feelings that people attach to the anticipated changes. If a

development promises to offer tangible benefits to surrounding communities (for

example job creation in a context of high unemployment or development), it is

unlikely that its impact on the character of the landscape or increase in nuisance

levels will be perceived in a negative light by most community members – even if

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Activities Aspect Impact Description

that impact is substantial from a nuisance point of view. If the proposed Project is

evaluated against these criteria, it is evident that it could produce a significant

impact in the context of Oranjemund, but to a lesser degree in the more

industrialised Lüderitz; however, Oranjemund might be more receptive and/or

willing to adapt to nuisance levels considering the potential benefits of the Project.

Social Stakeholder

opposition

It is possible that there could be some opposition towards the proposed Project,

especially as a result of people’s perceptions around employment, safety and

economic impacts.

Social Decommissioning

phase impacts

It is inevitable that the individuals employed during the Project’s exploration phase

will lose their jobs upon decommissioning.

Stakeholder engagement was conducted to identify potential I&APs, inviting I&APs to register , as well as to notify

I&APs of the ESIA process to obtain the required ECC from the MME. Input from I&APs has been considered and

was integrated into the Draft Scoping Report (DSR).

The DSR was made available for public comment over a period of 21 calendar days (excluding public holidays). All

comments received were captured in a Comment and Response Report (CRR) and included in the FSR , submitted

to the MME for acceptance.

2.2 Environmental and Social Impact Assessment Phase

All potential significant environmental issues (physical, biophysical, social and economic) associated with the

proposed Project identified in the Scoping Phase (Table 2-1) were investigated during the ESIA Phase.

2.2.1 Specialist Investigations

To address the potential impacts identified during the scoping phase (Table 2-1), the specialist investigations

described below were conducted. Specialist reports are contained in Appendix B.

2.2.1.1 Environmental Baseline Studies

An Environmental Baseline Study (EBS) was conducted to characterise the existing environment, with the following

objectives:

Describe the main physico-chemical and biological characteristics of the study area and highlight its main

sensitivities;

Emphasise the presence of any endangered species and/or habitat as well as the different types of invasive

species;

Describe the socio-economic context and activities related to the study area;

Locate, describe and map sensitive areas present in Block 2913b including biodiversity and ecosystems

services (i.e. existing or potential benefits that biodiversity or ecosystems contribute towards human well-

being; e.g. provisioning services, regulating services, cultural services and/or supporting services); and

Clearly identify and assess any existing infrastructure and/or any existing contamination of the natural

environment by pollutants (including but not limited to natural seepage) located wit hin the Block 2913B in order

to preserve the Company’s rights and circumscribe its responsibilities.

2.2.1.2 MetOcean Study

A Meteorological and Oceanographic Study (MetOcean Study) was conducted in Block 2913B. It collected the

following data:

Currents speed and directions through the water column;

Sea temperatures and salinity through the water column;

Water elevation;

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Wind speed and directions and atmospheric parameters; and

Wave height, period and directions.

2.2.1.3 Marine Noise Assessment

The relevant criteria and noise level thresholds for marine fauna (e.g. cetaceans, fish) to be used in the assessment

were determined. In addition, calculations of sound exposure levels on marine fauna and the preliminar y

determination of marine exclusion / impact zones for proposed marine drilling activities (including support vessels)

and vertical seismic profile (VSP) at Namibia Block 2913B were conducted.

2.2.1.4 Social Impact Assessment

The Social Impact Assessment (SIA) was conducted to:

Describe the baseline socio-economic environment of the site and surrounding area;

Verify, assess and rate the potential socio-economic impacts that may arise as a result of proposed Project

activities;

Identify, rank and assess the anticipated positive and negative social impacts of the proposed P roject;

Formulate appropriate mitigation measures to avoid and/or mitigate the anticipated negative social impact and

enhance positive impacts;

Develop appropriate mechanisms to manage and monitor socio -economic impacts and the mitigation or

enhancement thereof; and

Provide essential social input into the environmental authorisation process.

2.2.2 Impact Assessment and Mitigation Measures

The impact assessment methodology, as described during the Scoping Phase of the ESIA, takes into consideration

an impact’s nature (adverse or beneficial), type (direct, secondary or cumulative) and magnitude, and the sensitivit y

of the affected receptors, to yield a prediction of the impact’s overall ‘significance’.

Impact significance was assessed considering existing control measures that are incorporated into the Project

design. After the remaining potential impacts have been identified and a preliminary assessment was conducted,

strategies to further avoid or mitigate the impacts were then developed.

Where an adverse impact was identified, efforts were made to develop strategies to primarily avoid (e.g. through the

design process) or minimise the impact. The selection of mitigation measures has considered a standard mitigation

hierarchy (Figure 2-2) whereby preference is given to avoiding impacts altogether and subsequently to minimising

the impact, repairing its effects, and/or offsetting the impact through actions in other areas.

Figure 2-2: Mitigation Hierarchy

Mitigation and management measures were captured in an EMP. The EMP outlines all of the impact mitigation and

management requirements to be implemented during the course of Project implementation, including, where

necessary decommissioning.

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The significance of the impacts was then re-evaluated based on these mitigation measures. The resulting impact is

known as the ‘residual’ impact and represents the impact that will remain following the application of mitigation and

management measures, and thus the ultimate level of impact associated with the Project. The basic process which

was adopted for assessing potential Project impacts in the ESIA is illustrated in Figure 2-3.

Figure 2-3: Impact Identification and Assessment Process

2.2.3 Draft Environmental and Social Impact Assessment Report

This Draft ESIA Report has been prepared in compliance with Section 15(2) of the EIA Regulations 2012. The

specialist studies and other relevant information / assessments have been integrated into this report. The Draft

ESIA Report will be made available for public comment over a period of 21 calendar days (excluding public holidays).

The objective of the public comment period is for I&APs to raise issues about the information presented in the report

and for them to raise any other issues related to the proposed Project. It also provides an opportunity for I&APs to

see if their issues have been captured correctly.

2.2.4 Environmental and Social Management Plan

The ESMP (Appendix A) outlines the impacts and mitigation measures for the planning / mobilisation,

exploration/drilling (operation), and demobilisation phases of the Project. The ESMP comprises the following:

Summary of impacts: the predicted negative environmental impacts for which mitigation is required, and

positive impacts requiring enhancement;

Description of mitigation measures: the ESMP identifies feasible and cost-effective mitigation measures to

reduce significant negative environmental impacts to acceptable and legal levels. Mitigation measures are

described in detail and will be accompanied by designs, equipment descriptions, and operating procedures,

where appropriate, as well as descriptions of technical aspects of implementing the mitigation measures;

Description of monitoring programme: the monitoring programme indicates the linkages between impacts,

indicators to be measured, measurement methods and definition of thresholds that will signal the need for

corrective actions;

Emergency Action Plan: the identification of possible accidents during the various phases of the Project, with

measures on how these will be prevented and/or managed;

Institutional arrangements depict and define the responsibilities for mitigation and monitoring action;

─ Legal enforceability: the key legal considerations with respect to the ESMP are:

Legal framework for environmental protection.

Legal basis for mitigation.

Implementation schedule and reporting procedures that specify the t iming, frequency and duration of the

mitigation measures; and

Description of requirements for record keeping, reporting, review, auditing and updating the EMP.

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2.3 Final Environmental and Social Impact Report

Following the review period, the Draft ESIA Report will be updated with comments received from the public to

produce a Final ESIA Report. The Final ESIA Report will be submitted to the MME for recommendation to MET. MET

will then issue a decision concerning the ECC.

2.4 Decision-Making Phase

If the proposed Project is authorised to proceed, an ECC will be drafted and issued. The ECC may contain conditions

that TOTAL must adhere to. All I&APs will be notified of the decision and appeal provisions. Should I&APs or TOTAL

disagree with the decision taken, they may lodge an appeal.

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3. Policy, Regulatory and Administrative Framework

This section provides an overview of the policy and legislative context, including the preliminary identification of

legislation, policies, plans, guidelines and instruments applicable to the Project.

3.1 The Constitution of Namibia, 1990

The Namibian government has adopted a number of policies that promote sustainable development. Most of these

originate in clauses of the Namibian Constitution. In Article 95 (i), the State undertakes to actively promote and

maintain the welfare of the people by adopting policies aimed at the utilisation of natural resources on a sustainable

basis for the benefit of all Namibians. Article 98 (i) provides assurance that “the economic order of Namibia shall be

based on the principles of a mixed economy with the objective of securing economic growth, prosperity and a life

of human dignity for all Namibians”. Article 100 provides for the Sovereign Ownership of Natural Resources; all land,

water and natural resources shall belong to the State except when lawfully owned. Article 144 gives provision for

International Law and Agreements binding upon Namibia (Republic of Namibia, 1990) (Government of the Republic

of Namibia (GRN), 2005a).

The constitutional recognition of environmental concerns triggered widespread legislative reform relating to the

management of natural resources in Namibia. The country’s environmental protection effort is currently comprised

of the Environmental Management Act, 2007 (Act No. 7 of 2007) and its Regulations (2012).

3.2 Petroleum (Exploration and Production) Act, 1991 (Act No. 2 of 1991) and the Petroleum (Exploration and Production) Amendment

Act, 1993 (Act No. 2 of 1993)

TOTAL Namibia holds an offshore Exploration Licence under Block 2913B and intends to implement the activities

of the exploration programme by drilling one or more exploration wells within the exploration licence area.

In accordance with the Petroleum Act, 1991 and in an effort to promote petroleum exploration activities in Namibia,

the MME is the Competent Authority for this Project. In terms of Section 34 of the Petroleum Act , 1991, the

Directorate of Petroleum Affairs within the MME regulates the petroleum industry. It issues licences for petroleum

exploration and production and can approve or reject licence applications based on the outcome of ESIA reports.

3.3 Environmental Management Act, 2007 (Act No. 7 of 2007)

The purpose of the Environmental Management Act, 2007 (EMA) is to “promote the sustainable management of the

environment and the use of natural resources by establishing principles for decision making on matters affecting

the environment; to establish the Sustainable Development Advisory Council; to provide for the appointment of the

Environmental Commissioner and environmental officers; to provide for a process of assessment and control of

activities which may have significant effects on the environment; and to provide for incidental matters.”

The Act requires adherence to the principle of optimal sustainable yield in the exploitation of all natural resources.

The Act gives effect to Article 95 (l) of the Namibian Constitution by establishing general principles for the

management of the environment and natural resources. It promotes the coordinated and integrated management

of the environment and sets out responsibilities in this regard. Furthermore, it intends to give statutory effect to

Namibia’s Environmental Assessment Policy; further, it enables the Minister responsible for the environment to give

effect to Namibia’s obligations under international environmental conventions; and provides for associated matters.

The EMA promotes inter-generational equity in the utilisation of all natural resources. Environmental impact

assessments and consultations with communities and relevant regional and local authorities are provided for to

monitor the development of projects that potentially have an impact on the environment.

To obtain an ECC, a person who wants to carry out an activity listed according to Section 27 of the EMA must follow

a multi stage process in line with Sections 32-37 of the EMA and with the regulations for the implementation of the

EMA as Gazetted in February 2012 which have listed certain activities that may not be undertaken without an ECC.

The MET is the custodian of Namibia’s natural environment and its mission is to “promote biodiversity conservation

in the Namibian environment through the sustainable utilisation of natural resources and tourism development for

the maximum social and economic benefit of its citizens”. MET develops, administers and enforces environmenta l

legislation and policy.

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The MET is responsible for the administration of the ESIA process undertaken in terms of the Environmenta l

Management Act, 2007 and the EIA Regulations, 2012. The MET will be responsible for issuing a decision on the

ESIA based on the recommendation from MME. If approved, the MET will issue an ECC.

3.4 Environmental Impact Assessment Regulations, 2012

On 6 February 2012 the Commencement of the Environmental Management Act, 2007 (Act No. 7 of 2007) was

published in the Government Gazette (GG), thereby becoming law. The Minister of Environment and Tourism, under

Section 56 of EMA, made the regulations set out in the Schedule (GRN, 2012) . The Minister also listed activities

(each with sub-activities) that may not be undertaken without an ECC.

All activities which need an ECC must follow the EIA Regulations, 2012, which have been made according to Section

56 of the EMA. These require inter alia that the proponent of an activity designates an EAP to manage the

assessment process and ensures that the environmental assessment procedures, specified in the EMA, the EIA

Regulations and Guidelines, are followed.

Listed activities, as contained in the EIA Regulations, 2012, applicable to the Project are indicated in Table 3-1.

Table 3-1: EIA Listed Activities relevant to the Project

Activity Number Activity Description Relevance to the Project

Listed Activity 2.3 The import, processing, use and recycling, temporary storage, transit or export of waste.

Waste would be generated by the drilling unit and transported to shore. Drill cuttings will be discharged to the sea.

Listed Activity 3.2 Other forms of mining or extraction of any natural resources whether regulated

by law or not.

The objective of the proposed exploration well drilling is to discover and appraise the hydrocarbon potential

of the geological structure or “prospect” in the area of

interest. This may result in the extraction of oil or gas. Listed Activity 3.3 Resource extraction, manipulation,

operation, conservation and related

activities.

Listed Activity 3.4 The extraction or processing of gas from natural and non-natural resources.

Listed Activity 9.1 The manufacturing, storage, handling or processing of a hazardous substance

defined in the Hazardous Substances

Ordinance, 1974

Non-aqueous drilling fluid (NADF) and hydrocarbons are not specifically defined in the Hazardous

Substances Ordinance, 1974. This activity has,

however, been included as components of the drilling fluid are hydrocarbons and the “general view” is that

hydrocarbons are hazardous.

Listed Activity 9.3 The bulk transportation of dangerous goods using pipeline, funiculars or

conveyors with a throughout capacity of

50 tons or 50 cubic metres (m3) or more

per day.

The proposed drilling operation would make use of infrastructure (particularly the pipe casings inside the

wellbore) which could convey oil or gas from the

geological structure to the drilling unit at the surface.

This activity is included to provide for a situation where the throughput capacity of hydrocarbons is 50 tons or

50 m3 or more per day.

Listed Activity 9.4 The storage and handling of a dangerous goods, including petrol, diesel, liquid

petroleum gas or paraffin, in containers

with a combined capacity of more than 30 m3 at any one location.

The proposed drilling operation would make use of infrastructure which would handle and would store oil,

gas and/or fuel (diesel). This activity is included to

provide for a situation where the combined storage capacity exceeds 30 m3 at any one location.

Listed Activity 10.1 The construction of (e) any structure

below the high-water mark of the sea;

The proposed drilling operations would result in the placement of drilling equipment (i.e. a wellhead) on the

seabed. During decommissioning the wellhead(s)

would be abandoned on the seafloor.

3.5 Additional Applicable Legislation

Additional legislation that may be applicable to the Project are summarised in Table 3-2 below.

Table 3-2: Additional Applicable Laws and Regulations

Sector Law

Petroleum Petroleum Products and Energy Act, 1990 (Act No. 13 of 1990) (as amended by the Petroleum

Products and Energy Amendment Act, 1994 (Act No. 29 of 1994), Petroleum Products and Energy

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Sector Law

Amendment Act, 2000 (Act No. 3 of 2000) and Petroleum Products and Energy Amendment Act,

2003 (Act No. 16 of 2003)); Petroleum Act Regulations were made in 1991 and 2000 under the

Petroleum Products and Energy Act, 1990 (“Petroleum Act Regulations”), to provide for the

application of environmental standards and the avoidance of environmental harm caused by the keeping, handling, conveying, using and disposing of petroleum products

Petroleum Laws Amendment Act, 1998 (Act No. 24 of 1998)

Petroleum (Taxation) Act, 1991 (Act No. 3 of 1991)

Petroleum (Exploration and Production) Act, 1991 (Act No. 2 of 1991) (as amended by the Petroleum

Laws Amendment Act, 1998 (Act No. 24 of 1998))

Transport and Maritime Marine Traffic Act, 1981 (Act No. 2 of 1981) (as amended by the Marine Traffic Amendment Act,

1983 (Act No. 5 of 1983), the Marine Traffic Amendment Act, 1991 (Act No. 15 of 1991), and the Namibian Ports Authority Act, 1994 (Act No. 2 of 1994))

Merchant Shipping Act, 1951 (Act No. 57 of 1951) (and the Second Schedule: International

Convention for the Safety of Life at Sea 1974; Third Schedule: Convention on the International

Regulations for Preventing Collisions at Sea 1972; Fourth Schedule: International Convention on Load Lines 1966; Fifth Schedule: International Convention of Standards of Training, Certification,

and Watch keeping for Seafarers 1978; and Sixth Schedule: International Convention on Tonnage

Measurement of Ships 1969) (and the Merchant Shipping Fees Regulations, 1998)

Namibian Ports Authority Act, 1994 (Act No. 2 of 1994) (as amended by the National Transport Services Holding Company Act, 1998 (Act No. 28 of 1998), the Namibian Ports Authority

Amendment Act, 2000 (Act No. 12 of 2000) and the State-owned Enterprises Governance Act,

2006 (Act No. 2 of 2006)) (and the Port Regulations, 2001)

Aviation Act, 1962 (Act No. 74 of 1962) (as last amended by the Aviation Amendment Act, 1991 (Act No. 10 of 1991) and the Aviation Amendment Act, 1998 (Act No. 27 of 1998)) (and the

Namibian Civil Aviation Regulations 2001)); Civil Aviation Act, 2016 (Act No. 6 of 2016) and the

associated regulations

Road Traffic and Transport Act, 1999 (Act No. 22 of 1999) (as amended by the Road Traffic and

Transport Amendment Act, 2008 (Act No. 6 of 2008)) (and the Road Traffic and Transport

Regulations, 2001)

Territorial Sea and Exclusive Economic Zone of Namibia, 1990 (Act No. 3 of 1990) (and Territorial Sea and Exclusive Economic Zone of Namibia Amendment, 1991 (Act No. 30 of 1991))

Pollution Atmospheric Pollution Prevention Ordinance, 1976 (Ordinance 11 of 1976)

Dumping at Sea Control Act, 1980 (Act No. 73 of 1980)

Prevention and Combating of Pollution of the Sea by Oil Act, 1981 (Act No. 6 of 1981) (as amended by the Prevention and Combating of Pollution of the Sea by Oil Amendment Act, 1985 (Act No. 59 of

1985), Prevention and Combating of Pollution of the Sea by Oil Amendment Act, 1987 (Act No. 63 of

1987), and Prevention and Combating of Pollution of the Sea by Oil Amendment Act, 1991 (Act No.

24 of 1991), and the Namibian Ports Authority Act, 1994 (Act No. 2 of 1994))

Petroleum (Exploration and Production) Act, 1991 (Act No. 2 of 1991) (as amended by the Petroleum

Laws Amendment Act, 1998 (Act No. 24 of 1998))

Marine Traffic Act, 1981 (Act No. 2 of 1981) (as amended by the Marine Traffic Amendment Act, 1983

(Act No. 5 of 1983), the Marine Traffic Amendment Act, 1991 (Act No. 15 of 1991), and the Nam ibian Ports Authority Act, 1994 (Act No. 2 of 1994))

Marine Notice No. 02 of 2017: Requirements and Conditions for the Transfer of Oil within Namibian

Waters

Marine Notice No. 04 of 2018: Garbage Management Requirements in Namibia under the

International Convention for the Prevention of Pollution from Ships (MARPOL) Annex V

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Sector Law

Disaster Risk Management Act, 2012 (Act No. 10 of 2012) (and the Disaster Risk Management

Regulations, 2013)

Local Authorities Act, 1992 (Act No. 23 of 1992): Town of Lüderitz: Regulations relating to waste management

Environmental Management Act, 2007 (Act No. 7 of 2007)

Marine Resources Act, 2000 (Act No. 27 of 2000)

Water Resources Management Act, 2013 (Act No. 11 of 2013) (promulgated, but not yet

implemented)

National Marine Pollution Contingency Plan (NMPCP), 2017

Environmental Marine Resources Act, 2000 (Act No. 27 of 2000)

Nature Conservation Ordinance, 1975 (Ordinance 4 of 1975) (and the Regulations Relating to

Nature Conservation, 1976 and the Amendment of Regulations, 2010)

National Heritage Act, 2004 (Act No. 27 of 2004) (as amended by the State-owned Enterprises

Governance Act, 2006 (Act No. 2 of 2006)) (and the National Heritage Regulations, 2005)

Water Act, 1965 (Act No. 54 of 1956) (as made applicable in Namibia)

Water Resources Management Act, 2013 (Act No. 11 of 2013) (promulgated, but not yet

implemented)

Namibian Islands’ Marine Protected Area, 2009

Hazardous Substances Hazardous Substance Ordinance, 1974 (Ordinance 14 of 1974) (and the General Regulations,

1979)

Disaster Risk Management Act, 2012 (Act No. 10 of 2012) (and the Disaster Risk Management

Regulations, 2013)

Atomic Energy and Radiation Protection Act, 2005 (Act No. 5 of 2005) (and the Radiation Protection and Waste Disposal Regulations, 2011)

Labour Labour Act, 2007 (Act No. 11 of 2007) (and the Labour Amendment Act, 2012 (Act No. 2 of 2012)) (and the Regulations relating to the Health and Safety of Employees at Work, 1997; and Labour

General Regulations, 2008)

Employees’ Compensation Act, 1941 (Act No. 30 of 1941) (and General Regulations, 1961) (Amendment Act, 1995 (Act No. 5 of 1995), that came into force on 1 March 1995, amends the Act

substantially and changes its name from the Workmen’s Compensation Act to the Employees’

Compensation Act)

Social Security Act, 1994 (Act No. 34 of 1994) (as amended by the State-owned Enterprises Governance Act. 2006 (Act No. 2 of 2006) and the Labour Act, 2007 (Act No. 11 of 2007)) (and the

General Regulations, 1995)

Public and Environmental Health Act, 2015 (Act No. 1 of 2015) (promulgated, but not yet

implemented)

Affirmative Action (Employment) Act, 1998 (Act No. 29 of 1998) (as amended by Act No. 6 of 2007

and the Labour Act, 2007 (Act No. 11 of 2007)) (and the General Regulations, 1999)

Health General Health Regulations (Government Notice 121 of 14 October 1969 as amended)

Tobacco Products Control Act, 2010 (Act No. 1 of 2010) (and the General Regulations, 2014)

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Sector Law

Public and Environmental Health Act, 2015 (Act No. 1 of 2015) (promulgated, but not yet

implemented)

Marine Heritage Wreck and Salvage Act, 2004 (Act No. 5 of 2004)

Foreign Trade Foreign Investment Act, 1990 (Act No. 27 of 1990)

Arms and Ammunition Arms and Ammunition Act, 1996 (Act No. 7 of 1996) (and the General Regulations, 1998)

A summary of other policies, plans and guidelines applicable to the proposed project is provided in Table 3-3.

Table 3-3: Applicable Policies and Plans

Policy / Plan Provisions

Draft White Paper on the Energy Policy of Namibia, 1998

The White Paper on the Energy Policy (1998) is the overarching policy document which guides future policy and planning in the energy sector.

Namibia Vision 2030 This outlines the country's development programmes and strategies to achieve its

national objectives. One of the major objectives of Vision 2030 is to “ensure the

development of Namibia’s ‘natural capital’ and its sustainable utilisation, for the benefit of the country’s social, economic and ecolog ical well-being”.

Namibia’s 5th National Development Plan (NDP5) – Working together

towards prosperity (2017/18 –

2021/22)

The NDP5 provides the context for all development in Namibia, with the overarching aim of economic and social development.

NDP5 was launched on the 31 May 2017 by Namibia’s Head of State, His Excellency Dr.

Hage G.Geingob. This is the fifth NDP in the series of seven (7) NDPs that are to implement

and achieve the objectives and aspirations of Namibia’s long term vision (Vision 2030). In

sequence, NDP5 will be the third five year implementation vehicle towards Vision 2030

(Namport, 2018).

Namibia’s Green Plan , 1992 The Green Plan emphasised the reciprocal relationship between environmental health and living standards and the link between the state of the economy and the state of the

environment. The Green Plan recorded consensus on the need for an Environmental

Assessment Policy to “ensure that independent environmental impact assessments

form part of the prefeasibility study of all development projects and subjecting all such

projects to long term regular environmental monitoring”. In a reference to reducing opportunity costs, the Green Plan states (optimistically) that government should “permit

only those developments that do not restrict the developmental options of future

generations of poor people”.

Towards a Coastal Policy for

Namibia, Green Paper, 2009

The policy will guide the use and management of Namibia’s coastal areas in the short-

medium- and long-term. The intention is to bring lasting benefits to the people without jeopardising the chances of future generations to meet their own needs. This can only

happen when human interaction with the environment is well managed, and resources

are not exhausted. The Green Paper explores in broad strokes how this may be possible,

based on the results of the process thus far, and provides the opportunity for further

debate so that the end policy will be exactly what the country needs.

Minerals Policy of Namibia, 2002 The Policy sets out guiding principles for the development of the mining sector designed to ensure that it maintains its leading role in the growth of the national economy while at

the same time operating within environmentally acceptable limits. To this end, one of the

objectives of the policy is listed as ensuring compliance with national and other relevant

environmental policies.

Policy for the Conservation of Biotic

Diversity and Habitat Protection, 1994

This Policy was drafted by MET to ensure adequate protection of all spec ies and

subspecies, of ecosystems and of natural life support processes.

Namibia: National Code on HIV/AIDS in Employment, 2000

A Charter of Rights on HIV/AIDS was launched in 2000 to provide guidelines on confidentiality and privacy for people living with HIV/AIDS. In 2003, Namibia launched the

national antiretroviral therapy programme to provide treatment for people living with

HIV/AIDS in government health facilities. Since the programme was launched, the Ministry of Health and Social Services (MoHSS) has trained medical practitioners from both the

public and private sectors. The Ministry has also developed extensive prevention

programmes, especially for women and young people, including preventing mother-to-

child transmission, and workplace programmes.

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Policy / Plan Provisions

National Policy on HIV/AIDS, 2007 The National Policy on HIV/AIDS is geared towards guiding efforts related to Namibia’s expanded national response to the epidemic. It encompasses policy statements related

to the creation of an enabling environment; prevention; treatment, care and support;

impact mitigation and workplace interventions and stewardship and management of the nation’s response. The goal of the policy is to to “provide a supportive policy environment

for the implementation of programmes to address HIV/AIDS that reduces new infections,

improve care, treatment and support and mitigate the impact of HIV/AIDS-this in turn will

assist with achieving vision 2013.

National Gender Policy, 2010 – 2020 Namibia developed and adopted its first National Gender Policy (NGP) in 1997. This aimed

at closing the gaps created by the socio-economic, political and cultural inequalities that existed previously in Namibian society. To ensure the implementation of the policy, a

National Gender Plan of Action was developed in 1998.

In 2010, a review of the 1997 policy was conducted, which showed that some progress had been achieved in the advancement of gender equality and women’s empowerment

in Namibia, particularly in economic, political, legal and educational spheres. However,

despite this progress, many challenges still remained to be addressed to achieve true

equality and thus a new policy was developed to address the gaps.

The Namibia National Gender Policy (2010-2020) seeks to create an enabling

environment for sectors to mainstream gender in line with NDPs. It identifies who will be

responsible for the implementation of the policy and who will be accountable for gender equality results.

Compared to the first policy, the new policy has 12 critical areas of concern, with two new

areas of peace-building and conflict resolution, and natural disaster management; and gender equality in the family context. Other areas have been made more comprehensive

to address emerging issues.

National Policy on Coastal Management for Namibia, 2012

The National Policy on Coastal Management for Namibia represents the consensus of a two-year consultative process that included local communities, the public at large, non -

governmental organisations, sectoral and other special interest groups, the private sector, and government officials. The overriding point that surfaced was that Namibians

from all walks of life care deeply for their coast, and this policy is driven by their calls for

better management of Namibia’s coastal areas.

National Health Policy Framework

2010-2020 - “towards quality health

and social welfare services”

The National Health Policy Framework for the period 2010 – 2020 as set out in this

document is a continuation of efforts that started at the time of independence. The

Framework, therefore, provides the overall orientation for health and health actions in Namibia. Furthermore, health problems in Namibia are in transition – infectious diseases

are major contributors to the burden of disease as well as health problems relate d to

pregnancy and delivery and infant and childhood – the health system in Namibia has to

be able to respond to such changes and hence the emphasis on public health priority.

The Primary Health Care approach has shown its value as the key principle in health

system. The values of service delivery, universal coverage, leadership and public policy

are therefore embedded in this policy framework.

SEA for the coastal areas of the Hardap and //Karas Regions, 2012

In July 2008, the Namibian Coast Conservation and Management Project (NACOMA) commissioned DHI Water & Environment to develop a user friendly, decision guiding and

policy relevant SEA of the coastal zones of the //Karas and Hardap regions of southern

Namibia.

3.6 International Laws and Conventions

Relevant international conventions and treaties which have been ratified by the Namibian Government and which

have become law through promulgation of national legislation are listed in Table 3-4. Article 144 of the Constitution

of the Republic of Namibia also provides that international agreements binding upon Namibia under the Constitution

shall form part of the law of Namibia.

Table 3-4: International Treaties, Conventions and Protocols

Treaties, Conventions and Protocols

Promulgated in terms of the Merchant Shipping Act 57 of 1951:

International Convention on Standards of Training, Certification and Watch keeping for Seafarers, 1978

The International Convention on Load Lines, 1966 and its protocol of 1988

International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Casualties, 1969 (Intervention Convention)

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Treaties, Conventions and Protocols

Convention on Wetlands of International Importance, Especially as Waterfowl Habitat (The Ramsar Convention on Wetlands), 1971

Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972 (London Convention) and 1996 Protocol

Convention on the International Regulations for Preventing Collisions at Sea (COLREGS), 1972 (as amended)

Declaration of the United Nations Conference on the Human Environment, 1972

International Convention for the Prevention of Pollution from Ships (MARPOL), 1973 (as modified by the Protocol of 1978 adopted by the Inter-Governmental Maritime Consultative Organization ("IMCO") in London on 3 November 1973, and the

Protocol of 1997 (MARPOL))

Protocol Relating to Intervention on the High Seas in cases of Pollution by Substances Other Than Oil, 1973

International Convention for the Safety of Life at Sea (SOLAS), 1974 (as amended) with its Protocol of 1978

United Nations Convention on the Law of the Sea (UNCLOS), 1982 (Articles 198 and 221)

Vienna Convention for the Protection of the Ozone Layer, 1985

Montreal Protocol on Substances that Deplete the Ozone Layer, 1987 (as amended)

Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer, Adopted at the Fourth Meeting of the

Parties at Copenhagen on 25 November 1992; Amendment to the Montreal Protocol on Substances that Deplete the Ozone

Layer, Adopted by the Ninth Meeting of the Parties at Montreal on 17 September 1997; and Amendment to the Montreal

Protocol on Substances that Deplete the Ozone Layer, Beijing, 3 December 1999

Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, 1989

International Convention on Oil Pollution Preparedness, Response and Co-operation, 1990 (OPRC Convention)

Convention on Biological Diversity, 1992

United Nations Framework Convention on Climate Change, 1992 and the Paris Agreement (United Nations Framework Convention on Climate Change), 2016

International Convention on Civil Liability for Oil Pollution Damage, 1992

International Convention on the Establishment of an International Fund for Compensation for Oil Pollution Damage, 1992 and

the Protocol, 2003

Protocol on Preparedness, Response and Co-operation to Pollution Incidents by Hazardous and Noxious Substances, 2000 (OPRC-HNS Protocol)

International Convention on Civil Liability for Bunker Oil Pollution Damage, 2000

United Nations Educational, Scientific and Cultural Organization (UNESCO) Convention on the Protection of the Underwater Cultural Heritage, 2001

Convention for the Safeguarding of the Intangible Cultural Heritage, 2003

International Convention on the Establishment of an International Fund for Compensation for Oil Pollution Damage, 1992 and

the Protocol, 2003

International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 (also known as the Ballast Water Management (BWM) Convention)

Convention on the Protection and Promotion of the Diversity of Cultural Expressions, 2005

Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), 2007

International Finance Corporation Performance Standards, 2012

Regional Policy Guidelines Economic Instruments For the Environmentally Sound Management of Waste Oil, 2013

3.7 Development Policies and Institutions

Namibian policy is broadly aimed towards improving socio-economic welfare through the sustainable use of the

country’s natural resources. Although Namibian policy is increasingly focussed on beneficiation and the creation of

downstream opportunities, it is recognised that upstream industries involving resource extraction play a key role in

the overall goal of realising the full potential which the country’s resources can offer. The alignment of the proposed

Project in terms of National Development Objectives can be considered in terms of the:

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White Paper on the Energy Policy, 1998;

Vision 2030;

The Fifth National Development Plan; and

Namibia’s Industrial Policy.

3.8 Project Policies and Standards

3.8.1 TOTAL Group Code of Conduct

TOTAL is committed to instil the values of respect, responsibility and exemplarity. The following three priority

business principles are equally critical to TOTAL’s success as a responsible company:

Commitment to health, safety and environment.

Compliance with the highest integrity standards’

Respect for human rights.

3.8.2 TOTAL Group Ethics Charter

TOTAL is committed to growing its business based on shared values and common principles that clearly assert its

ethical standards and accountability for all its businesses. In particular, TOTAL is accountable to:

Its shareholders, with the objective of striving to ensure a good return on their investment and providing them

complete and transparent information on a regular basis.

Its customers, with the commitment to supplying quality products and services in strict compliance with

accepted safety and environmental standards.

Its employees, with attention to their professional development and the promotion of health and safety in the

workplace.

Its suppliers and partners, in accordance with clear contract terms and conditions. The Group expects them

to comply with the principles and behaviours described in its Code of Conduct.

The civil society. TOTAL contributes to the social and economic development of the countries in which it

operates, in compliance with local legislation and regulation. It is committed to protecting the environment and

respecting local cultures.

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4. Overview of the Project

TOTAL, as operator and major (70%) shareholder, propose to undertake offshore exploration drilling activities in

Block 2913B. The stages of a potential petroleum development project are indicated in Figure 4-1.

Figure 4-1: Stages of a Petroleum Development Project

4.1 Project Location

Exploration drilling will take place within offshore Block 2913B which is approximately 300 km off the coast of

Namibia from Lüderitz. (Figure 4-2), adjacent to the southernmost Namibian offshore border with South Africa.

Figure 4-3 provides an indication of the locality of Block 2913B in relatio n to other offshore exploration licence

areas. Water depths in this area range from approximately 2 ,600 to 3,300 mbmsl. The surface area of Block 2913B

is approximately 8,215km2 and several wells may be drilled for exploration or appraisal purposes within this block.

The expected well location(s) will be influenced by the location of oil-bearing layer(s), and the desire to avoid shallow

gas, which may pose a safety hazard during drilling.

4.1.1 Area of Influence

The Area of Influence (AoI) for the Project can currently be defined as:

The exploration licence area (Block 2913B) in which drilling will take place;

The route of the drilling vessel and supporting vessels from the onshore base ( Lüderitz) to Block 2913B; and

The flight path within which crew members will be transported, via helicopter, to Block 2913B.

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Figure 4-2: Location of Exploration Block 2913B

Figure 4-3: Block 2913B in relation to other Exploration Licence Areas

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4.2 Project Schedule

The duration of drilling operations is expected to be approximately three (3) to six (6) months per well, anticipated to

commence in the second half 2019 and first half of 2020..

4.3 Main Project Components

The main project components are described in this section:

4.3.1 Onshore logistics base

The onshore logistics base would be located in the Port of Lüderitz, due to its proximity to the licence area. The

shore base would provide for the storage of materials and equipment (including drill pipes, drilling mud, chemicals

and diesel) that would be shipped to the drilling unit and back to storage for onward international freight forwarding.

The shore base would also be used for offices (with communications and emergency procedures / facil ities), waste

management services, bunkering vessels, and stevedoring / customs clearance services.

The service infrastructure required to provide the necessary onshore support is currently in place in Lüderitz and

thus no additional permanent onshore infrastructure is expected for this Project.

Crew will be transported via helicopter to the drilling unit.

4.3.2 Exploration Activities

The exploration activities required include:

Mobilising of drilling unit (commonly referred to as "drilling rig", the precise typology of which is not yet defined

at this stage of the Project) and equipment:

─ Mobilisation of the drilling rig and up to three (3) or more support vessels (Figure 4-4);

─ The rig hosts skilled personnel necessary for operations, and will be equipped with a helideck for the

transport of equipment and staff;

─ Storage of equipment and products in a logistics base whose location will be decided during the coming

months;

Drilling and testing the well:

─ Placing equipment, preparation of drilling mud;

─ Use of a drill bit attached to a drill string to drill the marine subsoil in successive sections, of smaller and

smaller diameter;

─ Casing consolidation of the drilled section, then cementation to ensure cohesion between the ground

and the tube;

─ Continuous circulation of drilling mud to balance the well pressure and raise the drill cuttings to the rig;

─ Installation of a well blowout preventer, to prevent any accidental release of hydrocarbons and to shut

the well in case of blow out;

─ Evaluation of the characteristics of the well: logging, possibly vertical seismic profile in the well, well test,

and short-term burning of hydrocarbons and fuels produced in small quantities;

Capping and suspending/abandoning the well:

─ In the event of hydrocarbon discovery: temporary securing of the well (suspension): insulation by a

cement barrier at the roof of the reservoir and at the wellhead;

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─ In the absence of hydrocarbons: cement plugs isolating the different horizons crossed by the well and

the seabed for a definitive securing of the well (abandonment);

─ Withdrawal of all equipment (the wellhead(s) will remain and will be securely sealed);

─ Treatment of waste;

─ Departure of the rig from the licence area; and

Analysing the results.

Figure 4-4: Example of Drilling Rig and Support Vessel

4.3.3 Drilling Process

4.3.3.1 Overview of drilling process

The first step in the drilling process is to ‘spud’ the well using a large diameter conductor. This large diameter

conductor is, either set in place by jetting, or by drilling the sea floor formation. Drilling then continues from the

bottom of the conductor going deeper through the sea floor. Drilling typically proceeds by applying weight on a ‘drill

string’ made up of a drill pipe and a bottom hole assembly (that includes the drill bit, drill collars, heavy weight drill

pipe, jarring devices and down-hole measuring equipment). Normally, the rig’s top drive rotates the drill string to turn

the drill bit at its lower end. The drill bit has a larger diameter than the drill string, so that an annular space is formed

around the drill pipe as drilling progresses. The drill bit cuts into the rock formation and detaches cuttings. Drilling

fluid is pumped down inside the drill string, through nozzles in the drill bit, which then flushes the cuttings up through

the annular space between the drill string and the borehole wall until they are removed from the well.

Wells are drilled in sections, the top hole sections are typically drilled without a riser (riserless) and the drilling fluids

and cuttings are ejected from the well at the seabed. For subsequent hole sections, a ma rine riser / BOP assembly

is installed connecting the well back to the rig (Figure 4-5). The advantages of this are that:

The drilling fluids can be circulated back to the rig, cleaned and re-used;

A closed circuit of drilling fluid and cuttings makes it easier for well engineers to assess the composition of the

formation drilled;

Additional additives can be added to the drilling fluid to increase its weight and counteract the risk of a well

kick or blowout; and

If needed, in a case of loss of well control or blowout situation, the BOP can shear the drill pipe and seal in the

well by a succession of hydraulic rams.

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Figure 4-5: Schematic of drilling process

4.3.3.2 Drilling fluids

The functions of drilling fluid are to:

Control formation pressure and prevent well control issues;

Transfer cuttings from the wellbore to the surface;

Preserve wellbore stability;

Minimise formation damage and seal permeable formations;

Cool and lubricate the drill string;

Provide information about the wellbore; and

Minimise risk to personnel, the environment, and the drilling equipment (well barrier).

4.3.3.2.1 Riserless drilling

The initial sections may be drilled using a seawater system. Seawater will be pumped down the drill string forcing

the cuttings back up the borehole into the water column and onto the seabed. While drilling, the borehole will be

cleaned out using guar gum sweeps. Prior to cementing, the hole will be displaced to a pre-hydrated bentonite pad

mud to keep the hole open. The cuttings and drill fluids (pad mud and sweeps) produced during this section will be

discharged at the seabed. Table 4-1 indicates expected cuttings volumes from drilling. The two first phases are

planned to be drilled riser less using Water based mud (WBM). The WBM will be discharged during drilling operations

in allowable quantities.

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Table 4-1: Cuttings and mud volumes per phase

No. section Wellbore diameter

('')

Section length (m) Released cuttings (tons) Quantity of mud discharged

(tons)

1 36 70 220.54 475.00

2 26 550 903.83 2565.0

3 17.5 750 535.1 32.11

4 12.25 1175 410.8 24.65

5 8.5 565 95.1 5.71

4.3.3.2.2 Drilling with Riser

The surface casing will have been installed and the BOP and marine riser deployed for the drilling of the lower

sections. Once the marine riser / BOP assembly is in place, drilling fluids will be separated from the cuttings on the

rig (using the onboard solids control equipment) thus maximising re-use of the drilling fluid (Figure 4-6).

Figure 4-6: Drilling fluid circulation process and solids control onboard rig

4.3.3.3 Drilling chemicals

Drilling fluids (please refer to Table 4-2) range from simple water based, to more complex oil-based systems. Drilling

fluid additives include weighting materials; viscosifiers; filtration control additives; pH/alkalinity control chemicals ;

dispersants / deflocculants / thinners; surfactants and emulsifiers; shale inhibitors; corrosion inhibitors/hydrogen

sulphide (H2S) scavengers; lubricants; biocide and lost circulation materials (LCMs) (Table 4-3).

All drilling chemicals will be selected in accordance with TOTAL’s General Specification document ‘Environmenta l

Requirements for Projects Design and Exploration and Productio n Activities’ (GS EP ENV 001) which requires that

chemicals are selected according to the following criteria: lowest toxicity, lowest bioaccumulation potential and

highest biodegradation and must be in compliance with the REACH Regulation (1907/2006). GS EP ENV 001 also

states that offshore, chemicals will be selected according to a pre-screening scheme based on the Convention for

the Protection of the Marine Environment of the North-East Atlantic (OSPAR) methodology in force and provided

with their material safety data sheet (MSDSs).

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Table 4-2: Drilling fluids generic composition

Estimated Consumptions MT / Section Total Quantity

Products

(example)

Function Conc

HiVis /GG (kg/m3)

Conc PAD

(kg/m3)

36'' 26'' PAD MT

Barite Weight Agent2 100 80.00 80.0

Caustic Soda Alkalinity1 5 5 1.25 2.75 4.00 8.0

Soda Ash Alkalinity2 5 5 1.25 2.75 4.00 8.0

Aldacide G Bactericide 1.5 0.00 1.20 1.2

Potassium

Chloride Kcl

Shale inhibitor1 60 0.00 48.00 48.0

Ez-Mud Shale inhibitor1 (Polymer)

10 0.00 8.00 8.0

Bentonite Viscosifier1 80 20.00 44.00 - 64.0

Barazan Viscosifier2 (Polymer) 3 10 0.75 1.65 8.00 10.4

Dextrid Fluid Loss1 (Starch) 30 0.00 24.00 24.0

Pac R-Polymer Fluid Loss2 10 10 2.50 5.50 8.00 16.0

Condet E Surfactant 3 0.28 - 0.28

Table 4-3: Drilling fluids generic composition (Non-Aqueous Based Mud)

Estimated Consumptions MT / Section

Products (example) Function Concentration (kg/m

3)

17 1/2'' 12 1/4'' 8 1/2''

EDC-99 DW Base oil 500 16.78 12.88 2.98

FACTANT Primary emulsifier (fatty Acid) 70 2.35 1.80 0.42

EZ MUL NT Secondary emulsifier (fatty Acid)

40 1.34 1.03 0.24

DURATONE-E Filtration control-I (l ignite) 25 0.84 0.64 0.15

LIQUITONE Filtration control-II (Polymer) 45 1.51 1.16 0.27

Lime Alkalinity control 30 1.01 0.77 0.18

SUSPPENSION Pack Viscosifier 1 (Organophilic clay)

30 1.01 0.77 0.18

BARAVIS IE 568 Viscosifier 2 (Fatty acid) 15 0.50 0.39 0.09

Calcium Chloride Calcium Chloride 70 2.35 1.80 0.42

Barite (Weighting Agent) 850 28.53 21.90 5.07

4.3.3.4 Cementing

Cementing involves mixing a slurry of cement, cement additives and water and pumping it do wn into the casing and

up the annulus (void) formed between the casing and the well bore. The cement sheath anchors and supports the

casing string and protects the steel casing from corrosion by formation fluids. It also provides a hydraulic seal that

prevents fluid communication between producing zones in the borehole and blocks escape of fluids to the surface.

Typically a small margin of excess cement is prepared for each cementing activity in order to account for possible

losses on account of the activity. The excess cement is subsequently discharged in allowable quantities.

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4.3.3.5 Vertical seismic profile

It is anticipated that VSP activities will be carried out in order to verify surface obtained seismic data. VSP refers to

measurements made in a vertical wellbore using geophones inside the wellbore and a source (generally an airgun

array) at the surface near the well. This methodology generally obtains images of higher resolution than surface

towed seismic.

4.3.3.6 Abandonment

Well abandonment consists of plugging and isolating all the zones of interest (formations containing fluids) from the surface.

The well will be plugged and abandoned in accordance with Petroleum (Exploration and Production) Act, 1991 (Act No. 2

of 1991) (as amended by the Petroleum Law s Amendment Act, 1998 (Act No. 24 of 1998)) and TOTAL’s corporate

requirements.

The cement plugs will be designed to withstand the conditions generated by the geological formations.

4.3.4 Crew Transfer

Helicopters will be available for crew transfers to the drilling unit. The helicopters would allow up to 18 people to be

transferred at any one time. The helicopters can also be used for medical evacuations from the drilling unit if or when

required.

Two daily return helicopter operations are expected to occur during daylight hours daily, except in emergencies .

During bad weather conditions, i.e. fog or extreme rain / wind the helicopters will be unable to fly. This may result in

a possible positive impact in Lüderitz or Oranjemund as crew would have to stay in town for the day(s).

In order to make provision for refuelling on-board the drilling unit, helicopter fuel would be transported from the

supply base to the drilling unit via the platform supply vessels in specialised transportable fuel tanks.

4.4 Waste management

Activities related to exploration drilling (supply of rig, use of generators and other heat engines, possibly limited

burning of hydrocarbons and fuels in the well test phase, drilling itself, etc.) will generate liquid and solid waste.

Liquid discharges consist mainly of wastewater and bilge water treated before being discharged into the sea .

The main solid wastes include putrescible waste (mainly food), to be crushed before being discharged at sea, and

specific waste such as cuttings, discharged into the sea after treatment on board. To a lesser extent, waste common

to the operation of any offshore installation (such as used lubricants, paint remains, other limited quantity chemicals ,

etc.) will also be produced. These wastes will be transported to shore to be tr eated or disposed through existing

channels.

4.5 Description of Alternatives

This section provides an overview of the alternatives that have been considered as part of project planning for the

Project. The current description of the Project as provided above is the result of a process of examining various

alternatives, with the goal of developing a Project that is both technically and financially feasible, and which

minimises environmental and social impacts.

The design process started with consideration of high-level strategic options and progressively focused in on

more detailed alternatives. The following sections set out the key considerations during this process of refining

options

4.5.1 The ‘No Project’ Alternative

The ‘no project’ alternative refers to the option of withholding (indefinitely) any plans for development of Block

2913B and leaving it in its current state. This would mean that exploration within the licence area will not be

considered, thus avoiding the Project’s potential environmental and social impacts.

However, should the Project not proceed, the key objectives relating to establishing production of the oil fields in an

economically prudent manner using sound reservoir management principles would not be met, and it would

eliminate any benefits that would otherwise have resulted from the establishment of the Project. Most noticeably,

the Project will improve the availability of fuel products on a national level. It will also bring economic benefits such

as employment, secondary business opportunities that will be required over time, as well as infrastructure

improvements within certain coastal towns of Namibia.

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4.5.2 Drilling Unit Options

The conditions within Block 2913B, in particular the water depth, mean that certain types of drilling equipment (a

jack-up rig for example) are unsuitable. It is anticipated that the drilling in Block 2913B will be carried out with a semi-

submersible rig, or with a drill ship, depending on further studies and availability of each type of drilling unit on the

market.

4.5.3 Onshore Base Location

Lüderitz has been identified as a potential location for the logistics base to be established in support of the drilling.

Lüderitz hosts facilities and supporting contractors that could make it a suitable logistics base.

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5. Stakeholder Consultation Process

The SCP is an integral part of the ESIA process. The objectives of SCP in an environmental process are to provide

sufficient and accessible information to stakeholders in an objective manner to assist them to:

Raise issues of concern and suggestions to mitigate impact and enhance benefits;

Verify that their issues have been recorded and considered in the environmental investigations;

Assist in commenting on feasible alternatives;

Contribute relevant local information and knowledge to the socio- environmental assessment; and

Comment on the findings of the socio-environmental assessment.

The approach towards any SCP is dependent on the details of the project. Each project has a particular geographic

and technical nature, and hence the SCP should be structured accordingly. Where possible, and within the required

statutory frameworks, it is also desirable to structure such a process to address the process needs of I&APs.

5.1 Stakeholder Identification and Analysis

A stakeholder is defined as any individual or group that is potentially affected by the project, or who has an interest

in the project and its impacts. In order to develop an effective approach to engagement, it is necessary to determine

who the stakeholders are and to assess their needs and expectations for engagement based on their interest and

influence in relation to the project.

Stakeholder analysis considers how a stakeholder or stakeholder group may be affected by the project and what

influence they may have on project outcomes in order to understand their needs and expectations for engagement .

Stakeholder identification and analysis was thus conducted with the main aims of facilitating:

Identification of the stakeholders;

Consultation with the stakeholders;

Evaluation of:

─ Their perception of the Project and of its impacts; the gap between this perception and the reality;

─ Their expectations of the Project, for example job creation, use of the local goods and services by TOTAL

and its contractors, socio-economic development projects; the legitimacy and urgency of these

expectations were analysed;

─ Their potential level of influence (direct and indirect, positive and negative) on other stakeholders;

─ Positive, neutral or negative attitude towards the Project;

─ Potential disturbances and sources of pressure or constraints with some stakeholders;

Classification and ranking of stakeholders:

─ Those that are likely to be affected by the future Project; and

─ Those with a substantial influence on the Project.

A copy of the stakeholder database is contained in Appendix C. Currently, stakeholders can be grouped as:

Government:

─ National governmental departments (e.g. the MME, MET and Ministry of Fisheries and Marine Resources

(MFMR));

─ Local government (e.g. town councils);

─ Parastatals (e.g. the Namibian Ports Authority (NamPort));

Business:

─ Adjacent exploration licence area holders;

─ Non-Governmental Organisations (NGOs);

Civil Society:

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─ General public and other interested parties;

─ Potentially directly affected stakeholders (e.g. fishing associations); and

─ Potential indirectly affected stakeholders.

5.1.1 Public Open Days

Public Open Days were conducted as indicated in Table 5-1 below. The attendance registers, and comments from

the Public Open Days, as well as the information presented at these meetings will be contained in Appendix D.

Please refer to Appendix D.7.

Table 5-1: Public Open Days Conducted

Venue Town Date Time

Benguela Community Hall Lüderitz 09 April 2018 15h00 – 18h00

Namdeb Recreational Centre Oranjemund 11 April 2018 15h00 – 18h00

5.1.2 Draft ESIA Report Review Period

The purpose of the draft ESIA was to enable I&APs to verify that their contributions have been captured, understood

and correctly interpreted, and to raise any additional queries, comments or questions they may have of the

proposed Project. A period of 21 days was allowed for public review of the draft ESIA from 0 1 April 2019 to 21 April

2 0 1 9 at the venues indicated in Table 5-2. Electronic copies of the draft ESIA will be made available on request.

Table 5-2: Venues for Draft Scoping Report

Venue Address Contact Details

Lüderitz Community Library Ring Street, Lüderitz +264 63 202 444

Oranjemund Community Library 9th Avenue, Oranjemund +264 63 239 399

5.1.3 Final ESIA Report

Once the public review period for the draft ESIA concluded, the report was updated to a final ESIA together with the

CRR. The final ESIA will be submitted to the MME (this report).

5.2 Decision-making Phase

Should an ECC be issued, all registered I&APs will be notified of the decision and have the opportunity to appeal the

decision should they not agree with the authorisation issued or any conditions of authorisation.

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6. Baseline Environment

NOTE: THE SUB-SECTIONS SET OUT IN THE SECTION BELOW SHOULD BE READ IN CONJUNCTION WITH THE DESKTOP STUDY ENCLOSED

HER EWITH A S AP P ENDIX B.2 .

The understanding of the environmental and social context and sensitivity within the project area is important to

understand the potential impacts of the proposed project activities. In this ESIA, the receiving environment is

defined as the physical and geophysical environment, the biophysical environment (which includes marine and

coastal plants and animals), and the social environment (including livelihoods and commercial activities). This

section provides a description of the attributes of the physical, biophysical and social receiving environment of the

Project area and the southern Namibian offshore regional area.

Very limited information is available of the Project area, so comparisons have been made with the neighbouring

exploration areas Block 2913A and 2914B and the Orange Basin TCP, which lies offshore on the west coast of South

Africa and covers approx. 15,474km² in water depths between 2,700m and 4,250m (Figure 6-1).

Figure 6-1: The location of Block 2913B in relation to neighbouring blocks 2913A and 2914B

6.1 Physical Environment

6.1.1 Climate

During the summer season a clear east-to-west gradient is experienced on the Namibian coast and in winter, a

northwest-to-southeast gradient is experienced that is characterised by little to no rainfall. The coastal areas

experience mean monthly minimum temperatures ranging from 16 - 22 degrees Celsius (°C) and maximum

temperatures throughout the year of 10 – 17 °C (Figure 6-2 and Figure 6-5) (GRN, 2015).

Average daylight hours for Oranjemund and Lüderitz are indicated in Figure 6-4 and Figure 6-7 respectively.

Annual precipitation in 2018 ranged from 15.4 mm at Lüderitz to 53.1 mm at Oranjemund. The southern coastline

is characterised by frequent dense fog (which is further driven by the Benguela Current System), and overall lower

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temperatures than in the rest of the region. The extreme fog conditions experienced in winter could result in a delay

in planned flights as a result of decreased visibility (Figure 6-3 and Figure 6-6).

Figure 6-2: Oranjemund average annual temperature (Source: National Oceanic and Atmospheric

Administration (2018))

Figure 6-3: Oranjemund average annual precipitation (Source: National Oceanic and Atmospheric

Administration, 2018)

Figure 6-4: Oranjemund average daylight hours (Source: National Oceanic and Atmospheric

Administration, 2018)

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Figure 6-5: Lüderitz average annual temperature (Source: National Oceanic and Atmospheric

Administration, 2018)

Figure 6-6: Lüderitz average annual precipitation (Source: National Oceanic and Atmospheric

Administration, 2018)

Figure 6-7: Lüderitz average daylight hours (Source: National Oceanic and Atmospheric Administration ,

2018)

6.1.2 Air quality and Wind Patterns

The offshore ambient air quality of Namibia is not generally recorded but considered to be largely free of man-made

pollutants, as Namibia overall does not have major industries (Risk-Based Solutions, 2018). The nearshore Benguela

Current Large Marine Ecosystem (BCLME) is largely driven by wind. The wind generates the heavy and regular

south-westerly swells that impact on the coast on an oceanic scale, it equally locally contributes to the northward-

flowing longshore currents. The upwelling of deep, cool water along the Namibian coast is caused by the Benguela

Sea current. The prevalent winds in the BCLME region are driven by the South Atlantic subtropical areas of high

pressure (i.e. anticyclone), the eastward moving mid-latitude cyclones south of Southern Africa, and the seasonal

atmospheric pressure field over the subcontinent (Pisces Environmental Services (Pty) Ltd, 2018) ( Figure 6-8).

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Figure 6-8: The main features of the Benguela Current System (Source: Pisces Environ mental Services

(Pty) Ltd, 2018)

The south Atlantic anticyclone is a persistent feature within this system and it is also part of the intermittent belt of

high-pressure systems which encircle the subtropical southern hemisphere. This anticyclone experiences a range

of changes throughout the different seasons - the strongest in the arid and blazing summer season, when it also

attains its southernmost extension. Furthermore, it lies south west and south of Southern Africa as indicated by

Voluntary Observing Ship (VOS) data in Figure 6-9. During the winter season (season of low precipitation), the south

Atlantic anticyclone weakens and migrates north-westwards (Swart, 2017).

The most resilient upwelling cells are located where the inner-continental shelf is narrow (closer to the coast) and

winds are strong. This upwelling causes deep, nutrient-rich water to move to the sea surface where planktonic plants

make use the nutrients; these plants then serve as a food source for fish and other animals as driven by wind (Swart,

2017).

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Figure 6-9: Wind Speed vs Wind Direction data for the offshore area 28°29’ S; 15°16’E (Source: Pisces

Environmental Services (Pty) Ltd, 2018)

6.1.3 Bathymetry and Geology

The continental shelf off southern Namibia is variable in width. Off the Orange River, the shelf is approximately 230

km wide and characterised by well-defined shelf breaks, a shallow outer shelf, and the aerofoil-shaped submarine

‘Recent River Delta’ on the inner shelf. It narrows to the north reaching its narrowest point approximately 90 km off

Chameis Bay, before widening again to 130 km off Lüderitz (Rogers, 1977).

The prominent topographic features of the shelf include the relatively st eep descent to about 100 m, the gentle

decline to about 180 m and the undulating depths to about 200 m. The Orange Banks comprise three low mounds

rising to about 160 m on the outer shelf. North of Chameis Bay, the shelf becomes a stepped feature, with a low step

having an elevation between roughly 400 m – 450 m below mean sea level (bmsl), making it one of the deepest in

the world. The variable topography of the shelf is of significance for nearshore circulation and for fisheries (Shannon

and O’Toole, 1998). Banks on the continental shelf include the Orange Bank (Shelf or Cone), a shallow (160 m – 190

m) zone that reaches maximal widths (180 km) offshore of the Orange River, and Child’s Bank, situated approximately

150 km offshore at about 31°S. Tripp Seamount, approximately 100 km east of the area of interest, is a geological

feature situated approximately 300 km offshore at about 29°S, which rises from the seabed at approximately 1,000

m to a depth of 150 m (Figure 6-10).

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Figure 6-10: Expected Sediments within Block 2913B Offshore Namibia (Source: modified after Rogers,

1977)

The inner shelf is underlain by Precambrian bedrock (also referred to as Pre-Mesozoic basement), whilst the middle

and outer shelf areas are composed of Cretaceous and Tertiary sediments (Dingle, 1973; Birch et al., 1976; Rogers,

1977; Rogers & Bremner, 1991; Bagguley and Prosser, 1999; Stevenson and McMillan, 2004). Due to erosion on the

continental shelf, the unconsolidated sediment layer is generally thin, often less than 1 m. Sediments become finer

seawards, changing from sand on the inner and outer shelves to muddy sand and sandy mud in deeper water ; the

latter is expected to occur within Block 2913B. However, this general pattern has been modified considerably by

biological deposition (high levels of calcium carbonate (CaCO3) within the shelf sediments) and localised river input.

An approximately 500 km long mud belt (up to 40 km wide, and of 15 m average thickness) is situated over the outer

edge of the middle shelf between the Orange River and St. Helena Bay (Birch et al., 1976; Meadows et al., 1997;

2002; Herbert and Compton, 2007).

The bathymetry of the survey block has been assessed from the analysis of the first return extracted from previous

seismic datasets. These show several deep-water bathymetric features across the block which are expected to

relate to geological features, where variability in seabed erosion have created defined boundaries in the bat hymetr y

and potentially seabed erosion. This in turn may affect habitat types on both a localised and regional level.

Conspicuous features include shallow canyons (i.e. mass gravitational flow features), escarpments, eroded plateaus

and sedimentary basins.

6.1.4 Noise

N O TE: THIS SUB-SECTION BELOW SHOULD BE READ IN CONJUNCTION WITH THE IMPACT ASSESSMENT ENCLOSED HEREWITH AS APPENDIX

B.1 .

Noise pollution in the BCLME predominantly stems from mining exploration (seismic) and flights over predator

breeding sites usually transporting tourists, and mainly around the offshore islands. Seismic activities are believed

to affect the behaviour of some species of fish, particularly changing the migration pattern of tuna fish species or

resulting in the tuna fish species acclimatising itself deeper than its habitual level. Likewise, aircraft flying over

seabird and seal breeding colonies cause stampedes and nest desertion. Seismic related activities are not

permitted within Marine Protected Areas (MPAs) as the noise can have negative impacts to breeding areas (Davies

et al., 2014).

6.1.4.1 Sound Thresholds

Thresholds are usually proposed in terms of one or more different sound level metrics ( Sound Pressure Level (SPL)

and Sound Exposure Level (SEL)) and for different levels of potential impact ranging from mortality, physical injur y

and hearing impairment through to behavioural reactions which includes changes in feeding, breeding, respiration

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or patterns of movement such as fleeing or avoidance. Thresholds for hearing impairment consider potential

permanent and temporary effects on hearing where animals exposed to sufficiently intense or lengthy sound can

experience an increase in hearing threshold (i.e. poorer sensitivity) for some period of time following exposure.

This change in hearing is called a sound-induced threshold shift and the amount of shift is determined by the

distance between a sound and the individual at the time of hearing the sound in combination with the amplitude,

duration, frequency content, temporal pattern, and energy distribution of the sound exposure relative to the hearing

sensitivity of the species and the background sound levels. Hearing threshold shifts may be permanent (PTS) or

temporary (TTS) and thus hearing impairment impacts are generally considered at these two levels:

Permanent threshold shift (PTS) is a permanent, irreversible increase in the threshold of audibility at a specified

frequency or portion of an individual’s hearing range above a previously established reference level. This is

considered to be auditory injury. Due to the absence of data on permanent injury in marine taxa, PTS

thresholds have been extrapolated from observed TTS responses and therefore, there are high levels of

uncertainty in the currently available threshold criteria for PTS in marine receptors.

TTS is a temporary, reversible increase in the threshold of audibility at a specified frequency or portion of an

individual’s hearing range above a previously established reference level.

Behavioural thresholds are based on observations of individuals or groups of individuals when exposed to sound at

a given level (Southall et al., 2007; Popper et al., 2014; National Marine Fisheries, 2018). The sound levels involved

are lower or for a shorter duration than those that would give rise to PTS or TTS. The nature of the sound, in terms

of its frequency content as well as its duty cycle, whether continuous (e.g. non-impulsive sounds associated with

drilling) or intermittent (e.g. impulsive sounds associated with VSP airguns) governs how the receptor may respond.

The response of the animal is also often context-dependent (i.e. feeding, breeding, migrating, life cycle stage etc.)

and may relate to its motivation and previous experience to the perturbing sound. Where dual metric impact

thresholds are available, the threshold criterion which is exceeded first (i.e. the more precautionary of the two

measures) is used to determine potential impact distances (Southall et al., 2007; National Marine Fisheries, 2016).

6.2 Biophysical Environment

6.2.1 Marine Habitats

The offshore marine ecosystems comprise a limited range of habitats, namely unconsolidated seabed sediments

and the water column. The biological communities ‘typical’ of these habitats are described briefly below, focussing

both on dominant and conspicuous species, as well as potentially threatened or sensitive species, which may be

affected by the proposed exploration well drilling (SLR Environmental Consulting, 2017) .

Several studies have been carried out on the southern Afr ican West Coast continental shelf benthos however, the

benthic fauna of the outer shelf and continental slope (beyond 450m water depth) are very poorly known. However,

benthic communities are generally influenced by the complex interplay of environmental factors, with water depth

and sediment particle size being considered the two major factors determining and affecting benthic communit y

structure and distribution on the southern African West (MetOcean Services International (Pty) Ltd (2019) adapted

from Christie, 1974; 1976; Steffani, 2007a; 2007b). The periodic intrusion of low oxygen water masses in the deep -

water shelf areas of the southern Africa West Coast is likely to also contribute to benthic community variabilit y

(MetOcean Services International (Pty) Ltd (2019) adapted from Monteiro and van der Plas, 2006; Pulfrich et al.,

2006). Sampling and characterization of benthic fauna was including in the Environmental Baseline Study. The

benthic community observed during sampling and video observations was similar based on a firm cream to light

brown clay with only a fine soft surface layer of unconsolidated materials (ca 1-2 cm). Samples taken were not rich,

with conspicuous fauna limited to polychaetes, (including worm tubes) and sipunculids.

Much of the seabed has been broadly categorised by Rogers and Bremner (1991), however the species

communities and interaction of benthic animals are poorly understood. Polychaetes and small bivalves are likely to

dominate the seabed in shelf waters <200m whereas echinoderms (see urchins, star fish, etc.), burrowing and

swimming crabs and shrimps are more likely to be common in deeper waters (Rogers and Bremner, 1991). Epifaunal

and bottom dwelling species are also expected to occur within soft-bottom sediments in the survey area. Atkinson

(2009) reported numerous species of urchins and burrowing anemones beyond 300m depth off the South African

West Coast. The seabed was observed to be largely homogeneous during the Environmental Baseline Survey, with

an absence of conspicuous sedimentation. A characteristic sample is shown in (Figure 6-11).

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Figure 6-11: Photo of Seabed in Block 2913B

The bulk of the seawater in this area is made up by South At lantic Central Water (SACW) (Figure 6-12) and occurs

either in its pure form in the deeper regions or is mixed with previously upwelled water of the same origin on the

continental shelf (Nelson and Hutchings, 1983) with a salinity reported to range between 34.5% and 35.5%

(Shannon, 1985).

Figure 6-12: The Current System along West Coast of Namibia (Checkley et al., 2009)

Seawater temperatures on the continental shelf of the southern Benguela typically vary between 6°C and 16°C with

well-developed thermoclines. The continental shelf waters of the Benguela system are characterised by low oxygen

concentrations, especially on the bottom. SACW itself has depressed oxygen concentrations (~80% saturation

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value), but lower oxygen concentrations (<40% saturation) frequently occur (Bailey et al., 1985; Chapman and

Shannon, 1985).

6.2.1.1 Nutrients and Plankton production

Cold upwelled water is rich in inorganic nutrients containing various forms of nitrates, phosphates and silicates

(Chapman and Shannon, 1985). During upwelling processes, the comparatively nutrient -poor surface waters are

displaced by enriched deep water which supports substantial seasonal primary phytoplankton production. High

phytoplankton productivity in the upper layers again depletes the nutrients in these surface waters. This results in

a wind-related cycle of plankton production, mortality, sinking of plankton detritus and eventual nutrient re-

enrichment occurring below the thermocline as the phytoplankton decays (SLR Environmental Consulting, 2017).

Phytoplankton is mainly dominated by diatoms which are adapted to the turbulent sea conditions. Diatom blooms

occur after upwelling events whereas dinoflagellates are more common in blooms that happen during quiescent

periods (SLR Environmental Consulting, 2017).

Meso-zooplankton (< 2 mm body width) communities includes egg, larval, juvenile and adult stages of copepods,

cladocerans, euphausiids, decapods, chaetognaths, hydromedusae and salps, as well as protozoans and

meroplankton larvae (Maartens, 2003; Hansen et al., 2005) with copepods being the most dominant group making

up 70%-85% of the zooplankton (SLR Environmental Consulting, 2017).

Ecosystem models have estimated that 36% of the phyto- and 5% of the zooplankton are lost to the seabed

annually (Shannon et al., 2003), which has a substantial effect on the ecosystems of the Benguela region resulting

in high organic content of the muds in this region. Most of the organic detritus is not directly consumed and enters

the seabed decomposition cycle which can potentially lead to subsequent depletion of oxygen in deeper waters.

Within the survey area phytoplankton biomass is expected to be diminished due to high turbulence and deep mixing

in the water column, which leads to poor feeding conditions for micro -, meso-, macro-zooplankton and

ichthyoplankton (Lett et al., 2007), thus zoo- and ichthyoplankton abundance are expected to be low overall.

Severe oxygen depletion can lead to the formation of hydrogen sulphide (H2S) gas by anaerobic bacteria in anoxic

seabed muds (Brüchert et al., 2003). This can be released periodically from the muds as ‘sulphur eruptions’, causing

upwelling of anoxic water and formation of surface slicks of sulphur discoloured water (Emeis et al., 2004).

6.2.2 Fish

While overall species richness and levels of endemism are reasonably low, several species of marine fish and other

marine organisms are for the most part abundant along the Namibian coast as a direct result of the nutrient-rich

Benguela current and upwelling cells (Pisces Envieonmental Consulting (Pty) Ltd, 2014a). Fish and other marine

species which are important for the economy include hake, orange roughy and monkfish (demersal or deep-water

species), which are found at the sea bottom far out to sea and provide the highest economic returns; horse

mackerel, pilchard and anchovy (pelagics usually occur closer to the surface and shore); and species associated

with the coastline such as rock lobster, seals and birds. In addition, 31 species of cetaceans are known to occur in

Namibian waters, and the Heaviside dolphin (Cephalorhynchus heavisidii) is endemic to the Benguela current

ecosystem (Ministry of Fisheries and Marine Resources, 2009; Ministry of Environment and Tourism, 2010).

Sardine (Sardinops sagax) is a transboundary species occurring from southern Angola to South Africa eastwards

into the Agulhas system. There are two main stocks, southern and northern, separated by the Lüderitz upwelling

cell. The proposed Project area is located within the area of the southern stock, close to the Benguela Fronts as

illustrated in Figure 6-13. No spawning grounds have been recorded in the area and the occurrence of Madeir an or

flat sardinella (Sardinella maderensis) and the Round sardinella (S. aurita) is inexistent (Davie et al., 2014).

Due to its offshore location, plankton abundance is expected to be low, with the major fish spawning and migration

routes occurring further inshore on the shelf. The dominant fish in the area would include the migratory large pelagic

species such as albacore tuna (Thunnus alalunga), yellowfin tuna (T. albacares), bigeye tuna (T. obesus), swordfish

(Xiphias gladius) and shark species (Pisces Environmental Services (Pty) Ltd, 2018).

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Figure 6-13: Distribution of sardine (left) and distribution of both sardinella species (right) (Source:

Benguela Current Commission, 2012)

Fish species which are classified as endangered or vulnerable have that status as a result of various factors. These

factors may include poor regulation of the tourism sector, lack of pollution control, overfishing and unsustainable

fishing techniques. Table 6-1 indicates some of the fish species which have been categorised as Vulnerable (VU) or

Endangered (EN) within Namibian waters.

Table 6-1: Red Data Fish Species (Davies et al., 2014; Earth's Endangered Creatures, 2018)

Species Common name Namibian

status1

Year assessed Population

trend

Oxynotus centrina Angular Rough Shark VU 2007 Unknown

Thunnus obesus Bigeye Tuna VU 1996 Uncertain

Rhinobatos cemiculus Blackchin Guitarfish EN 2007 Decreasing

Rostroraja alba Bottlenose Skate EN 2006 Decreasing

Squalus acanthias Piked dogfish VU 2006 Decreasing

Rhinobatos rhinobatos Common Guitarfish / Violinfish EN 2007 Decreasing

Centrophorus squamosus Deepwater Spiny Dogfish VU 2003 Decreasing

Epinephelus marginatus Dusky Grouper EN 2004 Decreasing

Carcharias taurus Grey Nurse Shark / Spotted

Ragged-tooth Shark

VU 2005 Unknown

Carcharodon carcharias Great White Shark VU 2005 Unknown

Centrophorus granulosus Gulper Shark VU 2006 Decreasing

Galeorhinus galeus Soupfin VU 2006 Decreasing

1 EN – Endangered, VU – Vulnerable

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6.2.3 Seabirds

There are 49 bird species which can be found within the BCLME, approximately half of these species are migrants

from the south and just over a quarter is visitors from the north. The area between Cape Point and the Orange River

supports 38% of the overall population in winter and 33% in summer. The highest offshore shelf break depth

reached by most of the seabirds ranges between 200 – 500 m.

The nesting and breeding areas for these seabirds are distributed along the Namibian coast extending to the Orange

River Basin (Table 6-2) (Pisces Environmental Services (Pty) Ltd, 2014a). The breeding success of the seabirds is

directly linked to the quantity of food available, thus the majority of the nesting areas are located at or close to

upwelling cells where planktonic plants and organisms can provide nutrients and serve as a food source.

A good number of the breeding seabird species forage at sea with most birds being found r elatively close inshore

(10-30 km), however the African Penguins have been recorded to explore as far as 60 km offshore.

The most vulnerable seabirds in the BCLME are some of the migrant pelagic birds such as the Albatrosses

(Diomedeidae) and Southern Giant Petrels (Macronectes giganteus), and the Benguela endemic seabirds which

breed mainly on the offshore islands, such as the Cape gannet (Morus capensis), African penguin (Spheniscus

demersus), Cape cormorants (Phalacrocorax capensis) and Bank cormorants (Phalacrocorax neglectus) (Davies et

al., 2014).

During seismic survey studies conducted on Block 2913B in October 2018 and November 2018 by Benthic

Solutions (2019) a total of 26 species of bird were recorded on the 10 days at sea during the project. Five species

of albatross were recorded four of which are species of conservation concern; Wandering Albatross Diomedea

exulans, Tristan Albatross Diomedea dabbenena, Shy Albatross Thalassarche cauta Atlantic Yellow-nosed

Albatross Thalassarche chlororhynchos .

Nineteen of the species were recorded in the deep-sea areas around the survey site although the shallower waters

near the coast were more species rich than the site itself. Stormy weather on more than half of the days made

observing tricky with winds speeds >40 knots and wave height up to 7 m.

Table 6-2: Red Date Seabird Species (Source: Davies et al., 2014; Benthic Solutions, 2019)

Species Common name Namibian

status

Year

assessed2

Population

trend

Diomedea sanfordi Northern royal albatross EN 2010 Stable

Diomedea epomophora Southern royal albatross VU 2010 Stable

Diomedea exulans Wandering albatross VU 2010 Decreasing

Thalassarche chrysostoma Grey-headed albatross VU 2010 Decreasing

Thalassarche carteri Indian yellow-nosed albatross EN 2010 Decreasing

Thalassarche chlororhynchos Atlantic yellow-nosed albatross EN 2010 Decreasing

Thalassarche melanophrys Black-browed albatross NT 2010 Decreasing

Diomedea dabbenena Tristan Albatross CR N/A N/A

Thalassarche cauta Shy Albatross NT N/A N/A

Procellaria aequinoctialis White-chinned petrel VU 2010 Rapid

decrease

imminent

Morus capensis Cape gannet VU 2010 Decreasing

Phalacrocorax capensis Cape cormorant EN N/A N/A

Phalacrocorax neglectus Bank cormorant EN 2010 Decreasing

Spheniscus demersus African penguin EN 2010 Decreasing

2 EN – Endangered, VU – Vulnerable, CR – Critically Endangered, NT - Near Threatened

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6.2.4 Sea turtles

Sea turtles in Namibia are categorised under the critically endangered and endangered status, this is as a result of

the turtles being hunted extensively in the past for their skins and meat. Turtles that may be present in the area are

indicated in Table 6-3.

Table 6-3: Sea Turtles that may be present in the Study Area (Source: Benguela Current Commission,

2012)

Species Common name Namibian

status

Year assessed Population

trend

Dermochelys coriacea Leatherback turtle CR 2000 Decreasing

Caretta caretta Loggerhead EN 1996 Not recorded

Chelonia mydas Green turtle EN 2004 Decreasing

6.2.5 Marine Mammals

Marine mammals along the Namibian shoreline include seals, whales and dolphins (Bianchi, et al., 1999). Marine

mammals are divided into two orders, namely Cetacea and Pinnipedia. The Cetacea order consists of whales and

dolphins, while the Pinnipedia order represents seals (Figure 6-15) (Bianchi et al., 1999). According to (Currie et al.,

2008) these marine mammals contribute towards the retention and concentration of nutrients in the coastal regions

through supporting the ecosystem and 7% of these species are endemic to Namibia.

The biggest threat to these marine mammals is solid waste pollution, which consists mainly of plastic waste as well

as discarded or lost fishing gear (Davies et al., 2014). The closest marine mammal range to the proposed exploration

site is the Resident Killer whale (Orcinus orca), a sub-order of the Cetacea group.

During seismic survey studies conducted on Block 2913B in October 2018 and November 2018 by Benthic

Solutions (2019), visual sightings of marine mammal species are indicated in Table 6-4 and .

Table 6-4: Marine mammal sightings

Species Sightings

Common Name Scientific Name

Dusky Dolphin Lagenorhynchus obscurus 1

Fin Whale Balaenoptera physalus 4

Haviside dolphin Cephalorhynchus heavisidii 2

Cephalorhynchus heavisidii Globicephalus macrorhynchus 2

Unidentified Baleen whale sp. 4

Unidentified Whale sp. 1

South African and Australian Fur Seals Arctocephalus pusillus 28

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Figure 6-14: Sightings A: South African and Australian fur seal, B: Fin whale, C: Heviside Dolphin and D-E:

Figure 6-15: Distribution of marine species in the BCLME (Source: adapted from SLR Environmental

Consulting, 2017)

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6.2.6 Deep-water Coral Communities

Deep-water coral communities, some in the form of a reef whilst others remain solitary, may be present within the

Project area as these benthic filter-feeders generally occur at depths exceeding 150 m. These animals add

structural complexity to otherwise uniform seabed habitats thereby creating areas of high biological diversit y

(Breeze et al., 1997; MacIssac et al., 2001). They establish themselves below the thermocline where there is a

continuous and regular supply of concentrated particulate organic matter, caused by the flow of a relatively strong

current over special topographical formations which cause eddies to form. Nutrient seepage from the substratum

might also promote a location for settlement (Hovland et al., 2002). Substantial shelf areas in the productive

Benguela region should thus potentially be capable of supporting rich, cold water, benthic, filter-feeding

communities. Areas of potential interest within the block would typically be found around discreet bathymetric

features, such as along the edge of well-defined escarpments where strong currents and harder substrates are

likely to be encountered.

6.2.7 Seamount Communities

Seabed features such as the Orange Bank, Childs Bank, and Tripp Seamount have been reported for nearby licence

Blocks 2913A and 2914B. Features such as banks, knolls and seamounts (referred to collectively here as

‘seamounts’), which protrude into the water column, are subject to, and interact with, the water currents surrounding

them. The effects of such seabed features on the surrounding water masses can include the upwelling of relatively

cool, nutrient-rich water into nutrient-poor surface water thereby resulting in higher productivity (Clark et al., 1999),

which can in turn strongly influences the distribution of organisms on and around seamounts. Studies conducted

on other seamounts have identified that enhanced fluxes of detritus and plankton, developed in response to the

complex current regimes, lead to the development of detritivore-based food-webs, which in turn resulted to the

presence of seamount scavengers and predators. Many of these species are long-lived and slow-growing, moving

into deeper waters with age after spending time around the summits of seamounts in their early stages ( South

Pacif ic Regional Fisheries Management Authority (SPRFMA), 2007). Evidence of enrichment of bottom-associated

communities and high abundances of demersal fishes have been regularly reported over such seabed features.

Enhanced currents, steep slopes and volcanic rocky substrata, in combination with locally generated de tritus,

favour the development of suspension feeders in the benthic communities characterising seamounts (Rogers,

1994). Deep- and cold-water corals (including stony corals, black corals and soft corals) are a prominent

component of the suspension-feeding fauna of many seamounts, accompanied by barnacles, bryozoans,

polychaetes, molluscs, sponges, sea squirts, basket stars, brittle stars and crinoids (reviewed in Rogers, 2004).

There is also associated mobile benthic fauna that includes echinoderms (sea urchins and sea cucumbers) and

crustaceans (crabs and lobsters) (reviewed by Rogers, 1994). Some of the smaller cnidarian species remain solitary

while others form reefs thereby adding structural complexity to otherwise uniform seabed habitats. The coral

frameworks offer refuge for a great variety of invertebrates and fish (including commercially important species)

within, or in association with, the living and dead coral framework thereby creating spatially fragmented areas of high

biological diversity. Compared to the surrounding deep-sea environment, seamounts typically form biological

hotspots with a distinct, abundant and diverse fauna, many species of which remain unidentified.

Consequently, the demersal/benthic fauna of seamounts is often highly unique and may have a limited distribution

restricted to a single geographic region, a seamount chain or even a single seamount location (Rogers et al., 2008),

whereas large pelagic species in contrast are migratory and can travel vast distances across the oceans.

Sensitive communities including gorgonians, octocorals and reef-building sponges have been reported to occur

on the continental shelf and are expected to be found around Tripp Seamount, but are not likely to be found within

Block 2913B.

6.2.8 Conservation Areas

Numerous Priority Focus Areas (PFAs) (Figure 6-16, conservation areas and marine protected area (MPA) () exist

along the coastline of southern Namibia (Namibian Islands Marine Protected Area), although none fall within the area

of interest.

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Figure 6-16: Conservation areas along the Namibian Coast (Source: Holness et al., 2014)

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Figure 6-17: Proposed Marine Protected Area along the coast (Currie, Grobler, & Kemper, 2008)

6.3 Social Environment

6.3.1 Offshore Economic Activities

The economies of several towns along the coast of the !Karas region depend on marine based economic activities.

These dependencies are listed and briefly described below. Block 2913B is located well offshore beyond the

1,000m depth contour. Other users of the area inshore of the Exploration Licence blocks include the commercial

fishing industry, oil and gas licence holders and Namibia marine diamond mining concession holder s. Other

industrial uses include the intake of feed-water for fish processing, mariculture or diamond-gravel treatment (Pisces

Environmental Services (Pty) Ltd, 2014). However, as all these activities are located on the coast and well inshore of

the proposed survey area, none should be affected by exploration activities carried out within Block 2913B. .

6.3.1.1 Fishing

The fishing industry along the regional coastline is reportedly sustained by the high productivity of the Benguela

upwelling ecosystem. Fish stocks within these waters support intensive commercial fisheries. Mariculture

production is a developing industry based predominantly in Lüderitz. The dependency of coastal economies on

fishing mostly stems from (Benguela Current Commission, 2012):

Major employer providing direct and indirect work, especially in Lüderitz;

Significantly contributes to economic growth, as well as National and Regional Gross Domestic Product (GDP)

Fishing is reported to be the region largest earner of foreign currency and fourth largest within Namibia; and

Source of income for regional and nation income in the form of quota fess, licence fees, by-catch fees and the

Marine Resources Fund levies.

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6.3.1.2 Diamond Mining

Diamond mining is an important source of revenue for Namibia as well as the Region. Diamond mining companies

collectively contributed N$ 2.5 billion in royalties, taxes and dividends to the State Revenue Fund in 2013. De Beers

is by far the largest contributor in this respect, having paid US$154 million in taxes, royalties and charges in 2011

and almost double this amount, US$294 million, the following year. Efforts to promote and facilitate downstream

industries are also ongoing, with mining houses supplying local manufacturers with rough diamonds. Co astal and

offshore mining is concentrated most notably along the stretch of coast between Chameis Bay (around 150 km

south of Lüderitz) and Hondeklipbaai in South Africa. De Beers Marine, under contract with Namdeb, operates five

motor vessels used for extracting and processing diamonds from the ocean bed and a further two chartered

vessels used for exploration and sampling. Present-day land-based diamond mining also occurs near Lüderitz,

albeit on a far smaller scale than during the early 1900s, entailing a few satellite mines with some more substantial

operations closer to Oranjemund.

6.3.1.3 Tourism

The tourism industry makes a considerable contribution to Namibia’s economy. Tourist arrivals made up just under

91% of the 1.5 million arrivals to Namibia in 2015. Recreational activities making use of the coastal and marine

environment are an important component in the range of factors which attract tourists to Namibia. Lüderitz, and to

a lesser degree Oranjemund, are frequently visited by tourists, where activities centred around the ocean include

birding, sailing, fishing, wind-surfing and kiteboarding, surfing, kayaking and whale watching. The local tourism

industry in Lüderitz has reportedly grown significantly over the last 20 years. It has a number of historical sites and

buildings reflecting the town’s German history. The wild horses of the Namib, desert tours and trips to the historic

ghost mine town of Kolmanskop are also key tourist attractions. The Lüderitz Waterfront (N$35 million investment

in 2002) was created primarily to promote Lüderitz as a tourist destination. Lüderitz hosts key events with a focus

on the ocean (e.g. annual Crayfish Festival, Lüderitz Speed Sailing Challenge. A number of passenger cruise liner

operators include Lüderitz in their list of locations.

For tourists visiting Oranjemund, much of the town’s attraction lies in its abundance of desert fauna and flora that is

indigenous to the harsh environment of the Namib Desert. The area is strictly controlled as only tour operators with

concessions and visitors with valid permits are granted access. Tourist attractions include the former diamond

settlements, turned ghost towns, such as Kolmanskop, Pomona, Bogenfels and Elizabeth Bay.

6.3.1.4 Lüderitz Town

Several large-scale enterprises, mainly in mining, fishing and tourism, dominate the Lüderitz economy, whereas a

community of small-scale businesses located especially in and around the low-income areas generally lack the

capability to scale up their business models. A characteristic of the economy t hat arguably distinguishes Lüderitz

from other towns is its dependence on the regional and global economy. The Lüderitz economy is dependent on

industries which tend to be more cyclical in nature. The Lüderitz Town Council is working with businesses to diversify

and expand the local economy through an increased focus on developing industries such as aquaculture, tourism,

logistics, retail and amenities. The strong wind conditions in the area have also attracted interest from energy

companies interested in opportunities for wind energy.

6.3.1.5 Oranjemund Town

Oranjemund is a diamond mining town, established in 1936 as an accessory facility to support the land diamond

mining operations. The Town’ was classified as a private mining town and visitors to the town requir ed security

clearance and authorization in order to gain access to the town.

The town has several utilities, such as sport grounds, schools, medical centres, residential facilities, an airport of

international standard, and community centres, developed by Mining companies. Mining employees who resided in

Oranjemund town were provided with free housing, water and electricity, there are approximately 3 000 Mine owned

accommodation units within the town. A large part of the Towns economic activity is centred on services sector,

with Mining companies outsourcing non-core activities to private business and individuals, which led to the

establishment of the retail and service industry which include the following of the following shops and services:

Spar, Woolworths, Bars and Restaurants, Bottle stores, etc. It should be noted that mining operations within

Oranjemund are being decommissioned and the town has now been opened to the public. .

6.3.2 Administrative Context and Governance

Namibia gained independence on 21 March 1990 after more than a century of colonial rule and some 40 years of

being governed by the then-apartheid state of South Africa. Its population consisted of just over 2.3 million people

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in 2016 (Namibia Statistics Agency (NSA) 2017a), which is relatively low, when compared to its land surface area of

820,000 square kilometres (km2) (i.e. about four times the size of the United Kingdom). Namibia is divided into 14

administrative regions, of which the Khomas Region (in which the capital of Windhoek is situated) is the most

populated and most economically active.

The Project’s onshore activities will likely be based from Lüderitz and Oranjemund, which are both coastal tows

situated within the !NamiNűs and Oranjemund Constituencies of the //Karas Region. The Region is bordered in the

north by the Hardap Region, on the west by the Atlantic Ocean with South Africa’s Northern Cape Province forming

the Region’s Eastern and Southern Border. The Region’s administrative capital is situated in Keetmanshoop, which

is situated approximately 280 km north-east (as the crow flies) of Oranjemund town.

The country, which is a unitary state, is administrated by three tiers of governance, namely central, regional and local.

Central government consists of the President and the two Houses of Parliament, the National Assembly and

National Council. Regional governance is the responsibility of regional councils which regulatory powers is provided

under the Regional Councils Act of, 1992. (Act No. 22) The Act requires regional leaders to advise the President and

central government on matters relating to the region. The political head of a region is the Governor, who is appointed

by the President. The regions are divided into constituencies for electoral purposes. Each constituency elects one

member to the regional council using a first-past-the-post electoral system. The term of office of the regional

council members is six years. The regional councils elect from amongst their members two persons as member s

of the National Council. The sitting Governor of //Kharas Region, Mrs. Lucia Basson, is a member of South West

Africa People's Organization (SWAPO) and was elected in 2015. SWAPO also won both Oranjemund and !NamiNűs

constituencies during the 2015 regional elections. The next National and Regional elections will likely be held in

2020 and 2021, respectively.

The local authorities are generally only established in urban centres, with regional authorities administrating the rur al

areas within their region. Regional councils are responsible for specified service delivery in rural areas, while the

local authorities are responsible for service delivery in urban areas. Currently the only service provision

responsibility of the regional councils specified in the Regional Councils Act is the provision of basic services in

areas where settlements are proclaimed, but no local authorities are established. Local governance is undertaken

by four types of councils, with the nature of councils depending on the size of its jurisdiction; these councils include

municipal, town, village and settlement councils. The municipal councils are the most autonomous of the local

authorities. Under the Local Authorities Act, the Minister responsible for regional and local government may further

classify the municipalities into Part I and Part II municipalities. Currently there are three Part I and 15 Part II

municipalities, and 30 town and village councils in Namibia. Part I municipalities generally have a r obust financia l

basis and considerable autonomy regarding the determination of property tax and obtaining loans under the

provisions of the Local Authorities Act, whereas Part II municipalities have a more fragile financial basis and are

subject to control exercised by the Ministry of Regional and Local Government, Housing and Rural Development .

Most of the town councils cannot balance their budgets without substantial transfers from the central government

or donors, and their financial autonomy, in general, is limited.

Both Lüderitz and Oranjemund are governed by town councils lead by SWAPO who won the majority of seats during

the 2015 Local Government elections.

6.3.3 Demographics

6.3.3.1 Population Growth and Distribution

Similar to the national population, the regional population experienced marginal growth since 2011, growing with

2% annually to reach 85,759 in 2016 (NSA, 2017a). On a constituency level, Oranjemund recorded the highest

growth rate (2.3%), between 2001 and 2011, while !NamiNűs recorded a negative growth rate during this period

(NSA, 2014). Regional growth rates could partially be attributed to in-migration, as //Karas has experienced long

term nett in-migration of between 99 and 300 people per 1000 inhabitants since 2001. Although no census data is

available on constituency level from 2016 onwards, it is believed that Lüderitz Town would mimic regional growth

rates, whereas the growth rate in Oranjemund would have declined substantially in recent years, due to recent

downturn in economic activities.

Just more than half of the regional population (54%) resided within the region’s main urban centres in 2016, namely:

Keetmanshoop (25%), Lüderitz Town (16%), Karasburg (5%) and Oranjemund town (5%) (NSA, 2014; 2017a).

Settlement patterns throughout the region and both constituencies clearly follow economic activities. This trend is

especially evident in the !NamiNűs constituency, where 92% (or 12 537) of the constituency’s population resided

in Lüderitz and to a lesser degree in Oranjemund where only 33% (or 3 908) of the constituency resided in

Oranjemund town (NSA, 2014).

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In terms of population distribution //Karas is one of the least densely populated regions within the country, with less

than 0.5 persons per km2 on average, this trend is also evident in !NamiNűs (0.3 people/ km2). In contrast to the

Region and !NamiNűs Oranjemund, due to its relatively small land area (4 623 square kilometre or 3% of the regional

land area), boast with a population density of just more than 2 people/ km2 (NSA, 2014).

The average household size in the !NamiNűs constituency is 3.1, which is marginally higher than in Oranjemund

(2.7), but lower than the regional (3.6) and the national average (4) ( Table 6-5). Oranjemund has a relatively low

proportion of households (30%) which are headed by females - as opposed to 44% nationally, 33% regionally and

41% in ! !NamiNűs (NSA, 2014; 2017a).

Table 6-5: Population size and distribution (Source: NSA, 2014; 2017a)

A re a Ye ar A n n ual g rowth rate

2001 2011 2016 2001-2011 2011 -2016

Namibia 1 830 330 2 113 077 2 324 388 2.0 1.9

//Karas 69 329 77 421 85 759 1.1 2.0

!NamiNűs 14 542 13 859 na -0.5 na

Oranjemund 7 789 9 837 na 2.3 na

Table 6-6: Household size and head of household (Source: NSA, 2014; 2017a)

A re a House h old size Ge n d e r h ouse h old h e ad (2011)

2011 2016 Male F e m ale

Namibia 4.4 3.9 56% 44%

//Karas 3.6 3.3 61% 39%

!NamiNűs 3.1 Na 59% 41%

Oranjemund 2.7 Na 70% 30%

6.3.3.2 Age, Gender and Language Distribution

The age distribution on national, regional and constituency levels shows a similar trend across the regional

and!NamiNűs populations, with a third of the population falling within the 15 to 59 age bracket followed by those

between 5 and 14 years of age (Table 6-7). In contrast, Oranjemund has a considerably higher proportion of

individuals falling within the 15 to 59 year age bracket and relatively few individuals older than 60 years of age ( Table

6-7). Taking a closer look at working-age individuals reveals that the bulk of the working age population in !NamiNűs

constituency is concentrated in the 30 to 45-year-old age bracket, whereas the labour force in Oranjemund is more

widely distributed, between the 20 to 45- year-old age bracket. The town also has a notably smaller population

younger than 20 years old.

Table 6-7 also presents the gender ratio (proportion of males per 100 females in a given population) within the

region and its respective constituencies. It indicates relatively equal gender proportions across //Ka ras and

!NamiNűs, but a disproportionate distribution in Oranjemund, where males far outnumber their female

counterparts. This gender disparity can partially be attributed to past in-migration of male jobseekers, likely driven

by diamond mining and related economic activities within Oranjemund. This correlates with the relatively high

growth rate reported between 2001 and 2011. It should be notedthat this trend should be considered in light of

recent economic down turn in the constituency and Oranjemund town in particula r, which could result in some

outmigration-.

Prominent languages spoken throughout the region include Afrikaans (33%) followed by Oshiwambo (30%) and

Nama/Damara (25%) (NSA, 2017a). This distribution can be extrapolated to the respective constituencies; ho wever,

it is likely that the proportion of indigenous languages is more prominent in rural outskirts of both constituencies,

while the proportion of Afrikaans speaking people is slightly higher than the regional average in urban centres,

especially Oranjemund.

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Table 6-7: Gender and Age Distribution (Source: NSA, 2014; 2017a)

A re a Ge n d e r ratio tre n d A g e (ye ars) – 2016

2011 2016 0- 4 5-14 15-59 60>

Namibia 94 95 14% 22% 57% 6%

//Karas 104 102 14% 16% 63% 6%

!NamiNűs 101 Na 10% 20% 66% 4%

Oranjemund 121 Na 11% 15% 73% 1%

6.3.3.3 Literacy and Education

National literacy (or ability to read and write with understanding in any language) rates increased from 81% in 2011

to 89% in 2016 (Table 6-8). During the same period //Karas’ literacy rate increased with 5% to reach 97% (NSA,

2017a). The literacy rate among the regional population is slightly higher among males and within those residing in

urban centres, such as Lüderitz and Oranjemund (Table 6-9). The literacy rate within !NamiNűs and Oranjemund

constituencies in 2011 was 98% and 99%, respectively. In light of national and regional improvement in literacy

rates since 2011, it is anticipated that these rates would still be very high, especially within Lüderitz and Oranjemund

towns.

The level of formal education among the region’s adult population is relatively low, with only one fifth of those older

than 20 years having completed secondary school (Table 6-10). Constituency-level data on education levels could

not be obtained for 2016 onwards and it was therefore assumed that these educational levels will to a certain degree

mimic the level of education among the regional population. It is still likely that education levels are higher within

these constituencies due to their relatively high proportion of urbanised population, which implies better access to

educational facilities.

Table 6-8: Literacy by gender (15yrs>) (Source: NSA, 2016)

A re a 2016 2011

A l l Male F e m ale

Namibia 89% 89% 89.4 87.9

//Karas 96% 96% 96.5 95.7

!NamiNűs Na 98% 98.4 98.5

Oranjemund Na 99% 99.6 99.3

Table 6-9: Regional literacy rural vs. urban (15yrs>), 2016 (Source: NSA, 2017a)

/ /Karas Region Ge n d e r

Male F e m ale

Rural 94% 95%

Urban 98% 97%

Table 6-10: Highest level of education (20 yrs>) (Source: NSA, 2017a)

Ed ucation level No sc h ool in g Som e p rim ary Com p le te d

p rim ary

Com p le te d

se c on d ary

Complete Tertiary

Namibia – 2016 0.5 18.4 49.7 22.6 8.3

Namibia – 2011 1.5 23.7 48.5 20.5 5.8

//Karas 0.7 0.7 19.2 18.1 5.9

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6.3.4 Economic profile

6.3.4.1 Key economic sectors

The agriculture, forestry and fishing industries can be regarded as the mainstay of the regional economy, with just

less than a third of the regional population employed within this sector in 2011, followed by those employed in the

mining and administrative industries, which employed 8.9% and 8.5% of the respectively. On a constituency level

the data shows that !NamiNűs constituency was heavily reliant on fishing which, together with limited agriculture,

provides 42% of jobs, which is significantly higher than the regional average of 32%. The next most prominent

employing sectors are manufacturing and administrative and support service activities (both 8% ), with construction

as well as mining and quarrying contributing 6% of jobs each. For Oranjemund the largest proportion of the

employed population works in the mining sector.

Table 6-11: Main industry of employed population aged 15 years-old and above by area, 2011-2016

(Source: NSA, 2014; 2017a,b)

In d ustry Nam b iai

2016

Nam ib ia

2011

/ /Karas

2011

!Nam iNűs

2011

Agriculture, Forestry & Fishing 20.2% 30% 32.4% 42%

Mining & Quarrying 2.2% 3% 8.9% 6%

Manufacturing 6.6% 6% 5.7% 8%

Electricity, Gas, Steam & Heating, Ventilation, and Air Conditioning (HVAC) 0.7% 0.2% 0.2% 0.2%

Water & Waste management 0.7% 0.3% 0.4% 0.5%

Construction 9.3% 7% 6.3% 6%

Wholesale & Retail 9.7% 7% 6.3% 5%

Transport & Storage 3.3% 4% 3.8% 3%

Accommodation and Food storage 7.1% 4% 3.3% 4%

Information and communication 0.9% 1% 0.8% 0.6%

Financial Insurance Activities 2.3% 2% 1.4% 2%

Real estate 0.2% 0.1% 0.0% 0.1%

Professional Science 1.8% 2% 1.0% 1.1%

Administrative 6.0% 9% 8.5% 8%

Public Admin 4.5% 6% 6.9% 4%

Education 6.1% 6% 3.8% 3%

Human health & Social 2.8% 3% 2.5% 2%

Arts & Recreation 0.6% 1% 0.3% 0.2%

Other services 6.4% 3% 2.1% 1%

Private Households 8.7% 6% 5.0% 2%

Extraterritorial organisations 0.2% 0.1% 0.0% 0%

Don’t know 0% 1% 0.3% 0.5%

6.3.5 Employment and income

Three quarters of the region’s population was classified as economically active, which is considerably less than in

2011. The employment rate among the regional economically active population (population over 15 years-old,

which are economically active) was 80% in 2011, of these 68% were employed and 32% unemployed. Wages and

salaries are by far the most important source of income for households across all scales of the study area.

Approximately 48% of Namibian households report that their main source of income is from salaries and wages.

This figure is substantially higher for the!NamiNűs constituency and Oranjemund town.

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Table 6-12: Economic Activity, 15 years and older, //Karas Region (Source: NSA, 2014; 2017a,b)

A c tivity Karas

2011

Economically active 80%

Employed 68%

Unemployed 32%

Economically inactive 20%

Table 6-13: Household main source of Income (Source: NSA, 2014; 2017a)

Ec onomic activity Nam ib ia / /Karas !NamiNűs 2011 O ranjemund 2011

Salaries/wages 52% 74% 78.00% 87.10%

Farming 14.60% 2.00% 0.60% 0.30%

Business activities (excl. agriculture) 7.20% 3.80% 7.50% 5.40%

Pensions 1.30% 1.30% 5.20% 0.60%

Cash remittance 4.70% 1.50% 2.80% 4.30%

Old age grant/pension 10.20% 11% 5.20% 0.60%

Disability grant 0.80% 0.30% 0.40% 0.10%

Child grant 0.70% 0.80% 0.30% 0.10%

Other 8.10% 4.90% 0% 1.50%

6.3.5.1 Housing

Most of the households (Table 6-14) within the region and constituencies reside in detached or semi-detached

housing units, followed by a considerable number of households (18%-35%) residing in improvised housing units.

The proportion of households residing in detached housing is considerable higher than the national average,

however, the number of families residing in impoverish housing in Lüderitz is significantly higher than the national

average, whereas Oranjemund is substantially lowed.

Table 6-14: Type of housing (Source: NSA, 2014; 2017a)

Housing type Stud y are a

Namibia -

2016

//Karas -2016 //Karas -2011 !Nam iNűs -

2011

Oranjemund -

2011

Detached house/ Semi-detached house 31% 47.1% 47.1% 49.8% 47.8%

Apartment/flat 6.1% 14.1% 14.1% 7.7% 20.6%

Single Quarters 2.4% 3.7% 3.7% 6.1% 8.0%

Traditional dwelling 32.6% 8.1% 8.1% 0.1% 0.1%

Improvised housing unit/shack 26.6% 25.2% 25.2% 34.4% 18.0%

Other 1.4% 1.9% 1.9% 1.9% 5.7%

Table 6-15: Tenure status (Source: NSA, 2014; 2017a)

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Housing type Stud y are a

Nam ib ia –

2016

/ /Karas – 2016 / /Karas -2011 !Nam iNűs -

2011

O ranjemun d -

2011

Owner occupied with mortgage 12.4% 8.8% 13.2% 12.8% 9.5%

Owner occupied without mortgage 51% 28.3% 35.8% 30.6% 12.7%

Rented from employer 4.8% 20.3% 6.1% 4.0% 21.9%

Rented from individual 13.7% 10.5% 7.3% 7.4% 7.5%

Rented from Private firm - - 7.0% 6.8% 23.8%

Rented from local authority - - 5.1% 13.0% 4.7%

Occupied rent free 17.9% 32.1% 24.7% 25.0% 19.8%

Other 0.2% 0.0% 0.8% 0.5% 0.2%

6.3.6 Service delivery

6.3.6.1 Access to water and sanitation

Safe drinking water and adequate sanitation is a necessity for good health, as households without safe water and

proper sanitation systems are more vulnerable to water borne diseases. The majority of households within the

region and respective constituencies (95%) have access to safe water.

Access to sanitation facilities is problematic across in the regional area with almost a quarter of households that did

not have any access to sanitation (Table 6-16). In contrast, both constituencies have minimal households with now

access to sanitation.

Table 6-16: Sources of drinking and cooking water (Source: NSA, 2014; 2017a)

Source Namibia -

2016

//Karas -

2016

//Karas -

2011

!NamiNűs

- 2011

Oranjemun

d - 2011

Safe

water

Piped water 64% 73% 70% 70% 73%

Borehole with tank covered 7% 3% 6% 0% 0%

Public piped 22% 19% 17% 29% 27%

Borehole/with tank covered & well protected 4% 0% 0% 0% 0%

Bottled 1% 0% 0% 0% 0%

Total safe water 97% 95% 93% 99% 100%

Other Borehole with tank uncovered & well

unprotected

4% 0% 1% 0% 0%

River/ Dams and Canal 3% 2% 5% 0% 0%

Other 0% 0% 1% 0% 0%

Total unsafe water 7% 3% 7% 0% 0%

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Table 6-17: Access to sanitation (Source: NSA, 2014; 2017a)

San itation type Nation al -

2016

/ /Karas -

2016

/ /Karas -

2011

!NamiNűs -

2011

O ranjemund -

2011

Private/ Shared flush 41% 64% 64% 83% 77%

Pit latrine with ventilation pipe 6% 7% 4% 2% 11%

Covered pit latrine without ventilation pipe 4% 0.1% 3% 1% 4%

Uncovered pit latrine without ventilation pipe 3% 1% 2% 0% 3%

Bucket toilet (manually removed) 1% 2.9% 3% 4% 1%

No toilet facility (bush, riverbed, fields) 46% 25.1% 23% 10% 0%

Other 0.1% 0.1% 1% 0% 2%

6.3.6.2 Access to energy for cooking, lighting and heating

Electricity use at a regional level is relatively limited, with only 48% of households using it for cooking. In comparison,

a much larger proportion of households (69%) within the region use electricity for lighting purposes ( Table 6-18).

Table 6-18: Energy used for cooking, lighting, and heating (Source: NSA, 2014; 2017a)

Purpose of energy National - 2016 //Karas -

2016

//Karas -

2011

!NamiNűs

- 2011

Oranjemund

- 2011

Energy used for cooking

Electricity 35% 48% 42.1% 45.9% 62.4%

Wood 50% 25% 27.7% 4.0% 1.7%

Gas 12% 26% 29.2% 48.8% 35.5%

Energy used for lighting

Electricity 45% 69% 67% 77% 95%

Candle 12% 15% 23% 16% 4%

Other 43% 16% 10% 7% 1%

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7. Environmental Impact Assessment

The impact assessment methodology, as described during the Scoping Phase of the ESIA, takes into consideration

an impact’s nature (adverse or beneficial), type (direct, secondary or cumulative) and magnitude, and the sensitivit y

of the affected receptors, to yield a prediction of the impact’s overall ‘significance’.

7.1 Impact / Activity Screening

Subsequent to the Scoping Phase, a screening exercise was conducted of the potential interactions of the

proposed Project with the physical, biophysical and socio-economic environments:

N o int er act io n where the proposed Project is unlikely to interact on the environment;

Mino r negative interaction where there is likely to be an interaction, but the resultant effect is unlikely to change

baseline conditions significantly;

Mo derate/major negative int er act io n where there is likely to be an interaction and the resultant impact is likely

to have reasonable potential to cause a significant effect on the environment; or

Po sitive int er act io n where there is likely to be a positive interaction and the resultant impact has a positive

effect on the environment.

Impact significance was assessed considering existing control measures that are incorporated into the Project

design. After the remaining potential impacts have been identified and a preliminary assessment was conducted,

strategies to further avoid or mitigate the impacts were then developed.

7.2 Impacts on the Physical and Bio-physical Environment

7.2.1 Release of Air Emissions

Air emissions may be generated from the following activities:

Exhaust gas emissions produced by the combustion of gas or liquid fuels in turbines, boilers, compressors,

pumps and other engines for power and heat generation;

Fugitive emissions associated with leaking tubing, valves, connections, flanges, open-ended lines, pump

seals, compressor seals, pressure relief valves or tanks, and hydrocarbon, fuels, oils and lubricants loading and

unloading operations;

Vent or flaring off some of the oil and gas brought to the surface during well testing; and

Incineration of waste on board the drilling unit and support vessels.

The release of gaseous pollutants e.g. carbon dioxide (CO2), oxides of nitrogen (NOx), oxides of sulphur (SOx) and

carbon monoxide (CO) from the drilling unit, support vessels and helicopters have the potential to cause short-term

reductions in local air quality. These emissions will mainly be released near its source. Such emissions may have

negative physiological effects on marine fauna but may also contribute to global greenhouse gas emissions.

The release of emissions may cause a short-term reduction in local air quality and a negligible increase in

greenhouse gases that would make an insignificant contribution on the global scale. Most emissions would occur

at the drill site during drilling and well testing, as well as from support vessels and helicopters along the route from

the drilling unit, Lüderitz (onshore base) and potentially Oranjemund (helicopter base).

Flow testing would result in hydrocarbons being burned at the well sit e. Despite the negative perception of flaring, it

is one of the safest methods of disposing unwanted hydrocarbons that cannot otherwise be captured and used for

other purposes (SLR Environmental Consulting, 2017).

Even though most of the solid waste would be transported to shore for disposal, certain non-toxic combustible

wastes may be incinerated on the drilling unit and support vessels . An example of the non-toxic combustible waste

may include (e.g. galley waste). The volumes of solid waste that may be incinerated on board, and hence also the

volumes of atmospheric emissions, would be minimal. The frequency of waste transportation to shore will depend

on the waste volume produced relative to safety precautions.

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Table 7-1: Physiological effects of air emissions on marine fauna

IMPACT DESCRIPTION: PHYSIOLOGICAL EFFECTS OF AIR EMISSIONS ON MARINE FAUNA

Predicted for project phase: Mobilisation Operation Demobilisation

Dimension Rating

PRE-MITIGATION

Duration Short Term (1) Consequence:

Slightly detrimental

(-7)

Significance:

Low negative

(-21)

Extent Site (1)

Intensity x type

of impact Low Medium - negative (-4)

Probability Likely (3)

MITIGATION:

Implement a maintenance plan to ensure all emission causing infrastructure receives regular maintenance to minimise

emissions released into the atmosphere.

Implement leak detection on emission generating infrastructure .

Identify all Ozone Depleting Substances (ODSs) and implement controls to prevent or minimise release into the atmosphere

– this includes:

─ Replacing ODS generating equipment with non-ODSs generating equipment;

─ Minimising the use of ODS generating equipment; and

─ Maintaining ODS generating equipment to prevent leaks.

Repairing leaking equipment within a suitable timeframe.

Incineration of waste to be restricted outside of ports and to specific items. This should be detailed in the Waste

Management Plan.

Drilling schedules to be optimised to ensure that energy consumption is minimised.

Use a high-efficiency burner for flaring to maximise combustion of the hydrocarbons in order to minimise emissions and

hydrocarbon ‘drop-out’ during well testing.

Maximise flare combustion efficiency by controlling and optimising flare fuel/air/stream flow rate s.

POST-MITIGATION

Duration Short Term (1) Consequence:

Negligible

(-5)

Significance:

Low negative

(-15)

Extent Site (2)

Intensity x type of impact

Low - negative (-2)

Probability Likely (3)

Given the distance (250 km) of the offshore activities, air emissions are expected to disperse rapidly and there is no

potential for accumulation of air pollution leading to any long-term impacts. The potential impact of emissions due

to drilling and associated activities would be localised and of limited duration and far from any potential receptors.

The significance of this impact is, therefore, assessed to be very low without mitigation.

Table 7-2: Greenhouse gas emissions on global warming

IMPACT DESCRIPTION: GREENHOUSE GAS EMISSIONS ON GLOBAL WARMING

Predicted for project phase: Operation

Dimension Rating

PRE-MITIGATION

Duration Short Term (1)

Consequence:

Slightly detrimental

(-7)

Significance:

Low negative

(-21)

Extent Site (1)

Intensity x type

of impact Low Medium - negative (-4)

Probability Likely (3)

MITIGATION:

Use a high-efficiency burner for flaring to maximise combustion of the hydrocarbons in order to minimise emissions and hydrocarbon ‘drop-out’ during well testing.

Use energy-efficient combustion equipment (engines, turbines) to reduced fuel use and thus greenhouse gas (GHG)

emissions.

Maximise flare combustion efficiency by controlling and optimising flare fuel/air/stream flow rates.

Ensure no incineration of waste occurs within the port limits.

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IMPACT DESCRIPTION: GREENHOUSE GAS EMISSIONS ON GLOBAL WARMING

Predicted for project phase: Operation

POST-MITIGATION

Duration Short Term (1) Consequence:

Negligible

(-5)

Significance:

No Impact

(-10)

Extent Site (2)

Intensity x type

of impact Low - negative (-2)

Probability Possible (2)

The release of emissions may cause a short-term reduction in local air quality and a negligible increase in

greenhouse gases that would make an insignificant contribution on the global scale.

7.2.2 Discharge of Waste to Sea

Various discharges to sea are typical of an offshore exploration project:

Normal vessel discharge;

Ballast water discharge; and

Discharge of cuttings, drilling fluid and cement.

Discharge of waste shall comply with the Marine Notice No. 04 of 2018: Garbage Management Requirements in

Namibia under MARPOL Annex V.

7.2.2.1 Normal vessel discharge

Normal discharges are expected from the following sources:

Deck drainage: Deck drainage consists of liquids from rainfall, sea spray, deck and equipment washing.

Machinery space drainage: Vessels occasionally discharge treated bilge water. Bilge water is drainage water

that collects in a ship’s bilge space.

Sewage: Discharges of sewage would vary according to the number of persons on board and would be

intermittent.

Galley wastes: Galley wastes, comprising mostly of biodegradable food waste, generated on board the project

vessels would be discharged over board.

Cooling water: Seawater would be used as the cooling for generators on board the drilling unit and the heated

seawater would be discharged overboard.

Opening and closing of the BOP: A further operational discharge is associated with routine well opening and

closing operations.

These discharges would result in the local reduction in water quality, which may also impact marine fauna:

Physiological effects: Ingestion of hydrocarbons, detergents and other waste could have adverse effects on

marine fauna, which could ultimately result in mortality;

Increased food source: The discharge of galley waste and sewage would result in an additional food source for

opportunistic feeders; and

Increased predator - prey interactions: Predatory species may be attracted to the aggregation of fish attracted

by the increased food source.

The discharge of waste would mainly be done at the drill site and along transport route from the onshore base to

the drilling site. Although Block 2913B is located a great distance from sensitive receptors, discharges could still

affect migratory species within the area of influence. Vessel discharges on route to Lüderitz could result in

discharges closer to shore, thereby potentially having an environmental effect on the sensitive coastal environment.

The drilling unit and support vessels would have the necessary sewage treatment systems, oil/water separators

and food waste macerators to ensure compliance with MARPOL 73/78 standa rds. Given the distance from the

shore, waste discharges are expected to disperse rapidly and there is no potential for accumulation of wastes

leading to a long-term impact.

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It is only likely to be pelagic species of fish, birds, turtles and cetaceans that may be affected by the discharges,

some of which are species of conservation concern. The abundance of these species in the area of interest is

expected to be low, and they are unlikely to respond to the minor changes in water quality resulting from vess el

discharges.

Table 7-3: Reduction of water quality due to normal discharge to sea

IMPACT DESCRIPTION: REDUCTION OF WATER QUALITY DUE TO NORMAL DISCHARGE TO SEA

Predicted for project phase: Mobilisation Operation Demobilisation

Dimension Rating

PRE-MITIGATION

Duration Short Term (1) Consequence:

Negligible

(-5)

Significance:

Low negative

(-15)

Extent Site (1)

Intensity x type of impact

Low - negative (-2)

Probability Likely (3)

MITIGATION:

Develop the following plans which address all wastes generated during the various activities:

─ Shipboard Oil Pollution Emergency Plan (SOPEP);

─ Oil Spill Contingency Plan (OSCP)

─ Oil Spill Rehabilitation Plan;

─ Waste Management Plan; and

─ Ballast Water Management Plan.

These plans should discuss waste management strategies for drilling fluids, domestic wastes, sanitary wastes, radioactive

wastes, produced water, drill cuttings, hydrocarbons and any other waste stream s identified on site. These strategies should involve both sustainable production and consumption.

Waste must be segregated before storage and appropriate disposal. This should be clearly outlined in the Waste

Management Plan, e.g.:

─ The generation of waste should be avoided as far as practicable; where it cannot be avoided, waste should be reduced,

re-used and recovered (including recycling and composting); where waste cannot be reduced, re -used and/or

recovered, it should be disposed of in an environmentally sound manner (at the Lüderitz and/or Oranjemund landfills with prior permission from the Town Council(s)).

─ Waste minimisation can be achieved by: buying in bulk quantities; using refillable, bulk dispensers (e.g. toiletries) (vs. individually packaged products); working with suppliers in order to limit the use of, and establishing recycling for,

product packaging; avoiding the use of polystyrene foam altogether; using glass/durable plastic rather than disposable

plastic items (straws/cups); providing in-room recycling procedures and appropriate receptacles.

Waste storage must be available, secure and not open to the elements.

Disposal of general and hazardous waste should occur onshore in accordance with the appropriate laws and ordinances –

this methodology must be outlined in the Waste Management Plan. Where waste cannot be disposed of onshore the conditions of MARPOL must be adhered to.

Incineration of waste to be restricted outside of ports and to specific items. This should be detailed in the Waste

Management Plan.

Ships: Discharge of food waste less than 3 nautical miles offshore must be comminuted to particle sizes smaller than 25

millimetres (mm).

Ships: Discharge of food waste which is not comminuted may only be disposed at 12 nautical miles offshore.

Food waste cannot be discharged within 500 m of a fixed and floating platform (refer to the Marine Notice No. 04 of 2018:

Garbage Management Requirements in Namibia under MARPOL Annex V).

The discharge of sewage into the sea is prohibited, except when the ship has in operation an approved sewage treatment

plant or when the ship is discharging comminuted and disinfected sewage using an approved system at a distance of more

than 3 nautical miles from the nearest land. Sewage which is not comminuted or disinfected may be discharged at a

distance of more than 12 nautical miles from the nearest land when the ship is en route and proceeding at not less than 4

knots.

Sewage effluent must be discharged more than 5 m below the water surface.

Waste discharges must be controlled where fauna is observed being attracted to the area.

Oil spills must be cleaned immediately using the appropriate oil absorbents with low to no toxicity.

Relevant staff must be trained in spill identification and remediation.

Leak, spill detection and maintenance programmes must be undertaken on all infrastructure which has the potential to leak

and create waste (liquid, gas, solid, etc.).

Use a low-toxicity biodegradable detergent for the cleaning of all deck spillages.

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IMPACT DESCRIPTION: REDUCTION OF WATER QUALITY DUE TO NORMAL DISCHARGE TO SEA

Predicted for project phase: Mobilisation Operation Demobilisation

Use drip trays to collect run-off from equipment that is not contained within a bunded area and route contents to the closed

drainage system.

Dispose of residual oily waste onshore in accordance with the appropriate laws and ordinances.

The discharges of deck drainage that is contaminated with hydrocarbons, fuels, oils and lubricants, and all bilge water must

be treated before being discharged into the sea.

POST-MITIGATION

Duration Short Term (1) Consequence:

Negligible

(-5)

Significance:

No Impact

(-10)

Extent Site (2)

Intensity x type

of impact Low - negative (-2)

Probability Possible (2)

Based on the relatively small discharge volumes, offshore location and high energy sea conditions, the potential

impact of normal discharges from the drilling unit and support vessels would be of low intensity, short -term duration

and mainly limited to the immediate area around the drilling unit (highly localised).

Table 7-4: Effect of normal discharge on marine fauna and flora

IMPACT DESCRIPTION: EFFECT OF NORMAL DISCHARGE ON MARINE FAUNA AND FLORA

Predicted for project phase: Mobilisation Operation Demobilisation

Dimension Rating

PRE-MITIGATION

Duration Short Term (1) Consequence:

Negligible

(-5)

Significance:

Low negative

(-15)

Extent Site (2)

Intensity x type of impact

Low - negative (-2)

Probability Likely (3)

MITIGATION:

Disposal of general and hazardous waste should occur onshore in accordance with the appropriate laws and ordinances –

this methodology must be outlined in the Waste Management Plan. Where waste cannot be disposed of onshore the conditions of MARPOL must be adhered to.

Ships: Discharge of food waste less than 3 nautical miles offshore must be comminuted to particle sizes smaller than 25

mm.

Ships: Discharge of food waste which is not comminuted may only be disposed of between 3 and 12 nautical miles.

Offshore platforms more than 12 nautical miles from land and ships within 500 m of said platforms: discharge of

comminuted food waste is permitted; discharge of food waste which is not comminuted is not permitted.

The discharge of sewage into the sea is prohibited, except when the ship has in operation an approved sewage treatment

plant or when the ship is discharging comminuted and disinfected sewage using an approved system at a distance of m ore

than three nautical miles from the nearest land. Sewage which is not comminuted or disinfected may be discharged at a

distance of more than 12 nautical miles from the nearest land when the ship is en route and proceeding at not less than 4

knots.

Sewage effluent must be discharged more than 5 m below the water surface.

Waste discharges must be controlled where fauna is observed being attracted to the area.

Oil spills must be cleaned immediately using the appropriate oil absorbents with low to no toxicity.

Relevant staff must be trained in spill identification and remediation.

Leak, spill detection and maintenance programmes must be undertaken on all infrastructure which has the potential to leak

and create waste (liquid, gas, solid, etc.).

Use a low-toxicity biodegradable detergent for the cleaning of all deck spillages.

Use drip trays to collect run-off from equipment that is not contained within a bunded area and route contents to the closed

drainage system.

Dispose of residual oily waste onshore in accordance with the appropriate laws and ordinances.

All conditions and exceptions listed in the Marine Notice No. 04 of 2018: Garbage Management Requirements in Namibia

under MARPOL Annex V shall be adhered to.

POST-MITIGATION

Duration Short Term (1) Consequence: Significance:

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IMPACT DESCRIPTION: EFFECT OF NORMAL DISCHARGE ON MARINE FAUNA AND FLORA

Predicted for project phase: Mobilisation Operation Demobilisation

Extent Site (2) Negligible

(-5)

No Impact

(-10) Intensity x type

of impact Low - negative (-2)

Probability Possible (2)

7.2.2.2 Ballast water discharge

To maintain the stability and trim of the drilling unit and the support vessels, seawater would be pumped into

designated ballast tanks and released to sea during mobilisation and transit to site. Depending on where the ballast

water is loaded, it may contain larvae, cysts, eggs and adult marine organisms from other locations. Thus , ballasting

and de-ballasting of project vessels could lead to the introduction of exotic species and harmful aquatic pathogens

to the marine ecosystem. Vessels and the transportation of infrastructure from one location to another also provide

the potential for translocation of introduced or alien species. As such the unlikely impact related to the introduction

of alien invasive marine species is considered to be of medium intensity in the long-term and of regional to national

extent. Once established, an invasive species is likely to remain in perpetuity. The significance of impact is

consequently deemed medium to high without mitigation.

The discharge of ballast water from support vessels and drilling units would take place at the drill site, which is

located more than 250 km offshore. The drill site, as mentioned before, is not near any sensitive receptors or

conservation areas. The risk that discharge of ballast water may have is significantly reduced by management

measures to be implemented contained within the International Marine Organisation (IMO) guidelines: exchanging

ballast water at least 370 km from the nearest land and in water of at least 200 m depth. The risk of this impact is

further reduced by the highly dynamic, wave-exposed coastline of Namibia, which contributes to minimising the

establishment of alien invasive species resulting in comparatively low numbers of such species in the region (SLR

Environmental Consulting, 2017).

Table 7-5: Reduction of water quality due to ballast discharge to sea

IMPACT DESCRIPTION: REDUCTION OF WATER QUALITY DUE TO BALLAST DISCHARGE TO SEA

Predicted for project phase: Mobilisation Operation Demobilisation

Dimension Rating

PRE-MITIGATION

Duration Short to medium Term (2) Consequence:

Highly detrimental

(-14)

Significance:

Low negative

(-28)

Extent National (4)

Intensity x type

of impact Medium high - negative (-8)

Probability Possible (2)

MITIGATION:

Each vessel which carries ballast water is to have a Ballast Water Management Plan which complies with the requirements set out in the International Convention for the Control and Management of Ships ’ Ballast Water and Sediments, 2004.

All ships will also have to carry a Ballast Water Record Book and an International Ballast Water Management Certificate.

Ships need to comply with Regulations D1 and D2 of the International Convention for the Control and Management of

Ships' Ballast Water and Sediments, 2004).

Ships performing ballast water exchange shall do so with an efficiency of 95% volumetric exchange of ballast water. For

ships exchanging ballast water by the pumping-through method, pumping through three times the volume of each ballast

water tank shall be considered to meet the standard described. Pumping through less than three times the volume may be

accepted provided the ship can demonstrate that at least 95% volumetric exchange is met.

Ships conducting ballast water management shall discharge less than 10 viable organisms per cubic metre greater than or

equal to 50 micrometres in minimum dimension and less than 10 viable organisms per millilitre less than 50 micrometres in minimum dimension and greater than or equal to 10 micrometres in minimum dimension; and discharge of the indicator

microbes shall not exceed the specified concentrations.

Ballast water exchange must take place at least 200 nautical miles from the nearest land and in water at least 200 m deep

where possible, taking into account the guidelines developed by the IMO. No ballast water is to be exchanged within ports

or harbours.

All ships shall remove and dispose of sediments from spaces designated to carry ballast water in accordance with the provisions of the ship‘s Ballast Water Management Plan.

Ensure all infrastructure (e.g. wellheads, BOPs and guide bases) that has been used in other regions is thoroughly cleaned

prior to deployment.

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IMPACT DESCRIPTION: REDUCTION OF WATER QUALITY DUE TO BALLAST DISCHARGE TO SEA

Predicted for project phase: Mobilisation Operation Demobilisation

Use filtration procedures during loading in order to avoid the uptake of potentially harmful aquatic organisms, pathogens

and sediment that may contain such organisms.

Ensure that routine cleaning of the ballast tank to remove sediments is carried out, where practicable, in mid-ocean or

under controlled arrangements in port or dry dock, in accordance with the provisions of the ship's Ballast Water Management Plan.

Officers and crew shall be familiar with their duties in the implementation of ballast water management particular to the shi p

on which they serve and shall, appropriate to their duties, and be familiar with the ship‘s Ballast Water Management Plan.

The Ballast Water Management Plan must be approved by the relevant authorities.

POST-MITIGATION

Duration Short Term (1) Consequence:

Slightly detrimental

(-6)

Significance:

Low negative

(-12)

Extent Regional (3)

Intensity x type of impact

Low - negative (-2)

Probability Possible (2)

7.2.2.3 Cuttings, drilling fluid and cement

Discharge of cuttings, drilling fluid or cement are possible due to the following:

During the riserless drilling stage, cuttings from the top-hole sections would be discharged onto the seafloor

where they would accumulate in a conical cuttings pile around the wellhead;

After a casing string is set in a well, specially designed cement slurries are pumped into the annular space

between the outside of the casing and the borehole wall. During this operation a maximum of 150% of the

required cement volume would be pumped into the space between the casing and the borehole wall. Due to

the low temperatures and high pressures at the proposed well depth, the excess cement would diss olve slowly

into the surrounding seawater. Typically a small margin of excess cement is prepared for each cementing

activity in order to account for possible losses on account of the activity. The excess cement is subsequently

discharged in allowable quantities.

During the risered drilling, cuttings are circulated to the drilling unit, where the cuttings are removed from the

returned drill mud and treated to reduce oil content before being discharged overboard. Cuttings released

from the drilling unit would be dispersed more widely around the drill site by prevailing currents.

The potential impacts associated with the discharge of cuttings, drilling fluid and cement include:

Smothering of seabed habitat and associated benthic fauna. Any benthic fauna present on the seabed within

the footprint of the discharge may potentially be disturbed or crushed;

Marine fauna and benthic organisms may suffer toxicity and bioaccumulation effects due to leaching of

cement additives;

Increased water turbidity and reduced light penetration resulting in indirect physiological effects on marine

fauna; and

Reduced physiological functioning of marine organisms due to indirect biochemical effects.

The discharge of cuttings at the seabed would have effects on benthic faunal communit ies living on the seabed or

within the sediments in the vicinity of the drill site and within the fall-out footprint of the cuttings plume discharged

from the drilling unit. Although the benthic fauna at the water depths encountered in the area of interest is poorly

understood, deep water fauna inhabiting unconsolidated sediments is expected to be relatively ubiquitous, usually

comprising fast-growing species able to rapidly recruit into areas that have suffered environmental disturbance.

Epifauna living on the sediment typically comprise urchins, burrowing anemones, molluscs, seapens and sponges,

many of which are longer-lived and, therefore, more sensitive to disturbance. No rare or endangered species are

known to occur in the deep-water area. As noted in 6.2, during the field survey portion of the baseline study photos

and videos showed very limited evidence of conspicuous fauna.

TOTAL routinely conducts modelling of cuttings discharges prior to drilling using the SINTEF Dose related Risk and

Effect Assessment Model (DREAM) / ParTrack model. The DREAM (Dose Related Risk and Effect Assessment

Model) is a three-dimensional particle model for assessing the consequences of regular planned releases to the

marine environment. DREAM helps visualise and analyse releases occurring over extended time periods in the water

column. The ParTrack model includes releases of drill fluids and cuttings. Additional environmental risk calculations

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for bottom sediments and particle stress in the water column are also carried out using Predicted Environmenta l

Concentration (PEC) / Predicted No Effect Concentration (PNEC) analysis. The (PEC) is calculated by the model

based on the drilling fluids composition, product characteristics and environmental conditions. This PEC is then

compared to the Predicted No Effect Concentrations (PNEC) to characterize whether or not the anticipated

concentration is expected to have a significant risk of impact on the habitat. A fine resolution 1/32° configuration of

the global HYCOM assimilated currents model provides MetOcean inputs to cover the area offshore Namibia. The

results of the PEC / PNEC analysis are shown in Figure 7-1. Areas in red on the figure have PEC / PNEC greater than

1 at the period specified.

Figure 7-1: Maximum risk level on water column

Although the risk (PEC / PNEC) exceeds 5% near the well (~1 km), the risk to the water column is limited in time and

only during WBM discharges. The risk becomes non-significant to null when the riserless discharges are over

(planned for about 21 days after drilling begins). No residual impact on water column is expected at the end of

activities. Discharge of non-aqueous based mud on cuttings presents no risk to the water column below 5%.

Table 7-6: Reduction of water quality due to cuttings, drilling fluid and cement

IMPACT DESCRIPTION: REDUCTION OF WATER QUALITY DUE TO CUTTINGS, DRILLING FLUID AND CEMENT

Predicted for project phase: Operation

Dimension Rating

PRE-MITIGATION

Duration Short Term (1) Consequence:

Slightly detrimental

(-9)

Significance:

Low negative

(-27)

Extent Site (2)

Intensity x type of impact

Medium - negative (-6)

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IMPACT DESCRIPTION: REDUCTION OF WATER QUALITY DUE TO CUTTINGS, DRILLING FLUID AND CEMENT

Predicted for project phase: Operation

Dimension Rating

Probability Likely (3)

MITIGATION:

Collect and review Remotely Operated Vehicle (ROV) footage of pre-drilling surveys to identify potential vulnerable habitats within 150 m from the well location.

Ensure drill site is located more than 500 m from any identified vulnerable habitats.

Avoiding excess cement usage by monitoring (by ROV) for discharges during cementing.

Use high efficiency solids control equipment to reduce the need for fluid change out and minimise the amount of residual

fluid on drilled cuttings.

Ensure regular maintenance of the on-board solids control package.

Ensure that all responsible staff receive adequate training.

Report emergency situations to the relevant authorities and initiate the relevant emergency procedures (refer to Appendix A).

Prioritize low-toxicity and partially biodegradable additives in drilling fluid and cement.

POST-MITIGATION

Duration Short Term (1) Consequence:

Negligible

(-5)

Significance:

No Impact

(-10)

Extent Site (2)

Intensity x type

of impact Low - negative (-2)

Probability Possible (2)

Cuttings discharged from the drilling unit would also have both direct and indirect effects on primary producers

(phytoplankton) in surface waters and pelagic fish and invertebrate co mmunities in the water column. Due to the

offshore location of the area of interest, the abundance of phytoplankton, pelagic fish and invertebrate fauna is likely

to be very low. Being dependent on nutrient supply, plankton abundance is typically spatially and temporally highly

variable and is thus considered to have a low sensitivity.

7.2.3 Disturbance to the Seabed / Seabed Sediments

Disturbance to the seabed may occur during the following activities:

During pre-drilling surveys, a ROV would be deployed to obtain video footage of the seabed at the proposed

well location. Although the standard operating procedure is not to settle or rest the ROV on the seabed, the

ROVs thrusters may stir up the soft or silty sediments when operating close to the seabed. This res uspension

of fine sediments would temporarily disturb seabed communities and result in localised increased turbidity.

The penetration of the seabed by the drill bit would physically disturb a small surface area and displace deeper

sediments around the wellhead. Casing of the hole and installation of the wellhead and BOP would potentially

also result in localised direct disturbance of an area around the well site.

The removal of the BOP, which would include the use of a ROV, may also result in the localised disturbance of

the seabed.

Any benthic fauna and flora present on the seabed and in the sediment in the disturbance footprint would be either

eliminated or may potentially be disturbed or crushed. Resuspension of seabed sediments by ROV thrusters may

also result in increased turbidity near the seabed, potentially with physiological effects on benthic faunal and floral

communities.

Deep water fauna, inhabiting unconsolidated sediments, and flora is expected to be relatively abundant, comprising

fast-growing species able to rapidly recruit into areas that have suffered disturbance.

The immediate effect on the benthos depends on their degree of mobility, with sedentary and relatively immobile

species likely to be physically damaged or destroyed during the drilling disturbance. Sediment in the area of interest

is dominated by muds and sandy muds (SLR Environmental Consulting, 2017). Due to the high natural variability in

benthic communities in the region, the structure of the communities in the area of interest would likely be highly

spatially and temporally variable and is likely to comprise fast-growing species able to rapidly recruit into areas that

have suffered natural environmental disturbance.

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Table 7-7: Smothering of seabed due to discharge of cutting, drilling fluid and cement (affecting flora and

fauna)

IMPACT DESCRIPTION: SMOTHERING OF SEABED DUE TO DISCHARGE OF CUTTING, DRILLING FLUID

AND CEMENT (AFFECTING FLORA AND FAUNA)

Predicted for project phase: Operation

Dimension Rating

PRE-MITIGATION

Duration Long Term (4) Consequence:

Slightly detrimental

(-7)

Significance:

Low negative

(-21)

Extent Footprint (1)

Intensity x type

of impact Low - negative (-2)

Probability Likely (3)

MITIGATION:

Implement procedures that stipulate that ROVs do not land or rest on the seabed as part of normal operations.

Ensure drill site is located more than 500 m from any identified vulnerable habitats.

Avoiding excess cement usage by monitoring (by ROV) for discharges during cementing.

Ensure all recovered drilling mud is taken to shore for treatment and re-use.

Ensure that all responsible staff receive adequate training

Report emergency situations to the relevant authorities and initiate the relevant emergency procedures (refer to Appendix

A).

Use high efficiency solids control equipment to reduce the need for fluid change out and minimise the amount of residual fluid on drilled cuttings.

Prioritize low-toxicity and partially biodegradable additives in drilling fluid and cement.

POST-MITIGATION

Duration Medium Term (3) Consequence:

Slightly detrimental

(-6)

Significance:

Low negative

(-18)

Extent Footprint (1)

Intensity x type

of impact Low - negative (-2)

Probability Likely (3)

Considering the available area of similar habitat on and off the edge of the continental shelf in the Atlantic Offshore

Bioregion, this minimal disturbance of and reduction in benthic biodiversity can be considered negligible. Impacts

on the offshore benthos as a result of physical damage and sediment disturbance are considered to be much

localised. The intensity and duration of an impact on unconsolidated sediments is considered to be of medium

intensity in the short-term (recovery is expected to take place within two to five years). Therefore, this impact on

unconsolidated sediments is assessed to be of low significance without mitigation.

7.2.4 Noise Generation

N O TE: THIS SUB-SECTION BELOW SHOULD BE READ IN CONJUNCTION WITH THE IMPACT ASSESSMENT ENCLOSED HEREWITH AS APPENDIX

B.1 .

Noise are typically to be generated by the following sources during the proposed Project:

7.2.4.1 Semi-submersible rig positioning

Semi-submersible rigs always float on pontoons and are towed to location by tw o or more tugs. During drilling

operations, the deck is lowered but kept above wave height. Rigs used in deep water or harsh environments ,

maintain position over the drilling location either by anchors (and where fitted, with rig thruster assistance as

necessary) or by dynamic positioning using a series of computer-controlled thrusters. Rig anchoring typically

involves the deployment by anchor handler vessel, of eight or more 12 tonne high efficiency seabed penetrating

anchors. During the positioning of the semi-submersible rig:

PTS may occur in low frequency cetaceans if they remain within a distance of 23 m from tugs/anchor vessels

positioning the rig or 43 m from thrusters for a period of 1 hour. TTS may occur if they remain within 505 m

from tugs/anchor vessels or 934 m from thrusters for a similar period.

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PTS may occur in mid frequency cetaceans if they remain within close proximity (e.g. less than 10 m) from

vessels of thrusters for a period of 1 hour. TTS may occur if they remain within 29 m from vessels or 53 m from

thrusters for a similar period.

PTS may occur in phocid pinnipeds if they remain within a distance of 13 m from tugs/anchor vessels

positioning the rig or 23 m from thrusters for a period of 1 hour. TTS may occur if they remain within 271 m

from tugs/anchor vessels or 500 m from thrusters for a similar period.

PTS may occur in otariid pinnipeds if they remain within close proximity (e.g. less than 10 m) from vessels of

thrusters for a period of 1 hour. TTS may occur if they remain within 20 m from vessels or 36 m from thrusters

for a similar period.

Moderate behavioural reactions in marine mammals, such as changes in swimming direction and speed, may occur

beyond the range at which TTS could occur. At distances beyond 1 km the likelihood of any observable responses

to sound is expected to be low.

TTS may occur in high sensitivity fish if they remain within 185 m from vessels or 341 m from thrusters for a period

of 12 hours. Recoverable injury may only occur if they remain in proximity (within 10 m) to the operations for a period

of 48 hours; although the likelihood is that they will move away from a disturbing sound source. TTS effects on low

and medium sensitivity fish are estimated to be moderate within metres of a continuous sound source, and low at

intermediate and greater distances.

Previous studies in the project area (SLR Environmental Consulting, 2017) estimated that the overall underwater

ambient noise levels in the project area would range from about 80 decibel (dB)rms re 1μPa (root mean square sound

pressure over the measured period, expressed as dB re 1 μPa) in calm conditions (including possible low frequency

noise component), up to about 120 dBrms re 1μPa during periods of higher winds and or heavy rainfall, or when ships

are moving past the area of interest. It is assumed that such levels may be typical for the region in which the project

activity is taking place. It is therefore likely that marine life will have become largely habituated to such sound levels

and there would be a minimal relative increase to existing levels of disturbance on pinnipeds and fish species.

7.2.4.2 Driving/Drilling

Sound will be generated from the rig at the drilling location when the drilling programme is in progress. The sound

source levels emitted during the drilling programme would typically consist of the driving of a conductor pipe, drill

pipe operation and on-board machinery. The sound will be mainly emitted above water, with low transmission into

the water from the air; however, some sound will be emitted directly into the water. During the driving of conductor

pipe:

PTS may occur in low frequency cetaceans if they remain within a distance of 235 m from driving activities for

a period of 1 hour. TTS may occur if they remain within 2.3 km from driving activities for a similar period.

PTS may occur in mid frequency cetaceans if they remain within a distance of 11 m from driving activities for

a period of 1 hour. TTS may occur if they remain within 113 m from driving activities for a similar period.

PTS may occur in phocid pinnipeds if they remain within a distance of 171 m from driving activities for a period

of 1 hour. TTS may occur if they remain within 1.7 km from driving activities for a similar period.

PTS may occur in otariid pinnipeds if they remain within a distance of 197 m from driving activities for a period

of 1 hour. TTS may occur if they remain within 1.9 km from driving activities for a similar period.

Moderate behavioural reactions in marine mammals, such as changes in swimming direction and speed, may occur

beyond the range at which TTS could occur. At distances beyond 2 km the likelihood of any observable responses

to sound is expected to be low.

TTS may occur in fish if they remain within 201 m for a period of 1 hour. Injury (recoverable or mortal) may only occur

if they remain in proximity (within 15 m) to the operations for a period of 1 hour. For these and longer periods the

likelihood is that fish will move away from a disturbing sound source before any injury is likely to occur. Low level

disturbance to fish may occur at distances beyond the possible TTS distances. However, as described above, it is

considered that the local underwater sound environment would be dominated by sound from existing commercial

and oil industry vessel traffic and there would be a minimal relative increase to existing levels of disturbance on fish

species.

During drilling activities, PTS may occur in cetaceans and pinnipeds if they remain within proximity (e.g. less than 10

m) from drilling activities for a period of 1 hour. TTS may occur in low frequency cetaceans if they remain within 17

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m for a similar period; for other species groups this would occur if they remain within proximity (e.g. less than 10 m).

The likelihood of any observable effects on fish species due to drilling sound is low.

7.2.4.3 VSP Airgun Operations

Sound will be generated by air gun operations during VSP activities, where geophones are lowered into the well and

a seismic source (typically an array of multiple individual air guns) is either lowered over the well (from a rig or

stationary vessel, known as zero-offset VSP) or from a source vessel which travels away from the well (known as

offset VSP). Air is released into the water, forming a bubble, which expands and contracts resulting in a change of

pressure. The pressure output signature of an individual air gun consists of a short duration pulse, typically 10 -20

milliseconds (ms) associated with the initial release of air, followed by longer duration, lower amplitude pulses

associated with the secondary bubble oscillations. It is envisaged that the VSP will be shot from the rig and will take

place at the end of drilling operations. It will generally last for 12 hours during which it will be shot around 50 times

continuously for 6 hours. At present there are two likely source types which will be chosen by a contractor at a later

stage. During the VSP airgun operations:

PTS may occur in low frequency cetaceans if they remain within a distance of 30 m from VSP airgun activities

for a period of 1 hour. TTS may occur if they remain within 300 m from driving activities for a similar period.

PTS or TTS may occur in mid frequency cetaceans if they remain within close proximity (e.g. less than 10 m)

from VSP airgun activities for a period of 1 hour.

PTS may occur in phocid pinnipeds if they remain within a distance of 12 m from VSP airgun activities for a

period of 1 hour. TTS may occur if they remain within 122 m from driving activities for a similar period.

PTS may occur in otariid pinnipeds if they remain within a distance of 14 m from VSP airgun activities for a

period of 1 hour. TTS may occur if they remain within 143 m from driving activities for a similar period.

Table 7-8: Effects of marine noise on marine fauna

IMPACT DESCRIPTION: EFFECTS OF MARINE NOISE ON MARINE FAUNA

Predicted for project phase: Operation

Dimension Rating

PRE-MITIGATION

Duration Short Term (1) Consequence:

Slightly

detrimental

(-9)

Significance:

Low negative

(-27)

Extent Site (1)

Intensity x type

of impact Low Medium - negative (-6)

Probability Likely (3)

MITIGATION:

Employees must be provided with adequate Personal Protective Equipment (PPE).

The plant and all equipment must be properly maintained to avoid creation of unnecessary additional noise.

Noisy operations should, wherever possible run concurrently in order to minimise the duration of high noise levels .

Noise levels shall be monitored to comply with the relevant health and safety requirements.

All works that deviate from normal operating conditions shall be reported and actions initiated to mitigate against to prevent

recurrence of the incident.

VSP operations:

Undertake a 30-minute pre-start scan (prior to soft-starts) within the 3 km radius observation zone in order to confirm there

is no cetacean activity within 500 m of the source.

Ensure that observations “soft start” are planned :

─ Implement a “soft-start” procedure of a minimum of 20 minutes’ duration when initiating the VSP acoustic source. This

requires that the sound source be ramped from low to full power rather than initiated at full power, thus allowing a flight

response by marine fauna to outside the zone of injury or avoidance.

─ Commence “soft-start” procedure only once it has been confirmed by a suitably trained crew member during the 30-

minute pre start-up visual scan that there is no cetacean activity within 500 m of the source.

Where possible, sensitive receptors should be forewarned before noisy VSP operations commence.

Assign relevant staff for observation, distance estimation and reporting, to perform marine mammal observations and

notifications.

Maintain visual observations within the 500 m shut-down zone continuously during VSP operation to identify if there aren’t

any cetaceans present.

Shut down the acoustic source if a cetacean is sighted within 500 m shut-down zone until such time as the animal has

moved to a point more than 500 m from the source.

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IMPACT DESCRIPTION: EFFECTS OF MARINE NOISE ON MARINE FAUNA

Predicted for project phase: Operation

Dimension Rating

Ensure that during periods of low visibility (where the observation zone cannot be clearly viewed out to 3 km), including

night-time, the VSP source is only used if during the preceding 24-hour period:

─ there have not been three or more cetacean-instigated shut down situations, and

─ a two-hour period of continual observation was undertaken in good visibility (to the extent of the observation zone) and

no cetaceans were sighted.

POST-MITIGATION

Duration Short Term (1) Consequence:

Negligible

(-5)

Significance:

No impact

(-10)

Extent Site (1)

Intensity x type of impact

Low negative (-2)

Probability Possible (-2)

The use of soft start procedures and use of visual monitoring prior to start of source and delay if a marine mammal

is observed within a typical 500 m exclusion zone will allow time for marine mammals to move away from t he source

operations. Ensure that pre shot observation, soft start are planned for the VSP.

Provided that receptors are not located directed beneath the VSP source or within the main directivity of the source,

TTS may occur in fish if they remain within 26 m of VSP operations for a period of 1 hour.

Low level disturbance to fish may occur beyond 13 km. As described above, it is considered that the local

underwater sound environment would be dominated by sound from existing commercial and oil industry vessel

traffic and there would be a minimal relative increase to existing levels of disturbance on fish species.

7.2.5 Demobilisation and Infrastructure Abandonment

Once the wellhead has been installed, a BOP would be lowered to the seabed and installed onto the wellhead. The

BOP stack extends above the seabed into the water column, thereby providing a pillar of hard substrate in an area

of otherwise unconsolidated sediments. During initial cementing, excess cement emerges out of the top of the well

onto the cuttings pile or is discarded on the seabed, where it may set and remain in a pile to subsequently be

colonised by epifauna and attract fish and other mobile predators.

After the wells are abandoned, the wellhead would be left on the seafloor, thereby providing har d substrate in an

area of otherwise unconsolidated sediments. The availability of hard substrata on the seabed provides opportunity

for colonisation by sessile benthic organisms and provides shelter for demersal fish and mobile invertebrates

thereby potentially increasing the benthic biodiversity and biomass in the continental slope region.

The benthic fauna inhabiting unconsolidated sediments are expected to be relatively abundant, varying only with

sediment grain size, organic carbon content of the sediments and/or near-bottom oxygen concentrations. Epifauna

living on the sediment typically comprise urchins, burrowing anemones, molluscs, sea pens and sponges, many of

which are longer-lived and therefore more sensitive to disturbance.

The presence of the subsea infrastructure (e.g. wellheads and guide bases) would increase the amount of hard

substrate that is available for the colonisation of benthic organisms. This may increase biodiversity and biomass in

the vicinity of physical structures on the seabed.

Table 7-9: Demobilisation / abandonment of infrastructure

IMPACT DESCRIPTION: DEMOBILISATION / ABANDONM ENT OF INFRASTRUCTURE

Predicted for project phase: Demobilisation

Dimension Rating

PRE-MITIGATION

Duration Permanent (5) Consequence:

Slightly detrimental

(-8)

Significance:

Low negative

(-16)

Extent Footprint (1)

Intensity x type

of impact Low - negative (-2)

Probability Possible (2)

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IMPACT DESCRIPTION: DEMOBILISATION / ABANDONM ENT OF INFRASTRUCTURE

Predicted for project phase: Demobilisation

MITIGATION:

Seal the well by inserting cement plugs in the well bore.

Well integrity must be tested.

Remove all BOP infrastructure.

Notify the relevant authorities of the project closure.

Scan sea floor for dropped equipment and retrieve items where practicable and safe to do so.

Notify the relevant authorities where items could not be retrieved.

POST-MITIGATION

Duration Permanent (5) Consequence:

Slightly detrimental

(-8)

Significance:

Low negative

(-16)

Extent Footprint (1)

Intensity x type

of impact Low - negative (-2)

Probability Possible (2)

7.3 Impacts on the Social Environment

N O TE: THE SUB-SECTIONS SET O UT IN THE S ECTION BELOW SHOULD BE READ IN CONJUNCTION WITH THE IMPACT METHODOLOGY

HER EWITH A S AP P ENDIX B.3

The increase of surface area afforded by residual cement and abandoned wellheads is small and highly localised

and is likely to have an impact of low intensity on the benthic macrofauna. The duration of the impact would be

permanent. Overall the significance of this impact is considered to be of very low (neutral) significance.

The organisation and presentation of the full range of socio -economic impacts that are expected to arise because

of a proposed project or activity is challenging, for several reasons. First, potential impacts, and the elements that

combine to determine the socio-economic status of affected populations, are multi-dimensional and interrelated.

For example, insufficient access to services such as water, sanitation and health care is both a cause and an effect

of poverty. On the one hand, the lack of access to such services impacts negatively on health status, the

opportunity to acquire market-related skills and the amount of time available for productive activities. On the other

hand, poor people are often forced to live in areas where service delivery is limited or absent. Thus, if a project

increases the availability of services in an area, the ability of surrounding communities to take advantage of these

services may to some extent depend on their current socio -economic status. Second, the linkages between

various potential project impacts are complex and can be mutually reinforcing. For example, in-migration and

increased incomes can combine to put pressure on economies and infrastructure, as housing demand and

purchase power will increase. Impacts may also have both positive and negative dimensions. For example,

employment creation is an important project benefit, but it may also generate a context for negative impacts such

as social conflict and/or excessive in-migration. Finally, many socio-economic impacts cascade. For example, in-

migration is in itself an impact, but in turn may engender additional impacts, for example pressure on available

services such as housing and health services.

7.3.1 Employment creation during the mobilisation phase

The proposed project will require a small workforce to mobilise the drill rig and equipment and therefore has a small

potential to provide very limited direct employment to people within the local study area during the mobilisation

phase. It is expected that many of these positions will only last for a relatively short period, and will largely involve

highly skilled and semi-skilled positions, with limited employment opportunities for unskilled individuals. However,

the possible acquisition of new skills during the mobilisation period could make individuals more employable in the

future.

A large number of households within the study area face significant socio -economic challenges such as poverty;

unemployment and underdevelopment. Any project related employment therefore has the potential to improve the

livelihoods and income stability of future employees and their dependants, especially if employees are from socio -

economically depressed households. Whether unemployed and under-employed individuals within the study area

will be able to take up employment opportunities depends largely on their level of education, skill and work

experience. The demographic characteristics of the population in the local study area indicate that a large, relatively

uneducated, local labour pool is available. This suggests that, even though a large potential labour pool exists in the

study areas, a considerable proportion of this labour pool may not be adequately skilled to qualify for positions

requiring skilled labour. However, in recent years several oil and gas exploration projects have been undertaken

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within the region, which would have skilled some individuals, that if available can be considered for employment on

the Project.

The degree to which employment benefits of the projects will accrue to local communities further depends on the

following project-related factors:

The recruitment practices of the contractor appointed by TOTAL to assist with rig mobilisation, which in turn

may depend on the contractual requirements imposed by TOTAL on the contractor in terms of employment ;

and

The ease with which the construction contractor will be able to identify and recruit suitably skilled persons in

local communities, as very stringent standards are set for TOTAL’s contactors and the skill level required to

participate in any employment created.

In addition to creating job opportunities related to construction, the projects may also lead to indirect employment

creation. This could involve formal employment (e.g. upgrade of onshore facilities, refuse removal from logistic base,

catering and security services) or employment in the informal sector (for instance local residents can establish food

stalls for the convenience of mobilisation workforce).

Employment on the projects will also have some degree of multiplier effect on the local economy, and that increased

spending power due to wages and salaries earned will benefit local businesses, suppliers of goods and

commodities, etc. This multiplier effect will be further enhanced by capital and opera tional expenditure by the

projects – e.g. through the local procurement of goods, materials and services. The creation of employment

opportunities during the mobilisation phase of the project can therefore be seen as a positive impact on the

benefitting individuals and their dependants.

Table 7-10: Employment creation

IMPACT DESCRIPTION: EMPLOYMENT CREATION

Predicted for project phase: Mobilisation

Dimension Rating

PRE-MITIGATION

Duration Short term (2)

Consequence: Negligible

(5)

Significance: Negligible -

positive

(20)

Extent Limited (2)

Intensity type of

impact Very low - positive (1)

Probability Probable (4)

MITIGATION

Explore whether a skills database is available from government and Oil & Gas Company's that recently completed similar

activities in the area;

Maximise and monitor local recruitment & procurement (incl. using local skills and small-business databases);

Tender criteria should require training and skills development of the con tractor workforce by the contractor

Promote skills development and training for workforce;

Procurement of materials, goods and services from local suppliers where feasible; and

Encourage indirect employment creation in the informal sector where feasible.

POST-MITIGATION

Duration Short term (2)

Consequence: Slightly beneficial

(8)

Significance:

Minor - positive (40)

Extent Limited (2)

Intensity type of

impact Moderately high - positive (4)

Probability Likely (5)

7.3.2 Multiplier effects on the local economy

Considering the relatively depressed economic base of the towns where the Project would be based, it is likely that

the Project will result in some, albeit limited, economic benefits through direct and multiplier effects stimulated by

capital expenditure during the mobilisation and exploration/drilling phases.

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Establishment of onshore logistics base and mobilisation would increase, to a limited degree, the demand for of

goods and services, and as a result will stimulate and/or sustain growth within the local service sectors; which be

relatively well established, considering previous oil and gas exploration campaigns undertaken in the area. This

economic environment could generate some opportunities for small to medium businesses; provided they are

formalised and able to meet TOTAL’s procurement requirements. A considerable part of the Project’s needs will,

however, be highly technical and unlikely to be found within the site-specific or local study areas. For these needs,

TOTAL may procure from businesses elsewhere in region or in neighbouring countries, such as South Africa. Such

procurement will expose a wider area to the Project’s economic stimulus, albeit to a diluted degree.

Local and regional procurement spend will enhance the positive economic impact of the project to a certain degree,

as the revenue accruing to enterprises will produce limited, but beneficial downstream impacts on the local

economy, which is currently in decline. Given that a significant proportion of moneys derived from wages earned

would likely be spent locally, it is expected to create substantial flows of revenue within surrounding business

operators, thus acting as a catalyst for growth in the economy.

Table 7-11: Multiplier effects on the local economy

IMPACT D ESCRIPTION : MULTIPLIER EFFECTS ON TH E LOCAL ECON OMY

Pre d ic te d for p ro je c t p h ase : Mobilisation Operation

Dim e n sion Ratin g

PRE-MITIGATION

Duration Project Life (5) Consequence:

Moderately beneficial

(10)

Significance:

Negligible - positive

(30)

Extent Regional (4)

Intensity type of

impact Very low - positive (1)

Probability Unlikely (3)

MITIGA TIO N :

As for maximising employment benefits:

Give preference first to capable local service providers when appropriate;

Monitoring of sub-contractors’ procurement;

Development of a register of local service providers in consultation with the Namibian Government and other oil and gas

companies (in preparation for future activities – which are dependent on the exploration results); and

Local procurement objectives should be formalised in TOTAL's procurement policy for the Project.

PO ST -MITIGA TIO N

Duration Project Life (5) Consequence:

Moderately beneficial

(12)

Significance:

Minor - positive

(72)

Extent Regional (4)

Intensity type of

impact Moderate - positive (3)

Probability Highly probable (6)

7.3.3 Fiscal impact

Government will accrue revenue, which will constitute a beneficial social impact as it will increase the amount of

money Government will have at its disposal to construct and maintain infrastructure, implement development

projects and render other services to its constituencies. TOTAL will be liable for an annual petroleum licence are a

rental charge for exploration. During exploration, royalties would not apply and, as exploration does not directly

generate income, neither would direct taxes on company incomes / profits apply. There would, however, be indirect

benefits to the fiscus. These are likely to be relatively modest and should primarily take the form of Value Added Tax

(VAT) and income taxes levied on direct and indirect project expenditure in Namibia discussed above. The project

would have a necessarily high import content given its specialised nature. However, it would also be associated with

moderate amounts of local expenditure leading to a limited but positive impact on the balance of payments.

Whether this income translates into benefits for the Project’s host communities depends on how Government

decide to apply it. Current indications are that the overall positive impact associated on macro-economic variables

is considered to be of very low significance.

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Table 7-12: Fiscal impact

IMPACT DESCRIPTION: FISCAL IMPACT

Pre d ic te d for p ro je c t p h ase : Mobilisation Operation Demobilisation

Dim e n sion Ratin g

PRE -MITIGATION

Duration Project Life (5) Consequence: Moderately beneficial

(13) Significance:

Moderate -

positive

(78)

Extent National (6)

Intensity type of impact

Low - positive (2)

Probability Highly probable (6)

MITIGATION:

Private companies such as TOTAL generally have limited to no input in directing Government expenditure of revenue accrue from private sector projects.

Consequently, no measures to enhance the fiscal impact of the Project can be included as part of the ESIA.

PO ST-MITIGATION

Duration Project Life (5) Consequence:

Moderately beneficial

(13)

Significance: Moderate -

positive (78)

Extent National (6)

Intensity type of impact Low - positive (2)

Probability Highly probable (6)

7.3.4 Presence of project workforce

Despite the measures for maximising local employment recommended, it is still very likely that a substantial

proportion of the workforce will originate from outside the local area. The presence of non-local workers may have

a variety of social consequences:

It is possible that conflict might arise between the newcomers and local residents. One possible reason for

such conflict would be the perception among locals that the outsiders are taking up jobs that could have gone

to unemployed members of the local community. If any outsiders instigate sexual relationships with wives,

daughters or girlfriends of locals, this would certainly exacerbate the problem.

Generally, the workforce employed for these activities tend to be predominantly young, male, and mobile

population. This population range is usually associated with promiscuous sexual activities. Such behaviour

poses the risk that the prevalence of HIV/AIDS, tuberculosis (TB) and other communicable diseases in the local

study could increase. Other social pathologies associated with a transitory population with disposable income

such as drug/ alcohol abuse, abuse of women, etc. may also increase. Such problems, especially HIV/AIDS,

alcohol and gender abuse, are already prevalent within the local study area.

Table 7-13: Presence of project workforce

IMPACT D ESCRIPTION : PRESEN CE OF PROJECT WORKFORCE

Pre d ic te d for p ro je c t p h ase : Mobilisation

Dim e n sion Ratin g

PRE - MITIGA TIO N

Duration Short term (2) Consequence:

Slightly detrimental

(-8)

Significance:

Minor -

negative

(-40)

Extent Limited (2)

Intensity type of

impact Moderately high - negative (-4)

Probability Likely (5)

MITIGA TIO N:

In order to reduce the risk of conflict or competition between locals and newcomers, it is recommended that the

recruitment policy used to employ people on the Project must be fair and transparent.

Recommended measures to combat HIV/AIDS and other social ills include the following:

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IMPACT D ESCRIPTION : PRESEN CE OF PROJECT WORKFORCE

Pre d ic te d for p ro je c t p h ase : Mobilisation

Implementing HIV/AIDS, alcohol abuse, drug abuse, and gender-based violence prevention and awareness

campaigns among the workforce and relevant communities;

The contractor should make HIV/AIDS and Sexually Transmitted Diseases (STDs) awareness and prevention

programmes a condition of contract for all suppliers and sub-contractors; and

If appropriate medical facilities are available, consider introducing a voluntary counselling and testing (VCT)

programme through all the phases of the project and continued during operations.

POST-MITIGATION

Duration Short term (2) Consequence:

Slightly detrimental

(-6)

Significance:

Negligible -

negative

(-24)

Extent Limited (2)

Intensity type of

impact Low - negative (-2)

Probability Probable (4)

7.3.5 Physical Intrusion and Nuisance Impact

The impacts of these activities on the immediate physical environment include:

Increased marine traffic and disruption of shipping routes;

Noise generated through project activities;

Unplanned events: oil spills and increased risk to personal safety; and

Visual intrusion by the mobilisation activities and project infrastructure, which may impact negatively on the

aesthetic character of the coastal and oceanic setting.

The quantitative assessment of such impacts falls outside the scope of an SIA (being the purview of other specialist

disciplines). Nevertheless, it is necessary for a social assessment to take cognisance of such impacts, since all of

them have socio-economic implications especially in terms of their combined effect on the human environment .

For instance, increased traffic, noise, safety hazards and visual degradation may all detract from an area’s sense of

place. This, in turn, could have a negative effect on people’s quality of life, and may affect an area’s a ttractiveness

as a tourist destination (which would constitute an indirect socio -economic impact).

The impacts mentioned above are assessed in the ESIA and where necessary specialist investigations, where it is

concluded that none of these impacts are likely to be significant. The low intensity of these impacts is ascribed to

the fact that the majority of project activity is situated some distance away from the closest towns, while the

immediately surrounding coastal areas and areas use for recreational and residential purposes will likely not be

exposed to intense Project activity.

Table 7-14: Physical intrusion and nuisance impacts

IMPACT DESCRIPTION: PHYSICAL INTRUSION AND NUISANCE IMPACTS

Pre dicted for project phase: Mobilisation Operation Demobilising

Dim e n sion Ratin g

PRE -MITIGATION

Duration Medium term (3) Consequence:

Slightly detrimental

(-9)

Significance: Minor - negative

(-54)

Extent Limited (2)

Intensity type of impact Moderately high - negative (-4)

Probability Highly probable (6)

MITIGATION:

Environmental mitigation measures as outlined in the ESIA.

Stakeholder engagement planning, community liaison and continuous communication.

PO ST-MITIGATION

Duration Medium term (3)

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IMPACT DESCRIPTION: PHYSICAL INTRUSION AND NUISANCE IMPACTS

Pre dicted for project phase: Mobilisation Operation Demobilising

Extent Limited (2) Consequence: Slightly detrimental

(-6)

Significance: Negligible -

negative

(-30)

Intensity type of impact

Very low - negative (-1)

Probability Likely (5)

7.3.6 Impacts on the fishing industry

Fishing industry contributes to the economy of several of Namibia’s coastal towns, including Lüderitz. The project’s

impact on fisheries and recreational fishing have not been determined; however, if activities result in a significant

negative impact on the feasibility of the fishing industry it would likely impact a considerable number of households

that are dependent on the sector for their livelihoods (Barbour et al.,2017).

Fishery studies undertaken for similar scenarios established that it is likely for planned oil and gas exploration

activities to have insignificant impacts on the fishing industry, if appropriate mitigation is applied; however,

exploration activities could in the case of unplanned events such as a blow out from drilling and associated activities

result in a low to medium impacts despite mitigation measures.

Table 7-15: Impact on the fishing industry

IMPACT D ESCRIPTION : IMPACT ON TH E FISH IN G IN D USTRY

Predicted for project phase: Mobilisation Operation Demobilisation

Dimension Rating

PRE - MITIGA TIO N

Duration Beyond project life (6) Consequence:

Highly detrimental

(-15)

Significance: Moderate -

negative

(-75)

Extent Local (3)

Intensity type of

impact Very high - negative (-6)

Probability Likely (5)

MITIGA TIO N:

In the event of successful exploration and planned development, TOTAL should commission a fishery impact assessment to explore the probability of project activities could (a.) displace commercial and subsistence fishing activities and any related

livelihood impacts, (b.) restrict or disrupt access to fishing areas and (c.) influence fishing populations.

PO ST -MITIGA TIO N

Duration Beyond project life (6) Consequence: Moderately

detrimental

(-13)

Significance: Minor - negative

(-65)

Extent Local (3)

Intensity type of

impact Moderately high - negative (-4)

Probability Likely (5)

7.3.7 Impacts on Tourism

The ESIA established that although there will be noise impacts, that these could be mitigated; it is therefore unlikely

that these factors would significantly detract from the sense of place of areas such as Lüderitz, especially

considering other industrial activities in the area.

Sea-based tourism activities in the area tend to be focused on short boat trips/cruises leaving from Lüderitz and

Walvis Bay harbours as well as recreational fishing trips. The majority of boats trips are within 10 km of the coastline,

which ferry people to nearby islands, including Halifax Island. These activities along with recreational fishing are not

likely to be affected, or would be minimally affected, but only in the case of a large-scale unplanned event such as

an oil spill (Barbour, van Zyl, & Kinghorn, 2017). They are more likely to be impacted on by an unlikely accidenta l

surface spill from one of the supply vessels. Major passenger cruise liners pass through deep ocean areas that

could be affected by spills. However, with minor adjustments to the route, those travelling between South Africa and

Namibia or between Namibia and countries to the north, should be able to avoid the surface spill areas. In the

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absence of an unplanned event such as an oil spill, it is unlikely that the project would have a significant negative

impact on Tourism.

Table 7-16: Impact on tourism

IMPACT D ESCRIPTION : IMPACT ON TOURISM

Pre d ic te d for p ro je c t p h ase : Mobilisation Operation Demobilisation

Dim e n sion Ratin g

PRE - MITIGA TIO N

Duration Medium term (3) Consequence:

Slightly detrimental

(-8)

Significance:

Negligible - negative

(-24)

Extent Local (3)

Intensity type of

impact Low - negative (-2)

Probability Unlikely (3)

MITIGA TIO N:

Because of the low significance of this impact, mitigation measures are not applicable

PO ST -MITIGA TIO N

Duration Medium term (3) Consequence:

Slightly detrimental

(-8)

Significance: Negligible -

negative

(-24)

Extent Local (3)

Intensity type of

impact Low - negative (-2)

Probability Unlikely (3)

7.3.8 Opposition because of perceived negative impacts

This impact differs from the preceding ones in that it deals with potential impact of community and stakeholder

attitudes and actions on the project, rather than impacts of the project on communities. The relevance of such

impacts in the context of this report stems from the fact that, as with the other impacts discussed above,

appropriate mitigation will be required – the difference being that, in this instance, the mitigation measures would be

aimed at changing aspects of stakeholder perceptions and behaviour rather than changing aspects of the project’s

design and implementation.

The impact assessed here pertains to the fact that perceptions regarding potential negative project impacts

(whether these be accurate or not) could intensify community opposition to the proposed project – which, in turn,

could potentially increase active community resistance to project plans.

Strained stakeholder relations could have a very detrimental impact on the successful implementation of a project:

if a company’s affected parties view the operation with suspicion or disdain, they have t he power not only to delay

the environmental authorisation process through appeals; they can also damage the company’s public image

through bad publicity. Acrimonious stakeholder and community relations often give rise to active social mobilisation

against a project or to costly litigation.

Despite TOTAL’s best intentions to fostering positive community relations, there is considerable risk that one or

more of the negative scenarios sketched above could materialise during project implementation. This risk stems

primarily from the fact that the stakeholders that will be affected are sensitive about a.) practices of Oil and Gas

companies is general and b.) the potential impact on fishery and marine biodiversity. This sensitivity poses a risk for

the proposed project. These concerns and attitudes should not be ignored and their potential to solidify into active

community opposition to the project should not be underestimated.

Table 7-17: Opposition because of perceived negative impacts

IMPACT D ESCRIPTION : OPPOSITION BECAUSE OF PERCEIVED N EGATIVE IMPACTS

Pre d ic te d for p ro je c t p h ase : Mobilisation Operation

Dimension Rating

PRE - MITIGA TIO N

Duration Project Life (5)

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IMPACT D ESCRIPTION : OPPOSITION BECAUSE OF PERCEIVED N EGATIVE IMPACTS

Pre d ic te d for p ro je c t p h ase : Mobilisation Operation

Extent Local (3) Consequence: Moderately detrimental

(-12)

Significance:

Minor - negative

(-48)

Intensity type of impact

Moderately high - negative (-4)

Probability Probable (4)

MITIGA TIO N:

Communicate commitments regarding employment and procurement

Transparency regarding employment practices

Presentation of EIA findings in clear and understandable manner

Monitor community attitudes to anticipate/prevent active opposition

Appointment of a Community Liaison Officer (CLO) to enhance communication

PO ST -MITIGA TIO N

Duration Long term (4) Consequence:

Slightly detrimental

(-8)

Significance: Negligible -

negative (-32)

Extent Local (3)

Intensity type of impact

Very low - negative (-1)

Probability Probable (4)

7.3.9 Employment creation during the operational phase

It is expected that a limited number of employees will be required during the drilling and analysis phase. The majority

of this workforce will be skilled or semi-skilled. It is assumed that TOTAL has stated its preference that persons from

the local area or region should be appointed for these positions, if possible. However, it is likely that it might not be

possible to recruit adequately skilled persons from surrounding areas and might therefore be sourced from other

regions or from outside Namibia.

Even if a small number of local people are appointed during the drilling phase, the projects will still have certain

indirect benefits for the local economy. These would include a degree of indirect job creation for instance, through

the appointment of a local service providers for catering, security, logistics and maintenance services to the

onshore base and offshore operations. An additional economic benefit would be multiplier effects associated with

local procurement and increased local spending power.

Table 7-18: Employment creation during operation

IMPACT DESCRIPTION: EMPLOYMENT CREATION DURING OPERATION

Pre d ic te d for p ro je c t p h ase : Operation Demobilisation

Dim e n sion Ratin g

PRE -MITIGATION

Duration Project Life (5) Consequence:

Moderately beneficial

(10)

Significance: Negligible -

positive (30)

Extent Regional (4)

Intensity type of impact

Very low - positive (1)

Probability Unlikely (3)

Mitigation

Procurement of materials, goods and services from local suppliers, where possible

Maximise and monitor local recruitment and procurement (incl. using local skills databases)

PO ST-MITIGATION

Duration Project Life (5) Consequence:

Moderately beneficial

(12)

Significance: Minor - positive

(60)

Extent Regional (4)

Intensity type of impact

Moderate - positive (3)

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IMPACT DESCRIPTION: EMPLOYMENT CREATION DURING OPERATION

Pre d ic te d for p ro je c t p h ase : Operation Demobilisation

Probability Likely (5)

7.3.10 Change in employment requirements during demobilisation

Decommissioning may create a temporary spike on the project’s workforce requirements as the phase will involve

capping and suspending/abandoning wells and rig demobilisation etc., The net effect of decommissioning on

employment will however be negative unless it is possible to secure jobs for all the former personnel for other

exploration activities or project phases following exploration. If this is not possible, and job losses are unavoidable,

this would have social impacts in terms of psychological stress, loss of income, etc.

Table 7-19: Change in employment requirements

IMPACT DESCRIPTION: CHANGE IN EMPLOYMENT REQUIREMENTS

Pre dicted for project phase: Demobilisation

Dim e n sion Ratin g

PRE -MITIGATION

Duration Short term (2) Consequence:

Slightly detrimental

(-9)

Significance: Minor - negative

(-45)

Extent Local (3)

Intensity type of impact

Moderately high - negative (-4)

Probability Likely (5)

MITIGATION:

Maximise use of local labour in decommissioning activities

Adequate notification of pending decommissioning

Provide staff with references so that they can pursue work with other companies

If feasible, assist staff in finding employment at other operations

PO ST-MITIGATION

Duration Short term (2) Consequence:

Slightly detrimental

(-7)

Significance: Negligible -

negative

(-35)

Extent Local (3)

Intensity type of impact Low - negative (-2)

Probability Likely (5)

7.4 Summary of Impacts

A summary of the biophysical impacts (Table 7-20) and social impacts (Table 7-21) is presented below.

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Table 7-20: Summary of Physical and Biophysical Impacts

Impact

Pre-mitigation: Post Mitigation

Duration Extent Intensity Consequence Probability Intensity Duration Extent Intensity Consequence Probability Intensity

Physiological

effects of air emissions on

marine fauna

Short Term Site Low Medium - negative

Slightly detrimental Likely Low negative Short Term Site Low - negative

Negligible Likely Low negative

Greenhouse gas emissions on

global warming

Short Term Site Low Medium

- negative Slightly detrimental Likely Low negative Short Term Site

Low -

negative Negligible Possible No Impact

Reduction of water quality

due to normal discharge to

sea

Short Term Site Low - negative

Negligible Likely Low negative Short Term Site Low - negative

Negligible Possible No Impact

Reduction of water quality

due to ballast discharge to sea

Short to medium

Term

National Medium high

- negative Highly detrimental Possible Low negative Short Term Regional

Low -

negative Slightly detrimental Possible Low negative

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Impact

Pre-mitigation: Post Mitigation

Duration Extent Intensity Consequence Probability Intensity Duration Extent Intensity Consequence Probability Intensity

Effect of normal discharge on

marine fauna

Short Term Site Low -

negative Negligible Likely Low negative Short Term Site

Low -

negative Negligible Possible No Impact

Reduction of water quality

due to cuttings, drilling fluid and

cement

Short Term Site Medium - negative

Slightly detrimental Likely Low negative Short Term Site Low - negative

Negligible Possible No Impact

Smothering of

seabed due to discharge of

cutting, drilling fluid and cement

Long Term Footprint Low -

negative Slightly detrimental Highly likely Low negative

Medium

Term Footprint

Low -

negative Slightly detrimental Highly likely Low negative

Reduction of water quality

due to cuttings, drilling fluid and

cement

Short Term Site Medium - negative

Slightly detrimental Likely Low negative Short Term Site Low - negative

Negligible Possible No Impact

Smothering of

seabed due to discharge of

cutting, drilling fluid and cement

Long Term Footprint Low - negative

Slightly detrimental Highly likely Low negative Medium Term

Footprint Low - negative

Slightly detrimental Highly likely Low negative

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Impact

Pre-mitigation: Post Mitigation

Duration Extent Intensity Consequence Probability Intensity Duration Extent Intensity Consequence Probability Intensity

Toxicity to

marine fauna due to discharge

of cutting, drilling fluid and

cement

Short Term Site Medium -

negative Slightly detrimental Likely Low negative Short Term Site

Low -

negative Negligible Possible No Impact

Reduction in water quality

due to discharge of cutting,

drilling fluid and cement

Short Term Site Low - negative

Negligible Likely Low negative Short Term Site Low - negative

Negligible Possible No Impact

Elimination or

disturbance of benthic fauna

due to seabed disturbance

Short Term Site Medium -

negative Slightly detrimental Definite Medium negative Short Term Site

Low -

negative Negligible Highly likely Low negative

Reduction of water quality due to seabed

disturbance

Short Term Site Low - negative

Negligible Likely Low negative Short Term Site Low - negative

Negligible Possible No Impact

Effects of marine noise on

marine fauna

Short Term Site Medium - negative

Slightly detrimental Likely Low negative Short Term Site Low - negative

Negligible Possible No Impact

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Impact

Pre-mitigation: Post Mitigation

Duration Extent Intensity Consequence Probability Intensity Duration Extent Intensity Consequence Probability Intensity

Demobilisation / abandonment of

infrastructure

Permanent Footprint Low -

negative Slightly detrimental Possible Low negative Permanent Footprint

Low -

negative Slightly detrimental Possible Low negative

Table 7-21: Summary of Social Impacts

Impact

Pre-mitigation: Post-mitigation:

Duration Extent Intensity Consequence Probability Significance Duration Extent Intensity Consequence Probability Significance

Employment creation

Short term Limited Very low - positive

Negligible Probable Negligible - positive Short term Limited Moderately high -

positive

Slightly beneficial Likely Minor - positive

Multiplier effects on the

local economy

Project Life Regional Very low -

positive Moderately beneficial Unlikely Negligible - positive Project Life Regional

Moderate -

positive Moderately beneficial

Highly

probable Minor - positive

Fiscal impact Project Life National Low -

positive Moderately beneficial

Highly

probable Moderate - positive Project Life National

Low -

positive Moderately beneficial

Highly

probable Moderate - positive

Presence of

Project workforce

Short term Limited

Moderately

high - negative

Slightly detrimental Likely Minor - negative Short term Limited Low - negative

Slightly detrimental Probable Negligible - negative

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Impact

Pre-mitigation: Post-mitigation:

Duration Extent Intensity Consequence Probability Significance Duration Extent Intensity Consequence Probability Significance

Physical

Intrusion and nuisance

impacts

Medium term

Limited Moderately high -

negative

Slightly detrimental Highly probable

Minor - negative Medium term

Limited Very low - negative

Slightly detrimental Likely Negligible - negative

Impact on the fishing industry

Beyond project life

Local Very high - negative

Highly detrimental Likely Moderate - negative Beyond project life

Local Moderately high -

negative

Moderately detrimental Likely Minor - negative

Impact on Tourism

Medium term

Local Low - negative

Slightly detrimental Unlikely Negligible - negative Medium term

Local Low - negative

Slightly detrimental Unlikely Negligible - negative

Opposition

because of perceived

negative impacts

Project Life Local Moderately high -

negative

Moderately detrimental Probable Minor - negative Long term Local Very low - negative

Slightly detrimental Probable Negligible - negative

Employment

creation during operation

Project Life Regional Very low -

positive Moderately beneficial Unlikely Negligible - positive Project Life Regional

Moderate -

positive Moderately beneficial Likely Minor - positive

Change in

employment requirements

Short term Local

Moderately

high - negative

Slightly detrimental Likely Minor - negative Short term Local Low -

negative Slightly detrimental Likely Negligible - negative

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7.5 Cumulative Impacts

The International Finance Corporation (IFC) defines cumulative impacts as ‘impacts that result from the incrementa l

impact, on areas or resources used or directly impact by the project, from other existing, planned or reasonably

defined developments at the time the risks and impacts identification process is conducted’. Significant cumulative

impacts can result from individually minor but collectively significant actions taking place over a period of time. Thus

existing, proposed and possible future activities have and will continue to have a cumulative impact on the

biophysical and socio-economic environment in the Project area.

Cumulative effects are difficult to predict as they are the result of complex interactions between multiple projects

or activities. This difficulty is compounded by the fact that details of future development are largely unknown; there

are currently no other known drilling operations proposed at the same time.

Until oil and gas discoveries are made, it is difficult to predict whether and when any future oil and gas activity might

occur, or the type, location, duration or level of those potential activities. In addition, methods to explore for, develop,

produce, and transport petroleum resources would vary depending on the area, operator and discovery.

Mitigation and management of cumulative impacts often require cooperation with other stakeholders or at a

government level and are frequently beyond the ability of a single project development to control solely. In line with

international good practice, mitigation should be commensurate with the level of contribution to the cumulative

impact by TOTAL.

7.6 Unplanned Events

Offshore drilling operations carry an inherent risk of oil entering the marine environment because of an unplanned

oil spill event. Depending on the location and severity of an incident, oil could reach the coast. Reservoir

hydrocarbons, of which the exact composition is unknown, are a possible source of oil. Other possible oil sources

include; various oil derived materials stored and used in bulk on board the drilling unit and support vessels. The most

relevant of these materials are diesel or marine gas oil, lubricating oils and hydraulic oils.

It is important to understand the main risks of oil spills associated with exploration drilling and the consequences if

any spills were to occur. Identifying the consequence of a spill requires understanding of what is likely to happen to

the oil in the marine environment.

It was found that should an oil spill occur adjacent to the Project area, such a spill would not reach the coast or any

conservation areas (SLR Environmental Consulting, 2017). Oil is predicted to travel in a north-westerly direction

away from the coast and thus no oil is predicted to reach the shoreline. As such, it is assumed that as Block 2913B

is directly adjacent to the area studies in the SLR Environmental Consulting (2017) study, the same assumption can

be made.

However, it is recommended that, prior to exploration activities commence, TOTAL develops an oil spill contingency

plan.

In addition, the following management measures are to be implemented:

Engineer wells according to best practices (BOP, etc) .

Develop and implement an OSCP that summarises reactionary measures in the unlikely event of a subsea

release.

Develop and implement a SOPEP that summarises the reactionary measures in the event of on-board oil spills.

Develop and implement a refuelling procedure for bunkering.

Oil spill response training must be implemented.

Ensure all staff receive training on handling and storage of liquid hazardous materials .

Where options exist for variation in hazardous chemical products, the product with the lowest toxicity mus t

always be selected.

Ensure all liquid hazardous substances are stored within secondary containment.

Ensure all liquid hazardous substances are appropriately labelled and that the relevant MSDSs for their safe

use are kept on record.

All hazardous materials containment areas must be regularly inspected.

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Suitable firefighting equipment must be stored in close proximity and all staff must be made aware of the

dangers of burning chemicals/smoke inhalation.

Ensure drainage water passes though oil screening processes in order to remove oils prior to discharge.

Alternatively slop oil unit can be used to lower the oil content acceptable parts per million (PPM) volumes.

All staff are to be provided with appropriate PPE.

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8. Conclusion

The proposed Project would result in temporary and localised impacts on marine fauna and flora as well as on water

quality, but it is considered to be small and short-term under normal operating conditions. The area of interest is far

removed from the conservation area, the shore, and other sensitive receptors (e.g. key faunal breeding / feeding

areas, bird or seal colonies, and nursery areas for commercial fish stocks).

Benthic communities in the area of interest are relatively ubiquitous, comprising fast -growing species that are able

to rapidly recruit into disturbed areas; thus being less susceptible to the effects of smothering. The disturbance of

benthic communities within the drill cuttings deposition footprint is considered negligible in relation to the available

area of similar habitat on and off the edge of the continental shelf in the Atlantic Offshore Bioregion. The potential

impact on the benthic fauna is considered to be localised and of short -term duration.

Government will accrue revenue, which will constitute a beneficial social impact by virtue of the fact that it will

increase the amount of money Government will have at its disposal to construct and maintain infrastructure,

implement development projects and render other services to its constituencies. TOTAL will be liable for an annual

petroleum licence area rental charge for exploration, which will increase annually During exploration, royalties would

not apply and, as exploration does not directly generate income, neither would direct taxes on company incomes /

profits apply. There would, however, be indirect benefits to the fiscus. These are likely to be relatively modest and

should primarily take the form of Value Added Tax and income taxes levied on direct and indirect project expenditur e

in Namibia. The Project would have a necessarily high import content given its specialised nature. However, it would

also be associated with moderate amounts of local expenditure leading to a limited but positive impact on the

balance of payments.

Considering the relatively depressed economic base of towns where the Project would be based, it is likely that the

Project will result in some, albeit limited, economic benefits through direct and multiplier effects stimulated by capital

expenditure during the mobilisation and exploration/drilling phases.

The proposed Project will require a workforce to mobilise the drill rig and equipment and therefore has the potential

to provide limited direct employment to people within the local study area during the mobilisation phase. It is

expected that many of these positions will only last for a relatively short period, and will largely involve skilled and

semi-skilled positions, with limited employment opportunities for unskilled individuals. However, the acquisition of

new skills during the mobilisation period could make individuals more employable in the future. And during the

drilling/exploration phase?

The fishing industry contributes to the economy of several of Namibia’s coastal towns, including Lüderitz. Fishery

studies undertaken for similar scenarios established that it is likely for planned oil and gas exploration activities to

have insignificant impacts on the fishing industry, if appropriate mitigation is applied; however, exploration activities

could in the case of unplanned events such as a blow out from drilling and associated activities result in a low to

medium impacts despite mitigation measures. However, if activities result in a significant negative impacts on the

feasibility of the fishing industry it would likely impact a considerable number of households that are dependent on

the sector for their livelihoods. Fishery studies undertaken for similar scenarios established that it is unlikely for

planned oil and gas exploration activities to have significant impacts on the fishing industry, if appropriate mitigation

is applied; however, exploration activities could in the case of unplanned events such as a blow out from drilling and

associated activities result in a low to medium impacts despite mitigation measures.

The most significant environmental threat from offshore drilling operations is the risk of a major spill of crude oil

occurring either from a blow-out or loss of well control, which is highly unlikely with the implementation of all the

Project controls.

Offshore drilling operations carry an inherent risk of oil entering the marine environment because of an unplanned

oil spill event. Depending on the location and severity of an incident, oil could reach the coast. Reservoir

hydrocarbons, of which the exact composition is unknown, are a possible source of oil.

It was found that should an oil spill occur adjacent to the Project area, such a spill would not reach the coast or any

conservation areas (SLR Environmental Consulting, 2017), furthermore TOTAL’s early modelling (to support the

OSCP development) draws the same conclusion. Oil is predicted to travel in a north-westerly direction away from

the coast and thus no oil is predicted to reach the shoreline. As such, it is assumed that as Block 2913B is directly

adjacent to the area studied in the SLR Environmental Consulting (2017) study, the same assumption can be made.

However, it is recommended that, prior to exploration activities commence, TOTAL develops an oil spill management

and rehabilitation plan.

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Based on the findings of this ESIA, AECOM conclude that the generally low significant impacts with mitigation

associated with normal operations should support a positive decision and the issuing of an ECC for the proposed

Project.

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Appendix A : Environmental Management Plan

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Appendix B : Specialist Studies

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B.1 Marine Noise Modelling

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B.2 Environmental Baseline Study

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B.3 Social Impact Assessment

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Appendix C : Stakeholder Database

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Appendix D : Scoping and ESIA Stakeholder Consultation

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D.1 Authority Meeting Attendance Registers

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D.2 Site Notices

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D.3 Background Information Document

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D.4 Announcement Letters

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D.5 FGM Attendance Registers and Minutes

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D.6 Public Open Day Attendance Registers, Minutes and Information

Presented

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D.7 Draft ESIA Public Open Day Notices

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Appendix E : Comments and Response Report

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Appendix F : Impact / Activity Screening Results

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Project Phase Project Activities Physical

Environment

Biophysical Environment Social Environment

Wa

ter

Qu

alit

y an

d N

ois

e

Air

Qua

lity

and

No

ise

Se

ab

ed

Se

dim

ent

s

Fis

h a

nd

Pla

nkt

on

Be

nth

ic C

om

mu

niti

es

Av

i-fa

una

(Bird

s)

Ma

rin

e M

amm

als

Se

ab

ed

Fe

atu

res

Ne

ars

ho

re a

nd

Sh

ore

Are

as

Pro

tec

ted

Are

as

Fis

hin

g

Ma

rin

e T

raff

ic

Pu

blic

He

alth

an

d S

afe

ty

Se

rvic

e D

eliv

ery

Hu

man

Se

ttle

men

ts

Em

plo

ymen

t an

d In

co

me

Mob ilisation Transit of drilling unit and support vessels

Discharge of ballast water

Accommodation rental

Onshore base rental

Local Service providers

Procurement of equipment and material

Seabed survey

O p eration Presence and operation of drilling unit and

support vessels

Operation of helicopters

Drilling of wells

Discharge of drill cuttings and excess cement

Plug well with cement

De mobilisation Abandoned wellheads on seafloor

Demobilisation of drilling unit and support vessels from drill site

Colour Key: No interaction

Minor interaction

Moderate / major interaction

Positive interaction

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Phindile Mashau

Environmental Scientist

T: +27 12 421 3894

E: [email protected]

AECOM SA (Pty) Ltd

263A West Avenue

Centurion

Tshwane

0157 South Africa

T: +27(0) 12 421 3500

F: +27 (0)12 421 3501

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