prepared by: prepared for: march 2015 · • small dual band antenna system: kathrein 742226 •...

Environmental Scoping Report and Management Plan

2015

MACRO BTS AT SUN KARROS, DAAN VILJOEN NATIONAL PARK PREPARED BY: PREPARED FOR:

March 2015

ii

Proposed Construction of a Macro BTS site at Sun Karros, Daan Viljoen National Park

Draft Scoping Report – Public Review

March 2015

COPYRIGHT © ENVIRO DYNAMICS, 2015. ALL RIGHTS RESERVED

PROJECT NAME Environmental Scoping Report for the proposed construction of a macro BTS site at Sun Karros, Daan Viljoen National Park

STAGE OF REPORT Draft Environmental Scoping Report for public review

CLIENT Mobile Telecommunication Company (MTC)

Enquiries: Morne Weitz

Tel: (061) 280 2634

E-Mail: [email protected]

LEAD CONSULTANT Enviro Dynamics

Enquiries: C.L Harker

Tel: (061) 223-336

E-Mail: [email protected]

DATE OF RELEASE March 2015

AUTHOR Lester Harker, Eloise Carstens, Eddy Kuliwoye,

Internal Reviewer: Norman Van Zyl

mailto:[email protected]

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DECLARATION

I hereby declare that I do:

(a) have knowledge of and experience in conducting assessments, including knowledge of the Act, these regulations and guidelines that have relevance to the proposed activity;

(b) perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;

(c) comply with the Act, these regulations, guidelines and other applicable laws.

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

reasonably has or may have the potential of influencing –

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

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

Norman van Zyl

Environmental Assessment Practitioner (EAP)

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TABLE OF CONTENTS TABLES AND FIGURES ........................................................................................................... v

APPENDICES ....................................................................................................................... vi

ABBREVIATIONS .................................................................................................................. vii

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

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

1.2 TERMS OF REFERENCE ........................................................................................... 1

2 PROJECT AND SITE DESCRIPTION ................................................................................ 3

2.1 WHAT IS A CELLULAR NETWORK? ......................................................................... 3

2.2 SUMMARY DESCRIPTIONS OF PROJECT ............................................................... 4

2.3 LOCALITY OF THE PROJECT .................................................................................. 5

2.4 RATIONALE FOR THE PROPOSED PROJECT .......................................................... 6

2.5 THE ALTERNATIVES ................................................................................................. 6

2.5.1 TOWER SHARING ............................................................................................ 6

2.5.2 ALTERNATIVE SITE LOCATIONS ....................................................................... 6

2.5.3 ALTERNATIVE TECHNOLOGY ......................................................................... 6

2.6 SUMMARY DESCRIPTIONS OF THE SITE (RECEIVING ENVIRONMENT) .................. 8

3 LEGISLATION POLICIES AND GUIDELINES .................................................................... 9

4 PUBLIC CONSULTATION PROCESS ............................................................................. 13

4.1 THE INTERESTED AND AFFECTED PARTIES (I&APs)............................................... 13

4.2 KEY ISSUES IDENTIFIED .......................................................................................... 15

5 IMPACT ASSESSMENT.................................................................................................. 16

5.1 METHODOLOGY .................................................................................................. 16

5.2 SCREENING AND ASSESSMENT OF IMPACTS ...................................................... 19

5.3 DISCUSSION ......................................................................................................... 23

6 CONCLUSIONS AND RECOMMENDATIONS ............................................................. 25

7 REFERENCES ................................................................................................................ 26

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TABLES AND FIGURES

Table 1: Project description of the proposed site ......................................................... 4

Table 2: Site description of preferred alternative ......................................................... 8

Table 3: Table of legal frameworks within which the project is operated .................. 9

Table 4: Public consultation process followed during the EIA. .................................. 13

Table 5: Authorities involved in this project ................................................................. 14

Table 6: Main issues of concern ................................................................................... 15

Table 7: Definitions of each of the Criteria used to determine the significance of impacts ............................................................................................................ 18

Table 8: Definitions of the various significance ratings ............................................... 19

Table 9: Screening and assessment of impacts .......................................................... 20

Figure 1: Depiction of the different cell types created by different cellular sites. ... 3

Figure 2: Proposed locality of the project site ............................................................ 5

Figure 3: Screening process to determine key issues ............................................... 17

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APPENDICES

APPENDIX A CV of Norman van Zyl

APPENDIX B Fact Sheet on the Health effects of RF exposure

APPENDIX C Stakeholders list

APPENDIX D Newspaper adverts

APPENDIX E Background Information Document

APPENDIX F Environmental Management Plan

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ABBREVIATIONS

AM Amplitude Modulation

BID Background Information Document

BTS Base Transceiver Station

COW City of Windhoek

CRAN Communications Regulatory Authority of Namibia

CV Curriculum Vitae

EIA Environmental Impact Assessment

ELF Extremely Low Frequency

EMF Electromagnetic Field

EMP Environmental Management Plan

EMR Electromagnetic Radiation

FM Frequency Modulation

I&APS Interested and Affected Parties

IARC International Agency for Research on Cancer

MET Ministry of Environment and Tourism

MTC Mobile Communications Company (Pty) Ltd

NBC Namibian Broadcasting Corporation

NCC Namibia Communications Commission

NON-IONISING RADIATION

Electromagnetic radiation that does not carry enough energy per quantum to ionise atoms or molecules.

RF Radiofrequency Radiation

SCENIHR Scientific Committee on Emerging & Newly Identified Health Risks

UMTS Universal Mobile Telecommunications Systems

WHO World Health Organisation

1 INTRODUCTION

1.1 BACKGROUND

Telecommunications service providers such as MTC are under pressure to continuously improve their services to cater for the ever-growing customer demand. This holds true for Windhoek and surrounding areas as well, where demand for mobile communications services have increased exponentially. By providing additional coverage in areas that suffer from poor coverage, the quality of MTC’s service to their clients is greatly enhanced. It is for this reason that the Sun Karros site, in the Daan Viljoen National Park became an urgent need for the park personnel and visiting tourists. The site specifications are given in chapter 2 of this report.

In accordance with the Environmental Management Act (2007) and its Regulations (2012), an Environmental Impact Assessment (EIA) is required for the “construction of masts of any material or type and of any height, including those used for telecommunication broadcasting and radio transmission”.

Enviro Dynamics was appointed to conduct an EIA and develop an Environmental Management Plan (EMP) for the proposed mast. Lester Harker is the Environmental Assessment practitioner in training that conducted the Scoping level EIA under supervision of Norman Van Zyl. His CV is attached as APPENDIX A.

1.2 TERMS OF REFERENCE

The Terms of Reference for the proposed project is based on the requirements set out in the Environmental Management Act (2007) and its Regulations (February 2012). The process covered the following steps, which are reported on in this document as follows:

• Provide a detailed description of the proposed activity (Chapter 2);

• Identify all legislation and guidelines that have reference to the proposed project (Chapter 3);

• Inform Interested and Affected Parties (I&APs) and relevant authorities of the details of the proposed development and provide them with a reasonable opportunity to participate during the process (Chapter 4);

• Identify existing environmental (both bio-physical and socio-economic) conditions of the area in order to determine their environmental sensitivity (Chapter 5);

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• Consider the potential environmental and social (including biological) impacts of the development, and assess the significance of the identified impacts (Chapter 6).

• Outline management and mitigation measures in an Environmental Management Plan (EMP) to minimize and/or mitigate potentially negative impacts.

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2 PROJECT AND SITE DESCRIPTION

2.1 WHAT IS A CELLULAR NETWORK?

Networks are designed to ensure that mobile phones maintain a link with the network as users move from one cell to another.

Each individual geographic area in a network is called a 'cell'. Cells are created by a base transceiver station (BTS). The cells overlap at the edges to prevent holes in coverage (Figure 1).

There are three types of cells in a cellular network:

• Macro cell: Provides the main coverage in a network. Typically constructed on

higher ground so that it is not obstructed by surrounding buildings and terrain.

The proposed Sun Karros site is a macro cell. Micro cell: Provides infill coverage and additional capacity where there are a

high number of users in a macro cell. It is constructed at street level, usually

between 300 m and 1000 m apart. • Pico cells: Provides localised coverage and are usually less visible. They are put

up in shopping centres and airports to strengthen the signal.

The cells described above are from specific types of antennae connected to a specific BTS configuration. A comparison is given below of the two main types of antennae used for macro BTS sites.

Figure 1: Depiction of the different cell types created by different cellular sites.

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2.2 SUMMARY DESCRIPTIONS OF PROJECT

Table 1: Project description of the proposed site

PROJECT ASPECT DETAIL

SITE LOCATION Single antenna mounted on top of an existing water reservoir (Error! Reference source not found.) (S22.53990 E16.94853)

STRUCTURE DESIGN • Macro BTS Site: Provide more options for expanding the coverage capacity and strengthening signal levels in an area. An existing water reservoir will be used as base structure, 7 meter high

• Small Dual band Antenna system: Kathrein 742226 • Operating frequency bands: UMTS 880-960 MHz/1920MHz-2170 MHz.

ROAD ACCESS Direct Access to the site is obtained from a two-track gravel road leading from the main restaurant area. The Daan Viljoen Park is reached via the C28 road, about 20 km west of Windhoek.

POWER SUPPLY AND OUTPUT

• Electricity to the site will be provided by Sun Karros, Nampower grid • Power output from this site will be 20 Watt.

ASSEMBLY AND ERECTION (CONSTRUCTION PERSONNEL)

• The antennae will be mounted against an existing water reservoir and will not require any supporting cables.

• Three people are needed for one day to construct the site.

ASSEMBLY AND ERECTION (DURATION)

The physical assembling of the antenna and associated equipment will take place on site by using manual labour. The site will be earthed to protect it from lightning. The installation of the site takes approximately one day to complete.

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2.3 LOCALITY OF THE PROJECT

The proposed project site is located on an existing water reservoir on the Sun Karros property (Figure 2). This site is known as the Sun Karros site due to its location on the Sun Karros lodge’s property.

Figure 2: Proposed locality of the project site

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2.4 RATIONALE FOR THE PROPOSED PROJECT

MTC considered the lack of signal strength serving the area as basis to establish the cellular site at Daan Viljoen.

According to MTC, this lack of proper service provision within the National Park was found to be below the licence agreement held with the Communications Regulatory Authority of Namibia (CRAN) for mobile services provision in this area, and therefore improvements are needed.

The installation of a new macro cellular site within this target area is the only effective means of addressing the service shortfalls experienced there.

2.5 THE ALTERNATIVES

2.5.1 TOWER SHARING

In terms of the Communications Act of 2009, service providers are required to first consider sharing existing infrastructure in the area, before constructing new sites. MTC has considered this, and found an existing 15m high water reservoir that is sufficient to mount the antenna on in the target area.

2.5.2 ALTERNATIVE SITE LOCATIONS

A number of factors determine the location of a telecommunications site. These factors form the selection criteria used by MTC, to select the best possible position to place cellular infrastructure.

These are:

• Coverage offered by existing network infrastructure

• Surrounding topography and built-up environment

• Established and future urban area

• The required footprint

• The most appropriate design of the facility

Within these limits, MTC investigated all possible alternatives to the proposed locations. MTC has considered this, and found an existing 7 meter high water reservoir that is sufficient to mount the antenna against to service the target area.

2.5.3 ALTERNATIVE TECHNOLOGY

To determine the best technology for the specific project it is important to understand the options that are available and what the limitations and advantages of each are:

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Ø Mini vs. Macro BTS sites

A Base Transceiver Station (BTS) refers to the electronic equipment that facilitates wireless communication between the user and the network. It consists of a number of components including a transceiver and amplifier. Mini/macro refers to the size of the container in which this equipment is stored as well as the coverage area it provides.

The number and size of the equipment stored on a macro site is much more than that of a micro site. Because of the heat emitted from the equipment air conditioners are required to cool it down. Macro sites provide more options for expanding the coverage. The antennae should also be located higher from the ground than what is required for the mini BTS. This means that macro BTS are usually either constructed on elevated ground or on structures of more than 15 m high (as is the case at the Sun Karros site).

Due to the longer transmission range of macro BTS, MTC is proposing the construction of macro structure at the Sun Karros site.

Ø Dual band vs single band antenna

A Dual band Antennae system operates on two signal levels, constantly monitoring both signals utilising its bi-frequency bandwidths and selecting the stronger of the two frequencies to provide better signal strength to the end user. This system provides better coverage in areas that normally experience dead spots, drop out areas and signal fading areas. It is for these reasons that a dual band system is proposed at the Sun Karros site.

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2.6 SUMMARY DESCRIPTIONS OF THE SITE (RECEIVING ENVIRONMENT)

Only the most pertinent environmental sensitivities applicable to the preferred alternative site have been provided for in Table 2 below.

Table 2: Site description of preferred alternative

PROJECT ASPECT DETAIL

CLIMATE • Average maximum temperature is 30 ºC • Average minimum temperature is -3.5ºC during the coldest

months of winter (June and July).

LANDSCAPE Khomas Hochland Plateau, situated 1715 meters above sea level

HABITAT • Highland shrubland, with various Acacia species, kudu bush (Combretum apiculatum) and buffalo thorn (Ziziphus mucronata)

BIRDS • Some of Namibia's endemic bird species are found here including Ruppel's parrot (protected species, listed on CITES appendix II), Monteiro's Hornbill, Damara rockrunner and white-tailed Shrike.

SITE OWNERSHIP AND OCCUPANCY

• Daan Viljoen Game Park is managed by the Ministry of Environment and Tourism while the accommodation facilities are run privately under a Public Private Partnership with Namibia Wildlife Resorts (NWR). Sun Karros Lifestyle Safaris operates accommodation within the park.

• 19 chalets, and • 12 campsites

SURROUNDING LAND USES • State reserve • Tourism establishment (Sun Karros Daan Viljoen Lifestyle safaris)

CIVIL AVIATION The Sun Karros site is located further than 8km from the nearest aerodrome, airfield, airstrip or airport and therefore does not require clearance from the Directorate of Civil Aviation in compliance with the International Civil Aviation Organization.

NUISANCES Construction related nuisances i.e. dust and noise

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3 LEGISLATION POLICIES AND GUIDELINES

This review serves to inform the proponent and decision-maker at the DEA of the requirements and expectations, as laid out in terms of these instruments, to be fulfilled before the proposed project may commence and once operational. The findings of the abovementioned review are summarised below.

Table 3: Table of legal frameworks within which the project is operated

TOPIC LEGISLATION PROVISIONS REGULATORY AUTHORITY

APPLICATION TO PROJECT

NAMIBIAN LOCAL LEGISLATION

Erecting telecommunication facilities in Windhoek

City of Windhoek: Policy for the erection of Telecommunication facilities in Windhoek (2008)

Provides uniform, clear standards and assessment criteria to assist the development, control, design, installation, appearance and monitoring of telecommunication facilities within the City of Windhoek area.

City of Windhoek Provides clear guidelines to the specific issues that should be investigated during the Environmental Assessment. These include amongst others, the visual impact, anticipated electromagnetic field exposure strength and impact on Civil Aviation.

Promotes co-location or site sharing of operators to maximise the use of existing network resources.

Promotes community consultation with the surrounding residents.

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NAMIBIAN NATIONAL LEGISLATION

Environmental Assessment and Management Systems

Environmental Management Act (Act 7 of 2007), and EIA Regulations (2012):

Provides list of activities that require an environmental assessment, including:

“(k) The erection or construction of communication networks including towers, telecommunication lines and cables as well as sites associated therewith including roads”

Provides for adequate public participation during the environmental assessment process for interested and affected parties to voice their opinions about a project.

Ministry of Environment and Tourism, Directorate of Environmental Affairs

Communication site triggers an EIA.

Conduct public participation as part of the EIA process described in the act.

Broadcasting Communications Bill, 2009. Promotes the sharing of infrastructure of the dominant carrier with other carriers.

Provides for the regulation of telecommunications activities. The Bill provides for licensing and enforcement of conditions, and the approval of equipment and technical standards to ensure

Communications Regulatory Authority of Namibia (CRAN)

Encourage the sharing of towers to avoid cumulative impact.

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public health and safety.

Namibian Communications Commission Act, Act 4 of 1992

Provides for the establishment of the Namibia Communications Commission responsible to issue broadcasting licenses, control or supervises certain broadcasting activities and program content, and among other activities is responsible for the setting of specifications and standards for new technologies such as cellular, wireless and satellite services.

Namibian Communications Commission (NCC), Directorate Communications

Provides the standards for setting up cellular, wireless and satellite services.

Radiation The Atomic Energy and Radiation Protection Act, Act 5 of 2005:

Provides for the adequate protection of the environment and of people against the harmful effects of radiation by controlling and regulating the production, processing, handling, use, holding, storage, transport and disposal of radiation sources and radioactive materials, and controlling and regulating prescribed non-ionising radiation sources according to the standards set out by the ICNIRP.

Ministry of Health and Social Services, Atomic Energy Board of Namibia

Used to determine the “safe distance” around the site.

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INTERNATIONAL STANDARDS AND GUIDELINES

Non-ionizing Radiation “Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic, and Electromagnetic Fields (up to 300GHz)” (April 1998 developed by the International Commission on Non-Ionizing Radiation Protection (ICNIRP))

Provides international standards and guidelines for limiting the adverse effects of non-ionising radiation on human health and well-being, and, where appropriate, provides scientifically based advice on non-ionising radiation protection including the provision of guidelines on limiting exposure. ICNIRP exposure limits for non-ionizing radiation is 4.5W/m².

The EMR levels proposed by the ICNIRP are endorsed by Namibia.

The proposed project needs to adhere to exposure limits set out in these guidelines (see Appendix B_ Fact sheet).

World Health organization

Health and safety of wireless networks – A guide to local authorities (Draft, 2012)

Intended to help local authorities understand the different types of wireless networks and the infrastructure they need. Furthermore, it provides an overview of the health and safety issues involved with wireless networks.

Locally enforced by the City of Windhoek.

Provides background information to wireless networks and research on potential health effects and exposure standards.

The provisions most important, in terms of guiding this EA process from those listed above are those contained in the EIA Regulations, the Atomic Energy and Radiation Protection Act and the ICNIRP Guidelines.

4 PUBLIC CONSULTATION PROCESS

Public Participation forms an important component of the Environmental Assessment process. A summary of the public consultation process followed during this EIA process is provided in Table 4 below:

Table 4: Public consultation process followed during the EIA.

DESCRIPTION OF PROCESS TIME ALLOWED

SHARING OF INFORMATION WITH PUBLIC

Identification of stakeholders:

Key stakeholders were identified and included in an electronic register (stakeholders list) (APPENDIX C).

The register was maintained throughout the process.

Newspapers adverts:

Notices were placed in the media, briefly explaining the development and its locality, and inviting the public to register as stakeholders. (APPENDIX D).

On the 7th and 14th of November 2014 in The Namibian and Republikein.

Information documents

A Background Information Document was compiled that contained the information of the project (APPENDIX E). The BID was forwarded to all authorities and the registered stakeholders for Sun Karros.

Continued throughout the process

Public comments period

The date for final comments was set for the 4th of December 2014.

4.1 THE INTERESTED AND AFFECTED PARTIES (I&APS)

Specific I&APs, whom Enviro Dynamics received input from and who are interested in and/or affected by the proposed development, were identified, contacted and registered as I&APs. These I&APs were identified from the broader project area, all tiers of government and the private (non-state) sector. In addition, notices regarding the project were placed in widely circulated national newspapers for two consecutive weeks inviting members of the public to register as I&APs.

A summary of the stakeholder groups, consisting of authorities and interest groups at national, regional, and local level, are presented in Table 5.

The complete stakeholders list can be viewed in Appendix C.

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Table 5: Authorities involved in this project

ITEM LEVEL DESCRIPTION

STA

KEHO

LDER

DA

TABA

SE

NA

TION

AL

AUT

HORI

TIES

Ministry of Environment and Tourism

Ministry of Health and Social Services (Radiation)

Ministry of Information and Communication Technology

REG

ION

AL

AN

D LO

CA

L A

UTHO

RITIE

S Khomas Regional Council

City of Windhoek

PARA

STA

TALS

Communications Regulatory Authority of Namibia (CRAN)

Namibia wildlife Rersorts (NWR)

NG

O’S

AN

D O

THER

I&A

PS

Radiation Awareness Namibia

Sun Karros Lodge

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4.2 KEY ISSUES IDENTIFIED

Before one can assess the potential impacts associated with the proposed project, it is necessary to define key issues, which include those raised during the public consultation. The key issues identified, are determined based on the comments submitted to Enviro Dynamics, as well as professional opinion. These issues have been grouped according to theme to clearly distinguish the main issues of concern (Table 6).

Table 6: Main issues of concern

THEME ISSUE NEXT STEP

HEALTH CONCERNS

• Long term effects of non-heating continuous pulsing • Possible carcinogen • Involuntary, uncontrolled, continuous exposure

Carried over to the Impact assessment chapter to determine each significance.

ENVIRONMENTAL IMPACTS

• Presence of one protected Bird species • Wildlife in the park

Issue has been investigated and found not to be a concern.

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5 IMPACT ASSESSMENT

5.1 METHODOLOGY

The EIA Regulations require “a description of the significance of any significant effects, including cumulative effects that may occur because of the undertaking of the activity”. In order to determine significance each of the potential impacts identified they have been subjected to the following questions displayed graphically (steps 1 and 2 – Figure 3) and in tabular form (Table 9) below. These questions form the methodology for assessing the significance of the effects or impacts identified through this EA process:

1. The first step is to screen out (set aside) all impacts which do not fall within the scope of this project and responsibility of the developer;

2. The next step is to determine whether sufficient information exists to assess the potential impacts of those that remain. If insufficient information is available to assess (with a high degree of confidence) and recommend mitigation measures to address a given impact further investigation will be required,

3. If sufficient information is available, to assess (with a high degree of confidence) and recommend mitigation measures to address a given impact no further investigation will be required and the impact will be addressed in the EMP.

To understand the significance of each of the potential impacts, it is necessary to subject each to a range of assessment criteria. The application of these criteria, in determining the significance of potential impacts, uses a balanced combination of duration, extent, and intensity/magnitude, modified by probability, cumulative effects, and confidence. The definitions of each of the criteria are contained in

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Table 7.

Finally based on the answers obtained after applying steps 1-3 a decision can be made regarding the significance of the impact based on three categories – low, medium, or high.

The application of the screening process is displayed in Table 9 below.

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Figure 3: Screening process to determine key issues

Sufficient information to assess the impact

Insufficient information to assess the impact

No further investigation required

Further investigation required

Issue communicated to applicable authority

NO YES

Does the issue/potential impact fall within the scope of this EA and the

responsibility of the Developer?

Determination of impact significance

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Table 7: Definitions of each of the Criteria used to determine the significance of impacts

DESCRIPTION

NATURE Reviews the type of effect that the proposed activity will have on the relevant component of the environment and includes “what will be affected and how?”

EXTENT Geographic area. Indicates whether the impact will be within a limited area (on site where construction is to take place); local (limited to within 25km of the area); regional (limited to ~200km radius); national (limited to the borders of Namibia); or international (extending beyond Namibia’s borders).

DURATION Whether the impact will be temporary (during construction only), short term (1-5 years), medium term (5-10 years), long term (longer than 10 years, but will cease after operation) or permanent.

INTENSITY Establishes whether the magnitude of the impact is destructive or innocuous and whether or not it exceeds set standards, and is described as none (no impact); low (where natural/ social environmental functions and processes are negligibly affected); medium (where the environment continues to function but in a noticeably modified manner); or high (where environmental functions and processes are altered such that they temporarily or permanently cease and/or exceed legal standards/requirements).

PROBABILITY Considers the likelihood of the impact occurring and is described as uncertain, improbable (low likelihood), probable (distinct possibility), highly probable (most likely) or definite (impact will occur regardless of prevention measures).

SIGNIFICANCE Significance is given before and after mitigation. Low if the impact will not have an influence on the decision or require to be significantly accommodated in the project design, Medium if the impact could have an influence on the environment which will require modification of the project design or alternative mitigation (the design can be used, but with deviations or mitigation). High where it could have a “no-go” implication regardless of any possible mitigation (an alternative design should be used).

STATUS OF THE IMPACT

A statement of whether the impact is positive (a benefit), negative (a cost), or neutral. Indicate in each case who is likely to benefit and who is likely to bear the costs of each impact.

DEGREE OF CONFIDENCE IN

PREDICTIONS

Is based on the availability of specialist knowledge and other information.

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Table 8: Definitions of the various significance ratings

SIGNIFICANCE RATING

CRITERIA

LOW Where the impact will have a negligible influence on the environment and no modifications or mitigations are necessary for the given development description. This would be allocated to impacts of any intensity/ magnitude, if at a local scale/ extent and of temporary duration/time.

MEDIUM Where the impact could have an influence on the environment, which will require modification of the development design and/or alternative mitigation. This would be allocated to impacts of medium intensity/magnitude, locally to regionally, and in the short term.

HIGH Where the impact could have a significant influence on the environment and, in the event of a negative impact the activity(ies) causing it, should not be permitted (i.e. there could be a ‘no-go’ implication for the development, regardless of any possible mitigation). This would be allocated to impacts of high intensity, locally for longer than a month, and/or of high intensity regionally and beyond.

5.2 SCREENING AND ASSESSMENT OF IMPACTS

All impacts included in the table below fall within the scope of this project and responsibility of MTC. Each of the potential impacts is screened (Figure 3) and subjected to the criteria stipulated above (Table 7). The significance of each potential impact is determined based on the criteria in Table 8.

Detailed descriptions of mitigation measures for impacts that require mitigation are contained in the EMP (Appendix J).

Impacts with a medium or high significance rating are discussed at the end of this chapter.

Table 9: Screening and assessment of impacts

POTENTIAL IMPACT STATUS/ NATURE EXTENT DURATION INTENSITY PROBABILITY

CONFIDENCE/ SUFFICIENT

INFORMATION AVAILABLE?

SIGNIFICANCE

BEFORE MITIGATION

SIGNIFICANT MITIGATION

DEEMED POSSIBLE?

AFTER MITIGATIO

N

CONSTRUCTION PHASE

Compromised road safety due to the provision of access to a mobile cellular network

Negative. Movement of construction vehicles along existing roads pose a risk to road users.

Site specific Temporary Low Probable Yes Low Proper signage placed on road access points warning motorists of active construction taking place

Regulating the movement of construction vehicles daily.

Construction vehicles should not be on the main road (independence avenue during peak hours)

Low

OPERATION AND MAINTENANCE PHASE

Provision of access to a mobile cellular network

Positive. Access to a mobile cellular network will be provided to park personnel and visitors.

Local Long-term High Definite Yes High Construction of the cellular site.

High

Health impacts Thermal effects due to Site specific Long-term Low Improbable Yes Medium Ensure that the Low

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SIGNIFICANCE

BEFORE MITIGATION


DEEMED POSSIBLE?

AFTER MITIGATIO

N

associated with thermal effects of EMF

exposure to EMF experienced by residents located in the areas adjacent to the proposed site.

prescribed “safe distance” is adhered to, with no person living within at least a 15 m radius from the site.

Health impacts associated with non-thermal effects of EMF

Non-thermal effects due to exposure to EMF experienced by residents located in the areas adjacent to the proposed site.

Local Long-term Low Uncertain Yes Medium Ensure that the prescribed “safe distance” is adhered to, with no person living within at least a 15 m radius from the site.

See Appendix B which provides information on the health effects of non-ionizing radiation on human health.

Medium-Low

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SIGNIFICANCE

BEFORE MITIGATION


DEEMED POSSIBLE?

AFTER MITIGATIO

N

DECOMMISSIONING PHASE

Potential impact on road users and wildlife crossing the road

Movement of haul vehicle along existing roads pose a threat to road users and wildlife in the park.

Local Temporary Low Probable Yes Low Sufficient and clear warning signage should be erected at site entry points leading from the main road.

Adherence to specified speed limits in the park.

Low

5.3 DISCUSSION

From the above impact assessment process, the following impacts should be noted that have a medium significance rating.

• Health impacts associated with non-thermal effects of EMF and thermal effects of EMF: The most significant claim regarding the non-thermal effects of EMF exposure from BTSs is that it increases the risk of cancer. Numerous epidemiological studies have been conducted of cancer relation to exposure to power-frequency fields (ICNIRP, 1998; 2009). No consistent evidence has emerged from these studies to substantiate these claims. In a recent review of 10 epidemiological studies conducted between 2003 and 2009 on EMF exposure from BTSs (Khurana, et al., 2010) makes claims that an association exists between increased cancer risk and EMF exposure from BTSs which are compliant with the 1998 ICNIRP guidelines. The precautionary principle should be applied in instances such as these where scientific uncertainty exists. In the absence of consistent evidence for these claims however the current 1998 ICNIRP will be used to inform safe exposure limits for residential and occupational areas. The ICNIRP standards hold to the precautionary principle and has been applied in compiling the safe exposure limits. For a more comprehensive description on EMF exposure and research done in this regard see Appendix B.

• The Namibian context: The protection of the environment and people against the harmful effects of radiation is regulated by the Atomic Energy and Radiation Protection Act (Act no 5 of 2005). Under Section 33(1) the National Radiation Protection Authority is charged with the administration of the act by a) inspecting any radiation source in order to assess radiation safety conditions b) taking the necessary action to enforce the provisions made in the Act.

Section 43 (3) of the Act specifically makes reference to the standards published by ICNIRP:

“Regulations made under subsection (1) must take due account of any guidelines or standards published by the International Commission on Radiological Protection, the International Commission on Non-ionising Radiation, the International Atomic Energy Agency or other relevant international organisations. (3) The Minister may incorporate the guidelines established and published by the International Atomic Energy Agency, World Health Organisation, the International Commission on Radiological Protection or the International Commission on Non-Ionising Radiation or any other standards or guidelines published by any international

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organisation into regulations made under this section by reference. (4) The Minister may incorporate such standards or guidelines with such amendments as he or she thinks fit.”

Pursuant to Section 43 The Electromagnetic Fields Exposure Regulations have been drafted with the specific purpose of:

i. Minimizing the exposure of persons to the harmful effects of non-ionizing radiation; and

ii. Creating the regulatory framework for the control and regulation of sources of non-ionizing radiation.

These draft regulations have been formulated from the WHO Model Regulations for EMF protection which is based on the ICNIRP Guidelines.

The National Radiation Protection Authority acknowledges that ICNIRP standards are based on short-term exposure of EMF and advises the adoption of precautionary principles (Eiman, 2015. Pers Com.).

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6 CONCLUSIONS AND RECOMMENDATIONS

The negative impacts with a medium significance rating have been identified. Mitigation measures have been devised and outlined above (Chapter 6) to address these to ensure that this project (if granted Environmental Clearance) is implemented in the most sustainable way possible. All impacts discussed above will be addressed in the EMP (Appendix I).

The key impacts and their mitigation measures are summarised below:

• Non-thermal health impacts of EMF exposure: No consistent evidence exists that substantiate the claim that the non-thermal effects of exposure to EMF from BTSs increases cancer risk. The World Health Organization’s (2012) official stance is that “Studies to date provide no indication that environmental exposure to RF fields, such as from base stations, increases the risk of cancer or any other disease.” (WHO, 2013). In the absence of consistent evidence for these claims however the current ICNIRP (2010) standards will be used to inform safe exposure limits for residential and occupational areas. The ICNIRP standards hold to the precautionary principle and has been applied in compiling the safe exposure limits.

• Until such time that the National Radiation Protection Authority of Namibia has published specific directives for dealing with non-thermal, long and short term exposure of BTS sites, the limits set by ICNIRP should apply to the Namibian context. In terms of the uncertainties related to BTS sites and human health (e.g. pulsing and ELF), the ICNIRP standards are based on the precautionary principle and by adhering to the standards set by ICNIRP, the risks are expected to be minimal.

It is the opinion of the consultant that sufficient information is available to address all the issues associated with the establishment of the Sun Karros Macro BTS site from the construction phase through to the decommissioning phase. If the recommendations included in this report and the EMP is implemented, the significance of the impacts can be reduced to reasonably acceptable standards and durations.

Environmental clearance can therefore be granted for the establishment of the Macro BTS site provided that the proponent adheres to all the mitigation measures contained in this report and the EMP, and all others imposed by the DEA.

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7 REFERENCES

Final Environmental Scoping Report, 2012. Proposed construction of five Mini BTS structures in Ludwigsdorf, Windhoek: Enviro Dynamics

IARC, 2002. Volume 80: Non-Ionizing Ration, Part 1: Static and Extremely Low-Frequency (ELF) Electric and Magnetic Fields - Summary of Data Reported and Evaluation, Lyon, France: IARC Press, ISBN 92 832 1280 0.

ICNIRP, 2009. Exposure to high frequency electromagnetic fields, biological effects and health consequences (100 kHz-300 GHz), Germany: International Commission on Nono-Ionizing Radiation Protection (ICNIRP).

ICNIRP, 2010. ICNIRP guidelines for limiting exposure to time-varying electric and magnetic fields (1 Hz - 100 kHz). Health Physics 99(6):, pp. 818-836.

TechTarget, 2009-2014. WhatIs.com. [Online] Available at: http://whatis.techtarget.com/definition/dual-Wi-Fi-antenna [Accessed 11 12 2014].

World Health Organization, 2012. Health and safety of wireless networks - A guide for local authorities, s.l.: Unpublished Report.

prepared by: prepared for: march 2015 · • small dual band antenna system: kathrein 742226 •...

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