Luderitz Final EMP

Registration: cc/2012/2523
Vat number: 5728293015

P.O. Box 35473,
Kleine Kuppe, Windhoek
Mobile: 0812 567 709
One Step @ a
Website: www.tec.com.na
time E-mail: info@tec.com
RE-USE OF OLD / EXISTING BORROW PITS /

SITES FOR THE SUPPLY OF GRAVEL
MATERIALS FOR THE REGRAVELLING OF
ROADS IN THE LUDERITZ DISTRICT
ENVIRONMENTAL MANAGEMENT PLAN
April 2016
EMP: Re-use of existing borrow sites to supply materials for the re-gravelling of roads in Luderitz District
DOCUMENT INFORMATION
Document Type Project Report
BID Reference No: TEC004/2016
Title Environmental Management Plan (EMP) for borrow sites to supply gravel
materials for the re-gravelling of roads in the Luderitz Peninsula and town lands.
General Description Project Delivery
Author:
Tortoise Environmental Consultants (TEC)
Reviewed by:
Grace Shihepo
MSc. (Environmental Planning and Management)
Environmental Management Plan (EMP) for the Re-gravelling of Road in the Luderitz Peninsula
CONTENTS
1 Overview ............................................................................................................................. 1
1.1 Purpose of the EMP .................................................................................................. 2
2 Project information ............................................................................................................. 4
3 ROLE PLAYERS & THEIR RESPONSIBILITIES ................................................................. 7
3.1 ROLES and responsibilities ...................................................................................... 7
3.2 Compliance WITH REQUIREMENTS ...................................................................... 9
4 conclusion ........................................................................................................................ 19
LIST OF TABLES
Table 1.1: Existing and Preferred Borrow Sites in the Luderitz Peninsula ................................... 1
Table 1.2: Section 8 of the EIA Regulations listing the requirements of an EMP ........................ 3
Table 2.1: Road sections in the Luderitz Peninsula and Town Lands to be re-gravelled ............. 4
Table 3.1: Management activities to be implemented during operation and rehabilitation of the
borrow sites .............................................................................................................................. 10
LIST OF FIGURES
Figure 1: Existing and Preferred Borrow Sites to supply gravel for the re-gravelling of roads in
the Luderitz Peninsula & Town Lands ........................................................................................ 5
Figure 2: Map showing the locations of the existing borrow pit / sites as well the road that is to
be re-gravelled ........................................................................................................................... 6
Environmental Management Plan (EMP) for the Re-gravelling of Road in the Luderitz Peninsula & Town Lands 2
ABBREVIATIONS
BBB Buchter Bricks and Blocks
CEMP Construction Phase Environmental Management Plan
DEA Department of Environmental Affairs
EA Environmental Assessment
EAP Environmental Assessment Practitioner
EBS Existing Borrow Site
ECC Environmental Clearance Certificate
ECO Environmental Compliance Officer
EO Environmental Officer
EIA Environmental Impact Assessment
EMA Environmental Management Act (No. 7 of 2007)
EMP Environmental Management Plan
MET Ministry of Environment and Tourism
OEMP Operational Phase Environmental Management Plan
PBS Preferred Borrow Site
RA Road Authority
RE Regional Engineer
TEC Tortoise Environmental Consultants
1 OVERVIEW
This document constitutes the Environmental Management Plan (EMP) for existing borrow pits /
sites that are proposed for re-use to supply gravel material for the re-gravelling of roads in the
Luderitz Peninsula. The Roads Authority (RA) appointed Buchter Bricks and Blocks (BBB), to
carry out the road works and Tortoise Environmental Consultants (TEC) was appointed to
conduct the Environmental Assessment (EA) and compile the EMP.
The EMP is submitted to the Department of Environmental Affairs (DEA) of the Ministry of
Environment and Tourism (MET) as part of the application for the Environmental Clearance
Certificate (ECC). A total of 24 Existing Borrow Sites (EBS) were identified within the Luderitz
Peninsula. However, laboratory tests conducted by the Road Authority (RA) shows that out of
the 24 EBS, only 12 EBS have the required gravel quality for re-gravelling, herein referred to as
the Preferred Borrow Sites (PBS) or simply “P” as presented in the table below:
Table 1.1: Existing and Preferred Borrow Sites in the Luderitz Peninsula
GPS Coordinates Road Works Quantity of Gravel

EBS PBS 3
Latitude Longitude Distance (km) material required (m )
E-1 - 26°41'49.02"S 15° 7'12.10"E - -
E-2 - 26°43'25.49"S 15° 6'14.58"E - -
E-3 - 26°42'14.95"S 15° 6'52.73"E - -
E-4 - 26°43'39.01"S 15° 6'18.67"E - -

E-5 - 26°41'30.99"S 15° 8'23.89"E - -
E-6 - 26°41'2.55"S 15° 9'26.50"E - -
E-7 - 26°41'46.13"S 15° 7'36.25"E - -
E-8 - 26°43'48.61"S 15° 6'40.22"E - -
E-9 - 26°43'40.80"S 15° 6'43.80"E - -
E-10 - 26°42'4.40"S 15° 7'13.00"E - -
E-11 - 26°43'30.36"S 15° 6'16.44"E - -
E-12 - 26°43'52.35"S 15° 6'19.56"E - -
3
E-13 P-1 26°37'6.20"S 15°11'20.90"E 7.0 17,986.5 m
3
E-14 P-2 26°41'51.40"S 15° 7'27.80"E 7.5 17,287.5 m
3
E-15 P-3 26°39'24.40"S 15° 7'20.90"E 3.0 6,297.0 m
3
E-16 P-4 26°39'35.80"S 15° 6'48.90"E 3.5 7,346.5 m
3
E-17 P-5 26°41'17.50"S 15° 5'15.50"E 5.2 11,903.0 m
EMP: Re-use of existing borrow pits to supply materials for the re-gravelling of roads in the Luderitz District
3
E-18 P-6 26°42'57.00"S 15° 5'59.40"E 2.8 6,536.0 m
3
E-19 P-7 26°43'54.00"S 15° 6'43.20"E 6.0 16,173.0 m
3
E-20 P-8 26°43'49.50"S 15° 6'40.30"E 3.6 9,703.8 m
3
E-21 P-9 26°43'41.20"S 15° 6'43.10"E 3.4 9,164.7 m
3
E-22 P-10 26°42'22.96"S 15°10'6.86"E 3.0 8,086.5 m
3
E-23 P-11 26°41'14.39"S 15° 9'23.62"E 1.0 2,695.5 m
E-24 P-12 26°41'58.00"S 15° 7'17.40"E Blending Material only -

3
TOTAL 46 113,180.0 m
Gravel roads have an upper layer of gravel (known as a gravel wearing course), which is placed
on the roadbed to allow the gravel road to aid the movement of traffic safely and effectively.
With time, the gravel-wearing course is eroded away by both traffic and natural elements. This
layer needs to be replaced to continue to provide a safe and functional surface to the road user.
In order to undertake the road works, a suitable source of material required for the gravel-
wearing course. As per the laboratory test, 12 old / existing borrow in the surrounding areas of
the Luderitz town were found to contain suitable gravel material for the supply of gravel wearing
material. The content of this EMP will be binding on all parties who will have a role to play in the
mining excavations of road materials as well the rehabilitation thereof.
1.1 PURPOSE OF THE EMP
The EMP has been crafted to ensure that the excavation of road material by Buchter Bricks &
Blocks is being conducted as per the requirements of the Namibian Environmental Management
Act (No. 7 of 2007). The EMP also provides a control framework for implementing the
management actions aimed at reducing possible negative impacts.
The 2012 EIA Regulations define a ‘management plan’ as:

“…a plan that describes how activities that may have significant environments effects on the
environment are to be mitigated controlled and monitored.”
The EMP is an open-ended document implying that information gained during sand mining
activities from the borrow pit activities and/or monitoring of procedures on-site can lead to
changes in the EMP, and these changes or inclusions will need to be communicated to MET.
This document should therefore be considered as a binding document to all contractors as it is
a guiding tool to protecting the natural, bio-physical and socio-economic environment
throughout the project lifecycle.
The contents of the EMP must also include a system for assessing the effectiveness of
monitoring and management arrangements after implementation. Buchter Bricks & Blocks
therefore has the responsibility to ensure that the process of sourcing gravel material from the
borrow pits conforms to the principles stipulated herein.
Table 1.2 below lists the requirements of an EMP as stipulated by Section 8 (j) of the EIA
Regulations. These requirements have been fulfilled in the subsequent sections of this
document.
Table 1.2: Section 8 of the EIA Regulations listing the requirements of an EMP
Requirement
(j) a draft management plan, which includes –

(aa) information on any proposed management, mitigation, protection or remedial measures to be
undertaken to address the effects on the environment that have been identified including objectives in
respect of the rehabilitation of the environment and closure;
(bb) as far as is reasonably practicable, measures to rehabilitate the environment affected by the
undertaking of the activity or specified activity to its natural or predetermined state or to a land use which
conforms to the generally accepted principle of sustainable development; and
(cc) a description of the manner in which the applicant intends to modify, remedy, control or stop any
action, activity or process which causes pollution or environmental degradation remedy the cause of
pollution or degradation and migration of pollutants.
Copies of the EMP shall be distributed to all senior personnel and they shall be required to
familiarize themselves with the contents of this document. Please take note that this EMP
should be regarded as a living document and changes should be made to the EMP as required
during project evolution, while retaining the underlying principles and objectives on which the
document is based.
2 PROJECT INFORMATION
A total of 46 km of the roads in the Luderitz Peninsula and Town lands have been identified for
re-gravelling and the respective roads are indicated in the table below. A few borrow pits / sites1
have previously been used to source gravel material from. Amongst the existing borrow sites
are selections of sites that the laboratory analysis conducted by Roads Authority confirmed to
consist suitable material. These sites are therefore recommended by the Roads Authority to use
for re-gravelling in order to minimise haulage distances of materials.
The table below lists the road sections within the Luderitz Peninsula with their respective
distances set for re-gravelling.
Table 2.1: Road sections in the Luderitz Peninsula and Town Lands to be re-gravelled
Road Area Reference Distance

Number to be re-gravelled
DR 706 Agate Beach Road 4 km
DR 701 Grosse Bucht 20 km
DR 702 Diaz Point 10 km
DR 733 Diaz / Grosse Bucht connect 7 km
DR 734 Griffiths Bay 5 km
TOTAL 46 km
The Luderitz Peninsula is a recreational area, frequented by tourists as well as the residents of
Luderitz and falls within the //Tsau Khaeb (Sperrgebiet) National Park under the auspices of the
Ministry of Environment and Tourism. The ecological sensitivity of the area and the potential
capacity as a tourist attraction requires that the road re-gravelling activities be undertaken in a
responsible and environmental friendly manner. The Peninsula is also known for its exceptional
botanical richness and diversity.
The site visits to the area have revealed that previous activities of sourcing material have left
some unsightly conditions within the peninsula. This owes to the fact that no EMP was
previously implemented to ensure proper rehabilitation of the borrow sites. The large numbers
of tourists frequenting the Luderitz Peninsula shows the importance of good road maintenance
however the importance of minimal disturbance to the borrow sites should not be disregarded. A
good and well maintained road network in the peninsula would not only benefit the immediate
road users, but it would also ensure road safety and contribute to local economy through
attracting more tourists in the area.
1
Note, in this document, the terms borrow pits and borrow sites have been used interchangeably, because normally
the area were sand or gravel is taken is referred to as a borrow pit, but for the Luderitz Peninsula, the gravel is
collected over a larger and shallow area and there are no deep trenches to make them borrow pits per say and
hence the term borrow site is also used.
Figure 1: Existing and Preferred Borrow Pits / Sites to supply gravel for the re-gravelling of roads in the Luderitz Peninsula & Town Lands
Figure 2: Map showing the locations of the existing borrow pit / sites as well the road that is to be re-gravelled
3 ROLE PLAYERS & THEIR RESPONSIBILITIES

This section outlines the roles and responsibilities of the respective key personnel that would be
responsible for effective implementation of the EMP.
3.1 ROLES AND RESPONSIBILITIES
Formal responsibilities are necessary to ensure that key procedures are followed. The purpose
of this section is to define roles for personnel and to detail their respective responsibilities in the
execution of the EMP. The key role-players for the project are the Environmental Compliance
Officer (ECO) representing MET – DEA for environmental monitoring, the Contractor (Buchter
Bricks & Blocks) and The Regional Engineer (representative of Roads Authority). It is
recommended that an organisational structure be developed to ensure that:
 There are clear channels of communication;

 There is an explicit organisational hierarchy for the project; and
 Potential conflicting or contradictory instructions are avoided from either side.
All instructions and official communications regarding environmental matters shall follow the
organisational structure as determined by the RA. In terms of the recommended organisational
structure, all instructions that relate to environmental matters should be communicated to the
Contractor. The only exception to this rule would be in an emergency (defined as a situation
requiring immediate action and where failure to intervene timeously would, in the reasonable
opinion of the Regional Engineer (RE) (or equivalent), result in unacceptable environmental
degradation), where instructions may be given directly to the Contractor. Whatever the structure
adopted by the Contractor, it is essential that the responsibilities outlined are assigned to
specific parties with the capacity and experience required to implement the EMP.
The Contractor:
The Contractor will be responsible for the operations of the borrow pit / site and shall be
responsible for ensuring the day-to-day implementation of the EMP during the lifecycle of the
borrow pit activities, and shall be well-versed in the contents of this document:
 The Contractor shall appoint a Borrow pit Manager to oversee the daily onsite activities.
 The Contractor shall liaise closely with the Borrow pit Manager and RE on any
environmental management issues, incidents or emergencies.
 The Contractor shall ensure that the works on-site are conducted in an environmentally
sensitive manner and in accordance with the requirements of the EMP at all times. Special
care shall be taken by the Contractor to prevent irreversible damage to the environment.
 Where reasonably applicable, the Contractor shall set up the borrow pit site in accordance
with the layout of the Site Plan, and must ensure all work areas, stockpiles and facility
locations are located in a manner that complies with the requirements of this EMP.
 The Contractor shall ensure that all staff remain within the boundaries of the borrow pit site,
and that all works remain within the mining parameters as specified Site Plan.
 The Contractor shall ensure that all staff are adequately informed of the requirements of
the EMP pertaining to their site role, and that they have attended an environmental
induction training session (this session must be in the form of an on-site talk and/or a
written code of conduct that is clearly explained to and understood by the team).
 The Contractor shall ensure that any subcontractors or visitors to the site are conversant
with the EMP or relevant sections of the EMP pertaining to their role on-site.
 The Contractor shall ensure that the site is rehabilitated and reinstated as per the phased
planning or closure of the Site Plan and in accordance with the requirements of this EMP.
The Site Manager:
The Mine Manager in the context of this document refers to the party responsible for overseeing
the site activities associated with the borrow pit, including the site preparation phase, the
operational phase, the reinstatement and/or rehabilitation phases and the closure of the site.
The Site Manager could, for example, be a representative of the Contractor and could act as an
agent to Roads Authority.
The Environmental Compliance Officer (ECO):
The ECO in the context of this document refers to the party responsible for the environmental
compliance and auditing activities required by the EMP for the lifecycle of the borrow pit
activities. The ECO shall be appointed by Roads Authority or MET, and the designation shall be
reserved for a suitably qualified and independent environmental manager. The ECO shall have
adequate environmental knowledge to understand the detailed environmental issues associated
with the project, and is to be well versed in the contents of the EMP and its associated reports:
 The ECO shall undertake all monitoring and auditing activities to ensure compliance with
the EMP.
 The ECO shall inspect the borrow pit site prior to any preparation activities commencing; at
least once (1) a month during operation; on completion of any progressive rehabilitation
and re-vegetation activities per phase; and on final closure of the site.
 The ECO shall compile General Progress Reports following any site inspections (including
progressive rehabilitation inspections), Compliance Reports following any non-
compliances, and a Closure Report following the conclusion of mining and eventual
closure of the site.
 The ECO shall liaise closely with the Mine Manager and Contractor, and shall provide
guidance on any environmental management issues, incidents or emergencies that are
brought to their attention.
 The ECO shall assist in the assessment and review of the Contractor’s method statements
for proposed deviations to the standard borrow pit practices detailed in the WCG
Operational Manual, or variations to the site layout as demarcated in the Site Mine Plan, or
for any activities requiring special attention as specified in this EMP and/or requested by
the Mine Manager, ECO or Competent Authority.
 The ECO shall assist in providing recommendations for remedial action in the event of any
non-compliances.
3.2 COMPLIANCE WITH REQUIREMENTS
Environmental management is not only concerned with the final results of the Contractor's
operations to carry out the Works, but also with how such operations are carried out. Tolerance
with respect to environmental matters applies not only to the finished product but also to the
standard of the day-to-day operations required to complete the Works.
The development of an EMP for a project is an important and necessary task that is aimed at
assigning responsibilities and mitigation options to a variety of activities. However, in the
absence of auditing or monitoring activities the EMP will be ineffective. Auditing or monitoring
activities involve the structured observation, measurement, and evaluation of environmental
data over a period of time. The overall responsibility to ensure that the EMP is implemented
rests with the Contractor, who shall appoint appropriate engineering, environmental and
contracting teams to undertake the work. The ECO shall inspect the site at regular intervals
during the various phases of the mining process and shall report on the level of compliance with
this EMP to Roads Authority and MET.
3.2.1 Disciplinary Action
The EMP is a legally binding document. Non-compliance with the EMP shall result in
disciplinary action being taken against the perpetrator/s. Such action may take the form of (but
is not limited to) financial penalties, legal action, fines and/or suspension of work.
The Contractor shall be deemed to have not complied with the EMP if:
 Within the boundaries of the site, site extensions and haul/access roads there is evidence
of contravention of the EMP and its associated reports.
 Environmental damage ensues due to negligence.
 The Contractor fails to comply with corrective or other instructions issued by the Site
Manager, ECO or MET within a specified time.
 The Contractor fails to respond adequately to complaints from the public.
The disciplinary action shall be determined according to the nature of the non-compliance or
crime, and exact penalties are to the discretion of the ECO and MET-DEA according to the
severity of the incident.
Measures to be implemented, overseen and monitored by the ECO during the

construction phase are outlined in the following table:
Table 3.1: Management activities to be implemented during operation and rehabilitation of the borrow sites
Aspect Management Management Action Action Indicator / Data Party responsible for
Objective Frequency Source implementation
Communication with To ensure effective All correspondence relating to Contract term (from Records of All
Contractor, and formal construction issues between the site establishment correspondence
Contractor's staff and communication Contractor and the Project to contract
other stakeholders between the Field management Team to be signed by completion) No avoidable
Team and the the Contractor's Project Manager. environmental
Contractor on any impacts occurring
The contact details of the key due to
issues throughout
construction team must be available miscommunication
all stages of the
to all relevant parties.
project.
All sub-contractors and employees The ECO is aware of
etc. must be fully aware of the ad-hoc decisions
environmental management taken by the ER and
requirements detailed in this EMP. Contractor.
The ER, Contractor and ECO must be
informed immediately should
environmental issues arise.
A copy of the EMP and ECC must be
readily available for ease of reference
to all requirements.
Staff induction training To ensure that staff All construction workers must Contract term Signed induction Contractor and ER
and code of conduct are familiar with the undergo induction training. The attendance register
management induction training must cover
requirements for the environmental awareness, protection
borrow pits and of flora and fauna, noise minimisation
behave in an on site, SHE measures and training
environmentally in safe construction.
conscious manner.
Staff operating equipment (such as
loaders, etc.) shall be adequately
trained and sensitised to any
potential hazards associated with
their tasks.
Punitive measures Contractor to adopt a disciplinary Ad hoc A reduction in the Contractor/ ECO
and incentives for system to address common, minor number of fines
Contractor's staff health and safety misdemeanours of issued daily, PM
individual staff, such as littering, not reports
using ablution facilities and illegal
collection of specimen.
Road safety and traffic To reduce the Speed limit for heavy construction Contract term Public complaints Contractor and ECO
control impacts associated vehicles shall be restricted to and non-compliance
with increase of 30km/h. register
traffic on public Keep roads off and away from
roads sensitive areas such as rocky
outcrops and sand dunes.
Provision shall be made for the

turning movements of the vehicles to
minimise disturbed areas.
Roads leading to borrow sites must
be marked with a “NO ENTRY for
public vehicles" sign.
Vehicle Emissions Reduce All vehicles and equipment shall be Contract term Physical verification Contractor
unnecessary kept in good working order and and routine
greenhouse gas serviced as required. monitoring, record of
(GHG) emissions non-compliance
from poorly
maintained or
malfunctioning
equipment
Dust Control To maintain a safe Maintain appropriate cover on Contract term Physical verification, Contractor
working overburden stockpiles to prevent record of non-
environment with wind erosion (dampen were compliance
minimised applicable).
nuisances for road Dust suppression shall take
users, prevent cognisance of water efficiency. The
damage to the Contractor shall make use of
natural vegetation environmentally friendly dust
of the area and suppression / wetting agent to
protect topsoil increase the efficacy of water
where possible. sprayed for dust suppression
purposes and thereby allow for more
efficient use.
Noise Prevention and The Contractor shall not use sound Contract term Physical verification Contractor
reduction of noise to amplification equipment on site other and routine
Peninsula users. than in emergencies. monitoring
Protection of The Contractor shall provide suitable
workers against the hearing protection to all of their staff
harmful effects of and others entering areas with high
excessive noise noise levels occur.
Visual quality Luderitz Peninsula Demarcate the borrow site working Contract term Physical verification Contractor
is frequented for its area and contain all activities within and routine
scenery. the working area. monitoring
Appropriate signage and information
posters to be prominently displayed
and maintained warn motorists about
construction activities and heavy
vehicle movement where
appropriate.
Consider visual impacts when
determining the location and size of
stockpiles.
Site demarcation Ensuring adequate The borrow site area must be kept to Contract Physical verification Contractor
planning is given to a minimum (as demarcated) and commencement and routine
the layout of the site restricted to previously disturbed monitoring
areas where applicable.
To limit the spatial Unless otherwise agreed to by the
extent over which Project Manager, the Contractor
the Contractor will shall ensure that all activities are
have influence restricted to within the defined
Working Area. The areas outside of
the defined Working Area shall be
regarded as exclusion areas. The
Contractor shall ensure that no
unauthorised entry, stockpiling,
dumping or storage materials shall
be allowed within the exclusion
areas.
Reducing health The Contractor shall ensure that
and safety and access to the site and associated
security risks infrastructure and equipment is
associated with controlled throughout the
unauthorised construction period.
access to the The movement of site staff shall be
construction site restricted to the construction site.
No onsite burying, dumping or
burning of waste material. Ensure
appropriate waste collection and
removal from the site and dispose at
the municipal dumpsite.
Stockpiling of Minimise the The Contractor shall identify sites for Contract term / daily Physical verification Contractor, ECO
overburden and potential negative stockpiling within the Working Area. and routine
storage borrow impacts arising from Remove the upper 100 to 400 mm of monitoring
materials the incorrect topsoil and store appropriately to use
stockpiling of for rehabilitation.
overburden Locate overburden stock pile areas
materials away from construction materials,
vehicle visibility or driver’s line of
site.
Stockpiled material shall be located
with consideration for the prevailing
wind directions and if required,
additional windbreaks or other
mechanisms to protect such material
from wind erosion.
Overburden material shall be used in

the rehabilitation process upon
completion with mining.
Ablution facilities Reduce health risks The contractor shall ensure Contract term / daily Physical verification Contractor and ER
and environmental adequate ablution facilities for his / ad hoc and routine
pollution arising staff. Acts of excretion and urination, monitoring
from a other than at the facilities provided,
concentration of are strictly prohibited.
human excreta in
the environment
Verification of All ablution facilities are to be
adherence to inspected on a regular basis to
specified ensure the above requirements are
requirements being met.
Heritage Resources Reduce the impacts Recovery of heritage remains or Contract term Physical verification Contractor
of construction and artefacts discovered and their
associated removal must be directed by the
earthworks on National Museum (+264 61 276800)
heritage resources. or National Forensic Laboratory
(+264 61 240461).
No artefacts must be removed or be
interfered with prior to authorisation
from the Namibian National Heritage
Council (NHC).
Mitigation must involve the scientific
recording or collection of such
artefacts.
Water Use and surface Reduce the volume Water is a scarce resource in Contract term / daily Physical verification Contractor
water resources of water needed for Namibia and shall be conserved / ad hoc and routine
construction wherever possible. The Contractor monitoring
purposes shall minimise the use of water and
shall immediately attend to any
wastage.
Reduce the Pollution could result from the
likelihood of release, accidental or otherwise, of
pollution arising contaminated runoff from discharge
from the release of of contaminated water, oils, fuels,
contaminated water sewage, runoff from stockpiles, solid
waste, litter, etc. Accordingly, the
Contractor shall establish a
contaminated water management
system as well as suitable methods
for the disposal of contaminated
water.
Protection of ecological The borrow pit Prevent and discourage the setting of Contract term Physical verification Contractor, ECO
resources excavation activities snares (poaching), indiscriminate
may have impacts killing of perceived dangerous
on vegetation and species (e.g. snakes, etc.) in and
animals in the area. surrounding the project area.
Avoid the removal of plants
(especially protected species i.e.
Lithop species [Forestry Act No. 12 of
2001) including the development of
access routes.
Natural features (e.g. rocky outcrops)
situated in or around the borrow site
shall not be defaced, painted,
damaged or marked for survey.
Vegetation shall not be unnecessarily
disturbed.
Rehabilitation To ensure All areas disturbed as a result of the Contract completion Physical verification Contractor
disturbed areas are mining activities, irrespective of and routine
returned to pre- whether they occur within the defined monitoring
construction Working Area or not, shall be subject
conditions to the requirements outlined in this
EMP.
Borrow site closure Ensure proactive rehabilitation by
and rehabilitation site staff through appropriate
objectives shall be communication and training.
communicated to all
staff.
Demolition and Prior to landscaping, the Contractor
removal of shall demolish and remove from Site
structures everything not forming part of the
Permanent Works.
Access roads to All access roads to borrow sites shall
borrow site areas be rehabilitated and closed off to
prevent entry upon end of the
contract term.
Although land can Fill the borrow site with the saved
rarely be topsoil (overburden), stabilise and
rehabilitated back to contour to blend in with the
its former natural surrounding natural landscape.
state, every effort
shall be made to The borrow site shall be finished off
address resultant in a suitable approach to facilitate
impacts. natural re-establishment of
vegetation.
Erosion and Implement measures such as
sedimentation may contours (no steep slopes) upon
result from incorrect mining conclusion to limit erosion
shaping of the site and sedimentation if and when it
and maintenance rains in the area.
4 CONCLUSION
The EMP has identified the approaches with which to manage and rehabilitate the identified
borrow sites to source road construction material from. The aim of the EMP is also to ensure
proper site closure that is considered legally compliant and environmentally acceptable.
The re-gravelling and maintenance of the identified road sections discussed herein will have
positive impacts on the safety of road users in the Luderitz Peninsula, and will ensure that local
inhabitants and visitors to Luderitz will have access to scenic areas such as Dias Point etc. The
negative impacts associated with the excavation of borrow pits can be suitably managed and
mitigated should the recommended measures to be implemented.
It is recommended that an Environmental Control Officer and suitably experienced engineer,

monitors the preparation, operational and closure / rehabilitation of the subject borrow pits so
as to ensure that the mitigation and rehabilitation measures described in this report are
adhered to.

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Registration: cc/2012/2523

Vat number: 5728293015

RE-USE OF OLD / EXISTING BORROW PITS /

ENVIRONMENTAL MANAGEMENT PLAN

Document Type Project Report

BID Reference No: TEC004/2016

General Description Project Delivery

Tortoise Environmental Consultants (TEC)

GPS Coordinates Road Works Quantity of Gravel

E-2 - 26°43'25.49"S 15° 6'14.58"E - -

E-3 - 26°42'14.95"S 15° 6'52.73"E - -

E-4 - 26°43'39.01"S 15° 6'18.67"E - -

E-24 P-12 26°41'58.00"S 15° 7'17.40"E Blending Material only -

1.1 PURPOSE OF THE EMP

The 2012 EIA Regulations define a ‘management plan’ as:

(j) a draft management plan, which includes –

Road Area Reference Distance

3 ROLE PLAYERS & THEIR RESPONSIBILITIES

3.1 ROLES AND RESPONSIBILITIES

 There are clear channels of communication;

The Site Manager:

The Environmental Compliance Officer (ECO):

3.2 COMPLIANCE WITH REQUIREMENTS

3.2.1 Disciplinary Action

Measures to be implemented, overseen and monitored by the ECO during the

Provision shall be made for the

Overburden material shall be used in

It is recommended that an Environmental Control Officer and suitably experienced engineer,

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