Key points
- NMP responds to what it calls non-factual media comment on its clearance certificate application.
- The company says it has met every reasonable request for environmental and scientific study since 2011.
- NMP says it has followed Namibia’s regulatory path for environmental impact assessment and stands by the results.
NMP are looking to address the non-factual comments circulating in the media surrounding the application for the Sandpiper Marine Phosphate Project (Sandpiper Project) Environmental Clearance Certificate (ECC). Since 2011, NMP have fulfilled every reasonable request made for inclusion in the environmental and scientific studies required to be granted the ECC. .
- NMP have and will always put consideration of Namibia’s marine environment and statutory requirements first.
- NMP have followed Namibia’s regulatory path for environmental impact assessment and stands by the results and conclusions of the various independent consultants and specialists’ environmental studies.
- Numerous scientific studies of the data from the site support expert opinion that the Sandpiper Project will not “kill or detrimentally impact the fishing industry,” as has been circulated in the media.
- The Sandpiper Project will operate transparently and be openly accountable in compliance with all relevant legislation, in the same way that the marine diamond industry has been since the start of mining operations.
- There is firm evidence that the seabed does, in fact, recover after seabed mining, as presented in the 2008 BCLME study by Pisces Environmental Consultants on the cumulative environmental impacts of Namibia’s marine diamond mining operations over a 10-year period. How Many Environmental Studies Have Been Conducted?
In accordance with the Namibian Environmental Act, the following studies and consultations have taken place:
1. The Environmental Impact Assessment (EIA) and Public Consultation process commenced in 2011, and the application for the ECC was submitted in 2012.
2. Through these processes, the Verification Programme was developed most notably to address concerns raised by the Ministry of Fisheries and Marine Resources. Concluded in 2014, the Verification Report noted:
3. On their own, NMP decided to commission a Peer Review Process in 2014 – not a requirement of the Environmental Act. Using independent consultants, the Review concluded:
The EIA included and followed up with a number of Public and Stakeholder consultation processes.
NMP were requested by the Ministry of Environment and Tourism, Environmental Commissioner, and the Ministry of Fisheries and Marine Resources to carry out a Verification Study.
“The Verification Programme has enabled the level of confidence in the original assessments made in the EIA 2012 to be raised from medium to high. The Verification Programme Report and the integrated independent reviews have determined that there are no identified ecological risks of a significant nature that would preclude the project from being authorized. Ongoing monitoring of the assessed impacts is required as a mitigation, management and intervention tool, with responsibilities for this lying with both the proponent and the authorities.”
“The review team is impressed by the quality of the information provided to it and believes that all avenues and disciplines of concern relating to the proposed operation in SP-1 have been addressed adequately.”
“The policy decision on whether to proceed is a national one, but we can say that the information provided to us has convinced us that everything points to there being a minimal impact of the proposed operation, should a licence be granted, to the Namibian shelf ecosystem.”
4. The Environmental Management Plan (EMP) evolved through the various consultations in 2012, 2014, and 2016, which addressed all the points raised. The EMP consists of various monitoring recommendations as proposed by the various consultants to ensure that any potential impact to the Namibian marine environment is well understood.
Independent Consultants Stand by Their Work
✓ It is a requirement of Namibian regulations that any party seeking an Environmental Clearance
Certificate must appoint an Environmental Practitioner to conduct the EIA, including specialist consultants, and pay the cost. Equally, the same party must also cover the cost of any External Review commissioned by the Environmental Commissioner.
✓ The consultants chosen are all internationally renowned and reputable individuals and organisations,
who are often requested by the Namibian Government to assess and work on the Benguela marine ecosystem. These consultants all have relevant experience and specialist knowledge of the Benguela Current Large Marine Ecosystem (BCLME).
✓ NMP is completely transparent – all of the extensive environmental studies and reports have and will
continue to be available on NMP’s website, or through the office of the Minister of Environment and Tourism.
Namibia’s Environment is Important to NMP
To ensure credibility of the scientific work carried out by the selected consultants appointed under the management of the Environmental Assessment Practitioner, NMP proactively elected to allow the Environmental Practitioner to commission an Independent Peer Review of the environmental impact assessments, using internationally published industry specialists who are reputable and also leaders in their fields of expertise.
In addition, the Environmental Commissioner completed 3 separate independent external reviews of the EIA under the provisions of the Environmental Act 2007, all of which effectively concluded that there is no reason why the project should not proceed subject to the recommendations they provided.
The Sandpiper Project will be operated transparently and be fully openly accountable and compliant with all relevant legislation, in the same way that the marine diamond industry has been since mining operations began.
The 2008 BCLME Report on the Cumulative Impacts of Seabed Mining over a 10-year period provides firm evidence that the seabed does recover after excavation and without any significant impact to the commercial fishing industry.
Based on these studies and the EMP’s research, it is clear that the emotive statement that the Sandpiper Project will “kill or detrimentally impact the fishing industry” is scientifically unsupported.