Fishing and Phosphate can Co-Exist

Recent media reports and activist groups have alleged that the proposed development of the Sandpiper Marine Phosphate Project (“Sandpiper Project”) in ML170 by Namibian Marine Phosphate (Pty) Limited (“NMP”) will have a “catastrophic and detrimental impact” on both the Namibian fishing industry and marine environment. Some have claimed that the seabed mining for phosphates will “kill the fishing industry.” These claims are grossly exaggerated and factually untrue.

In Summary:

1. Independent environmental experts have concluded from factual data and studies in ML170 that the

Sandpiper Project will have no significant impact on the marine environment or the commercial fishing industry at the proposed scale of operations. None of these experts have indicated that phosphate mining will or could kill the fishing industry. 2. 14 environmental studies have been conducted to date as part of the Environmental Impact Assessment

(EIA) process, and the results have been submitted to independent review by the Environmental Commissioner on 4 separate occasions. 3. The independent reviews support the findings that marine phosphate mining in Namibia will have no

significant impact on the environment and the fishing industry. 4. Seabed mining currently co-exists with the bottom trawl fishing industry. Evidence from Namdeb’s studies

over the past 20 years confirms that the seabed is recovering after the excavation for mineral extraction. 5. No formal or legally valid moratorium currently exists regarding the marine mining of phosphates. 6. NMP welcomes the opportunity to formally address NASAWU and SPYL’s concerns that were recently raised

in the public arena.

Facts

The mining licence issued to the Sandpiper Project covers an area of 2,334km2. However, NMP intends to conduct dredging operations in a specific area: SP1 (60km2) which represents a small portion of ML170. The SP1 area has been specifically selected after extensive studies noting that:

NMP will

Not Kill the Fishing

 The area represents a minute percentage of the continental shelf area and is of such a small scale on a regional basis that the planned operations will have no detrimental impact or interfere with commercial fishing operations.

Industry

 The area is situated in water depths deeper than 200m, thus avoiding the:

o protected no trawling fish spawning zone o mud belt and associated Sulphur-charged sediments that are closer to shore

 Mineral resources in NMP’s SP1 area are sufficient to support mining for the first 20 years. This means, annually, NMP will affect only 2.5km2 of the seabed in comparison to the much larger areas impacted by marine diamond mining or bottom trawling.

Environmental

NMP has completed a comprehensive Environmental Impact Assessment (“EIA”), and its findings were independently reviewed on 4 occasions at the request of the Environmental Commissioner. These external reviews have endorsed the EIA’s findings in the position that at the scale of proposed operations, phosphate mining will have no significant impact, so therefore will not be detrimental on the marine environment or the commercial fishing industry. These reports are publically available from the Ministry of Environment and Tourism (“MET”).

Impact Assessment

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Environmental

The target area for dredging phosphate sand is small on a regional scale, and consequently any adverse environmental impacts can be appropriately managed through the comprehensive and legally binding Environmental Management Plan (“EMP”).

The cumulative impact will cover an area of approximately 60km2 over the 20-year life of mining. By comparison, in the 10-year period from 1998 to 2008, the estimated cumulative area of seabed diamond mining was already around 50km2.

Excellent Regulatory

Management

Plan

Once issued, all Environmental Clearance Certificates (“ECC”) are subject to a 3-year renewal process. So, any digressions by NMP from their Environmental Management Plan or the terms of the ECC during the current period will impact the consideration for the ECC renewal.

Cost To date, NMP has spent in excess of N$28.7m on environmental studies and will continue to fund environmental work as required to ensure the environment is understood and protected.

Fishing and Phosphate Marine Mining Can Co-Exist

All facts from onsite and regional studies conclude that the Sandpiper Project will not “kill the fishing industry,” as claimed. Also, strong evidence from those studies confirm that marine phosphate mining operations can co-exist with fishing just as fishing already does with the existing marine diamond mining operations.

There is No Moratorium on Marine Phosphate Mining

On national radio in August, the Hon. Minister Essau expressed his opinion that there is still a moratorium on the mining of marine phosphates in Namibia. This is not correct. The 18-month moratorium to which the Hon. Minister Essau refers is the Cabinet decision in September 2013, which expired in March 2015. The moratorium was never formally legislated, never notified formerly to the proponents, and never implemented by the Minister of Mines and Energy under the provisions of the Minerals Act 1992 nor was it gazetted, as required by the Namibian constitution.

NASAWU is Invited to Submit Scientific Concerns

NMP understands that the Namibia Seaman and Allied Workers Union (NASAWU) called its members to support a mandatory demonstration against phosphate mining in September 2019, which included a declaration that phosphate mining “will kill the fishing industry.” It appears NASAWU missed the opportunity to submit scientific concerns to the MET during the public consultation period from July to September 2018, as regulated. However, NMP welcomes the opportunity to address all of NASAWU’s questions in a formal setting. This invitation is also extended to the Swapo Party Youth League who made similar claims and expressed similar concerns in a media statement last month.

Public Consultation Process

The public consultation process defined by the MET and the office of the Environmental Commissioner in June 2018 was completed in December 2018. This public consultation process included a 3-month period for submission of public comment on NMP’s application for an Environmental Clearance Certificate, which was then followed by a 3- month period of review.

Practices

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14 Scientific Studies Conclude: No Significant Impact on the Marine Environment

In any of the independent expert reports completed to date, there is absolutely no suggestion or indication that the proposed phosphate dredging operations will in any way cause “catastrophic damage to the environment” or “kill the fishing industry.”

Furthermore, 14 environmental studies have been completed as part of the EIA process, which concluded that the Sandpiper Project will have no significant environmental impact on the marine environment in which the project is situated. Supporting Namibia’s mandate to protect the ocean, NMP enlisted internationally renowned scientists to conduct these studies, costing in excess of N$28.7 million, and ensured all the experts have worked in some capacity on the Benguela Coastal System.

As compared to fish bottom trawling which affects over 18,000km2 of the seabed annually, the Sandpiper Project will affect only 2.5km2 each year. NMP reiterates, findings of factual environmental reports based on data from the site conclude that the scale of operations will have no significant impact on the marine environment overall and will not have a deadly effect on the fishing industry.

NMP and the Sandpiper Project will not harm nor kill the fishing industry and the emotive statements claiming this are unfounded.