Key points
- NMP makes the case that phosphate dredging and fishing can co-exist in Namibian waters.
- The company argues both activities affect the marine environment and share responsibility for protecting it.
- The statement responds to commentary in the press and on social media.
The case for co-existence
In order to provide balance and perspective to current discussion and comments in the social media and press, Namibian Marine Phosphate Pty Limited (“NMP” or “the Company”) wishes to address the issue of co-existence between the activities of fishing and dredging of marine phosphatic sediments in Namibia.
Case for Coexistence The case for co-existence requires fair and open acknowledgment of the common impacts of both activities and the shared responsibility of all ocean industries to protect the marine environment. It also requires acknowledgment that management of the marine environment should be assessed and governed under a common set of fair and equitable standards in full compliance with the Namibian environmental legislation.
There are clear parallels between marine dredging, mining and fishing activities that in fact underpin a strong case for coexistence of fishing and marine phosphate dredging and for collaboration in environmental management activities in the ocean off Namibia. These parallel impacts have not been openly discussed in the media to any substantive level.
Those opposed to or advising against the development of the Sandpiper Marine Phosphate Project (“the Project”) are attempting to portray the issue as a” stand-off” between phosphate dredging and fishing, stating the position that “only one or the other” can exist. In reality, the data from site specific scientific studies and local evidence from the current fishing/trawling activities show clearly that this is not the case.
It is also both unfair and unreasonable to apply a “double standard” by imposing a requirement for higher levels of environmental knowledge, compliance and performance in assessment of the proposed phosphate dredging in comparison to those applied to the fishing industry.
Neither should the issue of phosphate and fishing be hi-jacked by those parties with vested interests or agendas to protect their individual interests nor those of one particular existing industry sector over the development of a new industry.
The real core of the issue is the mutual responsibility of developing all of Namibia’s natural marine resources to their fullest potential for the National benefit.
To achieve this vision it requires willingness and commitment for the co-existence of both new and existing marine resource industries along with implementation of a set of mutually fair and sound Environmental Management Practices which can ensure the protection and sustainability of the Namibian marine environment.
A “one or the other” mindset The mindset that “you can only have either one or the other – not both” which is put forward by certain parties opposed to or cautioning against the development of the Project is argued on the basis that “a viable fishing industry cannot exist in Namibia together with phosphate dredging” because dredging of phosphatic sediment is a disruptive exercise that will harm the seabed and marine environment through the generation of potentially toxic suspended sediment plumes and benthic habitat destruction that will ultimately threaten the viability of the fishing industry.
This argument is fundamentally flawed.
Firstly, for the parties promoting this position, the uncomfortable truth of the matter is that not one grain of phosphate has been dredged from the ocean however the seabed and marine environment off the Namibian coast is already being exposed to these disruptive activities at a significant scale in the form of the current fishing (trawling) and marine diamond mining operations.
In the statement issued on 7th July 2016 the Confederation of Namibian Fisheries Associations (“CNFA”) has publically acknowledged that current bottom trawling off the coast of Namibia does disrupt the sea floor. No comment is provided by CNFA on the scale or environmental impacts of the seabed disruption from trawling. However CNFA does state that “The South African hake trawling sector has been operating for 120 years without any significant adverse environmental effects”.
Secondly, it is already a globally established and a scientifically supported fact that there are significant parallels between the activities and the impacts of both fishing (bottom trawling) and dredging. Both dredging and bottom trawling cause a disruption of the seabed with consequential impacts on the marine habitats and ecosystem1 through the generation of re-suspended sediment plumes and benthic habitat disruption.
If , as CNFA states, the trawling industry is not affected by the disruptive effects of trawling across the continental shelf off Namibia , then why should the effects of a localised dredging operation pose any additional or greater risk to the fishing industry?
The “World First Phosphate Mining” misconception – The activity referred to as “Marine Phosphate Mining” that is proposed in Namibia is effectively a deep-water dredging operation to recover the phosphate bearing sediment, off the sea floor. The phosphate is contained within the sand particles in the seabed sediment which comprises a mixture of mud, sand and shelly gravel. Dredging is not a new or “world first” activity and has in fact been undertaken for more than 100 years in oceans around the world. Sediments recovered by dredging are deposited onshore and
are typically used for land fill for coastal construction, shoreline protection or for construction material.
In specific cases the sediments recovered by dredging are utilised for accessing their mineral content such Calcium Carbonate (for cement or aluminium refinery), diamonds, and iron or in this particular case phosphate. The dredging activity is then referred to as some form of sea mining such as marine diamond mining, or marine iron sand mining or marine phosphate mining. Regardless of the “mining” connotation attached, the process undertaken remains essentially a dredging activity. Dredging in shallow or deeper water does also not change the fundamentals of the operation. The actual “world first” component is one of the technical risk associated with the extension of the dredge arm from current 165m depth capability to access the seabed at depths of greater that 200m. The alleged implications of “world first” and “phosphate mining” are utilised in certain instances to over-exaggerate the potential significance or impact of the basic dredging operations as proposed.
Habitat and scale of operations Hake and Monk fish are the targeted commercial fishing species off the Namibian coast and both species are fished using bottom trawling nets and equipment. The Hake and Monkfish populations are bottom dwellers that exist on the seabed comprising the very same phosphate bearing sediments that will be targeted for phosphate dredging.
The 2012 EIA study noted that a fleet of approximately 100 Namibian demersal/bottom trawlers are registered to operate within Namibian waters. The Demersal fishing trawler fleet operates along the entire length of the Namibian coast in water depths of 200 to 500m. The ocean area off Namibia is 580,000km2 (FAO website country profile).
By comparison, for the Project in question one dredger is proposed to operate over the period of 20 years in the 60km2 target mining area (SP1) within ML170 which represents a very small fraction (0.01% or 1/100th of a percent) of the 580,000 km2 ocean area and l fishing grounds off Namibia.
The SP1 area lies entirely outside the commercial hake and monkfish grounds. The Project EIA has assessed a zero percent (0%) operational impact on the commercial hake and monkfish grounds within the SP1 area. In addition, there are no horse mackerel fishing operations in the entire ML170 area.
The Key Issue and the Common Impacts: The primary issues raised by fishing industry and activist groups against the proposed dredging of phosphatic seabed sediments (sand, mud and shell) are those of 1) the potential “toxicity of sediment plumes” and 2) “seafloor habitat destruction” and their potential for a catastrophic impact on fish stocks and ecosystem.
The potential impacts of the sediment plume and habitat disturbance arising from the proposed dredging for phosphatic sediments has been comprehensively evaluated in the Project Environmental Impact Assessment (“EIA”) 4 and subsequent Verification Study
completed as proposed in the Environmental Management Plan for the project. The effects were assessed at a high level of confidence to be of little or no impact on the fishing industry or environment at the proposed scale of the operation.
There are also numerous scientific studies that have definitively documented the disruptive impacts of bottom trawling the seabed resulting in disturbance of the surface sediments, habitat destruction and re-suspension of sediments generating large plumes of suspended sediments behind the bottom trawling net and equipment.
The Project’s phosphate dredging activities will affect an area of approximately 3km2 per year.
Marine diamond mining operations by Namdeb are estimated to affect an area of 10 – 14km2 per annum.
Currently, there is no available quantitative assessment of the scale of annual seabed disturbance area or the quantity of the re-suspended sediment load in the plumes generated annually from fishing/bottom trawling operations operating in Namibia.
However information referenced for the Sandpiper Project EIA specialist studies indicates that single trawl tracks for hake and/or monkfish are regularly 20-25km long and nets vary in width up to 30m. This represents a total surface disturbance area of 0.75Km2 per single trawl of 25km. Trawlers each run several trawls per day until their respective quotas have been filled.
A Greenpeace report on New Zealand fisheries notes that a single fishing vessel can trawl about 10 km2 of seabed every day .2
With regard to the potential re-suspended sediment load contained in plumes generated by trawling, there is scientific information published in 20101 from a study conducted in Grenlandsfjord, Norway that concluded that “5 tonnes of sediment was put into suspension over a 2 km trawl track with a trawl width of 25m.” This equates to 2.5 tons of suspended sediment per 1 km of trawl track. Release of toxins contained in the sediment pore waters was also recorded as a consequence of trawl generated sediment plumes.
Based on the data from the Norwegian study then, a single trawl track 25m wide and 25 km long would have generated 62.5 tons of suspended sediment load.
Clearly then, there is therefore likely to be a significant annual cumulative area of seabed disturbance and resultant load of suspended sediment generated from activities of multiple trawlers operating across the Namibian continental shelf.
The current status quo of the Namibian hake and monkfish populations, as well as the fishing industry as a whole are apparently not being adversely impacted by the current annual or cumulative effects of the suspended sediment plumes and seabed disturbance
generated by the activities of the Namibian bottom trawling fleet. If that is the case then why would it be any different for the smaller foot print of seabed disturbance created by the phosphate dredging?
Applying Double Standards A fair consideration for co-existence of fishing and dredging operations cannot be objectively assessed if “double standards” are being applied when it comes to considering the two activities, effectively advocating one standard for the fishing industry and another standard for phosphate mining industry when it comes to requirement for environmental studies and compliance with the Environmental Act 2007.
CNFA and others are quick to caution that “the potential environmental risks of the Sandpiper Project …cannot be highlighted enough” and state further that “This is why we are emphasising the absolute necessity for a research imposed Strategic Environmental Assessment (SEA) on the expected cumulative impacts from marine phosphate mining. This SEA needs to be carried out in order to understand the environmental cumulative and long- term implications before any decision is taken on whether or not to go ahead with mining”.
But this position taken by CNFA on this requirement for protection of the environment is both cynical and questionable as a double standard given the further uncomfortable truth that:
1) no such equivalent SEA has either been done or published by the fishing industry on the expected cumulative effects of bottom trawl fishing on the Namibian marine ecosystem
2) fishing is currently not a gazetted listed activity under the regulations of the Environmental Act of 2007 and hence fishing companies are not required to conduct EIA’s for bottom trawling activities to assess environmental and ecosystem level impacts
3) the Orange Roughie deep water trawl fishery was undertaken in sensitive deep water environments off Namibia apparently without adherence to Food and Agriculture Organisation of the United Nations (FAO) guidelines for identification and mapping of Vulnerable Marine Ecosystems(VME’s), despite the recorded recovery during trawling operations of VME indicators such as deep water sponges, corals and presence of localised seamounts3.
On a global basis, there are well defined measures to define and manage the negative impacts from dredging, however it is documented that limited attention has been paid to the effects of plumes generated by trawling sediment in the management of fisheries1.
In Namibia, an Environmental Impact Assessment, Environmental Management Plan and Environmental Clearance Certificate is required for any dredging/mining operation to be undertaken. No such requirement currently exists for conducting bottom trawling activities.
Fortunately, this situation is set to change. Namibia seems set to continue as a world leader in the area of marine environmental management with the recently proposed amendments to the Environmental Management Act 2007 and regulations for
Environmental Impact Assessments in which all commercial fishing activities are included as a Category A scheduled activity, requiring full public participation EIA’s and management plans.
Presumably the Competent Authority will require the commercial fishing companies to comply with the same comprehensive levels of environmental assessment that they imposed on the Sandpiper Project and its proponent.
To Conclude The facts, which are well documented internationally as well as the circumstantial evidence reject the argument that the proposed phosphate dredging (or marine phosphate mining) is somehow potentially more disruptive to the marine ecosystem than that of bottom trawling activities currently being carried out by the fishing industry.
Why then should Namibia be forced into a situation of having to choose between “one or the other” industries when the experts opinion and the circumstantial evidence indicate strongly that there are no substantive reasons why these activities should not be able to co-exist and be equitably managed under the provisions of the Environmental Management Act of 2007?
References:
1. Durrieu de Madron, X., B. Ferré, G. Le Corre, C. Grenz, P. Conan, M. Pujo-Pay, R. Buscail, and O. Bodiot. 2005. Trawling-induced resuspension and dispersal of muddy sediments and dissolved elements in the Gulf of Lion (NW Mediterranean). Continental Shelf Research 25:2387-2409.
2. Weeber, B. (2007b). Best Fish Guide 07 – 08 – Part Two: Criteria for ecological rankings of New Zealand commercial fisheries. Royal Forest and Bird Protection Society of New Zealand, November 2007 in: Greenpeace New Zealand,2009 , While stocks Last, Dr Maj De Poorter, Greenpeace New Zealand Publication
3. DEEPFISHMAN,A FP7 Project: Management and Monitoring of Deep-sea Fisheries and Stocks WP2 – Template for Case Study Reports
4. Namibian Marine Phosphate 2012. Sandpiper project Environmental Assessment Report, Appendix 1.
