Trust remains firm on marine phosphate mining (Part 1)
HERBERT JAUCH, CHAIRPERSON OF THE ECONOMIC AND SOCIAL JUSTICE TRUST (ESJT) WRITES:
We have submitted a detailed objection against marine phosphate mining to the Environmental Commissioner on 17 September 2018 in the hope that the environmental clearance certificate will be set aside permanently.
Below are our submissions:
Following the decision by the Hon. Minister of Environment and Tourism to set the environmental clearance certificate aside to allow for further consultations, we wish to appeal to you to permanently cancel this environmental clearance certificate and to prevent Namibia Marine Phosphate (Pty) Ltd. from resuming operations in our country.
Our objections are based on the following grounds:
1. THE NEED TO BE CAUTIOUS AND TO FOLLOW THE PRECAUTIONARY PRINCIPLE
It is no coincidence that marine phosphate mining has not been conducted anywhere in the world, despite large deposits of marine phosphates being available in many areas. The reason is simply that risks are far too great and Namibia must not allow itself to be abused for an experiment that can have long-lasting devastating consequences. Namibia would do itself a great disfavour to accept this world-first: it would be a dubious distinction and not to our credit.
Namibia’s marine environment is unique, and recognized as one of the most biologically productive open coastal upwelling regions in the world. It is a complex, highly variable ecosystem, but vulnerable to external and internal stresses. Consequently, the delicately balanced environment necessitates careful and responsible management to maintain its productivity and sustainability for the future.
NMP has admitted that it has been forced to “rush” the project through. (See page 9 of the document “NMP EIA Comments and Responses – 30 March 2012.) We are concerned that hasty and incremental marine mining will degrade this ecosystem, which will cause damage to Namibia’s oceanic waters and which will become apparent only when it is too late to recover, and that our children will be robbed of vital and valuable seafood resource.
Consequently, adequate national protection of the marine environment requires urgent, sound ecosystem baseline research. Strict environmental monitoring procedures must be officially formulated and maintained, to specifically monitor mining activities and their impact on the marine ecosystem. We are concerned that Namibia does not have the capacity to do this, as is evident with Angolan fishing vessels being filmed traversing our waters, with Namibia’s patrol vessels apparently unable to do anything about it.
It is against this background that the United Nations supports the precautionary principle when dealing with ventures such as marine phosphate mining. The Benguela ecosystem is a fragile though highly productive, large marine ecosystem. It is based on the nutrients in the seabed which provide the basis for phytoplankton which in turn forms the base of the food web of the entire marine ecosystem. Marine phosphate mining would involve a large scale destruction of the top layer of the seabed, and such disturbances of the seabed will present a severe threat to the ecosystem as a whole and all living mechanisms that it supports.
Fisheries scientists are concerned about the foundational building blocks of the ecosystem, because micro-organisms play a major part in keeping the ecosystem in balance, and keeping dangerous substances safely buried in the sediments. Different marine microbes control most processes in the deep sediments and water column, and the balance will be changed if mining excavates different proportions of heavy metals, nutrients, and oxygen demanding compounds. The liquid environments of these micro-organisms will change – which is something our renowned Namibian Constitution absolutely forbids us to ever allow.
Environmental research at sea has been undertaken by scientists employed by Namibia Marine Phosphates (NMP) in its bid to get environmental clearance. Such research, the results and the way these are interpreted and presented, whether intentional or not, cannot be considered objective. This is a common problem with EIAs (Environmental Impact Assessments). Notably the EIA submitted by NMP does not list mitigating measures as necessary for many of the concerns raised. The EIA also admits that for some risks, no mitigation would be possible. (See page 10 of the “NMP EIA Comments and Responses – 30 March 2012.) This is a very dangerous situation, as impacts could then go ahead undetected.
We have seen that even marine diamond mining has an ecological impact and is only allowed in a few countries. In Namibia, this industry is known to have destroyed the vibrant crayfish industry Namibia used to have off Luderitz. We need to keep in mind, though, that marine diamond mining does not involve the whole-scale removal of the seabed, while marine phosphate mining will remove the entire seabed over a large area, with likely resultant severe ecological impacts.
The seabed presents many unknown factors in terms of the ecological balance and once this balance is disrupted it could take millions of years if ever, to be restored. Thus the seabed with all its nutrients which support the ecosystem as a whole, must be considered a vital and non-renewable resource. It has to be protected against ventures that are merely concerned with short term profits and are willing to sacrifice the long-term survival of the ecosystem.
In essence, marine phosphate mining will mean that nutrients from the seabed will be removed in large quantities, which will affect the entire ecosystem. There is a danger of suffocating the living organisms and there is currently no technology available to reclaim the seabed.
Also – as not much is known about the geology of the seabed - it is not known whether there may be any vents in the Namibian seabed. If they should exist and are hit by seabed trenching, there could be eruptions which would further distort the ecosystem for many generations to come. It is precisely for this reason that the precautionary principle must be applied in the case of phosphate marine mining.
New Zealand, also an important fishing nation, turned down a request for marine phosphate mining by Chatham Rock Phosphates (which is also now interested in Namibia). New Zealand is also a major farming country, using fertilisers – yet, they did not see any benefit in adding phosphate mining from the seabed.
In rejecting the request, the NZ Environmental Protection Agency Decision Making Committee (DMC) found that it was “left with a lack of certainty about the receiving environment and the adverse effects of the proposal on the environment and existing interests. In these circumstances the DMC was required by legislation to ‘favour caution and environmental protection’ when making its decision”. It added that the sea mining project was “…unlikely to generate more than a modest economic benefit to New Zealand and that the quantum and distribution of that benefit were uncertain.
2. GREAT DANGERS FOR THE FISHING INDUSTRY
Fish is a renewable resource, provided the breeding grounds are healthy and the fishing industry is sustainably managed. The key argument is that as long as there is a reasonable level of uncertainty regarding possible damage to the ecosystem and thus also the fishing industry, marine mining cannot be allowed in Namibia.
Some of the main concerns of the fishing sector with regard to proposed marine phosphate mining activities include:
• Effects on breeding of major commercial fish species. Fish have specific breeding areas, which risk being permanently destroyed.
• Effects on ecosystem: microbial processes, bottom-living animals, food web and diet species of commercial fish.
• Change in sea bottom habitat (as mining will be total removal of seabed to a sediment depth of 1-3 metres).
• Effects of suspended sediment cloud (plumes), potentially including clogging of fish gills, poisoning, oxygen depletion and smothering of young fish in their breeding and nursery grounds.
• Effects on fishing activities: fishing grounds stretch across the length of the coast.
• Water quality from both mining (deep water) and processing (shallow water): e.g. suspended heavy metals and other contaminants, nutrient imbalance, reduced oxygen, possibly release of methane and hydrogen sulphide.
• Possibly unsafe radiation levels associated with the uranium content of marine phosphates, both at mining sites and from processing effluents.
• Effluent and waste from marine phosphate land based processing affecting all near-shore marine biota.
• Impact on quality of fishery and marine products, affecting food-safety levels for human consumption.
Current research by Dr. Jean-Paul Roux of the Ministry of Fisheries and Marine Resources, including analysis of seal faeces, has shown that the main nursery areas for young hake covers the inshore areas south of Walvis Bay all the way to Lüderitz, meaning that these valuable fish are concentrated in the same areas as the mining licenses (between 24 degrees S and 26 degrees S). These young hake are between 5 and 20 centimetres in length and are found in mid-water. The 2 mining licences so far issued are exactly in this area.
NMP proposes mining in an area south of Walvis Bay and since the areas likely to be mined are close to the 200 metre depth restriction, there is potential direct overlap with marine mining impacting on valuable juvenile fish.
Impact on critical ecosystem areas such as fish breeding and nursery grounds is a serious concern that would not immediately be apparent, because young fish, by fisheries law, are not allowed to be caught, so that only when the adult fish populations decrease, would the effect become obvious. Hake are caught when they are several years old, therefore it is obvious that it takes years and decades before such mining impacts would be revealed. Marine food webs are complicated. By then it will likely be too late to reverse the damage. When the impact becomes apparent, harm to fishing grounds and fish stocks may have become irreversible.
We have submitted a detailed objection against marine phosphate mining to the Environmental Commissioner on 17 September 2018 in the hope that the environmental clearance certificate will be set aside permanently.
Below are our submissions:
Following the decision by the Hon. Minister of Environment and Tourism to set the environmental clearance certificate aside to allow for further consultations, we wish to appeal to you to permanently cancel this environmental clearance certificate and to prevent Namibia Marine Phosphate (Pty) Ltd. from resuming operations in our country.
Our objections are based on the following grounds:
1. THE NEED TO BE CAUTIOUS AND TO FOLLOW THE PRECAUTIONARY PRINCIPLE
It is no coincidence that marine phosphate mining has not been conducted anywhere in the world, despite large deposits of marine phosphates being available in many areas. The reason is simply that risks are far too great and Namibia must not allow itself to be abused for an experiment that can have long-lasting devastating consequences. Namibia would do itself a great disfavour to accept this world-first: it would be a dubious distinction and not to our credit.
Namibia’s marine environment is unique, and recognized as one of the most biologically productive open coastal upwelling regions in the world. It is a complex, highly variable ecosystem, but vulnerable to external and internal stresses. Consequently, the delicately balanced environment necessitates careful and responsible management to maintain its productivity and sustainability for the future.
NMP has admitted that it has been forced to “rush” the project through. (See page 9 of the document “NMP EIA Comments and Responses – 30 March 2012.) We are concerned that hasty and incremental marine mining will degrade this ecosystem, which will cause damage to Namibia’s oceanic waters and which will become apparent only when it is too late to recover, and that our children will be robbed of vital and valuable seafood resource.
Consequently, adequate national protection of the marine environment requires urgent, sound ecosystem baseline research. Strict environmental monitoring procedures must be officially formulated and maintained, to specifically monitor mining activities and their impact on the marine ecosystem. We are concerned that Namibia does not have the capacity to do this, as is evident with Angolan fishing vessels being filmed traversing our waters, with Namibia’s patrol vessels apparently unable to do anything about it.
It is against this background that the United Nations supports the precautionary principle when dealing with ventures such as marine phosphate mining. The Benguela ecosystem is a fragile though highly productive, large marine ecosystem. It is based on the nutrients in the seabed which provide the basis for phytoplankton which in turn forms the base of the food web of the entire marine ecosystem. Marine phosphate mining would involve a large scale destruction of the top layer of the seabed, and such disturbances of the seabed will present a severe threat to the ecosystem as a whole and all living mechanisms that it supports.
Fisheries scientists are concerned about the foundational building blocks of the ecosystem, because micro-organisms play a major part in keeping the ecosystem in balance, and keeping dangerous substances safely buried in the sediments. Different marine microbes control most processes in the deep sediments and water column, and the balance will be changed if mining excavates different proportions of heavy metals, nutrients, and oxygen demanding compounds. The liquid environments of these micro-organisms will change – which is something our renowned Namibian Constitution absolutely forbids us to ever allow.
Environmental research at sea has been undertaken by scientists employed by Namibia Marine Phosphates (NMP) in its bid to get environmental clearance. Such research, the results and the way these are interpreted and presented, whether intentional or not, cannot be considered objective. This is a common problem with EIAs (Environmental Impact Assessments). Notably the EIA submitted by NMP does not list mitigating measures as necessary for many of the concerns raised. The EIA also admits that for some risks, no mitigation would be possible. (See page 10 of the “NMP EIA Comments and Responses – 30 March 2012.) This is a very dangerous situation, as impacts could then go ahead undetected.
We have seen that even marine diamond mining has an ecological impact and is only allowed in a few countries. In Namibia, this industry is known to have destroyed the vibrant crayfish industry Namibia used to have off Luderitz. We need to keep in mind, though, that marine diamond mining does not involve the whole-scale removal of the seabed, while marine phosphate mining will remove the entire seabed over a large area, with likely resultant severe ecological impacts.
The seabed presents many unknown factors in terms of the ecological balance and once this balance is disrupted it could take millions of years if ever, to be restored. Thus the seabed with all its nutrients which support the ecosystem as a whole, must be considered a vital and non-renewable resource. It has to be protected against ventures that are merely concerned with short term profits and are willing to sacrifice the long-term survival of the ecosystem.
In essence, marine phosphate mining will mean that nutrients from the seabed will be removed in large quantities, which will affect the entire ecosystem. There is a danger of suffocating the living organisms and there is currently no technology available to reclaim the seabed.
Also – as not much is known about the geology of the seabed - it is not known whether there may be any vents in the Namibian seabed. If they should exist and are hit by seabed trenching, there could be eruptions which would further distort the ecosystem for many generations to come. It is precisely for this reason that the precautionary principle must be applied in the case of phosphate marine mining.
New Zealand, also an important fishing nation, turned down a request for marine phosphate mining by Chatham Rock Phosphates (which is also now interested in Namibia). New Zealand is also a major farming country, using fertilisers – yet, they did not see any benefit in adding phosphate mining from the seabed.
In rejecting the request, the NZ Environmental Protection Agency Decision Making Committee (DMC) found that it was “left with a lack of certainty about the receiving environment and the adverse effects of the proposal on the environment and existing interests. In these circumstances the DMC was required by legislation to ‘favour caution and environmental protection’ when making its decision”. It added that the sea mining project was “…unlikely to generate more than a modest economic benefit to New Zealand and that the quantum and distribution of that benefit were uncertain.
2. GREAT DANGERS FOR THE FISHING INDUSTRY
Fish is a renewable resource, provided the breeding grounds are healthy and the fishing industry is sustainably managed. The key argument is that as long as there is a reasonable level of uncertainty regarding possible damage to the ecosystem and thus also the fishing industry, marine mining cannot be allowed in Namibia.
Some of the main concerns of the fishing sector with regard to proposed marine phosphate mining activities include:
• Effects on breeding of major commercial fish species. Fish have specific breeding areas, which risk being permanently destroyed.
• Effects on ecosystem: microbial processes, bottom-living animals, food web and diet species of commercial fish.
• Change in sea bottom habitat (as mining will be total removal of seabed to a sediment depth of 1-3 metres).
• Effects of suspended sediment cloud (plumes), potentially including clogging of fish gills, poisoning, oxygen depletion and smothering of young fish in their breeding and nursery grounds.
• Effects on fishing activities: fishing grounds stretch across the length of the coast.
• Water quality from both mining (deep water) and processing (shallow water): e.g. suspended heavy metals and other contaminants, nutrient imbalance, reduced oxygen, possibly release of methane and hydrogen sulphide.
• Possibly unsafe radiation levels associated with the uranium content of marine phosphates, both at mining sites and from processing effluents.
• Effluent and waste from marine phosphate land based processing affecting all near-shore marine biota.
• Impact on quality of fishery and marine products, affecting food-safety levels for human consumption.
Current research by Dr. Jean-Paul Roux of the Ministry of Fisheries and Marine Resources, including analysis of seal faeces, has shown that the main nursery areas for young hake covers the inshore areas south of Walvis Bay all the way to Lüderitz, meaning that these valuable fish are concentrated in the same areas as the mining licenses (between 24 degrees S and 26 degrees S). These young hake are between 5 and 20 centimetres in length and are found in mid-water. The 2 mining licences so far issued are exactly in this area.
NMP proposes mining in an area south of Walvis Bay and since the areas likely to be mined are close to the 200 metre depth restriction, there is potential direct overlap with marine mining impacting on valuable juvenile fish.
Impact on critical ecosystem areas such as fish breeding and nursery grounds is a serious concern that would not immediately be apparent, because young fish, by fisheries law, are not allowed to be caught, so that only when the adult fish populations decrease, would the effect become obvious. Hake are caught when they are several years old, therefore it is obvious that it takes years and decades before such mining impacts would be revealed. Marine food webs are complicated. By then it will likely be too late to reverse the damage. When the impact becomes apparent, harm to fishing grounds and fish stocks may have become irreversible.
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