Trust remains firm on marine phosphate mining (Part 2)
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:
3. NO PROPER PROCEDURES WERE FOLLOWED
The Hon. Minister of Fisheries and Marine Resources has stated clearly that the Ministry is opposed to marine phosphate mining in Namibia due to the great risks and many unanswered questions about its likely impact. It is important to note that the Ministry of Fisheries and Marine Resources did not receive an application from Namibia Marine Phosphate (Pty) Ltd for an environmental clearance certificate as required in terms of the Environmental Management Act (No 7 of 2007).
Furthermore, the Minister did not prescribe conservation measures as outlined in the Act.
It is worth mentioning that the Environmental Commissioner’s Office was seemingly provided with a report by Dr. Peter Tarr from the SAIEA in which he alluded that stakeholders did not have enough time to engage meaningfully. He stated that the most affected stakeholders were the Ministry of Fisheries and Marine Resources as well as fishing industry. He further acknowledged that the ocean is a “public resource” and justified public interest in the matter on this basis.
The significance of the public having a fundamental interest and right in this matter has further been cemented by a judgement delivered through Judge Festus Uitele when Michael Gaweseb’s appeal was challenged on the basis of legal standing. The judge confirmed that he as member of the public had standing.
It is thus clear that there has been inadequate opportunities for the public to engage the Environmental Commissioner and to participate in the proceedings leading to the granting of the environmental certificate for NMP.
We can recall that you expressed reservations in the studies provided to your office and that you called for a study by an oceanographer as indicated in your letter of 09 November 2015 addressed to NMP. The letter stated that you wanted a “verification report to be reviewed by an experienced Oceanographer in the region with an understanding of the Benguela current system”.
Since there has been no evidence that the marine component as identified by your good office was studied it is clear that there is still a high risk of consequences for the marine life as a consequence of marine phosphate mining.
4. LABOUR CONCERNS
The Namibian fishing industry, from latest available employment figures, in 2016 directly employed 16 800 people - many of them women, and nearly all of them Namibians. The number of indirect jobs is around 60 000.
In 2015, according to the Namibian Statistics Agency, it exported Namibia N$7.03 billion in seafood exports, valuable foreign exchange for the country. Few industry sectors in Namibia can match these figures.
It needs to be said that international prices for mined minerals are widely known to be fluctuating and generally offer dubious investments. Marine phosphate mining is only one potential sector in Namibia’s mining industry.
It would rely on massive dredgers, rather than people, to do most of the work, and many of those to be employed will require skills not currently available in Namibia.
While there is talk of creating a phosphoric acid/fertilizer processing plant in Lüderitz, those currently employed by fish processing plants in Lüderitz and indirectly through the ports authority, Namport, where the fish are landed, are already key contributors to the Lüderitz economy. It would make no sense for a marine phosphate industry to be established in Lüderitz, with unproven prospects, threatening to replace the fishing industry as it slowly fades away due to environmental degradation.
Namibia cannot seriously consider replacing its valuable fishing grounds with doubtful mine pits in the ocean.
5. THE PHOSPHATE MINING MORATORIUM
The Namibian government imposed a phosphate mining moratorium in an attempt to solicit independent research, with mining companies now arguing that the moratorium timeline has expired and that they should be allowed to start mining.
So far during the moratorium period, an independent Norwegian organization, SINTEF, linked to the Norwegian Institute of Marine Research (IMR), has done a scoping study for a Strategic Environmental Assessment (SEA) and identified the need for further research to fill knowledge and regulatory gaps. This needs to be urgently followed by a Strategic Environmental Assessment to address the significant degree of unknown environmental impacts and assumptions associated with marine phosphate mining.
The SEA will establish a way to compare the environment before and after the impact of multiple mines. This is strategically essential for safeguarding the future of the Namibian fishing industry and the ongoing health of the Benguela Current Ecosystem.
NMP started an EIA land-based scoping study for their planned Walvis Bay onshore operations in 2012, but did not complete it. Should NMP be given environmental clearance again, the company still has to do a convincing environmental impact assessment, including giving concrete measures to mitigate onshore environmental impacts from millions of tonnes of waste from the seabed, separated on land.
The dredging of major quantities of marine phosphates each year will result in massive amounts of solid and liquid waste – how and where will this potentially harmful waste be disposed of? The Namibian public has a right to be assured that effluent run-off from onshore processing will not impact fisheries resources, the mariculture industry, or marine protected areas – and that potential radiation waste material will not blow over the towns of Walvis Bay and Lüderitz, making people sick.
Practical steps and monitoring mechanisms to guarantee this currently do not exist, pointing to the need to shelf or bury the prospect of phosphate mining in Namibia
6. INTERNATIONAL LESSONS
There is broad global consensus that marine-origin phosphates have a higher radio-activity content than igneous phosphates. Namibia’s marine phosphates have either not been tested, or the results have not been made public.
Much of the US Florida phosphate wastes from fertilizer production exceeded permissible radioactivity levels, and have had to be stored in specially restricted areas in the USA.
On the other hand, there would be significant and permanent adverse effects to the marine environment and other potential environmental adverse effects. The DMC found that the economic benefits of the proposal to New Zealand to be insubstantial, relative to potential adverse environmental effects of the proposal.
Togo is one country that has allowed on-land phosphate mining, without enforcing safety regulations. The result has been that waste produced from the phosphate mining has flowed into the sea, causing serious problems of contaminated seafood to coastal communities.
New Zealand rejected marine phosphate mining in view of concerns for the environment, in favour of “caution and environmental protection”, and in view of the doubtful economic prospects of the venture.
Without proper independent and transparent environmental research by internationally recognised marine scientists with adequate knowledge and experience, the likely potential environmental risks of proposed marine phosphate mining in the Benguela Marine Ecosystem cannot be highlighted strongly enough.
This is why there has to be a research-led 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 government level. Any decision made without the required strategic environmental assessment research, is a dangerous “gamble” and would constitute recklessness.
Mining of phosphate from the sea will be costly while phosphate is a low value item. Making it economically viable for Namibia will require mining the seabed on a large scale. Presently, however, land-mined phosphate reserves in the world are predicted to be already sufficient for global demand for at least the next 60-80 years. At the same time, recycling of organic wastes to recover phosphates is fast coming to the fore as a more environmentally-sustainable source or fertilizer. Therefore, the future demand for marine-mined phosphate is uncertain, whereas the future demand for fish as a human food source is assured, obvious and vital.
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:
3. NO PROPER PROCEDURES WERE FOLLOWED
The Hon. Minister of Fisheries and Marine Resources has stated clearly that the Ministry is opposed to marine phosphate mining in Namibia due to the great risks and many unanswered questions about its likely impact. It is important to note that the Ministry of Fisheries and Marine Resources did not receive an application from Namibia Marine Phosphate (Pty) Ltd for an environmental clearance certificate as required in terms of the Environmental Management Act (No 7 of 2007).
Furthermore, the Minister did not prescribe conservation measures as outlined in the Act.
It is worth mentioning that the Environmental Commissioner’s Office was seemingly provided with a report by Dr. Peter Tarr from the SAIEA in which he alluded that stakeholders did not have enough time to engage meaningfully. He stated that the most affected stakeholders were the Ministry of Fisheries and Marine Resources as well as fishing industry. He further acknowledged that the ocean is a “public resource” and justified public interest in the matter on this basis.
The significance of the public having a fundamental interest and right in this matter has further been cemented by a judgement delivered through Judge Festus Uitele when Michael Gaweseb’s appeal was challenged on the basis of legal standing. The judge confirmed that he as member of the public had standing.
It is thus clear that there has been inadequate opportunities for the public to engage the Environmental Commissioner and to participate in the proceedings leading to the granting of the environmental certificate for NMP.
We can recall that you expressed reservations in the studies provided to your office and that you called for a study by an oceanographer as indicated in your letter of 09 November 2015 addressed to NMP. The letter stated that you wanted a “verification report to be reviewed by an experienced Oceanographer in the region with an understanding of the Benguela current system”.
Since there has been no evidence that the marine component as identified by your good office was studied it is clear that there is still a high risk of consequences for the marine life as a consequence of marine phosphate mining.
4. LABOUR CONCERNS
The Namibian fishing industry, from latest available employment figures, in 2016 directly employed 16 800 people - many of them women, and nearly all of them Namibians. The number of indirect jobs is around 60 000.
In 2015, according to the Namibian Statistics Agency, it exported Namibia N$7.03 billion in seafood exports, valuable foreign exchange for the country. Few industry sectors in Namibia can match these figures.
It needs to be said that international prices for mined minerals are widely known to be fluctuating and generally offer dubious investments. Marine phosphate mining is only one potential sector in Namibia’s mining industry.
It would rely on massive dredgers, rather than people, to do most of the work, and many of those to be employed will require skills not currently available in Namibia.
While there is talk of creating a phosphoric acid/fertilizer processing plant in Lüderitz, those currently employed by fish processing plants in Lüderitz and indirectly through the ports authority, Namport, where the fish are landed, are already key contributors to the Lüderitz economy. It would make no sense for a marine phosphate industry to be established in Lüderitz, with unproven prospects, threatening to replace the fishing industry as it slowly fades away due to environmental degradation.
Namibia cannot seriously consider replacing its valuable fishing grounds with doubtful mine pits in the ocean.
5. THE PHOSPHATE MINING MORATORIUM
The Namibian government imposed a phosphate mining moratorium in an attempt to solicit independent research, with mining companies now arguing that the moratorium timeline has expired and that they should be allowed to start mining.
So far during the moratorium period, an independent Norwegian organization, SINTEF, linked to the Norwegian Institute of Marine Research (IMR), has done a scoping study for a Strategic Environmental Assessment (SEA) and identified the need for further research to fill knowledge and regulatory gaps. This needs to be urgently followed by a Strategic Environmental Assessment to address the significant degree of unknown environmental impacts and assumptions associated with marine phosphate mining.
The SEA will establish a way to compare the environment before and after the impact of multiple mines. This is strategically essential for safeguarding the future of the Namibian fishing industry and the ongoing health of the Benguela Current Ecosystem.
NMP started an EIA land-based scoping study for their planned Walvis Bay onshore operations in 2012, but did not complete it. Should NMP be given environmental clearance again, the company still has to do a convincing environmental impact assessment, including giving concrete measures to mitigate onshore environmental impacts from millions of tonnes of waste from the seabed, separated on land.
The dredging of major quantities of marine phosphates each year will result in massive amounts of solid and liquid waste – how and where will this potentially harmful waste be disposed of? The Namibian public has a right to be assured that effluent run-off from onshore processing will not impact fisheries resources, the mariculture industry, or marine protected areas – and that potential radiation waste material will not blow over the towns of Walvis Bay and Lüderitz, making people sick.
Practical steps and monitoring mechanisms to guarantee this currently do not exist, pointing to the need to shelf or bury the prospect of phosphate mining in Namibia
6. INTERNATIONAL LESSONS
There is broad global consensus that marine-origin phosphates have a higher radio-activity content than igneous phosphates. Namibia’s marine phosphates have either not been tested, or the results have not been made public.
Much of the US Florida phosphate wastes from fertilizer production exceeded permissible radioactivity levels, and have had to be stored in specially restricted areas in the USA.
On the other hand, there would be significant and permanent adverse effects to the marine environment and other potential environmental adverse effects. The DMC found that the economic benefits of the proposal to New Zealand to be insubstantial, relative to potential adverse environmental effects of the proposal.
Togo is one country that has allowed on-land phosphate mining, without enforcing safety regulations. The result has been that waste produced from the phosphate mining has flowed into the sea, causing serious problems of contaminated seafood to coastal communities.
New Zealand rejected marine phosphate mining in view of concerns for the environment, in favour of “caution and environmental protection”, and in view of the doubtful economic prospects of the venture.
Without proper independent and transparent environmental research by internationally recognised marine scientists with adequate knowledge and experience, the likely potential environmental risks of proposed marine phosphate mining in the Benguela Marine Ecosystem cannot be highlighted strongly enough.
This is why there has to be a research-led 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 government level. Any decision made without the required strategic environmental assessment research, is a dangerous “gamble” and would constitute recklessness.
Mining of phosphate from the sea will be costly while phosphate is a low value item. Making it economically viable for Namibia will require mining the seabed on a large scale. Presently, however, land-mined phosphate reserves in the world are predicted to be already sufficient for global demand for at least the next 60-80 years. At the same time, recycling of organic wastes to recover phosphates is fast coming to the fore as a more environmentally-sustainable source or fertilizer. Therefore, the future demand for marine-mined phosphate is uncertain, whereas the future demand for fish as a human food source is assured, obvious and vital.
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