Dec 2023 Final Environmental and Social Impact Assessment for the Proposed 400 kV Auas-Kokerboom Transmission Line VOLUME 3 OF 3 APPENDIX G: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ESIA for the Proposed Auas-Kokerboom 400 kV Transmission Line Enviro Dynamics cc November 2023 iii EXECUTIVE SUMMARY INTRODUCTION NamPower intends constructing a 461 km long 400kV transmission line from the Auas Substation near Dordabis to Kokerboom substation near Keetmanshop, Namibia, as shown on the map overleaf. The line will assist in securing the supply of electricity to Namibia in future and open up opportunities for selling power to the Southern African Power Pool (SAPP). NamPower is currently applying to the World Bank for funding of the project, which will entail the following: • The new Auas-Kokerboom 400kV Transmission Line, with associated infrastructure at both substations such as switchgear and reactors. • A Battery Energy Storage System (BESS) to be installed at Lithop Substation, that will enable NamPower to store energy generated by, amongst other, renewable sources such as solar or wind energy to allow utilisation of such energy when these resources are not available, such as after sunset. An Environmental Impact Assessment for this project was completed in 2020 and an Environmental Clearance Certificate obtained for it in terms of Namibia’s Environmental Management Act, in 2021. The World Bank’s Environmental and Social Framework, consisting of ten Standards should be adhered to as a condition for the loan. Environ Dynamics was appointed to update the 2020 ESIA and ESMP, to meet all the above Standards where gaps are identified. This ESIA Report, together with the Appendices contains the findings of this work, including the required Management Plans necessary to implement satisfactory mitigation during construction and operation. PROJECT DESCRIPTION This Environmental and Social Impact Assessment (ESIA) was prepared for the proposed construction of a single-circuit 400 kV transmission power line from the Auas substation (near Dordabis) to the Kokerboom Substation (near Keetmanshoop) (hereafter refer to as the “Project”). The length of the transmission line is 461 km. The transmission power line will have a final servitude of 80 m width, with 12 m of that being cleared for an access track. The preferred transmission line route follows the existing 220 kV transmission corridor from the Kokerboom substation in the south for a distance of approximately 165km, after which it deviates to the east; to largely avoid homesteads, infrastructure and major topographic features; and passes through the Nauaspoort Mountain towards the Auas substation located in the north near Dordabis/Windhoek. ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 iv ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 v The tower designs along the majority of the route will consist of cross rope suspension towers (V-Structures), with self-supporting and strain towers in strategic points. The construction period will be approximately thirty-six months and it is likely to proceed on multiple construction fronts. Existing access roads will be utilized as far as reasonably possible to access the construction corridor. As shown in the diagram below, two alternative routes were considered namely, the western route which largely follows the existing 400kV transmission line and the eastern route (preferred option), which largely follows the existing 220kV transmission line. A comparative analysis was done between these two route options. It was concluded that the potential impacts on the western route will be marginally smaller, with ~3%, because of its slightly shorter distance. However, the western route is considered technically unfeasible due the route crossing the existing 200kV line, which will need the installation of a tower to ensure safe clearance. The close proximity of the two 400kV lines also increases the risk of a failure (power outages) of both lines, which is of national significance. Diagram illustrating western and eastern alternative routes ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 vi MAIN IMPACT RISKS AND PROPOSED MITIGATIONS Critical Habitat It is concluded from the Critical Habitat Assessment, that given all the ESS6 criteria combined, the Karas Dwarf Shrubland and Dwarf Shrub Savanna which cover the study area to the south are considered critical habitat for the Ludwig’s Bustard. The Ludwig's Bustard, which is classified as Globally Endangered, according to the IUCN Red Data list of species and listed as Endangered on the Namibian Red List, prefers open grassland found in the mentioned habitats. Within these habitats, the Hardap Dam is also an Important Bird Area and an important site for the migratory species Great White Pelican. Even though the dam is some 10km to the west of the proposed route, birds flying to and from this site can potentially collide with the power line. Despite the fact that these habitats are considered important areas for Ludwig’s Bustard and other species of conservation concern, it is the presence of the power line as a physical barrier, which poses the threat in terms of potential collisions, and needs to be addressed intentionally. Biodiversity Risk Management (or mitigation) measures following a mitigation hierarchy approach have been considered in the Critical Habitat Assessment. The goals of No Net Loss and Net Gain should be set in the Biodiversity Management Plan. A staggered design (i.e., the "staggering" or offsetting of pylons of the new 400 kV line with those of the adjacent 220 kV line) is being proposed, to increase the visibility of the obstruction of the power line infrastructure to flying birds, and thus reduce the chances of collisions. Since regional monitoring shows that current available mitigation, i.e., marking of lines to make them more visible, is ineffective for Bustards, the staggering mitigation is considered a potential solution and as such it is anticipated that the number of bird deaths at a regional scale can be significantly reduced. The staggering mitigation proposal is based on data which shows that most collisions take place mid-span between pylons, indicating that the pylons could be an effective visual barrier. The diagram below indicates the risk of the alternative mitigation methods. The existing 220kV line is not mitigation, and should another transmission line be added, the bustard collisions will effectively double. Should available mitigation be applied, there is expected to be a very small change to curb the bustard collision risk. The staggering mitigation option, however, is expected to reduce collisions on both lines, with approximately 45%. Not only will this be a major advance for the bustard population’s future on this project, but also as a potential future mitigation option on projects in the region with similar risks. ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 vii Bustard collision mitigation options compared. Though the confidence in the proposed staggering is high, the approach has not yet been proven, and will be applied as a trial to determine the effectiveness of staggering transmission lines to reduce bird collisions. It is proposed that, prior to construction, further studies, in addition to consultations with avifauna specialists, be conducted to refine this approach as a mitigation measure as part of the finalization of the design. This preparation period will also be used to refine the power line marking methods to be used for specific avifauna hotspots, and as preparation of a robust monitoring plan in the BMP. A plan of study is being proposed to set the terms for this further work prior to construction. The BMP will set out a short (pre-construction), medium (during construction) and long term (post-construction) monitoring programme. The BMP will in particular focus on the monitoring of key critical habitat areas, to assess the effectiveness of the mitigation measures that have been proposed thus far (staggering and line markers), with an aim to achieve Net Gain. A further aim of the monitoring is to assess local population numbers and trends of sensitive bird species (especially bustards) that are using these key critical habitat areas. The BMP will contain the requirements for further, ongoing biodiversity monitoring during the operational phase, to evaluate how effectively the mitigation measures proposed are in achieving the Net Gain targets. Impact assessment The impact assessment carried out revealed the following significant effects: • Impact on vegetation: Because of the linear nature of the project, the impact on vegetation is expected to be generally low. The loss of protected tree species, specifically the protected Camel Thorn rates medium and can be reduced to achieve a low significance with on-sit final route selection and ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 viii proper vegetation management. Appropriate mitigation is included in the Biodiversity Management Plan (BMP). • Impact on avifauna: The project area supports a relatively high diversity of red data species, including Vultures, Eagles, and Bustards that are particularly vulnerable to power line collisions. The main impact on birds will be bird strikes once the line is operational. The route has been aligned along an existing 220kV transmission line to minimise cumulative impacts. However, there still remain habitats that harbour sensitive red data bird species. Mitigation measures, which are a non-negotiable condition should be implemented, namely staggering the 220kV with the 400kV pylons (to be the same height to increase the chance of bustards seeing and clearing both lines), and where this staggering is not possible or ineffective after a period of monitoring, the line be marked with bird diverters. Bird marking is recommended for specific hotspot areas, where this type of mitigation is expected to be effective. A rigorous monitoring programme, is proposed, as discussed for Critical Habitat. • Social impacts: The most significant impacts include disruption to farm management and changed sense of place. For some farmers the key impact will be during construction when the team interferes with and could potentially introduce nuisances on their farms such as noise, dust, security risk, poaching, etc. to their land. This impact will continue periodically during operation when maintenance is carried out on the line. Some owners are concerned who already have a number of lines crossing their land. For some who place a high value on view sheds, their sense of place will change. These impacts are low generally for the entire route, but rated high to medium for some receptors. NamPower has made significant efforts to accommodate farm owners concerns in this regard, by making route adjustments where possible. Mitigation of potential nuisance and conflict on farms during construction and operation includes a well-planned management and communication protocol. There will be no resettlement or land take on this project. Land restrictions include that no structures be erected within the project servitude. Farms are generally large and used for grazing under the transmission line corridors. Grazing may continue without interruption. NamPower’s efforts to compensate for the land restrictions are considered reasonable and do satisfy the World Bank’s Environmental and Social Standard: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement. The limited land use restrictions are expected to have a low impact on the Nama Traditional Local Community, considered an Indigenous People group according to the World Bank ESS7. Engagement with the group’s representatives, including those of the! Hob! Naub Conservancy, confirmed ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 ix this assessment. The conservancy is large, none of their settlements or structures will be affected and livelihood strategies will continue mostly unaffected. Continued engagement with this group is very important and recommendations have been made to limit impact on the community during construction. A recommendation is also made to include a social upliftment programme targeting the Nama community, into the project implementation. • Impact on archaeology: Three sensitive sites have been discovered along the route, including one burial cairn, a grave (both in the south near Keetmanshoop) and a graveyard (on one of the commercial farms along the northern section of the route). These are not directly on the route (, i.e., between 2-4km away from the servitude boundary), but may be implicated during construction and operational activities in the area, particularly vehicles driving on the access track. The sites should either be marked and protected, or if this is not possible, removed completely before construction commences. The impact on these sites is rated high and the careful consideration of how to protect them is crucial. Other impacts, including impacts on labour, impacts related to waste, and community health and safety issues, have been assessed and should be addressed as part of the ESMP and the directives in the World Bank ESS. Cumulative Impact Assessment The cumulative impacts of the existing 220kV transmission line combined with the additional proposed 400kV transmission line were considered at a preliminary level. Impacts on the following Valued Environmental and Social Components (elements that are of value in the area), were assessed: • Health of vegetation, particularly Vachellia erioloba. The cumulative impact is expected to be low. The final survey of the power line should attempt to avoid these species as far as possible, and trees should be trimmed rather than removed where feasible. • Health of bird populations particularly those susceptible to power line collisions especially Ludwig’s Bustard and Kori Bustard. This impact is significant and a key focus of this study. By staggering the pylons, the impact is probably significantly reduced on both lines, resulting in possible Net gain. Bird markings and monitoring is also crucial to mitigate the impact, as prescribed in the Biodiversity Management Plan. • Visual quality as a tourism resource. Because of the increasing number of transmission lines, especially close to tourism related activities existing or planned, this impact is a concern. Rerouting has been done on the applicable farms where possible. • Social conditions on farms (specifically power line construction workers and maintenance teams) will likely be impacted. Farm owners have had to deal ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 x with the related frustrations in the past, and this project will likely add to these frustrations. Maintenance teams accessing the farms to work on the multiple lines adds to this social concern. Protocols for interactions on the farms have been included in the ESMP. The grievance redress mechanism provided for this project is crucial in terms of dealing with conflict and management of maintenance teams on the farms. RECOMMENDATIONS In light of what can be concluded regarding the potential impacts associated with the proposed transmission line, NamPower will be able to reduce the significance of most of these to acceptable levels if they implement the mitigation measures outlined in both the Construction and Operational ESMP. The BMP, SEP and LMP also need to be implemented. The preliminary BMP that was previously prepared as part of the ESMP will be updated according to the Plan of Study, contained in the biodiversity and critical habitat assessment, to refine biodiversity mitigation and monitoring, particularly as it relates to avifauna impacts and monitoring. It is important that the ESMP is audited to ensure compliance and that monitoring takes place as outlined therein otherwise the impacts identified will remain unacceptable. ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 xi TABLE OF CONTENTS MAIN ESIA REPORT VOLUME 1 OF 3 1 INTRODUCTION .............................................................................................................1 1.1 BACKGROUND .............................................................................................1 1.2 HISTORICAL AND CURRENT WORK PLAN ....................................................3 1.3 THE STUDY TEAM ...........................................................................................4 1.3.1 EIA For Submission To The Namibian MEFT .................................................4 1.3.2 Current Update Of ESIA for Compliance to ESS ........................................4 2 PROJECT DESCRIPTION .................................................................................................5 2.1 NEED FOR THE DEVELOPMENT .....................................................................5 2.2 TRANSMISSION LINE ......................................................................................7 2.3 THE PROPOSED SUBSTATION CHANGES ......................................................9 2.4 CONSTRUCTION ACTIVITIES .......................................................................10 2.5 CONSTRUCTION MATERIALS AND PROCESS .............................................10 2.6 WASTE MATERIALS ......................................................................................11 2.7 PROJECT WATER DEMAND ........................................................................11 2.8 LABOR AND EMPLOYMENT OPPORTUNITIES .............................................12 2.9 CONSTRUCTION CAMPS AND WORKFORCE ACCOMMODATION .........12 2.10 PROJECT COST AND TIMELINE ...................................................................12 3 ROUTE AND TOWER ALTERNATIVES ............................................................................13 3.1 ROUTE DESCRIPTION...................................................................................13 3.2 COMPARATIVE ANALYSIS ..........................................................................15 3.2.1 Bird Impacts................................................................................................15 3.2.2 Vegetation Impacts ..................................................................................16 3.2.3 Impacts Resulting From Topography........................................................16 3.2.4 Socio-Economic Impacts ..........................................................................17 3.2.5 Technical Preference ................................................................................18 3.2.6 Conclusion Alternative Preference ..........................................................19 3.3 Rationale for Towers Used .........................................................................19 ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 xii 4 LEGISLATION AND POLICIES.......................................................................................20 4.1 LEGAL REQUIREMENTS IN TERMS OF NAMIBIAN LEGISLATION .................20 4.2 WORLD BANK REQUIREMENTS ...................................................................23 4.2.1 Environmental and Social Framework .....................................................23 4.2.2 Other Applicable International Conventions And Guidelines ...............30 5 RECEIVING ENVIRONMENT ........................................................................................32 5.1 BIOPHYSICAL ENVIRONMENT.....................................................................32 5.1.1 Climate .......................................................................................................33 5.1.2 Drainage ....................................................................................................34 5.1.3 Groundwater .............................................................................................36 5.1.4 Vegetation .................................................................................................37 5.2 FAUNA .........................................................................................................41 5.3 AVIFAUNA ...................................................................................................41 5.4 BIODIVERSITY CONSERVATION ..................................................................45 5.5 ARCHAEOLOGY .........................................................................................47 5.6 SOCIO-ECONOMIC ENVIRONMENT..........................................................50 5.6.1 Affected area ............................................................................................50 5.6.2 Predominant land use and economic activity in the affected area ...51 5.6.3 Land Tenure and Management ...............................................................54 5.6.4 Project Area ...............................................................................................55 6 OCCURRENCE OF INDIGENOUS PEOPLES IN THE STUDY AREA .................................59 6.1 INDIGENOUS PEOPLES REQUIREMENT IN ESS7 ..........................................59 6.2 THE NAMA IDENTITY ....................................................................................60 6.3 TRIBES AND DISTRIBUTION ...........................................................................61 6.4 LIVELIHOODS ..............................................................................................61 6.5 CULTURE ......................................................................................................61 6.6 NAMA SETTLEMENT PATTERNS AND DENSITIES IN THE STUDY AREA ..........62 6.7 THE !KHOB ! NAUB CONSERVANCY ...........................................................64 ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 xiii 7 CRITICAL HABITAT ASSESSMENT .................................................................................66 7.1 BIODIVERSITY SCREENING FOR CRITICAL HABITAT ...................................69 7.1.1 Criteria 5. ....................................................................................................69 7.1.2 Criteria 4 ....................................................................................................71 7.1.3 Criterion 3 ...................................................................................................73 7.1.4 Criterion 2 ...................................................................................................... 7.1.5 Criterion 1: .................................................................................................75 7.2 CONCLUSION: CRITICAL HABITAT .............................................................76 8 IMPACT ASSESSMENT..................................................................................................83 8.1 IDENTIFICATION OF KEY ISSUES ..................................................................83 8.2 METHODOLOGY EMPLOYED FOR THE IMPACT ASSESSMENT ...................87 8.3 ASSESSMENT OF IMPACTS ..........................................................................88 8.3.1 Impact on Vegetation ..............................................................................88 8.3.2 Water Demand, Erosion and Flooding .....................................................91 8.3.3 Impacts Related to Waste Disposal .........................................................94 8.3.4 Impact on Avifauna ..................................................................................96 8.3.5 Social Impact .............................................................................................99 8.3.6 Destruction or Damage to Archaeological Sites .................................. 114 8.3.7 Assessment of Cumulative Impacts ....................................................... 116 9 STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE ...........................122 9.1 INTRODUCTION......................................................................................... 122 9.2 WORK DONE TO DATE.............................................................................. 123 9.5 ENGAGEMENT DURING IMPLEMENTATION AND BEYOND ..................... 125 10 CONCLUSIONS AND RECOMMENDATIONS ............................................................125 10.1 CONCLUSIONS ......................................................................................... 125 10.1.1 Route selection ........................................................................................ 125 10.1.2 Critical Habitat ......................................................................................... 125 10.1.3 Impact assessment .................................................................................. 126 10.1.4 Cumulative Impact Assessment ............................................................. 128 ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 xiv 10.2 RECOMMENDATIONS............................................................................... 129 11 REFERENCES ..............................................................................................................130 TABLES Table 2-1: Summary of tower structures to be used ....................................................8 Table 3-1: Vegetation types and extent of power line for planned 400kV route (eastern) and alternative route (western) in each type .............................................15 Table 3-2: Comparison Avifauna Impact ratings ........................................................16 Table 3-3: Comparison Vegetation Impact ratings ....................................................16 Table 3-4: Comparison of impacts caused by topographical features ...................17 Table 3-5: Comparison of socio-economic impacts ..................................................18 Table 4-1: Summary of ESF of the World Bank and their applicability to the project 24 Table 5-1: Species of concern which require mitigation measures. .........................40 Table 5-2: Number of bird species recorded, Red Data species, Namibian endemicand near-endemic species, and southern African endemics in the four vegetation types traversed by the proposed Kokerboom to Auas 400 kV transmission line corridor. .................................................................43 Table 5-3: Bird species of interest in the vicinity of the transmission line ...................44 Table 5-4 Proposed Project affected areas (north to south) ....................................51 Table 5-5: Distribution and tenure status of affected farms .......................................55 Table 6-1: ESS 6 Criteria for determining Critical Habitat............................................69 Table 6-2: Habitat related sensitivities ..........................................................................70 Table 6-3: Avifauna species of conservation concern triggering Ess6 Criteria 1-3 in theCHAA (Africa Conservation Services, 2023). ........................................78 Table 8-1: Summary of potential impacts addressed in this section .........................85 Table 8-2: Summary of Vegetation Impact Assessment.............................................90 Table 8-3: Summary of Water Resource, Erosion and Flooding Impact Assessment 93 Table 8-4: Waste disposal impact assessment ..........................................................95 Table 8-5: Summary of avifauna impact assessment ...............................................98 ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 xv Table 8-6: Summary of typical magnetic field levels encountered in various environments and close to household appliances (Hubbard, 2012) .. 101 Table 8-7: Electric and magnetic field exposure guidelines set by ICNIRP (1998) and ICNIRP (2010) versions. ..................................................................... 102 Table 8-8: Summary of the potential impacts of the proposed power line project on the social environment. ..................................................................... 111 Table 8-9: Summary of archaeology impact assessment ...................................... 115 Table 8-10: Comparative components of the planned 400kV and existing 220kV line structures that will run largely in parallel. ............................................... 119 FIGURES Figure 1-1: Locality Map of the proposed Transmission Line .......................................2 Figure 1-2: Diagrammatic summary of historical and current work plan ................... Figure 2-1: Existing transmission line network of Namibia (Source: NamPower, 2019). 6 Figure 2-2: Servitude details for the proposed transmission line .................................7 Figure 2-3: Structures to be used on the power line. ...................................................9 Figure 3-1: Locality map of the two major route alternatives considered. .............13 Figure 5-1: Catchment of the study area...................................................................34 Figure 5-2: Section 1, showing Catchment C21 ........................................................35 Figure 5-3: Section 2 of the project catchment areas. .............................................35 Figure 5-4: The catchments in Section 3.....................................................................36 Figure 5-5: The three vegetation zones identified in the study area ........................37 Figure 5-6 Acacia erioloba stand located in Section B ...........................................39 Figure 5-7: Vegetation types of the project area......................................................42 Figure 5-8: Locality of protected areas in the study area.........................................46 Figure 5-9: Positions of 25 archaeological survey sites ..............................................48 Figure 5-10: Private commercial farm (left) versus State land (right) ........................53 Figure 5-11: Land tenure of land traversed ..................................................................58 Figure 6-1: Distribution of Nama people in the study area .......................................62 Figure 6-2: Google earth image, showing settlements in the study area ...............63 Figure 6-3: Details at Kriess Settlement .......................................................................64 ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 xvi Figure 6-5: The !Khob !Naub Conservancy Management Plan ...............................65 Figure 7-1: Critical Habitat Area of Analysis ...............................................................68 Figure 8-1: Screening process to determine key issues ...............................................83 Figure 8-2: Typical Magnetic Field Levels expected from the 440kV Lines. ............. 102 Figure 8-3: Servitude details for the proposed transmission line ............................... 117 Figure 8-4: Cumulative servitude of the 400KV and 220kV lines .............................. 118 Figure 8-5: Examples of “staggering” or offsetting. ................................................... 120 APPENDICES Appendix A Environmental Clearance Certificate Appendix B Terms of Reference Appendix C Photographs Appendix D Facility Illustrations Appendix E Stakeholder Engagement Report with Plan APPENDIX F - SPECIALIST REPORTS – VOLUME 2 OF 3 ▪ Avifaunal assessment ▪ Draft Biodiversity and Critical Habitat Assessment Report ▪ Archaeological Assessment ▪ Vegetation Assessment ▪ Floodline Assessment ▪ Social Impact Assessment APPENDIX G - ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN – VOLUME 3 OF 3 ESIA for the Proposed Auas to Kokerboom 400 kV Transmission Line Enviro Dynamics CC December 2023 December 2023 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Environmental Impact Assessment for the Proposed 400 kV Transmission Line from Kokerboom Substation to Auas Substation i COPYRIGHT © NAMPOWER, 2023. ALL RIGHTS RESERVED PROJECT NAME Environmental Specific Environmental Management Plan for the Proposed 400 kV Transmission Line from Kokerboom Substation to Auas Substation REPORT Environmental and Social Management Plan STAGE OF REPORT Final CLIENT NamPower Enquiries: Martin van der Merwe (Pr. Eng, PMP®) Senior Engineer – Transmission Capital Projects Tel: +264 61 205 2724 Cell: +264 81 296 5374 Email: martin.van.der.merwe@nampower.com.na LEAD CONSULTANT Enviro Dynamics Enquiries: Stephanie van Zyl Tel: (061) 223-336 E-Mail: stephanie@envirod.com DATE OF RELEASE December 2023 CONTRIBUTORS TO THE REPORT Stephanie van Zyl, Norman van Zyl NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 ii DECLARATION I hereby declare that I do: (a) have knowledge of and experience in conducting assessments, including knowledge of the Act, these regulations and guidelines that have relevance to the proposed activity; (b) perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant; (c) comply with the Act, these regulations, guidelines and other applicable laws. I also declare that there is, to my knowledge, no information in my possession that reasonably has or may have the potential of influencing – (i) any decision to be taken with respect to the application in terms of the Act and the regulations; or (ii) the objectivity of this report, plan or document prepared in terms of the Act and these regulations. Stephanie van Zyl Environmental Assessment Practitioner NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 iii TABLE OF CONTENTS TABLE OF CONTENTS ................................................................................................... III LIST OF FIGURES ........................................................................................................... IV LIST OF TABLES ........................................................................................................... IV LIST OF ACRONYMS ..................................................................................................... V 1 SCOPE ............................................................................................................ 1 1.1 Reporting Structure .............................................................................................. 2 2 INTRODUCTION ...................................................................................................... 3 3 PROJECT INFORMATION ........................................................................................ 4 4 ENVIRONMENTAL AND SOCIAL FEATURES ........................................................... 6 5 MANAGEMENT OF ENVIRONMENTAL AND SOCIAL MEASURES ........................ 14 5.1 Contractual requirements ................................................................................. 14 5.2 Management and auditing capacity requirements....................................... 14 5.3 Promoting compliance ...................................................................................... 15 6 LEGAL REQUIREMENTS ......................................................................................... 17 7 MANAGEMENT REQUIREMENTS........................................................................... 19 7.1 Planning Phase ................................................................................................... 19 7.2 Construction Phase ............................................................................................ 33 7.3 Operation and Maintenance Phase ................................................................ 87 7.4 Decommissioning Phase .................................................................................... 92 APPENDIX A BIODIVERSITY MANAGEMENT PLAN ................................................ 94 APPENDIX B LIVELIHOOD RESTORATION PLAN ................................................... 95 APPENDIX C EXAMPLE OF ENVIRONMENTAL ENFORCEMENT SYSTEM ............... 96 APPENDIX D: ARCHEOLOGY CHANCE FIND PROCEDURE ................................... 99 APPENDIX E: NAMPOWER SAFETY, HEALTH, ENVIRONMENT AND QUALITY POLICY ........................................................................................................ 101 APPENDIX F: PRELIMINARY IMPLEMENTATION BUDGET.......................................... 102 APPENDIX G: LABOUR MANAGEMENT PROCEDURES ............................................ 104 NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 iv LIST OF FIGURES Figure 1 Locality map the transmission line route .................................................... 3 Figure 2: Vegetation zones on the route. ..................................................................... 8 Figure 3. Avifauna map with vegetation zones .......................................................... 10 Figure 4: A 14-km section (= blue line) of the new routing that passes close to known vulture areas. This section south of the NamPower coordinate of BP014 requires extra mitigation in the form of bird diverters. ....................................................................... 25 LIST OF TABLES Table 1: Project description ........................................................................................... 4 Table 2: Environmental features .................................................................................... 6 Table 3: National Legislation and World Bank compliance. ..................................... 17 Table 4 Management Requirements – Planning ....................................................... 19 Table 5 Management Requirements – Construction ................................................ 33 Table 6 Management Requirements – Operation and Maintenance .................... 87 Table 7 Management Requirements - Decommissioning......................................... 92 NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 v LIST OF ACRONYMS Acromym Description Acromym Description AIDS Acquired GN ESS Guidance Notes immunodeficiency syndrom AMSL above mean sea level GPN-LI World Bank Good GPN-SEA/SH Pactice Notes CoC Code of Conduct Ha Hectare ECB Electricity Control board HSE Health, Safety and Environmental ECC Environmental IUCN International Union for Clearance Certificate Conservation of Nature ECO Environmental Control kV kilovolt Officer EHSG-G World Bank m2 Square meter Environmental, Health and Safety Guidelines - General EHSG-ET World Bank MEFT Ministry of Environment, Environmental, Health Forestry and Tourism and Safety Guidelines - Electric Power Transmission and Distribution EPC Engineering, MME Ministry of Mines and Procurement and Energy Construction ESF World Bank MW megawatt Environmental and Social Framework ESIA Environmental and NBRI National Botanical Social Impact Research Institute Assessment ESMP Environmental and NHC National Heritage Social Management Council Plan ESS World Bank NP NamPower Environmental and Social Standard EWG Environmental Working PPE Personal Protective Group Equipment ff and forward SME Small and Medium Enterprises GIS Geographic information UV Ultraviolet system GPS Global Positioning WESCO WESCO WASTE System MANAGEMENT PTY LTD NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 1 1 SCOPE The purpose of this document is to provide regulations, regarding the environment, to any contractor whom NamPower appoints (this includes outside contractors as well as NamPower’s own construction people) for the: NamPower 400 kV Transmission Line (the project) from Kokerboom Substation near Keetmanshoop in the Kharas Region to Auas Substation near Windhoek in the Khomas Region of Namibia This document is to form part of the contract, and all recommendations and constraints laid out in this document are enforceable under the general conditions of contract. This management plan has a long-term objective to ensure that: • Environmental management considerations are implemented from the start of the project. • Precautions against damage and claims, arising from damage, are taken promptly. • The completion of the project is not delayed due to problems with land owners arising during the course of construction. NamPower needs a commitment from the NamPower Project Manager and contractor on the following issues: • To take into consideration the landowners and their rights. • To always behave professionally on and off site. • To ensure quality in all work done – technical and environmental. • To resolve problems and claims arising from damage immediately, in order to ensure a smooth flow of operations. • To underwrite NamPower’s environmental policy at all times. • To use this Environmental Management Plan for the benefit of all involved. • To preserve the natural environment by limiting destructive actions on site. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 2 1.1 Reporting Structure NP Project Manager NP Manager: NP Contractor NP Safety Site District Health & Supervisor Supervisor Environment (SHE) Contractor Environmental Control NP Officer Environmental (CECO) Control Officer (ECO) Contractor employees Landowners, community, and other stakeholders NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 3 2 INTRODUCTION The ESMP covers the proposed NamPower 400 kV Transmission Line (the project) from Kokerboom Substation near Keetmanshoop in the //Kharas Region to Auas Substation near Windhoek in the Khomas Region of Namibia (see Figure 1 below). Figure 1 Locality map of the transmission line route NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 4 3 PROJECT INFORMATION Key characteristics of the transmission line activities of the project are summarized in Table 1. Table 1: Project description ELEMENT DESCRIPTION Project Developer NamPower. Life of project Construction phase Approximately thirty six (≥36) months. Minimum 25 years. Operational phase Project location Khomas Region to //Kharas Region, Namibia. The line will be mostly east of the B1 trunk road (see Figure 1) Total land area of Project 2565Ha (or 40 m wide by 461 km long) site Coordinates of the These coordinates are only a guideline of the route area and not exact. project area -22.588478°, 17.369070° / -22.944307°, 17.529332° / -23.425082°, 17.377416° / -23.967715°, 17.495490° / -24.570717°, 18.043643° / -25.386568°, 18.259726° / -26.419110°, 18.291778° Land agreements and Right of way use will be negotiated according to NamPower and National use policies and procedures. No land will be expropriated. Project activities Construction and installatººion of the following: A 400kV transmission line consisting of: • Vegetation clearance of 12m wide under the line and 70m by 50m at each tower • Concrete pylon foundations, with concrete mixing on or near the pylon sites. • V type Cross rope suspension steel pylon (guyed V-Structure) with a height 40m and span of up to 500m between pylons. • Self-supporting suspension steel pylons for bends up to 30˚ and strain pylons for bends up to 60˚. • Pylons materials are transported to site and then assembled on site. • Stringing of the line and NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 5 • Infrastructure to connect to the existing Auas and Kokerboom substations. Expected The total estimated footprint is approximately up to 1050 ha. disturbance/footprint NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 6 4 ENVIRONMENTAL AND SOCIAL FEATURES The following key features (Table 2) show the vulnerability of this environment and raises awareness of the features to be conserved and managed to ensure protection and avoidance of collateral damage. Table 2 Environmental features Element Description Impact expected Geology and Important ephemeral river systems and their catchments and areas prone to erosion and Pylons affected by the flooding and erosion topography flooding are highlighted in the ESIA. The line traverses steep terrain only at very specific which can be avoided if pylons remain outside points. Therefore only minor sections of steep terrain occur distributed throughout the of these areas. length. Vegetation No critical vegetation habitat has been determined along the route. Physical destruction of vegetation of high conservation, by vegetation clearance for the The vegetation specialist report (Mannheimer, 2016) describes the important biodiversity footprint and collateral damage. areas along the route as follows: “Areas along the route east of Tsumis, as well as the southern parts of Highland Savannah and the portion south and north of bend point 4 carry dense populations of Acacia erioloba (Camel thorn). However, there are scattered densities of this species over much of the route in sections Mixed Tree / Schrub Savannah and Highland Savanna. This species, and other protected species, such as Albizia anthelmintica, often favour dune areas. It is thus virtually impossible to define a “critical” area regarding these species without including most of Mixed Tree / Schrub Savannah and Highland Savannah. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 7 Element Description Impact expected Slopes of koppies and mountains in the Highland Savanna carry numerous species of concern and should be avoided as far as possible. At present this habitat is almost untouched by the proposed route. Pan verges and banks of rivers and drainage lines are known to harbour higher than average numbers and sizes of protected woody species, as well as sedges such as Cyperus rehmii. Although it is very likely that this species is severely under-collected (most sedges are in Namibia), and may be more widespread and common than is presently known, the precautionary principle should be followed by avoiding this habitat for pylon sites. This will also favour the protected trees. Dense stands of Aloe dichotoma, although rare, may be encountered in the southernmost extent of the route. They are very easy to identify and, if encountered, should be avoided for pylon placement. Service tracks should easily be able to circumvent most individuals, which are usually sufficiently widely scattered. The key species are noted as of concern when near the route: Acacia erioloba (protected– Tsumis, BP4 – Hohewarte, riparian and dune areas), Albizia anthelmintica (protected), Aloe dichotoma (protected/IUCN-LRlc/CITES II), Aloe littoralis (protected/IUCN-LRlc/CITES II), Boscia albitrunca (protected/IUCN-LRlc), Cyperus rehmii (endemic, farm Binsenheim / Rietfontein), Euclea pseudebenus (protected), Maerua schinzii (protected/IUCN-LRlc), Ziziphus mucronata (protected). LRlc = Low Risk, least concern. None of the species has Red Data Status in Namibia. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 8 Element Description Impact expected Figure 2: Vegetation zones on the route. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 9 Element Description Impact expected Bio-diversity - The study area covers areas of critical habitat for specific raptor, hornbill and bustard Disturbance through noise, movement and Avifauna species as identified in the Biodiversity Management Plan (Appendix A). temporary occupation of an otherwise undisturbed habitat. The project area supports a relatively high diversity of red data species, including vultures, eagles, and bustards that are particularly vulnerable to power line collisions. Habitat loss, including foraging, roosting and breeding habitat of the area occupied by the The main impact on birds will be bird strikes once the line is operational. The route has been completed structures. aligned along an existing 220kV transmission line to minimise cumulative impacts. However, there still remain habitats that harbour sensitive red data bird species. Collision of priority species, including globally threatened birds and/or migrating birds. The following species meet the CHA criteria and (with high-medium confidence in the CHA) are likely to be impacted by the planned 400kV transmission line: Ludwig's Bustard (IUCN G EN, N EN), White-backed Vulture (IUCN G CR, N CR), Secretarybird (IUCN G EN, N VU), Lappet-faced Vulture (IUCN G EN, N EN), Verreaux's Eagle (IUCN N NT), Great White Pelican (IUCN N VU) The following species may meet the CHA criteria, and are likely to be impacted by the power line (with lower confidence in the CHA): Kori Bustard (IUCN G NT, N NT), Rüppell's Parrot (IUCN N NE), Damara Hornbill (IUCN N NE), Monteiro's Hornbill (IUCN N NE) Mitigation measures (including staggering the 220kV with the 400kV pylons, assure the two sets of pylons are the same height, and fitting bird markers) as well as a rigorous monitoring programme as prescribed in the Biodiversity Management Plan (Appendix A), is crucial to reduce avi-fauna population declines to an acceptable level. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 10 Element Description Impact expected The Biodiversity Management Plan (Appendix A) monitoring requirements include: • Pre-construction monitoring as per set criteria on both the existing 400 kV and 220 kV lines to start at least 9 months and 3 months prior to construction, including planning and design of bird diverters type and positions, to be included in the contract requirements. • Construction monitoring and final determination of positions of diverters. • Post construction monitoring sets at 3 and 9 months after completion of the line. Figure 3. Avifauna map with vegetation zones (potentially sensitive avifauna habitats (orange circle = White-backed Vulture breeding area; red circle = Verreaux's Eagle breeding area; yellow circle = Hardap Dam IBA; brown lines = ephemeral rivers) (based on a Google Earth image; EIS 2023). NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 11 Element Description Impact expected Archaeology The following important archaeological sites exist near the route (Figure 1). Impact only expected if uncontrolled movement is allowed into the nearby area and QRS 243/604 S26.14268 E18.30721: Pre-colonial burial cairn 2m diameter, slightly dispersed, particularly the hills. An archaeology chance- on stream terrace. find procedure is to be implemented and overall QRS 243/605 S26.14444 E18.30861: Colonial era grave, 2.2m long, unmarked, on stream degradation is to be limited. terrace. QRS 234/615 S22.88937 E17.56039: Historic/modern farm cemetery >50 graves, fenced, 30m east of road centreline. Confirmation is required as to whether this is the site referred to by the I&AP Comments and Response Report (4 th August 2016), Item B035, Mr Romeis. The site is an established cemetery and unlikely to be affected by the proposed Kokerboom to Auas transmission line corridor. These particular sites should be demarcated and no construction activities are to take place near them. No members of the team are to come near them. Traffic The transport route for heavy equipment and materials will both national and district roads During the construction phase the increase in in the central and southern part of Namibia. truck traffic along national and district roads transmission line site vicinity will be cumulatively moderate. However, the expected total traffic volumes along these roads will be temporary and still be well within the function of the roads and hence no operational issues are expected. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 12 Element Description Impact expected Socio- Housing to be catered for in Rosh Pinah. The rural areas in southern Namibia is sparsely Limited job creation and economic upliftment if economic populated, and due to its aridness is not attractive for significant population influx. a locals first policy is followed. indicators. Villages with populations large enough to provide labour is Dordabis (Khomas Region), Engagement with the regional and village Kalkrand (Hardap Region), as well as Berseba, Tses and Kries (//Kharas Region). councils is essential to facilitate temporary employment opportunities for locals first. Towns near the transmission line route is Rehoboth, Mariental and Keetmanshoop. The rural areas in southern Namibia show high unemployment rates and very low potential for future job opportunities, making longer term scope for permanent influx of workers from other regions very unlikely. The project will employ up to 150 people over the entire construction period spread over three regions, making the overall economic upliftment effect very limited. Cumulative Planned and future renewable energy development in the Khomas, Hardap and //Kharas The areas with higher wind and solar potential is features Region will require new transmission line infrastructure in and beyond these regions. sensitive to large footprint projects, including transmission lines, and may cause significant cumulative impacts on impact on habitat, vegetation, tourism, archaeology and socio- economic environments. Recommend that a Strategic Environmental Assessment (SEA) be conducted for renewable energy development in Namibia to address matters of strategic concern, including impact NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 13 Element Description Impact expected on habitat, vegetation, tourism, archaeology and socio-economic impact. The Environmental and Social Management Plan (ESMP) aims to provide a high-level management tool for the overall environmental management of the project in principle as well as direct mitigation measures related to the impacts expected. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 14 5 MANAGEMENT OF ENVIRONMENTAL AND SOCIAL MEASURES The following legal framework forms the backbone of this ESMP: 5.1 Contractual requirements The ESMP must be included in all contractual agreement between the Project Developer (NamPower) and Contract Implementers. Strict adherence to the ESMP is essential in view of the sensitivity of the project area and the fact that the ESMP is a legally binding contract between the Project Developer and MEFT. The ESMP incorporates the following essential components: • General mitigation measures that are applicable to all projects to ensure sound environmental and social management principles for a sustainable outcome. • The specific mitigation measures for this project that have been identified to avoid and reduce the significance of impacts in this sensitive environment. 5.2 Management and auditing capacity requirements. In order to be able to adhere to the above-mentioned requirements, the following capacity and system must be put into place: • NamPower shall appoint a qualified and dedicated Environmental Specialist from the NamPower SHE Section and with Environmental and Social Risk Management Practice qualifications and experience as Environmental Control Officer (ECO) for each project to coordinate and monitor the adherence to the Environmental and Social Management Plan (ESMP), as well as the external environmental audit process. This position will be responsible for: o The coordination of and liaison with the MEFT. o The coordination of the various Management and Monitoring Plans, especially the Biodiversity Management Plan. o The implementation of the ESMP through the Contractor. o The coordination and reporting of the environmental audit and monitoring system. • NamPower, in co-ordination with the ECO, should liaise with stakeholders at critical points to resolve specific matters, such as: o the local labour office recruitment, o Infrastructure provision and workforce accommodation. o The farm owners should also be contacted to inform them about the commencement and progress with the project and to iron out any grievances they may have. o Monitor and implement the various grievance resolution measures. • NamPower should implement an environmental and social review system such that reviews are conducted on a quarterly basis during construction and audits NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 15 on an annual basis during the construction and operation of the Project. This is to be used to ensure the successful implementation of the ESMP, to verify the effectiveness of the ESMP, to implement adjustments if required, and to have an objective set of records. Throughout the project cycle, it will be ensured that the World Bank and its ESS requirements are considered and included in reporting requirements. 5.3 Promoting compliance NamPower is responsible to ensure overall adherence to this ESMP by the various construction, operation, and maintenance operators throughout the entire life cycle of the project. The operator/contractor is however responsible for the enforcement of this ESMP to avoid contravention of this ESMP.1 The system should incorporate the following guidelines: (a) The Contract Implementer shall comply with the environmental and social specifications and requirements as described in the ESMP on an ongoing basis. The Contract Implementer shall include the necessary training and awareness raising as a constant process on site, including to new staff. Any failure to comply should set in motion a corrective procedure by the ECO, which culminates in a payment retention or deduction with continual non- compliance. Payment retention is the first step toward correction, with a deduction as further enforcement, which can be repeated if non-compliance persists. Certain contraventions are of high importance and a deduction shall be charged regardless of the correction, especially in cases where the damage is irreparable. (b) Enforcement should be assured through specific, quantitative measures such as payment deductions for small scale or irrecoverable activities and payment retention for large scale recoverable activities (See example in Appendix C). The terms should be specified in the special conditions of contract of implementation and operations contracts. (c) In the event of non-compliance, the following recommended process shall be followed: • The ECO shall issue a notice of non-compliance to the Contract Implementer, stating the nature and magnitude of the contravention. • The Contractor shall act to correct the non-compliance within 24 hours of receipt of the notice, or within a period that may be specified within the notice. • The Contractor shall provide the ECO with a written statement describing the actions to be taken to discontinue the non-conformance and to replace it with confirming actions, as well as the actions taken to mitigate its effects and the expected results of the actions. 1 In case NamPower remains the operator, a system promoting compliance is still required, with a disciplinary process being made applicable in cases of severe non-compliance, e.g. health and safety measures contravened, plants indiscriminately damaged, indiscriminate off-road driving undertaken or off-limit areas visited, etc. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 16 • In the case of the Contractor failing to remedy the situation within the predetermined timeframe, the ECO shall impose a payment deduction or retention based on the special conditions of contract. • In the case of the Contractor not being able to remedy the situation due to irreversible environmental and social impact already incurred, the ECO shall impose a payment deduction based on the special conditions of contract. • In the case of non-compliance giving rise to physical environmental damage or destruction, NamPower shall be entitled to undertake or to cause to be undertaken such remedial works as may be required to make good such damage and to recover from the Contractor the full costs incurred in doing so. • In the event of a dispute, difference of opinion, etc., between any parties in regard to or arising from interpretation of the conditions of the ESMP, disagreement regarding the implementation or method of implementation of conditions of the ESMP, etc., any party shall be entitled to require that the issue be referred to independent specialists to assist in the resolving of the dispute to the satisfaction of all the parties. • The ECO shall at all times have the right to stop work and/or certain activities on site via the appointed site manager / project manager in the case of ESMP non-compliance or failure to implement remedial measures. (d) A list of appropriate payment deductions and payment retention based on the content of the ESMP must be developed by the ECO before the project implementation starts and revised annually. Appendix C provides an example of an Environmental Payment Deduction or Retention System. (e) A record of all payment deductions and payment retention given and adhered to should form part of the Environmental Payment Deduction or Retention System. Repeat offenders will receive an official warning or will be ordered from the site if as deemed necessary. All staff and contractors should be made aware of the seriousness with which all Safety. Health, Environmental, and Quality (SHEQ) aspects of this ESMP and other legal requirements should be viewed at the site and the system should be knowledge to all on the team. (f) The formal NamPower Safety, Health, Environment, and Quality Policy (Appendix E) will be adhered to at all times. This policy is in line with all relevant ISO Systems and adherence to the SHEQ management system. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 17 6 LEGAL REQUIREMENTS Summarized below (Table 3) are the activities associated with the construction and operation of the power line that have specific requirements in terms of national legislation (such as permits). Table 3: National Legislation and World Bank compliance. LEGISLATION REQUIREMENT • Regulations relating to the health and safety of employees at work are Labour Act 11 of contained in GN 156/1997 (GG 1617). Must be complied with on this 2007 project. • Provision for the protection of various plant species. A permit will be Forestry Act No 27 of needed for removal or destruction of protected species mentioned in 2004 Table 2. • The act also requires any removal of any living tree, bush or shrub growing within 100 metres of a river, stream or watercourse to be done under to auspices of a permit issued by an appropriate official from the Directorate of Forestry. • The forms can be obtained from the permit office at the Ministry of Environment and Tourism, Windhoek or the Directorate of Forestry: Ministry of Agriculture, Water and Forestry, Government Office Park, P/Bag 13184 Windhoek, Tel +264 61 208 7555. A period of three months should be allowed for obtaining this permit. Species and numbers/quantities involved will need to be specified. • Permit needed for the removal or destruction of protected species ( See Nature the Vegetation Specialist study for a Complete list of species requiring a Conservation permit.) Ordinance 4 0f 1975 • No archaeological/heritage site or cultural remains may be removed, National Heritage damaged, altered or excavated. Act No 27 of 2004 • Section 48 sets out the procedure for application and granting of permits, such as the permit required in the event of damage to a protected site occurring as an inevitable result of development. Section 51 (3) sets out the requirements for impact assessment. • Part VI Section 55 Paragraphs 3 and 4 require that any person who discovers an archaeological site should notify the National Heritage Council. • The Compensation Policy for commercial areas as per the Resettlement Compensation Policy Framework (Appendix B), with its applicable forms are applicable to Policy this project. • Specifically ESS 2 and ESS 6 (2016) and the relevant Guidance Notes (2018) World Bank • To protect and conserve biodiversity and habitats. Environmental and • To apply the mitigation hierarchy and the precautionary approach in the design and implementation of projects that could have an impact on Social Framework. biodiversity. • To promote the sustainable management of living natural resources. • To support livelihoods of local communities, including Indigenous Peoples, and inclusive economic development, through the adoption of practices that integrate conservation needs and development priorities. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 18 Relevant to World Bank Group - • Terrestrial habitat alteration. Environmental, • Electric and magnetic fields once operational. • Hazardous materials. Health and Safety • Working at height on poles and structures. Guidelines for • Live power lines once operational. Electric Power Transmission and Distribution. • General Health and Safety Guidelines that is to be read in conjunction with World Bank Group - Namibian legislation and policies. Practical best practice should lead the General decision making as to the standard followed. Environmental, Health and Safety Guidelines. • Managing the risks of adverse impacts on communities temporary induced Word Bank Group - labour influx. The impact is expected to be low and can be managed Good Practice through ESMP requirements. • Addressing Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) in Notes Investment Project Financing involving Major Civil Works. The risk of SEA/SH is limited, but the impact if realised is high. The ESMP provides for deliberate avoidance measures during construction and include guards against gender violence. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 19 7 MANAGEMENT REQUIREMENTS 7.1 Planning Phase The planning phase constitutes the phase before the onset of construction. It ensures all design and preparation requirements are in place before construction commences. Responsibility: The Project Developer shall consider these aspects in conjunction with the ECO. Table 4 Management Requirements – Planning RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO Administrative, NamPower Nampower will appoint a contractor with Appropriate contract. X legal and policy To fulfil the suitable experience with similar contracts and requirements administrative and reputable E&S risk management measures to legal requirements undertake the construction of the transmission line. ESS 2 + GN Preference will be given to Namibia based companies in constructing and operating the or Namibian affiliations, where reasonably practical, proposed project. and if tender requirements are met. should strive to appoint a Namibian company or with Namibian affiliation, to undertake the work, assuming that they are able to meet the tender requirements. The Resettlement Policy Framework (Appendix B) must Reord of X be implemented, and records provided before implementation construction starts NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 20 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO Monitoring The duration of the project should be taken into Montly monitoring X X X X requirements Implementation of consideration when budgeting and planning for reports the ESMP monitoring activities. Monitoring should be carried out ESS 1 + GN every month. Critical periods during which significant environmental X X impact could occur are to be identified, and the presence of the NamPower representative (who will co-ordinate with the ECO) during those periods to avoid unwanted impacts is essential. The Project Developer will avoid the manufacture, Checklist (incl. X X trade and use of chemicals and hazardous materials exemptions) and subject to international bans, restrictions or phaseouts quarterly review. unless for an acceptable purpose as defined by the conventions or protocols or if an exemption has been obtained by the Borrower, consistent with Borrower government commitments under the applicable international agreements BIODIVERSITY The objective is to integrate and coordinate the Developed X X X MANAGEMENT To optimise the site prerequisite design interventions and management Biodiversity SYSTEM plans for vegetation and Avifauna with the project Management Plan in terms of construction and implementation systems. ESS 6 + GN avoidance of sensitive habitats. Clearly indicate the different sensitivity zones in the Design X X X final layout design for the TL. maps/drawings Compliance with ESS6 NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 21 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO Uncontrolled vehicle activity is of major concern. Infrastructure design X X Careful pre-planning of construction activities must be drawings enforcing done to identify where infrastructure will be absolutely corridor. necessary for both construction and maintenance, overlapping these in a single infrastructure corridor. These infrastructure corridors must be clearly marked Construction drawing X X X prior to construction activities beginning, together with designated turning points and construction clearance Marked routes and areas. Turning points for heavy vehicles must be turning points on site. designated and adhered to. The area used must be constrained as far as possible. Specific actions are mentioned in the next two (2) X X X X X sections in terms of vegetation and avifauna. PROTECTION OF To limit the Review the existing Biodiversity Management Plan Develop system X X X X X PLANTS OF removal of plants (BMP) (Appendix A) and determine amendments and during final design / CONSERVATION of conservation implementation strategies with a vegetation specialist. before construction CONCERN concern. starts. ESS 6 + GN Updated BMP Involve a specialist to identify plants (eg aloes) that Plant list with X X are candidates for potential removal. Consult with coordinates. NBRI as to whether any of the plants must be brought to the National Botanic Garden. Record of Communication with NBRI. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 22 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO Take care to make these arrangements well in Plan with 3 month X X advance so that NBRI staff can schedule and plan for lead time. any needed plant relocation. (Contact: The Head of NBRI 061 202 2017) via the specialist coordinator for the Record of Biodiversity Management Plan. Please contact the Communication with specialist coordinator of the Biodiversity Management C Mannheimer. Plan, Colleen Mannheimer (Tel. + 264 61 233614, Fax + 264 61 233727). FAUNA RELATED To continue or A bird monitoring programme, pre-constuction, BMP - Avifauna X X X X MONITORING initiate the during the construction, and initial operational phase Monitoring Plan. REQUIREMENTS required that includes searches for bird mortalities based on monitoring proposed guidelines in the specialist study (as per Quarterly review / ESS 6 + GN procedures as per BMP). update. the bird specialist studies. If deemed necessary by the specialist, extend Evaluate with X X monitoring to include nocturnal monitoring episodes specialist. as per proposed guidelines. All monitoring data should be collated annually and Annual Monitoring X X X made public via NamPower. report in public domain SOIL Avoid soil erosion Pylons must be placed outside the 1:100 flood line, as X CONSERVATION instep terrain, described in the Drainage Specialist study (Muir, 2016). riverbanks and 1:100 flood line NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 23 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO Where this is not possible the pylon bases must be designed to withstand erosion from flooding and be provided with flood protection. DESIGN OF Implement staggered power line mitigation along the Designs reviewed. X X TRANSMISSION existing 220kV power line from Auas to Kokerboom for LINE PYLONS the majority of its length; In order to ensure the staggering, the following has been agreedprescribed ESS 6 + GN in the ESIA: • The new 400kV line will employ small pylon support To minimise the risk towers to match the height, as far as possible, to of power line-bird that of the existing 220 kV line collisions. • Throughout the route, the proposed 400kV line must run adjacent to and employ staggered pylons, such that the pylons of the proposed 400 kV line align with the midspan of the 220 kV line; • The two lines (proposed 400kV and existing 220 kV) cannot deviate from each other for more than 2 km in any 100 km length as this will negate the staggered pylon mitigation. The routing follows that proposed from Auas south to Reviewed marking X X the Kalkrand area to avoid the vulture-breeding areas recommendations north of Kalkrand. before construction. Near Kalkrand (BP010) 14 km of the line requires bird Marking diverters as it traverses a high-risk vulture area. recommendation on Maps and layout drawings. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 24 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO As a mitigation for bird collisions, mark overhead Reviewed marking X X X X conductors using bird flight diverters/deflectors, as recommendations indicated below (Figure 4). The marking before construction. recommendations are conceptual at this stage, and will need to be confirmed during the pre-construction Marking site visit: recommendation on Maps and layout • A short section of the line intersects a previously drawings. identified high-risk vulture site (south of point BP014: Figure 2). • White-backed Vultures Gyps africanus use this area and it has been agreed with NamPower that bird diverters must be added to this 14 km section on the earth wire of the proposed 400 kV line to reduce further any possible impacts by these large and relatively unmaneuverable species. • It was also agreed that the 14 km section would have 7km of diverters (ideally spirals on the earth wires of the proposed 400 kV) and 7km without. We suggest 2km section with diverters, alternating with 2km sections with no diverters to test their efficacy in reducing vultures collisions These would then be searched for collision victims as set out in the monitoring section. • This whole section will need to be included in the surveys described in the EMP below. A specialist needs to mark the areas along the route that are a significant risk in terms of potential bird collision. The areas above are only vulture breeding areas but there are also other areas, e.g. near the NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 25 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO Hardap Dam that should be considered for marking.The specialist needs to recommend the particular line markers (e.g. flappers) to be introduced to the line. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 Figure 4: A 14-km section (= blue line) of the new routing that passes close to known vulture areas. This section south of the NamPower coordinate of BP014 requires extra mitigation in the form of bird diverters. 26 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO A specialist should rovide perch structure positions for Designs reviewed. X X X X raptors on selected power line poles (mainly in large wash area; further sections outside the main study area to be confirmed). Work on construction to be undertaken outside the Construction X X X X winter breeding months where large vulture or raptors program are found breeding < 100 m from the line Construction activities must be carefully planned so as Construction X X X X X not to interfere with the breeding seasons of sensitive program species. Avoiding large tree nests or cliffs where raptors or Designs reviewed. X X vultures are breeding POVERTY To ensure that the During drafting of tender documents, NamPower (or X X X X ALLEVIATION AND project renders the appointed labour consultant) shall include provisions Criteria design and GENDER EQUALITY maximum level of designed to maximise the use of local labour. All Plan to include in poverty alleviation unskilled and where available semi-skilled labour shall Tender / Bid review. ESS 2 + GN possible, and to be sourced from local communities. Specific promote gender NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 27 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO equality in recruitment procedures shall be confirmed with economic Regional and Village Councils, and spelled out. opportunities. Identification and appointment of local people should List of potential X be undertaken in consultation with the regional and employees from local constituency-level authorities at least 6-months prior to communities the commencement of construction. NamPower shall include provisions in all contracts to Criteria design and X X X X ensure gender equality, i.e. equal access to all Plan to include in positions, given personnel qualifications including Tender / Bid review. aptitudes, experience, skills and abilities. The successful Tenderer should specify what X X percentage of the contract value will be assigned to capacity building (as per NEEP). The Tenderer should compile a capacity building plan that benefits all employees but specifically aims to enhance the skills of workers originating from the directly affected constituencies. Optimise local The Project Developer shall ensure that local firms Criteria design and X X service and enjoy preference during tender adjudication, subject Plan to include in contractor to the provisions of the Public Procurement Act. Tender / Bid review. procurement. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 28 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO TENDERING Ensure all Ensure this ESMP is included in all tender documents Tender documents X X PROCESS environmental and contracts. To make all bidding and review. and social implementation parties aware of all ESHS requirements ESS requirements are and is addressed in implementation methodology. included in all contracts of contractors involved in the project. Ensure adequate budgeting and financial provision is Tender documents X X allowed for the items in the above documents. review. ESS 2 + GN Develop, adopt, and implement Labor Management LMP document. Procedures (LMP) for the Project in line with national legislation and ESS2. The LMP will be applicable to LMP records direct workers, contracted workers, including casual laborers. Ensure that sub-contractor(s) in particular the civil Schedule of Plans X X X X works contractors, have appropriate environmental and social management systems and plans in place, which will likely include (as applicable) plans that cover: NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 29 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO • Occupational health and safety that comply with national standardsa s well as EHSG-G and EHSG- ET. ESS 2 + GN • Labour force management including a grievance GPN-LI management mechanism for workers; GNP-SEA/SH EPC to report to NamPower regularly on ESHS Monthly report X X X X performance including labor management and grievance management ( see Labour Management Procedures). EMERGENCY An item shall be included in the contract documents Tender documents X X X PREPAREDNESS of all contractors, as follows: review. AND RESPONSE PLAN The Environmental and Social Management System (ESMS) (implementation of the ESMP during Ensure the construction)Contractor will establish and maintain an requirement for emergency preparedness and response system so an Emergency that the client, in collaboration with appropriate and Preparedness and relevant third parties, will be prepared to respond to Response Plan is accidental and emergency situations associated with included in the the project in a manner appropriate to prevent and tender mitigate any harm to people and/or the environment. documents. Consult https://www.ifc.org/en/insights-reports/2015/publications- handbook-esms-general https://www.ifc.org/wps/wcm/connect/6147cbba-efe8- 4879-ba77- NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 30 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO c7af63bede7c/ESMS_Toolkit_General.pdf?MOD=AJPERES&C VID=nzhmvxC (Section 5, p 36. for guidelines to prepare an emergency preparedness and response plan). This preparation will include: • the identification of areas where accidents and emergency situations may occur; • communities and individuals that may be impacted; • response procedures; • provision of equipment and resources; • designation of responsibilities; • communication, including that with potentially Affected Communities; • periodic training to ensure effective response; and • collaboration with other relevant emergency agencies. The emergency preparedness and response activities Monthly report X X X X will be periodically reviewed and revised, as necessary, to reflect changing conditions. CONTRACTOR’S • Is responsible for the implementation of the ESMP. ROLE • Ensuring all tasks undertaken under the scope of work, are in accordance both with NamPower’s SHE policy as well as to the requirements of this ESMP. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 31 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO • Putting in writing a system of communication, in which all incidents and accidents are reported to the NamPower SHE section. • Ensuring that all employees receive SHE induction before commencing with works. • Ensuring that the work being done does not create a nuisance to the residents or animals on the property. If the contractor deems to continue work after the usual working hours, in the evenings and at night or over weekends, he must obtain the NamPower’s (Project Manager) and landowner’s permission before proceeding with such work. SURVEYOR ROLE • Ensures route alignment for the proposed power line is as per route given in the final ESIA (or after consultation with the SHE section if no EIA has been done). • Ensures that the final alignment of the route be fine-tuned to keep at least 50m away from any farm infrastructure (such as reservoirs, cattle kraals, pumps etc.). • Ensures that the servitude or power-line route, should it run in parallel to a stream or riverbed has a buffer of between 15 m between the servitude and the river. • Ensures that the ECO accompanies the surveyor during site handover. The surveyor is to align the straight sections of the power line so that its centre line would avoid significant tree species (such as NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 32 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert ECO a valuable shade trees or endangered tree species) as far as possible. • Documents the removal of any economically valuable trees or bushes (such as valuable shade trees) and clearly communicated to the ECO the reasons for removal. • The Surveyor, together with the ECO, should carefully consider the need to remove large trees in the servitude, and specify this only where technically necessary. • Rocky outcrops and inselbergs in the project area are sensitive from an ecological aspect; they harbour vegetation worthy of conservation, and the final power-line alignment must avoid all such sites. • The Surveyor should ensure all coordinates given in the ESMP of environmental or social sensitive areas are included on the spanning sheets for the powerline prior to construction. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 33 7.2 Construction Phase Responsibility: The NamPower shall take ultimate responsibility for these aspects, with delegation to the applicable project operator, and the various contractors. Table 5 Management Requirements – Construction RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO ENVIRONMENTAL The Project Developer shall appoint an Environmental Monthly feedback to X X X X MANAGEMENT Control Officer (ECO) who will be responsible to NP/EPC coordinate and monitor the adherence to the ESS 2/6 + GN To ensure Environmental and Social Management Plan (ESMP), Scope of adherence to the as well as the external environmental audit process. responsibility. ESMP. The ECO shall report regularly to NamPower (NP) and Quarterly Project Manager (PM) on the implementation of performance review. Environmental & Social measures. See section 5.3. The ECO is responsible for the coordination of and Communication X liaison with external stakeholders such as village records councils and communities, neighbouring landowners, and the affected land owner. Implement an external environmental and social Quatrely audit X X X audit system on a quarterly basis during construction schedule and on an annual basis during the operation of the Project. This shall be used to verify the effectiveness of the ESMP and implement adjustments if required. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 34 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Use the Biodiversity Management Plan to integrate Monthly feedback X X and coordinate the management plans for vegetation, and Avifauna with the project construction and implementation systems. Structure and operate 1) Stakeholder engagement Monthly system X (communication, publication, awareness campaign feedback etc), 2) appropriate Grievance mechanisms including an option for complainants to submit anonymous grievances (see Stakeholder Engagement Plan). An audit shall be undertaken during bush clearing (i.e. Quarterly reporting X at the start of the work) , during, as well as within a specified period after completion of the work but before the contract is signed off. The audit shall be used to identify non-conformance for which the Contractor shall take corrective action. The auditor may either be internal or external to NamPower. The contractor shall arrange an inspection with the X X X X project manager, who will inform the ECO, for the final inspection of the works. A first inspection will be done on which NamPower will draw up a snag list. Should the same items on the snag list still not be according to NamPower’s satisfaction on the second inspection, all direct costs incurred for re-inspection will be on the contractor’s account. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 35 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO CONSTRUCTION Manage The construction schedule and process should be Programme and X X X X PROGRAMME interaction with designed to avoid the high tourist and hunting monthly records of the land owners. seasons. The landowners and users involved in tourism implementation. activities should be requested to confirm this information as part of the detailed planning process prior to construction. The construction schedule should be discussed with the commercial farmers to enable them to plan the rotation of livestock accordingly. Their limitations should be accommodated, where possible. The schedule and approach to construction must be presented to the directly affected receptors and constituency leaders for input prior to finalisation. Before work commences, NamPower should inform all affected landowners, nearby community members, and authorities about the project, at least 14 days before the start of the project. PERSONNEL To ensure Personnel should limit their contact with farm workers Minimise incidents X X CONTACT WITH personnel contact and other permanent residents of the area. involving contractor RESIDENTS with residents or employees. the community is ESS 2 + GN is a safe and GPN-LI regulated Any person making himself guilty of violence, No complaints X X X GPN-SEA/SH process. harassment or any other activity deemed received by inappropriate by the landowner, must immediately be landowners removed from the site. concerning NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 36 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO The distribution or supply of intoxicating liquor or drugs inappropriate of any kind by the employees of the contractor or any behaviour of contractor is strictly prohibited. contractor employees. The contractor shall inform the owner or his legal Contact record X X X representative before entering onto any private property, of his intention to do so and shall make such arrangements with such owner or his legal representative as may be necessary to ensure free and unhampered entry to, and movement on or over the property concerned, for the duration of the project. This should be done at least one month in advance and written proof of such communication should be available at all times. Whenever reasonably possible, the contractor shall meet with the landowner / representative of the property, introduce himself and the company he represents and explain the scope of the work. The landowner / representative must have knowledge of the planned route and duration of work on the property prior to the commencement of the work. This shall be done in due courtesy to the owner / representative. The contractor must ensure that the owner or his legal representative fill in forms containing the following information, before and after the contractor has worked on the property (these forms must be presented by the contractor to NamPower, whenever NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 37 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO the company requests it) and a copy shall be handed to NamPower at the end of the project. Before entry, to be completed and signed by the farm owner: • The state of their properties and assets prior to construction; the inclusion of photographs should be encouraged. Activities to be conducted on the farm (e.g. camping, construction etc.). • Specific conditions to be met on the farm. • Dates when entry is needed. • Farmer’s signature (if the farmer or his legal representative does not agree to sign the form, this must be noted on the form along with a list of names of all the people present at the meeting). • Contractor’s signature of commitment to adhere to the requirements. Upon leaving the farm, to be completed and signed by the farm owner: • Post-construction, the affected landowners or users should be invited to join NamPower and the appointed contractor for a ‘walk down’ the power line route to identify any outstanding issues. • Remarks on compliance and misconduct • Issues still to be resolved • Post-construction, the site should be reassessed to ensure that the farm is left in an acceptable state. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 38 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO ACCESS TO To ensure rights of • Roads marked with no entry signs, shall not be PRIVATE PROPERTY property and used. owners • Fences or gates of landowners shall not be damaged when gaining access to the servitude. • Gates and locks shall be regularly monitored to ensure that they are secure. • Gates to be left as they are found. If found opened, they must be left open, and if closed, they must be closed again upon entry. • If no gates are available at crossing points, landowners shall be informed prior to the loosening and crossing of fences. Fences loosened and crossed shall be immediately restored to its original state and to the complete satisfaction of the landowner. • All gates shall be fitted with locks and kept locked at all times during construction. NamPower must be supplied with three copies of these keys. Once the contractor has left the site, all gates shall be fitted with NamPower locks. STAKEHOLDER To ensure there is Reasonable contact should be made and Monthly system X X X ENGAGEMENT a clear maintained with the stakeholders of the project. feedback AND GRIEVANCE mechanism for PROCEDURE the public to The Stakeholder Engagement Plan provides the remain updated standard NamPower Grievance Mechanism. ESS 2 + GN on the GPN-LI construction GPN-SEA/SH process and to have access to a clear grievance NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 39 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO mechanism for complaints. A grievance procedure should be in place to deal Monthly grievance X X X X with community grievances in a satisfactory manner, procedure feedback and should at least include the following: • Identify the position on site where responsibility will be assumed for putting in place and managing the grievance procedure. • Ensure the current stakeholder database is updated. • Publish at the onset of the project, with the basic elements of it – construction time frame, contact details, who to contact for job opportunities, grievances, etc. The publication should be made in the local newspapers and on posters put at the local retail stores in Rosh Pinah and as advised by Roshskor. • The publication should also be placed on the website and Facebook page of the project and e-mailed to the applicable parties on the stakeholder database. • The poster shall contain a grievance mechanism – a method for community members to lodge complaints. The grievance mechanism shall state (1) Who can raise complaints (affected communities) (2) Where, when, and how community members can file complaints (this should preferably be in writing, unless the NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 40 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO complainant is illiterate, in which case the ECO should assist the complainant to articulate the complaint (3) Who is responsible for receiving and responding to complaints, and any external parties that can take complaints from communities (4) What sort of response complainants can expect from the company, including timing of response (5) What other rights and protection are guaranteed. • The community shall be regularly reminded as above, of their right to submit and receive responses to grievances. • The ECO, who is responsible for handling grievances, shall ensure that the grievances (1) are received and registered (with adequate documentation as reference), (2) reviewed and investigated, (3) resolution options are considered and an appropriate one is selected and implemented, (4) the grievance is properly responded to and the matter closed out, and (5) the success of the resolution option is monitored and adapted where necessary. ACCOMMODATIO The locations of the worker camps and laydown areas Accommodation X X X X N AND PERSONNEL To ensure that the should be identified in consultation with the relevant plan in place, MANAGEMENT impact of local authorities and land owners. Agreement should Periodical review. Contractor be given by the landowner and all neighbouring ESS 2 + GN personnel on the landowners in writing. environment is minimised. Such accommodation should be placed in an already disturbed area. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 41 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO No permanent accommodation facilities shall be Periodical review. X X X X allowed on site. Provide facilities including access to Periodical review. X X X X canteens/hygiene facilities/appropriate areas of rest to promote health, safety and well-being of the Contractor workers. A Labour Management Plan will be required which Monthly system X X X X comply with the Labour Act and national feedback employment regulations. The worker camps should be established and Accommodation X X managed in a manner that ensures that the workers plan in place, have access to all basic services and occupational periodic review. health and safety regulations are to be adhered to by the contractor. Workers should not need to exit the camp. Basic needs will include but may not be limited to food, water, sanitation, accommodation, recreation and medical care. The worker camp should be fenced and access to and from the camp strictly controlled to prevent trespassing into unauthorised areas. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 42 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO GPN-LI Uncontrolled labour influx may cause socio-economic Communication X X and environmental risks such as prostitution, health schedule and and disease risks, and uncontrolled access to the site. records. The contractor must have a clear communications instrument, distributed to the local community and regional population, which make employment policies and procedures clear. EMPLOYEE To ensure that the All staff shall receive an induction course prior to Induction and X X AWARENESS entire construction commencing work. The ECO shall discuss the ESMP reinforcement plan RAISING workforce is and Code of Conduct (CoC) with all employees and and records. aware of the make sure that all understand the contents and ESS + GN provisions of this importance thereof. ESMP and the reasons for All employees will agree to the CoC in writing. enforcing them. Photographs of specific sensitivities such as Photos in induction X X vegetation, etc. shall be used to sensitise the and reinforcement workforce. material. GPN-LI Workers Code of Conduct to comprehensively cover, Code of Conduct X X X GPN-SEA/SH but not be limited to the areas of respecting local review residents, their livelyhood activities and privacy, right to property, Gender Based Violence, SEA and Sexually Transmitted Disease, including relevant disciplinary measures, penalties and provisions for prosecution, prohibition of poaching, hunting and any other NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 43 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO damage to biodiversity, flora and fauna, specifically in the designated “no go” areas. Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) should be specifically addressed and the criminal consequences of the contravention emphasised. The employees shall be explained why this ESMP is Induction and X X being enforced, i.e., the need to protect the reinforcement plan environment. and records. Constant reinforcement is crucial. Induction and X X reinforcement plan and records. New employees who join the project later shall Induction and X X receive an induction course before they commence reinforcement plan with work. and records. Acknowledgement of attending the induction course Induction and X X and understanding the contents of it shall be signed reinforcement plan off and the attendance register kept on record. and records. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 44 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Personnel performance appraisal shall include Records of X X environmental compliance issues. contravening the ESMP. SAFETY AND To aim for zero OPHSMP approved, X X Draw up and implement an Occupational and Public SECURITY incidents and monthly accidents on the Health and Safety Management Plan that includes the implementation ESS 2 + GN construction site. following: reports and EHSG-G periodical review To ensure there Site visitors records. are emergency • The site supervisor shall be contacted before an response intended visit by an outside visited from an procedures in authority such as from MEFT, MHSS, etc. so that place in case of he/she can inform such visitors of the necessary incidents and safety requirements before entering the site. accidents. • Visitors shall also be made aware that they will be required to wear the necessary PPE (Personal To ensure security Protective Equipment) on site. measures are in • The Contractor shall ensure the least potential place to protect safety hazards during construction. The property and life Contractor’s plan to achieve this shall be for the duration of discussed at the project initiation meeting. the contract. Local community and general public • Develop and apply a Public Safety and Awareness Plan. • Develop danger signs along the farm boundaries and public roads that warn the public of the construction activity. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 45 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO • Abnormal loads will operate under an approved transportation plan with the necessary traffic routes and traffic accommodation plans in place • The Contractor shall liaise with the Roads Authority for their approval of road use and the conditions to be imposed. Abnormal load permits are to be acquired for every load. • Regional and Local traffic officials should assist abnormal load vehicles through the towns. • Construction and abnormal load traffic should be limited to outside the typical traffic peaks in build- up areas. • Abnormal loads should not be transported during the normal traffic daytime hours from 08h00- 17h00. • Once construction is completed the roads should be inspected and repaired where necessary. • Proper traffic and safety warning signs shall be placed at the construction site entrance to the satisfaction of the Project Engineer (NamPower)and the Roads Authority. • Develop a Traffic Emergency Preparedness and Response Plan. Construction personnel • The Contractor shall adhere to the regulations pertaining to Health and Safety of the Labour Act, including the provision of protective clothing, failing which the Contract may be ended with immediate effect. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 46 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO • The Contractor shall enforce relevant Health and Safety Regulations for these specific activities. • Staff will be trained in the appropriate use of PPE and the potential consequences if it is not used. The use of PPE shall be enforced. • Make sure that all staff are equipped and know how to use safety and Personal Protective Equipment (PPE). This includes safety goggles, ear plugs, dust masks, steel-toed shoes, gloves, overalls, etc. • Signage indicating the use of PPE will be required at appropriate locations. • Keep a comprehensive first aid kit at construction points. • Ensure that all staff know where the first aid kits are located and who is trained in first aid. • At least one person must be available on site that is trained in first aid. • All injuries and near miss incidents will be reported to the Project Engineer (NamPower) and recorded in a Health and Safety report to be submitted to the developer’s operational manager on a monthly basis. Measures to prevent recurrence shall be implemented and included in the monthly report. • Establish an emergency rescue system for evacuation of injured people, if needed. • Emergency procedures for accidents shall be communicated to all employees. • Emergency facilities to be identified as near to work as possible (police, fire brigade, and NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 47 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO hospital). Emergency telephone numbers shall be prominently displayed in the site office as well as on the outside of the site office. • Contact details of the Contractor and the second in charge must be forwarded in writing to land owners and village councils. • The local farmer association or community shall be informed in a case of fire as soon as possible. Do not wait until the fire is out of control. • No alcohol/drugs are allowed on site and anyone found to be under the influence of alcohol/drugs will be disciplined accordingly. Transport related safety • All drivers must adhere to traffic regulations at all times. No speeding shall be allowed. • All vehicles shall use the 4-wheel drive mode only on site. • The speed limit at the construction site will be 30km per hour. • No driving on site shall be allowed after 19h00, unless with agreement (permission) from relevant authorities. • Make sure all drivers/operators have valid licenses for the vehicles/equipment they are driving or operating. Copies of these records must be kept on file and must be readily accessible on site for inspection. • Make sure all vehicles are roadworthy. Repair faulty brakes, exhausts, etc. immediately. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 48 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO • Good driving and adherence to safety rules will result in a minimum number of road and workplace accidents. • Permanently wet areas should be shown on the spanning sheets. No vehicles shall be allowed in such areas. Only existing roads through such areas may be used with the approval of the landowner. No equipment that can cause irreparable damage to wet areas shall be used. • There must be a buffer line of at least 15m between the servitude of the power line and any water-containing body (rivers, vleis and pans), if the power line happens to run parallel to it. Fire safety • Fire extinguishers (with valid service date) shall be readily available at the construction site and where hot works takes place. Staff members from the construction team must be designated and trained to handle emergency situations such as fires, and trained to handle the necessary emergency equipment. • Fires are to be limited to the campsite only, as this will reduce the fire hazard. Any cases of veld fires caused during the construction period must be reported immediately. Damage caused by these fires will be remedied by the contractor. • If the need to make a fire on route (along the line, at any place except the campsite) arises, such a fire must be made inside a container or NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 49 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO on the ground, inside a shallow hole, surrounded by rocks. • All fires must be fully extinguished before it is left un-attended. General Safety • Emergency procedures shall be in place for incidents and accidents on site and staff trained in these procedures (See the requirement for an Emergency Response Plan). • Indiscriminate movement outside the construction areas shall be avoided. The area to be used for construction should be demarcated. • It is important that the necessary precautions be taken to protect property against theft. • Nobody shall carry any firearm or store it in his vehicle or at the construction site. • Dangerous areas shall be clearly marked and access to these areas controlled or restricted. • All site visitors shall report to the site office before entering the construction site. No visitors shall be allowed on site without the permission of the Contractor, and without receiving safety induction. • Train people who handle fuels in the correct procedure / technique to transfer fuels. • Food catering and preparation shall be done by the Contractor in an enclosed space only, using gas/electrical/solar cooking methods. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 50 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO • No fires shall be lit on the construction site. • Smoking is prohibited in areas where it is a fire hazard, e.g., fuel storage areas, workshops, etc. Thorough Develop and apply a Hazardous Material HMMP approved, X X HAZARDOUS management of Management Plan including a Hazardous Material monthly MATERIAL hazardous waste implementation Emergency Preparedness and Response Plan MANAGEMENT materials. reports and • All hazardous materials shall be stored (on periodical review EHSG-ET The protection of bunded area), handled and disposed of records. the natural according to the applicable Material Safety integrity of the Data Sheets (MSDS), as well as applicable Zero spills. environment. regulations (e.g. the Health and Safety Regulations). No environmental Adequate staff pollution occurring. • Hazard identification signage shall be erected at awareness of appropriate locations. Management procedures and Emergency • All items for treatment as specified in the according to Response Plans. Material Safety Data Sheets (MSDS) for procedures. hazardous materials shall be available in the first aid kit. • Used oils, fuel, paints, grease, and solvents should be stored in drums or other suitable containers, which must be labelled, sealed, and removed from the site to an appropriate disposal site or recycling facility. • Areas shall be monitored for spills and any spills shall be contained, cleaned, and rehabilitated immediately. • Oil contaminated soil must be collected, stored and removed for disposal at an appropriate NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 51 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO waste storage facility. The area, from which the contaminated soil was taken, must be filled with new soil. The new soil must be free of contamination, and should not be taken from a spot within a 100-metre radius of where the spill occurred. • In the event of a hazardous spill on site or during transportation of these substances to or from the site, the followings actions must be taken: • Stop the source of the spillage immediately. • Immediately contain the spillage by shovelling a soil bund wall with around it. • Absorb the oil spill as quickly as possible with the supplied spill kit. • Report the spill to the site supervisor. • In case of a major spill the Manager: SHE (NamPower) must be contacted and arrangements must be made for the implementation of the necessary clean-up activities. • Collect contaminated soil, water and other materials and dispose of it at an appropriate hazardous waste storage site. • Any rehabilitation activities needed because of an oil spill will be at the cost of the contractor. • Have sufficient fire fighting equipment available at the campsite. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 52 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO • Ensure that all staff are adequately protected and educated about the safe and proper handling and disposal of hazardous substances. • Hazardous substances should not be stored in an area that is situated within the migratory path of large mammals. MAINTENANCE OF Thorough Vehicle maintenance and refuelling activities must be X X Mitoring weekly and VEHICLES management of conducted within a bunded area. records of spills. hazardous waste EHSG-G materials. No environmental pollution occurring. The protection of Vehicle maintenance and refuelling activities may not X X the natural be carried out outside the campsite, except in cases Management integrity of the of emergency. according to environment. procedures. Adequate staff During servicing of vehicles, especially during X X awareness of emergency veld repairs, a suitable drip tray shall be procedures and used to prevent oil spills. Emergency Response Plans. In the event of a breakdown in the veld any oils spills X X shall be cleaned up immediately. The following shall apply: • All contaminated soil shall be removed and placed in containers. Contaminated soil can be taken to one central point, where soils can be treated or removed for disposal at an approved site. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 53 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO • Bigger spills can be treated on site with absorbent chemicals such as Peat-Sorb. • Major spills must immediately be reported to the project manager and the contractor shall employ a specialist contractor for the bio- remediation of contaminated soil. PERSONNEL AND To prevent or Develop a relevant Community Health and Safety Community Health X X COMMUNITY minimise the Management Plan based on the content of the and Safety HEALTH potential for Occupational and Public Health and Safety Management Plan community Management Plan as well as the following items: ESS 2 +GN exposure to Weekly disease EHSG-G water-borne, • All Contractor’s staff and any sub-contactor shall awareness raising water-based, identify all known water-borne, water-based, under workers water-related, water-related, and vector-borne diseases, and communicable diseases that could result from or Review absenteeism and vector-borne and screen recorded diseases, and spread further due to the project activities and/or the influx of temporary or permanent illness for target communicable diseases. diseases that project labour. could result from • These shall at least include HIV/AIDS, Have a disease project activities, Tuberculosis, Covid-19, bacterial diarrhoea, management taking into hepatitis, and any other applicable diseases at procedure in place. consideration the time of project implementation. differentiated Weekly PPE • The Contractor shall develop documented exposure to and monitoring. programmes to prevent and minimise the spread higher sensitivity to of such diseases during the construction period. Health check-up vulnerable groups. The prevention shall include the in-country procedure in place guidelines for the prevention of the identified and monitored diseases, as well as international guidelines that monthly. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 54 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO may be available at the time, such as those of the World Health Organisation. All staff shall be made aware of such programmes Awareness raising X X and it shall be mandatory for all staff to adhere to the records precautions being put in place. The Contractor shall provide to staff any personal Record of material X X protective equipment (PPE) as well as cleaning agents and sufficient clean water that may be necessary to ensure good hygiene at the workplace and prevent any of the identified diseases. The Contractor shall have a trained nurse available to Station with qualified X X the staff, who shall provide a protocol for regular person available. health check-ups and treatments. CONSERVATION To minimise The planning and design of the vegetation and soil Activity planning, X X X X X OF THE NATURAL damage to soil, rehabilitation starts before construction is allowed. The approval and review AND HISTORICAL vegetation, rehabilitation section on p43 and forward should be of plan. ENVIRONMENT habitat and read in conjunction with this section. heritage resources Audit and review ESS 6 + GN during the The objective of bush clearing is to trim out or clear the periods. construction minimum number of trees and bush necessary for the Flora safe electrical operation of the power line. phase. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 55 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO The contractor, NamPower and the landowner prior to X X X X bush clearing shall discuss all environmental factors. Should there be any changes to the route due to environmental factors, NamPower must first be consulted. Before construction, areas to be disturbed should be Q2 Records of planning X X prepared by plant relocation and topsoil preservation. 24 ff process and Any topsoil heaps should be placed upwind of the implementation. damaged area (i.e.: south west, in the path of the prevailing winds). Smaller heaps at each construction area would be preferable to large heaps. Once construction is complete, these heaps should be used to return the site to as natural an appearance as possible A permit is required from the Ministry of Environment X X and Tourism for the removal of vegetation within 100m from a riverbed or any protected species (in terms of the Forest Act of 2001). NamPower is responsible for applying for such a permit. A strip, only wide enough to allow for vehicular X X movement, shall be cleared for access roads. No bush clearing is allowed outside the servitude. While clearing the trees near the power line route, X X falling distance of any tree or trees, which are likely to fall on the conductors of the power line, as has been identified by visual inspection, shall be considered. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 56 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Such “high risk” trees, or its branches, shall be felled only under supervision of a NamPower representative. Environmental sensitivity shall be taken into account X X when clearing is done. Laws protect environmentally sensitive areas (such as wetlands, river crossings, areas of endemicity etc) and it is essential to obtain permits before the undertaking of any activities in such areas. The sketch plans should indicate existing or potential problem areas identified during site inspection of the power line route. Vegetation shall only be cut to allow for the passage X X of the pilot-cables and headboard. No vegetation clearing shall be allowed across ravines and gullies, as this vegetation will very rarely interfere with the clearance to a strung conductor. It is imperative that while maintaining the specified X X clearances, all tree branches capable of producing off-shoots in due course shall be cleared in such a way that it will be impossible for any of the off-shoots of these trees to grow towards the power lines. Near the power line, overhanging branches are not impermissible. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 57 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Manual bush clearing, as opposed to clearing using a X X bulldozer, is preferable, in order to minimise vegetation loss and hence reduce the risk of soil erosion. Where there are no real obstacles, where vehicles can simply drive over an area, or where obstacles can simply be removed by hand, blading shall not be used. To minimise soil erosion, vegetation should be trimmed as opposed to the complete removal of vegetation. When manual bush clearing is impractical, blading X X shall be used, but the blade shall be kept approximately ten centimetres from the soil surface to minimise the impacts to the soil surface and top layer, small plants and the root systems of larger plants. Big trees with large root systems shall be cut manually and removed, as the use of a bulldozer will cause major damage to the soil when the root system is removed. Stumps shall be treated with an approved herbicide. All the felled branches, cleared bushes/shrubs, and X X tree stubs etc. shall be removed from the line route and carted away in order to allow the free movement of maintenance vehicles and crews. This plant material may however not remain in heaps and should be scattered over the terrain. When needed, this plant material can also be used to combat soil erosion. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 58 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO No burning of vegetation is allowed as an alternative to cutting of vegetation. At the outset of construction (and during construction Q2 Construction activity X X as may be applicable), the ECO and the Contractor 24 ff and photographic shall visit all areas to be disturbed, including the records, incl. access road and other areas. Work shall be carefully construction planned before entering the worksite to limit the total drawings indicating footprint of the operations: no-go areas. • at the towers to 80m by 80m maximum, • at access roads to 3m wide and • line clearing to 12m wide. Access and parking at work sites shall be planned and Q2 Construction activity X X organized in order to facilitate the work intended at 24 ff and photographic each site while preventing the creation of new tracks records, incl. around work sites. construction drawings indicating no-go areas. Areas to be disturbed shall be clearly demarcated Q2 Construction activity X X with small pole markers, and no land outside these 24 ff and photographic areas shall be disturbed or used for construction records, incl. activities. The pole markers shall remain in place construction during the operation of the project and shall be drawings indicating removed during decommissioning. n-go areas. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 59 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO A Botanist or rehabilitation specialist in conjunction Q2 Records of planning X X X with the ECO and NBRI shall be responsible for any 24 ff and implementation. plant relocation (eg aloes). In the case of relocation on-site (eg. Aloes), plant Q2 Records of X X X survival shall be assessed until relocation is deemed 24 ff assessment as complete and stable , notably each growing season determined when others of this species in the area are found to have come into flower or leaf. Monitoring Method to be determined by rehabilitation practitioner involved. No bush clearing shall be allowed on river- and stream X X banks unless the line crosses the river or stream and this vegetation poses a risk to the line. In such cases, NamPower should be consulted on the action to be taken. Where the power line crosses river beds, an attempt should be made to prune riverine vegetation (over 4 m in height) as opposed to its removal. Where clearing is done near a river, the contractor must ensure that no felled bushes/branches/shrubs are left behind in the riverbed. All vehicles must stay strictly in the one track made – Q2 Access designs X X X X be careful to drive carefully in this track and not to 24 ff implemented. deviate from it. Weekly monitoring, Existing tracks should be used to at least reach the records of incidents tower sites rather than to drive through the fields. A NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 60 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO detailed plan with routes to the poles should be and corrective produced and availed to the contractor. measures. All conditions that the landowner may have shall be noted and adhered to. Turning points for vehicles should be carefully planned Q2 Access designs X X and designated to cause minimal disturbance to the 24 ff implemented. environment. Weekly monitoring, records of incidents and corrective measures. Reasonable precautions shall be taken to avoid damage to land, crops, grazing fields, farm gates, or property. No cultivated lands, fences, or structures (permanent or temporary) may be removed or damaged, unless NamPower’s written consent for doing so has been obtained. All damage to commercial crops shall be recorded immediately and a photographic record of such damage must be kept. Alien species and declared weeds must be identified and eradicated during rehabilitation. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 61 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Consult the ECO before any new areas are disturbed Q2 Activity planning, X X which have not yet been visited. 24 ff approval and review. Audit and review periods. Fauna Before construction starts, inspect each section for Q3 Site review X X X any signs of bird nesting activity; avoid disturbance of 23 nesting birds, in particular large raptors, bustards - species Q1 24 Offsite drainage lines must remain strictly undisturbed. Q2 Weekly monitoring, X X 24 ff records of incidents and corrective measures. No interaction, poaching or harvesting of birds, chicks X X or eggs are allowed. Red data species must not be disturbed in any way, especially when breeding. No off-road driving shall be allowed. Q3 Weekly monitoring, X X 23 ff records of incidents and corrective measures. Construction activities must be planned carefully so as X not to interfere with the breeding, calving and lambing season for most animal species. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 62 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Termite mounds should only be disturbed if they pose X a significant technical constraint. Only termite mounds inside the construction corridor should be demolished. Care should be taken when demolishing the termite mounds, since many other animals, other than termites, live inside these mounds. Some of which can threaten the safety of people. Underground burrows must not be flushed, closed up, X X or destroyed, on purpose, even if within the servitude area. Introduce 30 km/h speed limits on site. Q3 Awareness raising a X X X X 23 ff induction and On gravel roads, the speed limit for trucks will be 40 refresher courses. km/h and for other vehicles, it is 60 km/h – 80 km/h depending on the condition of the road. Weekly monitoring, records of incidents and corrective measures. Educate personnel to be sensitive to animal Q2 Awareness raising an X X X X movement on roads, especially tortoises and 24 ff induction and chameleons. refresher courses. Weekly monitoring, records of incidents and corrective measures. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 63 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Snaring, poaching, killing, taunting, collecting, Q2 Awareness raising a X X smuggling, or abuse of animal wild or domestic 24 ff induction and animal is prohibited. refresher courses. Weekly monitoring, records of incidents and corrective measures. If any reptiles, such as Namaqua chameleons as well Q2 Awareness raising a X X as varied tortoise species, are encountered during 24 ff induction and construction activities, they need to be carefully refresher courses. removed and relocated to an undisturbed area. Weekly monitoring, records of incidents and corrective measures. No animal shall be killed intentionally, chased, baited Q2 Awareness raising a X X or harassed, and no eggs shall be removed from a 24 ff induction and bird’s nest, nor may the nest be tampered with or refresher courses. damaged. Weekly monitoring, Any staff members caught in such an activity shall be records of incidents handed over to the relevant authorities and shall be and corrective dismissed/disciplined according to their employment measures or legal contract. actions taken. Avoid small mammal / reptile and bird nesting. Q2 Awareness raising a X X 24 ff induction and refresher courses. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 64 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Weekly monitoring, records of incidents and corrective measures. Keep an eye out for ground nests and mark their Q3 Awareness raising a X X X position to avoid accidental destruction. Ask a bird 23 ff induction and specialist for advice on protocols regarding particular refresher courses. nests. Weekly monitoring, records of incidents and corrective measures. No domestic animals (such as cows, chickens, dogs, Awareness raising a X X cats, goats or sheep) may be kept either at the induction and campsite on the construction site since they can refresher courses. introduce diseases or interbreed with the animals occurring naturally in the area. Monthly monitoring, records of incidents and corrective measures. No domestic or wild animals belonging to the Weekly monitoring, X X landowner, may be caught and killed, unless written records of incidents consent was given by the owner of the animal. and corrective measures. Incident record. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 65 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO No wood shall be collected from the construction Q2 Awareness raising a X X area. Meals shall be provided and prepared only by 24 ff induction and the Contractor, using only electrical and/or gas refresher courses. cooking methods in an enclosed area (no fires/firewood). Facilities inspections. Weekly monitoring, records of incidents and corrective measures. Avoid unnecessary noises such as hooting. Q2 Awareness raising a X X 24 ff induction and refresher courses. ARCHAEO - Under the Heritage Act of 2004, it is illegal to remove a Q3 Awareness raising an X X LOGICAL SITES fossil or an archaeological site without the consent of 23 ff induction and ESS 8 + GN the National Heritage Council of Namibia. refresher courses. The chance-find procedure provided in Appendix D Implement To ensure a should be in place. procedure with proper chance- weekly monitoring. find procedure for Before construction, the contractor shall inspect the archaeological area for any heritage sites that may be of No destruction of or sites. significance. These would include any mounds, walls damage to known packed of stones, gravesites etc. If any such site is sites. found, the area shall be cordoned off, and NamPower must be informed, who will, in turn, inform Management of the Monuments Council or an Archaeologist. existing sites and new discoveries. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 66 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO No litigation due to the destruction of sites. Should any new finds come to light at any stage Q2 Incident monitoring, X X X during the construction phase, the site shall be 24 ff records of incidents demarcated to prevent damage and the chance- and corrective find procedure be implemented. measures. SOIL Avoid soil erosion Access tracks for construction to be with as little X X CONSERVATION instep terrain, river disturbance to the stream bed as possible. banks and 1:100 flood line The track surface should follow the stream bed level as closely as possible. Erosion and drainage problems must be minimised by avoiding tracks crossing contours at right angles. Construction activities within the streams should be X X stopped for the duration of flow. Measures must be put in place to avoid erosion at X X river and stream channel crossings, and at places where existing erosion scars and dongas are encountered to avoid any further erosion at these points. Deep ruts and inaccessible sections must be repaired X X to avoid vehicles having to drive around bad sections (i.e. mud, deep ruts, and loose sand) thereby creating new tracks. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 67 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO After construction in sandy areas, the entire width of X X X the servitude should be levelled. Dicing is a suitable means of achieving this. Levelling of the servitude width is required to ensure compaction by construction vehicle tracks is minimised as well as to reduce preferential flow paths during rainfall runoff. Crossings of dongas and eroded areas shall be X X thoroughly planned. Water diversion berms shall be installed at donga crossings to ensure runoff water on the servitude does not run into dongas and cause an erosion hazard. Disturbances of topsoil on tower sites with severe X X X X slopes shall be minimised at all costs. At any tower site, where conventional foundations are installed, the contractor shall remove the topsoil (the top 10 cm of soil) separately and store it for later used during rehabilitation of such tower sites. Slopes in excess of 2% must be contoured and slopes in excess of 12% must be terraced. Other methods of rehabilitation of tower sites may also be used. Contour banks shall be spaced according to the slope on tower sites. The option of re-seeding should be investigated in X X X disturbed area NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 68 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO In mountainous / rough terrain, the contractor shall be X X X X responsible for any reasonable prevention of soil erosion should either the landowner or NamPower require it. ROAD To ensure the Construction of access roads should be only for Q2 Planning and design X X X CONSTRUCTION / making of roads essential access. 24 ff review at each step UPGRADING AND are kept to a of approval. DRIVING minimum, so as to Al track construction and changes to tracks will only avoid be allowed with written consent of of the Project Access designs unnecessary Manager and land owner. implemented. damage to the Damage to access roads due to the movement of Weekly monitoring, fragile desert vehicles must be reported to the Project Manager records of incidents plains. and the landowner. All repairs must be done and corrective To ensure the immediately and to the satisfaction of the landowner. measures. roads used are Continuous well maintained. monitoring and To ensure that review. track discipline is maintained at all times by the entire construction team. To minimise amount of dust generated. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 69 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO No roads shall be constructed on slopes of more than X X X 20% unless such roads follow contours. In such areas, the contractor shall use existing roads or alternative methods of construction. Do not make new roads when the quality of existing Q2 Access designs X X roads deteriorates. Repair or upgrade existing roads. 24 ff implemented. Weekly monitoring, records of incidents and corrective measures. Road construction methods shall ensure good road Q2 Access designs X X surfaces to preclude vehicles driving off road to find 24 ff implemented. smoother surfaces with less corrugations or potholes. Weekly monitoring, records of incidents and corrective measures. Do regular road maintenance to ensure good road Q2 Access designs X X X surfaces i.e., grading of the road once every two 24 ff implemented. weeks (or as frequently as necessary) during the construction phase. The road should also be sprayed Weekly monitoring, with water and biodegradable dust suppressor (grey records of incidents water if available) once a day to limit dust pollution. and corrective A proposal could be made to the contractor’s measures. representative if it is found that the dust suppressor keeps down the dust for longer than one day, in which case the daily restriction may be extended. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 70 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Demarcate areas that are prone to corner cutting to Q2 Weekly monitoring, X X avoid such. 24 ff records of incidents and corrective measures. The drainage lines which are more sandy, are prone Q2 Access designs X X to parallel tracks, but are also sensitive to disturbance. 24 ff implemented. They are more prone to erosion and are good habitat to birds nests, bat foraging, and other small fauna. Weekly monitoring, Particular care should be taken to avoid parallel records of incidents tracks and unnecessary driving in the drainage lines. and corrective measures. No roads shall cut through a river and stream banks as this may lead to erosion. If no other alternative is available, care should be taken to stabilise the bank. Existing drifts and bridges may be used if the landowner gives his consent. Such structures shall then be thoroughly examined for strength and durability before they are used New drifts and bridges shall only be constructed with the approval of NamPower and the landowner. The installation of concrete pipes and drifts, to facilitate access, shall be at the discretion of the project manager. Activities causing dust shall be limited along access Q2 Weekly monitoring, X X roads by keeping to the driving speed (30 km/hr) on 24 ff records of incidents all tracks in the project area. and corrective measures. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 71 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO As far as possible existing tracks within the present Q2 Access designs X X servitude shall be utilized for both construction and 24 ff implemented. maintenance. These shall be clearly indicated, together with designated turning points. Weekly monitoring, records of incidents and corrective measures. Vehicles driving along the Project Area shall engage Q2 Weekly monitoring, X X four wheel drive to prevent spinning and consequent 24 ff records of incidents impacts on fragile desert surfaces. and corrective measures. Large vehicles shall have right of way and light Q2 Weekly monitoring, X X vehicles shall leave the road (at the designated 24 ff records of incidents areas) to allow for an oncoming heavy vehicle to and corrective pass. measures. In order to promote visibility and communication Q2 Weekly monitoring, X X between drivers (and prevent accidents with 24 ff records of incidents consequent environmental impacts) vehicles shall and corrective always be driven with their lights on and indicators as measures. per road traffic rules shall be used on the Project Area. Markers shall be used to delineate the chosen access Q2 Access designs X X tracks into the construction area. 24 ff implemented. Weekly monitoring, records of incidents and corrective measures. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 72 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Only Roads Authority (RA) recognised access points Q2 Access designs X X may be used when turning off a RA proclaimed road 24 ff implemented. (trunk, main, district and farm roads). Where a deviation from this is unavoidable, appropriate Weekly monitoring, temporary warning signs should be erected and records of incidents clearly visible to road users. and corrective measures. Erect warning signage at the access points to warn motorists about construction activities and heavy vehicle movement where appropriate. Only use designated turning circle areas. Use 3-point Q2 Access designs X X turns and not U-turns. 24 ff implemented. Weekly monitoring, records of incidents and corrective measures. Prevent shortcuts between roads. Q2 Weekly monitoring, X X 24 ff records of incidents and corrective measures. Tyre pressures should be as low as possible to reduce Q2 Weekly monitoring, X X impacts. 24 ff records of incidents and corrective measures. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 73 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO All material for road or site construction to be brought Q2 Access designs X X in from outside of Park area andsources to be 24 ff implemented. approved by the ECO. Weekly monitoring, records of incidents and corrective measures. Roads no longer in use shall be rehabilitated. (See Q2 Access designs X X X Rehabilitation section). 24 ff implemented. Weekly monitoring, records of incidents and corrective measures. WASTE To avoid potential The Contractor shall submit a waste management Q1 Management plan X X X X MANAGEMENT surface and plan, including how it is intended to dispose of 24 ff approval and AND WATER groundwater hazardous and general waste, as described periodic monitoring RESOURCE pollution. hereunder. This plan shall be reviewed and approved and review. MANAGEMENT by the ECO. Design planning and ESS 3 + GN review. To ensure that sound waste management practices are adhered to during construction. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 74 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO All sewerage waste shall be removed regularly and Q2 Waste management X X disposed of at a designated sewerage treatment 24 ff records, Monthly facility (i.e. not to be disposed of anywhere at the review. Weekly site construction site). compliance inspection. The site should be inspected regularly for standing or Q2 Weekly monitoring, X X leaking water or wastewater points and attended to 24 ff records of incidents immediately. and corrective measures. Make sure that portable chemical toilets to be used Q2 Weekly monitoring, X X on site are in good working order and that they are 24 ff records of incidents clean. Cleaning record should be kept on site and and corrective readily accessible for inspection. measures. Temporary toilet facilities (preferably chemical toilets) used at the camp site and on terrain shall be sited away from any riverbed, vleis, or pan, even when dry. All waste (including domestic and construction waste) Q2 Waste management X X produced daily shall be sorted and taken to the 24 ff records, Monthly waste disposal site as arranged, i.e. Rosh Pinah for review. Weekly site general waste and a reputable waste salvage compliance company for hazardous waste. The construction site inspection. shall be left clean daily The Contractor shall arrange with towns along the Q2 Disposal agreement X X route for the use of their waste disposal site. 24 ff NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 75 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO No waste shall be buried or burned on site Q2 Weekly site X X 24 ff compliance inspection. All recyclable waste shall be taken to a recycling Q2 Waste management X X depot. 24 ff records, Monthly review. Weekly site compliance inspection. Adequate separate containers for hazardous and Q2 Weekly site X X domestic waste shall be provided on site. They shall 24 ff compliance be clearly marked. inspection. The workforce shall be sensitised to dispose of waste in Q2 Regular awareness X X a responsible manner and not to litter. 24 ff raising. Monthly records. Provide sufficient waste bins at work sites. Make sure Q2 Weekly site X X that all waste is removed from work and campsites. 24 ff compliance inspection. Refuse bins must be stable, i.e. cannot be tipped by Q2 Design, test and X X animals, and have scavenger and baboon proof lids. 24 ff approve NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 76 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Make sure that the bins are covered so that plastic Q2 Design, test and X X bags, paper, etc., are not blown away. 24 ff approve No waste shall remain on site after completion of the Q2 Completion X X X X project. 24 ff inspection Servicing of vehicles in the field or at the construction Q2 Weekly site X X site is not permitted. 24 ff compliance inspection. Drip trays shall be available for all heavy vehicles that Q2 Weekly site X X are intended to be used during construction. These 24 ff compliance trays shall be placed underneath each vehicle while inspection. the vehicles are parked. The drip trays shall be cleaned every morning and the spillage handled as hazardous waste. Accidental spills shall be cleaned immediately. The Q2 Weekly site X X contaminated soil shall be treated as hazardous 24 ff compliance waste. inspection. Incident & correction reports and records. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 77 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO In the event of a hazardous spill: Q2 Incident & correction X X X 24 ff reports and records. • Immediately implement actions to stop or reduce the spill. • Contain the spill. • Arrange implementation of the necessary clean- up procedures. • Collect contaminated soil, water and other materials and store it in an appropriate container for collection. • All spills shall be reported and a “spills register” kept. • A hazardous material spill kit shall be available at the construction site and there shall be at least one person with appropriate authority who is trained in hazmat response. Refuelling vehicles shall be equipped with specific Q2 Monthly site X X vehicle spill kits. Drivers shall be trained in relevant spill 24 ff compliance response procedures. inspection. Explosives shall be stored according to the prescribed Q2 Safety certificate to X X regulations. Blasting will only be allowed if no 24 ff be in place. alternative is available and change to ESMP effected Revised ESMP if and approved by DEA. approved. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 78 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO The floors of the designated bunded areas for the Q2 Spill prevention X X storage of potentially hazardous material shall be 24 ff designs reviewed lined with concrete. The bunded floor area shall be of and implemented. adequate capacity to contain 1.2 times (120%) the volume of the hazardous material to be stored in the Weekly inspection, bunded area, unless otherwise specified in relevant records of incidents regulations and standards. and corrective measures. Corrosive, explosive, toxic, and flammable material Q2 Weekly inspection, X X shall be stored in separate areas which are access 24 ff records of incidents controlled (locked) and corrective measures. All hazardous materials (such as oil) shall be stored in Q2 Spill prevention X X X separate containers (concrete liner, container, or 24 ff designs reviewed metal or plastic drip tray) and stored for transport and and implemented. proper disposal at an approved waste disposal site or for collection by an oil recycling company such as Weekly inspection, WESCO Salvage (this company collects significant records of incidents quantities of oil from central locations throughout the and corrective country). measures. Disposal records. The nearest Hazardous waste disposal site is in Q2 Weekly inspection, X X X Windhoek or Walvis Bay but WESCO Salvage currently 24 ff records of incidents removes hazardous waste from the area and they or and corrective any other available and reputable contractor shall be measures. contacted to remove all hazardous waste. No hazardous waste shall be burned or burried on site Disposal records. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 79 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Fuel tanks on site shall be properly bunded. The Q2 Spill prevention X X X volume of the bunded area shall be sufficient to hold 24 ff designs reviewed 1.2 times (120%) the capacity of the storage tanks. and implemented. The floor of the bunded area shall be concrete and the sides high enough to achieve the 1.2 times (120%) Weekly inspection, holding capacity. records of incidents and corrective measures. Foam fire extinguishers shall be in close proximity to Q2 Records of training X X X fuel kept on site. There shall be trained personnel to 24 ff and refresher courses. operate and handle this equipment. At least two fire extinguishers shall be placed at every fuel storage Weekly inspection, area. records of incidents and corrective measures. Water may only be taken from private, communal, or Q2 Water demand and X X X government-owned property on a basis agreed upon 24 ff design optimisation in writing between the Contractor and such owner. review. Proof that the resource, if a borehole will have Monthly water use asustainable yield, must be in place before use. reports record. Should the contractor be required to use water from a natural source, the contractor shall supply a method statement to that effect. The Contractor shall utilise water only as specified in Q2 Water demand and X X the approved water resource plan for the project. 24 ff design optimisation Low water consumption project technologies and review. methods should be investigated and implemented. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 80 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Water shall be used sparingly and all faulty and Q2 Monthly inspections X X leaking taps, toilets and pipes shall be immediately 24 ff and records of repaired. incidents and corrective measures. BORROW Use of soil and Only materials from commercial borrow-pits, with Q2 Record management X X X MATERIAL AND rock from the site Environmental Clearance Certificates (ECCs), shall be 24 ff and review. BORROW PITS for construction used for construction. No soils on site shall be used for purposes. construction except for material excavated for foundations, and compaction of in-situ material for roads. Should the opening of a new borrow pit be contemplated, this will require a separate ECC application. INFRASTRUCTURE Prevent damage No telephone lines shall be dropped during the Record management X X X to third party stringing operations. and review. infrastructure and services. Where pipe lines are found along the route, the depth Record management X X X of the pipes under the surface shall be determined to and review. ensure that proper protection is afforded to such structures. REHABILITATION Re-establishment Rehabilitation design starts before construction is Q1 Rehabilitation design X X X X X of pre-disturbance allowed. The Contractor must provide a 24 ff and review records form and Rehabilitation Plan before contruction can before construction ecological commence. starts. function (soil crusts, plants and Rehabilitation plan in animal burrows). place. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 81 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO Audit rehabilitation. Apply Biodiversity Management Plan. Rehabilitation should only be planned in conjunction Q1 Rehabilitation design X X X X X with the Biodiversity Management Plan (Appendix A). 24 ff and review records before construction starts. Once the final route and tower positions have been Q2 Create a site X X X fixed, the area of unavoidable and certain damage 24 ff disturbance map should be mapped. This should include all zones of overlay for the collateral damage, such as access roads. contractor’s layout drawings. Before construction, areas to be disturbed should be Q2 Records of topsoil X X prepared by potential aloe relocation and topsoil 24 ff conservation preservation. Any topsoil heaps should be placed stockpiles, and upwind of the damaged area (i.e.: south west, in the records of restoration. path of the prevailing winds). Smaller heaps at each construction area would be preferable to large heaps. Once construction is complete, these heaps should be used to return the site to as natural an appearance as possible. Once construction is completed and essential Q2 Rehabilitation X X operations infrastructure identified rehabilitation 24 ff procedures reviewed should be done in the following manner: and implementation records with a • Compacted areas such as where tracks may have crossed shrubland shall be ripped by using NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 82 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO picks and rakes, avoiding parallel furrows that will rehabilitation layout promote erosion. Calcrete should only be raked drawing. to assure surface soils are loosened ONLY if compacted. No mechanical ripping should be allowed at all. • Ripping shall occur to full rooting depth. On gravel plains a depth of about 50 mm should be adequate as this will break down the compaction without loosening too much of the soil. • The disturbed area shall be remodelled to, as far as possible, resemble previous conditions and fit in with the adjacent landscape. • Ripping should only be done of compacted, disturbed areas, NOT of vegetated areas. The areas to be ripped should be carefully marked off before this process is initiated. Continuous supervision of this process is required. • Stored topsoil, as well as soil and gravel shall be raked from adjacent areas to try and recreate the same texture and look as surrounding areas. Stones shall be redistributed with rakes so that the surface texture resembles the surroundings. • Plants should be transplanted and watered in thoroughly, using a watering can with a rose tip. They must be very carefully dug out, taking care to damage the root system as little as possible, and must be replanted equally carefully. The sites for relocation must be carefully chosen so as not to compromise other plants of concern that NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 83 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO may already be there, and the aim should be for the resulting plantings to look as ‘natural’ as possible i.e., the plants should be spread out and planted randomly, not in clumps or rows. This should be done under supervision of a botanist. • In order to prevent re-disturbance of rehabilitated tracks, physical barricades (e.g. rocks or sign boards) shall be implemented as an interim deterrent. All district personnel will be allowed to use the existing access/servitude roads only. Any temporary roads (i.e. turning points for heavy vehicles) will be closed and rehabilitated. Monitoring of relocated plants and areas of relocation Q2 Relocation procedure should be implemented as follows: 24 ff design, implementation • Once roads are demarcated, fixed point records. photography before construction activities can be used to assess overall compliance. • Several permanent transects, as well as fixed point photography should be used for at least three (3) years after construction, to monitor rehabilitation success. These should be repeated annually after the rainy season (i.e.: in September/October). • The condition of any plants of high conservation concern, such as Larryleachia for instance, that are transplanted should be assessed annually during late September to early October for at least three (3) years to determine translocation NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 84 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO success. This will provide information for future translocation efforts. • The specialist should advise the level of success of the translocation plan. He or she should also provide instruction for adapting or re-organising the plan according to the level of success. REHABILITATION To rehabilitate the All equipment, waste, temporary structures, stockpiles, Q3 Design of X X X STRUCTURES site office, work etc., shall be removed from the work sites. 25 rehabilitation and sites, servitude review. areas, tracks and other areas Audit rehabilitation. disturbed during Apply Vegetation construction as Management Plan. close to their original state as reasonably possible. Final payment shall not be issued unless the Q3 Compliance Audit X X X X environmental consultant is satisfied with the 25 Report obligations listed under this section (“rehabilitation”). Contractor shall be held responsible for all Q2 Compliance Audit X X X X unnecessary damage due to non-compliance, 24 ff Report. whether caused by his/her company or by subcontractors. Agreed penalty if needed. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 85 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO REHABILITATION During the first month of rehabilitation, monitoring is Q2 X X MONITORING very crucial and it is recommended that the ECO visit 24 ff Design of all rehabilitated sites at least twice a week. During this rehabilitation and visit, the ECO shall check for any signs of erosion and review. To ensure check the progress on re-establishing the surface crust. successful Any indications of unsuccessful rehabilitation shall Weekly monitoring rehabilitation require that the rehabilitation process to be repeated reports for 6 weeks. again and at this point it shall be necessary to gain the expertise of a desert rehabilitation specialist. Audit rehabilitation. Apply Vegetation Management Plan The ECO shall oversee the project and implement Q2 X X management and monitoring recommendations. 24 ff Review rehabilitation weekly. Recommendations and adjustments reporting weekly Apply Vegetation Management Plan. Workers shall be familiarized with the management Q2 ESMP implementation X X recommendations and contractually bound to its 24 ff Audit stipulations. recommendations applied in Induction and refresher courses. Records of induction amendments NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 86 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / Mitigation measures and products (highlighted) NamPower Contractor Monitoring measures Manager External Project reference to ESS Expert ECO The ECO shall conduct regular site inspections and Q2 Annual Audit Reports. X submit reports in this regard to the MEFT. 24 ff ECC Renewal Application reports. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 87 7.3 Operation and Maintenance Phase Responsibility: The Operator shall be responsible to ensure all obligations are being met and shall audit them at least annually. Table 6 Management Requirements – Operation and Maintenance RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Facility reference to ESS Expert ECO CONTINUITY OF To ensure Implement an external environmental audit system on Q4 Periodic review. X X SOCIAL AND continuity of an annual basis during the operation of the Project. 25 ff ENVIRONMENTAL environmental This shall be used to verify the effectiveness of the MANAGEMENT and social ESMP and implement adjustments if required. management actions once the RPSP is operational. The ECO shall provide staff with appropriate guidelines Q4 Monthly ESMP X X for environmental management during operation of 25 ff implementation and the Project, including: review report • All relevant provisions contained in the “construction” ESMP such as keeping a complaints register, sound disposal of hazardous and general waste, track discipline, health and safety precautions, etc. • Keeping an appropriate complaint and stakeholder grievance system and register in place. • The ECO shall design a record system for environmental, health and safety incidents and accidents along this power line and at the site. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 88 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Facility reference to ESS Expert ECO All contractors to be working on site during operation Q4 Contract including X X X and maintenance, should have an Environmental and 25 ff ESMP on record Social Management Plan as part of their contract (see “Construction” section.) Reasonable contact should be made and maintained Q4 Consultation records X X with the stakeholders of the project. 25 ff Q4 Grievance Procedure X X X A grievance procedure (as proposed above) should 25 ff implementation be in place to deal with community grievances in a strategy and records. satisfactory manner, and should at least include the following: • Identify the position on site where responsibility will be assumed for putting in place and managing the grievance procedure. • Ensure the current stakeholder database is updated. • Publish at the onset of the project, with the basic elements of it – construction time frame, contact details, who to contact for job opportunities, grievances, etc. The publication should be made in the local newspapers and on posters put at the local retail stores in Rosh Pinah and as advised by Roshskor. • The publication should also be placed on the website and Facebook page of the project and NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 89 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Facility reference to ESS Expert ECO e-mailed to the applicable parties on the stakeholder database. • The poster shall contain a grievance mechanism – a method for community members to lodge complaints. The grievance mechanism shall state (a) Who can raise complaints (affected communities) (b) Where, when, and how community members can file complaints (this should preferably be in writing, unless the complainant is illiterate, in which case the ECO should assist the complainant to articulate the complaint (c) Who is responsible for receiving and responding to complaints, and any external parties that can take complaints from communities (d) What sort of response complainants can expect from the company, including timing of response (e) What other rights and protection are guaranteed. • The community shall be regularly reminded as above, of their right to submit and receive responses to grievances. • The officer responsible for handling grievances shall ensure that the grievances 1) are received and registered (with adequate documentation as reference), 2) reviewed and investigated, 3) resolution options are considered and an appropriate one is selected and implemented, 4) the grievance is properly responded to and the matter closed out, and 5) the success of the NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 90 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Facility reference to ESS Expert ECO resolution option is monitored and adapted where necessary. CONTINUOUS Implement bird monitoring programmes as per the Q4 Monitor programme X X X To determine the MONITORING – Biodiversity Management Plan (Apprendix A) during 25 ff recorde long-term AVIFAUNA the operational phase that includes searches for bird incidences of bird and bat mortalities, as per World Bank requirements. mortalities during Searches should follow detailed protocols and should, the operational at least initially, be intensive (e.g., daily for the first two phase of the months) to gauge scavenger effects, after which project. search protocols may be amended. The landowners must be sensitised to the fact that the feeding of vultures close to a power line may create a high-risk collision potential for threatened vultures, and the vulture restaurant moved away from the line. All bird-power line interactions must be reported to the project manager, who will notify the SHE section. Reporting of the specialist/s should include an impact Q4 Monitor programme X X X X assessment, indicating low, medium or high significant 25 ff findings and of impact on birds and bats, based on the monitoring recommendations. data. In case of medium and high impact, recommendations should be provided and Design and implemented by the Operator to address the operational cahnges identified impact. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 91 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Facility reference to ESS Expert ECO Information on the entire procedure shall be published Q4 Publications records. X X X or made available online so as to contribute to future 25 ff rescue/relocation attempts in the southern Namib. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 92 7.4 Decommissioning Phase Responsibility: NamPower shall consider these aspects in conjunction with the ECO and Contractor. Table 7 Management Requirements - Decommissioning RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert EPC DE- All provisions under the Construction section shall be TBD Design of X X X X COMMISSIONING To ensure that the applicable for all contractors during decommissioning. rehabilitation and project does not review. Audit have cumulative rehabilitation. negative effects MEFT to review and after approve final decommissioning. decommissioning results. No waste may remain on site after completion of the TBD Site Closure Audit X X X project. An investigation shall be commissioned to determine TBD Disposal Plan design X X the best practical environmental solution for the and records disposal of structural components and SPV components, according to the solutions available at the time. Eradication of all exotic or invasive plants shall be TBD Invasive eradication X X conducted before decommissioning. plan, implementation records, and Audit. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 93 RESPONSIBILITY/ (Quarter/year) PARTNERSHIP Timeframe ASPECT OBJECTIVE / NamPower Contractor Mitigation measures and products (highlighted) Monitoring measures Manager External Project reference to ESS Expert EPC Implement staff severance packages according to TBD Human Resource labour legislation and inform staff of this step in Closure Plan review advance. and implementation records All areas used during the construction and operation TBD (haul roads, site offices, etc.) shall be cleared and inspected for decommissioning approval by the ECO. Before approval, the contractor shall still be liable for any costs to ensure proper decommissioning. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 94 APPENDIX A BIODIVERSITY MANAGEMENT PLAN NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 Dec 2023 Environmental and Social Management Plan for the Proposed 400 kV Transmission Line from Auas to Kokerboom Substation DRAFT BIODIVERSITY MANAGEMENT PLAN KATIMA MULILO-KONGOLA WATER SUPPLY PROJECT PHASE 3 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT AND ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN STAKEHOLDER ENGAGEMENT PLAN 2 COPYRIGHT © NAMPOWER, 2023. ALL RIGHTS RESERVED Proposed 400kV Transmission line from Kokerboom to Auas Substations PROJECT NAME ESIA and ESMP REPORT ESMP Biodiversity Management Plan STAGE OF REPORT Draft NamPower CLIENT Attention: Martin van der Merwe Enviro Dynamics Enquiries: Stephanie van Zyl LEAD CONSULTANT Tel: 264 81 1287002 E-Mail: stephanie@envirod.com DATE OF RELEASE December 2023 Authors: Stephanie van Zyl, Coleen Mannheimer, Ann & Mike Scott CONTRIBUTORS TO THE (African Conservation Services cc) REPORT Reviewed: Norman van Zyl ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 3 TABLE OF CONTENTS 1 INTRODUCTION ...................................................................................................... 5 2 BACKGROUND AND KEY MANAGEMENT OBJECTIVES ....................................... 6 2.1 Critical Habitat Assessment Background ....................................................6 2.1.1 Vegetation .....................................................................................................6 2.1.2 Avifauna .........................................................................................................6 2.2 Key Objectives ............................................................................................... 8 3 IMPLEMENTATION STRATEGY ................................................................................. 8 3.1 Pre-Construction/Design Phase....................................................................9 3.1.1 Route Selection .............................................................................................9 3.1.2 Avoiding Specific Hotspots ...........................................................................9 3.1.3 Avoiding Unnecessary Habitat Destruction ..............................................10 3.1.4 Monitoring To Establish Baseline Conditions Prior To Construction ..........10 3.1.5 To Confirm Measures In The Design Aimed At Mitigation Of Species Loss ......................................................................................................................11 3.1.6 Design Long Term Off-Set Programmes .....................................................11 3.2 Construction Phase ..................................................................................... 12 3.2.1 The Minimal Disturbance Of Habitat/Vegetation During Construction ..12 3.2.2 Minimum Loss Of Identified Species Of Concern......................................12 3.2.3 Identification, Permitting And Record Keeping Of Species To Be Removed......................................................................................................13 3.2.4 Monitoring Of Construction Activities To Ensure Compliance .................13 3.3 Operational Phase ...................................................................................... 13 3.3.1 Biodiversity Management Strategies .........................................................13 3.3.2 Monitoring Required To Track Effectiveness Of Mitigation .......................13 3.3.3 Design Holistic And Long Term Biodiversity Management And Off-Set Programmes .................................................................................................14 3.3.4 Monitoring Required To Track Species Recovery......................................15 4 BIODIVERSITY INDICATORS ................................................................................. 16 4.1 Avifauna ....................................................................................................... 16 5 RESPONSIBLE PARTIES TO ENSURE IMPLEMENTATION......................................... 16 ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 4 6 COST ESTIMATES................................................................................................... 16 6.1 Cost estimate: avifauna ............................................................................. 18 7 REFERENCES ......................................................................................................... 22 8 APPENDIX 1: IDENTIFICATION GUIDE TO PROTECTED TREES THAT MAY BE FOUND ALONG THE POWER LINE ROUTE. ........................................................... 23 GLOSSARY BMP Biodiversity Management Plan CHA Critical Habitat Assessment ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan ESS Environmental and Social Standards kV Kilo Volt FIGURES Figure 1: Locality of the proposed Auas-Kokerboom 400kV Transmission line ........ 5 Figure 2: The mitigation hierarchy for sustainable biodiversity management ....... 9 ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 5 1 INTRODUCTION NamPower intends constructing a 400kV power line from the Kokerboom Substation near Keetmanshoop to the Auas Substation near Dordabis, Namibia. The line will assist in securing the supply of electricity to Namibia in future and open up opportunities for selling power to the Southern African Power Pool. Figure 1: Locality of the proposed Auas-Kokerboom 400kV Transmission line NamPower is seeking funding from the World Bank for the construction of the transmission line with all its components. The World Bank requires of its Borrowers to fulfil the requirements of the Environmental and Social Framework (ESF). The ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 6 Framework sets out the Environmental and Social Standards (ESS) to be complied with on all projects funded by the World Bank. 1 This document is the Biodiversity Management Plan (BMP), which aims to provide the mitigation details to be incorporated into the project lifetime of the planned transmission line. The document has been prepared in line with Environmental and Social Safeguard 6 of the World Bank (Biodiversity Conservation and Sustainable Management of Living Natural Resources) and includes the following: 1) Background and key biodiversity objectives 2) Activities to achieve the objectives 3) Implementation schedule 4) Institutional responsibilities and 5) Cost estimates 2 BACKGROUND AND KEY MANAGEMENT OBJECTIVES 2.1 CRITICAL HABITAT ASSESSMENT BACKGROUND A Critical Habitat Assessment was conducted for vegetation and avifauna occurring in the Project area. 2.1.1 Vegetation The vegetation in the project area is categorised as natural habitat (mostly unaffected by development), with some measure of modified habitat (changed habitat due to human intervention). There is no part of the study area that meets the criteria of critical habitat, although protected species occurs occur along the route, and generally vegetation cover, because of its crucial role in protecting the surface from desertification and contributing to esosystem functioning should be highly valued and preserved where possible. For this reason, mitigation measures for vegetation are included in this Management Plan. 2.1.2 Avifauna The current Critical Habitat Assessment (CHA) for avifauna has shown that the study area may contain areas of Critical Habitat relevant to bird species of potential concern (World Bank 2016, 2018); however, there are uncertainties due to the lack 1https://www.worldbank.org/en/projects-operations/environmental-and-social- framework/brief/environmental-and-social-standards ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 7 of global population estimates for some species, or such estimates are dated; and to the lack of local population estimates for the study area. A precautionary approach is therefore required, together with an adaptive management strategy. The following Red Data species meet the CHA criteria and are likely to be impacted by the construction of the planned 400kV transmission line: • Ludwig's Bustard (Globally Endangered, Namibian Endangered) In terms of Threshold (b) for habitats (i.e. priority for conservation in Namibia), and areas important for congregatory species (criteria c), the following apply to the study area: • Karas Dwarf Shrubland and Dwarf Shrub Savanna (especially): open, grassy habitats that are favoured by bustards • Dwarf shrub savanna: the Hardap Game Park (nationally protected area) is also within the Karas Dwarf Shrubland, which is an Important Bird Area [IBA]), and an area important for congregatory species. An alternative route was considered to the selected route, as a potential avoidance measure, but there is little difference between the two power line routes in terms of impacts on avifauna, the chief impacted group being bustards. However, the alternative route (448 km) is 18 km shorter than the planned route (461 km), and therefore of a slightly lower potential avifauna impact. However, this alternative route is technically problematic for NamPower and is therefore not suitable. In areas of critical habitat, the World Bank requirement is that the Borrower will not implement any project activities that have potential adverse impacts unless all of the seven prescribed conditions are met (refer ESS6 paragraph 24 (a) to (g)). According to the findings of the current CHA report, the above requirements have been or will be met, in the ESIA and ESMP, and subsequent mitigation recommended in this BMP. NamPower, the Borrower, will manage the identified risks and impacts in accordance with the mitigation hierarchy and Good International Industry Practice (GIIP). It will adopt a precautionary approach and apply adaptive management practices in which the implementation of mitigation and management measures are responsive to changing conditions and the results of ongoing project monitoring. Additionally, in accordance with the requirements of ESS6, the present Biodiversity Management Plan (BMP) is being prepared for the project. This BMP will be updated when more data becomes available during further studies to specify the exact hotpots earmarked for bird markings, during pre-construction monitoring and confirmation of the staggering design. It is critically important that the ESMP and this BMP is audited to ensure compliance and that mitigation and monitoring take place as outlined therein, otherwise the impacts identified will remain unacceptable. It is considered that the Borrower's requirements will thus be addressed, based on the conditions above. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 8 2.2 KEY OBJECTIVES The key biodiversity values of significance on this project are a) power line collision prone avifauna that have protected status in the project aera and b) protected plant species occurring in the project area. The objectives are specifically designed to achieve no net loss, and net gain of these specific values. As strategic direction, NamPower focusses on avifauna as the priority targeted biodiversity value, due to the risk of significant losses of avifauna species on transmission lines in general, and on this project, specifically. The following biodiversity objectives have been set for the construction and operation of the 400kV transmission line: 1) Effective mitigation of habitat loss and ecosystem services loss outside the required footprint, 2) Effective mitigation of species loss during all phases of the project 3) Net biodiversity gain in the long term, in Namibia, specifically for avifauna 4) Strengthening research to better understand a) the positive and negative impacts of the project on avifauna and b) the effectiveness of mitigation, particularly the “staggered pylons” concept. 3 IMPLEMENTATION STRATEGY A management plan to protect and improve biodiversity on a project requires the implementation of the mitigation hierarchy (Error! Reference source not found.). The steps taken and planned according to this concept are systematically outlined in this section. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 9 Figure 2: The mitigation hierarchy for sustainable biodiversity management 3.1 PRE-CONSTRUCTION/DESIGN PHASE 3.1.1 Route selection • Two major alternative routes were selected and considered during the ESIA. The impact assessment of the selected route rated marginally higher on vegetation and avifauna but comparative analysis indicated that mitigation is similarly possible with the same expected results on both routes. The eastern route that was selected is favoured from a technical point of view, to avoid major technical risks. 3.1.2 Avoiding specific hotspots • Southern Kalahari: a sensitive bird "hotspot" lies 15 km east of the power line route, with White-backed Vulture breeding area/congregatory area (50-100 birds with nests) and bustard habitat; this sensitivity has already been avoided/ mitigated by re-routing the power line in terms of the ESIA, with recommendations for marking the relevant section of power line in the ESMP. • Pan edges, banks of rivers and other drainage lines and areas marked with large Camel thorn trees, as described in the ESMP, are to be avoided. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 10 • The Engineering Team and Contractor will pay special attention to avoid clumps of trees, and other hotpots as described above, by further adjusting the route where possible. 3.1.3 Avoiding unnecessary habitat destruction • Directives are provided in the ESMP for management strategies needed during the design stage to avoid habitat destruction including the placement of the construction camps, and the final survey of the transmission line to limit the destruction of trees, especially Acacia erioloba, to a minimum. • Planning for training of workforce and staff on the project to understand the importance of biodiversity management and how to go about it on the project. • Planning to off-set biodiversity loss, by implementing a monitoring strategy in conjunction with biodiversity minded partners in Namibia. 3.1.4 Monitoring to establish baseline conditions prior to construction • More specific monitoring avi-fauna monitoring is required prior to construction, to achieve the objectives mentioned in (Section 2.2.). Survey work is needed along sample areas of both the existing 220 kV line and the existing 400 kV line (as a control for the "staggered pylon" design, once in place), in all four main habitats, both before and after construction. This monitoring work is motivated in the avifauna reports for the ESIA (Simmons & Martins 2017; Simmons 2018) and the ESMP for the project. The pre-construction monitoring should be undertaken as follows: • By a competent ornithologist familiar with power line work and able to identify species found dead under power lines from their remains (feathers and wing bones); • Known-distance surveys to be undertaken 3-months and 9-months before construction of the two lines; the first should be undertaken in the dry season (to clear the line of any carcasses), with a follow-up survey just after the rain season (February-March); • The surveys should include (i) the existing 220 kV line in all four habitat types and (ii) the existing 400 KV line south to Kokerboom, and include samples from all three habitats; ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 11 • Specific (additional) surveys must be undertaken of the 14 km of planned 400 kV line that occurs within the high-risk vulture area near Kalkrand (see Simmons 2020). This must be included in pre-construction surveys and post-construction surveys to assess the efficacy of the recommended fitting of bird spiral flight diverters along the earth wires. • The same sample areas as those used for the initial study (Simmons & Martins 2017) should be used for direct comparisons. • Apart from power line mortalities, pre-construction monitoring should also include the recording of live priority species as far as possible (e.g. bustards, raptors), to provide a baseline of numbers at the start of the programme. • The resultant monitoring data should be compared and analysed after the 3- and 9-month assessment periods, to determine the rate of fatalities occurring per km, the species involved. Should any high-risk areas be identified (numbers of bustards killed by the new 400 kV line exceeding 1 per km of line, or for vultures numbers killed exceeding 1 per 7km of line), such areas should be incorporated, as far as possible, in the final mitigation design aimed at species loss. • The pre-construction monitoring surveys should be undertaken with the support of NamPower officials to share and discuss all results and any challenges arising from the surveys. NamPower officials will also be required to accompany the survey team, to provide access to all the lines. 3.1.5 To confirm measures in the design aimed at mitigation of species loss • The proposed mitigation to be included in the designs for implementation during construction are to be confirmed during the planning stage. These are particularly the bird markers specified in the ESMP. NamPower staff responsible for this project need to ensure that the bird diverters are included in the tender documentation, quoted for by the Contractor, and as per specifications. 3.1.6 Design long term off-set programmes • The rigorous long-term testing of the effectiveness of the proposed mitigation measures, particularly the “staggered pylons” concept, will enable confidence in its application in the future. This is considered to be a positive off-set measure in terms of avifauna species loss. • It is not considered practical to recommend the planting of trees for species loss – Namibia’s climate does not allow for trees planted that are not specifically nursed. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 12 3.2 CONSTRUCTION PHASE 3.2.1 The minimal disturbance of habitat/vegetation during construction Measures to achieve this goal are included in the ESMP for this project and include the following: • Creation of additional tracks, including those made by bulldozers and other large construction vehicles, outside of the service track should not be permitted unless absolutely necessary. • Staff camps should be pre-determined and marked. • Penalties should be in place for all contractors and sub-contractors that cause unnecessary collateral damage. • Random collection of wood for fuel and/or heating should be forbidden. No harvesting of wood by operational/maintenance staff should be permitted. Any wood used by staff for any purpose whatsoever must be permitted wood supplied by the farmers along the route themselves, or be invader species wood sourced from elsewhere. • Plant collection of any plants or parts thereof, including seeds and pods, should be forbidden. • Penalties, including dismissal for repeat offenders, should be in place for all transgressors. 3.2.2 Minimum loss of identified species of concern • Species loss during construction is particularly the protected Acacia erioloba and other protected tree species. • Appendix 1 provides a visual guide to these species along the project route. This guide is also appended to the ESMP, for the Contractor and all involved in the construction phase, to be aware of. • Measures have been included in the ESMP to minimise the loss of protected trees during bush clearing. Trees are to be marked and trimmed, rather than removed where possible. • Measures have been included in the ESMP to address this species loss, including the avoidance of and addressing tree harvesting and wood collecting. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 13 3.2.3 Identification, permitting and record keeping of species to be removed. • Where protected trees cannot be avoided, they are to marked and permits obtained for their removal from the Ministry of Environment, Forestry and Tourism. This is specified in the ESMP. • Records are to be kept of these identified trees. 3.2.4 Monitoring of construction activities to ensure compliance NamPower needs to commit to the arrangement for monitoring the management actions required during construction to ensure compliance according to the ESMP. The requirements for this monitoring is specified in the ESMP. Records shall be kept of protected tree species removed during construction as well as their permits and coordinates. This will form a useful database in future of protected tree species lost on power lines in Namibia. NamPower is encouraged to partner with conservation organisations and with the National Botanical Research Institute for the keeping of these records. 3.3 OPERATIONAL PHASE 3.3.1 Biodiversity management strategies • NamPower has a general Environmental Management Plan, including general biodiversity management strategies for the maintenance work on all their projects. • NamPower’s overall biodiversity management strategies and those that are specific to this project are contained in the ESMP for this project. 3.3.2 Monitoring required to track effectiveness of mitigation 3.3.2.1 Avifauna The post-construction monitoring (monitoring during operation of the transmission line) should take place during operation, as follows: • Surveys to be undertaken again 3-months and 9-months after construction of the line, one survey to include the wet season; this must be repeated in a second year, post-construction (i.e. total of four post- construction surveys, as a minimum) • A minimum of 20% of the new 400 kV line (20% of 461 km is 92 km) should be surveyed, within all four habitats identified, for bird carcasses along the same sections as surveyed along the adjacent 220 kV line in the previous (pre-construction) surveys; this must also be compared with 20% of the sampled existing 400 kV line, west of the B1, in similar habitats; ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 14 • The number of carcasses found per km (with each carcass photographed next to a GPS with the point logged) should be compared with fatalities found along similar lengths of the other, existing 400 kV line in similar habitats; • Specific (additional) surveys must be undertaken of the 14 km of planned 400 kV line that occurs within the high-risk vulture area near Kalkrand (see Simmons 2020). This must be included in pre-construction surveys and post-construction surveys to assess the efficacy of the recommended fitting of bird spiral flight diverters along the earth wires. • Ideally, the same sample areas as those detailed in the initial report (Simmons & Martins 2017) should be used for direct comparisons. • Apart from power line mortalities, post-construction monitoring should also include the recording of live priority species as far as possible (e.g. bustards, raptors), to provide an indication of population trends. • These monitoring data should be compared and analysed after the 3- and 9-month assessment periods, to determine the rate of fatalities occurring per km, the species involved, and if the mitigation measures (either staggered pylons or the use of bird diverters) are effective. • Should any high-risk areas be identified (numbers of bustards killed by the new 400 kV line exceeding 1 per km of line, or for vultures numbers killed exceeding 1 per 7km of line), then additional mitigation measures must be enacted within 3 months of the survey results. • The pre-construction monitoring surveys should be undertaken with the support of NamPower officials to share and discuss all results and any challenges arising from the surveys. NamPower officials will also be required to accompany the survey team, to provide access to all the lines. • The monitoring results should be published in local journals (e.g. Namibian Journal of the Environment) to publicise the results. They should also be added to the electronic bird-power line data base (www.the-eis.com). 3.3.2.2 Vegetation No monitoring required. 3.3.3 Design holistic and long-term biodiversity management and off-set programmes The rigorous testing of the effectiveness of the proposed mitigation measures, particularly the “staggered pylons” concept, will enable confidence in its application in the future. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 15 NamPower is encouraged to set up an overall biodiversity management policy to form the basis of biodiversity management including offsetting for its entire operation, including electricity generation projects. 3.3.4 Monitoring required to track species recovery In the longer term, the above avifauna monitoring will serve to indicate species recovery, based on records and population trends of live priority species (e.g. bustards, raptors) from the inception of the programme. If disturbance to vegetation habitats have been limited to the minimum required, then no further monitoring is needed. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 16 4 BIODIVERSITY INDICATORS Indicators are needed to determine changes in strategy should the current proposals prove ineffective. 4.1 AVIFAUNA • High-risk areas are identified, based on numbers of bustards killed by the power line exceeding 1 per km of line, or for vultures numbers killed exceeding 1 per 7 km of line. • Should these thresholds be exceeded, then additional mitigation measures must be enacted within 3 months of the survey results. Such measures would include the fitting of bird flight diverters in high-risk areas where diverters will initially not be fitted (in addition to the staggering mitigation applied during construction); and follow-up monitoring. 5 RESPONSIBLE PARTIES TO ENSURE IMPLEMENTATION • NamPower assumes the overall responsibility for implementing this BMP. • NamPower needs to ensure that the Contractor implements the content of the Construction ESMP. The Contractor needs to appoint an Environmental Control Office for this purpose. • This will involve monitoring to ensure compliance and if done in-house by NamPower, needs to be audited. • It is proposed that NamPower involves suitable NGO’s to partner with the implementation of the Plan, particularly Avifauna. The Namibian Chamber of Commerce has indicated preliminary interest to become involved (Dr Chris Brown, pers. Comm., 8/2023) 6 COST ESTIMATES The cost estimates provided are for the avifauna pre- and post-construction monitoring. The costs of management actions to be taken during construction are items costed by the Contractor and there are no separate costing items in this regard. • A conservative overall estimate for the pre-construction (one year, two surveys) and post-construction monitoring (two years, four surveys) is provided. • It is assumed that only actual expenses will be invoiced. • The costing details will need to be fine-tuned before the work commences. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 17 • The monitoring work will span four years (allowing for one year pre- construction; monitoring one year of construction, during which no monitoring will take place; and two years of post-construction monitoring). Inflation may therefore need to be considered, in the final budget. • It is understood that the costs are to be shared between the Namibian Chamber of Commerce (NCE) and NamPower; the individual contributions still need to be decided. • The costs of mitigation marking (i.e. purchase and fitting of bird flight diverters [BFDs]) will need to be confirmed by NamPower/Contractor. The fitting of BFDs during construction may possibly be absorbed into the costs of constructing the power line; however, the retro-fitting of BFDs, based on post-construction monitoring results that may indicate high-risk areas requiring further mitigation, would probably need to be added as an additional budgetary item. Similarly, the retro-fitting of BFDs on the existing 220 kV and 400 kV lines in any high-risk areas identified by the monitoring would also be an additional budgetary item. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 18 6.1 COST ESTIMATE: AVIFAUNA • Summary: total 6 surveys (2 pre-construction and 2 post-construction; see details of costing on following page) A) Pre- & Post-construction monitoring Pre-construction (N$) Post-construction (N$) Unit Cost Line Component Unit (N$) Units Session 1 Session 2 Units Session 3 Session 4 Session 5 Session 6 1 Travel Km 8,00 2 970 23 760,00 23 760,00 3 320 26 560,00 26 560,00 26 560,00 26 560,00 2 Time Days 5 000,00 9 45 000,00 45 000,00 13 65 000,00 65 000,00 65 000,00 65 000,00 (ornithologist) Time (assistant) Days 2 500,00 6 15 000,00 15 000,00 10 25 000,00 25 000,00 25 000,00 25 000,00 3 Accommodation Nights 1 800,00 6 10 800,00 10 800,00 9 16 200,00 16 200,00 16 200,00 16 200,00 132 760,00 94 560,00 94 560,00 $132 760,00 132 760,00 132 760,00 Total cost N$189 120,00 Total cost N$531 040,00 Combined total N$720 160,00 B) Marking of power lines as mitigation for collisions Costs (to be confirmed by Marking area Distance (km) Marking design NamPower) Mitigation of sensitive vulture area 20 Double loop spirals (large SWAN- Mitigation of Verreaux's Eagle 10 FLIGHT Diverters); both OPGWs to nesting area be marked; distance 10 m apart Retro-mitigation of new 400 kV line, unidentified As above; possible testing of further based on post-construction marking devices monitoring results ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 19 Avifauna: detailed breakdown of costs for power line monitoring 1. Power line monitoring a) Pre-construction (Session 1) Unit Cost Line Component Unit (N$) Units Total cost (N$) Comments 1 Travel 1.1 Surveys Km 8,00 220 1 760,00 Actual survey distances 1.2 Additional Km 8,00 750 6 000,00 Km between sections 1.3 From Windhoek Km 8,00 1 000 8 000,00 Km from and to Windhoek 1.4 Contingency Km 8,00 1 000 8 000,00 Sub Total 1 23 760,00 2 Time 2.1 Ornithologist Days 5 000,00 6 30 000,00 Survey 2.2 Preparation and data Ornithologist Days 5 000,00 3 15 000,00 processing 2.3 Assistant Days 2 500,00 6 15 000,00 Survey Sub Total 2 60 000,00 3 Accommodation 3.1 Surveys Nights 1 800,00 6 10 800,00 2 persons Sub Total 3 10 800,00 Total Session 1 94 560,00 b) Pre-construction (Session 2) Line Component Unit Unit Cost Units Total cost Comments 1 Travel 1.1 Surveys Km 8,00 220 1 760,00 Actual survey distances 1.2 Additional Km 8,00 750 6 000,00 Km between sections 1.3 From Windhoek Km 8,00 1 000 8 000,00 Km from and to Windhoek 1.4 Contingency Km 8,00 1 000 8 000,00 Sub Total 1 23 760,00 2 Time 2.1 Ornithologist Days 5 000,00 6 30 000,00 Survey 2.2 Preparation and data Ornithologist Days 5 000,00 3 15 000,00 processing 2.3 Assistant Days 2 500,00 6 15 000,00 Survey Sub Total 2 60 000,00 3 Accommodation 3.1 Surveys Nights 1 800,00 6 10 800,00 2 persons Sub Total 3 10 800,00 Total Session 2 94 560,00 Total Pre-construction (Sessions 1 + 2) 189 120,00 2. Post-construction ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 20 a) Post-construction (Session 3) Line Component Unit Unit Cost Units Total cost Comments 1 Travel 1.1 Surveys Km N$8,00 320 N$2 560,00 Actual survey distances 1.2 Additional Km N$8,00 1 000 N$8 000,00 Km between sections 1.3 From Windhoek Km N$8,00 1 000 N$8 000,00 Km from and to Windhoek 1.4 Contingency Km N$8,00 1 000 N$8 000,00 Sub Total 1 N$26 560,00 2 Time 2.1 Ornithologist Days N$5 000,00 10 N$50 000,00 Survey 2.2 Preparation and data Ornithologist Days N$5 000,00 3 N$15 000,00 processing 2.3 Assistant Days N$2 500,00 10 N$25 000,00 Survey Sub Total 2 N$90 000,00 3 Accommodation 3.1 Surveys Nights N$1 800,00 9 N$16 200,00 2 persons Sub Total 3 N$16 200,00 Total Session 3 N$132 760,00 b) Post-construction (Session 4) Line Component Unit Unit Cost Units Total cost Comments 1 Travel 1.1 Surveys Km N$8,00 320 N$2 560,00 Actual survey distances 1.2 Additional Km N$8,00 1 000 N$8 000,00 Km between sections 1.3 From Windhoek Km N$8,00 1 000 N$8 000,00 Km from and to Windhoek 1.4 Contingency Km N$8,00 1 000 N$8 000,00 Sub Total 1 N$26 560,00 2 Time 2.1 Ornithologist Days N$5 000,00 10 N$50 000,00 Survey 2.2 Preparation and data Ornithologist Days N$5 000,00 3 N$15 000,00 processing 2.3 Assistant Days N$2 500,00 10 N$25 000,00 Survey Sub Total 2 N$90 000,00 3 Accommodation 3.1 Surveys Nights N$1 800,00 9 N$16 200,00 2 persons Sub Total 3 N$16 200,00 Total Session 4 N$132 760,00 c) Post-construction (Session 5) Unit Cost Line Component Unit (N$) Units Total cost (N$) Comments 1 Travel 1.1 Surveys Km 8,00 320 2 560,00 Actual survey distances 1.2 Additional Km 8,00 1 000 8 000,00 Km between sections 1.3 From Windhoek Km 8,00 1 000 8 000,00 Km from and to Windhoek ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 21 1.4 Contingency Km 8,00 1 000 8 000,00 Sub Total 1 26 560,00 2 Time 2.1 Ornithologist Days 5 000,00 10 50 000,00 Survey 2.2 Preparation and data Ornithologist Days 5 000,00 3 15 000,00 processing 2.3 Assistant Days 2 500,00 10 25 000,00 Survey Sub Total 2 90 000,00 3 Accommodation 3.1 Surveys Nights 1 800,00 9 16 200,00 2 persons Sub Total 3 16 200,00 Total Session 5 N$132 760,00 d) Post-construction (Session 6) Unit Cost Line Component Unit (N$) Units Total cost (N$) Comments 1 Travel 1.1 Surveys Km 8,00 320 2 560,00 Actual survey distances 1.2 Additional Km 8,00 1 000 8 000,00 Km between sections 1.3 From Windhoek Km 8,00 1 000 8 000,00 Km from and to Windhoek 1.4 Contingency Km 8,00 1 000 8 000,00 Sub Total 1 26 560,00 2 Time 2.1 Ornithologist Days 5 000,00 10 50 000,00 Survey 2.2 Preparation and data Ornithologist Days 5 000,00 3 15 000,00 processing 2.3 Assistant Days 2 500,00 10 25 000,00 Survey Sub Total 2 90 000,00 3 Accommodation 3.1 Surveys Nights 1 800,00 9 16 200,00 2 persons Sub Total 3 16 200,00 Total Session 6 132 760,00 Total Post-construction (Sessions 3 + 4 + 5 + 6) 531 040,00 Total Pre + Post-construction (Sessions 1-6) 720 160,00 ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 22 7 REFERENCES IFC 2019. International Finance Corporation's Guidance Note 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources. International Finance Corporation, World Bank Group (http://documents. worldbank.org/curated/en/924371530217086973/ESF-Guidance-Note-6- Biodiversity-Conservation-English). Simmons RE & Martins, M. 2017. Proposed Kokerboom – Auas 400 kV transmission line. Avian Environmental Impact Assessment. Birds & Bats Unlimited (BBU) for Lithon Project Consultants. Simmons RE. 2018. Proposed Kokerboom - Auas 400 KV Transmission Line Environmental Impact Assessment. Avifaunal Assessment Report For Input into the Impact Assessment Report, August 2018. Birds and Bats Unlimited Environmental Consultants, Cape Town. Simmons RE. 2020. Proposed Kokerboom - Auas 400 kV Transmission line. Avian Environmental Impact Assessment – Amendment. Prepared by Birds & Bats Unlimited Environmental Consultants for NamPower. World Bank 2016. World Bank Environmental and Social Framework. World Bank, Washington, DC. License: Creative Commons Attribution CC BY 3.0 IGO. World Bank 2018. Guidance note for borrowers. ESS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources. World Bank, Washington, DC. (documents1.worldbank.org/curated/en/924371530217086973/ESF-Guidance- Note-6-Biodiversity-Conservation-English.pdf_ ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 23 8 APPENDIX 1: IDENTIFICATION GUIDE TO PROTECTED TREES THAT MAY BE FOUND ALONG THE POWER LINE ROUTE. Acacia erioloba camel-thorn, omuthiya, omumbonde, omuonde, Kameldornbaum, kameeldoring, llganab Semi-deciduous or deciduous tree with spreading crown, up to 20 m high; common and widely distributed, preferring sandy soils, depressions and dry riverbeds. BARK dark grey to blackish, rough with vertical fissures; young branchlets red-brown to plum-coloured, shiny, smooth, with characteristic zig-zagging between nodes. THORNS straight, paired, grey-white with black flecks, rigid, sharp, often with a pale brown tip. LEAVES twice-compound; 1–3 leaves per thorn axil; each pinna bearing 6–15 leaflet pairs; leaflets narrowly linear. FLOWERS golden-yellow. FRUIT a woody, velvety pod; young pods with rust to red-brown covering; older pods ear-shaped to sickle-shaped, grey. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 24 Albizia anthelmintica worm-cure albizia, aru, Wurmrindenbaum, oumaboom Deciduous tree, 2–10 m high; occasionally a shrub. BARK pale to dark grey to reddish-brown, young branchlets pale brown with white dots. LEAVES twice compound, with 2–5 leaflet pairs on each pinna; leaflets narrowly elliptic to obliquely obovate to almost circular, pale to blue- green or dark green with prominent veins. FLOWERS a semi-circular head up to 40 mm in diameter; stalk up to 25 mm long, pale yellow, pom-pom-like. FRUIT a papery, flattened pod, swollen above each seed; tip mucronate; splitting open when mature. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 25 Aloe dichotoma quiver tree, kokerboom, Kokerbaum Single-stemmed, often stout tree. STEM branches in two repeatedly to form a dense crown. Bark initially smooth and grey; on older stems pale yellow to yellow, rough, peeling in segments. LEAVES simple, in clusters at branch tips, oblong, boat-shaped; grey-green to brown-green; margin brownish-yellow with dark brown teeth; tip gradually pointed; base clasping the stem. FLOWERS yellow to golden-yellow, tubular, in branched sprays, carried above the leaf rosette. FRUIT a papery capsule. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 26 Aloe littoralis Windhoek aloe, mountain aloe, otjindombo Single-stemmed, tall succulent. STEM largely covered with old leaves and/or leaf remains. LEAVES simple, clustered at top of plant, succulent, boat-shaped; leaves of young plants often with white speckles; margin with long, red-brown to dark-brown teeth. FLOWERS pale red to deep red with yellow tips, tubular, carried in a branched, erect spray. FRUIT a papery capsule. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 27 Boscia albitrunca shepherd’s tree, witgat, omutendereti, omunkunzi Evergreen shrub or tree, up to 10 m high; widespread in Namibia, occurring in many different habitats and exhibiting a range of different growth forms. BARK pale in colour, almost white, although may be partially grey or occasionally yellow; rough, especially where flaking has occurred. LEAVES simple, spirally arranged, solitary or in clusters of 2–4 on dwarf shoots; blade oblong or oblong-elliptic, 10–55 x 3–10 mm; thick, leathery, brittle, slightly rough; both surfaces grey-green to dark green, practically hairless; midrib prominent, yellowish; margin smooth, finely fringed with hairs; tip blunt to shallowly notched, often with tiny hair-like tip. FLOWERS small, green-yellow; August to February. FRUIT spherical, c. 10 mm in diameter; yellow when ripe. SEEDS round to kidney-shaped, with brittle cream-coloured warty shell; one to several embedded in bright orange flesh. The shepherd's tree grows in conditions ranging from arid to subtropical. This species has many uses, making it an important component of the vegetation wherever it occurs. It is also an important shade tree. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 28 Euclea pseudebenus wild ebony, Cape ebony, abikwa, ebbehout, Ebenholzbaum, omuthema, tsàbì.s Evergreen tree, occasionally a shrub, 3–9 m high with characteristic thin, drooping branches. BARK grey to black-grey, very rough. LEAVES simple, narrow, drooping, leathery, light green. FLOWERS small, whitish, waxy-looking. FRUIT a ball-shaped berry, dark brown to black when ripe. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 29 Maerua schinzii ringwood tree, lammerdrol, Ringholzbaum, omutengu, goradab, omuhasuviwa Evergreen shrub or tree, 3–7 m high; reasonably common, and distributed almost throughout Namibia, with the exception of the central- and south-eastern parts. Found on plains, hill slopes and rocky outcrops, as well as along dry watercourses. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 30 Ziziphus mucronata buffalo-thorn, blinkblaar-wag-‘n-bietjie, omukekete, omukaru Semi-evergreen tree with a spreading crown, up to 7 m high; most common along rivers, as well as dam and pan edges, but also found on plains. BARK rough, grey to dark grey, cracked; branchlets mostly zig-zag, often drooping. THORNS in pairs with one straight and one curved thorn. LEAVES simple, ovate to broadly ovate; shiny green, with two veins originating together with midrib at base; margin scalloped; tip pointed, often with a hair-like tip; base asymmetric. FLOWERS small, green to yellow-green, carried in small clusters. FRUIT ball-like, hard, with thin, dry flesh; red-brown when ripe. ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 31 ESMP 400kV Transmission line Auas to Kokerboom Biodiversity Management Plan December 2023 95 APPENDIX B LIVELIHOOD RESTORATION PLAN NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 Dec 2023 Environmental and Social Management Plan for the Proposed 400 kV Transmission Line from Auas to Kokerboom Substation LIVELIHOOD RESTORATION PLAN KATIMA MULILO-KONGOLA WATER SUPPLY PROJECT PHASE 3 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT AND ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN STAKEHOLDER ENGAGEMENT PLAN ii COPYRIGHT © NAMPOWER, 2023. ALL RIGHTS RESERVED Proposed 400kV Transmission line from Kokerboom to Auas Substations PROJECT NAME ESIA and ESMP REPORT ESMP Livelihood Restoration Plan Final STAGE OF REPORT NamPower CLIENT Attention: Martin van der Merwe Enviro Dynamics Enquiries: Stephanie van Zyl LEAD CONSULTANT Tel: 264 81 1287002 E-Mail: stephanie@envirod.com DATE OF RELEASE December 2023 CONTRIBUTORS TO THE Authors: Stephanie van Zyl REPORT Reviewed: Norman van Zyl ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 iii TABLE OF CONTENTS 1 INTRODUCTION ...................................................................................................... 1 2 DESCRIPTION OF THE PROJECT ............................................................................. 2 2.1 PROJECT SERVITUDE.......................................................................................2 2.2 ALTERNATIVE PROJECT SERVITUDE CONSIDERED .........................................3 3 PROJECT IMPACTS ................................................................................................. 4 3.1 AFFECTED PROJECT AREA .............................................................................4 4 IMPACTS ON PROJECT AFFECTED FARMS ............................................................ 5 5 LEGAL FRAMEWORK FOR ADDRESSING COMPENSATION .................................. 5 5.1 ELECTRICITY ACT (4 OF 2007) ........................................................................5 5.2 COMPENSATION PROTOCOL ........................................................................6 5.3 PROGRESS ON THIS PROJECT ........................................................................7 5.4 STAKEHOLDER ENGAGEMENT .......................................................................7 6 GAPS IDENTIFIED IN LAND ACQUISITION PROCESS AND RECOMMENDATIONS 8 6.1 POLICY ............................................................................................................8 6.2 EVALUATION OF THE CURRENT PROCEDURE ................................................8 6.3 EVALUATION OF THE WAYLEAVE FORM........................................................9 6.4 CAPACITY AVALUATION................................................................................9 6.5 SUMMARY OF RECOMMENDATIONS .......................................................... 10 Appendix A: Way leave example ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 iv GLOSSARY BESS Battery Energy Storage System ESF Environmental and Social Framework ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan ESS Environmental and Social Standards kV Kilo Volt TABLES AND FIGURES Table 1: Proposed Project affected areas (north to south) .................................... 4 Figure 1: Locality map of the proposed Auas-Kokerboom 400kV transmission line 1 Figure 2: Servitude details for the proposed transmission line 3 ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 1 1 INTRODUCTION NamPower intends constructing a 400kV power line from the Kokerboom Substation near Keetmanshoop to the Auas Substation near Dordabis, Namibia. The line will assist in securing the supply of electricity to Namibia in future and open up opportunities for selling power to the Southern African Power Pool. Figure 1: Locality map of the proposed Auas-Kokerboom 400kV transmission line ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 2 NamPower is seeking funding from the World Bank for the construction of the transmission line, which will have the following components: • The new Auas-Kokerboom 400kV Transmission Line, with associated infrastructure at both substations such as switchgear and reactors. • A Battery Energy Storage System (BESS) to be installed at Lithops Substation, that will enable NamPower to store energy generated by, amongst other, renewable sources such as solar or wind energy to allow utilisation of such energy when these resources are not available, such as after sunset. The World Bank requires of its Borrowers to fulfil the requirements of the Environmental and Social Framework (ESF). The Framework sets out the Environmental and Social Standards (ESS) to be complied with on all projects funded by the World Bank. 1 Environmental and Social Standard 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement of the World Bank’s ESS, is being applied to the transmission line project in this report, and information is provided of the outcome and recommendations to comply with this Standard. ESS 5 “recognizes that project-related land acquisition and restrictions on land use can have adverse impacts on communities and persons. Project-related land acquisition or restrictions on land use may cause physical displacement (relocation, loss of residential land or loss of shelter), economic displacement (loss of land, assets or access to assets, leading to loss of income sources or other means of livelihood), or both. The term “involuntary resettlement” refers to these impacts. Resettlement is considered involuntary when affected persons or communities do not have the right to refuse land acquisition or restrictions on land use that result in displacement. “ 2 DESCRIPTION OF THE PROJECT 2.1 PROJECT SERVITUDE The proposed route of the project follows an existing 220kV transmission line for most of the route. The need for land acquisition and impacts on land use, livelihoods and assets has been avoided by: 1)Aligning the route parallel to an existing line 2)Adjusting the servitude to avoid any homesteads or other structures, as well as vistas that are important to farm owners where this was possible. 1https://www.worldbank.org/en/projects-operations/environmental-and-social- framework/brief/environmental-and-social-standards ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 3 The servitude dimensions will be as follows: The entire length of the proposed transmission lines is estimated to be 461 km. The servitude will be 80 m wide for the entire line an estimated 12 m width needs to be totally cleared of vegetation and obstacles to create a service road (Figure 2), to provide access (during construction and maintenance) to the line throughout its lifespan of 30 years. 40 m servitude on Total 80 m servitude 12 m to be either side of the line to be clear of cleared of in sparsely populated settlement in sparsely vegetation areas and 25 m in populated areas densely populated and 50 m in densely areas populated areas Figure 2: Servitude details for the proposed transmission line Since the line will run parallel to an existing power line to the south, the servitude width there including the existing line will be 111m in total, consisting of a minimum distance of 46m between the two line. There will be a 40m servitude outside the centre line of the 400kV line, and 25m outside the centre line of the existing 220kV line. NamPower has historically compensated the farm owners for the land restrictions imposed as a result of the existing 200kV transmission line. For safety and technical reasons, no permanent structures other than the towers are allowed within the servitude. Grazing and cultivation of fields with associated farming activities may be accommodated within this area, except for the 12 m strip, which is needed during construction. 2.2 ALTERNATIVE PROJECT SERVITUDE CONSIDERED It is best practice to align the servitude along an existing one, in order to avoid land sterilisation, habitat impact, etc. An alternative route (western route) was considered along an existing 440kV transmission line running to the west of this current servitude (Figure 1). This alternative route affects some 5% more land than the current eastern one. However, NamPower wishes to avoid crossings of high voltage lines. Such anticipated crossings, as well as two 400kV lines adjoining each other, constitute significant technical risks of power failure. Since the social impact, as explained below, is considered low, the technical reasons for preferring the current route is supported. ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 4 3 PROJECT IMPACTS 3.1 AFFECTED PROJECT AREA The proposed transmission line traverses three (3) regions (namely Khomas, Hardap and //Karas). Khomas Region is centrally located and landlocked; it has a population density of 9.3 people per km². Hardap has a low population density of 0.7 people per km2. The //Karas Region is the most southern and largest region in Namibia, with an area of 161,215km²; it is the least densely populated of Namibia’s 14 regions with only 0.5 people per km². The line passes through 6 constituencies, the majority of which are rural (see Table 1). Table 1 Proposed Project affected areas (north to south) Indirectly Affected Area Directly Affected Area Country Region Constituency Closest Town/ Farms Settlement Namibia Khomas Windhoek Rural Dordabis Hardap Mariental Rural Mariental (Mariental Urban) Mariental Urban Mariental Rehoboth Rural Duineveld, Kalkrand 101 Farms Gibeon Kries, Gibeon, Amper- Bo //Karas Berseba Tses Keetmanshoop Keetmanshoop Rural There are two types of farms affected, namely commercial and communal. The commercial farms are privately owned, by one owner, sometimes a legal entity owned by more than one person. The commercial farms are used mostly for livestock farming and the areas affected by the servitude used for grazing. There are isolated cases with tourism/hunting facilities. There are also commercial farms owned by the Government of Namibia. They are mostly leased on a 99-year agreement basis to the occupants. These farms are mostly used for subsistence purposes, which is livestock farming with cattle, goats and sheep. There are often multiple lessees on one farm, and sub-letting is also occurring. Data is often deficient and it is difficult or impossible to contact these lessees, because they change often and are not always formally registered. The communal farms in the study area are also used for livestock farming, but owned by the Government. There is also a large conservancy in the south of the study area (!Khob !Naub Concervancy Figure 1), which is registered in terms of the Parks and Wildlife Management Act. This area has livestock farming, as well as limited hunting activities managed by a committee consisting of community members elected for this purpose. ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 5 The formal registered farms in the study area are relatively large and vary from approximately 4000-6700Ha, on average. One Government farm in the South of the area is much larger, with some small settlements on it, all unaffected by the project. 4 IMPACTS ON PROJECT AFFECTED FARMS As for land restriction, the 80m wide strip of land will be required for the servitude, of which 12m will be completely stripped of vegetation. The grass, however, will grow back and can be used for grazing. The servitude will remain the property of the land owners, but no structures may be constructed within the servitude. Considering the relatively large size of the farms, compared to the narrow servitude required for the transmission line, the impact in terms of land use restrictions is considered low. Since most of the farms are being used for grazing, land use may continue mostly undisturbed. The impacts with respect to land use may be summarised as follows: • There is no involuntary or voluntary resettlement in the form of people being displaced on the project. There are no permanent structures of any of the land owners or occupants affected. • Land use restriction as a result of easement for the project: negligible, with some disturbance and reduced grazing during construction. • Loss of livelihoods as a result of the project: negligible, subsistence and commercial farming can continue undisturbed. • Visual impact affecting livelihood of tourism: low impact overall, but moderate impact on limited number of farms. There is already one or more transmission lines on some of the farms and if the farms are used for tourism, farm owners sometimes feel that the transmission lines have a visual impact, affecting their visual resource used for tourism. The route was re-adjusted where farm owners requested such, for the sake of preserving their views important for tourism. • Cumulative impact due to more than one transmission line traversing their land: Due to the large area on most of the farms, this impact is still considered low, although there are isolated cases when the farm owners have submitted their concern in this regard. 5 LEGAL FRAMEWORK FOR ADDRESSING COMPENSATION 5.1 ELECTRICITY ACT (4 OF 2007) Section 35 of the Electricity Act makes provision for the expropriation of land for the purposes of providing electricity, on condition that there was a process of consultation and a reasonable attempt to acquire the rights for the project. Such ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 6 a reasonable attempt involves the process of fair compensation for the right to use the land for the transmission line. NamPower does not currently have an approved, formal policy for dealing with easement and compensation cases, but it does have a standard compensation protocol, which is also used for this current project and is as described below. A compensation policy is currently being considered by the NamPower Board in this regard. The consultant did no have access to the draft policy, since it is under consideration. 5.2 CURRENT EASEMENT PROCESS When NamPower intends to develop a new transmission line, the most suitable route is contemplated from available cartography. In the development of such a route, the design team attempts to find an optimal route regarding the needs of all parties. The most direct route is often preferable, but topography such as mountains and rivers may necessitate bend points. Once such an optimal route is selected, landowners are approached in order to negotiate wayleaves over the route. In these negotiations, NamPower aims to find a mutually beneficial agreement with the landowner. The current as well as future land use on the property is considered, and often the line route is deviated to incorporate the comments received from landowners. On commercial farms, land uses such as livestock farming and game farming as well as tourism is often considered. Especially in the latter, NamPower takes cognizance of the fact that transmission lines have a visual impact. The line route is often deviated in order to minimize the impact on the landowner, and if an agreement is then reached, a wayleave is signed. The landowner is then paid a compensation based on the fair value of land. The wayleave does not expropriate the property from the landowner, but provides NamPower with the right to build, operate and maintain a transmission line within the area described in the wayleave (see Appendix A). The landowner’s rights in terms of the wayleave is limited only to the extent that no permanent structures may be placed in the wayleave area. In the event that no agreement is reached, an alternative route is considered to avoid the property of the landowner, and route changes are negotiated with neighbouring landowners. In the event where no agreement can be reached, and NamPower has no alternatives for route deviation, the Electricity Act allows for the land to be expropriated, against a fair compensation. In this event, the land portion would become the property of NamPower (Section 5.1 above). To date, this measure has not yet been used. The wayleave form used for the compensation process is attached as Appendix A. This wayleave is to be confirmed once the line is built and the exact portion of land has been determined. A formal servitude is not registered over the farm, there is ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 7 only an agreement of this nature between Nampower and the landowner. In case of Government farms, the applicable ministry is paid the easement compensation. The easement compensation is calculated according to the valuation of the Ministry of Lands, Water and Land Reform. Nampower provides an additional incentive of N$ 500.00 per Ha over and above the Government valuation. In the case of the current valuation example in Appendix A, it would be N$ 200.00 (Government valuation) + N$ 500.00 (Nampower incentive) = N$ 700.00/Ha as a once-off payment. 5.3 PROGRESS ON THIS PROJECT REGARDING WAYLEAVES There are 101 farms affected in total (based on the current route however subject to change depending on diversions), of which: a) Thirty owners have signed the wayleave agreement. Of these, 5 owners have been paid compensation, 3 owners’ payment is in process, and 1 servitude has been registered. b) Thirty six owners are in the engagement process, in preparation of the wayleave agreement. Of these, 26 are Government farms, and 10 servitude agreements are with the land occupants waiting for confirmation. c) One owner is not willing to sign. d) The information of eight farms are in the process of being gathered/researched. e) Twenty-six farm owners are yet to be approached. Appendix A is an example of a wayleave form that has been signed on this project. 5.4 STAKEHOLDER ENGAGEMENT The full stakeholder engagement process of this project is documented in the Stakeholder Engagement Report for this ESIA. Each individual farm owner is approached directly and personally as part of the waybill process, by Nampower. Besides this, the environmental and social consultants who have been involved on the project have, since 2016, provided several opportunities for farm owners to voice their concerns. In 2016 there were 7 regional meetings as well as local consultations with farm owners. During 2020, farm owners with concerns were personally consulted and public meetings were held in Windhoek and Rehoboth. ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 8 Overall, land owners have been in agreement with the proposed transmission line. There are individual cases where farm owners had concerns and these have mostly been addressed by rerouting the line to avoid sensitivities, including homesteads, vistas, a grave yard and a vulture breeding area. There remain isolated cases of farm owners (at the time of the report and to the knowledge of the consultant, two cases) who are dissatisfied with the cumulative effect of more than one line traversing their land. 6 GAPS IDENTIFIED IN COMPENSATION PROCESS AND RECOMMENDATIONS 6.1 POLICY It is important that NamPower has a policy for dealing with land compensation on their transmission line projects and it is therefore supported that such a policy has been drafted and is currently being circulated for approval. Compensation and negotiation strategies need to be fair and consistent. A policy also needs to be disclosed to the land owners involved and used as backing by those doing the actual negotiations. This current evaluation cannot include a scrutiny of this policy, since it has been not disclosed and is therefore acknowledged as a limitation. However, it is assumed that the policy is a formalisation of the current procedure used, as explained in Section 5.2. 6.2 EVALUATION OF THE CURRENT PROCEDURE The impact assessment outcome is that the effects of the land restrictions for the transmission line is generally low, since the land to be utilised is mostly grazing land, with the exception of limited impact on tourism and hunting activities due to vistas being affected. The hunting activities of the !Khob !Naub conservancy are not affected to any measurable extent. Grazing access on the servitude will continue and livelihoods therefore unaffected. Even though the land is restricted for the erection of physical structures, the farms are large, with ample space remaining and this impact is therefore negligible. Farm owners who use their land for tourism purposes where specifically accommodated by ensuring the route does not affect the vistas which are important for tourism. It is confirmed that NamPower has done their best to avoid impacts and to accommodate farm owners. Avoidance of impacts has been carried out successfully. As far as the compensation for the mentioned land restriction (i.e. no structures to be erected) goes, the use of the Government evaluation of farmlands is considered fair and consistent. The adding by Nampower of a further incentive is considered generous and this is applied consistently. The replacement cost principle is therefore generously met. ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 9 The only matter which remains unresolved is the isolated cases where NamPower could not avoid impacts mentioned. It is recommended that the policy includes a hierarchy of criteria for compensating such cases, which provides for the land owner’s loss in a consistent way, and facilitates smooth implementation for Nampower, avoiding the red tape of expropriation, as follows: 1. An additional rate per Ha added when there are cumulative high voltage lines crossing a farm. 2. A rate per Ha added when the land owner’s income is affected directly or indirectly by the transmission line, for instance the existence of or proven planned lodge which could not be avoided. 3. A mandate provided to the negotiator for cases where the land owner requests an alternative form of assistance instead of the cash compensation, for instance the moving of an existing power line, or the grading of a road by the Contractor, which is reasonably equal in value to the cash compensation. It is recommended that NamPower considers these additional categories for compensation and formalises them, for cases over and above the existing rate per Ha offered. It is also proposed that NamPower determines a cut-off date for those persons which cannot be reached beyond best efforts and that the funds for this compensation be kept in a fund for another grace period. 6.3 EVALUATION OF THE WAYLEAVE FORM It is proposed that the current standard wayleave form be updated to include a more detailed diagram of the power line servitude, with coordinates, and entered into the Nampower system on GIS. The standard wording should also be updated to reflect the outcome of the policy that is to be approved. 6.4 CAPACITY EVALUATION NamPower has proven capacity to implement the compensation process to the satisfaction of the World Bank. One qualified position is available for the compensation process and this position is currently filled. Nampower should evaluate the capacity to include the diagrams on their GIS system. ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 10 6.5 SUMMARY OF RECOMMENDATIONS 6.5.1 That the NamPower Policy for Land Compensation for Transmission Line Servitudes be finalised and formalised as a matter of urgency. 6.5.2 That additional criteria be considered for compensation as discussed in Section 6.2 6.5.3 That a cut-off date be formalised for the payment of compensation which will apply beyond best efforts to reach eligible land owners. 6.5.4 That NamPower update the current standard wayleave form to reflect the contents of the Livelihood Restoration Policy when approved. 6.5.5 That NamPower improve the current content of the Diagrams attached to the wayleave forms, to include coordinates and that the data be entered into the current GIS system. 7 EASEMENT BUDGET The total land required for the project, that will be restricted in terms of land use, is 3728 Ha. At N$ 700,00/Ha, this constitutes a total budget of N$ 2,609,600. This does not include an amount as additional compensation for cumulative impact, should this be approved. ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 1 APPENDIX A: WAYLEAVE EXAMPLE ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 1 ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 2 ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 3 ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 4 ESMP 400kV Transmission line Auas to Kokerboom Livelihood Restoration Plan December 2023 96 APPENDIX C Example of Environmental Enforcement System This is only an example and must be reviewed and compiled for site conditions by the ECO, NamPower and the Implementation Team. The following payment retention and deduction methods are in place for non- compliance listed below. It shall be issued after the non-compliance procedure has been duly followed. The ECO shall be the judge as to what constitutes non- compliance in terms of this document. Where the Operator inflicts non-repairable damage upon the environment or refuse to comply with any of the environmental specifications, he shall be liable to criminal and civil prosecution over and above any other contractual consequence. The ECO shall be responsible for a Report on the non-repairable damage and / or non-compliance with visual and other evidence as well as issuing the penalty to the Operator with the report attached. The Operator is deemed NOT to have complied with this Specification if: • within the boundaries of the site, site extensions and haul/ access roads there is enough evidence of contravention of ESMP specifications; • attributable environmental damage due to negligence; • destruction of vegetation without permission of the ECO and NamPower. • Safety of Operator personnel and public has been compromised due to negligence; • the Operator fails to comply with corrective or other instructions issued by NamPower or the ECO within a specific time; • the Operator fails to respond adequately to complaints from the public; and • Payment deductions or retention in terms of the contract shall not absolve the offender from being liable from prosecution in terms of any law. Retention and/or deductions shall be issued per incident at the discretion of the ECO. Such deductions shall be issued in addition to any remedial costs incurred as a result of non-compliance with the ESMP. The ECO shall inform the Operator of the contravention and the amount of the fine, which NamPower shall deducted from payments due under the Contract. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 97 The activities detailed below may guide the ECO in terms of recommending payment retention or deduction by NamPower on the Operator and/or his Subcontractors: Item Activity Retention amount Deduction amount 1 Damage to key sensitivities 1.1 General damage to sensitive Estimated value of the 150% of the value of environment such as sensitive cost of restoration the cost of full vegetation and bird habitat. operation plus 75%. restoration operation (if NamPower has to (Deal separately with each take restoration individualised damage as per responsibility), or 25% items 1.2, 1.3, 1.4 and 1.5 below) (if the contractor successfully restores the damage) 1.2 Movement of the Contract N$ 100,000 and apply N$ 100,000 and apply Implementer onto an area on the item 1.1. item 1.1. site before the vegetation specialist has identified sensitive vegetation and identified no-go zones. 1.3 Significant damage to the N$ 100,000 and apply N$ 100,000 and apply construction site without a map in item 1.1. item 1.1. place specifying where construction/movement is permitted. 1.5 Damage to sensitive vegetation N$ 50,000 and apply N$ 50,000 and apply per incident. item 1.1. item 1.1. 2 Non-compliance to ESMP items 2.1 Any person, vehicle, equipment, N$ 50,000 and apply Loss of each previous etc. activity related to the item 1.1. retention amount per Contract Implementer’s follow-up incident. operations outside the designated boundaries and restricted zones. 2.2 Person caught trespassing outside N$ 50,000 and apply Loss of each previous the demarcated construction item 1.1. retention amount per area. follow-up incident. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 98 Item Activity Retention amount Deduction amount 2.3 Any personnel guilty of reckless N$ 10,000 and apply Loss of each previous driving on and in the vicinity of the item 1.1. retention amount per site, including excessive speeds. follow-up incident. 2.4 Accident due to safety Estimated value of the 150% of the value of negligence. cost of recovery / the cost of full compensation plus recovery / 150%. compensation (if NamPower has to take restoration responsibility), or 25% (if the contractor successfully implement recovery / compensation) 2.5 Deliberate non-compliance with N$ 50,000 and closure Loss of each previous Safety Policy of site until retention amount per compliance follow-up incident. achieved. 3 Pollution activities 3.1 Persistent and un-repaired spilling N$ 50,000 and Loss of each previous of hazardous materials and estimated value of the retention amount per materials causing pollution. cost of restoration follow-up incident. operation plus 25%. Persistent littering on site. N$ 10,000 and apply Loss of each previous item 3.1. retention amount per follow-up incident. Individuals repeatedly not making N$ 10,000 and apply Loss of each previous use of the designated toilet item 3.1. retention amount per facilities. follow-up incident. Disposal of waste in a manner N$ 10,000 and apply Loss of each previous other than what was agreed upon item 3.1. retention amount per on site or the prescribed method in follow-up incident. the waste management plan section. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 99 APPENDIX D: Archeology Chance Find Procedure Areas of proposed development activity are subject to heritage survey and assessment at the planning stage. These surveys are based on surface indications alone, and it is therefore possible that sites or items of heritage significance will be found in the course of development works. The procedure set out herein covers the reporting and management of such finds. Scope: The “chance finds” procedure covers the actions to be taken from the discovery of a heritage site or item, to its investigation and assessment by a trained archaeologist or other appropriately qualified person. Compliance: The “chance finds” procedure is intended to ensure compliance with relevant provisions of the National Heritage Act (27 of 2004), especially Section 55 (4): “ a person who discovers any archaeological …. object ……must as soon as practicable report the discovery to the Council”. The procedure of reporting set out below must be observed so that heritage remains reported to the NHC are correctly identified in the field. Responsibility: Operator To exercise due caution if archaeological remains are found. Foreman To secure site and advise management timeously. Superintendent To determine safe working boundary and request inspection. Archaeologist To inspect, identify, advise management, and recover remains. Procedure: Action by person identifying archaeological or heritage material includes the following: a) If operating machinery or equipment stop work. b) Identify the site with flag tape. c) Determine GPS position if possible. d) Report findings to foreman. Action by foreman: a) Report findings, site location and actions taken to superintendent. b) Cease any works in immediate vicinity. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 100 Action by superintendent: a) Visit site and determine whether works can proceed without damage to findings. b) Determine and mark exclusion boundary. c) Site location and details to be added to project GIS for field confirmation by archaeologist. Action by archaeologist: a) Inspect site and confirm addition to project GIS. b) Advise NHC and request written permission to remove findings from work area. c) Recovery, packaging and labelling of findings for transfer to National Museum. In the event of discovering human remains: a) Actions as above. b) Field inspection by archaeologist to confirm that remains are human. c) Advise and liaise with NHC and Police. d) Recovery of remains and removal to National Museum or National Forensic Laboratory, as directed. NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 101 APPENDIX E: NamPower Safety, Health, Environment and Quality Policy NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 POLICY STATEMENT SAFETY, HEALTH, ENVIRONMENT & QUALITY (SHEQ) MANAGEMENT SYSTEM NamPower's Mandate is to generate, transmit • Continuously monitor, measure, analyse and trade in electricity and, to a limited extent, and evaluate the effectiveness of the distribute electricity as expressed in the SHEQ Management System; and licences it holds under the Electricity Act 4 of • Use the SHEQ Policy Statement as a 2007. framework to set business and operational objectives and targets. In line with its mandate, NamPower regards its stakeholders as important and pledges to provide NamPower Stakeholder's Accountability: a safe and healthy work environment in order to Stakeholders, including all employees, shall ensure the well-being of stakeholders, protect the commit and adhere to this policy statement by: environment and reduce pollution while ensuring customer satisfaction in fulfilling our Vision, Mission • Attending SHEQ Management System and Objectives. programmes as and when required. • Taking responsibility and accountability for To demonstrate conformance to the Safety, Health, their own health and safety, as well as that Environment & Quality (SHEQ) Management System, of others in the workplace. in line with ISO 9001:2015, ISO 14001:2015, ISO • Identifying and reporting potential hazards, 55001:2014 and ISO 45001:2018, NamPower commits environmental aspects, impacts and risks to to: the relevant NamPower representatives. • Protecting the environment in which • Ensure compliance in all operations in NamPower operates. accordance with applicable legal and • Adhering to SHEQ Management System other requirements; requirements, policies, standards and • Develop, implement, maintain and applicable legal and other requirements. continually improve Safety, Occupational Health, Environmental, Wellness and This policy statement is communicated, understood Quality Management Systems; and made available to all relevant stakeholders. • Ensure reliable assets by implementing the Asset Management System; This policy statement shall be reviewed every • Proactively identify, evaluate and five years or as and when required. mitigate environmental aspects and impacts, as well as hazards and risks associated with operations and activities; .............................................. .......................................... MANAGING DIRECTOR DATE 102 Appendix F: Preliminary Implementation Budget NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 103 The estimate of implementing the ESMP must be read considering the following principles: • This estimate summarises the cost to implement the Biodiversity Management Plan. • Costs of avifauna collision marker implementation and Procedure for removal of protected trees Procedure to be determined by NamPower. Item Stage Cost (N$) Avifauna Monitoring Pre Construction 200,000 Post Construction 550,000 Avifauna collision markers Construction To be determined Procedure for removal of Construction To be determined protected tree Environmental Control Officer – Construction (36 months) 720,000 NamPower (salary @ 20,000 / month) ECO-NP accommodation Construction (36 months) 360,000 (@ N$10000 /month) ECO-NP Transport Construction (36 months) 900.000 (@ N$25000/month) ECO-NP Office and admin. Construction (36 months) 360,000 (@ N$10000/month) Environmental Control Officer – Construction (36 months) 720,000 Contractor (salary @ 20,000 / month) ECO-C accommodation Construction (36 months) 360,000 (@ N$10000 /month) ECO-C Transport Construction (36 months) 900.000 (@ N$25000/month) TOTAL Budget 5,070,000 NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 104 Appendix G: Labour Management Procedures NamPower: Proposed 400 kV line Kokerboom to Auas Environmental and Social Management Plan December 2023 Dec 2023 Environmental and Social Management Plan for the Proposed 400 kV Transmission Line from Auas to Kokerboom Substation LABOUR MANAGEMENT PROCEDURES i COPYRIGHT © NAMPOWER, 2023. ALL RIGHTS RESERVED Proposed 400kV Transmission line from Kokerboom to Auas Substations PROJECT NAME ESIA and ESMP REPORT ESMP LABOUR MANAGEMENT PRPCEDURES Final STAGE OF REPORT NamPower CLIENT Attention: Martin van der Merwe Enviro Dynamics Enquiries: Stephanie van Zyl LEAD CONSULTANT Tel: 264 81 1287002 E-Mail: stephanie@envirod.com DATE OF RELEASE December 2023 CONTRIBUTORS TO THE Authors: Norman van Zyl REPORT Reviewed: Stephanie van Zyl ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 ii TABLE OF CONTENTS TABLE OF CONTENTS .....................................................................................................ii GLOSSARY .................................................................................................................... iii TABLES AND FIGURES ................................................................................................... iii 1 INTRODUCTION ...................................................................................................... 1 2 OVERVIEW OF LABOUR USE ON THE PROJECT ..................................................... 2 3 ASSESSMENT OF KEY POTENTIAL LABOUR RISKS .................................................. 4 4 LEGAL FRAMEWORK ADDRESSING LABOUR TERMS AND CONDITIONS.............. 7 5 LEGAL FRAMEWORK ADDRESSING OCCUPATIONAL HEALTH AND SAFETY........ 9 6 RESPONSIBLE STAFF .............................................................................................. 10 7 POLICIES AND PROCEDURES ............................................................................... 11 8 AGE OF EMPLOYMENT ......................................................................................... 12 9 TERMS AND CONDITIONS .................................................................................... 13 10 GRIEVANCE MECHANISM ................................................................................... 14 11 CONTRACTOR MANAGEMENT ............................................................................ 14 12 COMMUNITY WORKERS ....................................................................................... 15 13 PRIMARY SUPPLY WORKERS................................................................................. 15 APPENDIX A ................................................................................................................ 16 ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 iii GLOSSARY BESS Battery Energy Storage System ESF Environmental and Social Framework ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan ESS Environmental and Social Standards ILO International Labour Organisation kV Kilo Volt SEA/SH Sexual Exploitation and Abuse / Sexual Harassment TABLES AND FIGURES Table 1: Labour related terms and conditions ............................................................. 7 Table 2: Occupational Health and safety terms and conditions ............................... 9 Figure 1: Locality map - proposed Auas-Kokerboom 400kV transmission line ........ 1 Figure 2: Project reporting structure affecting Labour Management ...................... 10 ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 1 1 INTRODUCTION NamPower intends constructing a 400kV power line from the Kokerboom Substation near Keetmanshoop to the Auas Substation near Dordabis, Namibia. The line will assist in securing the supply of electricity to Namibia in future and open up opportunities for selling power to the Southern African Power Pool. Figure 1: Locality map - proposed Auas-Kokerboom 400kV transmission line ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 2 NamPower is seeking funding from the World Bank for the construction of the transmission line, which will have the following components: • The new Auas-Kokerboom 400kV Transmission Line, with associated infrastructure at both substations such as switchgear and reactors. • A Battery Energy Storage System (BESS) to be installed at Auas Substation, that will enable NamPower to store energy generated by, amongst other, renewable sources such as solar or wind energy to allow utilisation of such energy when these resources are not available, such as after sunset. The World Bank requires of its Borrowers to fulfil the requirements of the Environmental and Social Framework (ESF). The Framework sets out the Environmental and Social Standards (ESS) to be complied with on all projects funded by the World Bank. 1 Environmental and Social Standard 2: Labour and Working Conditions of the World Bank’s ESF, is being applied to the transmission line project in this report, and information is provided of the outcome and recommendations to comply with this Standard. “ESS2 recognizes the importance of employment creation and income generation in the pursuit of poverty reduction and inclusive economic growth. Borrowers can promote sound worker- management relationships and enhance the development benefits of a project by treating workers in the project fairly and providing safe and healthy working conditions. ” 2 OVERVIEW OF LABOUR USE ON THE PROJECT Employment opportunities on this project are limited. The construction of transmission lines is a specialised operation, which will be managed by a local or foreign contractor who will bring specialist foreign and Namibian staff from areas outside the project area. Number of project workers: About 150 people will be employed during construction of a section of line, of which approximately 10 people will be of management and supervisory capacity. The remainder will be artisan and skilled labour, with a smaller component of unskilled labour in support of the skilled labour. Characteristics of Project Workers: The management / supervisory team will be degree level qualified personnel with high levels of project construction management and technical specialist skills required to successfully manage and complete the project. If the contractor is an international company most of this 1https://www.worldbank.org/en/projects-operations/environmental-and-social- framework/brief/environmental-and-social-standards ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 3 team may comprise of international migrant professionals. If the contractor is Namibian, the team will likely consist of Namibian professionals. They are supported by a team of electrical and civil engineering technicians, foremen and artisans required for the execution of the project activities. If the contractor is an international company at least some of this team may comprise of international migrant professionals. If the contractor is Namibian, the team will likely consist of Namibian professionals. The only activities for which the contractors most likely use local unskilled labour is for the de-bushing process of the transmission line route (de-bushing will be done mostly with machines, but may be supplemented with manual labour), for assisting with the digging of the foundations, and unskilled administrative tasks such as assisting with the arrangement, storing, assembling, placement and relocation of the project materials, small equipment and camp maintenance. Unskilled labour will only be from Namibia and a locals first policy enforced on the contractor will ensure that local applicants receive preference to avoid internal migration in Namibia or any of its regions. The maintenance of the new transmission line is likely to be done by existing NamPower staff, therefore, no employment creation is expected during operation. If an agreement can be reached between NamPower and the local authorities, the vegetation maintenance of the cleared portion of the servitude could serve as an employment opportunity. Timing of Labour Requirements: The project schedule will demand that all the work packages are implemented in parallel. This means multiple specialist teams will function along the route as they are assigned to each work package. The full complement of the project labour will therefore be utilised within the first quarter of the project until the last quarter of the project. Local unskilled labour of likely up to 50 people will rotate through the project activity locality to comply with the locals first employment policy. Contracted workers: The project is not complex enough to require multiple specialist sub-contractors under the main contractor. The bush clearing may be sub-contracted to local sub-contractors with the necessary skills and equipment, for economic reasons. This kind of sub-contract is most likely to make use of unskilled labour (of up to 25 people at a time) and needs to be aware of and implement the locals first policy effectively. Highly specialised electrical sub-contractors may be employed at the sub-station work packages. Such employees will be small teams of (five or less) highly skilled professionals that are permanently employed or secured via long-term preferential contracts by the specialist sub-contractor. The main body of employees of the main contractor (approx. 100 people) will be permanent employees. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 4 Migrant workers: It is not likely that international migrant work will take place on the project. International workers on the project can only be highly skilled and not in demand on a permanent basis in Namibia. The risk of national migration due to unskilled work opportunities is always prevalent, unless it is managed by a locals first employment policy on the contract, which will eliminate work opportunities attracting migrants from other Namibian regions. Construction camps and work force accommodation: There will be two base camps and approximately eight satellite camps distributed over the area. The based camps will store most of the materials and will be the administrative centres for the construction project. It is anticipated that there will be approximately 30 workers per satellite camp, however it is not anticipated that these camps will be all occupied at one given time. Guidelines for camp establishment and workforce accommodation is included in the ESMP. 3 ASSESSMENT OF KEY POTENTIAL LABOUR RISKS PROJECT ACTIVITIES The construction of a 400kV transmission line consist of: • Vegetation clearance of 12m wide under the line and 70m by 50m at each tower • Concrete pylon foundations, with concrete mixing on or near the pylon sites. • V type Cross rope suspension steel pylon (guyed V-Structure) with a height 40m and span of up to 500m between pylons. • Self-supporting suspension steel pylons for bends up to 30˚ and strain pylons for bends up to 60˚. • Pylons materials are transported to site and then assembled on site. • Stringing of the line and • Infrastructure to connect to the existing Auas and Kokerboom substations. • Base and satellite camp operations and support activities. DESCRIPTION A general potential risk on construction projects is the exploitation of the workforce lacking the protection of their rights. Not giving attention to these matters on a project may lead to compromised relations, worker dissatisfaction, and unresolved grievances. By applying the Namibian Labour Act (11/2007), Regulations relating to the Health and Safety of employees at work (1992), combined with specific provisions of the World Bank ESS 2 and its Guidance Notes and World Bank as well as World Bank EHS Guidelines, in the construction contracts, and managing the contracts to ensure compliance, these risks are reduced to a low significance. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 5 RISKS The following specific risks with regard to labour can be distinguished: • Health and safety risks, particularly exposure to heat and cold conditions, working near construction equipment, working at heights, and working near live wires. The requirements of the ESMP, which comply with ESS 2 and its Guidance Notes and World Bank as well as World Bank EHS Guidelines will limit these risks to low significance. • Potential incidents of child labour or forced labour. Worst forms of child labour in Namibia occur in the agricultural, fishing and services (domestic work and street work, including begging as well as food service, including selling fruits, phone vouchers, and small goods) sectors. Child labor on this project, where most project activity is remote from general population centres and where a formal contractor is expected to comply with Government Regulations, is not expected to be a significant risk. Regular monitoring should be done on the project to check that all workers are 18 years of age or above. Legal requirements in this regard are provided in this Labour Management Procedures (LMP). • Likely presence of migrants or seasonal workers. The project has a duration of 36 months, therefore a seasonal workforce is a low risk. However, a limited amount of migrant workers (workers employed for a limited period) could be employed by the contractor if not managed. Therefore, a locals first employment policy, involving the regional councils, for unskilled labour on contractor and sub-contractor level should be enforced through the contract. • Risks of labour influx. Labour influx is expected to be limited, since people in search of job opportunities will normally move to large cities or to projects where the prospect of a job is considered good, unlike this project, which employs a low number of people and has a short duration. The proposed locals first employment policy, involving the regional councils, for unskilled labour on contractor and sub-contractor level will further limit the risk to low. • Risks of gender-based violence. Gender based violence is a risk in any situation in Namibia where both males and females will be working together for a period, especially when male and female labourers are accommodated for prolonged periods of time. Since expected employment figures are low, this risk is similarly low. Mitigation recommended include employing labourers from the local area where the work is conducted, divulging workers’ rights to them and ensuring an accessible a grievance mechanism on the project. These are including in the LMP. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 6 MITIGATION The Namibian Labor, and Health and Safety Regulations (1997) should be applied, combined with the World Bank Standards (ESS 2: Labour and Working Conditions), and World Bank EHS Guidelines which aim: • To promote safety and health at work. • To promote the fair treatment, non-discrimination and equal opportunity of project workers. • To protect project workers, including vulnerable workers such as women, persons with disabilities, children of working age, including those directly employed and contracted workers. • To prevent the use of all forms of forced labor and child labor. • To support the principles of freedom of association and collective bargaining of project workers in a manner consistent with national law. • To provide project workers with accessible means to raise workplace concerns. This is achieved through the requirement of an appropriate grievance mechanism put in place for the workforce, which is operational and accessible. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 7 4 LEGAL FRAMEWORK ADDRESSING LABOUR TERMS AND CONDITIONS Table 1: Labour related terms and conditions Legal Instrument Purpose and functions Actions on project Labour Act 11 of 2007 Details requirements regarding minimum NamPower should wage and working conditions (S39-47). ensure that all Fundamental Rights and Protections; contractors involved Prohibition and restrictions of child labour; in the construction of Prohibition of forced labour; Prohibition of the services discrimination and sexual harassment in infrastructure for this employment; Freedom of Association project comply with the provisions of these Chapter 3: Basic Conditions of employment legal instruments or Remuneration; Hours of Work; Leave; reported for relevant Accommodation; Termination of employment contraventions if it Chapter 4: Health, safety, and welfare of persists. employees Rights and duties of employers and employees; Health and Safety Representatives and Committees Chapter 5: Unfair labour practices Unfair disciplinary action; Employee and Trade Union unfair labour practices; Employer and Employers organization unfair labour practices Convention on the Rights The ILO Conventions cover a wide area of Project specifications of the Child, African social and labour issues including basic human need to reflect these Charter on the Rights rights, minimum wages, industrial relations, principles concerning and Welfare of the Child, employment policy, social dialogue, social labour, child and International Labour security and other issues. ILO Conventions womens’ rights in the Organisation (ILO), concerning gender-specific issues have a long workplace. Protocol to the history. The other conventions listed deal with Convention against protection against child labour, trafficking, Transnational Organised protection of rights of the vulnerable. Crime to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 8 World Bank Specifically ESS 2 (2016) and the relevant Environmental and Guidance Notes (2018) Social Framework To protect and conserve biodiversity and habitats. To apply the mitigation hierarchy and the precautionary approach in the design and implementation of projects that could have an impact on biodiversity. To promote the sustainable management of living natural resources. To support livelihoods of local communities, including Indigenous Peoples, and inclusive economic development, through the adoption of practices that integrate conservation needs and development priorities. Managing the risks of adverse impacts on Word Bank Group - communities temporary induced labour Good Practice Notes influx. The impact is expected to be low and can be managed through ESMP requirements. Addressing Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) in Investment Project Financing involving Major Civil Works. The risk of SEA/SH is limited, but the impact if realised is high. The ESMP provides for deliberate avoidance measures during construction and include guards against gender violence. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 9 5 LEGAL FRAMEWORK ADDRESSING OCCUPATIONAL HEALTH AND SAFETY Table 2: Occupational Health and safety terms and conditions Legal Instrument Purpose and functions Actions on project Health and Safety Rights and Duties of Employers with regard to NamPower should Regulations GN 156/1997 employees' health & safety; Welfare and ensure that all (GG 1617) as part of the facilities at workplaces; Safety of Machinery; contractors involved Labour Act 11 of 2007 Hazardous Substances; Physical Hazards and in the construction of general provisions; Medical Examinations and the services Emergency Arrangements; Construction infrastructure for this Safety; Electrical Safety project comply with the provisions of these legal instruments or reported for relevant contraventions if it persists. Convention on the Rights The ILO Conventions cover a wide area of Project specifications of the Child, African social and labour issues including basic human need to reflect these Charter on the Rights rights, minimum wages, industrial relations, principles concerning and Welfare of the Child, employment policy, social dialogue, social labour, child and International Labour security and other issues. ILO Conventions womens’ rights in the Organisation (ILO), concerning gender-specific issues have a long workplace. Protocol to the history. The other conventions listed deal with Convention against protection against child labour, trafficking, Transnational Organised protection of rights of the vulnerable. Crime to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children. World Bank Group - General Health and Safety Guidelines that is to Best practice should Environmental, Health be read in conjunction with Namibian guide all project and Safety Guidelines. - legislation and policies. Practical best practice activities to assure General / for Electric should lead the decision making as to the safety of workers and Power Transmission and standard followed. public. The World Distribution. Bank Group guidelines Also relevant to • Electric and magnetic fields once are to be integrated operational. where it exceeds the • Hazardous materials. minimum Namibian • Working at height on poles and structures. regulations required. • Live power lines once operational. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 10 Word Bank Group - Managing the risks of adverse impacts on Project specifications Good Practice Notes communities temporary induced labour influx. need to reflect these The impact is expected to be low and can be principles concerning managed through ESMP requirements. labour influx prevention as well as Addressing Sexual Exploitation and Abuse and sexual exploitation, Sexual Harassment (SEA/SH) in Investment abuse, or harassment Project Financing involving Major Civil Works. of both employees as The risk of SEA/SH is limited, but the impact if well as the general realised is high. The ESMP provides for public. deliberate avoidance measures during construction and include guards against gender violence. 6 RESPONSIBLE STAFF NamPower will take ultimate accountability for the labour processes and compliance on the project through the position of the Project Manager. Staff positions for the project are indicated in Figure 2 below. NP Project Manager NP Manager: NP Contractor NP Safety Site District Health & Supervisor Supervisor Environment (SHE) Contractor Environmental Control NP Officer Environmental (CECO) Control Officer (ECO) Contractor employees Landowners, community, and other stakeholders Figure 2: Project reporting structure affecting Labour Management ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 11 The NamPower Manager: Health and Safety will provide the necessary support to the Project Manager, through the ECO, to enforce compliance of the Contractor, who will be responsible for all labour requirements according to National and World Bank standards (Figure 2). The Contractor shall comply with the environmental and social specifications and requirements as described in the Labour Management Procedures on an ongoing basis. The Contractor shall include the necessary training and awareness raising as a constant process on site, including to new staff. All personnel or sub-contractors required to implement the project will be appointed, managed and supervised by the Main Contractor. The Main Contractor will be responsible for implementing all required labour as well as health and safety practices of the Labour Management Procedures and ESMP. The Main Contractor will appoint a CECO and Labour Manager or team satisfactory implement the requirements of the Labour Management Procedures and ESMP. 7 POLICIES AND PROCEDURES The Namibian Labor, and Health and Safety Regulations (1997) should be applied, combined with the World Bank Standards (ESS 2: Labour and Working Conditions), and World Bank EHS Guidelines which aim: • To promote safety and health at work . • To promote the fair treatment, non-discrimination and equal opportunity of project workers . • To protect project workers, including vulnerable workers such as women, persons with disabilities, children of working age, including those directly employed and contracted workers. • To prevent the use of all forms of forced labour and child labour . • To support the principles of freedom of association and collective bargaining of project workers in a manner consistent with national law. • To provide project workers with accessible means to raise workplace concerns. This is achieved through the requirement of an appropriate grievance mechanism put in place for the workforce, which is operational and accessible. The project risk assessment (Section 3) identified the risk of migrants or seasonal workers and labour influx (albeit limited) and the risk of gender-based violence as requiring specific action through policies and procedures. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 12 Migrants, seasonal workers and labour influx policy. Implement a locals first employment policy as per the ESMP as follows: • Require that the Contractor and it’s sub-contractors work through the regional and local councils to request potential workers to be identified. • The contractor / sub-contractors to list a set of positions and number of people required to be filled with locals. • The Local and Regional Councils use the list to identify specific locals to be offered the positions. The contractor / sub-contractors may set specific skills required by which each candidate will be considered. Unskilled labour positions will only have physical ability to complete the tasks as a criteria. • The contractor / sub-contractors will keep records of personnel solicited from local communities. • The contractor / sub-contractors will keep records proving that personnel not from the local communities are permanent employees of the company before the project start, or require skills that cannot be solicited from the local communities. Gender-based violence and exploitation prevention policy. • Contractor / sub-contractors apply the locals first employment policy. • Contractor / sub-contractors to provide sufficiently separated sleeping and ablution facilities for each gender group employed. • Contractor / sub-contractors to assure all workers agree in writing to and adhere to the Workers Code of Conduct prescribed in Section 8. Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) should be specifically addressed and the criminal consequences of the contravention emphasised. • Access to the Labour Grievance Mechanism should be possible privately and in person, or confidentially via relevant shop stewards with each project team, either electronically or by means of a physical copy. 8 AGE OF EMPLOYMENT The minimum age of a labourer according to the Namibian Labour Act No 11 section 42 is 15 years, for any form of industrial work including transmission of electricity. In the case of the project, ESS 2 sections 18 and 19 require that children under the age of 18 may not work on a World Bank funded project unless: • The work is not likely to be dangerous or harmful to the child’s health or development, ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 13 • Interfere with the child’s education • And a risk assessment is done prior to construction. Given these conditions it is justified to set the minimum age of any project employee at 18 years or older. 9 TERMS AND CONDITIONS The Contractor is required to fulfil the conditions of the Labour Act, its Health and Safety Regulations, as well as all relevant requirements and best practices of the ESMP and World Bank Guidelines mentioned in Sections 3 and 4 including: • If the contractor deems to continue work after the usual working hours, in the evenings and at night or over weekends, they must obtain the NamPower’s (Project Manager) and landowner’s permission before proceeding with such work. • The official locals first employment policy, involving the regional councils, for unskilled labour on contractor and sub-contractor level. • The locations of the worker camps and laydown areas should be identified in consultation with the relevant local authorities and land owners. Agreement should be given by the landowner and all neighbouring landowners in writing. • Workers Code of Conduct to comprehensively cover, but not be limited to the areas of o respecting local residents, their livelyhood activities and privacy, right to property, o Gender Based Violence, SEA and Sexually Transmitted Disease, including relevant disciplinary measures, penalties and provisions for prosecution, (Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) should be specifically addressed and the criminal consequences of the contravention emphasised.) o prohibition of poaching, hunting and any other damage to biodiversity, flora and fauna, specifically in the designated “no go” areas. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 14 10 GRIEVANCE MECHANISM The project requires an accessible and separate Labour Grievance Mechanism. The instrument is attached in Appendix A. Access to the Labour Grievance Mechanism should be possible privately and in person, or confidentially via relevant shop stewards with each project team, either electronically or by means of a physical copy. 11 CONTRACTOR MANAGEMENT For the Contractor, any sub-contractor or service provider to qualify to be appointed for the contract or any sub-section of the contract, the following documentation or proofs must be provided: • Records of registration according to the Labour Act No 11 and records of previous official contraventions. • Relevant business registration and licences required in Namibia. • In-company labour management policies, systems, and procedures documentation. • Records of qualified or certified labour, health, and safety personnel. • Records of relevant safety training and certification. • Accident / fatality and safety violation / response records including official notifications. • Legally required worker benefits records and payroll records including hours worked and proof of payment received • Required Labour Act safety committees, members and minutes of meetings. • Indication of previous work reflecting ESS 2 conditions. NamPower will include these requirements in its tender documents as a pre- qualifying condition. NamPower will enforce the continued implementation and compliance to the requirements as a pre-requisite for fulfilment of contractual duty for both the main contractor and sub-contractors. Control methods can include proof of: • Sample proofs of employment contracts or arrangements. • Records relating to o grievances received and their resolution, o safety inspections and incident records, ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 15 o Safety, Health and Environmental training and certification records, o Any government or third-party reviews of non-compliance with the labour laws and regulations. Worker grievance should follow the procedure in place under Section 9 of the Labour Management Procedures. 12 COMMUNITY WORKERS No community worker will be used on the project if not formally employed by the contractor. Any member of the local community to be employed must be solicited through the official locals first employment policy, involving the regional councils. 13 PRIMARY SUPPLY WORKERS Given conditions set in Section 7 it is justified to set the minimum age of any project employee at 18 years or older. The contractor / sub-contractor will provide proof of the age of all employees by means of a record of a valid Identity document. Forced labour is a criminal offence in Namibia. Any incident or complaint will be treated confidentially through the Worker Grievance Mechanism and reported to the Namibian police for investigation. ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures December 2023 APPENDIX A ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures November 2023 ESMP 400kV Transmission line Auas to Kokerboom Labour Management Procedures November 2023 This page is left blank intentionally Introduction and Background Grievances Resolution Procedures Aggrieved project workers may submit written grievances to the Project Director/Manager by NamPower undertakes to foster a email or letter for registration, evaluation, constructive working environment for projects investigation, and resolution. The project team and commits to ensuring that the views and will adopt 1. Receive, Register and procedures as illustrated in Figure 3 to rights of both NamPower and its internal and acknowledge the grievance amicably resolve logged grievances. external project stakeholders are collectively respected. The Grievance Resolution 2. Evaluate and investigate Procedures have therefore been instituted to: Grievance Form afford all project workers the opportunity to unmaliciously lodge individual or group 3. Grievance considered Yes grievances with the Project Director/Manager Please submit your grievance valid? Noto the project team in writing (email or letter); without prejudice to by completing the Grievance Form. contracts/interests/roles, and ensure a fair, consistent, and diligent worker resolution grievances 4. system. Develop the resolution Recourse or appeal Reject grievance or refer to with the complainant an appropriate channel However in instances of fraud or any impropriety conduct by a NamPower staff member relating to 7. Feedback & project(s), please be advised 5. Implement that NamPower has6.aMonitor,close the solution document, and Improve confidential fraud hotline toll free number: 0800 66 999 or E-mail address: nampower@tip- offs.com or Website address: Figure 3: www.tip-offs.com. Stakeholder Grievance Resolution Procedure Flowchart GRIEVANCE FORM (Please forward your completed form to the Project Manager) 1. Case No.: ___________________________________________________________ 2. First Name and ___________________________________________________________ Surname: I request that my personal / company details not be disclosed. I consent that my personal / company details may be disclosed. 3. Contact details: By Post (Please enter the correspondence address): (Please indicate the _____________________________________________________ preferred method of _____________________________________________________ communication: by post, email, or phone) By phone: _____________________________________________ By E-mail: _____________________________________________ Subject: _______________________________________________ Auas-Kokerboom 400kV Transmission Line Transmission Capital Projects 1 2 4. Grievance ________________________________________________ Description: Date: ________________________________________________ (Please indicate the subject of the grievance; Location: ________________________________________________ date of occurrence, Persons involved: __________________________________________ location relating to the __________________________________________ grievance, persons involved in the grievance __________________________________________ and effects of the ensuing Effects of the ensuing situation: situation) ___________________________________________________________ ___________________________________________________________ 5. Date of incident / One-time incident/grievance (Date): _________________ occurrence of the subject of the Happened often (Indicate how many times): grievance _________________ /emergence of the case: Ongoing (A currently existing problem). Recommendations (Please propose measures that would provide solutions to the problem): _______________________________________________________________________________________________________ ___________________________________________________________________________________ Signature: ___________________________________ Date: __________________ Please forward this form to (Name & Surname): ___________________________________________ Postal Address: _____________________________________________________________________ Email: _______________________________________ Phone Number: ___________________ Auas-Kokerboom 400kV Transmission Line 2 Transmission Capital Projects Corporate Communication and Marketing + 264 (61) 205 4111 register@nampower.com.na Mr. Martin van der Merwe (Project Manager) Senior Engineer: Transmission Capital Projects Tel: +264 61 205 2724 Fred.Bailey@nampower.com.na NamPower Centre, 15 Luther Street, PO Box 2864, Windhoek, Namibia, www.nampower.com.na Auas-Kokerboom 400kV Transmission Line 3 Transmission Capital Projects