Environmental and Social Scoping Report and ESMP NamPower Battery Energy Storage System (BESS) Environmental and Social Scoping Report and ESMP 254M45AXZDHF-1404536467-161 1BESS - NamPower Contact Fichtner GmbH & Co. KG Sarweystrasse 3 70191 Stuttgart Germany www.fichtner.de Christina Mansfeld +27 (72) 449 0353 mansfeldc@fis.fichtnergroup.com Fichtner GmbH & Co. KG 254M45AXZDHF-1404536467-161 2 BESS - NamPower Document approval Name Signature Position Date Prepared by: Christina Mansfeld Senior E&S Consultant 30.11.2023 Checked by: Banu Özcan Senior Consultant 01.12.2023 Document revision record Rev. Date Details of revision Fichtner Doc Ref. Prepared by Checked by 0 01.12.2023 New Report C Mansfeld B Özcan 1 02.19.2024 1st Revision C Mansfeld B Özcan 2 10.09.2024 2nd Revision C Mansfeld 3 Disclaimer The content of this document is intended for the exclusive use of Fichtner’s client and other contractually agreed recipients. It may only be made available in whole or in part to third parties with the client’s consent and on a non-reliance basis. Fichtner is not liable to third parties for the completeness and accuracy of the information provided therein. ----------------------------------------------------------------------------------- 254M45AXZDHF-1404536467-161 3 BESS - NamPower Table of Contents 1 Introduction .................................................................................................................................................................... 11 1.1 Background of the project ........................................................................................................................... 11 1.2 Objectives and Methodology of the Scoping Study ......................................................................... 11 2 Legal and Policy Requirements ............................................................................................................................... 12 2.1 National Laws, Regulations, Plans and Policies ................................................................................... 12 2.1.1 The Constitution of the Republic of Namibia (1990) and amendments (1998, 2010 and 2014) ..................................................................................................................................................................... 12 2.1.2 Environmental Management Act (Act No. 7 of 2007) ....................................................................... 13 2.1.3 Legislation........................................................................................................................................................... 13 2.1.4 The Green Plan and Vision 2030................................................................................................................ 17 2.1.5 Policies ................................................................................................................................................................. 17 2.2 International Conventions, Guidelines and Standards ...................................................................... 19 2.2.1 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (1992)....................................................................................................................................... 19 2.2.2 United Nations Framework Convention on Climate Change (1992) ........................................... 19 2.2.3 Convention on Biological Diversity .......................................................................................................... 20 2.2.4 Ramsar Convention ......................................................................................................................................... 20 2.2.5 World Heritage Convention ........................................................................................................................ 20 2.2.6 ILO Conventions ............................................................................................................................................... 21 2.2.7 World Bank Environmental and Social Framework ............................................................................ 22 3 Project Description ....................................................................................................................................................... 25 3.1 Location of the Project Site ......................................................................................................................... 25 3.2 Technical description ..................................................................................................................................... 26 3.2.1 BESS terminology ............................................................................................................................................ 28 3.2.2 Technology recommendations .................................................................................................................. 30 3.2.3 Equipment .......................................................................................................................................................... 31 3.2.4 BESS technical specifications ...................................................................................................................... 34 3.3 Project Stages ................................................................................................................................................... 35 3.3.1 Pre-construction............................................................................................................................................... 35 3.3.2 Construction ...................................................................................................................................................... 36 254M45AXZDHF-1404536467-161 4 BESS - NamPower 3.3.3 Operation ............................................................................................................................................................ 37 3.3.4 Decommissioning ............................................................................................................................................ 40 3.3.5 Disposal and recycling of batteries .......................................................................................................... 40 4 Methodology for assessment of the significance of impacts ..................................................................... 42 4.1.1 Step 1: Distinguish positive and negative impacts. .............................................................................. 44 4.1.2 Step 2: Dismiss non-significant impacts. ................................................................................................. 44 4.1.3 Step 3: Multi-criteria analysis for significant impacts pre- and post-mitigation ....................... 44 5 Analysis of Project Alternatives ............................................................................................................................... 49 5.1 Location selection ............................................................................................................................................ 49 5.2 Analysis of technologies and design ....................................................................................................... 49 5.3 ´´Without project´´ situation ........................................................................................................................ 50 6 Description of the Existing Environment ............................................................................................................. 51 6.1 Physical Environment ..................................................................................................................................... 51 6.1.1 Topography, Geology and Soils ................................................................................................................. 52 6.1.2 Groundwater ...................................................................................................................................................... 53 6.1.3 Surface Water .................................................................................................................................................... 54 6.1.4 Climate ................................................................................................................................................................. 55 6.1.5 Ambient air quality .......................................................................................................................................... 56 6.1.6 Ambient noise ................................................................................................................................................... 56 6.2 Biological environment ................................................................................................................................. 57 6.2.1 Biodiversity ......................................................................................................................................................... 57 6.2.2 Flora ...................................................................................................................................................................... 58 6.2.3 Fauna .................................................................................................................................................................... 60 6.2.4 Protected and Conservation Areas ........................................................................................................... 61 6.3 Human environment ...................................................................................................................................... 62 6.3.1 People .................................................................................................................................................................. 62 6.3.2 Tourism ................................................................................................................................................................ 63 6.3.3 Cultural, religious, and historical sites ..................................................................................................... 63 7 Assessment of Impacts and Mitigation Framework ........................................................................................ 65 7.1 Impacts and Mitigation Measures during Design, Construction and Operational Phase .. 65 254M45AXZDHF-1404536467-161 5 BESS - NamPower 7.1.1 Impacts on the Physical Environment ..................................................................................................... 65 7.1.2 Impacts on the Biological Environment .................................................................................................. 74 7.1.3 Impacts on the Human Environment ....................................................................................................... 79 7.1.4 Impacts and Mitigation Measures during Decommissioning ........................................................ 86 7.2 Summary of the impacts’ significance ..................................................................................................... 89 8 Consultation and Public Participation .................................................................................................................. 90 8.1 Identification of interested and affected parties. ................................................................................ 90 8.2 Steps in the Consultation Process ............................................................................................................. 91 8.2.1 Background Information Document ........................................................................................................ 92 8.2.2 Notification letters........................................................................................................................................... 92 8.2.3 Press and site notice ....................................................................................................................................... 92 8.2.4 Stakeholder database .................................................................................................................................... 92 8.2.5 Public consultation .......................................................................................................................................... 92 8.2.6 Public disclosure of ES Scoping Report .................................................................................................. 93 8.2.7 Comments received from stakeholders .................................................................................................. 93 9 Environmental and Social Management Plan .................................................................................................... 94 9.1 Institutional Requirements ........................................................................................................................... 94 9.2 ESMP ..................................................................................................................................................................... 95 10 Cost Estimate of ESMP implementation ............................................................................................................116 11 Conclusions and Recommendations ...................................................................................................................117 12 Reference List ...............................................................................................................................................................118 254M45AXZDHF-1404536467-161 6 BESS - NamPower List of Figures Figure 3-1 Location of Lithops SS (Source: Google Earth. 2023 CNES/Airbus) ........................................ 25 Figure 3-2: Arial view of Lithops SS (Source: NamPower) ................................................................................... 26 Figure 3-3: Access Road to Lithops Substation ....................................................................................................... 26 Figure 3-4: Schematic of electro-chemical accumulators.................................................................................... 27 Figure 3-5: Typical containerized BESS Source: Kokam .................................................................................... 28 Figure 3-6: Efficiencies of BESS main equipment.................................................................................................... 28 Figure 3-7: Visual explanation of BESS terminologies .......................................................................................... 30 Figure 3-8: BESS installed in the US by year and battery chemistry. .............................................................. 31 Figure 3-9: 2.7 MWh battery system in 40’ (12.2 m) container. Image: Sungrow / Samsung SDI ...... 32 Figure 3-10: WSTech APS series; Image I WSTech .................................................................................................... 33 Figure 3-11: SMA Sunny Central Storage PCS; ImaI(c) SMA ................................................................................. 33 Figure 3-12: GPTech WD3 Central PCS; Ige (c) GPTechs ....................................................................................... 34 Figure 3-13: Degradation of BESS with typical LFP technology of a 2023 model ........................................ 35 Figure 3-14 Estimated footprint and layout of 5 MVA / 10 MWh BESS units. ............................................ 36 Figure 3-15: BESS Layout at Lithops ............................................................................................................................... 37 Figure 5-1: Location of Erongo Region (Source: World Atlas) ......................................................................... 51 Figure 5-2: Lithops BESS location in the Erongo Region ..................................................................................... 52 Figure 5-3: Picture taken 28th October of the proposed site. ............................................................................ 58 Figure 5-4: Flowering wild aloe (aloe asperifolia) only plants located on site. ........................................... 59 Figure 5-5: Dorob National Park in relation to neighbouring protected areas and communal conservancies. ................................................................................................................................................ 61 Figure 6-1: Fichtner’s methodology for assessment of the significance of impacts .. 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List of Tables Table 2-1: Overview of Namibian Legislation ......................................................................................................... 13 Table 2-2: Environmental and social standards of the World Bank and their applicability for the project ............................................................................................................................................................... 22 Table 3-1: Operation ......................................................................................................................................................... 38 Table 3-2: Predictive maintenance .............................................................................................................................. 39 Table 3-3: Preventive maintenance............................................................................................................................. 39 Table 3-4: Corrective maintenance and repair ....................................................................................................... 40 Table 5-1: Monthly Temperature Summary (Marble Ridge Weather Station Data, 2017 - 2019) ..... 55 Table 5-2: Noise Limits according to international guidelines (World Bank Group, General EHS Guideline (2007), Chapter 1.7) ................................................................................................................. 56 Table 7-1: Summary of the significance of the impacts of the project during construction ............... 89 Table 9-1: Overview of Institutional Entities............................................................................................................ 94 Table 9-2: Indicative ESMP - Mitigation and Monitoring Measures during pre-construction............ 96 Table 9-3: Indicative ESMP - Mitigation and Monitoring Measures during construction .................... 99 Table 9-3: Indicative ESMP - Mitigation and Monitoring Measures during operation ....................... 111 Table 9-4: Indicative ESMP - Mitigation and Monitoring Measures during de-commissioning ..... 114 Table 10-1: Total Estimated Costs for Environmental and Social Management & Monitoring Plan 116 254M45AXZDHF-1404536467-161 7 BESS - NamPower List of abbreviations and acronyms AC Alternating Current AFOLU Agriculture, Forestry and other Land Use BESS Battery Energy Storage System BID Background Information Document BMS Battery Management System BOP BESS Balance of Power CBD Convention on Biological Diversity CENORED Central Northern RED CFC chlorofluorocarbons CHS Community health and safety CNES Comprehensive National Energy Strategy DC Direct Current DEA Directorate of Environmental Affairs DWA Department of Water Affairs EA Environmental Assessment EAP Environmental Assessment Practitioner ECB Electricity Control Board ECC Environmental Clearance Certificate EHS Environment, Health and Safety EIA Environmental Impact Assessment EMA Environmental Management Act (Act No. 7 of 2007) EPC Engineering, Procurement, and Construction ERP Emergency Response Plan ESDD Environmental and Social Due Diligence ESF Environmental and Social Framework ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan ESMS Environmental and Social Management System ESS Environmental and Social Standards (World Bank) EU European Union FCCC Framework Convention on Climate Change FDS Fire detection system FI Financial Intermediaries FSS Fire suppression system HS Health and Safety HSE Health Safety and Environment HVAC Heating, ventilation, and air conditioning IAP Interested and affected parties ILO International Labour Organisation IMP insulated metal panels INC Intergovernmental Negotiating Committee IPP Independent Power Producer 254M45AXZDHF-1404536467-161 8 BESS - NamPower KfW Kreditanstalt für Wiederaufbau (Development Bank) LFP Lithium Iron Phosphate MAWF Ministry of Agriculture, Water and Forestry MEFT Ministry of Environment, Forestry and Tourism MFMR Ministry of Fisheries and Marine Resources MGECW Ministry of Gender Equality and Child Welfare MHSS Ministry of Health and Social Services MLR Ministry of Lands, Resettlement and Rehabilitation MLRS Ministry of Labor and Social Welfare MME Ministry of Mines and Energy MSDS Material Safety Data Sheet MV Megavolt MVA Megavolt Ampere MW Megawatt MWT Ministry of Works and Transport NBSAP National Biodiversity Strategy and Action Plan NCA Lithium Nickel Cobalt Aluminium Oxide NDC Nationally Determined Contribution NDP National Development Plan NEMWA National Environmental Waste Management Act NGO Non-governmental Organization NHC National Heritage Council NIRP National Integrated Resource Plan NMC Lithium Nickel Manganese Cobalt Oxide NORED Northern Regional Electricity Distributor NP National Park OEC Office of the Environmental Commissioner OHS Occupational Health and Safety OSHA Occupational Safety and Health Administration PCS Power Conversion Systems PM particulate matter PPC Power Plant Controller PPE Personal Protective Equipment PPP Public Participation Process PV Photovoltaic RETF Recipient Executed Trust Fund RED Regional Electricity Distributors SAIEA Southern African Institute of Environmental Assessments SAPP Southern African Power Pool SEA Strategic Environmental Assessment SEP Stakeholder Engagement Plan SL Service Level UN United Nations UNEP United Nations Environmental Program 254M45AXZDHF-1404536467-161 9 BESS - NamPower UNESCO United Nations Educational, Scientific and Cultural Organization UNFCC United Nations Framework Convention on Climate Change US United States USD United States Dollar VAT Value Added Tax WMP Waste Management Plan 254M45AXZDHF-1404536467-161 10 BESS - NamPower 1 Introduction 1.1 Background of the project NamPower’s strategy is to augment its supply with cost-efficient renewable energy sources while at the same time maintaining high grid reliability to ensure a secure and continuous electricity supply to Namibia. Currently, a large portion of Namibia’s energy demand requirements must be imported from neighbouring countries. However, further large-scale PV, wind, biomass, and hydro as well as firm power projects are under implementation to reduce energy imports which can be, depending on the time of import, very expensive. A first BESS project is under implementation at the Omburu substation. To support the development and uptake of renewable energy plants, NamPower is exploring the feasibility of integrating additional Battery Energy Storage Systems (BESS) into the transmission network. The main goal is to identify where and how a second BESS can be implemented in the most feasible way possible. A detailed technical feasibility study was undertaken to determine the required BESS application for integration into the grid, its operating regime, sizing, technology, location, and time of implementation to suit the Namibian energy market. As part of the feasibility study an environmental and social scoping report (this report) was undertaken to assess potential environmental and social risks and impacts, and to a provide measures to avoid or mitigation impacts. 1.2 Objectives and Methodology of the Scoping Study The scoping study was carried out based on internationally accepted standards (World Bank Environmental and Social Standards, as well as General Environmental, Health and Safety (EHS) Guidelines and EHS Industry Sector Guidelines of the World Bank Group and Core Labour Standards of the International Labour Organization (ILO). The process included information gathering, the analysis of the obtained data and the production of this Report. Applicable national standards, laws and regulations were also considered. The steps undertaken for the study, include desktop review of available data, conducting site verification visits, formal engagement with key stakeholders, as well as development of this Report. For the data gathering, background information was collected and reviewed to present a description of the project and of the existing environmental and social conditions. A site visit was undertaken to the project site with the aim to provide enough baseline information about the environmental and social components of the project area, and support undertaking an identification of the main sensitivities associated with each of them. The site visit was conducted 28th October 2023 by Fichtner’s international experts. Various other stakeholders were contacted between 6th November and 10th November 2023, and again during a stakeholder meeting in Swakopmund on the 9th April 2024. The list of the contacted stakeholders and the summary of the feedback are provided in Section 8. 254M45AXZDHF-1404536467-161 11 BESS - NamPower 2 Legal and Policy Requirements The legal and policy requirements regarding assets in general and BESS in particular that are considered in this report cover the following items: ▪ Occupational health and safety ▪ Waste and Hazardous Materials ▪ Community health and safety: safety of people and assets in the vicinity of the BESS ▪ Protection of the physical, biological and socio-economic environment ▪ Power quality and reliability of the electricity supply. The Republic of Namibia has five tiers of law and several policies relevant to the proposed project and these include: ▪ The Constitution ▪ Statutory laws ▪ Common law ▪ Customary law ▪ International law. As the main source of legislation, the Namibian Constitution makes provisions for the creation and enforcement of applicable legislation. In this context and in accordance with its Constitution, Namibia has passed numerous laws intended to protect the natural environment and to mitigate against adverse environmental impacts. As financiers of the project, the World Bank requires compliance with its own Environmental and Social Standards (ESS), reflected in the Bank’s Environmental and Social Policy and a set of Environmental and Social Framework (ESF). The following sections provide a summary of the relevant Namibian legislation, international treaties to which the country is signatory/a party, the applicable World Bank ESS, and other and industry standards and guidelines applicable to the proposed BESS project. 2.1 National Laws, Regulations, Plans and Policies 2.1.1 The Constitution of the Republic of Namibia (1990) and amendments (1998, 2010 and 2014) The following articles of the Constitution are relevant for the project and this report: ▪ Article 91: defines the function of the Ombudsman. - Article 91 (c) describes the duty to investigate complaints concerning the over-utilization of living natural resources, the irrational exploitation of non-renewable resources, the degradation and destruction of ecosystem and failure to protect the beauty and character of Namibia. ▪ Article 95 (l): states that “the State shall actively promote and maintain the welfare of the people by adopting, inter alia, policies aimed at … maintenance of ecosystems, essential ecological processes and 254M45AXZDHF-1404536467-161 12 BESS - NamPower biological diversity of Namibia and utilization of natural resources on a sustainable basis for the benefit of all Namibians both present and future; in particular the Government shall provide measures against the dumping or recycling of foreign nuclear and toxic waste on Namibian Territory.” ▪ Article 100: states “that the land, water and natural resources below and above the surface of the land …shall belong to the State if they are not otherwise lawfully owned .” The constitutional recognition of environmental concerns triggered widespread legislative reform relating to the management of natural resources in Namibia. The country’s environmental protection effort is currently comprised of the Environmental Management Act (No. 7 of 2007) and its Regulations (2012). 2.1.2 Environmental Management Act (Act No. 7 of 2007) The Environmental Management Act (EMA) has three main purposes: ▪ to make sure that people consider the impact of activities on the environment carefully and in good time. ▪ to make sure that all interested or affected people have a chance to participate in environmental assessments. ▪ to make sure that the findings of environmental assessments are considered before any decisions are made about activities which might affect the environment. The EMA presents the procedures and application process to obtain an environmental clearance certificate (ECC) for a proposed activity and defines the respective roles and responsibilities. If an environmental clearance certificate is required, certain activities may first require an environmental assessment, which shall serve the following purposes: ▪ ensure that activities which may have a significant effect on the environment follow the principles of environmental management planning and development process. ▪ analyze the possible environmental impacts of activities and look at ways to decrease negative impacts and increase positive ones. ▪ make sure that the environmental effects of activities are given adequate consideration before the activities are carried out. ▪ provide an opportunity for public participation in considering the environmental impact of a project. 2.1.3 Legislation The following table provides an overview of Namibian Legislation pertaining to environmental and social sectors. Table 2-1: Overview of Namibian Legislation Title and date of Sector Primary agency Purpose document National Government of Namibian The constitutional recognition of Environmental Namibia Constitution First environmental concerns triggered Management Amendment Act widespread legislative reform relating to (Act No. 34 of the management of natural resources in 1998) Namibia. The country’s environmental 254M45AXZDHF-1404536467-161 13 BESS - NamPower Title and date of Sector Primary agency Purpose document protection effort is currently comprised of the EMA and its Regulations (2012). Environmental Ministry of Environmental The Act promotes sustainable Management Environment, Management, Act 7 management of the environment and Forestry and of 2007 the use of natural resources. Tourism It provides a process of assessment and control of activities that may have a possible significant effect on the environment. Environmental Ministry of Environmental The EIA Policy of 1995 promotes Management Environment, Assessment Policy accountability and informed decision Forestry and for Sustainable making through the requirement of EIAs Tourism Development and for listed programmes and projects. The Environmental EIA policy is currently enforced through Conservation the EMA and its Regulations (2012). (1995) Soil Ministry of The Soil Law relating to the combating and Environment, Conservation Act prevention of soil erosion, the Forestry and (Act No. 76 of conservation, improvement and manner Tourism 1969) of use of the soil and vegetation and the protection of the water sources of Namibia. Heritage Ministry of National Heritage This Act provides for, inter alia, the Environment, Act (Act No. 27 of protection and conservation of places Forestry and 2004) and objects of heritage significance. A Tourism National Heritage Council has been established to identify, conserve, manage, and protect places and objects of heritage significance. Heritage Ministry of National This Act establishes a National Environment, Monuments Act Monuments Council and provides for Forestry and (Act No. 28 of the preservation of certain property as Tourism 1969) National Monuments and the maintenance of certain burial grounds. Labour Ministry of Labour Act (Act This Act consolidates and amends the Labour, Industrial No. 11 of 2007) labour law, establishes a comprehensive Relations labour law, entrenches fundamental labour rights and protections, regulates basic employment terms and conditions, ensures the safety, health, and welfare of employees, protects employees from unfair labour practices, regulates trade union and employer organisation registrations, regulates collective labour relations, provides for systematic prevention and resolution of labour 254M45AXZDHF-1404536467-161 14 BESS - NamPower Title and date of Sector Primary agency Purpose document disputes, establishes the Labour Advisory Council, the Labour Court, the Wages Commission and the labour inspectorate, provides for the appointment of the Labour Commissioner and Deputy Labour Commissioner, and provides for incidental matters. Energy Ministry of Mines Electricity Act of Establishment of the Electricity Control and Energy 2007 Board; to provide for the requirements (The electricity and conditions for obtaining licenses for sector is regulated the provision of electricity; to provide by the Electricity for the powers and obligations of Control Board) licensees; and to provide for incidental matters.1 Water Ministry of Water Resources The Act provides for the management, Agriculture, Water Management Act, development, protection, conservation and Land Reform No. 11of 2013 and use of water resources, and established various regulatory and advisory institutions. Atmospheric Ministry of Health Atmospheric Air pollution is controlled primarily by Conditions and Social Services Pollution Prevention this Ordinance, which deals with air Ordinance, No. 11 pollution as it affects occupational of 1976 health and safety issues if these are the subject of one of the conditions of a registration certificate issued under the Ordinance. It considers air pollution from point sources, but it does not address ambient air quality. Roads Ministry of Works Road Traffic and Provides for the control of traffic on and Transport Transport Act, 22 of public roads and the regulations 1999 pertaining to road transport. Pollution MEFT and others Pollution Control The purpose of this Bill is to regulate and Waste and prevent the discharge of pollutants Management Bill to the air and water; and enable the (3rd Draft country to fulfil its international September 2003) obligations in this regard. With respect to water pollution, the draft Bill forbids any person from discharging or disposing of pollutants into any water or watercourse without a Water Pollution License, aside from the discharge of domestic waste from a 1 https://laws.parliament.na/annotated-laws-regulations/law-regulation.php?id=422 254M45AXZDHF-1404536467-161 15 BESS - NamPower Title and date of Sector Primary agency Purpose document private dwelling or the discharge of pollutants or waste to a sewer or sewage treatment works. Health and Ministry of Health Regulations These Regulations establish health and Safety and Social relating to the safety regulations for the workplace. Services health and safety of employees at work (GN 156 of 1997) Hazardous Ministry of Health Hazardous The Hazardous Substances Ordinance Waste and Social Substances 14 of 1974 provide for the control of Services Ordinance 14 of toxic substances which may result in 1974 injury, ill health, or death of human beings. Public Health Ministry of Health Public Health Act, This Act is only relevant in as much as and Social Services No. 36 of 1919, with workers must be protected from harm, subsequent especially during construction. amendments 254M45AXZDHF-1404536467-161 16 BESS - NamPower 2.1.4 The Green Plan and Vision 2030 In 1992, Namibia’s Green Plan was drafted by the newly created Ministry of Environment and Tourism (MET) (now Ministry of Environment, Forestry and Tourism (MEFT)) and presented at the United Nations Conference on Environment and Development in Rio de Janeiro. This document analysed the main environmental challenges facing Namibia and specified actions required to address them. Following on the foundation laid by the Green Plan, an effort was made to incorporate environmental and sustainable development issues and options into Namibia’s National Development Plans (NDPs), which run for a period of five years each. In addition, Vision 2030, which was formulated in 2001/02, aims to guide the country’s development plans from NDP 2 through NDP 7, while providing direction to government ministries, the private sector, non- governmental organizations (NGOs) and local authorities. The most recent NDP is NDP 5 covering the period 2017/2018 until 2021/22. NDP 5 is based on four pillars, namely Economic Progression, Social Transformation, Environmental Sustainability (climate change falls within this area) and Good Governance. Vision 2030 fully embraces the idea of sustainable development. For the first time in a National Development Plan (NDP 5), Namibia included an intermediate emissions reduction target (Greenhouse gas emissions 30% reduction against Business-as-Usual projection, by 2022). For the natural resource sector, it states: “The nation shall develop its natural capital for the benefit of its social, economic and ecological well -being by adopting strategies that: promote the sustainable, equitable and efficient use of natural resources; maximize Namibia’s comparative advantages; and reduce all inappropriate resource use practices. However, natural resources alone cannot sustain Namibia’s l ong-term development, and the nation must diversify its economy and livelihood strategies.” 2.1.5 Policies Namibia’s policies provide the framework for the applicable legislation. Whilst policies do not often carry the same legal recognition as official statutes, policies can and are used in providing support to legal interpretation. Relevant policies currently in force include: Policy Relevance The EIA Policy (1995) The Policy defines the required steps for an EIA, the required contents of an EIA report, the need for post-implementation monitoring, and the system of appeals. The purpose of the Policy is seen as: informing decision makers and promoting accountability; ensuring that options and alternatives and environmental costs and benefits are considered; striving for a high degree of public participation and involvement of all sectors; incorporating internationally accepted norms and standards; taking into account secondary and cumulative environmental impacts; promoting the user pays principle; and promoting sustainable development. 254M45AXZDHF-1404536467-161 17 BESS - NamPower Namibia’s Environmental Assessment Policy for The EIA Policy of 1995 promotes accountability Sustainable Development and Environmental and informed decision making through the Conservation (1994) requirement of EIAs for listed programmes and projects. The EIA policy is currently enforced through the EMA and its Regulations (2012). National Development Plan 5 (NDP) and Vision The Visions rationale is to provide long-term 2030 policy scenarios on the future course of development in the country at different points in time up until the target year 2030. National Renewable Energy Policy (2017); The renewable energy policy is intended to provide the necessary boost to renewable energy development in Namibia and to serve as a clear signal of the government of Namibia 's commitment to a clean energy future for its people powered by renewables and replete with economic opportunities created by the growth of the renewable sector National Energy Policy (2017) The Ministry of Mines and Energy issued the National Energy Policy aiming to ensure the security of all relevant energy supplies, to create cost-effective, affordable, reliable and equitable access to energy, to promote the efficient use of all forms of energy, and to incentivise the discovery, development and productive use of Namibia’s diverse energy resources. National Industrial Policy (2012) Namibia’s Industrial Policy is aimed at achieving Vision 2030. Since it is a policy document, it is confined to principles and broad parameters that will guide Namibia’s approach towards industrial policy over the next two decades. Policy for the Conservation of Biotic Diversity The policy is to ensure adequate protection of all and Habitat Protection (1994) species and subspecies of ecosystems and of natural life support processes. The National Climate Change Policy of Namibia The Policy seeks to outline a coherent, (2011) transparent and inclusive framework on climate risk management in accordance with Namibia’s national development agenda, and the relevant legal framework. National Integrated Resource Plan (NIRP 2016 The NIRP is a 20-year electricity sector development plan. It aims to provide an indication of Namibia’s electricity demand, how this demand could be supplied and the cost of supply. National Policy for Independent Power The national IPP policy is part of the Producers (2018) government's drive in creating a conducive environment for private sector investment and outlines the key provisions of the government's commitment to encourage private investment in Namibia’s power sector National Land Tenure Policy (2003) The policy covers all land tenure systems in urban, communal, commercial (freehold) and resettlement areas, and is intended to guide all land tenure rights in Namibia. 254M45AXZDHF-1404536467-161 18 BESS - NamPower 2.2 International Conventions, Guidelines and Standards 2.2.1 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (1992) Namibia became a signatory to the Basel Convention in 1995. The Convention establishes a global notification and consent system for the transboundary shipments of hazardous and other wastes among Parties and requires Parties to manage and dispose of waste in an environmentally sound manner. 2.2.2 United Nations Framework Convention on Climate Change (1992) The first World Climate Conference was held in 1979, followed by several more specific meetings and, in 1990, by the establishment of a UN sponsored Intergovernmental Negotiating Committee (INC), which was tasked with establishing the finer details of the Framework Convention on Climate Change (FCCC). The convention was duly completed and signed by 154 governments, including Namibia, at the Earth Summit in Rio de Janeiro in 1992. The main objective of the convention is to ‘ stabilize greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous, man-made interference with the climatic system’. It hopes to achieve this as quickly as possible, thereby allowing ecosystems time to adapt naturally to gradual climatic change. The FCCC emphasized the responsibility of developed countries in reducing and stabilizing greenhouse gas emissions to 1990 levels by 1995. They are furthermore expected to transfer technology to developing countries so as to enable the latter to meet their own commitments (UN 2005). Namibia is a non-Annex I Party to the UNFCC. The country is required to provide information to the Convention on the national inventory of anthropogenic emissions (carbon dioxide, methane, nitrous oxide and precursor gases), steps taken or planned to implement the Convention and any other relevant information the country considers relevant to achieve the objectives of the Convention through national communications. Namibia has ratified the Kyoto Protocol to the UNFCC (2003) and the Paris Agreement (2016) and has been meeting its reporting obligations. According to Namibia´s Updated Nationally Determined Contribution (NDC) from 2021, the total national emissions increased by 1.7% over the years 2010-2015. The Agriculture, Forestry and other Land Use (AFOLU) sector are responsible for 80% of the total national emissions followed by Energy with 17% in 2015. The updated NDC presents a progressive shift above the 2015 pledge to reduce emissions from 89% to 91% by 2030. Namibia’s vulnerability to climate change is high, as it is the driest country in Southern Africa in terms of water resources and as much as 70% of its people depend on agriculture for their existence. The Updated NDC points out different mitigation measures such as increasing the share of renewable in electricity generation and increase energy efficiency. By harnessing solar and other forms of renewable energy, the country would be making a small but important contribution to the world’s environmental stability. 254M45AXZDHF-1404536467-161 19 BESS - NamPower 2.2.3 Convention on Biological Diversity The Convention on Biological Diversity (CBD) is the first global agreement on the conservation and sustainable use of biological diversity. Over 150 governments signed the document in 1992 at the Rio conference, and since then more than 175 countries have ratified it. Namibia is a party to the Convention on Biological Diversity since August 1997 by ratification. The responsibility for achieving the CBD’s goals rests largely with the countries themselves. Under the Convention, governments undertake to conserve and sustainably use biodiversity and are required to develop national biodiversity strategies and action plans, and to integrate these into broader national plans for environment and development. The first Namibian National Biodiversity Strategy and Action Plan (NBSAP 2001-2010) constituted a ten- year strategic plan of action for sustainable development through biodiversity conservation. In 2012, Namibia set about the process of developing its second-generation NBSAP (NBSAP2). The vision of NBSAP2 is for Namibia’s biodiversity to be healthy and resilient to threats, and for the conservation and sustainable use of biodiversity to be key drivers of poverty alleviation and equitable economic growth, particularly in rural areas. 2.2.4 Ramsar Convention The Ramsar Convention on Wetlands of International Importance Especially as Waterfowl Habitat (the Ramsar Convention) entered into force in Namibia on 23 December 1995. The Convention’s mission is “the conservation and wise use of all wetlands through local and national actions and international cooperation, as a contribution towards achieving sustainable development throughout the world”. Namibia currently has 5 sites designated as Wetlands of International Importance (Ramsar Sites). A check has to be made if the final site is close to them (Namibia | Convention on Wetlands (ramsar.org)). 2.2.5 World Heritage Convention The World Heritage Convention (Convention Concerning the Protection of the World Cultural and Natural Heritage, 1972) defines the kind of natural or cultural sites which can be considered for inscription on the World Heritage List, sets out the duties of States Parties in identifying potential sites and their role in protecting and preserving them, explains how the World Heritage Fund is to be used and managed, stipulates the obligation of States Parties to report regularly to the World Heritage Committee, and encourages States Parties to strengthen the appreciation of the public for World Heritage properties. Namibia accepted the Convention in April 2000 and has 2 properties inscribed on the World Heritage List. 8 sites are presently on the Tentative List (an inventory of those properties which each State Party intends to consider for nomination). Once the location of the project is known, the Consultant will assess its proximity to an inscribed or tentative property and whether this could affect the development of the project (Namibia - UNESCO World Heritage Convention). 254M45AXZDHF-1404536467-161 20 BESS - NamPower 2.2.6 ILO Conventions The International Labor Organization (ILO) aims to promote rights at work, encourage decent employment opportunities, enhance social protection, eliminate forced or compulsory labour and child labour and strengthen dialogue on work-related issues. Therefore, the ILO lists fundamental principles and rights at work, laid down in eleven fundamental conventions. Namibia has been a member of ILO since 1978, and has ratified and set into force 8 of the 11 ILO Fundamental Conventions, namely: ▪ C029 - Forced Labour Convention, 1930 (No. 29) ▪ C087 - Freedom of Association and Protection of the Right to Organize Convention, 1948 (No. 87) ▪ C098 - Right to Organize and Collective Bargaining Convention, 1949 (No. 98) ▪ C100 - Equal Remuneration Convention, 1951 (No. 100) ▪ C105 - Abolition of Forced Labour Convention, 1957 (No. 105) ▪ C111 - Discrimination (Employment and Occupation) Convention, 1958 (No. 111) ▪ C138 - Minimum Age Convention, 1973 (No. 138) ▪ C182 - Worst Forms of Child Labour Convention, 1999 (No. 182) The Ministry of Labour and Social Welfare administers industrial relations, employment, migration and social security as well as being responsible for labour inspection. The Directorate for Labour Services is responsible for inspections whilst the following laws cover labour matters: ▪ Labour Act No. 11 of 2007: The Act consolidates and amends the labour law, establishes one comprehensive labour law, that entrenches fundamental labour rights and protections, regulates basic employment terms and conditions, ensures the safety, health, and welfare of employees, protects employees from unfair labour practices, regulates trade union and employer organisation registrations, regulates collective labour relations, provides for systematic prevention and resolution of labour disputes, establishes the Labour Advisory Council, the Labour Court, the Wages Commission and the labour inspectorate, provides for the appointment of the Labour Commissioner and Deputy Labour Commissioner, and provides for incidental matters. ▪ Regulations relating to the health and safety of employees at work (No. 156 of 1997) The Regulations relating to the health and safety of employees at were established under the Labour Act. The regulations are aimed at ensuring the health and safety of employees at work. ▪ Public Service Act, 1995 The Act is a Namibian law that provides for the establishment, management, and efficiency of the public service. It also regulates the employment, conditions of service, discipline, retirement, and discharge of staff members in the public service, and other incidental matters. The Act establishes a Public Service Commission in accordance with the provisions of Chapter 13 of the Namibian Constitution. 254M45AXZDHF-1404536467-161 21 BESS - NamPower 2.2.7 World Bank Environmental and Social Framework The World Bank’s Environmental and Social Framework (2016) determines 10 Environmental and Social Standards (ESS) which have been designed to meet sustainable development in financing projects throughout the lifecycle. The standards, their objectives and their applicability for the project are listed as follows: Table 2-2: Environmental and social standards of the World Bank and their applicability for the project WB ESS Main topics Applicability to the project ESS1: Assessment and ESIA, ESMP (content and outlines), project For the project, an management of monitoring, stakeholder engagement Environmental & Social environmental and Assessment report, and an social risks and impacts ESMP are prepared. ESS2: Labor and Working conditions and management The project will employ working conditions. of worker relationships; Protecting the work workers for construction and force; Grievance mechanism; OHS. operation. Specifically designed to protect/manage project workers: direct, contracted, primary supply and community workers; full- time, part-time, temporary, seasonal and migrant workers ESS3: Resource Resource usage efficiency (energy, water, The project potentially could efficiency raw materials), pollution prevention and generate (noise/ waste/soil) and pollution management (waste, air pollution, chemicals, pollution. prevention hazardous materials and pesticides), and management ESS4: Community CHS (Infrastructure and equipment design The project potentially health and safety and safety, Safety of services, Traffic and impacts the health, safety, road safety, Ecosystem services, health and security of project- issues, hazardous materials, emergency affected communities during preparedness and response), security the construction phase (due personnel, safety of dams to transport etc.) ESS5: Land acquisition, Definition of eligibility criteria (not only legal NOT APPLICABLE restrictions landowners are entitled to compensation), on land use and avoidance of resettlement by project design The project will not cause involuntary alternatives, compensation and benefits, permanent or temporary resettlement community engagement, grievance involuntary resettlement, as mechanism, requirements for displaced the land belongs to persons. NamPower. Similarly, there Outline and contents of resettlement will also be no need for instruments: livelihood restoration → Resettlement Plan measures. → Resettlement Framework → Process Framework ESS6: Biodiversity Definition of modified, natural and critical The ESS is still regarded as conservation habitat (different requirements apply), relevant, however the Lithops biodiversity offsets, legally and site has been cleared of 254M45AXZDHF-1404536467-161 22 BESS - NamPower WB ESS Main topics Applicability to the project and sustainable internationally protected/recognized areas, vegetation and is largely a management invasive alien species, sustainable modified habitat therefore of living natural management of living natural resources. little to no impact is resources anticipated. ESS7: Indigenous Impact assessment specifically on NOT APPLICABLE peoples/sub-saharan IP/SSAHUTL, Free, Prior, and Informed African historically Consent (FPIC), IP/SSAHUTL Plan, underserved traditional consultation, cultural heritage, grievance local Communities management ESS8: Cultural heritage Cultural Heritage Management Plan, Chance NOT APPLICABLE finds procedure, stakeholder consultation. ESS9: Financial ESMS for FIs, stakeholder engagement NOT APPLICABLE Intermediaries The project is not financed by Financial Intermediaries (FIs) ESS10: Stakeholder Stakeholder Engagement Plan, information The project will involve engagement disclosure, meaningful consultation, stakeholders; a SEP is and Information grievance mechanism, external reporting, prepared Disclosure 2.2.7.1 General Environmental Health and Safety Guidelines of the World Bank Group The Environmental, Health, and Safety (EHS) Guidelines are technical reference documents that provide Good International Industry Practice in investment projects. The standard states that the applicability of the EHS Guidelines is tailored to the hazards and risks established for each project on the basis of the results of an environmental assessment in which site-specific variables, such as host country context, assimilative capacity of the environment, and other project factors, are taken into account. Considering the type of technology and location of the project the main areas of EHS assessment includes: ▪ Environmental assessment, e.g. waste streams, and noise. ▪ Occupational health and safety such as physical hazards, personal protective equipment, communication and training. ▪ Community health and safety, e.g. hazards for the surrounding communities. The risks and impacts of the BESS have been assessed throughout their lifecycle regarding the above-mentioned aspects. The Environmental and Social Management Plan will list the identified issues and determines appropriate management actions and monitoring procedures for mitigation. 2.2.7.2 World Bank Group Environmental Health and Safety Guidelines for the Power Sector The EHS Guidelines for Electric Power Transmission and Distribution include information relevant to power transmission between a generation facility and a substation located within an electricity grid, in 254M45AXZDHF-1404536467-161 23 BESS - NamPower addition to power distribution from a sub-station to consumers located in residential, commercial and industrial areas. This document provides impacts and mitigation measures for issues such as terrestrial habitat alteration, aquatic habitat alteration, electric and magnetic fields and hazardous materials. For the BESS the industry specific EHS guideline that is relevant is the Electric Power Transmission and Distribution (2007) Guideline. The environmental issues related to the construction, operation and decommissioning of energy projects and facilities include: ▪ Electric and magnetic fields ▪ Hazardous materials ▪ Occupational Health and Safety 254M45AXZDHF-1404536467-161 24 BESS - NamPower 3 Project Description 3.1 Location of the Project Site The project is proposed to be located at the existing Lithops substation, whose land was obtained over 10 years ago for the purpose of constructing a substation. The Lithops substation is in the Erongo region falls directly on the edge of the Dorob National Park. The substation is located adjacent to the B2 which is the main road between Swakopmund and Windhoek, at a distance of approximately 45 kilometres east from Swakopmund in the direction of Windhoek (see Figure 3-1 below). Further details relating to the physical environment can be found in section 6. Figure 3-1 Location of Lithops SS The desert around the substation has almost no vegetation and requires almost no clearing or levelling. The area selected for the installation of the BESS is therefore considered to be largely characterized by modified habitats. A modified habitat, in terms of the World Bank ESS6 is considered to be an area that may contain a large proportion of plants and/or animals species which are not native and or where human activities has substantially modified an area’s primary ecological function and species composition as in the case of the BESS location. 254M45AXZDHF-1404536467-161 25 BESS - NamPower Figure 3-2: Arial view of Lithops SS (Source: NamPower) The site can be accessed from the B2 (tarred road) turning south onto the private access mine road to Husab Mine. The mine road is a dirt road (see Figure 3-3 below) that is well constructed and graded and in excellent condition. This road provides direct access to the Lithops substation. Figure 3-3: Access Road to Lithops Substation 3.2 Technical description A Battery Energy Storage System is an electro-chemical energy storage which can charge and discharge electrical energy with a fast response time. These electro-chemical accumulators convert electricity by 254M45AXZDHF-1404536467-161 26 BESS - NamPower means of chemical reactions. There are two types of electro-chemical batteries. One has an internal storage, where the energy is stored where the reaction takes place. The other one has an external storage, where the reaction unit and electro-chemical storage are physically segregated. In addition, there is a distinction between low and high-temperature batteries. ▪ Function of Anode: Stores lithium and releases lithium–ion when discharging ▪ Function of Cathode: Stores lithium and releases lithium –ion when charging. Source: Hideninc Figure 3-4: Schematic of electro-chemical accumulators The combination of materials for electro-chemical storage is theoretically unlimited. In practice, the following batteries are commonly used, have a great potential from a technical or economic perspective and differ fundamentally in their technology: ▪ Lead-Acid (Low Temperature) ▪ Lithium (Low Temperature) ▪ Sodium-Sulphur (High Temperature) ▪ Flow Battery (External Storage). Mostly, battery storage plants are used for short-term peak power and ancillary services to increase the grid stability. With recent cost reductions, the shift of energy for several hours is becoming more feasible. The term BESS refers to the whole integrated turnkey battery system including the required auxiliaries and balance of system. A typical BESS contains the following main components: ▪ Housing: The BESS is often containerized with indoor or outdoor power conversion and transformer stations. ▪ Battery cells: The building block of any battery system, which is a single cell consisting of cathode and anode. ▪ Battery module: Multiple cells connected in series and/or parallel to form a battery module, which typically includes protection elements, module management system, cells’ state and temperature monitoring. 254M45AXZDHF-1404536467-161 27 BESS - NamPower ▪ Battery rack: Multiple modules stacked together, usually connected in series, and stacked vertically. Racks are the BESS main building unit. ▪ Power Conversion System (PCS): Usually a bi-directional power electronics converter to convert between the battery DC and the grid AC in both directions for charging /discharging. ▪ Battery Management System (BMS): The controller of the battery system, which monitors and controls the batteries, usually implemented on module level, rack level, and BESS level. ▪ BESS Balance of Power (BoP): All auxiliaries required for the BESS electrical installation including cabling, transformers, protection devices, etc. ▪ BESS Balance of System (BoS): All auxiliary systems required by the BESS to function correctly and safely, including HVAC equipment, fire detection & suppression system, lighting, surveillance & alarms, etc. Figure 3-5: Typical containerized BESS Source: Kokam The following conversion losses of major equipment need to be taken into account in a BESS to determine the round-trip efficiency. In addition, auxiliary losses for I&C and HVAC systems will increase the difference between charged and discharged energy. Charge Charge DC/AC Charge Grid Battery Cells Discharge Discharge AC/DC Discharge Ƞ Transformer Ƞ AC cabling Ƞ PCS Ƞ DC cabling Ƞ cells Figure 3-6: Efficiencies of BESS main equipment 3.2.1 BESS terminology The BESS technology as a unique simultaneous generation and load asset differentiates from other generation or grid infrastructure technologies. The following terms summarize the most important energy storage terminology and definitions: 254M45AXZDHF-1404536467-161 28 BESS - NamPower ▪ Battery capacity is the nameplate energy capacity of the battery at the beginning of life. It is usually expressed in MWh or Ah. ▪ Usable battery energy capacity is the actual utilizable energy capacity of the battery expressed in MWh (at beginning of life at the point of connection). It is slightly less than the battery capacity due to conversion and transmission losses. ▪ BESS maximum charge/discharge power is the maximum power that can be supplied or absorbed by the BESS. This value can differ between the charge and discharge and is typically expressed in MW. ▪ C-rate is the ratio between the maximum power of BESS or battery to the battery capacity. ▪ Storage-hours is the inverse of C-rate, expressed in hours. ▪ State of Discharge (SoC) is the ratio of actual energy stored in the battery to the total battery capacity, which is typically expressed in % (e.g. 100% SoC means fully charged battery). ▪ State of health (SoH) is a complex indicator of the health state of the battery that indicates if the battery needs maintenance or replacement. ▪ Depth of Discharge (DoD) is the inverse of SoC, which is the ratio of the total battery capacity to the actual energy stored. It is typically expressed in % (e.g. 100% DoD means fully discharged battery). ▪ Maximum Depth of Discharge is a set-point of the BESS BMS to determine the maximum allowable depth of discharge that the battery in this system can reach. This is important for the protection of excess degradation of the battery and usually a manufacturer recommendation. ▪ Cycle: The complete charge and discharge of the BESS. One cycle is measured by the discharged energy of the currently available useable battery energy capacity at the point of connection. ▪ End of Life (EoL) is the point where the battery needs to be replaced and is considered as having reached its end of life. It is typically a manufacturer given figure and expressed with % of initial nameplate capacity (typically EoL is at 70-80% of initial battery capacity for Li-ion batteries). ▪ Lifetime cycles is the number of full cycles a battery can perform before reaching EoL. The value is typically between 4,000-6,000 for mainstream Li-ion commercial technologies. However, flagship Li- ion battery technology may reach more than 10,000 cycles. ▪ Capacity degradation: The cells degrade by various factors including consumption pattern, temperature, performed cycles, etc. This value depends on the application and is usually provided by the BESS supplier. ▪ Battery aging is the % loss of battery initial capacity due to chemistry aging, typically below 3%/year for Li-ion batteries. ▪ Augmentation is the additional installation of battery modules during operation to offset battery aging. ▪ Calendric lifetime is the end of life of battery due to aging only, regardless of cycles performed, typically around 15-20 years for Li-ion Batteries. ▪ Cells round-trip efficiency is the typical cycle efficiency of the cells accounting only for the losses due to battery cells chemistry and electrodes. It is typically above 90% for Li-ion Batteries. ▪ Charging/discharging efficiency is the one-way efficiency that accounts for charging or discharging losses expressed in %. This can account for PCS and DC losses or only DC losses. ▪ BESS round-trip efficiency is the combined efficiency for a typical charge and discharge cycle. For AC coupled Li-ion BESS systems, the AC-AC round-trip efficiency is typically around 85%. ▪ BESS auxiliary demand is the power demands of the auxiliary systems in BESS including HVAC, BMS, lighting, transformer, and PCS standby losses, etc. ▪ Use cases are the potential application scenarios of the BESS in which it will try to create value for the owner. 254M45AXZDHF-1404536467-161 29 BESS - NamPower ▪ Duty cycle is an annual charge and discharge operational procedure based on the Use Cases for the BESS which is required by BESS suppliers to design the optimum suitable system and forecast the battery aging. The following schematic shall aid in understanding the different BESS terminologies for a BESS system with three differently aged and charged battery systems. DoD % Actual Capacity (SoH = 60%) [kWh] Max DoD % or Usable capacity [kWh] Actual Capacity (SoH = 85%) [kWh] DoD % Actual Capacity (SoH = 96%) [kWh] Max DoD % or Usable capacity [kWh] Max DoD % or Usable capacity [kWh] DoD = 20% DoD % DoD = 30% DoD = 60% Nominal capaciy [kWh] Nominal capaciy [kWh] Nominal capaciy [kWh] SoC % SoC % SoC % SoC = 40% SoC = 70% SoC = 80% 40 % degradation Degradation % 15 % degradation Degradation % BESS at year 1 BESS at mid-life BESS at End of Life (4% capacity degradation (15% capacity degradation (40% capacity degradation due to aging) due to aging) due to aging) Figure 3-7: Visual explanation of BESS terminologies 3.2.2 Technology recommendations While for long periods of time the lead-acid technology has been the predominant technology for battery applications, lithium-ion, sodium and redox flow technologies are today also potential solutions. When selecting the current technology for the desired application, the power-to-energy ratio is important. While lead-acid and lithium-ion technology can work with a high power-to-energy ratio, sodium and redox flow require a lower power ratio to be feasible. The table below lists some battery system technologies suitable for different power-to-energy ratios. Table 3-1: Typical power-to-energy ratios for different technologies Technology Optimum power to energy ratio in MW/MWh Lead acid: high power 3:1 Lead acid: standard 1:20 Lithium Ion: LFP type 5:1 - 1:4 (most typical: 1:1 1:2) Lithium Ion: NMC type 2:1 - 1:4 (most typical: 1:1 1:2) Lithium Ion: LTO type 10:1 - 5:1 (most typical: 1:1 1:2) Sodium sulphur 1:6 - 1:8 (most typical: 1:6) Sodium Nickel Chloride 1:2 1:4 Vanadium Redox Flow 1:4 - 1:10 (most typical: 1:6) It should be noted that the power-to-energy ratio is only one of multiple performance benchmarks relevant for the selection of a suitable battery technology. Other benchmarks include: ▪ Efficiency ▪ Calendric and cycle lifetime ▪ Material and product availability ▪ Compatibility with ambient conditions (e.g. temperature, dust, earthquake resistance). 254M45AXZDHF-1404536467-161 30 BESS - NamPower Due to their broad power-to-energy ratio range and drastic CapEx decrease, a BESS using a battery system of lithium-ion type is currently the most economical choice both for power-based use cases with high power-to-energy ratios around 1:1 and energy-based use cases with power-to-energy ratios around 1:4. This is in line with the general trend of BESS installations by technology as shown in the Figure 3-8 below. It is apparent that lithium-ion batteries currently dominate the market. BESS installed in the US by year and battery chemistry 2018 2017 Lithium-ion Lead-acid 2016 Flow Other 2015 0% 20% 40% 60% 80% 100% Figure 3-8: BESS installed in the US by year and battery chemistry. Lithium-ion accumulators are known for their high energy density, and they find application in mobile devices like phones, laptops and electric vehicles. Due to the vast range of applications, most of the research and development budget in recent years has gone into this technology. The stationary lithium storage profits from the large-scale factories deployed for the demand of electric vehicles. There is currently no other storage technology which benefits from technical improvements and cost reductions in a similar way. Within the lithium-ion technology, three major sub-technologies are available on the market. They differentiate mostly by their cathode materials: ▪ NCA: nickel cobalt aluminum oxides ▪ NMC: nickel manganese cobalt oxides ▪ LFP: iron phosphate Fichtner’s recent large-scale BESS tender experience from 2023 confirms the best value of lithium-ion, in particular the LFP technology. A potential tender for this project shall be kept open to lithium-ion cell chemistries such as NMC, NCA, LFP, etc. as well as potential upcoming sodium-ion technologies to benefit from potential market shifts. However, the LFP technology has been selected for this project. Cost parameters and technical specifications will be based on this technology, as it will be the most likely selected technology for this project. 3.2.3 Equipment A BESS using lithium-ion batteries features the following main components: ▪ Battery system with accessories ▪ Power Conversion System (PCS) for AC/DC conversion to charge and discharge the battery system. ▪ Main transformers (standard types for inverters) ▪ Main switchgear (standard types) 254M45AXZDHF-1404536467-161 31 BESS - NamPower ▪ Control system ▪ Electrical Balance of Plant (BOP) ▪ Civil Balance of Plant (BOP) ST54 80KW H-5000HV-MV 3.2.3.1 Battery system with accessories Storage System In most contemporary BESS, the battery system with accessories comes factory-made. This reduces the time and possible errors of any integration on site. Due to transport safety concerns, the battery modules may be shipped separately and mounted on site. Battery systems for large-scale BESS often come in 40’ (12.2 m) sea freight containers due to the ease of transport and handling of these units. One container typically has an energy capacity of between 2 MWh and 4 MWh. Higher energy densities of up to 9 MWh are possible, but these densities significantly increase cost, maintenance effort and result in cooling difficulties. Figure 3-9: 2.7 MWh battery system in 40’ (12.2 m) container. Image: Sungrow / Samsung SDI 3.2.3.2 Power conversion system (PCS) Power conversion systems for large-scale BESS are often adaptations of inverters from PV or wind. Central PCS of a nominal power between 2 MVA and 3 MVA are used in most applications. High-voltage (HV) and medium-voltage (MV) equipment SYSTEM FEATURES Just as in any larger electrical asset like transformer substations, wind power plants and large industrial customers, large-scale BESS contain HV and MV transformers, switchgears, cables and other accessories. These components are typically operated at lower currents, but much higher voltages, than the low- Highly integrated system including three standard 40ft containers for minimized labor voltage components. Therefore, they have a higher risk of emitting high-level electric fields at the grid High energy frequency density (usually 50 Hz). system integrated with reliable lithiumd battery Integrated with MV The countermeasures transformer against and these emissions MV include switchgear shielding in the of the affected system and suitable components arrangement of the cables. As this risk is existent in most other electrical assets, the countermeasures are Integrated local controller to enable unifie c ommunication state-of-the-art technology. Integrated HVAC and FSS to ensure system safety and maximize i system effice n cy Inverters and other low-voltage (LV)2 equipment The power conversion structure between DC and AC in a BESS is very similar to the power conversion in PV power plants and DC-coupled wind power plants. All energy that is fed into the grid from the battery CIRCUIT 2 DIAGRAM According to the IEC definition, low voltage refers to voltages up to 1000 V AC and 1500 V DC Li-battery Container 254M45AXZDHF-1404536467-161 BCP 32 BESS - NamPower PCS Container DC AC AC RACK RACK RACK RACK RACK RACK RACK Switch Contactor and charged from the grid into the battery passes through a Power Conversion System (PCS, also referred to as Inverter). This PCS is a device that uses fast switching solid-state switches to convert DC to AC and AC to DC. Common switching frequencies are in the range of 1 kHz to 4 kHz and the associated rise times of the current are in the range of 10 ns to 300 ns. These steep current rise times naturally lead to the emission of high-frequency magnetic and electromagnetic fields, which are harder to shield than the low-frequency electrical fields from the HV and MV components. These fields can be radiated from the inverter cabinet itself. They can also be transmitted through the AC low-voltage cabling up to the step-up inverter and the DC low-voltage cabling and radiated from these cables or the transformers and batteries. Figure 3-10: WSTech APS series; Image I WSTech Figure 3-11: SMA Sunny Central Storage PCS; ImaI(c) SMA 254M45AXZDHF-1404536467-161 33 BESS - NamPower Figure 3-12: GPTech WD3 Central PCS; Ige (c) GPTechs 3.2.4 BESS technical specifications The following technical specifications have been based on actual performance and guaranteed results from other recent BESS projects for the LFP lithium-ion technology to be implemented in 2024. No major further technology improvements are expected for the implementation in 2026. Currently, the trend is to increase the energy density for EV applications and reduce the costs from economy of scale. ▪ Useable Energy Capacity (State of Health) depending on utilization and typical warranty conditions of LFP cells for 2020. ▪ Round-trip efficiency of 85% (up to 87% possible in moderate climates) with load factor of 17%. This includes the auxiliary losses during operation. ▪ For the climate of 20-25 °C average annual ambient temperature, an auxiliary consumption for stand- by (no charging or discharging) will be required of 0.995%/MWh/h of installed BESS energy capacity. This means that for the given climate, a 1 MWh BESS will consume around 10 kW during stand-by. ▪ Footprint Energy Capacity: up to 5 MWh for the battery system fit in one 40-foot (12.2 m) container. ▪ Footprint Power: up to 5 MVA for the Power Converter, transformer and MV Switchgear fit in one or two outdoor stacks (8 m) container. ▪ Depth of Discharge is 100%. ▪ End of Life in the year where the State of Health drops below 60% for the first time. The lifetime and degradation are dependent on the utilization of the BESS. The utilization is measured by the amount of average annual cycles per day. The definition of cycles can sometimes vary between suppliers. For the figure below, the definition of one cycle shall be the discharge at the point of connection of the current energy capacity of the storage (i.e. if a 10 MWh BESS discharged 3,650 MWh per year). The degradation as shown in Figure 3-13 is rather significant in the first year (initial degradation). Afterwards, the degradation is almost linear with the slope depending on the number of cycles a day. Since the End-of-Life energy capacity (i.e. State of Health below 60%) is reached earlier with more cycles, the potential lifetime can be determined. While a BESS with 1 cycle or less per day can reach a lifetime of 20-23 years, two cycles per day will result in a lifetime of only 18 years. 254M45AXZDHF-1404536467-161 34 BESS - NamPower State of Health Expectations [%] 100% 90% 80% 70% 60% 50% 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Years 1 Cycle per day 2 Cycles per day Figure 3-13: Degradation of BESS with typical LFP technology of a 2023 model Augmentation of the BESS, meaning the installation of additional battery modules throughout the lifetime, would increase the State of Health and could potentially increase feasibility further. This should, however, not be used for decision-making due to uncertainties in the augmentation costs. Whether the option of augmentation will add value should be decided during operation when the actual degradation is known and the investment in additional energy capacity vs potential additional revenues can be calculated with greater certainty. It is, however, recommended to leave around 20% additional physical space for potential augmentation. Below a remaining SoH of 60%, the lithium cells should be decommissioned and recycled, as they have reached the end of life and larger cell variations could increase safety risks. 3.3 Project Stages The BESS will be constructed within the footprint of the existing land of the Lithops Substation. An ESIA was undertaken in 2011 where an optimum location for the Lithops substation was identified, based on the following reasoning: “The selection of a suitable site for the substations was made on the basis that the substations must be placed on level ground, it should be outside of sensitive environmental and tourism areas, it cannot be placed on marble because as it must be earthed, it must fit into the planning for the temporary and permanent power line routes, and must adhere to the aviation authority restriction on placing the substation outside of the critical zone of the Arandis airport. ” Metago, 2011. 3.3.1 Pre-construction During the pre-construction phase, all environmental and socioeconomic risks and impacts as identified in this report will be incorporated into the design. For the current planned BESS project in Namibia, it is assumed that parts and equipment will need to be internationally sourced. Port of entry for these parts etc. will most likely be Walvis Bay industrial port in the Erongo region, which allows for easy and reliable access to site. 254M45AXZDHF-1404536467-161 35 BESS - NamPower Li-ion batteries can generate a great amount of heat if short circuited. In addition, the chemical contents of these batteries may catch fire if damaged or if improperly designed and/or assembled. Hence, batteries and their respective components should be packed to eliminate the possibility of a short-circuit or activation while in transport. For these reasons, there are safety regulations controlling the shipment and transport of these types of batteries. Usually Li-ion batteries are regulated as hazardous materials or as dangerous goods, that may only be transported under specific hazardous materials/dangerous goods regulations. It is recommended for NamPower to source Batteries from suppliers which considers sustainability as part of their manufacturing strategy. NamPower should also include commitments to identify battery technology which considers use of materials that are considered sustainable and that their installer/ contractor will demonstrate, it has done its due diligence on the battery supply chain as was as reasonably possible. 3.3.2 Construction The BESS containers will arrive preassembled and placed their designated location on the levelled site. The BESS will require a footprint of roughly 4000m2 (or 0.4 ha) for 9 units of 5 MVA / 10 MWh to achieve a useable BESS capacity of 45 MVA / 90 MWh. The total footprint of those BESS units including PCS and transformer would be with a typical design 3000 m². An additional area of 1000 m² should be considered for the MV Switchgear station, maintenance roads and fencing. Figure 3-14 Estimated footprint and layout of 5 MVA / 10 MWh BESS units. The area in white would indicate the 16 hectares of land that is available to NamPower at Lithops Substation of which 8 hectares is unfenced and available for the placement of the BESS. Currently only the existing infrastructure is fenced as can be seen in figure 3-15. The actual placement of the BESS on the available land will be determined by the transmission connection planning which is currently ongoing. Less than 4000m2 (or 0.4 ha) will be needed for the BESS and will therefore have sufficient area within the existing Lithops SS footprint. Construction, site preparation Construction risk for large scale BESS projects is generally regarded as low and is classified as a simple building task. This is because the BESS is pre-assembled and containerized, with limited construction activities required at site. The actual works at the Lithops substation will include general civil work such as minimal land clearing, land levelling, preparation for the site office and temporary facilities, foundation work of the battery 254M45AXZDHF-1404536467-161 36 BESS - NamPower system, Power Conversion System (PCS), Medium Voltage (MV) switchgear and then the electrical cables trench works for connection to the actual substation. Construction risks will be managed in accordance with the Management Plan. Figure 3-15: BESS Layout at Lithops There are steps to reduce risks on the BESS site which must be part of the emergency preparedness plan: ▪ Locate storage systems well away from critical buildings or equipment. Each BESS container must be situated 1-3m away from the next. ▪ Exterior protection such as a passive thermal barrier and active fire protection such as drenchers must be part of the design of the BESS. ▪ Battery management systems and the electrical switch gear must not be located within the preassembled containers and must be situated between 10 –20m away from the closest container. ▪ Adequate fire doors (>FR60) must be installed as part of the preassembled containers. They must be maintained in the closed position and equipped with automatic closure mechanisms. Where insulated metal panels (IMPs) are used, these should contain a mineral wool core and be installed in accordance with the terms of their approval. Only non-combustible IMPs should be installed. ▪ Ensure proper management of cable/service penetrations. Cable penetrations should be adequately sealed to meet the fire resistance of the compartment (two-hour fire resistance rating). Heating, ventilation and air conditioning ducts must have fire dampers provided that automatically close on activation of the fire alarm. Establish a permit to access system to manage changes to service or cable penetrations under an audited system. ▪ Develop a fire protection Plan, that includes highly sensitive smoke detectors, and an inert gas and/or foam fire suppression system to control thermal runaway. 3.3.3 Operation During Operation this section lists the typical tasks that apply for large-scale BESS using lithium-ion batteries. Specific technologies and suppliers may require additional works. 254M45AXZDHF-1404536467-161 37 BESS - NamPower This section lists typical O&M tasks that apply for large-scale BESS using lithium-ion batteries. Specific technologies and suppliers may require additional works. The following terms are used. Term Meaning Battery system The DC battery system including cells, modules, DC switchgears and cabling PCS / Power The bidirectional inverter Conversion System PPC / Power Plant The central controller for the operation of the BESS power plant Controller Primary equipment Other equipment that takes part in the main power flow, e.g. transformers and medium-voltage switchgear FDS Fire detection system FSS Fire suppression system (if any) Auxiliaries Other equipment, e.g. auxiliary power, UPS, lighting BESS Battery energy storage system, i.e. the combination of all of the above The column "S" indicates whether the task is BESS-specific ("Y") or also commonly has to be carried out for other energy installations ("N"). The column "SL" indicates the service level that is usually required for the task: 1. Means general tasks that can be carried out by local personnel, e.g. technicians. 2. Means tasks that require specific education. These can be carried out by specially educated local personnel or the suppliers’ personnel. 3. Means tasks that require expert skills. Usually carried out by the supplier. Table 3-2: Operation Equipment(s) S SL Work (Operation) Interval BESS N 1 Site safety monitoring Continuously BESS N 2 Operation control and supervision including Continuously remote diagnosis (usually in a remote operations and control centre) BESS Y 2 Health and safety management (including Continuously battery-specific risks with specific skill and PPE requirements) BESS N 2 Monitoring of economic key performance Continuously indicators, e.g.: ▪ Service quality ▪ BESS availability All N 2 Switching procedures for start-up and When required shutdown 254M45AXZDHF-1404536467-161 38 BESS - NamPower Equipment(s) S SL Work (Operation) Interval All N 2 General isolation and connection procedures Maintenance, repair PCS, battery system Y 2 Isolation and connection procedures on the DC Maintenance, system repair BESS Y 2 Emergency procedures management In case of emergency BESS Y 2 Operation documentation (including Continuously verification of data log completeness required for warranty) 3.3.3.1 Maintenance Predictive maintenance Table 3-3: Predictive maintenance Equipment(s) S SL Work (Preventive Maintenance) Interval PCS, PPC, battery Y 3 Remote monitoring by supplier Continuously system BESS Y 2 Monitoring of technical key performance indicators, e.g.: ▪ Equipment availability ▪ Efficiency ▪ Auxiliary power consumption BESS N 1 Visual inspection 1 week Preventive maintenance Table 3-4: Preventive maintenance Equipment(s) S SL Work (Preventive Maintenance) Interval HVAC, PCS N 1 Air filter replacement 1 month -1 year PPC, other IT security- N 3 IT security updates and patches (usually 1 month or related equipment serviced remotely) when needed PCS, battery system Y 2 General maintenance according to 1 year manufacturer's instructions HVAC, PCS N 2 Cooling system preventive maintenance 1 year (pumps, fans, cooling liquid status, etc.) All N 2 Cleaning 1 month -1 year All N 1/2 General electrical safety testing (HiPot, AC 1 year protection functions, thermography) All Y 2 Battery system electrical safety testing 1 year (insulation resistance, protection functions, thermography) Battery system Y 2 Energy capacity test 1 year 254M45AXZDHF-1404536467-161 39 BESS - NamPower Equipment(s) S SL Work (Preventive Maintenance) Interval PCS, PPC, battery Y 3 Software and firmware updates Continuously or system 1 year PCS, battery system Y 2 Spare parts maintenance (restocking, 1 year inspection, spare battery recharging) FDS, FSS Y 3 Minor maintenance 3 months FDS, FSS Y 3 Major maintenance 1 year Auxiliaries N 1 General auxiliaries’ maintenance (inspection, UPS 1 year battery replacement, lamp replacement, etc.) Corrective maintenance and repair Table 3-5: Corrective maintenance and repair Equipment(s) S SL Work (corrective maintenance and repair) Interval BESS N 2 Fault identification After fault Battery system Y 2 Battery module and fuse replacement After fault PCS Y 3 Power stack and fuse replacement The developer, owner and operator (NamPower) should prepare a fire safety and emergency plan which will contain, but not be limited to, the ingress and egress routes to buildings, access routes for emergency vehicles, fire management and compliance with fire safety legislation. 3.3.4 Decommissioning The BESS system must be de-energised safely before any other steps can be taken. Before the transportation of the components, relevant safety prescripts must be in effect, to ensure that the BESS system and its components are safe to transport. A decommissioning plan will be prepared before any decommissioning activities begin. The plan must and clearly define which parties are responsible for decommissioning the BESS. The plan should be a living document that is updated as technologies, experience with BESS, and relevant codes and regulations evolve over the project lifecycle. This plan must be submitted to MEFT for approval prior to the decommissioning phase. The decommissioning of the BESS site itself must be done in accordance with the site specific NamPower ESMP: 3.3.5 Disposal and recycling of batteries As most batteries contain heavy metals and other toxic substances, it is not desired to dispose of them in general landfills or in the environment. The battery “blades” contain valuable rare earth metals - particularly Lithium and Cadmium that are sealed within gel structures. These are of high value when they reach the end of their working life and should be returned to the manufacturer for recycling. 254M45AXZDHF-1404536467-161 40 BESS - NamPower The major environmental risk is leakage of the battery cells when they have been disposed of improperly after the decommissioning of the BESS. This leakage may lead to soil and groundwater contamination. There are currently no regulations in Namibia which governs safe disposal of electronic waste therefore the project will adopted international best practices for the disposal of batteries. Furthermore, in an effort to reduce impacts associated with battery waste the project will prioritize procurement of batteries from suppliers with a take back policy. In the instance where batteries are disposed of without returning to the supplier, only local recycling processors that adhere to appropriate methods of disposal and recycling will be used, and under the guidance of the original equipment manufacturer and as stipulated in the WEEE plan that will be developed for the project. NamPower will ensure that the decommissioning and disposal (D&D) costs at end of life are duly considered and factored into the operational cost of the project. 254M45AXZDHF-1404536467-161 41 BESS - NamPower 4 Methodology for assessment of the significance of impacts Fichtner’s methodology for classifying the impacts of a project on the environment is based primarily on the ARVI approach (IMPERIA, 2015). ARVI is an approach for assessing the significance of the expected impacts of a proposed development project and was the key deliverable of the EU sponsored IMPERIA Project3. The ARVI approach was adapted by Fichtner’s experts based on the European Commissions’ Guidance on Scoping (EU, 2017) and Fichtner’ s long term experience with ESIAs. This resulted in a transparent, reliable and objective methodology that is depicted into the following 3 steps: ▪ Step 1: Distinguish positive and negative impacts. ▪ Step 2: Dismiss non-significant impacts. ▪ Step 3: Multi-criteria analysis for significant impacts pre- and post-mitigation A scheme of the three steps and the interactions among them is shown in Figure 4-1. An explanation is provided in the following paragraphs. 3 More on this project here: https://www.jyu.fi/science/en/bioenv/research/natural-resources-and- environment/imperia-project 254M45AXZDHF-1404536467-161 42 BESS - NamPower Figure 4-1: Fichtner’s methodology for assessment of the significance of impacts 254M45AXZDHF-1404536467-161 43 BESS - NamPower 4.1.1 Step 1: Distinguish positive and negative impacts. The methodology begins by distinguishing positive from negative impacts. Positive impacts do not require further evaluation but require the development of enhancement and respective monitoring measures were pertinent and feasible. Negative impacts shall be further evaluated in Step 2. 4.1.2 Step 2: Dismiss non-significant impacts. For those impacted components for which a threshold or a limit value is defined (in the national legislation or international guidelines), these shall be used to initially understand the degree of change in the receiving environment. If the impact of the project is foreseen as being below the threshold or limit value, then the impact can be classified as non-significant and can be dismissed from further assessment. For non-significant impacts mitigation measures are not necessary, but monitoring may be applicable. If the impact of the project is foreseen as being above the threshold or limit value, then the impact can be classified as significant and shall be subject of further assessment by using the multi-criteria analysis method (Step 3). This method is also to be used when no thresholds or limit values are available. 4.1.3 Step 3: Multi-criteria analysis for significant impacts pre- and post-mitigation At present, there is no international consensus among practitioners on a single or common approach for analysing and classifying the significant impacts. Fichtner developed an approach based on the one commonly followed in the EU that consists of evaluating significance based on the magnitude of the predicted effect and the sensitivity of the receiving environment: Magnitude vs Sensitivity = Significance The formula above is applied exclusively to negative significant impacts, i.e., to those impacts that need further assessment beyond steps 1 and 2. For all significant impacts, mitigation measures are defined to lower, eliminate or compensate for negative effects. The residual significance, i.e., the significance after specified measures are applied is then assessed by applying once more the multi-criteria analysis. 254M45AXZDHF-1404536467-161 44 BESS - NamPower Magnitude The magnitude of the negative significant impacts is evaluated based on 6 criteria, each of them being evaluated based on 2 to 4 levels: ▪ Spatial extent of the impact - local: up to 5 km (typically including site + neighbouring properties/settlements) - municipal: 5 -10 km (typically including one municipality) - regional: 10 - 100 km (typically including one region) - wide range/transboundary: > 100 km (typically including several regions and/or crossing national borders)4 ▪ Duration of the impact - short term: construction activity5 <1 year - medium term: construction activity >1 year - long term: project life (operation) - permanent: lasting (even after decommissioning) ▪ Frequency of the impact - once - irregular but less than or equal to once per year - seasonal (2 to 4 times per year) - repeatedly (more frequently than 4 times per year) ▪ Ability of the receiving environment to recover/degree to which impact can be reversed. - Ability to recover - reversible impact. - No ability to recover - irreversible impact. ▪ Probability of the impact occurring (expert assessment) - unlikely: unlikely to occur. - possible: may occur. - probable: likely to occur. - definite: will certainly occur. ▪ Intensity (can often be measured with various physical units; if not, expert assessment is used) - low - the change to environmental conditions or on people is small (or up to 5% above thresholds/standards) - medium - the project has a clearly observable negative effect on nature or environmental load (or up to 25% above thresholds/standards). A social change has an observable effect on people’s daily lives and may impact daily routines. - high - the project has a large detrimental effect on nature or environmental load (or up to 50% above thresholds/standards). A social change clearly hinders people’s daily lives. - very high - the project has an extremely harmful effect on nature or environmental load (or equal to or more than 75% above thresholds/standards). A social change substantially hinders people’s daily lives. 4 A transboundary impact is always classified as a wide range impact, even when it is expected within a range shorter than 100 km. 5 Construction activity in this context refers to specific time-limited activities leading to impacts such as excavations, levelling, blasting, etc., and not to the whole construction period. 254M45AXZDHF-1404536467-161 45 BESS - NamPower After each magnitude criteria is classified according to one of the 4 levels (or 2 levels, in case of “ability to recover”), these are evaluated by means of a scoring system, improving thereof the level of transparency and objectivity of the analysis. The result is a classification of the magnitude of each impact as low, medium, high, and very high. MAGNITUDE EXAMPLE Scoring -1: -2: -3: -4: Impact X Criteria Wide Spatial extent Local Municipal Regional Regional: -2 range/Transboundary Medium Long Permanent: - Duration Short term Permanent term term 4 Frequency Once Irregular Seasonal Repeatedly Once: -1 Ability to Reversible - - Irreversible Reversible: -1 recover Probability Unlikely Possible Probable Definite Possible: -2 Intensity Low Medium High Very high Medium: -2 Sum -14 Magnitude of the impact Medium Key: Magnitude Sum Low -6 to -9 Medium -10 to -14 High -15 to -19 Very high -20 to -24 Sensitivity The sensitivity of the receiving environment is evaluated based 3 criteria, each of them being evaluated based on 4 levels. ▪ Existing regulations and guidance - there are specific receptors6 in the impact area which have some level of protection, either by law or other regulations: - very high protection level - the impact area includes an object that is protected by national law, EU Directives, or international agreements which may prevent the proposed development. - high protection level - the impact area includes an object that is protected by national law, EU Directives, or international agreements which may impact the feasibility of the proposed development. - medium protection level - national regulation sets recommendations or reference values for an object in the impact area, or the project may impact an area conserved by a national or international program. 6 Population and human health, biodiversity, land, soil, water, air and climate, material assets, cultural heritage, and the landscape 254M45AXZDHF-1404536467-161 46 BESS - NamPower - low protection level - few or no recommendations which add to the conservation value of the impact area, and no regulation restricting use of the area (e.g., zoning plans) ▪ Value of the receptor to the society - economic values, e.g. water supply; social values, e.g. landscape or recreation; or environmental values, e.g. natural habitat: - very high - the receptor is unique, very valuable to society and possibly irreplaceable; it may be deemed internationally significant and valuable; the number of people affected is very large. - high - the receptor is unique and valuable to society; it may be deemed nationally significant and valuable; the number of people affected is large. - medium - the receptor is valuable and locally significant but not very unique; the number of people affected is moderate. - low - the receptor is of small value or uniqueness; the number of people impacted is small. ▪ Vulnerability to the changes (ability to tolerate changes; number of sensitive targets): - very high - Even a very small external change could substantially change the status of the receptor. There are many sensitive targets in the area. - high - Even a small external change could substantially change the status of the receptor. There are many sensitive targets in the area. - medium - At least moderate changes are needed to substantially change the status of the receptor. There are some sensitive targets in the area. - low - Even a large external change would not have substantial impact on the status of the receptor. There are only few or no sensitive targets in the area. After each sensitivity criteria is classified according to one of the 4 levels, these are evaluated by means of a scoring system, improving thereof the level of transparency and objectivity of the analysis. The result is a classification of the sensitivity of each impact as low, medium, high, and very high. SENSITIVITY EXAMPLE Scoring -1: -2: -3: -4: Impact X Criteria Existing Low Medium High Very high regulations and protection protection protection protection Very high: -4 guidance level level level level Value of the Low Medium High Very high High: -3 receptor Vulnerability to Low Medium High Very high Low: -1 the changes Sum -8 Sensitivity of the receptor Medium Key: Sensitivity Sum Low -3 to -5 Medium -6 to -8 High -9 to -10 Very high -11 to -12 254M45AXZDHF-1404536467-161 47 BESS - NamPower Significance The level of significance of each impact is finally assessed as low, medium, high, or very high. This is done by means of a matrix evaluating the magnitude of the impact against the sensitivity of the receiving environment. Magnitude of the impact SIGNIFICANCE Very high High Medium Low Low High Medium Low Low Sensitivity of the Medium High High Medium Low High Very high High High Medium receptor Very high Very high Very high High High 254M45AXZDHF-1404536467-161 48 BESS - NamPower 5 Analysis of Project Alternatives 5.1 Location selection This section provides a summary of the assessment for the different possibilities in terms of sites for installation of the second BESS in the Namibia electrical power system. In addition, for the different case studies, a differentiation of the technical applicability for voltage support, peak load reduction, loss reduction compared to the alternative projects and the flexibility of operation has been made. The installation of the BESS close to renewable production areas such as Rosh Pinah, Arandis and Khan could also reduce the peak load in the day or during night-time (by partially meeting the demand with the energy stored). The BESS could increase the NamPower revenue by storing energy during curtailment or low tariff periods (no wheeling charges at MV level from PV to BESS) and delivering this energy during expensive periods that typically coincide with high peak demands. Furthermore, the BESS could help to reduce energy curtailment during high energy production periods, thus energy arbitrage service shall reduce renewable energy curtailment and hence improve the revenue of the second (new) BESS. In addition, another example could be Rosh Pinah in which the solar farm surplus could be stored, and it then could also deliver to the grid. A drawback for this example is that there are no significant population or demand areas close to this energy production area. Therefore, the surplus should be rather collected at medium voltage levels in areas with a load center. Thus, the most suitable solution - for this point - is to store the energy surplus in Lithops substation at MV level from upcoming nearby PV power plants (e.g. 100 MW Arandis in 2028). Once the optimum location for a BESS was identified, placing the BESS at Lithops Substation was optimum as the site is a modified habitat which therefor significantly reduce impacts. Lithops Substation also has existing additional space for the BESS which did not require any enlarging of the existing disturbed area footprint, this reduces further environmental risks significantly. 5.2 Analysis of technologies and design In Section 3 a detail description regarding BESS technology is provided in that section technical data and information is provided as to how the technical team arrived at the decision of choices in equipment. While for long periods of time the lead-acid technology has been the predominant technology for battery applications, lithium-ion, sodium and redox flow technologies are today also potential solutions. When selecting the current technology for the desired application, the power-to-energy ratio is important. While lead-acid and lithium-ion technology can work with a high power-to-energy ratio, sodium and redox flow require a lower power ratio to be feasible. The table below lists some battery system technologies suitable for different power-to-energy ratios. Table 5-1: Typical power-to-energy ratios for different technologies Technology Optimum power to energy ratio in MW/MWh Lead acid: high power 3:1 Lead acid: standard 1:20 Lithium Ion: LFP type 5:1 - 1:4 (most typical: 1:1 1:2) 254M45AXZDHF-1404536467-161 49 BESS - NamPower Lithium Ion: NMC type 2:1 - 1:4 (most typical: 1:1 1:2) Lithium Ion: LTO type 10:1 - 5:1 (most typical: 1:1 1:2) Sodium Sulphur 1:6 - 1:8 (most typical: 1:6) Sodium Nickel Chloride 1:2 1:4 Vanadium Redox Flow 1:4 - 1:10 (most typical: 1:6) It should be noted that the power-to-energy ratio is only one of multiple performance benchmarks relevant for the selection of a suitable battery technology. Other benchmarks include: ▪ Efficiency ▪ Calendric and cycle lifetime ▪ Material and product availability ▪ Compatibility with ambient conditions (e.g. temperature, dust, earthquake resistance). Fichtner’s recent large-scale BESS tender experience from 2023 confirms the best value of lithium-ion, in particular the LFP (Lithium Iron Phosphate) technology. LFP technology offers optimum power-to- energy ration whilst also providing optimum results in efficiency, cycle lifetime, product and material availability as well as being compatible with the ambient conditions expected at Lithops Substation. In most contemporary BESS, the battery system with accessories comes factory-made. This reduces the time and possible errors of any integration on site. Due to transport safety concerns, the battery modules may be shipped separately and mounted on site. Battery systems for large-scale BESS often come in 40’ (12.2 m) sea freight containers due to the ease of transport and handling of these units. One container typically has an energy capacity of between 2 MWh and 4 MWh. Higher energy densities of up to 9 MWh are possible, but these densities significantly increase cost, maintenance effort and result in cooling difficulties. One of the biggest advantages of this technology lies in its positive environmental impact. BESS reduces the reliance on less environmentally friendly power sources, helping minimize greenhouse gas emissions and creating a more sustainable energy future. 5.3 ´´Without project´´ situation This alternative considers the option of ‘do nothing’ and maintaining the status quo. Should the proposed project not proceed, the site will remain unchanged. NamPower will not be able tp provide short-term peak power and ancillary services to increase the grid stability. Therefore, the no-go alternative is not considered to be feasible. Also, by not going ahead with the project it would result in Namibia lagging behind in meeting its Green Plan and Vision 2030 goals as well as becoming more energy dependant. 254M45AXZDHF-1404536467-161 50 BESS - NamPower 6 Description of the Existing Environment This section provides a description of the project relevant environmental and social baseline conditions at the site, i.e., the existing physical, biological and socio-economic conditions before the project’s implementation. The determination of the baseline status of the project area is essential to assess the significance of the negative and positive impacts to be eventually delivered by the project´s construction and operation. The following aspects are considered in this section: ▪ Physical Environment ▪ Biological Environment ▪ Human Environment Along with a description of the existing physical, biological and human environment in the project affected area, this chapter classifies the degree of sensitivity of the receptors to impacts according to the methodology described in Chapter 6. 6.1 Physical Environment The Erongo Region is located in the central western part of Namibia (Figure 6-1). Landmark features of its boundaries include the Atlantic Ocean in the west, the Ugab River in the north, and the Kuiseb River as part of the southern border. Much of the region is occupied by the Namib Desert which stretches parallel to the coast for the length of the country, to about 120-150 km inland. The Lithops Substation lies entirely within the central Namib of the Erongo Region (refer to Figure 6-2). Figure 6-1: Location of Erongo Region (Source: World Atlas) 254M45AXZDHF-1404536467-161 51 BESS - NamPower Figure 6-2: Lithops BESS location in the Erongo Region 6.1.1 Topography, Geology and Soils Lithops Substation is located in the desert zone of the Namibia desert. The area consists largely of sandy gravel plains dissected by ephemeral watercourses. The plains are scattered with koppies (rock outcrops or hills) and rocky ridges of varying composition, including marble ridges. The geology of the area is characterised by the Damara Supergroup and Gariep Complex geological division and falls within the Swakop Group (Mendelsohn, Jarvis, Roberts, et al., 2002). The dominant soils for the Swakop Group consist of Schists. The site’s geology is not considered to be a sensitive receptor for the project’s impacts. This is because the project’s construction and operation do not have an influence on the site’s geology. The landscape at the Substation is characterised by shallow and hardened soil profiles on an old landscape surface. This surface also exhibits very distinct crusting that is dominated by gypsum salts with 254M45AXZDHF-1404536467-161 52 BESS - NamPower the Sulphur probably from oceanic and mist origin. These surface crusts and dense subsoils lead to very low infiltration rates with the result that any significant rainfall leads to some runoff. The gypsum crusts are formed from the very long-term addition of Sulphur from marine fog and the subsequent rapid oxidation of Sulphur, formation of sulphate and precipitation as CaSO4 due to the high Ca levels in the calcrete. Gypsum mobilisation takes place in the soils and this gypsum is precipitated along preferential flow channels and cracks in the weathering calcrete. The BESS will be installed on a prepared platform adjacent to the existing Lithops substation. The platform forms part of the Lithops substation but is currently not fenced and contains no build structure. Run-off from the Lithops substation could potentially contribute to erosion, however since it is an arid area, rainfall is low and not likely to cause significant erosion. Sensitivity of the receptor The site’s topography, geology and soils are not considered to be a sensitive receptor for the project’s impacts. This is because the project’s construction and operation do not have an influence on the site’s topography, geology and soils. 6.1.2 Groundwater The groundwater baseline information was obtained by conducting a desktop review. The sources of water in the central Namib are fog, direct summer rainfall, surface water runoff during the rainy season in the rivers running from the interior of the country through the central Namib, groundwater and seawater. However, the origin of all water in the desert is due to some form of precipitation and the occurrence of this vital resource is determined by important factors such as climate, hydrology, topography and geology. Unfortunately, the hydro-climate does not lend itself to produce an abundance of water. There are four main ephemeral rivers flowing through the central Namib: the Omaruru, Khan, Swakop and Kuiseb Rivers. The Khan and Swakop River are in the vicinity of the project. All of these contain intermittent surface flows following rain, but most of the time, water ‘flows’ below the surface in the sediments of the riverbed. All the coastal aquifers are recharged by runoff originating in the central highlands of Namibia where rainfall is higher and more reliable. The Swakop River can be described in compartments of approximately 25km in length. These compartments are separated by basement highs covered by shallow alluvial deposits of 5m maximum depth. All basement highs are characterised by a shallow water table and dense vegetation which results in high evapotranspiration rates. Water levels in the compartments between the basement highs are found at depths of between 23m to 26m. Similar alluvial aquifer descriptions are associated with the Khan River. Perched aquifers are thought to occur on the plains in association with the washes. In addition, bedrock aquifers exist at depths of approximately 60m below the plains that are located to the north and south of the Swakop River. 254M45AXZDHF-1404536467-161 53 BESS - NamPower Sensitivity of the receptor The site’s groundwater is not considered to be a sensitive receptor for the project’s impacts. This is because the existing aquifers at the project site are compartmentalised and not easily accessible, therefore eventual oil spills or other soil pollution would unlikely affect the groundwater. This low risk however does not allow NamPower to allow any spillages and accidents to go unremedied and all mitigations to prevent any form of soil contamination must at all times be enforced. 6.1.3 Surface Water No surface water was evident during the site visit and desktop research showed that no surface water has been recorded at the substation location in recent recorded history. With a rainfall significantly less than 100 mm per annum (Mendelsohn et al. 2002), recharge to most aquifers (especially bedrock aquifers) is expected to be very low (below 1% of total rainfall). The Khan and Swakop Rivers are recharged after most large flood events although surface runoff generated in the higher rainfall inland areas seldom reaches the coast (for example as a result of dams upstream), resulting in lower recharge to the alluvial aquifers in the coastal areas. Flood events are short lived and stay within the river channels, characterised by flash flood waves and short durations. The alluvial aquifers of both the Khan and Swakop Rivers are not homogenous but separated into sections called compartments created by outcropping bedrock or narrowing of the river gorge. These compartments are mostly dominated by vertical flow (evapo-transpiration and recharge), rather than lateral flow. The stored water volumes in each compartment are therefore not replenished on a continual basis from upstream, but rather from occasional flood events (SAIEA, 2010). Figure 6-3: Lithops BESS location in relation to nearest Rivers. 254M45AXZDHF-1404536467-161 54 BESS - NamPower Sensitivity of the receptor The site’s surface water is not considered to be a sensitive receptor for the project’s impacts. This is because there is no existing surface water. 6.1.4 Climate Summers are moderately hot (average maximum temperature during the hottest month is about 30°C), but the climate is tempered by cool coastal conditions brought inland by prevailing westerlies, south- westerlies, and southerlies (Lindesay & Tyson 1990; Mendelsohn et al. 2002). Winters are cool (average minimum temperature in coldest month is between 10 and 12°C), but hot easterly bergwind conditions can result in unseasonal warm conditions. This is verified by statistics from 2017-2019 taking at the Marble Ridge just south of Swakop Uranium Husab Mine. The highest temperatures recorded during the three-year period between January 2017 and December 2019 was 41°C (November) with monthly averages of indicating August and September to be the cooler months, and October to March being the hottest. Table 6-1: Monthly Temperature Summary (Marble Ridge Weather Station Data, 2017 - 2019)7 6.1.4.1 Rainfall The Lithops Substations is situated within a hyper-arid region, with a long-term average rainfall of less than 50 mm rain pa (Mendelsohn et al. 2002) (Figure 4-1). Spatial and temporal variability in rainfall is high (Mendelsohn et al. 2002). Rainfall mainly occurs as convective summer storms (Lindesay & Tyson 1990), sporadic, and often falling in one area (e.g. thunderstorms) rather than widespread across the region. The Namibian rainy season occurs most often in March and April. Average rainfall recorded at the Swakop Uranium Husab Mine in the past years has always been below the 50mm average. Sensitivity of the receptor The site’s climate is not considered to be a sensitive receptor for the project’s impacts. This is because the project’s construction and operation entail very little or no greenhouse gases emissions. For the construction phase all water will be trucked to site for human consumption and construction needs. The potential of fire is not increased due to climate factors and will be managed in the ESMP. 7 Scoping Report (Including Impacts Assessment) For the Proposed Changes to The Husab Mine and Linear Infrastructure. Report to the client Swakop Uranium, SLR, 2021. 254M45AXZDHF-1404536467-161 55 BESS - NamPower 6.1.5 Ambient air quality The main sources of air pollution in the region include mining operations, public roads (paved, treated and unpaved), and natural exposed areas prone to wind erosion. The main pollutant of concern in the Erongo Region is particulate matter (PM). The impact of PM on human health is largely dependent on (i) particle characteristics, particularly particle size and chemical composition, and (ii) the duration, frequency, and magnitude of exposure. The potential of particles to be inhaled and deposited in the lung is a function of the particles size, shape, and density. Due to the nature of work and type of facility air quality is not considered to be of concern. 6.1.6 Ambient noise Just as any other electrical installation, the components of a Battery Energy Storage System emit acoustic noise into their vicinity. It is not anticipated that the BESS will emit any significant noise or air pollution. The noise generated is generally comparable to electrical substations or PV power plants. The current ambient noise conditions were low, no noise was identified from the road or the mine at the time of the site visit. It is anticipated that at times an airhorn from trucks or other vehicular noise may be heard from the B2, however this is infrequent and would be continuous. No noise could be heard from the mine as this facility was also out of sight. Again ad hoc noise such as explosions or vehicular traffic passing the Substation may disturb the serene conditions at the substation. The only current noises present continuous were from transformers on site these were well below 55dB. The sound power represents the power of the noise output of a device and is expressed in decibel (dB). The main sources of noise emissions from a BESS and exemplary sound powers are: ▪ Transformers (as in other electrical installations); e.g. SGB DOTML 2.5 MVA: 55 dB ▪ Power Conversion System (inverters, as in PV power plants); e.g. SMA 3 MVA: 92.6 dB ▪ Fans and pumps of heat exchangers and chillers, e.g. Lenox LGH036 sufficient for one 40’ battery container: 73 dB. These sound powers refer to operation at rated power and decrease when the BESS is idle or at partial load. Some reference sound powers for comparison are: ▪ Household fridge: 50 dB ▪ Vacuum cleaner: 80 db ▪ Loud conversation: 90 dB ▪ Diesel truck: 115 dB The World Bank Group’s General EHS Guideline (2007) addresses impact of noise beyond the property boundary of the facilities. According to these international guidelines noise impacts should not exceed the levels presented in Table 6-2 or result in a maximum increase in background levels of 3 dB at the nearest receptor location off-site. Table 6-2: Noise Limits according to international guidelines ( World Bank Group, General EHS Guideline (2007), Chapter 1.7) 254M45AXZDHF-1404536467-161 56 BESS - NamPower Receptor One-hour LAep* (dB(A) Daytime Nighttime 7:00am – 10:00pm 10:00pm – 7:00am Residential, institutional, educational 55 45 Industrial, commercial 70 70 Note: *LAep is the A-weighted equivalent continuous sound level in decibels measured over a stated period of time. No Sensitive receptors were identified at the time of the site visit nor during desktop review. Sensitivity of the receptor Due to the BESS being located directly adjacent a Substation and in an area with the nearest neighbour being a mine (12,5 km away), the significant of the noise being generated is not considered significant although the ambient conditions are very low. 6.2 Biological environment 6.2.1 Biodiversity Biodiversity provides value for ecosystem functionality, aesthetic, spiritual, cultural, and recreational reasons. Biodiversity can be impacted upon in the following manner by the proposed project: ▪ Physical destruction and/or disturbance of fauna and flora. ▪ WWater resources as an ecological driver. 254M45AXZDHF-1404536467-161 57 BESS - NamPower Figure 6-4: Picture taken 28th October 2023 of the proposed site. Sensitivity of the receptor The site falls within the desert biome, which is characterised with a low density of fauna and flora (Barnard, P 1998). Considering that the location at Lithops substation has been recently cleared and that the biodiversity of site is not of significant status as can be seen in Figure 6-4 above, the sensitivity of placing the BESS at this location is deemed low to biodiversity. 6.2.2 Flora The project area falls in the central desert biome. This biome is known for high levels of endemism in plants, reptiles, invertebrates, and mammals. Vegetation cover is sparse, mostly concentrated in washes and ravines and on rocky marble ridges, as well as on distributed patches of mostly perennial grasses on the gravel plains that form an important part of the available fodder for large grazers such as Hartmann’s Mountain zebra. These patches are probably formed by surface water flows, a well-known phenomenon in arid and hyper-arid areas, but are maintained by gerbils (AWR, 2021). Fog-dependent species such as Zygophyllum stapffii (no conservation value) and Stipagrostis spp (LC) are generally dominant, but plant communities are set apart by numerous endemic and near-endemic taxa, including Commiphora oblanceolate (LC), Euphorbia giessii (LC), Ruellia diversifolia (LC), Aloe asperifolia (LC) and others. According to the initial EIA done for the substation, Wassenaar & Mannheimer (2010) defined twelve habitats across the whole study area8 based on their physical and ecological characteristics: 1. Khan and Swakop River 2. Rocky Valley Drainages 3. Plains Drainage Channels 4. Pink Gramadoelas 5. Black Gramadoelas 6. Marble in Gramadoelas 7. Gypsite Plain 8. Grasssy Plain 9. Hard Undulating Plain 10. Koppies and Ridges on Plains 11. Welwitschia Plains 12. Aquatic Habitat Based on habitat and least impact and sensitive biodiversity the choice of locality for the substation in the EIA was then chosen to be in the least sensitive habitat of the grassy plains habitat. This habitat has the following physical and ecological characteristics: ▪ Largest part of study area, consists of pale semi-consolidated eroded material ▪ Substrate mostly deep loamy gravel-sand 8 The Environmental Impact Assessment Report for The Husab Mine Linear Infrastructure (2011) detailed the study area of the mine and all associated Infrastructure as covered in that EIA. 254M45AXZDHF-1404536467-161 58 BESS - NamPower ▪ Drained by numerous sinuously twisting drainage channels that often fan out and disappear on very gentle or flat slopes ▪ Includes sheet drainages that are too small to map out separately ▪ Includes area underlain by metamorphosed sediments of the Kuiseb formation forming fine-grained dark sandy surfaces ▪ Includes small pockets of aeolian sand at the edge of the gramadoelas, integrating with the sandy bottom of rocky valley drainages ▪ Contains high numbers of annual and perennial grasses ▪ Primary habitat for small burrowing and digging mammals: gerbils, suricates and a number of unidentified viverids; especially gerbil burrowing may result in localised fertilisation (potential keystone process and keystone group) ▪ Possibly important area for re-charge of superficial aquifer/s on the plain (needs to be confirmed through dedicated study) ▪ Probably seasonally important grazing areas for zebra; year-long important grazing areas for springbok and ostrich ▪ Represents the only habitat with significant numbers of Cape hare ▪ Together with Rocky Valley Drainages and Plains Drainage Channels, is important habitat for Rüppel’s Korhaan ▪ Includes a significant part of the Welwitschia population; those parts of this habitat containing Welwitschia plants are dealt with as an independent habitat (Welwitschia Plain) Aloe asperifolia is endemic to western Namibia and occurs on limestone and conglomerate in parts of the Namib Desert which are not only devoid of other plant life, but almost devoid of soil. Most of the moisture available to plants of this species is derived from fog. The species is rated to be of least concern. Figure 6-5: Flowering wild aloe (aloe asperifolia) only plants located on site. Sensitivity of the receptor 254M45AXZDHF-1404536467-161 59 BESS - NamPower The flora is classified as having low sensitivity to the project’s impacts. There are no nationally or internationally protected flora species in the project area. It is also classified as low as the site has been previously cleared. SENSITIVITY - Flora Criteria Classification Scoring Existing regulations Medium -2 and guidance protection level Value of the receptor low -1 Vulnerability to the low -1 changes Sum -4 Sensitivity of the receptor Low 6.2.3 Fauna Small endemic mammals such as the dassie rat (Petromus typicus) (LC), pygmy rock mouse (Petromyscus collinus) (LC) and Setzer’s hairy-footed gerbil (Gerbillurus setzeri) (LC) also occur, and often play an ecological engineering role, creating habitat for plants (particularly grasses) and thus food for a range of large mammal herbivores. A recent study has shown how widespread the effect of gerbils is on the productivity of the gravel plains (Shaanika, 2020). Sensitivity of the receptor The fauna is classified as having low sensitivity to the project’s impacts. There are no nationally and internationally protected fauna species in the project area. It is also classified as low as the project site for the BESS is a very small piece of land that will be affected and thus disturbance to the small mammals and reptiles etc. will not be deemed significant. SENSITIVITY - Fauna Criteria Classification Scoring Existing regulations Medium -2 and guidance protection level Value of the receptor low -1 Vulnerability to the low -1 changes Sum -4 Sensitivity of the receptor Low 254M45AXZDHF-1404536467-161 60 BESS - NamPower 6.2.4 Protected and Conservation Areas Dorob National Park is a protected area in the Erongo Region along the central Namibian. It was gazetted as a National Park and then the nature conservation ordinance No.4 of 1975 on 1st December 2010. The Dorob National Park is located along the coast between Skeleton Coast NP and Namib-Naukluft NP. The park extends to 8,118 km2 and is approximately 260 km long and 40 km wide. The park’s northern border is shared with the Skeleton Coast NP, while to the south it is contiguous with the Namib-Naukluft NP. It is one of the six coastal protected areas of Namibia (five terrestrial protected areas and one marine protected area) (Figure 6-6). Figure 6-6: Dorob National Park in relation to neighbouring protected areas and communal conservancies. Dorob is classified as a National Park: i. to protect the ecological integrity of one or more ecosystems for present and future generations, and exclude exploitation or occupation inconsistent with such protection; and ii. ii. to provide a foundation for compatible cultural, scientific, educational, recreational and visitor opportunities. The main purpose of Dorob NP is captured in the following six strategic objectives9: 9 Ministry of Environment, Forestry and Tourism, 2021. Management Plan for Dorob National Park 2021/2022-2030/2031. 254M45AXZDHF-1404536467-161 61 BESS - NamPower 1. To secure and increase landscape connectivity. 2. To protect and maintain biodiversity. 3. To develop, implement and maintain regional conservation synergy through effective interaction with all park neighbours, residents, and major stakeholders. 4. To maximise regional economic development, based on the principles of sustainable utilisation. 5. To protect and maintain cultural and historic, archaeological, and paleontological assets. 6. To provide for recreational opportunities to park visitors without compromising environmental values Dorob is a multi-use park with recreational areas. Sensitivity of the receptor Lithops Substation and the BESS fall on the border to the Dorob National Park, a mere 300m outside the Park, due to proximity it should not be argued whether the BESS falls inside or outside the park, but cognisance of the Dorob NP regulations and objectives should be included in the planning of the BESS. When reviewing the Management Plan for Dorob National Park this project falls within objective 4 above, (to maximise regional economic development, based on the principles of sustainable utilisation) whilst not contravening the other objectives. It is for this reason that the significance of the Dorob national Park is give a low significance. SENSITIVITY - Protected and Conservation Areas Criteria Classification Scoring Existing regulations Medium -2 and guidance protection level Value of the receptor low -1 Vulnerability to the low -1 changes Sum -4 Sensitivity of the receptor Low 6.3 Human environment 6.3.1 People The people affected by the BESS will be NamPower staff operating at the substation and the BESS as well as employees and visitors to the Husab Mine. Due to access to the BESS being along the mine road the site is not accessible by the general public and no other communities live in the vicinity. It is estimated that at a peak during the construction phase of this project 50 workers may be present on site. This peak workforce will last a maximum time of 2 months. It is anticipated that that total construction phase will take about 6 months with only a few people at site during most of the duration. Sensitivity of the receptor 254M45AXZDHF-1404536467-161 62 BESS - NamPower The people driving by the project affected area are classified as having low sensitivity to the project’s impacts. SENSITIVITY - People Criteria Classification Scoring Existing regulations Low -1 and guidance Value of the receptor Low -1 Vulnerability to the Low -1 changes Sum -3 Sensitivity of the receptor Low 6.3.1.1 Land ownership The Lithops Substation along with the adjacent land for the BESS belongs to the proponent NamPower. 6.3.2 Tourism The site is within a restricted mining area. Access to NamPower for the substation and the proposed BESS is given as this site lies close to the entrance of the mining road and before any mining operations. However due to this being a restricted mining area, the area has no tourism value. Sensitivity of the receptor Due to the site being a restricted area no sensitivity of impact is identified. 6.3.3 Cultural, religious, and historical sites Over the past 12 years several archaeological studies have been done as part of the Husab Mine Project. The area has thus been well studied and the only heritage sites of significance surveyed and documented, are the Welwitchia siding and Khan Mine valley, approximately 15km from site. The Welwitschia siding and remnant of the rail embankment on the west of the site have been protected from disturbance by physical barriers. Sensitivity of the receptor The sensitivity of receptors for all human environmental factors have been combined as no impact and thus no sensitivity is identified. SENSITIVITY - Cultural, religious and historical sites Criteria Classification Scoring -3 254M45AXZDHF-1404536467-161 63 BESS - NamPower Existing regulations Medium and guidance protection level Value of the receptor Low -1 Vulnerability to the Low -1 changes Sum -5 Sensitivity of the receptor Low 254M45AXZDHF-1404536467-161 64 BESS - NamPower 7 Assessment of Impacts and Mitigation Framework This section presents the expected impacts from operation and construction of the BESS project, as well as mitigation measures that could be applied to reduce/eliminate impacts. The measures shall be read as recommendations and are not binding at this stage. 7.1 Impacts and Mitigation Measures during Design, Construction and Operational Phase 7.1.1 Impacts on the Physical Environment 7.1.1.1 Topography The construction of the BESS will include clearing of the site area and required earthworks. The construction of the project facilities will in addition imply levelling, operation of construction machines and vehicles, possible hammering, drilling works, etc. Such activities will not result in alteration of the landscape of the area and thus not affect the natural drainage channels and local topography settings of the site. Magnitude and significance pre-mitigation Impacts on topography are not anticipated and be insignificant. Mitigation measures No additional mitigation measures will be required. 7.1.1.2 Soil and Groundwater Improper housekeeping practices during construction (such as illegal disposal of waste to land, hazardous materials/waste spills) could contaminate and pollute soil which in turn can pollute groundwater. This could also indirectly affect flora/fauna and the general health and safety of workers (from being exposed to such wastewater streams). Hazardous waste is expected to be generated throughout the construction phase and this could include consumed oil, chemicals, paint cans, etc. Hazardous waste generated within the project activities will be collected and stored safely (sealed area with controlled access) on site and then managed (collected, treated and disposed) by a specialized company approved for such activity. The nature of construction activities entails the use of various hazardous materials such as oil, chemicals, and fuel for the various equipment and machinery. Improper management of hazardous material entails a risk of leakage into the surrounding environment either from storage areas or throughout the use of equipment and machinery. The site is flat with very low rainfall (less than 100mm per year), there is no risk for soil erosion. 254M45AXZDHF-1404536467-161 65 BESS - NamPower Magnitude and significance pre-mitigation Impacts on soil and groundwater are negative and may be significant. These are anticipated to happen throughout the whole construction period, and to be long-term and irreversible. Given this, the topography impacts pre-mitigation are considered of medium magnitude. Considering that the sensitivity of the receptors “soil” and “groundwater” is classified as low, and that the magnitude of the impacts on these receptors during construction is medium, the impacts’ significance is classified as medium. Mitigation measures are required and suggested below. MAGNITUDE - Impacts on soil and groundwater CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Medium term -2 Frequency Irregular -2 Ability to recover - -2 Probability Possible -2 Intensity Low -1 Sum -10 Magnitude of the impact Medium vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptors Low Mitigation measures The following identifies the mitigation measures related to hazardous waste and materials management, which are to be applied by the Contractor during the detailed design and construction phase and which include: ▪ adhering to the BESS O&M recommendation set by the technical team. ▪ hiring a contractor authorized for the collection, treatment, and disposal of hazardous waste. ▪ prohibiting illegal disposal of hazardous waste to the land. ▪ arrangements for management of hazardous waste in accordance with the Regulations on the manner of storage, packaging and labelling of hazardous waste (according to ESS 3 and the Hazardous Substances Ordinance 14 of 1974) 254M45AXZDHF-1404536467-161 66 BESS - NamPower ▪ ensuring that containers are emptied and collected by the contractor at appropriate intervals to prevent overflowing. ▪ ensuring that hazardous materials are stored in proper areas and in a location where they cannot reach the ground surface in case of accidental spillage. This means storage facilities that are of hard impermeable surface, flame-proof, with 110% containment capacity, accessible to authorized personnel only, locked when not in use, and prevent incompatible materials from coming in contact with one another. ▪ a register of all hazardous materials used and accompanying Material Safety Data Sheet (MSDS) must be present at the storage and usage location at all times. Spilled material should be tracked and accounted for; incorporate dripping pans at machinery, equipment, and areas that are prone to contamination by leakage of hazardous materials (such as oil, fuel, etc.). ▪ regular maintenance of all equipment and machinery used on site. Maintenance activities and other activities that pose a risk for hazardous material spillage (such as refuelling) must take place at a suitable location (impermeable surface) with appropriate measures for trapping spilled material. ▪ ensuring that a minimum of 1,000 litres of general-purpose spill absorbent is available at hazardous material storage facility. Appropriate absorbents include zeolite, clay, peat and other products manufactured for this purpose; and ▪ if spillage occurs, spill must be immediately contained, cleaned-up, and contaminated soil disposed as hazardous waste. The above listed requirements, among others, shall be stipulated in a Waste Management Plan (WMP) for construction phase which must be developed for the project by the Contractors in accordance with the Law on Waste Management (Pollution Control and Waste Management Bill) and related legislative requirements, and WB General HSE Guidelines, for various types of waste, such as hazardous, biomedical, municipal solid waste, electronic waste, etc. The WMP will also meet the WB ESS3 Standards on Resource efficiency and pollution prevention and management. Magnitude and significance post-mitigation The mitigation measures may allow reducing the impact’s frequency to “seasonal” and its probability to “unlikely”: Therefore, the magnitude post-mitigation is classified as low. Based on the significance matrix, the significance of the residual impact (impact post-mitigation) is classified as low. MAGNITUDE - Impacts on soil and groundwater CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Medium term -2 Frequency Seasonal -3 254M45AXZDHF-1404536467-161 67 BESS - NamPower Ability to recover Reversible -1 Probability Unlikely -1 Intensity Low -1 Sum -9 Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptors Low 7.1.1.3 Surface water Due to a lack of surface water at site the concern of potential impact on surface water is only during the transportation of equipment and materials during the construction phase. Surface water sources are evident from along major transport routes to the site. The construction phase of the project will involve transportation of various equipment and materials. The nature of construction activities entails the use of various hazardous materials such as oil, chemicals, paint cans and fuel for the various equipment and machinery. The use of transportation equipment and mobile machinery, which is inappropriate for the purpose, and/or is in unsatisfying technical condition, could lead to pollution of water by leakages of oils in or near a water body. In addition, spillage or fallout of the transported materials, in particular paints and other chemicals in or near a water body poses a risk of pollution as well. Improper management of hazardous materials entails a risk of leakage into the surrounding environment during the transportation of equipment and machinery. Magnitude and significance pre-mitigation Impacts on surface water are negative and may be significant, if not properly addressed when incidents occur. Given this, surface water impacts pre-mitigation are considered of low magnitude, for transport. Considering that the sensitivity of the receptor “surface water” is classified as low, and that the magnitude of the impacts on these receptors during construction is medium, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. MAGNITUDE - Impacts on surface water CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Medium term -2 254M45AXZDHF-1404536467-161 68 BESS - NamPower Frequency Irregular -2 Ability to recover Reversible -1 Probability Unlikely -1 Intensity Low -1 Sum -8 Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low Mitigation measures Appropriate management of hazardous material during transportation is to be planned and implemented by the contractors and their sub-contractors. The personnel shall be trained with regards to good housekeeping practices. Magnitude and significance post-mitigation The mitigation measures may allow reducing the impact’s frequency to “seasonal” and its probability to “unlikely”: Therefore, the magnitude post-mitigation is classified as low. Based on the significance matrix, the significance of the residual impact (impact post-mitigation) is classified as low. MAGNITUDE - Impacts on surface water CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Irregular -3 Ability to recover Reversible -1 Probability Unlikely -1 Intensity Low -1 Sum -8 254M45AXZDHF-1404536467-161 69 BESS - NamPower Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptors Low 7.1.1.4 Landscape and visual impacts It is not anticipated that the BESS will have any impacts on the landscape or pose a visual impact, as the public has no access to the area. With the existing substation in place, a visual impact has been created (albeit limited), adding the BESS directly next to it would not exacerbate the impact. Some visual and landscape impact would occur during construction activities. However, these impacts are also considered negligible, as the area is already disturbed and known as restricted mining area. 7.1.1.5 Ambient Air Quality The construction of the BESS will cause short-term and local gaseous and particulate air emissions. Initially, these will be associated to the clearing of the site. The construction of the facilities will in addition imply levelling. All these activities are potentially generators of short-term and local air emissions, especially of dust. The trucks used to transport materials, as well as other construction equipment’s movements, such as power generators, loaders and vehicles, will also be a source of short - term air emissions in the project areas (such as SOx, NOx, CO, etc.) which would also have minimal direct impacts on ambient air quality. However, it is important to note that the generation and dispersion of dust depends on weather conditions; dry conditions with high wind speeds would cause excessive dust generation, while wet conditions and low wind speeds would not. Magnitude and significance pre-mitigation Impacts on ambient air quality are negative and may be significant, as the emissions of the vehicles and machinery, and/or the consequent ground level concentrations in the ambient air may be above the national and international standards, even if only locally and temporarily. All the above impacts are anticipated to be temporary as they are limited to the construction period only. Impacts on air quality are reversible as baseline conditions will revert back after construction works are completed. Given the above, the pre-mitigation impact is considered of medium magnitude. Considering that the sensitivity of the receptor “ambient air quality” is classified as low, and that the magnitude of the impacts on this receptor during construction is medium, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. MAGNITUDE - Impacts on ambient air quality CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -2 254M45AXZDHF-1404536467-161 70 BESS - NamPower Frequency Repeatedly -4 Ability to recover Reversible -1 Probability Definite -4 Intensity Medium -2 Sum -14 Magnitude of the impact Medium vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low Mitigation measures The following identifies the mitigation measures to be applied by the Contractor during the construction phase (to prevent impacts caused by the construction activities and which are within his control). Such measures include: ▪ If dust or pollutant emissions are found to be excessive, construction activities should be stopped until the source of such emissions have been identified and adequate control measures are implemented. ▪ Comply with NamPower internal Occupational Health and Safety Procedures, developed in accordance with the national legal occupational health and safety requirements, and the Occupational Safety and Health Administration (OSHA) requirements to ensure that for activities associated with high dust levels, workers are equipped with proper Personal Protective Equipment (e.g. masks, eye goggles, safety boots, etc.). ▪ Apply basic dust control and suppression measures which could include: >>regular watering of all active construction areas >>proper planning of dust causing activities to take place simultaneously in order to reduce the dust incidents over the construction period. >>proper covering of trucks transporting aggregates and fine materials (e.g. through the use of tarpaulin) >> adhering to a speed limit of 15km/h for trucks on the construction site. >> Develop a regular inspection and scheduled maintenance program for vehicles, machinery, and equipment to be used throughout the construction phase for early detection of pollution sources to avoid unnecessary pollutant emissions. Magnitude and significance post-mitigation The mitigation measures may allow reducing the impact’s intensity to “low”, its frequency to “seasonal” and its probability to “possible”. Therefore, the magnitude post-mitigation is classified as low. Based on the significance matrix, the significance of the residual impact (impact post-mitigation) is classified as low. Compensation measures are required and suggested below. 254M45AXZDHF-1404536467-161 71 BESS - NamPower MAGNITUDE - Impacts on ambient air quality CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Medium term -2 Frequency Irregular -2 Ability to recover Reversible -1 Probability Possible -2 Intensity Low -1 Sum -9 Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 7.1.1.6 Ambient Noise The construction of the project together with the associated infrastructures will result in the generation of short-term noise emissions. Initially, these will be associated with the clearing of the site area and access to the site and with any type of earthworks required. The construction of the other facilities will in addition imply levelling, operation of construction machines and vehicles, possible hammering, drilling works etc. All these activities are potentially generators of short-term and local noise emissions. All the above activities will likely include the use of machinery and equipment such as generators, hammers, compressors, etc., which are expected to be a source of noise and vibration generation within the Project site and its surroundings. If improperly managed, there is risk of nuisance and health effects to construction workers on site and to a lesser extent to the nearby receptors. Magnitude and significance pre-mitigation Impacts on ambient noise levels are negative and may be significant. However, these are anticipated to be temporary and of short-term nature as they are limited to the construction period only and are reversible as baseline conditions will be restored upon completion of construction works. Impacts on the construction workers may occur if proper protection equipment (ear plugs, for example) is not provided. Given the above, noise impact is considered of the pre-mitigation impact is considered of low magnitude. Considering that the sensitivity of the receptor “ambient noise” is classified as high, and that the magnitude of the impacts on this receptor during construction is medium, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. 254M45AXZDHF-1404536467-161 72 BESS - NamPower MAGNITUDE - Impacts on ambient noise CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Medium term -2 Frequency Repeatedly -4 Ability to recover Reversible -1 Probability Definite -4 Intensity Medium -2 Sum -14 Magnitude of the impact Medium Vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low Mitigation measures The following identifies the mitigation measures to be applied by the Contractor during the construction phase and which include: ▪ Apply adequate general noise suppressing measures. This could include the use of well-maintained mufflers and noise suppressants for high noise generating equipment and machinery, developing a regular maintenance schedule of all vehicles, machinery, and equipment for early detection of issues to avoid unnecessary elevated noise level, etc. ▪ Comply with NamPower internal Occupational Health and Safety Procedures, developed in accordance with the national legal occupational health and safety requirements, to ensure that for activities associated with high noise levels, workers are equipped with proper Personal Protective Equipment (e.g. Earmuffs). ▪ The vehicles and equipment’s shall be kept in good maintenance state. If generators are used, sound barriers such as portable or free-standing screens shall be installed around the generators. ▪ Before construction commences, properly plan work activities to ensure that noisy activities are restricted between late evening hours and early morning hours (from 10 pm till 6 am) especially at those areas close to the nearby receptors (such as nearby houses) to the greatest extent possible. ▪ Trucks and vehicles crossing housing areas shall reduce their speed to a maximum of 30 km/h; traffic speed on unpaved access roads shall be reduced to 15 km/h. ▪ If noise levels were found to be excessive (complaints by residents), noise level shall be monitored throughout the construction phase on the identified sensitive receptors. 254M45AXZDHF-1404536467-161 73 BESS - NamPower Magnitude and significance post-mitigation The mitigation measures may allow reducing the impact’s intensity to “low”, its frequency to “seasonal” and its probability to “possible”. Therefore, the magnitude post-mitigation is classified as low. Based on the significance matrix, the significance of the residual impact (impact post-mitigation) is classified as low. Compensation measures are required and suggested below. MAGNITUDE - Impacts on ambient noise CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Medium term -2 Frequency Irregular -2 Ability to Reversible -1 recover Probability Possible -2 Intensity Low -1 Sum -9 Magnitude of the impact Low Vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 7.1.2 Impacts on the Biological Environment 7.1.2.1 Terrestrial flora During construction of the BESS, the initial process will include clearing of the land through earthworks. The construction of the project facilities will in addition imply levelling, operation of construction machines and vehicles, possible hammering, drilling works, etc. The resulting impacts are loss of vegetation within areas physically affected by the construction activities. Magnitude and significance pre-mitigation Impacts on terrestrial flora are negative and not considered significant. These are anticipated to happen during site clearing. Considering that the sensitivity of the receptor “terrestrial flora” is classified as low, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. 254M45AXZDHF-1404536467-161 74 BESS - NamPower MAGNITUDE - Impacts on terrestrial flora CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to recover - -2 Probability Probable -3 Intensity Low -1 Sum -9 Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low Mitigation measures ▪ The removal of vegetation should be reduced to the minimum extent possible; it is forbidden to use any chemicals for this activity. Magnitude and significance post-mitigation The mitigation measures will not affect the rating however best management principles and mitigation techniques should always be utilised. MAGNITUDE - Impacts on terrestrial flora CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to recover Reversible -1 254M45AXZDHF-1404536467-161 75 BESS - NamPower Probability Possible -2 Intensity Low -1 Sum -7 Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 7.1.2.2 Terrestrial fauna Impact on the fauna is classified is not seen to be significant. There are no nationally and internationally protected fauna species in the project area. It is also deemed as low due the very small piece of land occupied by the BESS, thus disturbance to the small mammals and reptiles etc. will not be deemed significant. Magnitude and significance pre-mitigation Impacts on terrestrial fauna are negative and are not significant. These are anticipated to happen during site clearing. Considering that the sensitivity of the receptor “terrestrial fauna” is classified as low, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. MAGNITUDE - Impacts on terrestrial fauna CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to recover Reversible -1 Probability Definite -4 Intensity Low -1 Sum -9 Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 254M45AXZDHF-1404536467-161 76 BESS - NamPower Mitigation measures ▪ The removal of vegetation should be reduced to the minimum extent possible to reduce on the impact on the habitat of terrestrial fauna; it is forbidden to use any chemicals for this activity. ▪ All cleared areas must be re-vegetated and rehabilitated as soon as construction in that area has been completed. Magnitude and significance post-mitigation The mitigation measures will not affect the rating however best management principles and mitigation techniques should always be utilised. MAGNITUDE - Impacts on terrestrial fauna CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to recover Reversible -1 Probability Possible -2 Intensity Low -1 Sum -7 Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 7.1.2.3 Natural Protected areas Lithops Substation on the BESS fall on the border to the Dorob National Park, due to proximity it should not be argued whether the BESS falls inside or outside the park, but cognisance of the Dorob NP regulations and objectives should be included in the planning of the BESS. Magnitude and significance pre-mitigation 254M45AXZDHF-1404536467-161 77 BESS - NamPower Impacts on Dorob National Park are negative and but not significant. These are anticipated to happen due to the presence of the BESS. Considering that the sensitivity of the receptor “natural protected areas” is classified as low, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. MAGNITUDE - Impacts on natural protected areas CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Repeatedly -4 Ability to Reversible -1 recover Probability Unlikely -1 Intensity Low -1 Sum -4 Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low Mitigation measures The main mitigation measures are to ensure that the flora and fauna mitigation measures are implemented. Magnitude and significance post-mitigation The mitigation measures may allow reducing the impact’s frequency to “once” and its probability to “unlikely”: Therefore, the magnitude post-mitigation is classified as low. Based on the significance matrix, the significance of the residual impact (impact post-mitigation) is classified as low. MAGNITUDE - Impacts on ambient noise CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 254M45AXZDHF-1404536467-161 78 BESS - NamPower Duration Short term -1 Frequency Once -1 Ability to Reversible -1 recover Probability Unlikely -1 Intensity Low -1 Sum -6 Magnitude of the impact Low Vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 7.1.3 Impacts on the Human Environment 7.1.3.1 Health & Safety Impacts Worker’s Health and Safety impacts are addressed in the World Bank’s ESS2 and the Namibian Labour Act. Construction activities pose risks to the health, safety, security and wellbeing of construction workers if not managed appropriately. Similarly, there is the risk of adverse occupational health and safety (OHS) impacts related to personal accident or injury on any construction site. Some of the OHS risks which are likely to arise during the construction phase of the project and are typical to many construction sites include: exposure to physical hazards from use of heavy equipment; trip and fall hazards; exposure to dust, noise and vibrations; falling objects; exposure to hazardous materials; and exposure to electrical hazards from the use of tools and machinery. Other risks common to electricity infrastructure projects specifically include working in trenches, live power equipment. 7.1.3.1.1 Thermal runaway and fire The largest concern associated with Li-ion batteries is the possibility of thermal runaway and resulting fire. The energy density of the cells and the combustibility of the organic-based electrolyte make these batteries a fire hazard. Excessive charging, discharging, high current, or imbalances between cells can cause overheating in a cell and result in thermal runaway as neighbouring cells also overheat. Extreme high temperatures lead to leaks, smoke, gas venting, and/or combustion of the cell pack. Manufacturers of large systems have employed sophisticated battery management systems to monitor cell performance and limit operation to safe and acceptable performance ranges. 254M45AXZDHF-1404536467-161 79 BESS - NamPower In addition to this generic fire risk, a BESS causes a specific risk due to the "electrochemical" and chemical energy stored in its cells. The "electrochemical" energy is repeatedly stored and released during charging and discharging whereas the chemical energy is only released in the case of a fire. Magnitude and significance pre-mitigation Impacts on Thermal Runaway and fire are negative and may be significant to the project, however no significant impact is foreseen on the environment in this circumstance. This is only anticipated to happen when poor housekeeping and poor discipline is present on site. Given this, impacts pre-mitigation are considered of low magnitude. Considering that the sensitivity of the receptor “ environment” is classified as low, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. MAGNITUDE - Impacts on Fire CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to recover Reversible -1 Probability Unlikely -1 Intensity Medium -2 Sum Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low Mitigation measures The principal effort for BESS-specific fire protection is built up in around mitigating any safety related incident before it occurs. Thus as part of the design and operation of the BESS the following three principles will be considered and adhered to: 254M45AXZDHF-1404536467-161 80 BESS - NamPower 1. The cells should not be charged or discharged to voltages beyond their operational range as specified by their manufacturer. This will be achieved by continuous monitoring and regular maintenance. 2. The cells should not be exposed to temperatures above or below the range specified by their manufacturer. This will be prevented through the implementation of Cell level temperature monitoring devices. 3. The safety concept should be robust against cells that have manufacturing defects. It will be ensured that batteries are transported in a manner to prevent accidental damage and will need to be inspected prior to installation and part of maintenance. Any damaged or defected batteries will need to be disposed of in accordance with the WEEE plan to be developed for the project A fire risk assessment will be undertaken once the type of battery technology has been confirmed. An adequate number of Class A and Class D fire extinguishers shall be installed on site. As part of fire protection, the following is recommended: ▪ A fire monitoring system with early warning smoke detection; ▪ A fire suppression system that will not aggravate a fire (e.g. prevent the application of water to metallic sodium); Personnel shall be trained in the correct emergency response procedure and fire fighting techniques in the event of a fire associated with the BESS. Magnitude and significance post-mitigation The mitigation measures may allow reducing the intensity to “low”: Therefore, the magnitude post- mitigation is classified as low. Based on the significance matrix, the significance of the residual impact (impact post-mitigation) is classified as low. MAGNITUDE - Impacts on Fire CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to Reversible -1 recover Probability Unlikely -1 Intensity Low -1 254M45AXZDHF-1404536467-161 81 BESS - NamPower Sum -6 Magnitude of the impact Low Vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 7.1.3.1.2 Radiated electromagnetic emissions As with any other electric device and asset, BESS emit electromagnetic radiation during operation. The purpose of emission regulations regarding these fields is not to reduce them to zero, but to keep their impact on the environment within reasonable limits. The common objective of regulations regarding electromagnetic emissions is to protect people, assets and the environment outside the BESS from negative impacts. Negative impacts from electromagnetic emissions may include: ▪ Malfunction of electronic devices: Malfunction of non-critical devices, e.g. flickering of consumer electronics displays, may already occur at low levels. Malfunction of critical devices such as vehicle and plane controls or pacemakers usually only occurs at very high levels that cannot be transmitted to their outside. ▪ Malfunction of radio-based communication: may occur at very low levels of radiated emission. Remarks on the scope of this section: ▪ These emission regulations only cover the so-called non-ionizing radiation in the electromagnetic spectrum. Ionizing radiation (e.g. like from nuclear plants) is usually not an issue with BESS. ▪ In some regulations, mains-borne (or line-bound) electromagnetic emissions from the BESS to the electricity grid (e.g. flicker, harmonics, pulse voltages) are considered together with the radiated (i.e. air-borne) emissions. ▪ In some regulations, the electromagnetic emissions inside and outside the BESS are considered together. This section only covers the BESS emissions to the outside of the BESS. ▪ In some regulations, the electromagnetic immunity, i.e. the resistance to withstand mains-borne and air-borne electromagnetic disturbances from other sources towards the BESS, are considered together with the emissions. Magnitude and significance pre-mitigation Impacts on radiated electromagnetic emissions are negative and may be significant to the project, however no significant impact is foreseen on the environment in this circumstance. This is only anticipated to happen when poor housekeeping and poor discipline is present on site. Given this, impacts pre-mitigation are considered of low magnitude. Considering that the sensitivity of the receptor “environment” is classified as low, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. MAGNITUDE - Impacts on occupational H&S CONSTRUCTION | PRE-MITIGATION 254M45AXZDHF-1404536467-161 82 BESS - NamPower Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to recover Reversible -1 Probability Unlikely -1 Intensity Medium -1 Sum Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low Mitigation The following methods are common as a proof that the radiated (air-borne) electromagnetic emissions from a BESS are within reasonable boundaries: ▪ All major components shall be type-tested not to exceed standard emission levels, e.g. according to IEC 61000-6-4. ▪ The installation of components shall be in compliance with general good practice for EMC reduction. ▪ Careful shielding of the inverter cabinet ▪ Usage of EMC filters of all connections that enter and leave the inverter cabinet, including: - AC low-voltage connection to the transformer ("AC filter") - DC low-voltage connection to the batteries ("DC filter") - Inverter auxiliary power supply ▪ Inverter data interfaces (may include galvanic separation, e.g. via optocouplers) EMC-compliant design and installation of the entire electrical system, e.g.: - Low-resistance functional grounding - Avoidance of ground loops - Appropriate cable management and cable shielding Magnitude and significance post-mitigation The mitigation measures will ensure the magnitude post-mitigation to remain classified as low. Based on the significance matrix, the significance of the residual impact (impact post-mitigation) is classified as low. 254M45AXZDHF-1404536467-161 83 BESS - NamPower MAGNITUDE - Impacts on ambient noise CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to Reversible -1 recover Probability Unlikely -1 Intensity Low -1 Sum -6 Magnitude of the impact Low Vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 7.1.3.1.3 Occupational Health & Safety and Labour Standards Potential Labour and Workers Rights impacts are related to inhumane labour conditions and refusal of human rights. ESS 2 has the objectives to promote safety and health at work, to promote the fair treatment, non-discrimination and equal opportunity of project workers, to protect workers, including vulnerable workers such as women, persons with disabilities, children (of working age, in accordance with this ESS) and migrant workers, contracted workers, community workers and primary supply workers, as appropriate and to prevent the use of all forms of forced labour and child labour. ESS 2 further has the objectives to support the principles of freedom of association and collective bargaining of project workers in a manner consistent with national law and to provide project workers with accessible means to raise workplace concerns. The Project shall also meet the following International Labour Organization (ILO) core standards: ▪ Forced Labour (C105). ▪ Child Labour (C182). ▪ Discrimination (C111). ▪ Freedom of Association and the Right to Organize (C 87). ▪ Equal Remuneration (C100); and ▪ Minimum Age (C138). Magnitude and significance pre-mitigation 254M45AXZDHF-1404536467-161 84 BESS - NamPower Impacts on occupational H&S are negative and may be significant. These are anticipated to happen especially when poor housekeeping and poor discipline is present on site. Given this, impacts pre- mitigation are considered of low magnitude. Considering that the sensitivity of the recep tor “people” is classified as low, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. MAGNITUDE - Impacts on occupational H&S CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Irregular -2 Ability to recover Reversible -1 Probability Possible -2 Intensity Low -1 Sum -8 Magnitude of the impact Low vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low Mitigation measures ▪ Contractor to develop OHS Plan consistent with national regulations and WB ESS2 ▪ Enforce the site ESMP and engage in regular toolbox talks. ▪ PPE must be utilised at all times when on site. ▪ Ensure during construction a Health and Safety officer is at site at all times. Magnitude and significance post-mitigation The mitigation measures may allow reducing the impact’s frequency to “once” and its probability to “unlikely”: Therefore, the magnitude post-mitigation is classified as low. Based on the significance matrix, the significance of the residual impact (impact post-mitigation) is classified as low. MAGNITUDE - Impacts on ambient noise CONSTRUCTION | POST-MITIGATION 254M45AXZDHF-1404536467-161 85 BESS - NamPower Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to Reversible -1 recover Probability Unlikely -1 Intensity Low -1 Sum -6 Magnitude of the impact Low Vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 7.1.3.1.4 Community Health and Safety The people affected by the BESS will be NamPower staff operating at the substation and the BESS, as well as employees and visitors to the Husab Mine. Due to access to the BESS being along the mine road the site is not accessible by the general public and no other communities live in the vicinity. 7.1.3.2 Cultural Heritage With the closest site of cultural significance, the Welwitschia siding and remnant of the rail embankment being approximately 15 km away, no impact is anticipated. 7.1.4 Impacts and Mitigation Measures during Decommissioning 7.1.4.1 Disposal and recycling of Batteries As most batteries contain heavy metals and other toxic substances, it is not desired to dispose of them in general landfills or in the environment. The battery “blades” contain valuable rare earth metals particularly Lithium and Cadmium that are sealed within gel structures. These are of high value when they reach the end of their working life and should be returned to the manufacturer for recycling. The major environmental risk is a leakage of the battery cells when they have been disposed of improperly after the decommissioning of the BESS. This leakage may lead to soil and groundwater contamination. Magnitude and significance pre-mitigation 254M45AXZDHF-1404536467-161 86 BESS - NamPower Impacts on radiated electromagnetic emissions are negative and may be significant to the project, however no significant impact is foreseen on the environment in this circumstance. This is only anticipated to happen when poor housekeeping and poor discipline is present on site. Given this, impacts pre-mitigation are considered of low magnitude. Considering that the sensitivity of the receptor “environment” is classified as low, the impacts’ significance is classified as low. Mitigation measures are required and suggested below. MAGNITUDE - Impacts on occupational H&S CONSTRUCTION | PRE-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Long term -3 Frequency Repeatedly -4 Ability to recover Irreversible -4 Probability Possible -2 Intensity High -3 Sum -17 Magnitude of the impact High vs SIGNIFICANCE Medium (see matrix) Sensitivity of the receptor Low Mitigation As a lot of materials in batteries can be recycled easily, recycling regulations aim at forcing the separation and re-usage of the materials in a battery in specialized facilities. As an example, 99% of the materials in lead-acid batteries sold in Germany are currently recycled. The recycling quota is lower for lithium-ion batteries, but in the waste treatment process, toxic substances are eliminated before storing the battery waste in landfills. As part of the WEEE Plan to be developed once the battery technology has been confirmed. NamPower may investigate the possibility of recycling in Namibia and within the regional context of SADC. Furthermore, in an effort to reduce impacts associated with battery waste the project will prioritize procurement of batteries from suppliers with a take back policy. In the instance where batteries are disposed of without returning to the supplier, only local recycling processors that adhere to appropriate 254M45AXZDHF-1404536467-161 87 BESS - NamPower methods of disposal and recycling will be used, and under the guidance of the original equipment manufacturer and as stipulated in the WEEE plan that will be developed for the project. The transport, storage, handling and disposal of the respective materials and components will be addressed in detail in the NamPower WEEE, once the battery type and technology is defined. Magnitude and significance post-mitigation The mitigation measures may allow reducing the impact’s frequency to “once” and its probability to “unlikely”: Therefore, the magnitude post-mitigation is classified as low. Based on the significance matrix, the significance of the residual impact (impact post-mitigation) is classified as low. MAGNITUDE - Impacts on ambient noise CONSTRUCTION | POST-MITIGATION Criteria Classification Scoring Spatial extent Local -1 Duration Short term -1 Frequency Once -1 Ability to Reversible -1 recover Probability Unlikely -1 Intensity Low -1 Sum -9 Magnitude of the impact Low Vs SIGNIFICANCE Low (see matrix) Sensitivity of the receptor Low 254M45AXZDHF-1404536467-161 88 BESS - NamPower 7.2 Summary of the impacts’ significance Table 7-1 show a summary of the significance of the impacts expected to be delivered by the project’s construction and operation. Whenever the significance post-mitigation is medium or high, the table indicates the need for compensation measures. Compensation and mitigation measures will be defined in the forthcoming ESIA. Table 7-1: Summary of the significance of the impacts of the project during construction CONSTRUCTION Significance of the impacts Feature Pre-mitigation Post-mitigation PHYSICAL ENVIRONMENT Topography Low Low Soil & Groundwater Low Low Surface Water Low Low Landscape and Visual None None Ambient Air Quality Low Low Ambient Noise Low Low BIOLOGICAL ENVIRONMENT Flora Low Low Fauna Low Low Natural Protected Areas Low Low HUMAN ENVIRONMENT Thermal Runaway and Fire Low Low Radiated Electromagnetic Emissions Low Low Occupational H&S Low Low Cultural heritage Low Low DECOMMISSIONING PHASE Battery and Disposal Medium Low 254M45AXZDHF-1404536467-161 89 BESS - NamPower 8 Consultation and Public Participation An important element of the planning and decision-making process is to involve the affected communities and keep the public informed. Stakeholder engagement, in form of a Background Information Document (BID), was sent to identified stakeholders on the 7th November 2023. The BID was sent to consult with the affected people, authorities and non-governmental organizations (NGOs) and identify any concern by any party. The initial communication of the BID was simply to establish whether any concern or comments are presents from known Stakeholders. NamPower will undertake a comprehensive a Stakeholder engagement process at the same time as applying for Environmental Clearance with MEFT. The decision was taken at this time not to engage the public at large as this may cause confusion when the MEFT application requires the same process. As part of a separate ESIA running as a parallel project to this BESS project, an Environmental and Social Impact Assessment for the Proposed 400 kV Transmission Line from Auas to Kokerboom Substation was undertaken by EnviroDynamics. Due to the larger project and more significant impact EnviroDynamics undertook a detail Stakeholder Engagement Plan10 and detail engagement process. The focused stakeholder strategy undertaken in this project was specifically done so as to dovetail into the SEP done by EnviroDynamics. NamPower is required to conduct a meaningful participation and consultation process that allows affected people and interested stakeholders to express their views and concerns on project risks, impacts and the proposed mitigation measures. At the same time, the process shall also enable the executing agency to take these views into account and to react. For the sake of transparency, the executing agency is required to disclose relevant information on the environmental and social assessment and a non- technical summary via appropriate media channels at an accessible location and in a timely, appropriate manner. The whole process shall be comprehensive and cover all phases of the project. The public participation process for this project aims to ensure that all persons or organizations that may be affected by, or are interested in, the proposed BESS project are informed of the issues and can register their views and concerns. 8.1 Identification of interested and affected parties. The site for implementing the BESS will be within an existing NamPower substation, at Lithops Substation in the Karas Region near Swakopmund. The site is located with no residential areas in the vicinity, the only nearest neighbours are mines. Consultation with the public forms an integral component of an environmental and social assessment and enables Interested and Affected Parties (IAPs) e.g. neighbouring landowners, local authorities, environmental groups, civic associations and communities, to comment on the potential environmental and social impacts associated with the operations and to identify additional issues which they feel should 10 Proposed 400kV Transmission line from Auas to Kokerboom Substations ESIA and ESMP - Stakeholder Engagement Plan and Report. Prepared for NamPower. Envirodynamics. 2023. 254M45AXZDHF-1404536467-161 90 BESS - NamPower be addressed in the detailed assessment phase. Consultation will be initiated and facilitated through notification letters, site and press notices and stakeholder meetings. The following stakeholders have been identified: ▪ NamPower ▪ Ministry of Mines and Energy (MME) as competent authority ▪ Ministry of Environment, Forestry and Tourism, (MEFT) as regulator ▪ Ministry of Agriculture, Water and Land Reform (MAWF) ▪ Ministry of Works and Transport (MWT) ▪ Ministry of Labour and Social Welfare (MLRS) ▪ Ministry of Health and Social Services (MHSS) ▪ Ministry of Industrialization, Trade and SME Development ▪ National Heritage Council (NHC) ▪ Regional Council of Erongo ▪ City of Arandis and Swakopmund as off-takers ▪ Adjacent Landowners - Usab Mine, Sahara Mine Dimension Stone, Khan Mine, Stone Africa Dimension Stone, Savanah Marble, Roessing Mine. 8.2 Steps in the Consultation Process According to the Environmental Management Act (Act No. 7 of 2007) and the respective EIA regulations and policies (Section 2.1), the following steps need to be undertaken: ▪ Identification of interested and affected parties (IAPs) (Section 8.1) ▪ Background Information Document ▪ Notification letters to stakeholders and relevant local authorities ▪ Press notice ▪ Site notice ▪ Stakeholder database ▪ Stakeholder meeting / Public consultation ▪ Public disclosure of assessment report ▪ (potential comments, response trail). The project shall additionally comply with the requirements of the WB regarding stakeholder engagement and information disclosure in a way proportionate to the nature and scale of the project and its potential risks and impacts. The requirements are described on the bank’s ESS 10 and summarized as: ▪ stakeholders are engaged throughout the project life cycle. ▪ such engagement commences as early as possible in the project development process. ▪ the engagement follows a timeframe that enables meaningful consultations with stakeholders on project design. ▪ all stakeholders will be engaged in meaningful consultations. ▪ stakeholders will be provided with timely, relevant, understandable and accessible information. ▪ consultation will be undertaken in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. 254M45AXZDHF-1404536467-161 91 BESS - NamPower Also following the WB ESS10, the process of stakeholder engagement must involve: 1. stakeholder identification and analysis. 2. planning how the engagement with stakeholders will take place. 3. disclosure of information. 4. consultation with stakeholders. 5. addressing and responding to grievances; and 6. reporting to stakeholders. Stakeholder engagement shall be in line with the Stakeholder Engagement Plan compiled by Enviro Dynamics for the RETF. 8.2.1 Background Information Document Interested persons must be notified about the project and the Scoping Report. Background Information Documents (BIDs) will be provided to IAPs. This document provides an overview and non-technical summary of the proposed development and act as an easy reference to proposed project information. This step was done at this time and the BID is attached to this report as Annex 1. 8.2.2 Notification letters The Environmental Commissioner (appointed by the Ministry of Environment and Tourism) can take care of the notification or can require that the proponent takes care of the notification and then provide the Environmental Commissioner with proof that it has been properly done. The notification must say that interested persons can view the full application and assessment report at the Office of the Environmental Commissioner. It must also invite interested persons to make written submissions to the Environmental Commissioner and give the deadlines for these submissions. 8.2.3 Press and site notice Information to a wider public was done by publication of a notice in local newspapers, by advertisements and posters. These were place in National Namibian newspapers on 27 th March 2024 and again on April 9th, 2024, refer to Annex 3 for copy of the advertisement. 8.2.4 Stakeholder database During the public consultation process, IAPs will be made aware of their rights to provide input into the assessment process through registering on the project and providing comments and concerns. The invitation to register as an IAP shall appear on all the press and site notices. The registered IAPs with those previously identified to be IAPs by the project (which received notification letters), comprise the stakeholder list for the project. 8.2.5 Public consultation It was decided to hold a public hearing on the report, and to carry out a process of public consultations. 14 days’ advance notice was given to all identified stakeholders. Public notice of the meeting was published 14 days in advance, with the date, time and place of the hearing and a brief description of the proposed activity which is under consideration. This process is intended to make sure that everyone with 254M45AXZDHF-1404536467-161 92 BESS - NamPower an interest in the proposed activity had a fair chance to have a say. The public consultation meeting was held on the 9th April in Swakopmund, at the MTC Dome. The following attendees at the public meeting were recorded (Annex 4 for attendance register): 1. Elifas Iilende 2. Christina Mansfeld 3. Onesmus Jacobus 4. Marlon Izaks 5. Linekela Haipinge 6. Niita Hamunyela 7. Sharlien Tjambari 8. Isabel Bento 9. Isidor Shilongo 10. Adolf Kaure 11. Renate Rengura 12. Rainer Horsthemke 8.2.6 Public disclosure of ES Scoping Report The notification stated that interested persons can view the full application and assessment report at the NamPower. Persons and parties who may be affected by the proposed project must be given a chance to inspect the assessment report and given the opportunity to make submissions on it. The comments received from stakeholders were recorded, responded to and reflected in this updated and revised ES Scoping report. 8.2.7 Comments received from stakeholders The following individuals and company’s responded acknowledging that they had received the information regarding the BESS and Lithops substation and would respond should any concerns arise: ▪ Annelize Swart - Executive Assistant at the Municipality of Swakopmund ▪ Gerhard Coeln - GeCoCo (Gerhard Coeln Consulting) ▪ Esleen Guriras - Property Clerk & Acting PA to CEO of Arandis The only queries came from Sharlien Tjambari a Journalist at the Namib Times, she requested additional information about the project and had some questions for the article, these as well as feedback are reflected in Annex 5. 254M45AXZDHF-1404536467-161 93 BESS - NamPower 9 Environmental and Social Management Plan The potential environmental and social impacts of the project, as described in Section 7, can be avoided, minimized, mitigated or compensated by performing suitable measures. This chapter describes a set of indicative mitigation and monitoring measures (Section 9.2) to be undertaken during the pre- construction, construction, operation and decommissioning of the project. These measures will need to be updated once the project location is known. 9.1 Institutional Requirements Table 9-1: Overview of Institutional Entities AGENCY RESPONSIBILITY Office of the Issue of Environmental Clearance Certificate (ECC) based on the review of the Environmental Environmental Assessments (EA) reports prepared in accordance with the Environmental Commissioner (OEC), Management Act (2007) and the Environmental Impact Assessment Regulations, 2012. Ministry of Conduct participation and consultation process that allows affected people and interested Environment, Forestry stakeholders to express their views and concerns on project risks, impacts and the and Tourism (MEFT) proposed mitigation measures and public disclosure of project documents related to environmental and social risks. Ministry of Mines and Is responsible for development and implementation of wider electricity industry Energy (MME) legislation and institutional mechanism including – the overall exercise control over the electricity supply industry and to regulate the generation, transmission, distribution, use, import and export of electricity in accordance with prevailing Government policy so as to ensure order in the efficient supply of electricity. Electricity Control Falling under the Ministry of Mines and Energy (MME). The Electricity Control Board (ECB) Board (ECB) is a statutory regulatory authority established in 2000 under the Electricity Act 2 of 2000; which has subsequently been repealed by the Electricity Act, 4 of 2007; the latter Act having expanded the ECB mandate and core responsibilities. The core mandate of the ECB is to exercise control over the electricity supply industry with the main responsibility of regulating electricity generation, transmission, distribution, supply, import and export in Namibia through setting tariffs and issuance of licenses. The ECB executes its statutory functions through the Technical Secretariat headed by the Chief Executive Officer. NamPower NamPower is a state-owned enterprise, registered and operating according to the Companies Act. NamPower’s core business is the generation, transmission and energy trading within the Southern African Power Pool (SAPP). NamPower supplies bulk electricity to mainly Regional Electricity Distributors (REDs), and to Local Authorities and, Farms (where REDs are not operational) and Mines throughout Namibia. Regional Electricity A RED is a regional electricity distributing company tasked with supplying electricity to the Distributors (REDs) residents in a specific region. In the central and southern regions where REDs have not Northern Regional become operational yet, NamPower is responsible for the MV electrification and bulk Electricity Distributor supply to local authorities, villages and settlements. (NORED), Central Northern RED (CENORED) and Erongo RED Ministry of The Directorate of Resource Management within the Department of Water Affairs (DWA) Agriculture, Water at the MAWF is currently the lead agency responsible for management of surface and and Land Reform groundwater utilization through the issuing of abstraction permits and wastewater disposal permits. DWA is also the Government agency responsible for water quality monitoring and reporting. 254M45AXZDHF-1404536467-161 94 BESS - NamPower 9.2 ESMP The following tables present an indicative environmental and social management plan which includes: a) information on any proposed management, mitigation, protection or remedial measures to be undertaken to address social and environmental impacts that have been identified. b) as far as is reasonably practicable, measures to rehabilitate the environment affected by the undertaking of the activity or specified activity to its natural or predetermined state or to a land use which conforms to the generally accepted principle of sustainable development; and c) a description of the way the applicant intends to modify, remedy, control or stop any action, activity or process which causes adverse social impacts, environmental pollution or degradation, and offset social impacts and remedy the cause of pollution or degradation and migration of pollutants. Management and monitoring measures are presented for pre-construction, construction, operation and decommissioning phases. This distinction allows providing the different project actors with compartmented and, consequently, easier-to-understand information about their responsibilities. 254M45AXZDHF-1404536467-161 95 BESS - NamPower Table 9-2: Indicative ESMP - Mitigation and Monitoring Measures during pre-construction Environmental Management and Monitoring Plan E&S Responsible for Mitigation and/or compensation measures, Monitoring Action, Procedure/Type Aspect/Recept Potential Impact/ Negative Impact implementation Management Action of Management or Land No land acquisition is required for the No mitigation anticipated. NamPower / A grievance mechanism may be Requirements project site. Contractor required. Vegetation The land requirements result in site- • Limit vegetation clearing to areas within the site boundary. Contractor Site inspection prior to clearing specific construction issues such as the • Only clear where it is strictly necessary. commencement of activities. removal of vegetation. Marking the borders of works site In case of the Lithops site, vegetation boundaries. clearing will be restricted to a few individual • Clarify with responsible authorities whether a license is Contractor Site inspection prior to plants as the site was previously cleared needed. commencement of activities. and is in a low vegetation habitat. • Describe the methods of vegetation clearance. Site inspection during site clearance. • Ensure that no chemicals/pesticides are used, burning of No use of fires or chemicals on site; vegetation is restricted etc. usage of warning signs. • Do not clear vegetation more than two months in advance of operations. Archaeological No archaeological chance find is expected at Develop a chance finds procedure and ensure all finds of cultural Contractor Site inspection during Chance Finds Lithops site. heritage (e.g. graves, old ceramic, old building fragments) are excavation activities. Notification reported immediately to the relevant authority and avoid records to relevant authority. excavation in the neighbourhood of a chance find, fence the Training records, Records about chance find and await instructions from the competent authority. chance finds. Human The construction activities may result in • Job opportunities shall be prioritized for residents, especially NamPower / Site inspection during pre- Environment need for local workforce. groups of people who live below the poverty line to get the Contractor construction activities. Potential risks that may occur related to the work they can do. Training records. arrival of workers from outside are the risk • Collaborate with the local government in involving local Grievance records. of human trafficking, GBV, child workers. Developed guidelines. labour and sexual abuse. • Provide training for certain types of work (capacity building). related to human trafficking, sexual • Prioritize buying food items from residents, e.g. vegetables harassment, GBV and child abuse. to meet consumption needs for employees. Security Personnel Management • Promote fair treatment, non-discrimination, and equal Plan developed. opportunity of project workers, including vulnerable workers such as women, persons with disabilities, migrant workers, etc. as appropriate and to prevent the use of all forms of forced labour and child labour. • Establish a grievance mechanism. • Regarding the issue of human trafficking, sexual harassment, GBV and child abuse, the project shall make guidelines and 254M45AXZDHF-1404536467-161 96 BESS - NamPower Environmental Management and Monitoring Plan E&S Responsible for Mitigation and/or compensation measures, Monitoring Action, Procedure/Type Aspect/Recept Potential Impact/ Negative Impact implementation Management Action of Management or monitor outsiders not to be involved in these illegal activities. • In case security services are contracted, assure that those providing security are not implicated in past abuses, are adequately trained, have an appropriate conduct towards the citizens and other workers, and act within the applicable law. Labor and All Project phases involve the employment • Promote fair treatment, non-discrimination, and equal NamPower / Site inspection during pre- Working of personnel. All activities of the involved opportunity of project workers, including vulnerable Contractor construction activities. Conditions parties must comply with the listed ILO core workers, such as women, persons with disabilities, migrant standards. workers, etc. as appropriate and to prevent the use of all Guidelines for labour recruitment forms of forced labour and child labour. and employment system in line with • The contractor must establish guidelines for the labour ILO cores standards. recruitment and employment system in line with ILO core standards that include no use of forced labour, no Guidelines related to human discrimination, no child labour, equal pay for women and trafficking, sexual harassment, GBV men, respect of working hours and respect of freedom of and child abuse available at project association and right to organize. site and included in training • Regarding the issue of human trafficking, sexual harassment, material. GBV and child abuse, the project shall make guidelines and Review of grievance records. monitor outsiders not to be involved in these illegal Visual inspection on regular basis. activities. This issue should also be discussed during public consultations to create awareness within the communities. • Prohibit the involvement of children (minimum age 18 years) in working directly or indirectly on the project and enforce this prohibition. • In case security services are contracted, assure that those providing security are not implicated in past abuses, are adequately trained, have an appropriate conduct towards the citizens and other workers, and act within the applicable law. • Establish a grievance mechanism. Health & Safety Construction activities may pose a risk to • The contractor shall develop and implement a site-specific NamPower/ Notification records to relevant (H&S) the health, safety, and well-being of Health & Safety Management Plan. Contractor authority (e.g. road authority). workers on site and members of • Health & Safety manager on duty. To be consulted on site: Workers neighbouring communities. • Provide adequate, timely and regularly updated training and Code of Conduct, Fire Safety and briefings for workers on safety precautions. Emergency Response Plan, 254M45AXZDHF-1404536467-161 97 BESS - NamPower Environmental Management and Monitoring Plan E&S Responsible for Mitigation and/or compensation measures, Monitoring Action, Procedure/Type Aspect/Recept Potential Impact/ Negative Impact implementation Management Action of Management or • Notice of commencement of construction to the Ministry of Traffic Management Plan; and Labour at least 30 days prior to the commencement of Health and Safety Management works. Plan. • Construction site shall be fenced, and the entrance gates Security Personnel Management shall be guarded by security staff to prevent any Plan. unauthorized access to the site, thus also minimizing possible A grievance mechanism may be impacts on community health. required. • Inform population of settlements along public roads in Training records. advance, in case of transporting heavy equipment. Site Inspections. • Security arrangements to be guided by principles of proportionality, good international practice, and national law. • Develop and implement a site-specific Fire Safety and Emergency Response Plan. • Operate accessible Grievance Redress Mechanism and document all grievances and follow up until resolution in grievance logbook. Appropriate staffing to be planned. End-of-life • Procurement of batteries should prioritize manufacturer/ NamPower/ WEEE Plan11 battery disposal suppliers with a take back policy. contractor (Hazardous • E-Waste (WEEE) management plan to be developed which waste outlining disposal and recycling procedures (e.g. recyclable management) metals) that will be followed for end-of-life batteries. • 11 The WEEE Plan must be developed by NamPower during to the operations phase once all design and technical specifications are finalised. 254M45AXZDHF-1404536467-161 98 BESS - NamPower Table 9-3: Indicative ESMP - Mitigation and Monitoring Measures during construction Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management Considering ESS 1 and WB Standards and General HSE Guidelines Soil erosion by site preparation Ensure that work site boundaries and limits are Traffic Management works (land clearing, levelling) in accordance with plans and technical design as Plan agreed upon in advance. All construction activities should be carried out within Contractor Site Inspection Continuously NamPower / Soil boundaries. on site Contractor Restrict vehicle movements to paved roads and In presence of high wet roads. winds The construction activities will A Waste Management Plan shall be developed generate waste which has the prior to construction with measures to handle potential to affect the soils of the the different waste streams. The following basic project area physically and principles shall be considered in the WMP: chemically. The following • A waste management hierarchy of waste streams are expected: avoidance, minimization, reuse, recycling, excess soil or rocks from levelling: treatment and disposal plant debris; construction waste • Segregation of all waste based on their Waste Management like unused / unusable nature and ultimate disposal sites. NamPower / Plan construction material, wood from • Ensure that hazardous materials are stored Weekly Contractor frameworks, maintenance waste, in proper areas and in a location where they Contractor packaging material, empty cannot reach the soil surface in case of Site Inspection containers, etc. accidental spillage. This means storage Soil hazardous waste: fuel, engine oil, facilities that are of hard impermeable and lubricants; drums and surface, flame-proof, with 110% containers (of hazardous and non- containment capacity, accessible to hazardous materials); authorized personnel only, locked when not domestic/household garbage; in use, and prevent incompatible materials domestic wastewater. coming in contact with one another. • good technical planning to minimize the generation of construction waste. • staff training to increase awareness of waste management hierarchy and procedures, segregation, storage, and labelling issues. • inspecting and auditing principles. 254M45AXZDHF-1404536467-161 99 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management • A register of all hazardous materials used Waste Management must be present at any time. Spilled Contractor Plan Weekly NamPower / material should be tracked and accounted. Contractor Site Inspection The following measures shall be included in the WMP: • The construction waste shall be reused as much as possible on site. • Any construction debris generated shall be Waste Management sorted by type managed and ultimately Plan disposed, reused or recycled in accordance Continuously with the WMP. Contractor • Incorporate drip pans at machinery, Site Inspection NamPower / equipment, and areas that are prone to Contractor contamination by leakage of hazardous materials (such as oil, fuel, etc) • Regular maintenance of all equipment and machinery used onsite. Maintenance activities and other activities that pose a risk for hazardous material spillage must take place at a suitable location (hard surface) with appropriate measures for trapping spilled material. • Prohibit fly-dumping of any solid waste to Waste Management the land. Plan • Distribute an appropriate number of bins Daily and containers, each designed to securely Contractor contain waste and properly marked with Site Inspection NamPower / the type of waste they are intended for. Contractor To handle hazardous waste: • Store the hazardous waste on separate locations on site with the following characteristics: 254M45AXZDHF-1404536467-161 100 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management • Labelled, enclosed and impermeable Waste Management containers. Contractor Plan Continuously NamPower / • Floor made of impermeable material. Contractor • Safety sheets available on the containers. • Final transport and disposal to be done by Site Inspection an authorized company. • Agree with the supplier of oils, and other hazardous materials to take back the empty drums after construction. • Drain the oil filters to remove the excess oil. • Deliver used oil to companies that are accredited to recycle it. • Ensure that a minimum of 110 % of spill absorbent is available at hazardous material storage facility. • If spillage occurs, spill must be immediately Waste Management contained, cleaned-up, and contaminated Plan soil disposed as hazardous waste. Contractor Continuously NamPower / • Ensure all works carried out minimize Contractor pollution risk (e.g. liquid effluents, air Site Inspection emissions, noise and vibration management, vehicle and equipment maintenance and selection, fuel, oil and chemical storage and handling). • Store construction material (bags of cement etc.) in containers. The Construction Contractor shall deposit excess soil at existing landfills after agreement with the regional authorities concerning the quantity and types of waste to be deposited. NamPower / Maintain records and manifests that indicate Contractor Prevention, planning Continuously Contractor volume of waste generated onsite, collected by contractor, and disposed of at the landfill. Numbers are to be consistent to ensure no illegal dumping at the site or other areas. Considering WB ESS 2 & ESS 4 and General HSE Guidelines (Waste Management, Hazardous Material Management) 254M45AXZDHF-1404536467-161 101 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management The construction works will cause Apply adequate general noise suppressing noise emissions during clearing, measures which could include use of well- trenching, movements of vehicles maintained mufflers and noise suppressants for and machinery, hauling, stringing, high noise generating equipment and machinery, NamPower / Noise welding, lowering, excavations, developing a regular maintenance schedule of all Contractor Site Inspection Daily Contractor concreting, backfilling, usage of vehicles, machinery for early detection of issues. pumps and compressors, etc. Considering WB ESS 2 General HSE Guidelines and HSE-Guideline: Construction Materials Extraction Construction activities will likely If dust or pollutant emissions are found to be result in an increased level of dust excessive, construction activities shall be NamPower / Contractor Site Inspection Daily and particulate matter emissions stopped until adequate control measures are Contractor due to temporary and permanent implemented. infrastructures during clearing, and Spray unpaved areas subject to vehicle movements of vehicles and movements with non-drinkable water in case machinery, excavations, dust suspension is visible and considered critical; NamPower / concreting, backfilling etc. If keep in mind that this activity must not result in Contractor Site Inspection Continuously Contractor improperly managed, there is a the formation of puddles, lead to rutting by risk of nuisance and health effects equipment or vehicles, tracking of mud onto to construction workers onsite and roads or siltation of watercourses. possibly nearby surrounding Cover the trucks transporting earth and loose NamPower / Contractor Site Inspection Continuously receptors from windblown dust. materials with tarpaulins. Contractor Air Quality Do not store earth and pulverous materials in Other impacts on the air quality NamPower / the open, ensure that material cannot be blown Contractor Site Inspection Continuously during construction are related to away. Contractor the air emissions derived from the Keep diesel generators further away from the diesel generators that will work to workers occupational areas. NamPower / Contractor Site Inspection Continuously provide energy to the workers Contractor camps and some construction Develop a regular inspection and scheduled Engines switched off equipment. maintenance program for vehicles, machinery, during breaks and and equipment to be used throughout the after work finished. NamPower / construction phase for early detection of issue to Contractor Review of grievance Weekly Contractor avoid unnecessary pollutant emissions. records, accident/ incident records and training records. 254M45AXZDHF-1404536467-161 102 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management Considering WB ESS 1 and WB General HSE Guidelines Temporary impacts may be caused No dumping of rocks or soils indiscriminately in due to the circulation of vehicles the vicinity or edge of the site. No new rock piles Landscape and machinery, presence of piles or soil dumps to be created from overburden or Continuously of excavated material, storage, waste materials from construction. All excess NamPower / and visual Contractor Site Inspection during borrow and deposit areas material to be removed to an approved waste Contractor aspects construction site. Considering WB ESS 6 and General HSE Guidelines Loss of vegetation within areas The construction activities shall be limited to the physically affected by the defined construction corridor and vehicle NamPower / construction activities. movements and storage of construction material Contractor Site Inspection Continuously Contractor outside of this site shall be prohibited. Terrestrial fauna injuries, death or temporary disturbances due to NamPower / construction activities. Hunting shall be prohibited for all. Contractor Site Inspection Continuously Contractor Avoid to the extent possible areas of ecological Site inspection value. Avoid natural habitats disturbance. Adjust prior to working times to only during daytime hours (no commencemen activities at night). Site Inspection t of activities NamPower / Contractor Biodiversity / Speed limits set to 20 km/h for construction and during site Contractor Biological vehicles on access roads, to avoid collisions with clearance Environment animals. Well maintained and noise-reduced machinery and technologies shall be used. Regularly Site Inspection NamPower / Contractor Contractor Improper management of The removal of vegetation should be reduced to construction activities could the minimum extent possible; it is forbidden to potentially disturb existing use any chemicals for this activity. In case of Upon NamPower / Contractor Site Inspection habitats (flora and fauna) within removal of vegetation or restoration of damaged occurrence Contractor the Project area. areas, restoration must be done with indigenous species from the wider area. Site Clearing Prior to the site being cleared and levelled an Contractor/ Prior to site NamPower / Site Inspection ecologist familiar with the central desert biome NamPower clearing Contractor 254M45AXZDHF-1404536467-161 103 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management should conduct an inspection to ensure that no endangered or vulnerable species are present. No fires may be used to clear any vegetation and NamPower / Contractor Site Inspection Continuously no open fires may be made at any time. Contractor Considering WB ESS 6 &ESS1 and General HSE Guidelines Natural General impacts related to losses Should any species of concern be identified, Protected Areas of protected flora and permits to be able to relocate must be obtained Contractor/ NamPower / disturbances and losses of prior to an on-going activity. Site Inspection Continuously NamPower Contractor protected fauna within protected areas Considering WB ESS 2, General HSE-Guideline and HSE-Guidelines: Occupational Health and Safety; Construction Materials Extraction Development of a Health & Safety Management Regular health Plan and a HSE team organigram showing HSE & personnel and responsibilities. safety • Execution of appropriate risk assessments inspections with all needed actions to prevent workers from possible incidents and accidents. CC Daily during • The construction activities will be supported construction. by a suitable health & safety management promptly Risks for the workers’ health and plan including and outlining all required Regular health & whenever safety during construction health & safety prevention and control safety inspections; accidents, activities and general procedures. HSE Plan in place. incidents and incident/accidents on and off- site; Contractor/ NamPower / • Availability and use of personal protective PPE used by everyone emergencies Occupational accommodation, worker´s rights, NamPower Contractor equipment on site; Training occur. Health and rules and obligations and • Availability of communication equipment performed and Safety employment standards, injuries • Appointment of HSE staff recorded; Project Owner - and accidents by lifting operations, • Appointment of first aid staff and monthly during working at height, working in availability first aid equipment construction. remote locations with slow rescue • Provision of training prior commencing any promptly chain work whenever accidents, incidents and emergencies occur The HSE Plan shall comply with requirements as Contractor/ NamPower / per WB General EHS Guidelines, as well as sector HS Site Inspections Daily NamPower Contractor specific WB HSE Guidelines (for Electric Power 254M45AXZDHF-1404536467-161 104 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management Transmission and Distribution), national legislation, and NamPower internal procedures and requirements. Train staff in H&S topics, conduct daily toolbox Contractor/ NamPower / talks, allow only qualified personnel for specific HS Site Inspections Daily NamPower Contractor tasks, provide respective PPE. Have a clear, understandable, and accessible Prior to Contractor/ NamPower / human resources policy HS Site Inspections construction NamPower Contractor works begin Communicate to all workers their working Contractor/ NamPower / conditions and terms of employment and HS Site Inspections Continuously NamPower Contractor provide them with pertinent documentation. Provide and make accessible a transparent Contractor/ NamPower / HS Site Inspections Continuously grievance mechanism for workers NamPower Contractor Make all security arrangements compliant with Contractor/ NamPower / HS Site Inspections Continuously the best international standards NamPower Contractor Provide adequate, timely and regularly updated Every time training and briefings for workers on before a occupational health and safety worker is hired After incidents and Contractor/ or changes to a NamPower / near misses, and NamPower new function Contractor inductions Regularly during construction Require the workers to use the provided Continuously NamPower / personal protective equipment Contractor HS Site Inspections during Contractor construction Report and record any accidents, incidents Continuously Contractor/ NamPower / and/or breach of relevant legislation HS Site Inspections during NamPower Contractor construction Assure that all workers have access to adequate, Continuously safe, and hygienic basic facilities on-site, with Contractor/ NamPower / HS Site Inspections during separate facilities for women and men, and that NamPower Contractor construction qualified first-aid can be provided Emergency and Response Plan shall include: 254M45AXZDHF-1404536467-161 105 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management • Assure the rapid availability of trained paramedical personnel, and emergency transport. • provisions for containment of hazardous materials stored on site (with containment capacity 110%) etc. • provision of emergency equipment such as first aid and medical kit, fire extinguishers, spill kits, etc., which will always be accessible during working hours and Contractor/ Emergency Response Regularly, at NamPower / provided in appropriate amount for the size NamPower Plan and HS Site least monthly Contractor of the site and number of personnel. Inspections • Ensure the workforce has access to primary healthcare, providing prescriptions and vaccinations. In case more than 35 workers are present on site, ensure that a hospital, medical clinic or a health centre can be reached within a period of 45 minutes. • responsibilities and communication procedures in the event of different types of emergencies. • information posters showing instructions for behaviour in case of different types of emergencies. • plan for emergency drills. • measures for restoration and cleanup of the environment following any major accident The ERP shall be reviewed on a regular basis (with frequency of 6 months and as necessary, Every 6 months e.g. based on lessons learned after a drill or an Contractor/ NamPower / Prevention, planning and as accident, change of responsible personnel, etc.). NamPower Contractor necessary 254M45AXZDHF-1404536467-161 106 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management Hygiene and Sanitary conditions Ensure the provision of hygienic and sanitary . facilities at the site, including shaded welfare Appropriate H&S and areas, bathrooms, changing rooms and potable sanitary facilities water. Ensure toilets and changing rooms are provided at site. separated between male and female employees. Regular and Contractor/ NamPower / random Ensure the provision of adequate space, supply NamPower Contractor Appropriate inspection of water, adequate sewage and garbage disposal conditions and system, appropriate protection against heat, infrastructure for cold, damp, fire and disease-carrying animals, workers on site (e.g. adequate sanitary and washing facilities, accommodation, adequate lighting, and basic medical services, in sanitation facilities, accordance with all applicable health and safety changing rooms etc.). regulations and norms. Review of grievance records. Report any occurrence of any communicable diseases amongst the workforce (STD, HIV/AIDS, Communicable TB, and Hepatitis B and C). Sensitize workers Diseases Register. through toolbox talks. Contractor/ Training performed Regular and NamPower and recorded. NamPower / random Contractor inspection Unlawful labour and working Developing and implementing of a clear, conditions understandable and accessible human resources policy in accordance with national labour and employment law (which will include any applicable collective agreements), including workers’ rights related to hours of work, wages (shall not be below minimum wage rate specified by Namibian government), equality of Contractor/ Prevention and Regular NamPower / wages between male and female workers, NamPower control inspections Contractor overtime, compensation and benefits, as well as those arising from the requirements of the World Bank ESS2; • procedure to ensure that all workers are in possession of a valid work permit in Namibia. 254M45AXZDHF-1404536467-161 107 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management • procedure to ensure that no children are employed according to Namibian regulations documenting of and communicating to all workers their working conditions and terms of employment. • respect the requirements of all existing national legislation on Occupational Safety and Health and international best practices, inclusive in the supply chain. • development of measures for emergency prevention, preparedness and response. Contractor/ Prevention and Regular NamPower / • providing and making accessible a NamPower control inspections Contractor transparent grievance mechanism for workers (and their organizations, where they exist) in accordance with this Scoping report Providing adequate, timely and regularly updated training and briefings for workers on safety precautions and their responsibility for their safety and the safety of others; · work specific safety procedures for all project activates, such as lifting procedure, working in and over water procedure if applicable, manual handling, working close to and in water, etc. Contractor/ Prevention and Regular NamPower / requirement for the workers and visitors to use NamPower control inspections Contractor the provided personal protective equipment, mandatory for all persons present on site (safety helmet, safety shoes appropriate for the type of work, high visibility vest), as well as additional required task-specific PPE; providing and maintenance of welfare facilities on each project micro location where works are being performed, e.g. mobile toilets; · reporting and recording of any accidents, incidents and/or breach of relevant legislation arising from the project assuring that all workers have access to adequate, safe and hygienic basic facilities 254M45AXZDHF-1404536467-161 108 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management onsite, and that qualified first aid can be provided any time; · assuring of the rapid availability of trained paramedical personnel, and emergency transport to nearest hospital Contractor/ Prevention and Regular NamPower / with accident and emergency facilities; ·ensuring NamPower control inspections Contractor that primary sub-contractors and first-tier suppliers uphold the same principles. Project proponent shall ensure, in case of any accident/injury/loss of life, that the worker is Contractor/ Upon NamPower / Mitigation paid a minimum compensation as calculated NamPower occurrence Contractor under the national legal requirements. Considering WB ESS 4 & ESS 9, General EHS-Guideline and EHS-Guidelines: Community Health and Safety; Construction Materials Extraction Economy and It is recommended that the project makes use of employment the possibilities for renting of accommodation for the project personnel in the surrounding Contractor/ During NamPower / n.a. settlements. This could enhance positive NamPower construction Contractor attitude towards the project and contribute to local economy Hiring of local labour force during the construction phase of the project, subject to the Contractor/ During NamPower / n.a. availability of the required skills shall be NamPower construction Contractor prioritized. Considering WB ESS 8 and General EHS-Guideline Consultation with the local communities shall be undertaken to determine if small objects or sites related to cultural traditions exist along the Contractor/ During detailed NamPower / project area (like crosses placed in specific areas As needed NamPower design Contractor to mark a funeral procession, among others). Damages to known and unknown Cultural Heritage archaeological sites, buildings and Establish a Chance Find Procedure which should Prevention objects contain measures such as: Site inspection during One month -ceasing work as soon as historical and cultural excavation activities. Contractor/ before NamPower / sites, buildings, or objects are encountered Notification records to NamPower construction Contractor during earthworks or other construction relevant authority. works begin activities. Records about chance finds 254M45AXZDHF-1404536467-161 109 BESS - NamPower Environmental Management and Monitoring Plan Responsible Monitoring Action, E&S Potential Impact/ Negative Mitigation and/or compensation measures; Frequency of Responsibility for Procedure/ Aspect/Receptor Impact Management Action monitoring for monitoring implementation Type of Management -providing relevant information to the MEFT. The Ministry will then determine the value of the historic/archaeological monuments and provide guidance on if and how to proceed with the construction. 254M45AXZDHF-1404536467-161 110 BESS - NamPower Table 9-4: Indicative ESMP - Mitigation and Monitoring Measures during operation Environmental Management and Monitoring Plan Responsible for Monitoring Action, E&S Mitigation and/or compensation measures; Potential Impact/ Negative Impact implementation Procedure/Type of Aspect/Receptor Management Action Management Landscape The operational BESS is being installed in compact containers and does not include no visual impact expected any components of height. The existing substation facilities are taller in height. Noise and Air The BESS will emit acoustic noise into their NamPower Regular noise Component selection: Special low-noise cooling Quality vicinity when in operation from power measurements. compressors, fans and transformers. transformers, cooling compressors and • Erection of physical barriers fans. • Provision of ear protection equipment to maintenance Noise can affect stakeholders and cause staff. potential health implications. Labor and All Project phases involve the employment Promote fair treatment, non-discrimination, and equal NamPower / Site inspection during Working of personnel. All activities opportunity of project workers, including vulnerable Contractor operation. Conditions of the involved parties must comply with workers such as women, persons with disabilities, migrant Review of grievance the listed ILO core standards. workers, etc. as appropriate and to prevent the use of all records. Visual forms of forced labour and child labour. inspection on regular • The EPC contractor must establish guidelines for the basis. labour recruitment and employment system that Implementation of comply with ILO core standards that include no use of Security Personnel forced labour, no discrimination, no child labour, Management Plan. equal pay for women and men, respect of working hours and respect of freedom of association and right to organize. • Regarding the issue of human trafficking, sexual harassment, GBV and child abuse, the project shall make guidelines and monitor outsiders not to be involved in these illegal activities. This issue should also be discussed during public consultations to create awareness within the communities. • Prohibit the involvement of children (minimum age 18 years) in working directly or indirectly on the project and enforce this prohibition. 254M45AXZDHF-1404536467-161 111 BESS - NamPower Environmental Management and Monitoring Plan Responsible for Monitoring Action, E&S Mitigation and/or compensation measures; Potential Impact/ Negative Impact implementation Procedure/Type of Aspect/Receptor Management Action Management • In case security services are contracted, assure that those providing security are not implicated in past abuses, are adequately trained, have an appropriate conduct towards the citizens and other workers, and act within the applicable law. • Establish a grievance mechanism. Hazardous substances in the form of • Some lithium-ion batteries under development use an NamPower Depending on the chemicals are an integral part of the aqueous electrolyte which significantly reduces the selected workings of batteries. Lithium batteries hazards associated with organics and acids. technology / supplier. may contain heavy metals such as cobalt • Lithium-ion batteries require battery management and manganese, as well as an organic systems to monitor and protect cells from solvent solution of lithium perchlorate, overcharging or damaging conditions. acetonitrile solution with lithium bromide. • Large BESS systems should be designed with In the event of containment failure, appropriate fire detection and suppression systems. hazardous substance may contaminate surrounding water resources as well as soil. Lithium, for example, causes long-term biodegradation. Hazardous Emissions may arise due to reactions • Large BESS should be in an isolated location or NamPower Depending on the Substances occurring within the battery. If over- containerized with battery management, and selected charged, batteries have a high explosion monitoring systems. technology / supplier. risk, due to the emission of hydrogen. This • Fire Safety and Emergency Response Plan, depending poses risks to both air quality and to the on the selected technology. health of battery operators and workers on site. Maintenance of batteries may result in the • E-Waste (WEEE) management plan to be implemented EPC Contractor Depending on the generation of waste which will need to be which outlines disposal and recycling procedures (e.g. selected disposed of. Hazardous waste has severe recyclable metals). technology / supplier. negative impacts on the environment. • Maintenance personnel should be properly trained, Maintenance of batteries will also have a knowledgeable in hazardous materials and have the degree of risk in terms of spillages during necessary equipment to deal with leaks and spills. the maintenance procedure. These pose • Maintenance of lithium-ion batteries is generally risks to the ecosystem and to the health of limited to replacement (and disposal) of battery cells 254M45AXZDHF-1404536467-161 112 BESS - NamPower Environmental Management and Monitoring Plan Responsible for Monitoring Action, E&S Mitigation and/or compensation measures; Potential Impact/ Negative Impact implementation Procedure/Type of Aspect/Receptor Management Action Management battery operators due to the hazardous at the end of life. nature of the chemicals used. • Fire Safety and Emergency Response Plan, depending Lithium-ion batteries require low on the selected technology. maintenance and are generally • The owner may request the supplier to provide a considered field replaceable warranty for certain parts or whole modules, in case components. When exposed to of failure of parts before end-of-life time. water and air (moisture), lithium • The project should have a set aside for emits flammable gases; therefore, decommissioning and disposal, e.g. in form of a maintenance procedures may result reserve account. in safety risks. Overheating / Lithium batteries are subject to thermal • Conduct a fire risk assessment once the battery NamPower Depending on the Fire / Lightning runaway and can rapidly overheat if technology has been confirmed selected operated outside of normal parameters. • Fire Safety and Emergency Response Plan, depending technology / Most lithium batteries use organic on the selected technology. supplier. electrolytes, which are combustible. • An adequate number of Class A and Class D fire extinguishers shall be installed on site. • Personnel shall be trained in the correct emergency response procedure and fire fighting techniques in the event of a fire associated with the BESS. 254M45AXZDHF-1404536467-161 113 BESS - NamPower Table 9-5: Indicative ESMP - Mitigation and Monitoring Measures during de-commissioning Environmental Management and Monitoring Plan Responsible for Monitoring Action, E&S Mitigation and/or compensation measures; Potential Impact/ Negative Impact implementation Procedure/Type of Aspect/Receptor Management Action Management Visual Impact & Modularized and packaged systems offer • Site restoration would include infrastructure removal NamPower Site inspection Landscape ease of system removal from site for and revegetation of cleared areas, where possible using disposal at end of life. Site contamination is native species. unlikely. • Rehabilitate borrow areas, backfill material stockpile sites and access roads, where applicable. • Spill Prevention Plan and respective equipment in place. • Train staff in handling of hazardous materials and spill prevention. Hazardous Disposal and/or recycling will highly • The disposal of hazardous substances will need to be at EPC Contractor / Depending on the Waste depend on the type of battery. Container a hazardous waste disposal facility. There are only a few Battery cell selected technology Management and infrastructure might be reusable. of these facilities in the country and will require a supplier / supplier. The materials used in Li-ion batteries are specific license. typically considered non-hazardous waste. • The recycling of lithium is an extremely complicated The metals in the system can be recycled, process, as the material is toxic, highly reactive and but they do not represent a high salvage flammable. Furthermore, due to the high costs of value. Certain materials within the battery recycling lithium and the associated risks, there is a can be recycled; however, a significant global absence of lithium recycling. Owners should amount will be disposed of. consider provisions for disposal at end of life to ensure proper disposal. There are currently a limited number of Hazardous landfill sites are generally the facilities that recycle lithium-ion batteries. Because main route for disposal of a hazardous lithium battery systems currently have negative scrap substance. However, other mechanisms value, it is important that the decommissioning plan is are available. These mechanisms include sufficiently well financed to cover the full costs of incineration and disposal of the decommissioning and removal from site. hazardous waste to land (not in a • Environmental regulations prohibit disposal of government owned landfill site). hazardous waste in general landfills, thus need to be These mechanisms will be governed by disposed of at a hazardous landfill facility. the NEMWA. • Some programs provide for disposal and decommissioning of battery systems at end of life. The The transportation of the hazardous waste project should have a set aside for decommissioning to either a recycling facility or a hazardous and disposal in form of a reserve account. 254M45AXZDHF-1404536467-161 114 BESS - NamPower waste disposal facility will have associated • The owner may request the supplier to provide a risks (contamination emanating from warranty for certain parts or whole modules. spillages). • Measures to be defined in an E-waste (WEEE) Management Plan, adjusted to the specific battery technology and transport routes. Which must be finalised prior to the construction 254M45AXZDHF-1404536467-161 115 BESS - NamPower 10 Cost Estimate of ESMP implementation Physical, biological and social management, mitigation and monitoring measures will be carried out during the pre-construction, construction and operation phases. The measures for physical and biological impacts overlap for the largest part, and therefore the price depiction shown below covers both issues. Decommissioning could range from partial to full removal of all BESS components; thus, costs cannot be estimated at this point of time. Decommissioning shall be done based on a Decommissioning Plan, which shall also include a respective estimate of costs. The total estimated cost for the management and monitoring plan, including the applicable VAT of currently 15% and a contingency budget of 5%, is 23,100 USD. The total cost estimation can be taken from the following table. Table 10-1: Total Estimated Costs for Environmental and Social Management & Monitoring Plan Estimated Cost (USD) Activities Pre-construction Construction phase Operation phase phase Management 1,500 2,000 - Physical and Biological Environment 2,000 3,000 - Social Environment 2,000 1,000 - Monitoring - 2,000 2,000 Training of local staff in HSE monitoring 2,000 1,500 1,000 Total 7,500 9,500 3,000 Total estimated cost 20,000 VAT 15% 2,000 Total incl. VAT 15% 22,000 5% Contingency Budget 1,100 Grand total 23,100 254M45AXZDHF-1404536467-161 116 BESS - NamPower 11 Conclusions and Recommendations The main potential impacts of the project may take place during the construction stage and could leak to contamination of soil and water (mainly during the transportation phase), and the impacts of health and safety on the workers through air and noise emission. The impacts on soil and water will be really easily to mitigate through implementation of the ESMP and Good Housekeeping. Insuring all employees and staff on site are fully equipped with proper PPE at all times will also protect them from air and noise emissions especially dust and particles in the desert environment. The few medium impacts that have been identified for the Lithops substation should all be able to be mitigated down to a low if all measures of the ESMP are implemented; it is not anticipated that there will be any severe environmental nor social impacts from the project. This Project does not require any resettlement aspects, nor livelihood restoration, as the land is already in possession of NamPower. Positive impacts of the project are related to creating job opportunities especially during the construction phase, it is not in anticipated that any new job opportunities will arise from the operational phase during this construction phase. With new investment the potential of training and more qualified workers could arise. The additional power storage will increase the total output and stability of the network in the Erongo region and especially support the energy usage of the mining industry which is an industry crucial to the Namibian economy. In summary it can be concluded that the proposed project can be implemented without having significant adverse impacts on the environment and if all mitigation and monitoring measures are implemented as recommended in the ESMP this project can mostly be positive in impact. 254M45AXZDHF-1404536467-161 117 BESS - NamPower 12 Reference List Biodiversity Impact Assessment for the Proposed Husab Mine Heap Leach Facility. African Wilderness Restoration (AWR), 2021. Liebenberg-Enslin, H. (2021). Husab P20 Heap Leach Project, Namibia: Air Quality Impact Assessment. Report done for SLR Environmental Consulting (Namibia) by Airshed Planning Professionals. Lindesay JA, Tyson PD. 1990. Climate and near-surface airflow over the central Namib. Pages 27-37 in Seely, M.K. (ed.) Namib Ecology: 25 years of Namib Research. Transvaal Museum Monograph No. 7. Environmental Impact Assessment Report for The Husab Mine Linear Infrastructure. Prepared for Swakop Uranium (Pty) Ltd. Metago. 2011 Proposed 400kV Transmission line from Auas to Kokerboom Substations ESIA and ESMP - Stakeholder Engagement Plan and Report. Prepared for NamPower. Envirodynamics. 2023. Mendelsohn, J., Jarvis, A., Roberts, C., Robertson, T. (2002). Atlas of Namibia. David Philip Publishers, Cape Town. Petavratzi E, Kingman S, Lowndes I. (2005). Particulates from mining operations: A review of sources, effects and regulations. Minerals Engineering 18: 1183–1199 SAIEA (2010). Strategic Environmental Assessment for the central Namib Uranium Rush. Ministry of Mines and Energy, Windhoek, Republic of Namibia. Scoping Report (Including Impacts Assessment) For the Proposed Changes to The Husab Mine and Linear Infrastructure. Report to the client Swakop Uranium, SLR, 2021. Shaanika, H. (2020). Assessing the likelihood that burrowing gerbils in the central Namib can be ecological engineers. Unpublished master’s Thesis, Namibia University of Science and Technology. SGS Bateman, (2021). Husab P20 Heap Leach Project Feasibility Study Report, M7556-0760-001REV A, s.l.: SGS Bateman (Pty) Ltd. Wassenaar TD, Mannheimer C. 2010. Biodiversity Impact Assessment at Swakop Uranium’s Husab Project. Unpublished Report to the client Swakop Uranium via SLR Environmental Engineers (previously Metago Environmental Engineers). Plants photographed elsewhere in Namibia (not on Kyffhäuser) https://www.kyffhauser.co.za/Plants3/Aloe_asperifolia/Image3.htm. Ministry of Environment, Forestry and Tourism, 2021. Management Plan for Dorob National Park 2021/2022-2030/2031. 254M45AXZDHF-1404536467-161 118 BESS - NamPower Annex 1 BID 254M45AXZDHF-1404536467-161 119 BESS - NamPower Annex 2 Client Background Information Document (BID) Logo NAMPOWER Battery Energy Storage Systems (BESS) 1. Aim of this Document This BID aims to provide stakeholders / Interested and/or Affected Parties (IAP) with the following information: − Brief description of the proposed project. − Motivation for/or desirability for the proposed project. − The potential key issues as identified during the initial assessment phase, both positive and negative which may arise as a result of the proposed project. Figure 1: Lithops Substation Location 254M45AXZDHF-1404536467-161 120 BESS - NamPower Figure 2: Typical containerized BESS Figure 3: Typical containerized BESS facility (source: smart-energy.com) 2. Introduction As part of NamPower’s short-to-medium term strategy to fulfil its future energy demand, NamPower is exploring the feasibility of the integration of Battery Energy Storage Systems (BESS) Project into the transmission network with an estimated capacity of 45 MW / 90 MWh and market standard lithium-ion technology. Fichtner has been appointed by NamPower to conduct the Environmental and Social Assessments for the Project and produce a scoping Report as well as Environmental and Social Management Plan (ESMP), as per the World Bank Environmental and Social Framework (ESF) and the respective Environmental and Social Standards (ESS) and Namibia’s Environmental Management Act No. 7 of 2007 and its Regulations. 254M45AXZDHF-1404536467-161 121 BESS - NamPower 3. Project Description and Motivation The Government of Namibia is committed to environmental protection and socioeconomic and sustainable development, as expressed, and articulated in the Environmental Management Act No. 7 of 2007, whose objective is to prevent and mitigate the significant effects of activities on the environment. The following two phases are being conducted as part of the project: d) Phase I: consisted of a detailed technical feasibility study to determine the required BESS application for integration into the grid, its operating concept, sizing, technology, location, and time of implementation to suit the Namibian energy market. This included aScoping Report and overview (Table of Content) of an Environmental and Social Management Plan (ESMP), a preliminary carbon credit and avoided emissions calculation, and a high-level financial feasibility assessment. e) Phase II: consists of the design basis report, the detailed financial feasibility study and economic modelling of the BESS project. This will serve as the basis for project appraisal by NamPower, as well as for NamPower’s discussions with the regulator (Electricity Control Board) on a suitable tariff regime to cover the long-term cost of the BESS project. This phase also includes the detailed project risk assessment report, detailed carbon credit and avoided emissions calculation, as well as the Scoping Report including an Environmental and Social Management Plan (ESMP) for submission to the Ministry of Environment, Forestry and Tourism (MEFT). A Battery Energy Storage System (BESS) is comprised of three major components: the battery which is the energy container; the power conversion system/inverter, which interfaces the DC battery system to the AC power system; and the power plant controller which governs, monitors, and executes the intended functions of the energy storage application. Since the BESS needs to be operated economically within the current power system, BESS must be designed to meet all economic, legal, and safety-related requirements that best suits its intended use case. BESS can be placed either in a building or module-wise within containers. In this present project, a container concept is planned. Several battery modules will be installed in one container with their respective cooling system, and battery management systems. It is estimated that a total area of approximately 2 hectares will be utilized at an existing substation of NamPower. 4. Project specifics The NamPower grid shows strong feasibility during normal operation. The final decision to install the BESS at Lithops substation is taken in terms of arbitrage. This is a suitable location for the BESS installation: - This location is close to high-loading mine area and the BESS could reduce the inrush current when the heavy machinery is connected. - Power fluctuations from upcoming PV projects can be compensated directly at the source. 254M45AXZDHF-1404536467-161 122 BESS - NamPower - BESS will allow PV penetration to be increased beyond the current committed expansion plans in the region. The demand here for captive PV power plants is especially interesting due to the large industrial loads. 5. The Affected Environment The Lithops Substation falls within the Dorob National Park. The Lithops substation already belongs to NamPower, and no additional land would be required for the BESS. The BESS would be located at the Lithops SS with no additional access roads required for construction or operation and no other additional infrastructure needed either. The Dorob National Park was proclaimed in 2010 and covers the central Namib desert. This area also contains a few surprises. Extensive lichen fields are found north of Wlotzkasbaken and Cape Cross, while the Messum Crater in the north contains San rock paintings and archaeological sites from Damara nomads. Site visit and desktop review will be done to ensure that the site surrounding Lithops does not contain any Rock art, lichens, or plants such as the welwitschia as part of ensuring the immediate environment remain unaffected. 6. Potential Impacts Identified The following potential impacts may result from the proposed project. Table 1: Impacts Identified Impact Description Hazardous Hazardous substances in the form of chemicals (e.g. sulfuric acid) are an integral Substances part of the workings of batteries. Furthermore, the battery includes the use of heavy metals (lead). Noise The BESS will emit acoustic noise to their vicinity when in operation from power transformers and cooling compressors and fans. Disposal of Hazardous landfill sites are generally the main route for disposal of a hazardous Waste substance. However, other mechanisms are available. These mechanisms include incineration and disposal of the hazardous waste to land (not in a government owned landfill site). 7. Possible Mitigation Measures The following mitigation measures are envisaged to remediate the potential impacts associated with the proposed project. Table 2: Mitigation Measures Impact Proposed Mitigations Hazardous ▪ BESS should have secondary containment systems that prevent environmental Substances release following spill or damage. ▪ Some lithium-ion batteries under development use an aqueous electrolyte which significantly reduces the hazards associated with organics and acids. 254M45AXZDHF-1404536467-161 123 BESS - NamPower ▪ Lithium-ion batteries require battery management systems to monitor and protect cells from overcharging or damaging conditions. ▪ Large BESS systems should be designed with appropriate fire detection and suppression systems. Noise ▪ Component selection: Special low-noise cooling compressors, fans and transformers ▪ Barriers ▪ Provision of ear protection equipment. Disposal of ▪ Owners should consider provisions for disposal at end of life to ensure proper Waste disposal. There are currently a limited number of facilities that recycle lithium- ion batteries. ▪ The owner may request the supplier to provide a warranty for certain parts or whole modules. ▪ Some programs provide for disposal and decommissioning of battery systems at end of life. ▪ The project should have a set aside for decommissioning and disposal, e.g. in form of a reserve account. ▪ Decommissioning and Disposal costs at end of life should be considered and factored into any facility financial model. Disposal costs tend to increase with system size. ▪ Because lithium battery systems currently have negative scrap value, it is important that the decommissioning plan is sufficiently well financed to cover the full costs of decommissioning and removal from site. 8. How to register comments To register any comments as a stakeholder/ Interested and/or Affected Parties (IAP) for the proposed project, please submit in writing your complete contact details; your interest in the proposed project (direct business, financial, personal, etc.) as well as your comments and/or concerns to Fichtner as listed below: Fichtner: Christina Mansfeld NamPower: Connie Pandeni E-Mail Address: E-Mail Address: Christina.Mansfeld@fma.fichtner.de Connie.Pandeni@nampower.com.na Postal Address: Fichtner GmbH & Co. KG Postal Address: NamPower Center Sarweystraße 3 15 Luther Street 70191 Stuttgart P O Box 2864, Germany Windhoek Telephone Nr.: +27 (72) 4490353 Telephone Nr.: 061 205 2974 254M45AXZDHF-1404536467-161 124 BESS - NamPower Figure 4: Indicative location of BESS at Lithops substation 254M45AXZDHF-1404536467-161 125 BESS - NamPower Annex 3 254M45AXZDHF-1404536467-161 126 BESS - NamPower Annex 4 254M45AXZDHF-1404536467-161 127 BESS - NamPower Annex 5 254M45AXZDHF-1404536467-161 128 BESS - NamPower 254M45AXZDHF-1404536467-161 129 BESS - NamPower