started this petition to
Minister of Environment and Tourism Pohamba Shifeta,
Minister of Fisheries and Marine Resources Bernhardt Esau,
Ombudsman Adv. John Walters,
Office of the Environmental Commissioner
Please help stop marine phosphate mining! The dredging of 3‐6 metres of the sea floor over potentially 2233 square kilometres by just one company will cause direct irreparable destruction to the building blocks of the entire marine ecosystem causing direct harm to the food supply chain for fish, humans, endangered sea turtles and endangered marine mammals. What if more than one company is granted this same permission?
Namibia: Say No to Marine Phosphate Mining.
Our youth face a bleak future. Studies show that
by 2050 there may be no more fish in the sea because of what we are doing to
the ocean worldwide. This is bad news for the environment across the planet. In
a desert country like Namibia, this is a serious threat on a basic survival
level: fish are good for food security, especially in times of drought.
Yet, at this most critical time of drought, our
government is being asked by international marine phosphate mining companies to
compromise the integrity of Namibia’s environmental laws by promoting industry
that will directly and dramatically decrease the sustainability of the living
marine resources, leaving behind an ocean that cannot provide for current or
The Environmental and Social Impacts of
Marine Phosphate Mining
Worldwide, land based phosphate
mining and processing has left a serious pollution problem behind. This is
because phosphate rock contains various metals and radioactive elements. Among
these elements are heavy metals which include: Cadmium, Arsenic, Lead, Mercury,
Chromium, Vanadium, Selenium and two radioactive elements, Uranium and Thorium.
Levels of radioactive materials are typically much higher in marine phosphate.
Phosphate mining of the seafloor is a major concern
for leading marine scientists worldwide. In Australia, the Government of the
Northern Territory considered all seafloor mining as such a threat that a
moratorium was imposed while further environmental and risk assessments were
conducted. Namibia followed suit and also placed a moratorium on marine
phosphate mining in 2013 while a strategic environmental assessment was
conducted. Although this study is not yet complete, the Environmental
Commissioner has granted Environmental Clearance for a marine phosphate company
to go forward, despite the Minister of Fisheries and Marine Resources legal
request not to grant the Clearance.
This is after other countries have repeatedly
prohibited marine phosphate mining due to its dangerous implications for the
marine environment. In 2016, Mexico’s federal environmental authority denied a
license for the Don Diego marine phosphate mining project because the project
would destroy the seabed‐dwelling organisms on which the endangered loggerhead turtles feed.
Specialists and international experts have
identified significant and critical issues that require further investigation
and to date these have not been addressed by the companies seeking to mine
marine phosphates in Namibia. Some of the critical environmental impacts
Impacts on the Ocean
‐ Dredging of
3‐6 metres of the sea floor will cause direct irreparable destruction to the
building blocks of the marine ecosystem in the benthos layer causing direct
harm to the food supply chain for endangered sea turtles, endangered marine
mammals, fish and humans.
‐There will be
direct harm to hatcheries for fish species such as juvenile monk and hake.
‐ There are
serious potential negative effects on the spawning of fish.
‐ There are
serious potential negative effects of a disturbed ecosystem (turbidity) on
marine predators including hake and endangered African penguins.
of hazardous substances including radioactive materials, methane gas, and
hydrogen sulphide will directly kill wildlife and cause many commercial fish
stocks including hake and monk to be unmarketable and not sale quality as food
quality regulations for export are stringent.
‐ Plumes will
negatively affect zoo‐plankton, another building block of the Benguela current marine
ecosystem, further causing harm to marine wildlife including endangered marine
phosphate entering the water and acting like a fertilizer will increase algal
blooms and harm shellfish and other species.
‐ Change in
the nutrient balance in upwelling will affect the Benguela Current marine
ecosystem which relies heavily on the upwelling of nutrients which are
‐ Noise and
hazardous waste pollution will directly affect and potentially damage
endangered marine mammals irreversibly.
‐ Increase in
phosphate nutrients will increase algae and bacteria in the water making salt
for salt mining too poor of a quality for sale.
‐ Poor quality
sea water will hamper the aquaculture industry.
Impacts on the Land
-According to the Environmental Impact Assessment, 125,500 tonnes of phosphate and radioactive and other waste will be
discharged on shore during each week of operation, with the transfer to shore being
once every 2-3 days. These are radioactive substances that will certainly have
numerous environmental impacts, especially for human and environmental health.
‐ A buffer
pond containing radioactive substances is set to be placed by the
internationally protected RAMSAR site of Sandwich Harbour and a National Park,
causing direct harm to the legally protected land ecosystem.
‐ A pipeline
will cross through two National Parks carrying radioactive substances, further
exposing the public and the wildlife to radiation.
‐ A processing
plant and tailings dam by the sewerage works in Walvis Bay will disperse
radioactive materials and chemicals into underground water and through the air.
potential for flood events and sea level rise will cause radioactive and
chemical waste to be released throughout the town of Walvis Bay as well as into
the surrounding National Parks.
‐ Plans to
release waste products and seawater back into the ocean will cause additional
negative impacts on marine life.
requirements of 320 cubic metres of fresh non‐potable water per hour will impact on the
local desert communities and environment to which this fresh water is a vital
resource, especially in the hyper‐arid coastline during times of drought.
The Laws of Namibia are Being Blatantly
The Constitution states that the government must
maintain essential ecological processes and biological diversity on a
sustainable basis for current and future generations. The late honourable Chief
Justice Mahomed described the Constitution as a "...is a mirror reflecting
the national soul/the identification of the ideals and aspirations of a nation,
the articulation of the values bonding its people and disciplining its
government." Honourable President Hage Geingob, we appreciate that you
were recently quoted in agreement stating that “The environment is part and
parcel of Namibia’s foundation of democracy, peace and stability. It has been
so in the past, it is so today and will be so tomorrow. Protection of the
environment is enshrined in our Constitution.” Ignoring the Constitutional
provision which protects the environment would be like losing the soul of our
This Constitutional provision led to the
formation of the Environmental Management Act of 2007 and the Environmental
Impact Assessment Regulations of 2012. These laws protect the people and state
clearly that “the participation of all interested and affected parties must be
promoted and decisions must take into account the interest, needs and values of
interested and affected parties.” Interested and affected parties have raised
numerous concerns in the past and substantial concerns by the public and
scientists about significant effects have been effectively brushed under the
surface. Cumulative impacts of various activities on the marine and land
environment have also not been considered. An Environmental Impact Assessment
for the land component of the project has not been completed. Yet according to Namibian law, these studies
must be conducted prior to any decision being taken and the cumulative and
potential significant effects of activities on the environment raised by
concerned parties must be considered in time and carefully.
To date, public and
scientific consultation as part of the Environmental Impact Assessment process
has been inadequate and not in accordance with Namibian law, International
Seabed Authority guidelines, or International Best Practice standards. The
Environmental Commissioner of Namibia and the proponents of marine phosphate
mining have failed to conduct public consultation on the amended and
resubmitted Environmental Impact studies as required under section 6 of
Namibia's Environmental Management Act (2007), and sections 16 and 19 of the
Environmental Assessment Regulations (2012).
According to the Environmental Management Act of
2007, damage to the environment must be prevented and activities which cause
such damage must be reduced, limited or controlled. In addition, the law
enshrines the precautionary principle stating that all decisions must be made
with caution especially when there is a lack of full scientific certainty about
possible environmental degradation. The burden is on the marine mining
companies to remove all doubt of the environmental impact if they wish for the
mining projects to go forward. Yet, they have never made their verification scientific
reports available to the public or other interested and affected parties. Instead, they expect the government of
Namibia to ignore its own seriously concerned public and make a decision based
on reports that have not gone through a public consultation process as required
by law. The mining companies hope to gain a larger profit by ignoring the laws
Namibia's Vision 2030 warns of this and states
that it is unacceptable for there to be increasing pollution, coastal
degradation and biodiversity loss. It also states that it is unacceptable for
industry to become too powerful and exert pressure on the government.
Finally, the Environmental Management Act of
2007 states that renewable resources must be used on a sustainable basis for
the benefit of present and future generations. Fishing, aquaculture, tourism
and salt mining, when managed properly, have proven to offer a substantial
potentially sustainable benefit to the Namibian economy over the long‐term. In fact the fishing industry alone
offers $4.8 billion dollars in foreign currency earnings and directly employs
around 15,000 people. Yet marine phosphate mining is a direct threat to the
continued existence of these and other industries, such as tourism, as
demonstrated by a significant number of marine and social specialists.
According to Namibian environmental laws, the government is required to
prioritize industry that causes the least damage to the environment over
industry that causes more damage. Simply put, in no way must an unsustainable
short‐term option be adopted at the expense of the potentially sustainable
The government must not take its decisions
lightly. They are deciding what world Namibian children and future generations
will be faced with and how likely they will be to survive. In Namibia it is the
duty of the government to ensure a sustainable environment for current and
future generations. The government of Namibia must choose whether they will
fall under the pressure of international mining giants to ignore critical
provisions of law that protect the environment and the people of Namibia or
whether they will take pride in their entrusted duty under the Constitution to
ensure a sustainable environment for current and future generations. May the highest authorities in Namibia hear
the plea of the people and say no to marine phosphate mining once and for all.