SYNTHESIS AND ASSESSMENT OF INFORMATION ON THE BCLME
THEMATIC REPORT 3

INTEGRATED OVERVIEW OF DIAMOND MINING IN THE BENGUELA CURRENT REGION

B.M. Clark, W.F. Meyer, C. Ewart-Smith, A. Pulfrich and J. Hughes
AEC Report # 1016/1 March 1999

CONDITIONS OF USE

1. This report is the property of the UNDP who may publish it provided that:

   • Anchor Environmental Consultants (AEC) is acknowledged in the publication.

   • AEC is indemnified against any claims from damage that may result from publication.

   • AEC receives copies of any publications emanating from this work.

2. AEC will not publish this report without the prior written consent of the client. AEC may, however, use technical information obtained from the compilation of this report, but AEC will not identify either the client, or the subject of this study.

SCOPE
Barry Clark of Anchor Environmental Consultants (AEC) was commissioned by United Nations Development Programme (UNDP) to prepare an integrated overview of marine diamond mining in the Benguela Current region (Angola, Namibia and South Africa). The report was to include the following written terms of reference, received by AEC on September 28, 1998.

• A Historical Perspective

• Areas of Activities (inter-tidal, shallow-water, offshore)

• Key Players and Stakeholders

• Diamond Mining Techniques

• Operational Practices

• Economic and Social Importance

• Environmental Policy and Legislation

• Environmental Impacts of Activities on Fisheries and Ecosystem

• EIA procedures and Mitigation Measures

• Environmental Management Plans

• Conflict Issues and Resolution Mechanisms

The report was also to document:

• Key problems, threats and issues to the environment/ecosystem from marine diamond mining

• Gaps in knowledge (environmental management, monitoring, mitigation)

• Transboundary issues

Due to the confidential nature of much of the literature used, references are not specified in the text but are appended in a bibliography.

The study was undertaken by B.M. Clark, W.F. Meyer, C. Ewart-Smith, A. Pulfrich and J. Hughes. Sue Lane (Sue Lane & Associates), Dr Gabi Schneider (Ministry of Mines and Energy, Namibia), Alison Dehrmann (Department of Mineral and Energy, South Africa) and Dr Mick O'Toole (Ministry of Fisheries and Marine Resources, Namibia) commented on earlier drafts of the manuscript.

EXECUTIVE SUMMARY

Historical Perspective

• 1900's: Early diamond discoveries on the southern Namibian coast result in the start of terrestrial mining operations 

• 1920's: First diamonds are discovered on the South African coast, leading to a southward spread in mining operations

• 1960's: The first diamonds are recovered from the sea, initiating both small scale diver assisted mining in the nearshore zone and large scale dredging operations in the offshore zone off the coasts of South Africa and Namibia

• 1970's: International diamond market slumps resulting in a temporary cessation in offshore dredging operations, but onshore and small-scale diver assisted mining continues in the nearshore zone

• 1990's: As richer onshore deposits become exhausted, offshore mining operations recommence, initiating an increasing shift in emphasis from onshore to offshore operations

Major Players and Areas of Operation

• Currently, marine diamond mining operations are conducted only in South Africa and Namibia, largely controlled by a few large companies

• Major players in South Africa include De Beers and its affiliates, Alexkor and Trans Hex, with concession areas covering most of the west coast from Paternoster in the south (32°45'S) to the Orange River in the north, extending from 100 km inland out to 500 m depth offshore

• Major players in Namibia include Namdeb, Ocean Diamond Mining, Diamond Fields International and Arena Mining with concessions areas extending from 100 km inland to 3 km offshore, from the Orange River to 26°30'S

• Some prospecting has been undertaken off the Angolan coastline and several companies are negotiating the lease of potential mining areas, but no concessions have yet been allocated 

Mining Techniques and Operational Practices

Onshore Mining

• Onshore mining is undertaken via large-scale open cast mines, using heavy-duty earth moving equipment

• Overburden is first stripped off to expose underlying diamondiferous gravel, which is then collected and transported to centralised processing plants 

• Sometimes sea walls are used to extend terrestrial operations several hundred meters offshore of the original coastline

• Oversize tailings are generally deposited on mine dumps, while undersize material is pumped into slimes dams or directly into the sea

Nearshore Mining

• Diver assisted suction equipment is deployed from the shore or small boats to collect gravel from littoral and sublittoral areas down to a depth of ~30 m

• "Blowers" are sometimes used to give divers easier access to the underlying orebody 

• Diamondiferous concentrate is bagged and processed ashore while oversize and fine tailings are deposited overboard

• Nearshore mining is opportunistic and weather dependent, with divers generally operating fewer than 10 days per month

Offshore Mining

• Remote operated dredges or drills with airlift systems, deployed from large (50-140 m) self contained vessels, are used to collect gravel at depths of up 120 m

• Gravels are processed into a concentrate onboard which is sent ashore for hand sorting

• All tailings generated during the sorting process are discharged to sea

• Semi-mobile jack-up rigs and bulk dredges may be introduced in the future to mine lower grade ores

Environmental Policy and Legislation

• Mining and associated activities in South Africa and Namibia are regulated by a suite of legislative Acts designed to mitigate their effects on the environment, including requirements for Environmental Assessments (EA's) and Environmental Management Programmes (EMPs) 

• Additional legislation also controls pollution at sea, the use of landing facilities, access to the coastal zone, and damage to natural or cultural resources in these two countries

• No information was available regarding Angolan legislation at the time of writing

Environmental Issues, Impacts and Mitigation

• Marine diamond mining is the cause of a number of socio-economic and biophysical impacts in South Africa and Namibia, both positive and negative

• Major socio-economic benefits provided by the diamond industry include the creation of employment and tax revenue 

• Negative aspects include problems associated with the influx of people into small towns, lack of facilities for waste disposal, gaps created by the shifting emphasis from on- to off-shore mining, conflict with other resource users and the foreclosure of future land use options through aesthetic impacts

• Little has been done to mitigate problems associated with negative socio-economic impacts, but attention is being given toward developing alternative land-use options (e.g. tourism and mariculture), alternative skills training and conflict resolution mechanisms 

• The de-facto reserve status of the terrestrial diamond areas arising from restricted access represents the only major positive biophysical impact of diamond mining in the BCLME 

• In terms of the overall aerial extent, mining affects less than 1% of the concession areas in South Africa and Namibia per annum and negative impact are largely deemed to be of low significance

• Several negative impacts have been identified on a local scale, including impacts on vegetation and soils, generation of sediment plumes, disruption of littoral and sublittoral benthic communities, kelp cutting, conflict with the fishing industry and disturbance of marine mammals and birds

• Mitigation measures have been introduced to address most of these impacts

• Most of the larger diamond mining companies and many of the smaller operators already have, or are in the process of drawing up Environmental Management Plans

Diamond Mining in the BCLME - Toward Integrated Environmental Management

• Integrated Environmental Management, as it applies to marine diamond mining, is evolving with steady improvement, but a few criticisms are warranted 

Socio-economic Environment

• EMPRs have generally not taken due cognisance of socio-economic impacts

• Steps must be taken toward reallocating diamond mining revenue toward upgrading infrastructure, stimulating development in the areas most severely affected by mining and redressing racial imbalances in the industry

Biophysical Environment

• Shortcomings in terms of biophysical environmental management include the broad-scale nature of the baseline information, the desktop nature of most assessments and the high taxonomic level at which assessments have been undertaken (i.e. individual species may be ignored) 

Environmental Management as a Whole

• Cumulative impacts within the mining industry and amongst all users need to be addressed more fully

•  Regular audits need to be undertaken of EMPRs to ensure that they include the latest information and technology

Conclusions - The Way Forward

• In South Africa and Namibia, directed studies must be commissioned to address gaps in knowledge to improve integrated environmental management of activities in the BCLME

• The IEM process must be adopted in Angola and the necessary baseline information collected before marine and coastal mining is initiated.

 1. INTRODUCTION

The Benguela Current Large Marine Ecosystem (BCLME), situated off the west coast of southern Africa, is one of 49 LME systems that have been described around the world. LMEs are defined as large bodies of water (200 000-sq. km) with distinctive bathymetry, productivity and trophically dependent populations. The Benguela Current LME is one of the most productive of these systems, supporting an important global reservoir of biodiversity and biomass of fish, sea birds and marine mammals. 

Several issues of common concern to South Africa, Namibia and Angola, the three countries bordering the BCLME, are commercial fishing, recreation, diamond mining, oil and gas exploration and coastal zone development. These activities are putting escalating strain on the BCLME. With the advent of environmental concern, most countries have drafted legislation that seeks to ensure responsible and sustainable use of the environment for all users. The efficacy of both the legislation and enforcement, however, remain in question. A related concern is the potential for conflict between users of the BCLME, as escalating effort and technologies will see increasing overlap between the various sectors. With a view to resolving conflicts and responsible environmental management, there has been a call for an integrated and co-ordinated approach to the management of this system. To this end, the United Nations Development Programme has called for a Synthesis and Assessment of Existing Information on the BCLME, reviewing activities in the BCLME, their impact on the environment, and their management. This review will be used to assess the status quo, identify gaps and shortcomings in the management of activities affecting the BCLME, and direct further research, policy and funding through a Strategic Action Programme. 

This document forms a part of the synthesis and assessment phase reviewing marine diamond mining in the BCLME. Specifically, it traces the history and development of marine diamond mining; outlines the key players and their areas of operation; describes the methods and equipment employed in extracting marine diamonds; reviews the legislation relevant to diamond mining activities; outlines how these methods impact the environment; reviews conflict and mitigation; and finally, highlights gaps and shortcomings and suggests methods by which integrated management of the BCLME can be achieved. Emphasis is placed on marine-based activities, although terrestrial aspects are discussed briefly, as they also affect future marine and coastal users.

2. HISTORICAL PERSPECTIVE

Diamonds were formed aeons ago in the mantle of the earth, some 150-250 km below the surface. They are formed of carbonaceoyus material, subject to extreme heat and pressure, crystallised into diamonds as they were brought up to the surface in streams of molten magma. This diamondiferous magma, known as kimberlite spewed out in various places over the southern African subcontinent, solidifying on the surface and in magma pipes leading up to the surface. Over geological time (ca. 80 million years), this kimberlite material gradually eroded, with rivers carrying an estimated 3 billion carats of diamonds to the sea. Concomitantly, river mouths meandered up and down the coast, thereby building up extensive submarine deltas containing diamonds along much of the coast. Wave action removed much of the lighter and softer material, concentrating the heavier and harder material, such as diamonds, in beach terraces and paleo channels. Tectonic movements together with climatic changes resulted in immense fluctuations in sea level, and consequently diamonds became concentrated in a series of beaches or terraces both above and below the present day sea level, each terrace corresponding to former static sea levels. 

Diamonds were first discovered in South Africa in 1866 on a farm south of Kimberly. This discovery was followed by further finds of both diamond-bearing kimberlite pipes and alluvial deposits in the drainage system of the Vaal River. The first discoveries on the west coast of southern Africa only occurred 42 years later, however, when a railway construction worker, Zacharia Lewala, found the first diamond near Lüderitz in 1908. Picking up the shiny stone, he passed it to his supervisor August Stauch an employee of the Deutsche Koloniale Gesellenschaft (DKG) responsible for keeping the newly constructed railway between Lüderitz and Keetmanshoop clear of sand. On the 20th of June 1908 Stauch reported his find to the DKG and applied for prospecting licenses, which they granted. In January 1909 rich deposits were found south of Pomona, which was soon followed by the discovery of deposits in the Bogenfels region. Word soon spread and people flooded into the area and settlements sprung up out of the desert almost over night.

At the time of the discoveries, South West Africa (SWA, now Namibia) was under German jurisdiction, with the exception of the port of Walvis Bay and a series of 'guano islands' off the coast. In September 1908 the German government granted the DKG the sole right to search for and work mineral deposits between the Orange River in the south and 26ºS latitude in the north stretching 100km inland. This area, which became known as the Sperrgebiet, was fenced off and entrance was restricted to prevent the theft of diamonds. The Sperrgebiet remains closed to unauthorised persons today.

The Germans were to remain in control of SWA until WW1 when the territory was handed over to South Africa to Administer. In 1920 the Anglo American corporation of South Africa gained control of the diamond interests in SWA forming the Consolidated Diamond Mines of SWA (CDM).

The finds in the Lüderitz area inspired prospectors south of the Orange River in the new Union of South Africa. Eventually these efforts paid off, with discoveries by Jack Carstens near Port Nolloth in 1926. As mining and prospecting progressed in the Namaqualand region, Dr Merensky and Dr Reuning recognised the link between old marine terraces and diamond deposits. Armed with this information they soon discovered numerous rich deposits south of the Orange River mouth. These finds brought prospectors from the Lüderitz area to the beaches immediately north of the Orange River mouth. Here they were to find significant diamond deposits, and the focus of mining in the Sperrgebiet consequently shifted south, to what is today known as Mining Area 1.

It was not until 1961 that diamonds were mined offshore on the west coast of southern Africa. Sam Collins a rich Texan whose company specialised in submarine pipelines became interested in the theories that rich diamond deposits lay offshore of the Orange River mouth. His pipeline experience enabled him to develop techniques for dredging diamonds from the seabed. The feasibility of this venture was doubted, however, as it was accepted at that time that the deposits could not be mined economically. Sam Collins was not deterred and tenaciously stuck to the task, proving his critics wrong. His company Marine Diamond Company (Pty) Ltd successfully mined payable deposits in shallow water off Chamies and Bakers Bay. In the process he experimented with various sea going vessels, from small fishing boats, to large mining barges, to a converted 70 m ex-US Navy tank landing craft, using a combination of airlifts and centripetal pumps. Initially De Beers had thought that this would not be economical but admitted their error, eventually buying a controlling share of MDC in 1965. Soon after however, the diamond market slumped and MDC ceased offshore mining operations in 1971. Smaller scale operators continued to mine from converted fishing vessels, however, while De Beers continued prospecting in deep water areas.

Small-scale shallow water operations continued to increase steadily over the years, but deep-water offshore mining operations only really started again in the early 1990s. These deep-water operations now represent the pinnacle of technological development in the diamond mining industry, requiring dedicated mining vessels, complex electronic navigation systems and specialised remotely operated mining tools. Onshore diamond mining operations along the coast are also a far cry from their early beginnings when diamonds were first collected by hand on moonlit nights. At first diamonds were excavated manually using shovels, which were then screened by various sieving techniques. Gradually mechanical excavators and concentrating devices were employed to process the large volumes of sediment required. Today large mining plants process millions of tons of gravel per year, utilising heavy-media separation, cyclones and x-rays in the concentration process.

3. AREAS OF OPERATION AND MAJOR ROLE PLAYERS

The areas in which mining occurs in the Benguela ecosystem have been divided into 5 distinct categories and is discussed under two broad headings for the purposes of this document. These are defined as:
Onshore

• Terrestrial mining - mining above the high water spring tide mark (HWS)

• Beach mining - mining of beaches into the subtidal through the construction of sea walls (coffer dams)
  Offshore

• Shallow water mining - Operations to a depth of 30 m, further divided into:

  • Shore based mining - divers operating from the shore

  • Boat-based - divers operating from small boats

• Mid-water mining - 30-75 m depth utilising remotely-operated tools, mostly air-lift dredges 

• Deep-water mining - Operations deeper than 75 m, using customised mining vessels and specially designed remotely-operated mining tools

Diamond mining occurs across all of the above mentioned categories in distinct concession or license areas. Concession areas are allocated differently in Namibia and South Africa and these are discussed separately below with particular reference to the major role players involved. 

3.1 SOUTH AFRICA
3.1.1 Onshore Mining
Terrestrial concessions, including beach mining concessions, are mined between the Orange River mouth and an area slightly south of the Olifants River. Two major companies, Alexkor (a parastatal organisation which is currently being privatised) and De Beers Namaqualand (Pty) Ltd dominate diamond production along the shores of Namaqualand and the Northern Cape. Alexkor operates from the Orange River mouth to just south of Port Nolloth, while De Beers operates from Alexkor's border to slightly north of the Olifants River (Figure 1). Around these major concessions are a number of smaller concessions operated by companies like Trans Hex Investments (Pty) Ltd.

3.1.2 Offshore Mining
In South Africa the offshore concessions stretch from the border with Namibia off the Orange River mouth, to an area just south of Saldanha Bay (Figure 2). Each concession area is further split into four sub-areas in an offshore direction (Figure 3). The 'a' concession extends from low water to 31.5 m offshore, while the 'b' concession extends from the western boundary of the 'a' concession to a co-ordinated boundary approximately 5 km offshore (less from concession number 15-20). The 'c' concession runs from the western boundary of 'b' concession to the 200m isobath and the 'd' concession runs from the western boundary of 'c' concession to the 500m isobath.

The major players, including concession owners and concession operators in the offshore diamond industry of South Africa are listed in Table 1. Three companies dominate the offshore diamond industry: De Beers Consolidated Mines (mainly mid- to deep-water concessions), Alexkor (mainly shallow-water concessions) and Trans Hex (shallow and deep-water concessions). Other significant players are BHP-Benguela Nominees, Ocean Diamond Mining, De Beers Marine (undertakes all De Beers offshore operations), Namagroen prospecting, Benguela Concessions and Marine 17 Mining.

3.2 NAMIBIA
3.2.1 Onshore mining
Namdeb Diamond Company (Pty) Ltd (formally Consolidated Diamond mines of SWA) controls mining of the 'Sperrgebiet' under the Namdeb Agreement (1994). They have exclusive rights to prospect for and mine diamonds within the Sperrgebiet until the year 2010. The Sperrgebiet stretches from the Orange River in the south to latitude 26ºS in the north, extending 100 km inland (Figure. 4). Namdeb is a 50/50 partnership between De Beers and the Namibian government and is responsible for the majority of onshore production in the southern parts of the Sperrgebiet (immediately north of Oranjemund), in their beach mining operations. Some smaller contractors also operate onshore on the Namibian coast, but they mine predominantly in the northern license areas.

3.2.2 Offshore mining
Namibian offshore concessions cover the full length of counties coastline, extending from the Orange River to the Kunene (Figure. 5). Concession boundaries are not regulated by depth as in South Africa. Onshore mining licenses extend 3 km offshore, and Namdeb thus controls most of the shallow water mining activities (with the exception of the island concessions, which are operated by ODM). Offshore licenses are issued after specific application to government, which must include the co-ordinates of the intended mining area.

he major companies involved in the Namibian offshore diamond industry are Namdeb, Ocean Diamond Mining (ODM)(of which Eiland Diamante is a subsidiary), the Namibian West Coast Mining Company - Diamond Fields International (DFI) group, the Namibian Minerals Corporation (NAMCO) - Arena Mining group, and Tidal Diamonds (an associate company of Namdeb). Numerous other companies like De Beers Marine, Yam Diamonds (who also own their own concession) and Windvogel Diamonds mine mainly on contract to the larger players. 

3.3 ANGOLA
No coastal or offshore mining currently occurs in Angola. Prospecting and mining activities are continuing inland but the Angolan government has issued no licenses for coastal areas, preferring to concentrate their efforts on terrestrial operations.

Figure 1. Map of onshore diamond mining areas in the Republic of South Africa.

Figure 2. Map of the offshore concession areas of the Republic of South Africa. A key to the concession holders and operators is provided in Table 1 (provided by De Beers Marine).

Figure 3. Schematic representation of delineation of concession areas (modified from DME 1997)

Table 1. Diamond mining concession holders and operators in the Republic of South Africa.

Figure 5. Major coastal and offshore diamond mining concession areas of Namibia. (Original coverage provided by B. Beuthin, Geological Survey, Ministry of Mines and Energy, Namibia).

4. Mining Techniques and Operational Practices

Diamonds in the southern African coastal region are concentrated in the vicinity of paleo drainages, in bedrock gullies, potholes and depressions, along offshore ridges and south facing paleo bays, headlands and aeolian transport corridors. The greatest concentrations of diamonds usually occur near or on the bedrock. In order to retrieve diamonds, the overlying marine and terrestrial deposits (overburden) first has to be removed, followed by the collection of the diamondiferous gravel below. The techniques used to remove the overburden and to collect the gravel varies considerably according to where the gravel is located, the richness of the ore and the thickness of the overlying deposits. Basic distinctions can be drawn between operations conducted on land, and in shallow-, mid- and deep-water areas. These are elaborated separately below.

4.1 Terrestrial and Beach Mining
Onshore mining activities immediately adjacent to the coast are undertaken mostly using heavy-duty earth moving equipment, operational in large-scale open cast mines. Five fairly distinct phases are involved in the mining operation, including prospecting, overburden stripping, excavation of terrace gravels, mineral processing and sorting. The precise methods used in each of these phases has been developed and improved upon over the years and varies somewhat between areas and from company to company. What follows here is a generic description of the methods currently in use.

The major form of prospecting involves the drilling of small diameter percussion holes, followed in some cases with large diameter auger drilling and/or the excavation of trenches of varying depth and length. Overburden material from the trenches is generally deposited in overburden dumps on the surface next to the trenches and the underlying gravel is removed for processing. These three methods of prospecting are used to locate, intercept and sample the terrace gravels. As terraces have eroded erratically and diamond occurrence is sporadic, prospecting is generally undertaken in a closely spaced pattern in order to delineate the ore bodies accurately.

The next phase, overburden stripping, is done using a variety of earth moving machines including bowl scrapers, bulldozers, mass excavators and in some areas bucket-wheel excavators. Excavation is generally undertaken on a block-by-block basis and the overburden removed is dumped into trenches from which the underlying gravel has been removed; piled into overburden dumps; or used to create a seawall, extending the shoreline several hundred meters out to sea.

By constructing protective seawalls, gravels up to 20m below sea level and several hundred meters beyond the present shoreline can be recovered using terrestrial operations. Once the overburden has been removed, the bulk of the diamond bearing gravel is excavated mechanically. Deposits remaining in gullies and potholes on top of the bedrock are then swept and collected manually using pick, broom and shovel teams or using suction equipment. All the ore is transported to treatment plants where the gravel is crushed, washed, sieved and concentrated in a solution of seawater and ferrosilicone using heavy media cyclones. The gravel concentrate is then dried, sorted by means of x-ray machines and finally the diamonds picked out by hand. Gravel, from which the concentrate has been extracted, is disposed on tailings dumps, while water containing sand and fine sediment is discharged into slimes dams or pumped directly into the sea. Most of the ferrosilicone is recovered before it leaves the plants and is recycled in the process.

4.2 Shallow-water Mining
Shallow-water mining operations are conducted using small-scale, diver assisted suction equipment. Shore-based operators generally operate in the intertidal down to a depth of around 10 m, while the boat-based operators usually work in the 10-30 m depth range. This delineation is not strict, however, with the boat-based miners moving inshore in areas where access to the shoreline is difficult (where sea-cliffs abut directly onto the shore or in the offshore islands concessions).

The techniques used for shore- and boat-based operations are very similar, expect that boat-based operations generally employ larger equipment and more divers. A shore-based operation typically consists of 2-3 divers, their assistants and a tractor modified to drive a rotary classifier and centripetal pump to which an eight inch suction hose is attached. The divers, operating on surface-supplied diving equipment, guide the terminal end of the hose into the gravel deposits, which are sucked up and delivered directly to the classifier. Concentrate is bagged and brought to central sorting houses onshore. Large rocks are often moved by the divers (or pulled up onto the shore using a tractor) to allow the pump nozzle to reach deep layers of gravel where the heavy diamonds settle. Coarse material is allowed to build up on the shore, while fine material is returned to the sea. In some instances, kelp may be cut to facilitate access to shallow inshore ore bodies.

A typical boat-based operation consists of a 10-15m vessels with a 5-8 man crew, of which 2-3 are divers. The vessels are equipped with 1-2 hoses per boat, with the duration of their activities limited to daylight hours for 3-10 diving days per month. Some 20-22m vessels, offering surface decompression facilities and with 8-11 man crews, are also operational. These larger boats are able to work on a 24h basis for up to 21 days per month. However, due to the water depths involved, diving in nearshore mining operations necessitates strictly enforced decompression routines thereby limiting bottom working time. The diamondiferous concentrate is bagged onboard, and brought ashore for final processing in shore-based jig plants and sorting houses. On vessels operating further afield, the initial jigging may be conducted on board. Oversize tailings are either returned directly overboard to the mined area or transported further offshore in inflatable boats and dumped. The fines are washed overboard. In the mining process large rocks may either be exposed, or removed by divers to allow the suction nozzle to reach deeper gravel layers. The rocks are sometimes accumulated by the divers into rock piles.

Shallow-water mining is opportunistic in nature and highly dependent on weather and sea conditions. Due to the difficulty of employing modern geophysical survey techniques and large-boat sampling in shallow water nearshore areas, exploration and investigation in water depths <30m, is generally limited to irregular side-scan sonar mapping and prospecting dives from the shore or from small boats. These surveys are often based on historical recoveries. Small-scale sampling is undertaken by diver-assisted dredging, the gravel being bagged and processed ashore. Many of the nearshore operations are currently being enhanced by more sophisticated tracking and positioning systems to help focus efforts on the more productive areas. Both shore- and boat-based miners generally only operate in exposed rocky shore areas where gravel is pumped from deeper gullies, or on the edges of sandy bays where the layer of overburden is relatively thin. Mining off sandy beaches is generally unprofitable for these small-scale operators due to the large volumes of overburden that have to be removed before it is possible to gain access to the heavier gravel. However, the use of underwater 'blowers' to shift overlying fine sediment, initially used only when operating in shallow water (<8 m depth), is becoming more widespread as it allows for the exploitation of gravel deposits which were previously uneconomic to recover.

4.3 Mid-Water and Deep-Water Mining
A variety of methods are used to mine marine diamond resources in water depths >30 m, which may be split into mid-water operations (down to a depth of 75 m) and deep-water operations (down to a depth of 200 m). The geophysical survey and prospecting methods in use are similar for both regions, and include high resolution side-scan sonar, shallow reflection seismic profiling, video, vibrocoring, rock drilling and grab sampling. The resulting data are used to produce maps of the seabed geomorphology, sediment and bedrock distribution, bathymetry and sediment type and thickness profiles. From these maps, areas of unconsolidated sediment suitable for sampling are identified, and a sampling grid is positioned over the area. Surveying activities are usually ongoing in order to develop geological models encompassing all the concession areas held by a company. Precise sediment sampling using penetrating tools is subsequently carried out on the grid. 

Once a mineable ore reserve has been identified, bulk sampling is conducted in the sampling grid. The bulk sampling process is done in a scattered grid pattern and is similar to mining but on a smaller scale. Mineable marine ore reserves are divided into rectangular blocks of 50x50 m which are then systematically and contiguously dredged. While some block groups may only be a few 100 m long, others can stretch 1-2 km in length. Commonly, Wirth Drill or seabed crawlers are used to clear 50 m2 areas of sea floor to bedrock level. Seabed crawlers, equipped with anterior articulated cutting and/or sucking devices are lowered onto the seabed on a hoist rope, with power and signal umbilical cable attached and controlled remotely from a surface support vessel. The vehicle mines by systematically advancing along a specific 'lane' achieving precise coverage of the area to be mined. This mining tool is especially suitable on flat areas with few boulders and is capable of mining sediment thicknesses of up to 5 m in water depth of up to 150 m. The Wirth Drill is a vertically mounted, larger diameter drill-head used to recover diamond bearing gravel in a systematic pattern of overlapping circles over the mining block. The drill is capable of drilling through more than 5 m of sediment and penetrating rock in water depths to 150 m.

Mining using the above techniques involves the removal of only the unconsolidated superficial sediments. The dredged sediment-slurry is airlifted to the surface, discharged into a slotted circular tower and dropped onto a multi-decked screen, which separates the oversize and undersize fractions. These are immediately discarded overboard, care being taken to prevent covering unmined areas. Of the material airlifted to the surface, 99.9% is returned directly to the sea. Re-mining of an area occurs only when the initial coverage of a block by the mining tool was insufficient.

The fraction of interest (plantfeed) is fed through a ball mill to fragment the shell and clay components, before being mixed with ferrosilicone and pumped under pressure into a dense medium separation plant. Low-density materials (floats) are separated from the concentrated plantfeed and discarded overboard. The remaining high-density fraction is dried and passed through an x-ray sorting machine to separate the diamonds. Non-fluorescent material is discarded overboard and the fluorescent fraction is automatically sealed in cans. On some of the smaller offshore vessels the high-density fraction is still hand sorted for diamonds.

The prospecting and mining vessels currently employed in offshore diamond recovery in Namibian and South African waters are semi-mobile platforms on a dynamic positioning system, or self-mooring systems comprising three to four anchors. These ships, which range in size from 50 m (26 crew) prospecting vessels to 140 m (90 crew) mining vessels, are fully self contained mining units operating on a 24 h basis through 11 months of the year. 

Several new techniques are planned for the future that will reduce mining costs and allow for the exploitation of lower grade ores in the mid- and deep-water zones. These include jack-up rig platforms and bulk dredging operations. Jack-up rigs will be semi-mobile platforms housing the separation and recovery plants, which are fed slurried gravel via flexible hoses attached to multiple dredge crawlers. These platforms will be moved as required (probably not more than once or twice per year) and will be serviced by ship or helicopter from the nearest logistical base.

Massive sheet gravels occur in some mid- and deep-water areas that are uneconomic to exploit using currently available methodology. Plans are afoot, however, to begin exploiting this low-grade ore using high volume suction hopper dredges. These plans call for the use of large dredges on which under- and over-size material will be screened to separate hoppers, while plant feed material is transferred to processing plants at sea or on the shore. Tailings disposal would be back to the sea in designated tailings areas.

5. ENVIRONMENTAL POLICY AND LEGISLATION 

5.1 INTRODUCTION
Numerous legislative Acts have been promulgated to regulate and mitigate effects of mining and associated activities in South Africa and Namibia. The main environmental provisions of Acts pertinent to the management of activities affecting the BCLME are described below. At the time that this report was prepared, no information was available regarding legislation controlling the exploitation of minerals in Angola.

5.2 SOUTH AFRICA
5.2.1 Minerals Act, 1991 (Act 50 of 1991) 
Prior to commencing prospecting or mining operations, section 39 of the Minerals Act requires a "layout plan and rehabilitation programme", now referred to as an Environmental Management Plan Report (EMPR) to be submitted to the regional director Department of Mines and Energy (DME). Prior to approval of an EMPR, the regional director must consult with Cape Nature Conservation and/or Sea Fisheries Research Institute for comment. Exemptions from EMPRs may be granted in certain circumstances, however. Procedural, format and performance assessment requirements for these documents are detailed in Section 5.2.5 below.

The Act requires the holder of the prospecting permit or mining licence to rehabilitate the "surface of land" to the Regional Director's satisfaction and to do this as an integral part of, and simultaneous with, prospecting or mining operations. On termination of prospecting and mining activities, all structures not required by the landowner are to be demolished and all debris removed. The mining licence holder is responsible for rehabilitation, until such time that the Regional Director issues a closure certificate. Before a mining or prospecting licence is granted, the applicant must demonstrate the financial ability to pay for rehabilitation by establishing a rehabilitation trust fund, submitting bank guarantees, lodging cash with the DME or by other mutually acceptable arrangements.

5.2.2 Environmental Conservation Act, 1989 (Act 73 of 1989)
Regulations promulgated in September 1997 under the Environmental Conservation Act 1989, list activities which require an Environmental Assessment and the procedures to be followed. Although mining per se is not a listed activity (as it is in Namibia's Draft Environmental Management Bill 1998) several land use activities ancillary to mining are listed. These include roads, harbours, structures and reclamation of land below the high water mark, dams, onshore infrastructure and services (sewage treatment, waste disposal), and industrial buildings. 

5.2.3 National Environmental Management Bill of 1998
Provisions of the Environmental Conservation Act, 1989 and its regulations relating to listed activities and compilation of environmental impact reports will be repealed by promulgation of the National Environmental Management Bill of 1998. The aim of this bill is to co-ordinate the activities of all listed state departments having an influence on the environment, and to allow for revision of regulations on listed activities and environmental management procedures. Until new regulations on procedures, report contents and listed activities are gazetted, existing regulations for EIAs under the Environmental Conservation Act, 1989 and regulations for EMPRs under the Minerals Act 1991 remain in force. EMPR requirements are currently being revised by the DME in accordance with the National Environmental Management Bill, and are due for implementation in June 1999 (MME pers. comm.).

5.2.4 Other Legislation Relevant to Environmental Aspects of Mining Activities
Other statutory acts and regulations applicable to marine mining activities and employee behaviour on land and at sea are listed and described briefly below:

Pollution at Sea

1. Prevention and Combating of Pollution of the Sea by Oil Amendment Act 24 of 1991 - regulates oil pollution from ships at sea

2. Marine Pollution (Control and Civil Liability) Act 6 of 1981 (and Marine Notices) - establishes reporting requirements and procedures for oil spills and oil bunkering

3. 1973 Convention for the Prevention of Pollution from Ships (MARPOL) - controls all waste disposal at sea (oil, hazardous waste, solid waste (plastics, tins, glass, organic matter etc, and sewage). RSA is a signatory on this convention.

4. National Water Act 36 of 1998 - controls discharge of tailings, and sea and fresh water pollution on land

Air Pollution

1. Montreal Protocol on Substances that Deplete the Ozone Layer was adopted in 1987 to which signatories undertake to control and limit the consumption of chlorofluorocarbons (CFCs) and not to import CFCs from states which are not parties to the Protocol. 

Use of Harbours and Ports, Landing Facilities and Specific Tidal Rivers by Vessels

1. Marine Living Resources Act 18 of 1998 and its regulations of September 1998 - regulates use of fishing harbours by vessels and staff

2. South African Transport Services Act 65 of 1981 - regulates use of harbours under Portnet's jurisdiction (e.g. Port Nolloth)

3. Sea Shore Act 21 of 1935 and Environmental Conservation Act 73 of 1989 - controls construction of structures below high water mark (e.g. jetties)

4. Nature and Environmental Conservation Ordinance 19 of 1974 - regulates boating on Verlorenvlei, the Olifants River, and lower Berg River

Vehicle Access to Coastal Zone and Other Sea Shore Activities

1. Control of Vehicles in the Coastal Zone* (Regulations under Environmental Conservation Act 73 of 1989) - requires implementation of a permit system for beach use by vehicles, restricts vehicle use to non-sensitive areas (e.g. below high water mark, away from dunes) and to existing tracks
   * Specifically excludes approved diamond mining activities, although MME has pledged to apply these regulations through EMPRs (MME pers. comm.)

2. Regulations and bylaws under the Sea Shore Act 21 of 1935 promulgated by local authorities - controls beach access, littering, camping, bathing, launching of boats, and in the case of the West Coast District Council, disturbance of animals, birds and plants below the high water mark

Disturbance or Damage to Natural and Cultural Resources

1. Marine Living Resources Act 18 of 1998 and its regulations of September 1998 - licences required for cutting and removal of kelp, disturbance or collection of lobsters; and all other forms of fishing

2. Sea Birds and Seals Protection Act 46 of 1973 - controls disturbance of sea birds and seals on islands (no-one may set foot on an island without permission)

3. Nature and Environmental Conservation Ordinance (19 of 1974) - regulates hunting; disturbance of wild animals, collection and damage to plants, pollution of inland waters

4. United Nations Convention on Biological Diversity - conservation of biodiversity, sustainable use of its components, and equitable share of the benefits arising from the use of genetic resources.

5. National Monuments Act 28 of 1969* - disturbance and removal of archaeological and palaeontological sites and shipwrecks
   * This act excludes mining from disturbance to archaeological sites except shell middens and cave contents (i.e. the majority of sites in the coastal zone)

Health and Safety of Employees and Vessels

1. Regulations under Mines and Works Act 27 of 1956 - regulates diver qualifications, diving equipment and diving procedures

2. Merchant Shipping Act 57 of 1951 - regulates safety and licensing requirements for vessels

3. Marine Traffic Act 1981 - regulates traffic of marine vessels

4. Wreck and Salvage Act - regulates liability for removal of wrecks

5.2.5 Requirements for the Compilation of Environmental Management Plan Reports 
Procedures
Compilation of EMPRs are based on Integrated Environmental Management (IEM) and involves but are not necessarily restricted to:

1. Consultation with the Director: Mineral Development of DME and all relevant authorities to determine the scope of the EMPR

2. Scoping with other interested and affected parties to further define the scope of the EMPR through identification of issues of concern

3. Assessment and Evaluation of Impacts (involving I&APs)

4. Compilation of a plan for management of impacts (involving I&APs)

5. Submission of a draft EMPR to DME who will circulate it to relevant Government departments and make it available to the public

6. Revision and resubmission (if needed)

7. Approval unless further mitigatory planning is required and revisions necessary.

Contents of EMPRs 
As a minimum, EMPRs for offshore mining should be separated into three parts: Part A (EIA); Part B (EMPR) and Part C (Supporting References and Statutory Requirements) and should contain:

1. General Information

1. Contact addresses and numbers, 

2. Maps showing concession area, proposed mining area, location of mining and onshore logistical facilities, other projects and activities in adjacent areas

3. Description of proposed project (production rate, life expectancy, timetable of project phasing and sequencing)

2. Project Motivation

1. Local, regional and national socio-economic benefits (mine expenditure, revenue, multiplier effects, infrastructure benefits etc.

2. compatibility with other policies, plans and land users

3. consideration of project alternatives

3. Detailed Project Description for all offshore and onshore activities including infrastructure and support facilities; mining methods including processing operations, transportation requirements and methods; all waste emissions and disposal methods; chemicals to be used; and use of water and electricity.

4. Description of Pre-mining Environment to provide baseline information to establish a reference for determining and evaluating impacts, and design of mitigation measures. The following environmental aspects should be described and mapped: geology and sediment; oceanographic patterns, physical nature of surrounding areas (coastal zone, sensitive areas e.g. wetlands, islands, dunes etc); fauna and flora that occur in the area and may be affected, particularly benthic organisms; climate; sites of cultural resources (archaeology, shipwrecks etc); recreational areas and transport routes; mariculture areas; fishing areas, and other marine harvesting areas e.g. kelp.

5. Environmental Impact Assessment should include a quantitative and qualitative analysis of the nature of impacts of all project activities on all components of the natural, socio-economic and cultural environment before and after mitigation for each phase of mining: construction, operation, decommissioning and post closure. Each impact should be evaluated using the following criteria: nature; time of occurrence; spatial extent; duration; intensity; probability and significance.

6. Environmental Management Plan. Measures to mitigate the effect of each impact on each environmental component (identified in Part A of the report) for each project phase should be described. The plan must include rehabilitation of disturbed areas, pollution control, emergency procedures, links with existing contingency plans, future public participation strategies, and outline of the decommissioning strategy.

7. Monitoring of EMP Performance and Reporting Requirements. Describe the monitoring programmes to be implemented for each phase, and include a statement of objectives, targets for compliance, description of physical monitoring systems and frequency of monitoring. Describe the auditing system that will be followed to assess EMP performance (adequacy and appropriateness) and the reporting procedures to be followed (type, frequency and format of reports and other information to be submitted).

8. Financial Provision. Indicate what financial provisions (complying with regulations under the Minerals Act) have been made to implement environmental management and rehabilitation. 

9. Supporting Documentation and Statutory Requirements. Include in this section permissions granted under other statutes, applications submitted, and future statutory requirements. 

EMPR requirements for a) concessions and surf zone mining
As an alternative to the above, a tabular format for EMPRs for companies mining in the a) concession and surf zone areas only can be completed and submitted together with a locality map (1:50 000 map), and a layout plan showing the location of all infrastructure including access roads.

Operating and Rehabilitation Requirements of the EMP
The DME has compiled a set of standard operating and rehabilitation requirements for mining in the a) concession area and surf zone, which are legally binding on the mining operation after approval of the EMP has been given. These standards cover issues such as the requirement to update maps on a quarterly basis, minimum infrastructure requirements for construction camps, use and maintenance of access roads to beach and campsite areas; waste disposal; water pollution control; location of processing areas; deposition of tailings onshore and at sea, and rehabilitation.

Compliance with EMPRs: Performance Assessment and Monitoring
Regulations for EMP Performance Assessment (PA) and Monitoring have been gazetted under the Minerals Act. These regulations stipulate the need for holders of prospecting and mining authorisations to undertake ongoing monitoring of the EMP and to compile performance assessments for submission to the Director: Mineral Development. EMP performance assessment and reporting should be done according to the period specified in the EMP; annually, or as agreed by the Director: Mineral Development. The PA report should contain information on the period applicable to the PA; procedures used for the assessment; information yielded from monitoring; criteria used in evaluation performance and the results; and recommendations on rectifying deficiencies identified and areas of non-compliance.

Responsibility for PA lies with the prospecting/mining authorisation holder and may be done by independent qualified consultants. Where a PA report is deemed inadequate by the Director: Mineral Development, the holder may be required to repeat the whole or relevant aspects of the EMP PA and resubmit a revised report or appoint an independent team to do so. A final EMP PA is required where closure of a mine is intended and should accompany or precede a closure application. The final PA will be assessed to ensure that all relevant legislation has been complied with; closure objectives as described in the EMP have been met and all residual and latent environmental impacts have been identified and arrangements finalised for managing their risk and/or occurrence.

The regulations do not specify whether the PA reports are circulated to other relevant government departments for comment prior to their approval by the Director: Mineral Development. PA reports are available on request.

5.3 NAMIBIA
5.3.1 Minerals (Mining and Prospecting) Act, Act 33 of 1992
Application and Granting of Mining Licences
An applicant for a mining licence must comply with the provisions of the Minerals (Mining and Prospecting) Act, Act 33 of 1992. Applicants are required to estimate the effect of mining or prospecting on the environment and the steps to be taken to counteract such effects. In line with the Minerals (Mining and Prospecting) Act, Act 33 of 1992, prior to consideration of a mining licence, the Minister may require an environmental impact study. Alternatively, the holder of a mining licence must prepare an environmental impact assessment (in a form determined by the Commissioner) before any mining or prospecting is undertaken. If pollution is likely to be caused by mining, an environmental management plan (EMP) is required.

The minerals act allows for various types of prospecting and mining licences, issued by the Mining Commissioner, covering both small-scale and formal activity:

• Mining Claims - available to Namibian citizens only, these claims are for the development of small-scale mines and mineral deposits. Up to a maximum of ten claims can be held at any one time, each valid for three years (with a possible two-year extension).

• Reconnaissance Licences - designed for regional, mainly remotely sensed exploration to facilitate the identification of exploration targets. Valid for six months on a non-renewable basis only.

• Exclusive Prospecting Licences - for exclusive exploration rights in areas up to 1000 km2. Valid for three years, but can be extended twice for two-year periods, but not beyond seven years without ministerial approval.

• Mining Licences - grant exclusive mining rights on a piece of property for 25 years or the life of the mine, with renewals valid for 15-year periods. Holders are required to demonstrate financial and technical ability to develop and operate a mine.

• Mineral Deposit Retention Licence - allows an exploration company to retain tenure on a prospecting licence, mining licence or mining claim without mining obligations. Valid for five years with two year renewal periods. 

Responsibility of Licence Holders
Social obligations of mineral licence holders to employees and to Namibia include: the need to give job preference to Namibian citizens possessing appropriate qualifications; conduct training programmes; use products produced and services available in Namibia, and co-operate with other Namibians involved in the mining industry to aid skills development. 
The licence holder is ultimately responsible for all actions of subcontractors and must ensure that all licence conditions are equally applied to subcontractors. 

Environmental Protection
Provisions of the Minerals (Prospecting and Mining) Act relating to environmental protection and rehabilitation are weak and unlikely to enforce compliance. Abandonment of a mining or prospecting area stipulates the need to give written notice to the Commissioner; to demolish accessory mining works (unless required by the landowner), and to "take all such steps" to "remedy to the reasonable satisfaction of the Minister any damage" caused by the mining or prospecting operation to the "surface of, and the environment on, the land in the area in question". Further, contravention of these provisions may incur a fine not exceeding R8000 which is unlikely to be a deterrent to non-compliance.

Issuance of mining or prospecting licences requires the holder to sign a Pro-forma Environmental Contract with the Government of Namibia (represented by the Ministry of Environment and Tourism, the Ministry of Fisheries and Marine Resources and the Ministry of Mines and Energy). This contract obliges the holder to apply the Environmental Assessment Policy (see below) and to reduce and mitigate all environmental damage and to leave the environment in a reasonable state. The contract requires the licence holder to submit a bi-annual Environmental Report documenting compliance with the submitted and approved EMP.

5.3.2 Environmental Assessment Policy of 1995 and the New Environmental Management Act 
Namibia's Environmental Assessment Policy, compiled in 1995 by the Ministry of Environment and Tourism, lists the activities for which an environmental assessment is required (which includes mining, mineral extraction and mineral beneficiation) and describes the procedure to be followed for undertaking and compiling them. The Ministry of Mines and Energy and the Ministry of Fisheries and Marine Resources do not have their own set of requirements in this regard.
Recently an Environmental Management Act (Act X of 1998) has been compiled which prescribes the need for environmental assessments for listed activities and outlines their minimum requirements. Listed activities relating to marine mining include: mining and mineral extraction, the construction of harbours and associated structures, structures below the high water mark, reclamation of land below the high water mark, the erection of buildings and structures for industrial activity, construction of sewage treatment plants and dams or reservoirs, and the construction of waste sites or facilities for waste treatment. Environmental assessments are submitted to, and reviewed by, the Competent Authority and Environmental Commissioner. The latter, after full consideration, and possibly further consultation and external review, submits the EA with his/her recommendation to a Sustainable Development Commission. The Sustainable Development Commission (represented by officers from all key ministries, sustainable development specialists and NGO representatives) is responsible for issuing or refusing the granting of an Environmental Clearance, with or without conditions.

According to the Ministry of Environment and Tourism (MET) (Dohogne pers. comm.) a flexible system for environmental assessments and management plans is followed for mining whereby depending on the phase of the companies programme further environmental information is requested. The different mining phases and requirements are:
Survey activities: Simple environmental contract
Sampling: EMPR including monitoring programme
Mining: EA including EMPR and monitoring programme

5.3.3 Other Legislation Regulating Environmental Aspects of Mining
Activities undertaken during marine mining are regulated by legislation dispersed through several Government Acts and Regulations. Several South African acts applicable in Namibia have not been altered since Namibia obtained independence in 1991. However, in South Africa some of these (e.g. the Water Act) have been revised while others (e.g. the National Monuments Act) are in the process of revision. Pertinent statutory legislation relevant to marine mining in Namibia is listed below:

Pollution at Sea

1. Sea Fisheries Act 29 of 1992 - regulates pollution at sea and controls disposal of fish and household waste from ships; disturbance of rock lobsters marine invertebrates and aquatic plants, and restricts areas of seabed damage 

2. Prevention and Combating of Pollution of the Sea by Oil Amendment 24 of 1991 - regulates oil pollution from ships at sea

3. 1973 Convention for the Prevention of Pollution from Ships (MARPOL) - controls all waste disposal at sea (oil, hazardous waste, sewage and solid waste)

4. Water Act 54 of 1956 - controls tailings discharges and sea and fresh water pollution on land

Disturbance or Damage to Natural and Cultural Resources

1. National Monuments Act 28 of 1969 - controls disturbance of shipwrecks and archaeological deposits, such as shell middens and cave contents

2. Sea Birds and Seals Protection Act 46 of 1973 - controls disturbance of sea birds and seals on islands 

3. United Nations Convention on Biological Diversity - regulates conservation of biodiversity, sustainable use of its components, and equitable share of the benefits arising from the use of genetic resources.

Harbour Regulations

1. Namibian Ports Authority Act 2 of 1994 - gives Namport the responsibility of protecting the environment within the harbour area

2. Maritime Notice No 4 of 1994 - provides rules and procedures for collecting garbage in Namibian Waters.

Security

1. Diamond Industry Protection Act 17 of 1939 as amended - tables laws relating to regulation, control, development and protection of the diamond industry in Namibia and illegal entry into prohibited areas. This act will soon be replaced by the New Diamond Bill to be tabled in March 1999.

Employee Regulations

1. Labour Act 6 of 1992 -provides conditions of employment for employees of Namibian companies and Occupational Health and Safety Regulations. Parts of this Act are soon to be repealed and replaced by the Mine Health and Safety Regulations to be tabled as an amendment of the Minerals Act, 1992.
   b) Immigration Control Act 7 of 1993 - regulates employment and issuance of work permits and obliges employers to give job priority to Namibians.

5.3.4 Environmental Management Plan Reports (EMPRs)
Namibian legislation requires that all new applicants for mining licences prepare an Environmental Management Plan. No specific guidelines exist for compiling EMPRs, and these are usually assessed according to the international literature and according to the specific programme proposed by the Mining Company. Since South African consultants compile most of the EMPRs, the South African EMPR guidelines (section 5.2.5) are usually followed.

6. ENVIRONMENTAL ISSUES, IMPACTS AND MITIGATION

6.1 INTRODUCTION
In the search for and extraction of ore bodies, the diamond mining industry by its very nature exploits the environment. Large amounts of sediment need to be removed and processed, stripping areas and producing tailings. These operations cause both positive and negative impacts on the Benguela Current marine ecosystem, and are the source of conflict with industries utilizing coincident resources.

To avoid these issues becoming a major political concern, and in keeping with the philosophy of Integrated Environmental Management adopted worldwide, a three stage process has generally been followed by the mining industry. Firstly, issues or impacts of major concern to the public, government authorities and conservation bodies are identified during scoping studies. Secondly, specialist or review studies are commissioned and the scale and extent of impacts resulting from the mining activities examined through strategic environmental impact assessments. Finally, in situations where the scale or intensity of the impact is considered to be significant, mitigation measures designed to minimize negative and maximize positive impacts on the environment are recommended. Collectively, this process leads to an Environmental Management Programme (or Plan), which is a dynamic set of documents updated as new mining techniques are employed and/or new information becomes available. Most of the larger diamond mining companies and many of the smaller operators already have, or are in the process of drawing up Environmental Management Plans.

The major issues that have been identified in the compilation of EMPs, and a summary of the pertinent research undertaken and mitigation measures adopted by the industry are outlined in this section and are summarized in Table 4.

6.2 SOCIO-ECONOMIC ENVIRONMENT - POSITIVE IMPACTS
6.2.1 Creation of Revenue and Employment
South Africa
South Africa has 66 registered diamond mining concerns (excluding about 1500 registered alluvial diggers), 49 of which produced rough diamonds in 1996 and 18 of which were from marine concessions. Production statistics (Source: Diamond Enquiry) for the last 10 years for South Africa as a whole indicate a fairly stable, but slightly increasing, level of annual diamond production at around 10 million carats. Diamond production from kimberlite sources has remained constant, accounting for 89% of diamond production, but there has been a shift over the last 4 years from alluvial to marine diamond production. Alluvial diamond production declined by 245 000 carats on average between the period 1987-1993 and the period 1994-1997, but increased in 1997 due to higher output at De Beers Namaqualand (DBNM) and some Trans Hex mines. In contrast, with the onset of deep-sea mining in 1991, annual average carat production for marine mining increased from 53 885 for the period 1987-1990 to an average of 147 833 for 1991-1993. Marine diamond production statistics show a decline since 1994, and particularly in 1995, as a result of reduced output from Alexkor's beach and marine sources. Marine mining at present contributes about 10% of South Africa's total diamond production.

Diamond revenues, levied through income tax on diamonds, mining leases, mining rights and diamond export duties, are put into the Central Revenue Fund from where they are allocated to various budgets by the Government. The proportional contribution of diamond revenues to overall tax revenue collections has declined over the last 17 years, and the diamond taxation system is under review by the Katz Commission.

Statistics for diamond mining in 1997 indicated that 473 male employees worked at sea, compared to a total diamond mining workforce of about 10 000 males and 900 females (Minerals Bureau 1997 statistics), providing roughly 54% to the Gross Geographic Product (down from 80% in the 1970s) and 66% of employment in the Namaqualand region. Quantifying financial input into local economies from diamond mining is very difficult as a result of the wide range of multiplier effects. Combined male and female earnings for all diamond mining in 1997 totalled almost R553.5 million, however, it is unclear what proportion of this may have entered the local economy since many of the higher income employees live outside the region.

Namibia
As in South Africa, Namibian onshore diamond mining is winding down and the future lies in offshore diamond mining. In 1996, beach and marine mining yielded 43% of total diamond production (compared to 10% in South Africa), estimated at 1.49 million carats. The diamond mining contribution to GDP was valued at N$2.1 million in 1997. As in South Africa, diamond mining revenues go to Namibia's central government funds.
Namdeb is the biggest taxpayer, exporter and private sector employer in Namibia. To prolong the life of its onshore activities, Namdeb invested in new dredge mining techniques in 1997 that led to increased production levels. Namdeb produces approximately 1.3 million carats of which its deep-water operator, De Beers Marine, contributes 35%. In contrast, ODM produced just over 58 000 carats in Namibia in 1997.

In 1993, 4500 workers (1% of Namibia's workforce) were employed by Namdeb at its diamond mines in the Sperrgebiet. The majority of low-skilled employees originate from the northern regions of Namibia and send remittances to families back home. At rough estimate, a minimum of 800 people is employed at sea - excluding shore-based operations. 

Angola
In 1971 Angola, through formal production channels, produced 2.4 million carats, although production subsequently declined due to civil war and instability. The 1991 cease-fire led to an influx of thousands of "garimpeiros" (illegal diamond miners) to diamond fields, which has lead to widespread uncontrolled digging and smuggling. Estimates suggest that over 50% of the Angolan Government total potential revenue from alluvial diamonds has been lost to smugglers. In 1994 revised legislation was passed to provide order to the diamond industry, and in particular to provide for greater security. The new law gives ENDIAMA, the state mining company which has the sole rights for prospecting, mining and marketing of diamonds in Angola, powers of negotiation to attract foreign investors in new mining ventures either in joint ventures with ENDIAMA or as sole investors.

As a result, production has since increased to 3.7 million carats in 1996 contributing roughly 9% to Angola's GDP, with most production from onshore mining. Significant interest has been shown in Angola's diamond resources since they are known to be of particularly high quality. De Beers and ODM both have agreements with ENDIAMA to mine onshore diamonds. De Beers plans to spend $75 million on prospecting three prospects covering 63 000 km2 in Quela, Mavinga and Lunda Norte. De Beers has indicated its commitment to ensuring the stability of the diamond mining industry in Angola by investing in a 12-storey diamond sorting building in Luanda.

No authorised offshore prospecting and mining has been undertaken in Angola to date, although companies, such as De Beers, have been negotiating for rights with the Angolan Government for some years.

Table 2. Summary of total diamond production, contribution by marine and beach mining and total contribution by diamond mining to GDP for South Africa, Namibia and Angola.

6.2.2 Human Resource Development and Social Betterment
South Africa
Initiatives to develop the skills of employees have been undertaken mainly by the large onshore mining companies who employ a significant staff complement of mainly low-skilled workers. Onshore human resource development initiatives by large companies include the establishment of trusts to fund training; sponsorship of community needs (such as clinics); conducting skills training at mining towns; and developing alternative land uses. Training on mines has been fragmented, however, and qualifications are not nationally standardised, leaving most employees with little improved chance of finding jobs. 

DBCM, for instance, together with Anglo America, contribute to the Chairman's Fund, which is the largest corporate contributor to educational and social development in South Africa. In 1997, the fund made donations totalling over R56 million of which De Beers contributed R18.5 million. Most of the funding is invested in education.

To improve financial viability of mining, extend the life of the mines, and create jobs, some of the larger companies are investigating, or are already undertaking, alternative land use activities. Alexkor has mariculture and farming projects underway, and have further plans for mariculture expansion. The company, in conjunction with the Northern Cape Government, is also investigating tourism and other land use development options with a view to providing up to 700 jobs (if all plans reach fruition). DBNM are awaiting approval to start abalone cultivation and harvesting of Gracilaria and are considering other projects such as hemp cultivation and other agricultural projects. It appears that mariculture ventures undertaken by diamond mining companies in their processing dams would not otherwise be financially viable and can be considered a positive spin-off. It is not known whether these ventures would remain viable after mine closure, however. Unfortunately, the success of many of these projects will depend largely on the availability of fresh water - a scarce resource along the Namaqualand coast.

Namibia
Namibia's Minerals Act, 1992, requires holders of any mineral licence to: give preference to Namibian citizens with appropriate skills; carry out training programmes to promote the development of Namibian citizens; make use of products, equipment and services produced and available within Namibia, and co-operate with Namibians involved in the mining industry to promote skills development. 

Namdeb took initiatives with Namibian small contractors in 1990 after pressure was exerted to expand shallow water operations in Namibia, similar to those that had been operating in Namaqualand since the 1980s. However, many small contractors operating from the beach south of Lüderitz failed to make a profit because of adverse working conditions and operational problems. Larger-sized "small contractors" operating from boats (e.g. Yam Diamonds) and others produced over 132 500 carats in 1994. Small contractors employ roughly 250 people, most of whom live in Lüderitz.

In line with government policy and to prolong the life of the mine by reducing overhead costs, Namdeb has privatised most non-mining activities in its mining town of Oranjemund, which are now run mainly by black entrepreneurs. The diamond industry has also benefited the local economy of Lüderitz (which houses its Elizabeth Bay mine) through the payment of wages (estimated at N$8 million), local sponsorship and direct business (N$3 million).

6.3 SOCIO-ECONOMIC ENVIRONMENT - NEGATIVE IMPACTS
6.3.1 Shifting Emphasis from Onshore to Offshore Mining
The intensity of onshore diamond mining in the coastal zone is in decline with a shifting emphasis to offshore operations. This is likely to have far reaching implication for aspects such as employment and skills training in both South Africa and Namibia.

Impact on Employment: The number of employees in South Africa's onshore diamond mining industry as a whole has declined from over 19 500 in 1992 to less than 15 000 in 1997 (a rate of approximately 2.5-3% per annum). Alexkor and DBNM have been scaling down onshore operations and will continue to do so over the next 25 and 10 years respectively, as diamond reserves are depleted. Between the two companies, a minimum of 1800 jobs has been lost since 1992. The majority of employees in onshore diamond mines are from Namaqualand, about 80% of which are low-skilled workers. Mine retrenchments will therefore exacerbate the already dire unemployment situation in Namaqualand unless alternative employment sources are found. The unemployment rate in rural areas of Namaqualand has been estimated at 60% - a problem that has been compounded by the decline of the fishing industry, particularly the rock lobster industry.

Loss of jobs due to downscaling is not restricted to South Africa. Downscaling through natural attrition, facilitated by retirement and voluntary retrenchments, is ongoing in Namibia, and will continue over the next two decades exacerbating the already high unemployment rate in this region (estimated at about 34%). 

The decline in onshore mining has occurred in parallel with a rapid growth in marine mining. Onshore mining companies are shifting the focus of their activities towards marine mining, and other companies have entered the diamond mining industry (e.g. Ocean Diamond Mining, Nautical Diamonds, BENCO). Marine mining is a highly specialised activity, requiring high capital inputs in the form of purchasing, maintaining and equipping mining vessels with technical processing equipment. Relative to onshore mining, marine diamond mining requires lower inputs of low-skilled labour - up to 10% (in contrast to the 80% in onshore mines). With the present lack of alternative job sources in Namaqualand, the majority of workers retrenched from onshore mines in the next decade have little chance of finding work in the offshore industry. Furthermore, because a high level of skills are required for offshore mining, the majority of staff is recruited from urban centres overseas and in South Africa, particularly impacting Namibian employment. DeBeers Marine, for instance, employs qualified British Marine Officers because of the lack of qualified South Africans or Namibians. This is set to increase, as more mining vessels become operational - DeBeers Marine, ODM and Namco are all planning to augment their mining fleets by one vessel in the next two years. 

In the absence of alternative employment in Namaqualand, many retrenched workers will, in all probability, relocate southwards to Cape Town or Saldanha (the centre of the West Coast Investment Initiative), attracted by the prospect of industrial expansion and job creation. For those that remain in Namaqualand, the loss of jobs and financial hardship that this will create may cause greater dependence on the natural resource base. This may include increased pastoralism and resultant overgrazing of sensitive coastal vegetation as well as increased collection (largely through poaching) of coastal shellfish resources (abalone, mussels and rock lobster). 

Impact on Skills Training: With continued job losses due to downscaling of onshore mining activities, fewer training and skills enhancement opportunities will be available for unskilled workers thereby compounding the unemployment and poverty problem in rural mining areas. Migration of workseekers to other urban centres is likely to erode the economic support base of the former and compounds the unemployment problem in the latter. Offshore mining also provides fewer training opportunities for low-skilled employees, limited mainly to sponsorship of students to study engineering-related courses. 

Mitigation: There is no direct mitigation that can be undertaken to stem the loss of jobs resulting from declining coastal reserves. Investment in training and investigation of future landuse options, however, are indirect means to provide opportunities for self-help.

Onshore and offshore mining companies are implementing training programmes that target upgrading of skills which will improve the chances of employees obtaining secure jobs in the post-mining environment. These companies should allocate a certain proportion of annual turnover to training and sponsorship for education. In line with the new Minerals Policy and Mine Health and Safety Act, which gives employees the right to education and training, the South African government has undertaken to promote Adult Basic Education and Training (ABET), and in particular, to ensure that people in the minerals and mining industry have access to quality education and training. The South African Qualifications Authority Act is also working towards standardising, at a national level, the qualifications achieved by training on mines.

6.3.2 Involvement of Small Scale Miners
Impact: Limited involvement of small-scale miners in the diamond mining industry has created imbalances in the distribution of benefits of mining and has restricted the potential for these miners to secure a living. Small-scale mining has been hampered by factors including: 1) lack of access to finance by financiers unwilling to fund ventures which offer limited financial security and returns; 2) lack of appropriate structures to assist small scale mining development; 3) location of mining operations far from major markets; 4) lack of access to marketing channels; 5) lack of management and technical skills, and; 6) inability of small-scale entrepreneurs to provide adequate diamond security measures. Not only have these problems marginalised small-scale miners, but they have also led to the non-exploitation of marginal diamond deposits regarded by larger companies as unprofitable. 

Mitigation: In line with the new Minerals Policy of South Africa and policies of the Ministry of Mines and Energy of Namibia, the respective governments have pledged to increase participation in the mining industry by those previously excluded. Measures that have been proposed to improve small miner involvement in the mining industry are: 1) to facilitate access to funding through appropriate institutions; 2) to ensure that information on technology and mineral development and exploitation is made available to the small-scale mining sector; 3) to encourage municipalities to support the emergence and development of small-scale miners, and; 4) to enhance the capacity of Department of Minerals and Energy to provide support to small-scale miners.

6.3.3 Promotion of Joint Management Ventures with Employees 
Impact: Racial imbalances are prevalent within the mining industry (as in other industries) with the majority of middle and senior management positions still occupied by whites. Lack of joint management ventures or partnerships with mine employees has led to lack of advancement of "black" workers and professionals into senior positions or management levels. This has created a situation whereby black employees have become demoralised through lack of economic empowerment, which undermines the political and economic stability of the mining industry. 

Mitigation: Training programmes to upgrade skills amongst the workforce have targeted this disparity (see above) but will still take many years to effect significant changes. To date, few mining companies have sought to involve employees in joint management ventures such as shareholder participation schemes. The policies of South Africa and Namibia (see above) seek to improve employee-employer relations within the workplace and promote black participation in ownership and management within the mining industry. Authorities have also undertaken to consider changes to tax administration and company law to reduce obstacles to mining companies introducing Employee Share Ownership Participation Schemes for low-income workers.

6.3.4 Reduced Revenue from Offshore Diamond Mining to Local Areas
Impact: Onshore mining companies have devolved significant benefits to local areas. Most large companies have, or are in the process of, compiling and implementing company policy for the purchase of local goods and services and, where possible, from entrepreneurs from previously disadvantaged communities. In this way, these mining companies seek to devolve mining benefits to the local area and in so doing create a stable economic and political environment within which to conduct their activities. 

Opportunities, however, for offshore mining companies to do likewise are limited by the fact that operations are conducted out of major urban centres, and most goods and services required to support offshore mining are high tech and not available from small scale enterprises. This is particularly the case in Namibia, where the use of Cape Town as a base for vessel servicing, repairs and victualling represents a loss of potential income for the Namibian economy. The shifting emphasis from onshore to offshore mining will lead to further losses to local economies.

Mitigation: No active mitigation measures have been implemented.

6.3.5 Allocation of Diamond Mining Revenues to Mining Areas
Impact: The diamond mining industry and the governments of South Africa and Namibia have been criticised by communities and local authorities for the lack of investment in infrastructure and services in towns near diamond mining areas. This stems from the policy where diamond revenues are put into a central revenue fund that are allocated to various budgets by the Government, rather than direct re-investment in the local district. To date, initiatives to address the allocation of a portion of these revenues to local and/or provincial authorities have been rejected. The mining industry, as well as the fishing industry, has not been required to directly fund the maintenance of state or provincial roads and have placed strain on harbour facilities. This is a contentious issue amongst relevant local authorities.
Despite the high income realised by diamond mining, areas surrounding diamond-mining exhibit retarded growth, lack of investment and in some places (e.g. Lüderitz) a growing population of unskilled workseekers. Elsewhere, where onshore diamond mining is in decline (e.g. Namaqualand), towns exhibit outmigration of the economically active age group to seek work elsewhere because of the lack of economic investment. Work seekers tend to move towards urban areas, such as Cape Town and Lüderitz, thereby compounding problems of crime, poverty, family separation and general demoralisation when jobs are not found.

Mitigation: No active mitigation measures have been implemented.


6.3.6 Strain on Infrastructure and Services of Towns near Mining Areas
Impact: Several towns along the South African and Namibian coasts are experiencing problems arising from the demand for infrastructure, services and resources to support the diamond mining industry. Many towns do not have the capacity to support the growing offshore mining industry - a problem compounded by the lack of direct financial inputs by Government. Infrastructure, services and resources which are often over-stretched include strain on harbour facilities, land fill sites, fresh water, and accommodation. 

Mitigation: Facilities and the capacity of affected towns to support mining are being upgraded through redirection of financial and service inputs by Government and/or by creating incentives for mining companies to do so by working in conjunction with local authorities. This process needs to be expedited, however.

6.3.7 Conflict with the Fishing Industry
Issue: Conflict exists between the rock lobster fishing and marine diamond mining industries. The rock lobster industry holds the diamond mining industry responsible for the killing of lobster and large-scale destruction of lobster habitat by stirring up sediments, cutting kelp, and poaching. Although research studies suggest there is no causal relationship between increased marine diamond mining and the decline in fish catch rates experienced in recent years, the issue remains a source of conflict between the two industries. 

Mitigation: The formation of fora or committees on which all the major stakeholders are represented appears to be the current trend for pre-empting and resolving conflicts as they arise. The Marenpro Forum in Lüderitz, Namibia, in which representatives of the fishing and mining industry as well as government ministries participate, is one such active forum. A West Coast Liaison Committee is soon to be established and has similar objective to the Marenpro Forum. All the players in the diamond mining industry in each area along the coast e.g. Western Cape and Northern Cape and Namibia should be encouraged to participate and contribute to these fora.

6.3.8 Impacts on Future Land Use and Tourism
Impact: Perhaps one of the most significant impacts of onshore and surf zone mining is the impact on future land use and tourism potential. Trenches, mining blocks, overburden dumps and an overabundance of roads scar the landscape, considerably altering the original topography. This constitute a significant aesthetic impact, which will have "knock on" effects on the tourist industry and may jeopardise the future land use potential of decommissioned mining land. 

Mitigation: Currently, the issuance of mining licences requires proof of funds for rehabilitation. However, prior to 1980 rehabilitation was not enforced, and large areas have been left scarred and un-rehabilitated. Some of the damage was caused by companies who no longer operate and the present holders of mining licences for these areas cannot be held responsible. The ultimate responsibility for rehabilitating these areas now lies with the government of the respective countries. In South Africa, the Department of Mines and Energy (DME) and the Department of Water Affairs (DWAF) contribute to a fund for derelict and ownerless mines, which is used for rehabilitation, and health and safety reparations. However, limited funding as well as the inherent problems of rehabilitation in arid areas, are the biggest constraints to successful rehabilitation. 

6.3.9 Loss of Cultural Resources
Impact: The entire southern African coastal zone has a wealth of archaeological deposits, mainly found as surface shell middens, to a lesser extent cave deposits, and shipwrecks. Onshore, poorly planned access roads, camps and processing areas can inadvertently destroy middens constituting a significant loss to cultural heritage. Within the surf zone, shipwrecks are particularly vulnerable to mining disturbance. At least 2000 vessels are known to have sunk or run aground off South Africa's shores since 1500 of which only a small fraction have been located. Surf zone mining, through displacement of obstacles such as boulders and suctioning of gravel, risks dispersing and breaking up shipwreck material. At present, the extent of damage to archaeological deposits has not been quantified.

Mitigation: Historically, mining companies have not had a responsible attitude towards protection of cultural resources. This is probably due mainly to the freedom the mining industry has enjoyed as South Africa's and Namibia's most important economic sector and the lack of environmental controls exerted on the industry until recently. In South Africa, negligence towards cultural resources has been partially encouraged by legislation that excludes diamond mining from the regulations under the Environmental Conservation Act on the use of off-road vehicles, and to portions of the National Monuments Act. This situation is changing, especially amongst the larger mining companies, who are demonstrating greater environmental responsibility in this regard by commissioning archaeological surveys prior to expanding their mining activities. Some companies, however, still have far to go in this regard.

6.4 BIOPHYSICAL ENVIRONMENT - POSITIVE IMPACTS 
6.4.1 Conservation of Flora and Fauna in Restricted Areas
Impact: The most notable positive impact on the biophysical environment comes from the de facto nature reserve status of much of the terrestrial mining area. Access to most mining areas is highly restricted in order to minimise diamond theft, and as a consequence, human interference in many areas has been kept to a minimum. Many habitats have been left in pristine or near pristine condition, the scale of which is not insignificant - the Namibian 'Sperrgebiet,' for example, alone encompasses some 26 000 km2 of land. 

The positive benefits from diamond mining are unequally shared between the marine and terrestrial environments, however. While access is restricted on land, large-scale offshore fishing enterprises continue uninterrupted along much of the diamond coast. Only shore-based forms of exploitation are effectively excluded. 

6.5 BIOPHYSICAL ENVIRONMENT - NEGATIVE IMPACTS
Considered as a whole, marine diamond mining affects only a small fraction of the marine environment (Table 3). The overall aerial extent of mining activities encompasses less than 1% of the concession areas in South Africa and Namibia per annum, irrespective of the form of mining category. On the scale of the BCLME therefore, impacts of diamond mining are deemed to be of low to negligible significance. At local scales, however, their impact may be more severe. Due consideration must be given to the scale of operations when the impacts outlined below are evaluated.

Table 3. Relative extent of the various diamond mining activities in South Africa and Namibia.

6.5.1 Environmental Impacts of Terrestrial Mining
Mining, Overburden and Tailing Dumps and Roads
Impact: The impacts of terrestrial mining are caused individually or in synergy from 10 categories of mining activity: prospecting trenches; overburden dumps; tailings dumps; mining blocks; sediment plumes; roads and vehicle tracks; scarring and quarries; mining infrastructure; seaward disposal of fines tailings; and beach mining. Perhaps the three greatest impacts from terrestrial mining are due to the removal of overburden and diamondiferous gravel, the creation of overburden and tailings dumps, and the construction of roads. These activities impact soils and plant communities, in turn impacting the animal communities associated with them. The degree of impact depends on both the scale of the mining activity and the type of soil that is impacted. Actively forming soils harbour plant communities that are dynamic and resilient to even massive disturbances, whereas plant communities growing on older complex soils are dependent on the equilibrium of the soil, and usually fail to recover from disturbance if this equilibrium is not maintained. Stripping of overburden with a complex topsoil therefore has a relatively greater impact of longer duration than stripping an area of actively forming soils. Although some areas are back-filled, topsoils are generally not stored and the loss of topsoil means that recovery of plant comminutes to their former state depends on the formation of new soils - in the order of decades to centuries. Loss and recovery of animal fauna presumably follows the same route. Roads and heavy vehicle movement has the opposite effect to mining. These activities tend to compact the soil, thus rendering the area unsuitable for re-colonization by new plants. Additionally, it should be noted that numerous rare, threatened or endemic animal and plant species occur in the diamond areas, and are negatively affected by mining activities.
Areas denuded of vegetation, such as trenches, mining blocks and tailings are inherently unstable, with the result that sand plumes frequently develop due to the strong winds and flat topography characteristic of the mining area. These sand plumes can be quite extensive, smothering vegetation and causing a significant secondary impact. It is believed that sediment plumes may have been a triggering force in the collapse of the saltmarsh ecosystems of the Orange River wetlands.
Additional, lesser impacts are caused by mining infrastructure as buildings and equipment are often left on site following completion of mining, or if the equipment becomes derelict. Not only does this hinder recovery of the ecosystem, it also causes an aesthetic impact, in addition to the mine dumps and trenches that now dominate in a previously flat landscape.

Mitigation: Mitigation is principally through rehabilitation of the affected areas. The severe disturbance that results from mining in these arid terrestrial ecosystems, the dynamics of which are greatly retarded by the harsh environment, makes rehabilitation very difficult, however. Generally larger mining companies make the effort to stockpile topsoil and overburden separately and replace this material in appropriate positions in the refilled mining blocks. Little or no effort is made to rehabilitate prospecting trenches, however.

Seaward Disposal of Fine Tailings
Impact: Discharging fine tailings to sea impacts the intertidal region, whether at a large scale such as the Elizabeth Bay Mine (Namibia) or at a smaller scale such as small contractors operating from the shore. 

The sediment plume generated from the seaward disposal of fine tailings impacts intertidal rocky shores. The impact is localised to the extent of the sediment plume - a scale of 100 m in the case of large recovery plants, and a scale of 10 m for the smaller operations. The impact is caused by sand inundation that appears to impact particularly the grazers in the intertidal zone (e.g. Patella granatina, P. argenvillei), causing a decrease in the ability of these animals to adhere to the substrate. The resultant reduction in herbivory often leads to an increase in foliose algal cover, which causes shading and in turn decreases corralline algae cover below. A cascade effect is the loss of food to seabirds that forage on the intertidal. At small-scale contractor mining sites, full recovery takes less than two years after the cessation of mining activity. 

Subtidal rocky shores do not appear to be adversely affected by light siltation by mine tailings, with the possible exception of sponges which are particularly sensitive to sand inundation. Should a beach prograde to cover the reef however, complete loss of habitat with the associated communities, will ensue.

The seaward pumping of fine tailings on sandy shores can have a profound effect on communities associated with these habitats. Fine fractions of tailings are suspended in the sea and advected offshore, whereas coarser fractions settle rapidly onto the beach. If large volumes of tailings are pumped seaward, this can lead to severe alterations of the physical state of the affected beach. For example, fine tailings at Elizabeth Bay have increased the size composition of sand across the entire beach. Prior to mining, Elizabeth Bay beach was composed of fine to very fine sands, with sand particles coarser than 100mm making up less than 10% of the total amount. With the advent of mining in 1991, mean particle size at the centre of the beach where tailings are disposed has increased from 110-160 mm to 600-900 mm, with a accompanying reduction of surf zone width by ~50% and an increase in the beach slope from 1:40 to 1:14. Beach macrofauna communities are almost entirely determined by the physical state of the beach, and this alteration to the physical state of the beach has led to a shift from a mussel dominated community to a community dominated by crustaceans with an accompanying loss of diversity. Following mine closure, recovery of the affected beaches to a pristine state will depend on the speed at which the beach returns to pre-mining physical conditions. This could take decades or even centuries. 

Fish appear to benefit from the turbidity plume produced by the discharge of tailings spoil material from the Elizabeth Bay diamond mine, with increased species richness and abundance recorded within the plume relative to control sites on the same beach. It is believed that this is attributable to increased shelter from predators provided by the plume. Loss of potential food items (beach macrofauna discussed above), reduction of habitat through the narrowing of the surf zone, and the development of more turbulent waters associated with a narrower surf zone must have some, though unquantified, negative effects.
Mitigation: Terrestrial slime dumps are an alternative to the seaward disposal of tailings, but this option is not without its own impact on the environment. No other mitigation or rehabilitation options are considered economically feasible.

6.5.2 Environmental Impacts of Beach Mining
Seawalls
Impact: The construction of seawalls has significant effects on the marine environment. Seawalls are constructed to push the shoreline between 200 and 500m into the sea, permitting access to diamond deposits of the subtidal. The seawalls require constant maintenance as rough seas typical of this coast continually erode the walls. Overburden alone is often insufficient for the construction and maintenance of these dams, and as a result, other sources of material are used for building material including the coastal dunes (in itself an impact on the terrestrial environment). Following mining, maintenance of the seawalls ceases, the wall collapses, and the area is left to reform a new shoreline. Because the seawalls are constructed of a melee of fine sands to boulders not resembling the original beach material, the resulting shore is left physically altered. In some cases fine-grained beaches have been left as coarse-grained beaches while in other cases, rocky reefs have been converted to boulder fields. As discussed above, alterations to grain size can have profound effects on biological communities of sandy beach and rocky shore communities. Although such an impact has hitherto not been assessed in terms of field studies, the effects are roughly predictable. Pre-mining baseline data has been collected at one site, however, and the impact should be fully quantified once mining is underway in the next few years. 
Mitigation: Mitigation action includes the use of materials for seawall construction that are roughly equivalent to the sandy beaches that are stripped.

6.5.3 Environmental Impacts of Shallow-Water Mining Operations (<30m depth)
Diver-assisted shallow-water mining activity targets gravel-filled gullies and potholes between reef ridges. Access to this gravel is either via the shore or through boat-based operations. 

Access to Shore-based Mining Sites
Impact: Access to nearshore diamondiferous gravel by shore-based operators often requires the construction of new roads, blasting rock cuts, moving of boulders and the construction of work camps in order to move machinery sufficiently close to the seashore. The act of mining leaves tailing dumps, most often left above the high water mark. The aesthetic and terrestrial impacts of these activities, albeit at a larger scale, have been discussed above.

Mitigation: It has been suggested that impacts of this nature could be mitigated if nearshore diamond pumping were undertaken exclusively from boats. Although possible, start-up costs associated with such a policy may be prohibitive for new entrants.

Kelp Cutting
Impact: Kelp (primarily Laminaria spp.) is often cut by divers to provide unencumbered access to the mining site. This activity causes a localised impact, the severity and duration of which depends on the extent and frequency of kelp cutting and the age of the plants. Kelp sporelings settle most successfully at or near the holdfasts of adult kelp plants, and recovery of kelp beds proceeds from the fringe of the cut area. Therefore, the greater the area cut the slower the recovery. By the same argument, a clear-cut area or repeatedly cut area will recover relatively more slowly than an area where only adults are cut and small kelp plants are left behind. In the best case scenario, recovery can take less than two years, although in some areas recovery has not occurred, especially where high densities of sea urchins (Parechinus angulosus) occur. Sea urchins feed preferentially on kelp sporelings, and in sufficient densities can keep an area entirely denuded of kelp. Many animals utilise the kelp bed habitats during the juvenile stage of their lives, and the loss of this habitat could have a small but important cascade effect.

Mitigation: Mitigation action includes restricting the width of the lane of kelp cut, discouraging clear-cutting, and discouraging repeated cutting.

Benthic Communities
Impact/Mitigation: Nearshore pumping of diamondiferous gravel by divers has a myriad of effects, such as the development of sediment plumes; uncovering of new reef where gravel is removed; the smothering of reef where tailings are discharged; the de-stabilising of reef where 'cementing' gravel is removed; physical disturbance of the suction pipe and diver abrading the reef; and the moving of boulders to access gravel beneath. 

Concern has been expressed regarding the effect of sediment plumes on the primary productivity of phytoplankton and macroalgae. Compared with the naturally high levels of suspended sediment in this highly dynamic nearshore environment or the fine tailings deposited into the sea from land-based mining operations, this impact is thought to be negligible. 

Nearshore mining putatively impacts the habitat of rock lobsters, rock lobsters themselves and their food source. A strong association of rock lobsters with reef- and boulder-dominated seabed has been established, as has the diversity of benthic organisms, most of which constitute the food source of the rock lobster. Diamond mining primarily targets sand and gravel areas, however, and the mining process does not directly threaten the reef and boulder communities. By removing gravel, mining may in fact expose expanses of previously embedded rock and boulders. Although these are initially uninhabited, recolonisation by benthic communities is rapid and the area becomes statistically indistinguishable from unmined areas within six months, despite the bottom topography being considerably altered. Mining activity therefore can effectively convert gravel gullies into boulder beds, which are potentially suitable for habitation by rock lobsters. 

The converse can also occur, however, if tailings are dumped onto reef- and boulder-dominated seabed, thereby smothering rock lobster habitat and/or food. Some dumping inevitably occurs on adjacent reef, but if this is restricted the impact is thought to be limited, as small quantities of tailings will be dispersed during subsequent storms. If the impact is cumulative, however, this can have the effect of converting preferred rock lobster habitat into sub-optimal small boulder or unsuitable gravel areas. These areas may be stabilised in time, although further research is needed before conclusive answers can be given concerning the impact of rock piles and tailings dumps. Mitigation measures should, however, include keeping the shifting of boulders to a minimum and dumping of tailings further offshore on non-reef areas.

Although diamond divers admit to pumping rock lobsters 'for the pot', the quantities involved are insignificant compared to the annual quota landed by the commercial rock lobster industry. To discourage poaching, however, mining vessels should be inspected occasionally for illegal catches, and mining licenses be confiscated if found guilty.

Seabirds and Seals
Impact/Mitigation: Disturbance of seabirds and seals on the nearshore islands off the Namibian coast is a further issue of environmental concern. Nearshore subcontractors working the island concessions are forbidden to land on the islands except in emergency or if accompanied by personnel from the Ministry of Fisheries and Marine Resources (MFMR) in Lüderitz. All landings are recorded and reported to the MFMR. 

Harder Fishing
Impact/Mitigation: Allegations have also been made that the activity of diamond boats within the Olifants River estuary, and mining operations near the estuary mouth, have led to a reduction in gillnet catches of harders by local subsistence fishermen. Problems associated with waste disposal and maintenance operations which potentially release contaminants (e.g. oil, antifouling paints, sewage) into the estuarine environment have also raised concerns. Although the conclusions of the EIA were speculative only, reduced catches were attributed to overfishing and possible recruitment failure rather than boat traffic. It was, however, recommended that mining near or within the mouth and increased use of the estuary as a harbour for diamond vessels be discouraged.

6.5.4 Environmental Impacts of Mid-water and Deep-water Mining Operations (>30m)
Tailings Plumes 
Impact: Fine tailings can remain in suspension for long periods forming plumes that are advected away from the mining vessel by ambient currents. Most of the silt sinks rapidly (minutes) during the initial convective descent phase; entrainment of seawater resulting in dilution of both the dissolved and particulate constituents of the discharge. Ultimately the density of the diluted discharge becomes neutrally buoyant, with the remaining particulate matter spreading and settling further through passive diffusion (hours). The potential impacts on water column processes of the temporary redistribution of slow sinking silts and clays originating from mining activities has received much attention in both Namibia and South Africa. A structured approach to the assessment of suspended sediment plumes, as recommended by the Environmental Protection Agency of the United States, has been adopted by the mining companies concerned. This includes desktop studies and predictive modeling in the pre-mining phase, followed by more intensive in situ biological and toxicological evaluations requiring field sampling, laboratory testing and rigorous data analysis. 

Although the plumes may extend several kilometers, the potential impact on phytoplankton communities through reduction of light, nutrient enrichment, remobilization of contaminants, and deep oxygen consumption through decomposition of silt particles during descent, is generally very limited and localized. The extent of the impact of the plume depends largely on the proportions of silts and clays in the targeted sediment, and the sea surface conditions during disposal. Measurements of dissolved nutrient concentrations (NH4, PO4, NO3 and NO2) in the tailings discharge were within the specified limits set by the "Water Quality Guidelines for the South African Coastal Zone". Rapid descent and dilution of dissolved nutrients and contaminants in the convective descent and passive dispersion phases resulted in ammonium concentrations declining to below detection levels within an hour of release. There was no evidence of the release of NO3 and NO2 from interstitial waters as is to be expected from anoxic sediments. Due to their low solubility in seawater, elevated concentrations of trace elements (Cd, Co, Cr, Mn and Pb) have, however, been recorded in the tailings plumes; those of Cd, Cr, Cu and Zn breaching the recommended water quality guidelines. Evidence suggests that pesticide levels resulting from resuspended biogenic muds are unlikely to exceed recommended guideline levels. Remobilization and subsequent uptake of contaminants by marine organisms has important implications for bioaccumulation down the food chain. Assessments of the potential oxygen consumption through decomposition of silt particles during descent have indicated that rates are low and no measurable impacts on the typical bottom water concentrations are expected. 

Ferrosilicon loss in the tailings has been reduced through the introduction of vertical impact crushers and sophisticated recovery systems, but an average of 127 t (in 1995) per vessel are still lost annually. In areas with iron deficiency, this could potentially increase primary productivity and alter the phytoplankton community structure.

Mitigation: No mitigation is warranted.

Impacts on Benthic Fauna
Impact: The mining process removes unconsolidated sediments, resulting in the destruction of benthic fauna, and modification of the benthic habitat in the mining path and in adjacent areas where disturbed sediments are re-deposited. This causes direct mortality of organisms through the dredging and discharging process, potential smothering of organisms affected by the fallout, and possible aggravation of oligoxic conditions causing migration or even death. Consequently, a significant change in abundance and diversity of benthos has been observed in mined areas and their immediate vicinity. Substantial restratification of sediments occurs thereby influencing the rate of recolonisation as well as the structure of the developing benthic community. The recovery rate of a perturbed area has been estimated to take as long as eight years, but habitat modifications may be permanent resulting in a persistent environmental impact and change in the associated communities. This may potentially affect the food chain and have important implications for the distribution and abundance of other marine organisms such as rock lobsters and fish. However, without baseline data on the natural variability and patchiness in benthic community structure with sediment type, depth, and transient changes in water quality, it has not been possible to provide a cumulative assessment of mining damage. Furthermore, spatial heterogeneity of benthic communities has precluded the application of results across wider areas. 

Mitigation: Leaving lanes of sediments undisturbed will facilitate the recovery of benthic communities.

Impacts on Fish and Fisheries
The fish fauna of the west coast of South Africa and Namibia has a low diversity and contains few endemic species. Most species are widespread and to some extent migratory and are thus able to escape from oligoxic incursions as well as disturbance by mining tools. Although baseline knowledge exists of the abundance and distribution of the commercially important species in the areas of mining activity (hake, monkfish, sole, kingklip, and rock lobster), attempts to quantify these on a sufficiently fine scale to determine the impacts of offshore mining have not been attempted. Rock lobster and sole are the most restricted in their distributions and migratory capacity and thus the most likely to be at risk. The main spawning areas of the commercially important fish species are primarily north (<25°S) of current mining activities in Namibia, and south (St Helena Bay) of activities in South Africa. The shallow shelf region between St Helena Bay and the Olifants River appears to be utilized as recruitment grounds by most of these species. Desktop studies have identified the main potential impact of mining on fish to be on the breeding success rather than on the adult stocks themselves. The impact is thought to be greatest in the water column below the thermocline where the vulnerable early life-history stages may be negatively influenced by oligoxic conditions in the suspended sediment plumes. No quantitative data are available, however, and the coincidence between the sediment plume and fish egg and larval distributions needs to be investigated further. 

The principle risk of offshore mining activities to rock lobster is the aggravation of oxygen poor conditions and the disruption of seasonal offshore migrations as part of their breeding and moulting cycles. Most of the rock lobster fishing activities occur within 5 nautical miles of the coast; overlap with offshore mining is thus limited. However, information on rock lobster behaviour in deeper water and the role of migrations is lacking and should be researched further before conclusions concerning the impact of mining can be made. 

Impacts on Other Marine Fauna
The primary sources of noise associated with mining operations are the sounds caused by equipment and machinery, and sonar and seismic equipment. The latter frequencies overlap with the spectrum of frequencies used by marine mammals to communicate and have the potential to cause injury and discomfort. 

Some crew changes involve aircraft flying low over wetlands, which has been found to cause disruption to the waterbirds. Reactions to fixed-wing aircraft and helicopters varies between bird species but foraging, roosting and breeding activities are generally negatively affected, potentially reducing reproductive success. Although no similar studies have been conducted on the effects of low flying helicopters on seabird and seal populations on offshore islands, short-term disturbances are to be expected.

6.5.5 Generic Impacts 
Numerous impacts are generic in nature, synonymous with virtually any shipping activity. These include waste disposal, sewage, paints, hydrocarbons, bunkering, freshwater, etc. Legislation is in place to deal with many of these impacts, and consequently these are not dealt with here.

Table 4. Summary of Socio-economic and biophysical impacts of marine diamond mining operations in the BCLME.

7. DIAMOND MINING IN THE BCLME - TOWARD INTEGRATED ENVIRONMENTAL MANAGEMENT

The Integrated Environmental Management philosophy, encompassing scoping, impact assessments and environmental management plans, is a large step toward the integrated environmental management of activities affecting the BCLME. Environmental concern, however, has had a recent birth, and the processes and mechanisms of environmental management are still evolving. The current model is good, but a few criticisms are warranted to take the environmental management of diamond mining in the BCLME into the future. Criticisms of socio-economic, biophysical and environmental management as a whole are discussed below.

7.1 SOCIO-ECONOMIC ENVIRONMENTAL MANAGEMENT
EMPRs completed to date are deficient in their attention to socio-economic impacts, and in defining appropriate measures to mitigate or optimise these effects. In many instances, the discussion of socio-economic impacts focuses on the positive impacts of the mining venture only, such as employment creation, and a brief discussion of the economic spin-offs for the local economy (without expanding on predicted local expenditure). Management actions to address the negative socio-economic impacts of mining, such as problems associated with influx of job seekers and the infrastructural and service capacity of the affected towns and their capacity to support mining activities, are seldom considered in any detail. Furthermore, EMPRs rarely set management targets or goals for example, for implementing affirmative action, and the purchase of goods and expenditure in local communities from small micro-enterprises. Mining companies are reluctant to commit themselves to these kinds of policies, which can be audited.

Blame for shortcomings in environmental management cannot only be levelled at the companies concerned. There is a need for the governments of the respective countries to create incentives and to provide appropriate guiding legislation. Perhaps the most pressing requirement in this regard, is the need for the governments of Namibia and South Africa to redress their policies on the allocation of diamond mining revenues. Consideration should be given to investing a certain proportion of annual revenues to the areas which support diamond mining in order to upgrade infrastructure, stimulate development and create employment for local residents, especially in anticipation of continued downscaling of onshore diamond mining. Incentives such as tax breaks should be considered to encourage companies to purchase a greater proportion of goods and services from local entrepreneurs. 

7.2 BIOPHYSICAL ENVIRONMENTAL MANAGEMENT
Many environmental impact studies undertaken to date have been speculative desktop assessments, or conducted after-the-fact. In most cases, pre-mining baseline data were lacking or inadequate, which preclude detailed assessments of changes to the biophysical environment attributable to diamond mining. In an ecosystem where natural heterogeneity in the biophysical environment is commonplace, a great deal of uncertainty therefore remains concerning the extent and significance of the damage caused by mining activities. For example, despite considerable desktop effort devoted to rock lobsters, conflicts arise time and again because speculation is not defensible. Directed field studies that recently been completed are helping to clarify this issue, however.

A further shortcoming of many environmental impact studies is that most studies are addressed at either a high taxonomic level, or at the level of the community. For example, the effects of diamond mining have been examined with respect to benthic communities, sea birds, fish, mammals, etc. When considered as a group, more often than not the conclusions reached are that impacts are minimal. Some species, however, may be neglected through such an approach and there are cases where mining may in fact detrimentally impact specific components of the community. This is not insignificant, especially if the species in question are rare, endangered, or perhaps of commercial value. For example, beach communities as a whole are considered resilient to disturbance. However, there is considerable body of circumstantial evidence that suggests one component of beach communities is particularly susceptible to diamond mining: the semi-terrestrial isopod Tylos granulatus. Human impact on Tylos is so widespread, in fact, that it is being considered for inclusion as a Red Data Book species. This animal warrants further attention.

7.3 ENVIRONMENTAL MANAGEMENT AS A WHOLE
Cumulative impacts are an important, although a largely ignored issue both within and between the various users of the BCLME. Between industries, environmental management is most often conducted in isolation. That is to say that the EMPRs of diamond mining companies examine the effects of diamond mining, those for oil and gas exploration likewise only examine their own direct impacts, and so on. In an ecosystem such as the BCLME that has a myriad of users, isolated approaches may fail to uncover possible cumulative effects between industries that could ultimately lead to environmental catastrophe. With increasing pressure on the BCLME from fishing interests, oil and gas exploration, diamond mining, coastal shipping and recreational use, there is a dire need for an integrated and co-ordinated approach to the management of activities affecting this ecosystem. 

On the other hand, cumulative impacts within the mining industry are also largely ignored. Impacts such as kelp cutting, disturbance to the benthic communities, and habitat modification, for example may act in synergy, although thus far these impacts have only been considered in isolation. Together, they may have chronic, acute or even beneficial impacts on the natural environment and these need to be further investigated through focused and scientifically valuable research and monitoring programmes. Such monitoring programmes will enable quantification of cumulative impacts in space and time, in relation to environmental and resource sustainability. The importance of cumulative impacts become all the more pervasive in an expanding and technologically advancing mining industry.

Environmental Management Programmes should be dynamic documents, being updating as mining methodologies or plans change, or as new environmental information becomes available. This is a side to EMPs that is not often seen. The plethora of monitoring activities have little value if the results of monitoring are not objectively evaluated and likewise incorporated within existing management programmes. Part of the problem is attributable to the insular approach to environmental management that has been adopted, which leads to considerable duplication in scoping, impact assessments, specialist studies and management plans. In addition to a waste of resources, information that is collected is rarely disseminated, with the result that mistakes can, and often are, repeated. As the problems faced by the mining industry are largely ubiquitous through the region, considerably more effort must be channeled into two activities: objective reviews of the information to date, and a means of consolidating directed research and monitoring.

The criticism levelled above becomes all the more pervasive when the future of marine diamond mining, and coastal and marine use as a whole, is considered. At present, the vast majority of diamond mining is terrestrial based, with marine mining enjoying only a small proportion of the effort. Numerous coastal mines are set to close over the next 10 to 20 years and future diamond mining effort is likely to expand into the offshore. Concomitantly, the stage is set to see an increase in effort in both fishing, and oil and gas exploration (see other documents in this series). Almost without question, this will lead to an increase in the number and severity of conflicts between these sectors, as the natural resource base is finite and shrinking, under pressure from an increasing number of users. This makes the need for co-ordinated efforts taking a holistic approach to environmental management all the more important.

7.4 CONCLUSIONS - THE WAY FORWARD
Environmental management of the marine diamond mining industry in South Africa and Namibia, although very much in its infancy, has made major progress. A considerable volume of baseline information, albeit at a fairly coarse scale, has been collected and is available for use in the management of the system. Most of the major biophysical impacts of the mining activities on the environment have been addressed and, wherever feasible, appropriate mitigation measures have been implemented. The total area of the marine environment affected per annum by the diamond mining industry as a whole remains relatively small relative to what is available. Thus, whilst some of the impacts of mining may appear very severe in terms of the local environment, these must be placed into perspective on a larger geographical scale. In terms of the biophysical environment, several issues still require attention, with cumulative impacts of mining coupled with those of other users, as well as selected single species studies being the most pressing. 

Perhaps the most significant step toward an integrated approach to the management of the environment is the establishment of fora as a means of fostering communication, education and securing funding. In Namibia, the Lüderitz Forum was established to tackle issues affecting all users of the marine environment and Lüderitz town. The Forum comprises representatives of local and national government (e.g. Ministry of Mines and Energy, the Ministry of Fisheries and Marine Resources), and the fishing and mining industry. A liaison committee is soon to be established for the West Coast region in the South Africa on which various industries and other coastal users will be represented. Another positive initiative has been the formation of the South African and Namibian Marine Diamond Mining Associations. The former association has recently adopted a coordinated approach to environmental management through the development of a Generic Environmental Management Programme. A consolidated environmental baseline report on the environment of the South African west coast B, C and D concession areas was compiled in late 1997, and is to be followed shortly by a baseline report for the A concession areas and a generic EMPR for all four zones. Such initiatives must be commended.

In Angola, however, marine diamond mining is very much still in its infancy. Few, if any, serious initiatives have been undertaken towards sustainable exploitation of the mineral resources in this country. While it is good to think that much of the experience gained and many of the lessons learned in South Africa and Namibia will put this country in good stead for the future, several major stumbling blocks remain. Decades of civil war and continued political instability have stifled the development of local expertise and prevented access by foreign scientists. Consequently, there is little information available with regard to basic knowledge of biological and ecological functioning of systems in this country. Much of the country lies within subtropical and tropical areas and most of the information gathered regarding the consequences of mining in temperate ecosystems of South Africa and Namibia will be of little value. In this regard, desktop approaches will be all but meaningless, necessitating more costly field-based approaches in order to establish meaningful baselines on which comprehensive impact assessments can be based.

 8. BIBLIOGRAPHY

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 9. PEOPLE CONSULTED

South Africa
Sue Lane: Sue Lane & Associates
Lionel Philips, Alexkor, Alexander Bay
Louis Luke, DMNM Human Resources Manager, Kleinsee
Patti Wickens, De Beers Marine, Cape Town
Andy Grills, De Beers, Namaqualand
Jeremy Midgely and Romaine Kotze, Nautical Diamonds/Arena, Cape town
Piet Slot-Nielsen, Transhex, Die Punt, W.Cape
Mr Agenbag, Minerals Development, DME, Cape Town
Mr A. Eager, Communications Dept., Minerals Bureau, Pretoria
Ms.N. Botha, Statistics, Minerals Bureau, Johannesburg 
Mr A. Damarupurshad, Mineral Commodity Specialist, Minerals Bureau, Pretoria
Ms. E. Swart, DME (Environmental Policy aspects), Pretoria
Mr van Rensburg, N.Cape DME, Kimberley
Mr. P. Schroeder, Ocean Diamond Mining South Africa Ltd
West Coast District Council

Namibia
Colleen Parkins, Environmental Officer, NAMDEB
Mr JJ Dohogne, Directorate of Environmental Affairs, Windhoek
Dr G. Schneicer, Director of Geological Survey, Ministry of Mines and Energy, Windhoek
Mr G. McGregor, Commissioner of Mines, Ministry of Mines and Energy, Windhoek
Mr W. Malango, Acting Director of Mines, Ministry of Mines and Energy, Windhoek
Dr. AE Macuvele, Ministry of Mines, Windhoek