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Proposed construction of nine mini cellular structures in Windhoek

Final Scoping Report April 2015

2015

ENVIRONMENTAL ASSESSMENT AND MANAGEMENT PLAN FOR THE PROPOSED CONSTRUCTION OF NINE MINI

CELLULAR STRUCTURES IN WINDHOEK FINAL SCOPING REPORT

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COPYRIGHT © ENVIRO DYNAMICS, 2015. ALL RIGHTS RESERVED

PROJECT NAME Environmental Assessment and Management Plan for the proposed construction of nine mini cellular structures in Windhoek

STAGE OF REPORT Final Scoping Report

CLIENT Mobile Telecommunication Company (MTC)

Enquiries: Morne Weitz

Tel: (061) 280 2634

E-Mail: [email protected]

LEAD CONSULTANT Enviro Dynamics

Enquiries: Eloise Carstens

Tel: (061) 223-336

E-Mail: [email protected]

DATE OF RELEASE April 2015

AUTHOR Eloise Carstens, Eddy Kuliwoye.

Internal Reviewer: Norman Van Zyl

mailto:[email protected]

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DECLARATION

I hereby declare that I do:

(a) have knowledge of and experience in conducting assessments, including knowledge of the Act, these regulations and guidelines that have relevance to the proposed activity;

(b) perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;

(c) comply with the Act, these regulations, guidelines and other applicable laws.

I also declare that there is, to my knowledge, no information in my possession that

reasonably has or may have the potential of influencing –

(i) any decision to be taken with respect to the application in terms of the Act and the regulations; or

(ii) the objectivity of this report, plan or document prepared in terms of the Act and these regulations.

Eloise Carstens

Environmental Assessment Practitioner (EAP)

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`

TABLE OF CONTENTS TABLES AND FIGURES .......................................................................................................... iv

APPENDICES ........................................................................................................................ v

ABBREVIATIONS .................................................................................................................. vi

1 INTRODUCTION............................................................................................................. 1

1.1 BACKGROUND ...................................................................................................... 1

1.2 TERMS OF REFERENCE ........................................................................................... 1

2 PROJECT AND SITE DESCRIPTION ................................................................................ 3

2.1 RATIONALE FOR THE PROPOSED PROJECT .......................................................... 3

2.2 WHAT IS A CELLULAR NETWORK? ......................................................................... 3

2.3 SUMMARY DESCRIPTIONS OF PROJECT ............................................................... 4

2.4 THE ALTERNATIVES ................................................................................................. 8

2.4.1 TOWER SHARING ............................................................................................ 8

2.4.2 ALTERNATIVE SITE LOCATIONS ....................................................................... 8

2.4.3 ALTERNATIVE TECHNOLOGY ....................................................................... 11

2.5 SUMMARY DESCRIPTION OF THE SITES ................................................................ 11

3 LEGALISLATION AND GUIDELINES .............................................................................. 13

4 PUBLIC CONSULTATION PROCESS ............................................................................. 15

4.1 THE INTERESTED AND AFFECTED PARTIES (I&APS) .............................................. 16

4.2 KEY ISSUES IDENTIFIED .......................................................................................... 17

5 IMPACT ASSESSMENT.................................................................................................. 18

5.1 METHODOLOGY .................................................................................................. 18

5.2 SCREENING AND ASSESSMENT OF IMPACTS ...................................................... 21

5.3 DISCUSSION ......................................................................................................... 24

6 CONCLUSIONS AND RECOMMENDATIONS ............................................................. 26

7 REFERENCES ................................................................................................................ 27

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TABLES AND FIGURES

Table 1: Project description of preferred alternative .................................................... 5

Table 2: Site description of preferred alternative ........................................................ 12

Table 3: Public consultation process followed during this EIA. ................................... 15

Table 4: Key stakeholders identified during the public consultation process ........... 16

Table 5: Main issues of concern .................................................................................... 17

Table 6: Definitions of each of the Criteria used to determine the significance of impacts ........................................................................................................ 20

Table 7: Definitions of the various significance ratings ................................................ 21

Table 8: Screening and assessment of impacts ........................................................... 22

Figure 1: Extent of reach of each of the type of cells (Mobile Operators Association, 2012). ......................................................................................... 3

Figure 2: Proposed location for the nine mini tower structures in Windhoek. .......... 7

Figure 3: Location of the preferred alternative KFC site option .............................. 10

Figure 4: Location of the preferred alternative Roman Catholic site option........... 9

Figure 5: Screening process to determine key issues ............................................... 19

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APPENDICES

APPENDIX A Coverage prediction maps for the 9 Mini BTS

APPENDIX B CV – Eloise Carstens

APPENDIX C Environmental Management Plan

APPENDIX D Stakeholders List

APPENDIX E Newspaper Notices

APPENDIX F Notice Board

APPENDIX G Background Information Document

APPENDIX H Exposure to Electromagnetic Fields

APPENDIX I Comments and Responses Trail

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ABBREVIATIONS

BID Background Information Document

BTS Base Transceiver Station

CRAN Communications Regulatory Authority of Namibia

CV Curriculum Vitae

ECC Environmental Clearance Certificate

EIA Environmental Impact Assessment

EMF Electromagnetic Field

EMP Environmental Management Plan

GPS Global Positioning System

I&APs Interested and Affected Parties

ICNIRP International Commission on Non-Ionizing Radiation Protection

MHz Mega Hertz

MICT Ministry of Information and Communication Technology

MTC Mobile Communications Limited

ORC Omusati Regional Council

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1 INTRODUCTION

1.1 BACKGROUND

Due to the constant growth in the use of mobile voice and data services in Windhoek, service providers such as Mobile Telecommunications (Pty) Ltd (MTC) are under pressure to continuously expand their communications network. By adding new infrastructures, cellphone reception and accessibility to mobile voice and data services can be assured. The quality of the mobile services provided by MTC to their customers is greatly improved (See Appendix A).

In accordance with the Environmental Management Act (2007) and its Regulations (2012) an Environmental Clearance Certificate (ECC) and thus an Environmental Impact Assessment (EIA) is required for the “construction of masts of any material or type and of any height, including those used for telecommunication broadcasting and radio transmission”.

Enviro Dynamics was appointed to conduct an EIA and develop an Environmental Management Plan (EMP) for the proposed project. At the outset of the EIA study 9 sites were proposed and considered as locations for the erection of the mini BTS. Public consultation was also done for the 9 proposed sites. However, due to unforeseen circumstances, 2 of the 9 sites fell away (after public participation) and are no longer to be considered for environmental clearance. The two sites that are no longer considered are the KFC site and the International University of Management (IUM) site.

Eloise Carstens is the Environmental Assessment Practitioner that conducted the EIA (see Appendix B for CV).

1.2 TERMS OF REFERENCE

The Terms of Reference for the proposed project is based on the requirements set out by the Environmental Management Act (2007) and its Regulations (February 2012). The process covered the following steps, which are reported on in this document as follows:

• Provide a description of the proposed activity (Chapter 2);

• Identify all legislation, policies and guidelines that have reference to the proposed project (Chapter 3);

• Identify existing environmental (both ecological and socio-economic) conditions of the receiving environment in order to determine environmental sensitivities (Chapter 2);

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• Inform Interested and Affected Parties (I&APs) and relevant authorities of the details of the proposed development and provide them with a reasonable opportunity to participate during the process (Chapter 4);

• Consider the potential environmental impacts of the development, and assess the significance of the identified impacts (Chapter 5).

• Outline management and mitigation measures in an EMP (Appendix C) to minimise and/or mitigate potentially negative impacts, which cannot be avoided.

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2 PROJECT AND SITE DESCRIPTION

2.1 RATIONALE FOR THE PROPOSED PROJECT

Due to the continued increase in the demand for quality mobile communication services in Windhoek, MTC should continuously expand their communications network in order to achieve additional capacity and coverage. This ensures that the quality of the service provided by MTC to their customers is ensured and greatly improved.

PROJECT SITE RATIONALE

Maerua Mall Due to a lack of serving signal level strength, customer service in/around the area is below license (CRAN) agreement and improvements are only possible by constructing a new site.

Grove Mall, Concordia, Ausspanplatz, Roman Catholic, KFC, Satcom,

School of Management,

Arebusch supermarket

Capacity limit was reached on the existing serving cells and expansion is only possible through the construction of a new mini site at each of the identified locations.

2.2 WHAT IS A CELLULAR NETWORK?

Networks are designed to ensure that mobile devices maintain a communication link with the network as these devices move from one cell (geographic area served by a Base Transceiver Station (BTS)) to another.

The cells overlap at the edges to prevent holes in coverage. If base stations are too far apart, calls cannot be handed over from one area to another and are

Figure 1: Extent of reach of each of the type of cells (Mobile Operators Association, 2012).

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interrupted or 'dropped' when mobile phone users are on the move (Mobile Operators Association, 2012).

There are three types of cells (Figure 1):

• Macrocell: Provides the main coverage in a network. Typically constructed on higher ground so that it is not obstructed by surrounding buildings and terrain.

• Microcell: Provides infill coverage and additional capacity where there are a high number of users in a macrocell. It is constructed at street level, usually between 300 m and 1000 m apart.

• Picocell: Provides localised coverage and is usually less visible. They are put up in shopping centres and airports to strengthen the signal and have even smaller services areas than a microcell.

The proposed sites in this report are microcells, designed to improve localised coverage.

2.3 SUMMARY DESCRIPTIONS OF PROJECT

A summary of the proposed sites and their specification is provided in Table 1.

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Table 1: Project description of proposed sites

Project site Site location Structure type

Structure design (Example) Type of Antenna

Power output (Watts)

Radio Frequency

Roman Catholic Existing billboard on the northern boundary of the property

Billboard

Integrated Antennas

5 1920 - 2170 MHz

Auspanplatz Circle

Existing billboard at the centre of the circle

Billboard 2 x Kathrein 736350 (8dBi Omni)

5 1920 - 2170 MHz

Concordia Existing billboard on the southern boundary of the Concordia College

Billboard 3 x Kathrein 742265 (65 degree, dual band)

20 880 - 960 MHz / 1920 - 2170 MHz

KFC Building On top of the KFC building, corner of Mandume Ndemufayo Avenue and Tal street.

Rooftop Integrated Antennas

5 1920 - 2170 MHz

Arebbusch Supermarket

On top of Supermarket building, Arebbush street in Cimbebasia

Rooftop 2 x Kathrein 736350 (8dBi Omni)

5 1920 - 2170 MHz

Equipment Box

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Project site Site location Structure type

Structure design (Example) Type of Antenna

Power output (Watts)

Radio Frequency

Maerua Mall On top of Maerua Mall

Rooftop

Grove Mall On top of Grove Mall

Rooftop

IUM (School of Management)

On top of the entrance gate at the School of Management

Rooftop Integrated Antennas

5 1920 - 2170 MHz

Satcom On top of an existing structure on the Satcom building in Suiderhof

Rooftop

Integrated Antennas

5 1920 - 2170 MHz

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Figure 2: Proposed location for the nine mini tower structures in Windhoek.

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2.4 THE ALTERNATIVES

2.4.1 TOWER SHARING

In terms of the Communications Act of 2009, service providers are required to first consider sharing existing infrastructure in the area, before constructing new structures. The use of billboards and buildings for this specific project is the culmination of the requirement that existing infrastructure should be used.

2.4.2 ALTERNATIVE SITE LOCATIONS

When considering site locations, MTC uses the following criteria to optimise the positions of their new structures:

• Coverage of existing network infrastructure

• Surrounding topography and built-up environment

• Established and future urban area

• The required footprint

• The most appropriate design of the facility

Within these limits, MTC investigated all possible alternatives to the proposed locations. Because the proposed mini structures have a small and specific coverage area, the specific locations were selected because it would achieve optimal coverage.

However, the initial KFC and Roman Catholic sites were investigated, but were found to be unfeasible because these institutions’ rejected the use of their premises to erect the antennas on. Subsequently these two sites were moved to alternative locations nearby, and thus became the preferred alternatives, but still bearing the same initial names. The new co-ordinates for both preferred alternative sites are listed below:

• The KFC site has moved to the rooftop of the Cashbuild building (opposiste KFC) at this coordinate position: - S22.56966 E17.08155

• The Roman Catholic site has moved off the hospital premises to a billboard in Mandume Ndemufayo Street (taxi rank), directly opposite the hospital premises. This location can be found at this coordinate position: - S22.56476 E17.08072

Site acquisition was done for both alternative sites. See figure 3 and figure 4 illustrating the alternative sites below.

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Figure 3: Location of the preferred alternative “Roman Catholic” site (on a billboard)

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Figure 4: Location of the preferred alternative “KFC” site (on the Cashbuild building rooftop)

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2.4.3 ALTERNATIVE TECHNOLOGY

To determine the best technology for the specific project it is important to understand the options that are available and what the limitations and advantages of each are:

Ø Mini vs. Macro BTS sites

A Base Transceiver Station (BTS) refers to the electronic equipment that facilitates wireless communication between the user and the network. It consists of a number of components including a transceiver and amplifier. Mini/macro refers to the size of the container in which this equipment is stored as well as the coverage area it provides.

The number and size of the equipment stored on a macro site is much more than that of a micro site. Because of the heat emitted from the equipment air conditioners are required to cool it down. Macro sites provide more options for expanding the coverage capacity but due to the size of the equipment it requires a larger footprint area and is often visually obtrusive. The antennae should also be located higher from the ground than what is required for the mini BTS. This means that macro BTS are usually either constructed on elevated ground (increasing the visual impact) or on structures of more than 15 m high (increasing the visual impact and the risk of civil aviation interference).

Mini BTS, on the other hand, are usually confined to compact containers with a footprint area of no more than 1 or 2 meters. The overall size of the equipment makes it visually more acceptable than macro BTS. These sites are however restricted in the number of antennae or radios it can accommodate and consequently a higher concentration of sites is needed to transmit the signal in the area.

Due to the longer transmission range of macro BTS another macro site in the project area could cause interference with the existing macro sites and thus compromise on the quality of the signal. For this reason MTC is proposing the construction of micro BTS structures. The localized coverage of the mini BTS provides good quality services for a small area.

2.5 SUMMARY DESCRIPTION OF THE SITES

Only the most pertinent environmental sensitivities have been outlined pertaining to the preferred alternative in Table 2 below.

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Table 2: Site description of preferred alternative

PROJECT ASPECT

DETAIL

Climate • Annual precipitation: Approximately 350 – 450 mm • Maximum temperature: 28-30˚C • Minimum temperature: 4-6˚C

Site ownership and occupancy

• Ownership of the 9 mini sites are divided so that: • Billboard structures – owner of the structure • Rooftop structures – private property • A legal agreement will be entered into with the owners of these sites once the

EIA process has been completed.

Surrounding land uses

Roman Catholic Various small business (e.g. car dealership), the Roman Catholic Hospital, Wernhill Park, the Taxi rank

Auspannplatz Circle

Various small businesses

Concordia Concordia College, residential developments

KFC Site Businesses including Fruit and Veg, fuel station, car dealership

Arebbusch Supermarket

Residential

Maerua Mall Businesses associated with the mall

Grove Mall Businesses associated with the mall

IUM (School of Management)

Institutional

Satcom Residential, Suiderhof Primary School, Army base camp

Civil aviation Due to the height of the structures not exceeding regulations, Civil Aviation approval is not required for any of the mini sites.

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3 LEGALISATION AND GUIDELINES

The pursuit of sustainability, with respect to any development, is guided by a sound legislative and policy framework. This section provides a review of applicable and relevant Namibian legislation, policies and guidelines. This review serves to inform the Developer and decision-maker at the Directorate of Environmental Affairs of the requirements and expectations, as laid out in terms of these instruments, to be fulfilled before the proposed project may commence and once operational. The findings of the abovementioned review are summarised below.

LEGISLATION/ GUIDELINE

RELEVANT PROVISIONS IMPLICATIONS FOR THIS PROJECT

NAMIBIAN NATIONAL LEGISLATION

Namibian Constitution First Amendment Act 34 of 1998

“The State shall actively promote… maintenance of ecosystems, essential ecological processes and biological diversity… and utilization of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future” (Article 95(l)).

Ecological sustainability should inform and guide this EA and the proposed development.

Environmental Management Act (EMA) (7 of 2007)

• Requires that projects with significant environmental impact are subject to an environmental assessment process (Section 27).

• Details principles which are to guide all EAs.

The principles laid out in the EMA should inform and guide this EIA process.

Labour Act 11 of 2007

Details requirements regarding minimum wage and working conditions (S39-47).

The KTC should ensure that all contractors involved during the construction, operation and maintenance of the proposed project comply with the provisions of these legal instruments.

Health and Safety Regulations GN 156/1997 (GG 1617)

Details various requirements regarding health and safety of labourers.

Listed Activities Notice and Environmental Impact Assessment Regulations GN 29-30 (GG 4878)

• Requires ECC for the “construction of masts of any material or type and of any height, including those used for telecommunication broadcasting and radio transmission”

• Details requirements for public consultation within a given environmental assessment process (GN 30 S21).

• Details the requirements for what should be included in a Scoping Report (GN 30 S8) and an Assessment Report (GN 30 S15).

Communication site triggers an EIA.

Conduct public participation as part of the EIA process described in the act.

Communications Bill, 2009.

Promotes the sharing of infrastructure of the dominant carrier with other carriers.

Encourage the sharing of towers to avoid

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LEGISLATION/ GUIDELINE

RELEVANT PROVISIONS IMPLICATIONS FOR THIS PROJECT

Provides for the regulation of telecommunications activities. The Bill provides for licensing and enforcement of conditions, and the approval of equipment and technical standards to ensure public health and safety.

cumulative impact.

The Atomic Energy and Radiation Protection Act, Act 5 of 2005:

Provides for the adequate protection of the environment and of people against the harmful effects of radiation by controlling and regulating the production, processing, handling, use, holding, storage, transport and disposal of radiation sources and radioactive materials, and controlling and regulating prescribed non-ionising radiation sources according to the standards set out by the ICNIRP.

ICNIRP standards will be used to determine the “safe distance” around the proposed site.

INTERNATIONAL STANDARDS AND GUIDELINES

ICNIRP Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic, and EMFs (up to 300GHz) (April 1998)

Provides international standards and guidelines for limiting the adverse effects of non-ionising radiation on human health and well-being, and, where appropriate, provides scientifically based advice on non-ionising radiation protection including the provision of guidelines on limiting exposure. ICNIRP exposure limits for non-ionizing radiation is 4.5W/m².

The proposed project needs to adhere to exposure limits set out in these guidelines.

The provisions most important, in terms of guiding this EA process from those listed above are those contained in the EIA Regulations, the Atomic Energy and Radiation Protection Act and the ICNIRP Guidelines.

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4 PUBLIC CONSULTATION PROCESS

Public Participation forms an important component of the Environmental Assessment process. A summary of the public consultation process followed during this EIA process is provided in Table 3 below:

Table 3: Public consultation process followed during this EIA.

ASPECT DESCRIPTION OF PROCESS

SHARING OF INFORMATION WITH PUBLIC

Stakeholder identification

Key stakeholders (see Table 4) were identified and included in a stakeholders list (Appendix D).

Newspaper notices

Notices were placed, for two consecutive weeks in two widely circulated newspapers, briefly explaining the development and its locality, inviting the public to register as stakeholders (Appendix E).

Notice board A notice board (Appendix F) was placed close to each of the proposed sites informing the local community of the proposed project.

Information provision

A Background Information Document (BID) was compiled that contained essential information about the project (Appendix G). The BID was forwarded to all authorities and registered I&APs.

Public comments period.

A public comments period was provided for from the 6th of November to the 4th of December 2014 on the BID and posters launched.

Public comments were provided between the 13th and the 27th of March 2015 on the Draft Scoping Report and its appendices. The comments received are

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ASPECT DESCRIPTION OF PROCESS

SHARING OF INFORMATION WITH PUBLIC

recorded in the Comments and Responses Trail (Appendix 1).

The public was notified that 2 of the 9 proposed sites with their alternative locations are no longer considered for environmental clearance, due to unforeseen circumstances.

4.1 THE INTERESTED AND AFFECTED PARTIES (I&APS)

Specific I&APs were identified from the broader project area, all tiers of government and the private (non-state) sector. In addition, notices regarding the project were placed in widely circulated national newspapers (Appendix E) for two consecutive weeks inviting members of the public to register as I&APs. A summary of the stakeholder groups, consisting of authorities and interest groups at national, regional and local level, are presented in Table 4. The complete stakeholders list can be viewed in Appendix D.

Table 4: Key stakeholders identified during the public consultation process

ITEM LEVEL DESCRIPTION

STA

KEHO

LDER

DA

TABA

SE

NATIONAL Ministry of Environment and Tourism

Ministry of Agriculture Water and Forestry

Ministry of Works and Transport

Directorate of Civil Aviation

Ministry of Health and Social Services

Ministry of Information and Communication Technology

REGIONAL AND LOCAL AUTHORITIES

City of Windhoek

NGOs & OTHER

Communications Regulatory Authority of Namibia (CRAN)

Radiation Awareness Namibia

Building Management

Site owners

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4.2 KEY ISSUES IDENTIFIED

Before one can assess the potential impacts associated with the proposed project, it is necessary to define key issues. These issues are determined based on the comments submitted to Enviro Dynamics, as well as professional opinion. It has been grouped according to theme to clearly distinguish the main issues of concern (Table 5).

Table 5: Main issues of concern

THEME ISSUE

HEALTH AND SAFETY CONCERNS

• Long term effects of non-heating continuous pulsing • Involuntary, uncontrolled, continuous exposure.

AGREEMENT OF SITE SHARING

• Establishment of agreement with site owner

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5 IMPACT ASSESSMENT

5.1 METHODOLOGY

The EIA Regulations require “a description of the significance of any significant effects, including cumulative effects, that may occur as a result of the undertaking of the activity”. In order to determine significance each of the potential impacts identified have been subjected to the following process displayed graphically (steps 1 and 2 – Figure 5) and in tabular form (Table 8) below. It forms the methodology for assessing the significance of the effects or impacts identified through this EA process:

1. The first step is to screen out (set aside) all impacts, raised during the public consultation process, which do not fall within the scope of this project and responsibility of the developer (see Table 5);

The next step is to determine whether sufficient information exists to assess the potential impacts of those that remain:

2. If insufficient information is available to assess (with a high degree of confidence) and recommend mitigation measures to address a given impact further investigation will be required;

3. If sufficient information is available to assess (with a high degree of confidence) and recommend mitigation measures to address a given impact no further investigation will be required and the impact will be addressed in the EMP.

To fully understand the significance of each of the potential impacts, it is necessary to subject each to a range of assessment criteria. The application of these criteria, in determining the significance of potential impacts, uses a balanced combination of duration, extent, and intensity/magnitude, modified by probability, cumulative effects, and confidence. The definitions of each of the criteria are contained in Table 6.

Finally based on the answers obtained after applying steps 1-3 a decision can be made regarding the significance of the impact based on three categories – low, medium or high.

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Figure 5: Screening process to determine key issues

Sufficient information to assess the impact

Insufficient information to assess the impact

No further investigation required

Further investigation required

Issue communicated to applicable authority

or client

NO YES

Does the issue/potential impact fall within the scope of this EA and the

responsibility of the Developer?

Determination of impact significance

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Table 6: Definitions of each of the Criteria used to determine the significance of impacts

DESCRIPTION

NATURE Reviews the type of effect that the proposed activity will have on the relevant component of the environment and includes “what will be affected and how?”

EXTENT Geographic area. Indicates whether the impact will be site specific (on-site where construction is to take place); local (limited to within 25km of the area); regional (limited to ~200km radius); national (limited to the borders of Namibia); or international (extending beyond Namibia’s borders).

DURATION Whether the impact will be temporary (during construction only), short term (1-5 years), medium term (5-10 years), long term (longer than 10 years, but will cease after operation) or permanent.

INTENSITY Establishes whether the magnitude of the impact is destructive or innocuous and whether or not it exceeds set standards, and is described as none (no impact); low (where natural/ social environmental functions and processes are negligibly affected); medium (where the environment continues to function but in a noticeably modified manner); or high (where environmental functions and processes are altered such that they temporarily or permanently cease and/or exceed legal standards/requirements).

PROBABILITY Considers the likelihood of the impact occurring and is described as uncertain, improbable (low likelihood), probable (distinct possibility), highly probable (most likely) or definite (impact will occur regardless of prevention measures).

SIGNIFICANCE Significance is given before and after mitigation. Low if the impact will not have an influence on the decision or require to be significantly accommodated in the project design, Medium if the impact could have an influence on the environment which will require modification of the project design or alternative mitigation (the design can be applied, but with deviations or mitigation). High where it could have a “no-go” implication regardless of any possible mitigation (an alternative design should be used).

STATUS OF THE IMPACT

A statement of whether the impact is positive (a benefit), negative (a cost), or neutral. Indicate in each case who is likely to benefit and who is likely to bear the costs of each impact.

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Table 7: Definitions of the various significance ratings

SIGNIFICANCE RATING

CRITERIA

LOW Where the impact will have a negligible influence on the environment and no modifications or mitigations are necessary for the given development description. This would be allocated to impacts of any intensity/ magnitude, if at a local scale/ extent and of temporary duration/time.

MEDIUM Where the impact could have an influence on the environment, which will require modification of the development design and/or alternative mitigation. This would be allocated to impacts of medium intensity/magnitude, locally to regionally, and in the short term.

HIGH Where the impact could have a significant influence on the environment and, in the event of a negative impact the activity(ies) causing it, should not be permitted (i.e. there could be a ‘no-go’ implication for the development, regardless of any possible mitigation). This would be allocated to impacts of high intensity, locally for longer than a month, and/or of high intensity regionally and beyond.

5.2 SCREENING AND ASSESSMENT OF IMPACTS

All impacts included in the table below fall within the scope of this project and responsibility of MTC. Each of the potential impacts is screened (Figure 5) and subjected to the criteria stipulated above (Table 6). The significance of each potential impact is determined based on the criteria in Table 7.

Detailed descriptions of mitigation measures for impacts that require mitigation are contained in the EMP (APPENDIX C).

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Table 8: Screening and assessment of impacts

POTENTIAL IMPACT

STATUS/ NATURE EXTENT DURATION INTENSITY PROBABILITY CONFIDENCE/ SUFFICIENT

INFORMATION AVAILABLE?

SIGNIFICANCE

PRE-MITIGATION

MITIGATION POST-MITIGATION

CONSTRUCTION PHASE

Noise impacts Negative. Construction activity will generate noise which may affect nearby residents or tenants.

Site specific

Temporary Low Probable Yes Low Work after hours to minimize disturbance (before 7h00 and after 17h00).

Low

OPERATION AND MAINTENANCE PHASE

Provision of access to a mobile cellular network

Positive. Access to a mobile cellular network will be provided to users in each area.

Local Long-term High Definite Yes Low Construct the mini structures.

High(positive)

Health impacts associated with thermal effects of EMF

Negative. Thermal effects due to exposure to EMF experienced by residents located in the areas adjacent to the proposed structure.

Site specific

Long-term Low Improbable Yes Low Adhere to ICNIRP Guidelines.

Low

Health Negative. Non-thermal Local Long-term Low Uncertain Yes Medium Adhere to Low

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POTENTIAL IMPACT

STATUS/ NATURE EXTENT DURATION INTENSITY PROBABILITY CONFIDENCE/ SUFFICIENT

INFORMATION AVAILABLE?

SIGNIFICANCE

PRE-MITIGATION

MITIGATION POST-MITIGATION

impacts associated with non-thermal effects of EMF

effects due to exposure to EMF experienced by residents located in the areas adjacent to the proposed structure.

ICNIRP Guidelines.

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5.3 DISCUSSION

The following should be noted concerning the negative impacts listed above that have a medium significance rating:

• Non-thermal health impacts of EMF exposure: The most significant claim regarding the non-thermal effects of EMF exposure from BTSs is that it increases the risk of cancer. Numerous epidemiological studies have been conducted of cancer relation to exposure to power-frequency fields (ICNIRP, 1998; 2009). No consistent evidence has emerged from these studies to substantiate these claims. In a recent review of 10 epidemiological studies conducted between 2003 and 2009 on EMF exposure from BTSs (Khurana, et al., 2010) makes claims that an association exists between increased cancer risk and EMF exposure from BTSs which are compliant with the 2010 ICNIRP guidelines. The precautionary principle should be applied in instances such as these where scientific uncertainty exists. In the absence of consistent evidence for these claims however the current 2010 ICNIRP will be used to inform safe exposure limits for residential and occupational areas. The ICNIRP standards hold to the precautionary principle and has been applied in compiling the safe exposure limits. For a more comprehensive description on EMF exposure and research done in this regard see Appendix H.

• The Namibian context: The protection of the environment and people against the harmful effects of radiation is regulated by the Atomic Energy and Radiation Protection Act (Act no 5 of 2005). Under Section 33(1) the National Radiation Protection Authority is charged with the administration of the act by a) inspecting any radiation source in order to assess radiation safety conditions b) taking the necessary action to enforce the provisions made in the Act.

Section 43 (3) of the Act specifically makes reference to the standards published by ICNIRP:

“Regulations made under subsection (1) must take due account of any guidelines or standards published by the International Commission on Radiological Protection, the International Commission on Non-ionising Radiation, the International Atomic Energy Agency or other relevant international organisations. (3) The Minister may incorporate the guidelines established and published by the International Atomic Energy Agency, World Health Organisation, the International Commission on Radiological Protection or the International Commission on Non-Ionising Radiation or any other standards or guidelines published by any international organisation into regulations made under this section by

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reference. (4) The Minister may incorporate such standards or guidelines with such amendments as he or she thinks fit.”

Pursuant to Section 43 The Electromagnetic Fields Exposure Regulations have been drafted with the specific purpose of:

i. Minimizing the exposure of persons to the harmful effects of non-ionizing radiation; and

ii. Creating the regulatory framework for the control and regulation of sources of non-ionizing radiation.

These draft regulations have been formulated from the WHO Model Regulations for EMF protection which is based on the ICNIRP Guidelines.

The National Radiation Protection Authority acknowledges that ICNIRP standards are based on short-term exposure of EMF and advises the adoption of precautionary principles (Eiman, 2015. Pers Com.).

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6 CONCLUSIONS AND RECOMMENDATIONS

The negative impacts with a medium significance rating have been identified. Mitigation measures have been devised and outlined above (Chapter 5.3) to address these so as to ensure that this project (if granted Environmental Clearance) is implemented in the most sustainable way possible. All impacts discussed above will be addressed in the EMP (Appendix C). The key impacts and their mitigation measures are summarised below:

• Non-thermal health impacts of EMF exposure: No consistent evidence exists that substantiate the claim that the non-thermal effects of exposure to EMF from BTSs increases cancer risk. The World Health Organization’s (2012) official stance is that “Studies to date provide no indication that environmental exposure to RF fields, such as from base stations, increases the risk of cancer or any other disease.” (WHO, 2013). In the absence of consistent evidence for these claims however the current ICNIRP (2010) standards will be used to inform safe exposure limits for residential and occupational areas. The ICNIRP standards hold to the precautionary principle and has been applied in compiling the safe exposure limits.

• Until such time that the National Radiation Protection Authority of Namibia has published specific directives for dealing with non-thermal, long and short term exposure of BTS structures, the limits set by ICNIRP should apply to the Namibian context. In terms of the uncertainties related to BTS sites and human health (e.g. pulsing and ELF), the ICNIRP standards are based on the precautionary principle and by adhering to the standards set by ICNIRP, the risks are expected to be minimal.

It is the opinion of Enviro Dynamics that sufficient information is available to address all impacts identified during this Scoping-Level EIA through the recommended mitigation and management actions for the construction, operation and decommissioning phases of the proposed project. If the recommendations included in this report and the EMP are implemented, the significance of the impacts can be reduced to reasonably acceptable standards and durations.

It is therefore recommended that only the seven remaining proposed sites (Arrebusch Supermarket, Ausspannplatz circle, Maerua Park, the Grove Mall, Concordia college, Sat-Com and Roman Catholic) and the following associated activities receive Environmental Clearance, provided that the EMP is implemented:

• The construction masts of any material or type and of any height, including those used for telecommunication broadcasting and radio transmission.

The proposed KFC and IUM sites should not be considered for Environmental Clearance.

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7 REFERENCES

Environmental Information Service Namibia, 2014. Powerlines and birds assessment tool. [Online] Available at: http://www.the-eis.com/ [Accessed 1 December 2014].

ICNIRP, 2009. Exposure to high frequency electromagnetic fields, biological effects and health consequences (100 kHz-300 GHz), Germany: International Commission on Nono-Ionizing Radiation Protection (ICNIRP).

International Commission on Non-Ionising Radiation Protection, 1998. ICNIRP Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic and Electromagnetic Fields (up to 300 GHz). Health and Physics, 74 (4), p. 494‐522.

Khurana, V. G. et al., 2010. Epidemiological Evidence for a Health Risk from Mobile Phone Base Stations. International Journal of Occupational and Environemental Health, Volume 16, p. 263–267.

Mendelsohn, J., Jarvis, A., Roberts, C. & Robertson, T., 2009. Atlas of Namibia. 3rd ed. Cape Town: Sunbird Publishers.

Mobile Operators Association, 2012. Mobile Operators Association. [Online] Available at: http://www.mobilemastinfo.com/base-stations-and-masts/ [Accessed 10 October 2012].

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