The following comment in the Scoping report for the marine component is quoted out of context and/or misinterpreted: Appendix 2A page 12 of 37:

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1 Namibian Marine Phosphate (Pty) Ltd Page 1 of 8 Comments and Response Trail All the comments made on the Marine Scoping Report, are presented in the table below, along with responses indicating where and how the comments were addressed. Name Date and Method Comment Response Section where addressed. Anja Van der Plas The following comment in the Scoping report for the marine component is quoted out of context and/or misinterpreted: Appendix 2A page 12 of 37: The correction is noted and the issues raised have been given to the appropriate specialist consultant to address. Page 13 of 44: MFMR: The dredging will release nutrients into the water column. What effect will this have on the ecosystem and to what spatial extent? Generally when we refer to nutrients in the marine environment we refer to the following nutrients in their dissolved form in seawater: silicate, phosphate, nitrate, nitrite, ammonium. In fact, in the comments we sent, the sentence following the quoted part refers specifically to the analysis of the pore water fraction of the sediment which should have indicated that we are referring to dissolved nutrients and specifically to dissolved phosphate (PO43-) rather than to the phosphate pellets (P2O5) that you inferred that we were referring to. Hence your response that The phosphate is insoluble in seawater is incorrect in this case as we are not referring to the same phosphate. Similarly, this response to our comment on

2 Namibian Marine Phosphate (Pty) Ltd Page 2 of 8 the changed Redfield ratio in the surface waters is also not appropriate as we are, once again, referring to the dissolved nutrients. The dredger will release the water fraction of the sediment at around 10 meter below the surface and, as pointed out above and we intended pointing out with our comment of 29 September 2011, the water fraction of the sediments that you intend dredging is likely to contain a high concentration of dissolved nutrients, specifically dissolved phosphate and dissolved ammonium. Anja Van der Plas The following comment in the Scoping report for the marine component is quoted out of context and/or misinterpreted: Appendix 2A page 20 of 37: The correction is noted and the issues raised have been given to the appropriate specialist consultant to address. Page 24 of 44 MFMR: Given that the fishing activities occur further offshore, no conflicts are expected between the mining activities and fishing activities. The above comment refers specifically to the commercial hake fishery which is restricted to outside the 200m depth zone, however, as you quote it, it may be misconstrued to refer to all fishing activities. Therefore please adjust our comment to read as follows: Given that the commercial hake fishing activities occur offshore of the 200-metre isobath, minimal conflicts are expected between the mining activities and the hake fishing activities as the mining will occur in

3 Namibian Marine Phosphate (Pty) Ltd Page 3 of 8 water depths of metres. Furthermore, in the comment just below this (also App 2A page 20) you mention our concern that the dredging activities are likely to impact the hake spawning. However, you leave out our concern that the dredging activities may also affect the (Cape) hake recruitment due to an overlap with an area where Cape hake pre-recruits tend to occur (please refer to page 2, paragraph 2 of the Comments MFMR submitted to you on 29 September 2011). The response on page 12 (of 37), Appendix 2a, in response to the concern raised about nutrient eutrophication of surface waters is misleading and avoids the issue raised. The nutrients referred to are not the phosphate deposits to be mined, but rather the high concentrations of bio-available nutrients (nitrates, silicates, phosphates, etc), which are typically in high concentrations within organic-rich sediments in the upwelling marine environments (where they are recycled from the settled biological material). The dredging (and release of fines) will likely release these into surface waters, causing severe phytoplankton blooms and disrupting the natural ecosystem in surrounding waters. The scale of these impacts and their details need to be addressed in the EIA studies. On page 13 (of 37), Appendix 2a, there is a question mark (? ) in the column headed Does this fall in the marine EIA Scope?, in reference to a query raised about how long it will take the sulphide-oxidizing bacteria to re- The Miocene marine phosphate deposits targeted by the dredging operation lie seawards (>190m depth) of the organically rich environment of the Holocene mud belt which lies inshore of the 150 m isobaths. The bacterial mats are associated with the Holocene mud belt generally inshore of the 150 m isobaths, hence then query as to whether the issue is relevant to this EIA. Page 14 of 44 Page 15of 44

4 Namibian Marine Phosphate (Pty) Ltd Page 4 of 8 grow on the dredged sediment surface. Why is there a question mark here? This is certainly an important fact that needs to be investigated by the EIA, as scientific evidence suggests that these bacterial mats provide an essential function to the benthic and pelagic ecosystems. At the top of 33 (of 37), Appendix 2a, indication is given that assessment of effluent discharge will be addressed in the terrestrial EIA. If there is no assessment of effluent into the marine environment during the marine EIA, then I understand that there will be NO effluent released into the marine environment once the sediment has been pumped ashore from the dredger? Is this correct? If there is to be any potential of waste material released into the marine environment, then this would surely have to be included in the marine EIA? At the bottom of page 34 (of 37), Appendix 2a, the meeting response suggested that shell wastes might be put back into the sea. However the adjacent column suggests that it will not be included in the marine EIA and the report response suggests it will be addressed in the terrestrial EIA. However if NMP is planning to discharge wastes back into the ocean, then this process is most certainly part of the marine concern and should be included in the marine EIA. Similar to point 4 above, on page 35 (of 37), Appendix 2a, mention of Some slurry containing sediments might be discharged,.... I repeat my point above if there is any foresight of potential discharges being released into the marine environment, then impacts thereof need to be addressed in the The potential release of nutrients and contaminants (e.g. heavy metals) and their possible impact will be addressed by the water column specialist. The marine EIA is designed to meet the requirements of the deepwater Mining Licence. The effluents from the land based plant to the near-shore will be assessed in the terrestrial EIA. As in the case with discharges (see above) the disposal of the shell fraction will be the subject of a specialist study for the terrestrial EIA. The marine EIA is designed to meet the requirements of the deepwater Mining Licence. The discharges from the land based plant to the near-shore will be assessed in the terrestrial EIA. N/A N/A N/A

5 Namibian Marine Phosphate (Pty) Ltd Page 5 of 8 marine EIA component. A frequent 'Report response' to ecological concerns raised, argues that The issue is the scale these potential impacts on the overall context of the ecosystem.... This is certainly valid, however the difficulty (and the question which I throw back at the proponent) is to define what the extent of the ubiquitous ecosystem is around the areas to be dredged? Certainly the entire Namibian coastline is not one homogeneous ecosystem. The relevant questions are 'what proportion of the locally unique ecosystem will be disrupted?' and 'which essential biological processes to the surrounding ecosystem will be disrupted and to what extent?. I would argue that these questions are very hard to answer with our current limited understanding of the marine systems off Namibia and the proponents should be required to adhere to a conservative precautionary approach in regards to their potential disruption of the environment and its dependent fishery resources. I would like to know who provided the 'Report responses' and based on what scientific background or evidence? Frequently in response to ecological concerns of the mining activities, the 'report response' includes phrases such as Unlikely, but these matters will be addressed by the specialists in the EIAEMPR., and...the impacts are likely to be negligible. However,.... These assertions that impacts will be 'unlikely' or 'negligible' are unfounded, premature and are made without adequate explanation of the scientific evidence to support them. In my The specialist studies will put the potential impacts of the dredging operation in the context of the broader marine environment The report responses were made in the context of the potential scale of the impacts with input from the appointed external environmental advisors/consultants to the project. However, in each case it was emphasised that the issue still had to be investigated by the specialist(s) concerned. N/A

6 Namibian Marine Phosphate (Pty) Ltd Page 6 of 8 Auriol Ashby (Private Consultant) opinion they represent a biased attempt at down-playing the concerns raised. An issue to be considered for both the onshore and marine project, is the impact of the very likely rise of sea level due to climate change. The world is assuming that this will not take place in the next 20 years but the scientists are shocked at the rapid pace of the breakup of both polar ice-sheets. Noted. and responses Trail Under theme General All coastal projects should be built with this potential impact in mind. Bronwen Currie Appendix 2A p.9 This project should only be considered if a series of extensive, comprehensive, relevant research and monitoring programmes, done well in advance and reviewed by competent specialists, can convincingly show that any negative impacts are negligible to the environment. I would like to emphasize the importance of this statement and add my support to it: as the focus area is understudied with regard to the proposed treatment it is not possible to assess the impacts satisfactorily until such studies are completed. Therefore several relevant research studies need to be financed and carried out by the developer before the project goes ahead: these include sediment-water column interface studies; improved benthic ecology studies to include <1mm animals, and modeling of chemical and sediment plume mixing at the expected rate of dredging, according to actual measured concentrations of potentially The project proponent will undertake such baseline studies and monitoring that is deemed necessary, to satisfy the requirements of, or verify the predictions made by, the expert studies in the impact assessment and to meet the requirements of the environmental contract. While the proponent remains open to consider supporting relevant 3 rd party primary scientific research programmes, the proponent considers that the onus to undertake primary scientific research and provide regional background data lies with national research institutions and relevant government departments. For example, as is the case for onland mineral exploration and development activities, relevant government agencies such as Geological Survey (Ministry of Mines and Energy) as well as other government department/agencies are responsible for conducting primary scientific research and mapping for provision of regional as well as and responses Trail Page 9 of 44

7 Namibian Marine Phosphate (Pty) Ltd Page 7 of 8 impacting substances in the surface muds (these are mentioned in the biogeochemical section). There is also the need for behavior and tolerance experiments on the fish of concern w.r.t. oxygen and sediment levels. Such studies must then be reviewed by independent specialists. local geological maps, geophysical survey maps, geochemical sampling maps /reports, topographic maps, infrastructure and zoning maps and much more. This information is provided to support investment and responsible project development. Bronwen Currie Regarding p.11 Biogeochemical impacts p.12 Mining will take place seawards of the mud belt where H2S and methane products are known to predominantly occur, thus the effect of the H2S and methane regime is likely to be negligible This issue will be addressed in the relevant specialist study where scientific opinion and potential impacts will be addressed. And a continual comment on many concerns: The impacts are likely to be negligible I disagree. Because of the presence of sulphide-oxidizing bacteria there must be available amounts of sulphide in the sediment, and associated impacts are likely they are not likely to be negligible. Extrapolation from core data from equivalent depths shows that appreciable amounts of H 2 S are likely to be liberated and that the disturbance caused by the frequency of dredging could keep the area anoxic. Therefore preliminary in situ biogeochemical studies must be made to measure all the parameters of concern mentioned in the Biochemical impacts section, together with in situ water column measurements, in order to calculate representative scenarios; - before the likely to be

8 Namibian Marine Phosphate (Pty) Ltd Page 8 of 8 Bronwen Currie negligible comment is given to these concerns. All concerns already listed in the biogeochemical impacts are valid and require such treatment. p.24 There is a close link between the water column and the sediment layer. It is important to also not look at them separate only. The water column specialist study will address the potential effect arising from the disturbance of sediments by dredging and responses Trail Page 28 of 44 Agreed and support this concern: there should be preliminary benthic-pelagic coupling studies completed prior to any mining, with respect to both biogeochemical and biological coupling in order to establish baseline conditions before any disturbance starts, (followed with continual monitoring during the proposed mining).