The Three Musketeers Investment (Pty) Ltd plans to supply the Sinomine Resource Group–owned Tsumeb smelter with silica by undertaking small-scale mining and quarrying on Mining Claim 73963 at Farm !Uris No. 481. Environmental Compliance Consultancy (Pty) Ltd (ECC) has been appointed as the independent environmental assessment practitioner to run the environmental and social impact assessment (ESIA) for the project and to produce an environmental and social management plan (ESMP).
The operation will focus on collecting silica gravel from the quarry area and trucking it to the Tsumeb smelter, formerly owned and operated by Dundee Precious Metals Tsumeb (DPMT).
The proposed footprint is 17.6 hectares, with a planned output of about 1,500 tonnes of screened silica per month and up to 3,000 tonnes including fines.
The intended life of the operation is ten years. The site lies roughly 15 kilometres from Tsumeb and is accessed from the B1 road.
The project triggers listed activities under Namibia’s Environmental Management Act, No. 7 of 2007 and its 2012 Regulations.
As part of the environmental clearance application, an environmental scoping report, a full ESIA and an ESMP are required to support the competent authority’s decision.
The ESMP will be appended to the environmental scoping report and is based on the assessment’s findings; the scoping report remains the primary source for detailed project description, methodology, applicable legislation and impact findings.
The ESMP is a live document to be reviewed at defined intervals and updated if the scope changes or new information becomes available.
All personnel working on the project will be legally required to comply with the final ESMP once approved by the competent authorities and the Ministry of Environment, Forestry and Tourism (MEFT).
Three Musketeers Investment will hold the environmental clearance certificate and is responsible for implementing and managing the ESMP. Compliance will be monitored through daily activities and monthly inspections, with reporting to the competent authority as required.
Where any provision of the ESMP conflicts with a contractor’s obligations under contract or with statutory requirements such as licences, approval conditions, permits, standards, guidelines or relevant laws, the contract must be amended and statutory requirements will take precedence.
This ESMP does not cover occupational health and safety measures and will be set out separately in a safety management plan to be developed by the proponent.
The ESMP reflects the project description contained in the scoping report; any changes to design or operational methods may necessitate an update to the ESMP, and if warranted, further assessment may be undertaken.
ECC (Reg. No. 2022/0593) prepared the report on behalf of the proponent.
ECC and its authors declare independence, have no material interest in the outcomes, and no shareholding in the project, with remuneration not contingent on results or government decisions.
The information is based on the best available data and professional judgement at the time of writing, acknowledging that environmental conditions may change and absolute accuracy or currency cannot be guaranteed.
Silica is required at the Tsumeb smelter for process and plant operations. The smelter, constructed in the early 1960s to treat concentrates from the Tsumeb copper mine, is one of only five commercial-scale copper smelters on the African continent and is connected to the Port of Walvis Bay by rail.
Inputs such as silica, coal, concentrates and ore are commonly imported or moved domestically by rail.
The smelter produces blister copper, grading approximately 98.5% copper, for refining in Europe and Asia.
It also produces sulphuric acid as a by-product, which is sold to third-party customers in Namibia’s uranium and copper mining sectors.
To prepare the quarry footprint, the proponent anticipates obtaining a forest permit to remove encroaching bush over approximately 17.6 hectares before production commences.
Monthly quarrying is expected to total about 3,000 tonnes, including fines, with screened, loose gravel delivered to the smelter according to its specifications.
From an environmental management standpoint, the ESMP commits the operation to impact avoidance where feasible, minimisation where avoidance is impracticable, and rehabilitation of disturbed areas on a progressive basis.
It outlines how the proponent will manage key risks typically associated with small-scale quarrying and short-haul logistics near Tsumeb, including dust and noise control, erosion and runoff management, traffic safety, waste handling, spill prevention and response, and community relations.
It also sets out lines of responsibility for day-to-day supervision, incident reporting, training and induction, document control, and stakeholder communication. Oversight will include scheduled inspections, record keeping and corrective actions where non-compliances are detected, with the competent authority retaining the power to impose additional conditions through the environmental clearance process.
In practical terms, the project’s ten-year plan to supply silica to Tsumeb is designed to align with the smelter’s raw material needs while keeping the quarry’s footprint modest and manageable.
The combination of an approved ESMP, a separate safety management plan, and contractual alignment to statutory obligations provides the governance structure expected under Namibia’s environmental regime. If the scope of work evolves, the proponent will be expected to revise the ESMP and, where necessary, submit additional assessments for consideration by MEFT.
