Comments on the Final Environmental Impact Assessment Report to Support the Application for Environmental Clearance Certificate (ECC) for the Proposed 2D Seismic Survey covering the area of interest (AOI) in the Petroleum Exploration License (PEL) No. 73, Kavango Sedimentary Basin, Kavango West and East Regions, Northern Namibia

Natural Justice argues that the EIA for Reconnaissance Energy Namibia's 2D seismic survey in the Kavango Sedimentary Basin fails to meet the 2012 EIA Regulations. The organization claims the assessment lacks a 'need and desirability' analysis, relies on an inadequate four-day baseline survey, and ignores significant impacts on endangered species like African wild dogs, pangolins, and elephants. Furthermore, it asserts that the project violates indigenous rights by failing to obtain free, prior, and informed consent and ignores Namibia's climate change policies and international treaty obligations regarding the Kavango-Zambezi Transfrontier Conservation Area and the Okavango Delta.

• The EIA failed to conduct a mandatory 'need and desirability' analysis as required by the 2012 Environmental Impact Assessment Regulations, failing to assess how the project aligns with national policies or the goals of the Kavango-Zambezi Transfrontier Conservation Area.
• The baseline survey was insufficient, consisting of only four days of fieldwork, which the EIA admitted was too short to observe mammals and amphibians due to weather and time constraints.
• The EIA failed to study specific risks to the endangered African wild dog, including the impact of increased human presence, vehicle strikes, and the potential for survey activity to displace dogs into closer proximity with lions.
• The assessment ignored the risk that an influx of job seekers and increased human population density would increase the illegal trafficking of vulnerable pangolins.
• The analysis regarding elephants was flawed, incorrectly asserting that the 300 Hz frequency of weight drops is outside the range of elephant communication, while ignoring other impacts like habitat avoidance and trafficking risks.
• The EIA and Environmental Management Plan (EMP) contradict each other regarding the creation of new vehicle tracks; while the EIA claims no new tracks are envisaged, the EMP includes measures to 'rehabilitate all new tracks created.'
• The project fails to consider the cumulative effects of the seismic survey as a precursor to further exploration and commercial production, which Natural Justice argues violates the principle of intergenerational equity.
• Reconnaissance Energy failed to obtain the free, prior, and informed consent of indigenous people because public consultations focused on socio-economic benefits while omitting environmental, health, and cultural harms.
• The EIA does not analyze how the project's environmental degradation would impede Namibia's ability to adapt to and mitigate climate change, contrary to the 2010 National Policy on Climate Change.
• The project may violate international obligations under the Convention on Biological Diversity and the World Heritage Convention, specifically regarding the protection of the Okavango Delta.

APA

Natural Justice (n.d.). Comments on the Final Environmental Impact Assessment Report to Support the Application for Environmental Clearance Certificate (ECC) for the Proposed 2D Seismic Survey covering the area of interest (AOI) in the Petroleum Exploration License (PEL) No. 73, Kavango Sedimentary Basin, Kavango West and East Regions, Northern Namibia. https://naturaljustice.org/wp-content/uploads/2021/07/Namibia-Recon-Africa-2D-Survey-Comments-FINAL.pdf

Chicago

Natural Justice. Comments on the Final Environmental Impact Assessment Report to Support the Application for Environmental Clearance Certificate (ECC) for the Proposed 2D Seismic Survey covering the area of interest (AOI) in the Petroleum Exploration License (PEL) No. 73, Kavango Sedimentary Basin, Kavango West and East Regions, Northern Namibia. n.d. https://naturaljustice.org/wp-content/uploads/2021/07/Namibia-Recon-Africa-2D-Survey-Comments-FINAL.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=Comments on the Final Environmental Impact Assessment Report to Support the Application for Environmental Clearance Certificate (ECC) for the Proposed 2D Seismic Survey covering the area of interest (AOI) in the Petroleum Exploration License (PEL) No. 73, Kavango Sedimentary Basin, Kavango West and East Regions, Northern Namibia |url=https://naturaljustice.org/wp-content/uploads/2021/07/Namibia-Recon-Africa-2D-Survey-Comments-FINAL.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljusticendcomments, author = {{Natural Justice}}, title = {{Comments on the Final Environmental Impact Assessment Report to Support the Application for Environmental Clearance Certificate (ECC) for the Proposed 2D Seismic Survey covering the area of interest (AOI) in the Petroleum Exploration License (PEL) No. 73, Kavango Sedimentary Basin, Kavango West and East Regions, Northern Namibia}}, publisher = {Natural Justice}, url = {https://naturaljustice.org/wp-content/uploads/2021/07/Namibia-Recon-Africa-2D-Survey-Comments-FINAL.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }