First steps toward best practice SEA in a developing nation: lessons from the central Namib uranium rush SEA

Abstract

The intent of this study is to contribute to the discussion of strategic environmental assessment (SEA) best practice based on experience gained in a recent SEA initiative: the central Namib (Namibia) uranium rush SEA. We evaluate this SEA process against internationally established characteristics of ‘best practice’ SEA to improve and strengthen future practice in Namibia. The study draws primarily on the final assessment report as well as inputs from six informants involved in the assessment. The results reveal some elements of good practice as well as areas for improvement, and in particular, the need for improved baseline data collection; adequate consideration of alternatives; committing to preferred scenario/options; enforceability; and a more robust institutional capacity. We offer insight into how consideration of these factors may help to strengthen SEA practice in Namibia. Overall, the SEA may not represent a ‘best practice’ example according to international standards, but it does suggest a potentially bright future for SEA practice in Namibia.

Keywords::

• strategic environmental assessment
• cumulative effects
• SEA best practice
• uranium mining

1. Introduction

Strategic environmental assessment (SEA) became prominent in the 1990s as a way to address the potential environmental effects of policies, plans and programs (PPPs; Lee & Walsh 1992; Bailey & Renton 1997). Concerns for PPPs ‘upstream’ of project environmental impact assessment (EIA) are warranted as many decisions that affect the environment often precede physical development proposals (Bina 2007; Noble 2010). It is argued that by focusing on the strategic context, PPPs can contribute to a higher level of environmental protection by integrating environmental considerations into planning and policy-making processes (Donnelly et al. 2006). However, SEA is also used as a stand-alone process to assess the potential impacts of competing development scenarios (Noble & Storey 2001; Geneletti 2012) and articulate a preferred development future.

While SEA takes many forms (Verheem & Tonk 2000), SEA best practices, procedurally speaking, are fairly well developed (Partidário 2012; White & Noble 2013). Its use has proliferated in both developed and developing countries such as Canada, Portugal, the UK and South Africa (Thérivel & Partidário 1996; Noble & Harriman-Gunn 2009; Croal et al. 2010). Comparatively fewer examples of SEA exist in developing countries (Dalal-Clayton & Sadler 1999; Alshuwaikhat 2005; Oberling et al. 2013) though evidence of increasing application are emerging with countries such as Namibia undertaking a sectoral SEA for its mining and coastal developments. This paper looks at a recent application of SEA to the Namibian uranium mining sector to investigate how well it compares to established international SEA best practices.

Namibia, with about 5% of global uranium reserves, is the fourth-largest producer with uranium mining accounting for 10% of its gross domestic products and over 40% of foreign exchange earnings (World Bank 2009). Uranium mining in Namibia has been ongoing for over a century with many of the deposits found in the central Namib region, although the first uranium mine in the region, Rössing Uranium Mine, was officially commissioned in 1976 (Smith 2007). Uranium prospecting occurred at a relatively low intensity until a recent global scramble for uranium – otherwise tagged a ‘uranium rush’ – both by existing (e.g. Germany) and emerging (e.g. China) interests as part of the drive to meet their projected nuclear reactor requirements (Ellmies 2009; Ministry of Mines and Energy [MME] 2010).

As of 2011, 36 exploration licenses for uranium exploration have been issued in the central Namib region (Mischo & Ellmies 2012). Environmental consideration via the Minerals Act (Act No. 33 of 1992) and the Environmental Management Act of 2007 (Smith 2007) is often part of the licensing screening criteria; however, independent scientific enterprise and findings from civil societies are revealing that with the absence of a strategic direction, the existing piecemeal and often discretional environmental management approach will be inadequate to combat large-scale cumulative effects associated with mining activities in the region (Acheson 2011; Dasnois 2012). The ‘uranium rush’ as well as the need for a wider understanding of the mining processes, associated environmental effects and their interrelationships with ecosystem functions and wider issues of regional sustainable development pressured the Namibian government to declare a moratorium on the issuance of uranium prospecting licenses in 2007 (Pietrzela 2013). The objective was to re-orientate prospecting and exploration activities toward a new agenda shaped by environmental issues and prevention of irreversible environmental impacts using SEA (MME 2010). This decision becomes more important as debates surrounding the nuclear energy regime (especially since the Fukushima [Japan] earthquake of 2011) and concern for its inherent unquantifiable environmental risk continue to grow.

The potential benefits of SEA include the opportunity to design a proactive framework by which project-specific impacts and benefits can be measured (Dalal-Clayton & Sadler 1999; Runhaar 2009; van Doren et al. 2013). It also has the capacity to address complex issues of cumulative effects and regional sustainability (Arce & Gullón 2000; Nilsson & Dalkmann 2001; Retief 2007; White & Noble 2013) while also enhancing social learning (Sinclair et al. 2009; Stoeglehner 2010), which is perhaps why more developing countries are adopting it. In order for SEA to progress in a country like Namibia, it is useful to compare early SEA practice with internationally established best practices and at the same time look at how environmental governance and implementation context may affect it. In Namibia, there is a recognized need for SEA to guide uranium exploration; yet few attempts to date have been made to understand the success of its application. By investigating the SEA process, future environmental assessment of PPPs in Namibia can have improved outcomes.

2. SEA best practice

In this paper, SEA is defined as the ‘systematic process for evaluating the environmental consequences of proposed policies, plans or programmes in order to ensure they are fully included and appropriately addressed at the earliest stage of decision-making on par with economic and social considerations …’ (Sadler & Verheem 1996, p. 27). The objective of an SEA is to help protect the environment and ensure that environmental issues are fully addressed during planning, policy and/or decision-making process while at the same time promoting sustainable development (Thérivel 2004; White & Noble 2013). It is considered a broader, more proactive approach to environmental assessment that allows long-term planning and includes regional environmental concerns (Canada-Nova Scotia Offshore Petroleum Board [CNSOPB] 2003). This implies that larger sectoral policy or broader geographic environmental issues are strategically addressed before individual projects are defined. The strategic context is also driven by the need to consider environmental factors at the early stage of decision-making, as well as the increasing obligations toward sustainability-focused policy-making (Nilsson & Dalkmann 2001; Retief 2007). It is often anticipated that this approach will result in individual projects with improved environmental characteristics (CNSOPB 2003; Fischer 2007).

Studies of best practices in SEA have evolved over time, captured by different labels such as ‘effectiveness criteria’, ‘good practice’ and ‘performance criteria’, especially since the early 1990s when SEA studies began to proliferate (Sadler & Verheem 1996; Nooteboom 2000). A 1999 document prepared by the International Association for Impact Assessment & Institute of Environmental Assessment (IAIA 1999) was the first to formally characterize key principles that should inform the design, process, implementation and monitoring of EIA generally. The context of SEA was also envisaged in the document. The primary reason for developing these principles was to serve as a pruning approach to ‘promote the effective practice of EIA consistent with the institutional and process arrangements that are in force in different countries’ (p. 2). To accurately interpret the reliability and success of an assessment, two set of principles were suggested in the document1: (a) ‘basic principles ’ – a list of 14 factors that should characterize the quality of an assessment and (b) ‘operating principles,’ which address the extent to which each stage of the assessment (e.g. screening, scoping, implementation, etc.) exhibits each of the 14 basic principles.

A detailed description of best practice characteristics for SEA described as ‘assessment within a strategic context’ can also be found in later studies (Fischer 1999; Partidário 2003; Dalal-Clayton & Sadler 2005; Marshall & Fischer 2005; Fischer & Gazzola 2006; Sadler et al. 2010). Generally speaking, the ideal practice would arguably be to use all of the suggested basic principles for EIA to also conduct best practice SEA. Often, however, many of the basic principles listed in the IAIA's document share characteristics that are analogous to each other. Credibility, for example, which emphasizes professionalism, rigor, fairness, objectivity, impartiality and balance in assessment as sub-themes, exhibits similar characteristics with principles such as efficiency and practicality (listed as separate basic principles), thus making it challenging to isolate each principle and interpret differently without an overlap. Fischer and Gazzola (2006) observe in a study of the Italian SEA system that many of the best practice criteria in SEA literature are proposed largely based on the experience of a few countries such as the UK and the Netherlands. This observation suggests that a systematic process for widening the scope of such studies may be valuable to further developing best practice while also contributing to more beneficial, context-relevant SEA practice in different jurisdictions. As SEAs are carried out under different institutional and regulatory environments, studying SEA in other contexts, including developing countries, will help to advance discussions and knowledge about what constitutes best practice SEA internationally.

More recently, Noble and Harriman-Gunn (2009) proposed a methodological framework that is specific to the context of regional SEA (Figure 1). The framework is based on an earlier one proposed by Noble and Storey (2001), which is a seven-stage process developed to identify a strategic option for energy policy in Canada. For cases where experience in SEA is rudimentary and insufficient, Fischer (2007, p. 66) states that: ‘the seven “gateways” introduced by this [Noble and Storey] framework made rational sense to in-house personnel and senior management’ with responsibilities for carrying out SEA but having limited experience doing so. To further strengthen the post-assessment stage where SEA is implemented and follow-up activities are carried out, Noble and Harriman-Gunn (2009) proposed a modified framework that expanded upon the initial Noble and Storey (2001) framework.

Figure 1 SEA methodological framework introduced by Noble and Harriman-Gunn (2009).

Noble and Harriman-Gunn's (2009) framework is a nine-step process conceptualized in three different phases of assessment that in addition to reflecting the principles and stages of the earlier Noble and Storey (2001) framework, explicitly addresses the stages of mitigation and follow-up. In the pre-assessment stage, a ‘terms of reference’ (ToR) detailing the objectives of the SEA is developed to help identify issues of concern, and environmental stressors and trends. In the main assessment stage, different strategic options are identified and evaluated to determine which is most preferred based on the stated objectives of the SEA. In the final phase of assessment, mitigation needs and required follow-up actions associated with the preferred option are determined, followed by the implementation of the entire assessment report.

Noble and Harriman-Gunn (2009) argue that SEA effectiveness and performance can be best understood during the implementation phase when PPP results are expected to be measured, monitored, revised and communicated appropriately, and when influence on any downstream EIAs and development activity can be observed. With primary reference to the Noble and Harriman-Gunn's framework described above as the basis for ‘best practice’ principles, this study attempts to reconcile the approach adopted in the central Namib uranium mining SEA to gauge the effectiveness of the process, identify features that affect its performance, and the required steps to strengthen future SEA process in Namibia.

3. Methods

3.1 The central Namib uranium rush study area and SEA context

The central Namib is located in the west central part of Namibia within the Erongo Region and extends from the escarpment in the east, to the Atlantic coast in the west, and from the Ugab River in the north to the Kuiseb River to the south (MME 2010). The region is characterized by aridity and vast desert landscapes and has been identified as a region high in biodiversity. A recent survey of plant species in the region identified 70 species that are either threatened or endangered, 17 of which are endemic to the region (Burke 2012). Most of the region is designated conservancies (i.e. National Parks; Figure 2) and as a result secondary occupations such as tourism and transportation services are increasingly part of the main economic activities (Ministry of Health and Social Services [MHSS] 2013). The growth in demand for uranium, especially in the last decade, has been identified as a major threat to biodiversity, livelihood sustainability and access to clean potable water in the region (Smith 2007; Von Hase 2012).

Figure 2 Map of Erongo region. Source: http://www.erc.com.na/maps/erongo-region/.

The need for a balance between nature conservation, economic growth and social well-being is a major challenge, as mining remains the mainstay of Namibian economy but results in significant negative implications for regional welfare and sustainability (Von Hase 2012). Biodiversity studies, economic planning and exploration licensing have progressed over the decades in a disjointed uncoordinated manner providing counter-balance effects on efforts to promote sustainable regional development (Pietrzela 2013). As a result of the potential for increased mineral exploration in the region and its cumulative effects, and recognized limitations of an uncoordinated approach to resource management, the idea of a strategic approach as an overarching blueprint for further licensing and exploration activities was promoted by a section of the civil society. As a response, in January 2009, the Government of the Republic of Namibia contracted the Southern African Institute for Environmental Assessment to prepare a SEA for the central Namib uranium rush. Its overall purpose was to provide a strategic direction for uranium industry with emphasis on the cumulative effects and sustainable development of mining activities (Tarr 2008; Walmsley et al. 2010). Four objectives were identified to guide the SEA study: (1) to develop and assess viable scenarios as the basis for decision-making and formal planning; (2) to recommend a strategic approach for sustainable mining development; (3) to identify cumulative impacts and propose mitigation strategies; and (4) to develop a strategic environmental management plan (SEMP).

A 30-member Steering Committee was established to ensure representation from key stakeholders and development sectors, including academics, community-based organizations, non-governmental organizations (NGOs) and industry. The role of the steering committee included the dissemination of information within their institutions and networks, and providing critical feedback to other stakeholders during deliberations. During the 16-month SEA process, the Steering Committee met eight times. Youth workshops and debates were held to create awareness and stimulate environmental responsibility at a ‘grassroots’ level. The ToR restricted the SEA scope to mining and related activities such as construction of desalination and chemical plants rather than also looking at ‘airport and harbour expansions, seawater desalination, fishing, aquaculture, irrigated agriculture and urban expansion’ (MME 2010, pp. 2–3) that are in existence or being planned for in the region.

The ToR also required that the SEA would feed into subsequent processes of planning, licensing and decision-making in the mining sector (Eberhardt & Nghilila 2009). Notwithstanding the huge investment of human and financial resources into the SEA process, limited understanding exists about whether the process reflects international best practice standards or whether it contributed to more environmental-friendly mining practices in the central Namib.

3.2 Data collection and analysis

Data for the present study were gathered from the online version of the Final Report of the central Namib uranium rush strategic environmental assessment released in January 2011. The report was supplemented by peer-reviewed works, newsletters, government publications and industry reports regarding the case. We analyzed the documents by systematically extracting relevant information to compare the central Namib SEA approach to the SEA best practice criteria outlined in Section 2. We did not consider the analytical methods and techniques applied at each stage of the SEA process to assess their overall relevance or effectiveness as the focus of the study is on the assessment process. However, the details of such methods and techniques are discussed where they help to illuminate process effectiveness. Additional inputs were sought via email from project informants who were stakeholders listed in the SEA reports. A total of 22 informants were contacted, but only six (denoted as R1–R6 in the analysis) eventually agreed to participate over the course of the six months that the recruitment lasted. Out of the six, three are consultants, two government representatives and one from an NGO. We found this number adequate for the study judging from the fact that five of the six informants are SEA experts and were involved in all the stages of the SEA. Qualitative interview data were coded theme by theme based on the identified best practice principles and entered into spreadsheet software for analysis. The process is further compared subjectively to the SEA best practice characteristics mentioned above using three criteria: (i) met – thoroughly, completely and efficiently performed; (ii) partially met – some omissions, deficiencies and shortcomings; and (iii) not met – significant omissions, deficiencies and shortcomings. The document analysis and survey responses resulted in the identification of key process elements that influenced the outcomes of the central Namib SEA.

4. Results

The SEA consisted of four phases: a baseline study that involved the collection of available data used for the assessment; scenario analysis based on four different trends; cumulative effects assessment including the desired state of the environment during and after the uranium rush; and the SEMP. Discussion of each phase is presented in the following sections.

4.1 Baseline study

The first step of the SEA was to obtain a thorough understanding of the current situation regarding the receiving environment. This resulted in the identification of factors such as biodiversity and heritage resources, the state of water, power and other resources, the adequacy of existing social and physical infrastructure, and radiation and health levels. Although the term valued ecosystem component(s)2 – a term more popular in wider EIA literature – was not used in the SEA report, the overall objective was to identify key issues from uranium mining that affect both human environment and the ecological integrity of the region. Some of the data were obtained from the previous mine-specific EIAs, government departments, industry reports and other studies. New studies were also commissioned by the project steering committee in mid-2009 to gather additional data where regional data deficiencies became evident. To identify data for inclusion in the baseline assessment, a consultation process that combined interviews, focus-group discussions, a youth workshop and debate, a questionnaire survey and a multi-stakeholder workshop was conducted. A further outcome of the stakeholder engagement process was to guide the SEMP as a set of ‘desired states’, or visions as to how people would like to see the central Namib in the future.

There was consensus among project informants that this phase was the most challenging in the process. First, ‘getting all stakeholders identified without omitting any’ (R2) and ‘setting up a valuable and functioning steering committee’ (R1) in order to build a transparent and credible process were some of the initial challenges. Second, reaching consensus on critical tasks, especially agreeing on what constitutes an environmental quality objective (EQO) for the SEMP, was also identified. Some stakeholders were more favorably disposed to designating some areas as ‘no-go’ areas for future uranium prospecting and mining, while others saw the inclusion of such as a plan to limit future exploration and associated economic prospects in the region. As explained by one of the consultants for the SEA (R3):

… we wanted to see certain areas of the Namib excluded from future prospecting and mining because of their value for tourism, biodiversity conservation, and heritage value. This principle was rejected by government mining authorities, and we ended up with a very watered down system of ’red flag’ zones where extra precautions would be necessary if mining was to go ahead.

This reclassification was perceived as a real risk because of a number of newly licensed exploration companies with ‘unproven reputations’ (R1) and that without such a caveat, ‘the accelerated exploration activity, particularly in the park or other recreational areas’ (R1) may be counter-intuitive to the objectives of the SEA.

4.2 Scenario analysis

What scenario planning does is to simplify an avalanche of data into a limited number of possible states (Schoemaker 1995), envision plausible transformations and bring them into social decision processes (Peterson et al. 2003). Exploratory scenarios (i.e. descriptive scenarios) are those that are developed from the present to explore what might happen in the future while normative scenarios (i.e. prescriptive or anticipatory) take a target as a starting point and back-cast on how this future could emerge (Alcamo 2001; Börjeson et al. 2005). An exploratory type of scenario analysis was used in the Namibia uranium SEA which provided insights into its emphasis on the global uranium market trend. Based on the current global uranium demands and Namibia's estimated reserves, projected development trajectory emphasizes expected production capacity of the uranium industry. Using this approach, four possible futures of uranium exploration in the region were envisioned: below expectation scenario (up to four mines operating by 2020); expected scenario (two to six mines operating by 2020); above expectation scenario (up to 12 mines operating by 2020); and a ‘boom and bust’ scenario (worst case scenario where all the mines close suddenly and in an unplanned way).

The forces and dynamics of the uranium rush also influenced the analysis of each scenario, particularly concerns about uranium supply security due to diminishing secondary uranium supplies and typically long lead times involved in expanding primary uranium production capacity (MME 2010). Other evaluative factors applied in constructing the scenarios included:

project-specific factors such as the attractiveness of the project, the seriousness of the investor, the quality of project management, and the degree to which the project proponents manage to establish good working relations with and be accepted by local stakeholders. (MME 2010, pp. 4–19)

The scenario analysis fed into the impact identification and trend analysis of the cumulative effects for the SEA. Notwithstanding the importance placed on scenario analysis in the report, however, no preferred scenario was selected or recommended to decision-makers. One consultant (R4) stated that the purpose of the SEA was simply to ‘understand the implications of each scenario’ as a tool to guide future licensing and exploration. Another informant (R2) noted that as most mines are not operational yet, it is difficult to select any preferred scenario as such decisions are ‘dictated by (economic) circumstances.’ It was also reportedly difficult to understand how best to categorize the current volume of mining activities in the region; while one consultant described the situation as ‘below expectation scenario’, another – an NGO informant – described it as a ‘boom and bust’ scenario. Both arguments are valid depending on the particular context and interpretation. While the current functional mines in operation are still fewer than four and therefore ‘below expectation’ based on the SEA document, the same is also true for ‘boom and bust’ in a situation where the 36 already licensed companies commence operations without any commitment to implementing the SEA.

4.3 Cumulative impacts analysis

A thematic analysis of the cumulative effects of the uranium rush on various components of the receiving environment was conducted based on the first three scenarios. These are impacts felt beyond the mining license area including those of other developments that are expected within the same time and spatial boundaries. In assessing the cumulative impacts of uranium mining, the scope of assessment was expanded to include projects with potential interactions with mining development such as transportation, power lines, roads and railway. Future predictions were also based on the baseline data collected in phase I. Out of the 16 EQOs identified, seven were analyzed for cumulative effects based on the desired state of environment during and after the uranium rush. These were health, infrastructure, sense of place, water, government revenue, social structure, and biodiversity. Different trends, predictions and mitigation strategies were studied for each of the objectives. An attempt was also made to present the link among the objectives by aggregating the positive and negative effects to show which environmental aspects would be most affected.

For example, the cumulative impact of the uranium rush on biodiversity identified over 90 biodiversity features (e.g. critically endangered – 57; endangered – 30; vulnerable – 7) within the entire region. Areas of high biodiversity were broadly classified into two based on the impacts of mining activities – the ‘red flag’ (where extra precautions would be necessary if mining was to go ahead) and the ‘yellow flag’ (areas where mineral license applications will be approved only after careful consideration). Figure 3 shows the combined effects of different activities resulting in habitat loss based on the three different development scenarios, with mining contributing approximately 98% of the total predicted impact in all three of the analyzed scenarios.

Figure 3 Cumulative habitat loss potentially caused by mines and new infrastructure (in km²) under the three scenarios. Source: MME (2010).

According to the SEA report, the areas were calculated on the assumption that the construction and final footprints in all cases will be minimized and that most infrastructure will be confined to a designated corridor. It was also assumed that where possible, there will be optimum use of the infrastructure, for example, one pipeline supplying water to more than one mine. The fourth scenario (the ‘boom and bust’) was not included in the analysis. One participant (R1), in particular, observed the inadequate treatment of the ‘boom and bust’ scenario analysis as a major weakness of the SEA, explaining that the ‘scenario was never properly addressed in the SEA … and yet that is currently the scenario in which we are sitting.’ This is perhaps due to that the government of Namibia had already issued plenty of exploration licenses to enable scenario 3 in the minimum, before declaring a moratorium on issuing more, which suggests ‘closing the stable door after the horse had bolted’ (Walmsley & Tarr 2011). The reality on the ground, however, is that two uranium mines are in operation (Rossing and Langer Heinrich), one is in ‘care and maintenance’ (Areva), a new one is under construction (Husab), and the other prospects are ‘treading water’, hoping for the uranium price to improve. Therefore, the current situation can be described operationally as scenario 1, but in terms of exploration licenses already issued, it suggests an ‘above expectation scenario’.

4.4 Strategic environmental management plan

The goal of the SEMP was to provide a framework and coordination for the implementation of the SEA. It is a framework and roadmap for addressing the cumulative impacts of the existing and potential developments in the region using a precautionary approach in relation to the limits of acceptable change. As explained by one of the informants (R6), ‘the SEMP is not an implementation plan per se but provides a framework for monitoring towards the EQOs.’ The task of implementation has been left in the hands of individual mining operators and, as explained by another informant (R3), ‘the obvious government department, Environment, was reluctant to lead a planning process for environmental least harm’ despite the ‘potentially significant’ benefits of an integrated approach to implementation and monitoring. Project informants recognize the need for: (1) improved political will to keep up the momentum; (2) formal legal backing for the implementation of the SEA; and (3) incorporating adaptive management practice into the follow-up and monitoring activities. Given the difficulties related to implementation, there is a mixed perception of the usefulness and effectiveness of the SEA. While one informant ranks it as ‘reasonable to poor’ (R6) given the reluctance of the responsible ministry to lead a planning process for its implementation, another (R2) is of the opinion that the SEA ‘follows high standard and good example … and was done with best practice and of international standard.’

4.5 Summary: compliance with SEA international best practice standards

Table 1 provides an evaluation of the SEA using the framework proposed by Noble and Harriman-Gunn (2009). The results of the SEA evaluation show a mixed performance: only five out of nine of the criteria were met; three partially met; one – identifying a preferred option – not met at all. The post-assessment phase is evidently the most well-thought-out phase; however, results indicate the implementation has suffered some setbacks due to lack of political will and unwillingness of the responsible department to take ownership of the SEA implementation. One respondent (R1) pointed out that ‘the slowdown in uranium mining activity in the region’ may be responsible for this reduced sense of urgency in implementing the SEA.

Table 1 Evaluation of the SEA using Noble and Harriman-Gunn (2009) proposed methodological framework.

SEA best practice criteria	Central Namib SEA performance	Evaluation
Pre-assessment
Develop a reference framework	The reference framework for the assessment was clearly defined, although emphasis is placed more on economic development than biophysical issues	Met
Scope the baseline and issues of concern	Baseline data were collected but the challenge of inadequate data was also identified, and the issues of concerns were identified as EQOs	Partially met
Identify trends and stressors	Trends were projected based on expected mining production; mining and mining-related activities were identified as stressors	Partially met
Assessment
Develop strategic alternatives	Four scenarios were identified – three as paths that could be pursued; not to proactively guide selection and implementation of a preferred development path	Met
Assess the potential effects of each alternative	The cumulative effects of each scenario were identified taking into account other developments in the region	Met
Identify a preferred option(s)	No preferred option identified; development to be pursued with management and mitigation strategies considered for each scenario	Not met
Post-assessment
Determine mitigation needs	Mitigation needs identified for each scenario	Met
Develop a follow-up program	The SEMP is created to handle the monitoring and follow-up of the SEA	Met
Implement the strategy and monitor	SEMP was released in 2013 – later than scheduled; it is doubtful if implementation will succeed due to the absence of political will and responsible ownership	Partially met

5. Discussion

Experience from the central Namib uranium SEA provides useful insights into how to improve SEA practice in the Namibian context. The SEA is unique in the sense that it was a first in the entire southern Africa for mining sector. The process therefore required a planning and assessment framework that is different from what was established in the previous types of assessment. However, when undertaking best practice evaluation of SEA, it is important to revisit themes that are germane to a credible, transparent, participative and efficient process and outcomes as underlined by Noble and Harriman-Gunn's (2009) framework. We examine some of the issues that emerged in the analysis of the SEA with regard to baseline data collection; consideration of alternatives; preferred scenario/options; enforceability; and institutional capacity, and offer insights into how different treatments of these may help to strengthen SEA practice in Namibia in the future.

5.1 Baseline data collection

The success of SEA is contingent upon the availability of accessible and appropriate information (Thompson et al. 1995). The predictions and recommendations in SEAs are always based on baseline information of ecological and socioeconomic conditions or on the nature, scale and location of likely future developments (Alshuwaikhat 2005). Typical of many assessments in developing countries (Li 2008), the impact predictions in the central Namib SEA are fraught by lack of adequate baseline data. The assessment proceeded despite acknowledgement of the inadequacy of the existing data especially on biodiversity, a key EQO of the assessment (MME 2010, pp. 2–4). It would have been more credible to state in specific terms what the data gaps are and how that would affect the various projections and predictions. The challenge of data inadequacy may also contribute to inaccuracy or uncertainty in some of the predictions as well as the proposed mitigation strategies. Although SEA results can be predicted and communicated using newly collected data, there is still a stronger place for reliable and usable historical data in order to prevent over-reliance on newly collected information which may be found to have very little traction with strategic initiatives under consideration. The central Namib SEA experience demonstrates why environmental data inventory and management matter for improved SEA practice in Namibia.

5.2 Consideration of alternatives and methods of decision-making

The emphasis of SEA should focus on both the process and product (the report) in order to ensure that SEA influences PPP outcomes. However, attention on the process is considered as a critical factor in fostering ownership of its outcomes (Brown & Thérivel 2000). One way of achieving the robustness in process is through adequate consideration of alternatives for formulation and implementation of the SEA (Brown & Thérivel 2000), which ideally suggests the evidence of a thorough, transparent and highly inclusive assessment. Although the case study considers four different scenarios, what is uncertain in this regard is the adequacy of the process given that: (1) the assessment period lasted for only 16 months and (2) the prediction models and methodologies used were not discussed in the report. Taking into account the lack of baseline data indicated previously, 16 months may not have been enough to fully consider the implications of each development scenario. Another limiting factor is that many of the stakeholders had limited understanding of the scale of uranium rush as of the time of the assessment (Walmsley & Tarr 2011). It is difficult to conclude that the full spatial and temporal implication of mining development was incorporated into the SEA, which may affect the overall assessment results. With respect to the methods adopted in particular, a more explicit description of the models used in the SEA report has the potential to contribute to the legitimacy of an assessment, and effective implementation by providing the opportunity to adaptively manage follow-up activities according to changing variables and assumptions and encourage knowledge transfer, replication and improvement in future SEAs.

5.3 Preferred scenario/options

SEA as a tool is generally expected to support the goal of sustainable development by identifying preferred options and directions for decision-making from different scenarios or alternatives (Alshuwaikhat 2005; Noble 2009). It should also include setting thresholds for each of the indicators used to help in the monitoring process. Plans for mitigation are clearly addressed based on ‘viable scenarios’; however, the SEA report is ambiguous on what constitutes a viable scenario given the current rate of uranium exploration in the region. There is also no recommendation of a preferred option or an acceptable threshold in the blueprint. In essence, the SEA is just an evaluation of different mining development scenarios to be pursued, a situation that betrays the objective of impact assessment generally, and good practice SEA specifically, which is to identify a preferred scenario or scenarios, proactively test how ‘robust’ this selection is, and set direction for future development in the region (Noble 2008; White & Noble 2013). The controversy surrounding current tempo of mining activities in the region is evident even among the experts involved, especially the debate regarding whether it is a ‘below expectation’ or ‘boom and bust’ scenario. It is even more startling that the extreme situation of a ‘boom and bust’ scenario is not anticipated despite the possibility of such a scenario, especially where political will to implement the SEA seems to be weak, such as in currently the case. A greater concern, however, is that with increasing demand for global uranium, the absence of a commitment to a particular mining exploration and development scenario may inhibit monitoring activities and result in significant negative impacts, especially in protected parks. This is also important for monitoring cumulative effects in the region as pursuing a preferred development scenario can help anticipate the interactions between the projected mining development activities and the EQOs identified in the SEA.

5.4 Enforceability

As suggested by Buckley (2000), SEA as a supporting tool for sustainable development must include not only formal reports under the name SEA, but also any instrument that gives effect to a policy such as legislation or any government document involved with budgeting, and/or national or international agreements. Although the absence of legislated SEA is not peculiar to developing nations such as Namibia, it is essential that SEA goes beyond strategic guidelines and move to a formal policy document to guide mining activities in the region. This was explicitly suggested by one of the expert participants, and it may be especially germane to the success of SEA given the ineffectiveness of non-legislated EIA practice in most developing nations (Alshuwaikhat 2005). Such ‘clear, rigid and prescriptive government provisions’, as recommended by Fischer and Gazzola (2006, p. 407) for the Italian SEA system, may also prove valuable for the success of SEA implementation in central Namib. An enforceable instrument or some form of executive directive (such as the Canadian Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals) may also offer the opportunity to ensure individual project EIAs stand to benefit directly from the SEA recommendations and help to coordinate regional data management for other, lower-tiered assessments.

5.5 Institutional capacity

A key challenge to implementing SEA is lack of or limited institutional capacities (Noble 2009), and this can be more evident in developing nations (Axelsson et al. 2012). According to Eggenberger and Partidário (2000), institutional capacities include arrangements for coping with emerging issues and duties, a responsible authority to coordinate integration, and arrangement for information sharing. The central Namib SEA resulted in a SEMP that prepares for different mining development phases in the region, but the challenge of inadequate manpower and associated institutional capacity may affect the administration, monitoring and enforcement of the SEA results in an ever-dynamic uranium market as observed by some project informants. This may explain why the initial enthusiasm that characterized the initiation of the SEA is waning and ‘keeping the momentum’ is seen as a challenge. Training of both technical and decision-making stakeholders must be ongoing (OECD 2012), and original objectives of the SEA must be adaptive to changing environmental and socio-economic realities (Azcarate et al. 2013).

Notwithstanding the above shortcomings, which may suggest that the central Namib SEA process suffered from certain deficiencies, some novel and encouraging lessons can be highlighted for improved practice of SEA in Namibia. First, it must be noted that the SEA is tiered to earlier EIAs and introduces additional considerations for reinforcing project evaluation. Similarly, subsequent prospecting, mining and major infrastructure developments in the region are to be guided by the SEA and the SEMP. This suggests that SEA can have a positive added value for environmental management of uranium mining and positive implications for attaining regional sustainable development. Second, the involvement of different stakeholders including the youth and other interest groups, however, unidirectional, reflects environmental awareness and responsibility of the public in a manner that is uncommon to practice in many developing nations (Purnama 2003; Li 2008). Third, regarding implementation, the relatively short time-scale (from 2010 to 2020), may serve as an incentive to implement many of the initiatives. In particular, the 10-year span can substantially oblige stakeholders to monitor the EQOs effectively, allow timely audit of the SEA/SEMP overall performance and redirect effort toward an improved environmental management practice especially where failure has been recorded.

There was also indication of an initial political drive to allow the SEA to guide future mining directions. For example, a 2010 report indicates the MME's commitment to its implementation (Walmsley et al. 2010) with the allocation of USD300 million for a second desalination plant based on the recommendations of the SEA (Kaira 2011). Where more effort is needed is in the area of coordination and improved political will. Four, some failsafe strategies were also put in place through corrective action programs to remedy situations of non-compliance with the SEA recommendations and misjudgment in the data and assumptions used for the projected scenarios. This is an excellent example of integration of adaptive management thinking into the implementation phase of the SEA. And finally, the extensive consideration of cumulative effects in the central Namib SEA provides a good example of CEA practice at strategic level within a developing nations' context where such analysis is often excluded (Glasson et al. 2005; Li 2008).

6. Conclusion

The study highlights the relative weaknesses and strengths of the SEA process in relation to basic and operating principles of international best practice. Overall, the central Namib SEA shows that SEA for the mining sector is in its formative stage and was largely untested until this assessment. The assessment may not represent the picture of what a ‘best practice’ SEA should be according to international standards; however, it shows increasing recognition of the need for a strategic level of assessments to address issues of cumulative effects, biodiversity conservation and regional sustainable development and suggests a potentially bright future for SEA practice in Namibia. Currently, SEA is being extended to other areas of development in Namibia such as coastal management (Skov et al. 2010) and regional land-use plans (Nghitila 2012). The central Namib experience was also directly responsible for convincing the Benguela Current Commission to initiate an SEA for the ongoing Benguela Current Large Marine Ecosystem, a three-nation initiative to improve the management of a shared marine environment in southern African region. This represents a step forward and presents opportunities to eliminate some of the deficiencies identified in the central Namib process. SEA in Namibia arguably needs to be formalized through a stronger, more explicit guidance instrument such as the Canadian Cabinet Directive, which promotes consistent SEA usage and practice among government departments and agencies (whereas individual project assessments are carried out under existing EIA legislation when triggered). This may be necessary to encourage implementation and act as collateral for stakeholders' involvement in future SEA. Although this study is based on the central Namib case, the results have wider applications to sector-wide SEAs in other developing nations where practice is also still in its early stages.

Acknowledgements

The authors acknowledge the support and suggestions of Penelope Sanz of the Department of Interdisciplinary Studies, University of Saskatchewan, Canada. The authors would also like to thank Bram F. Noble, University of Saskatchewan, for his comments on earlier drafts of this paper.

Notes

^1. The basic principles emphasize how purposive, rigorous, practical, relevant, cost-effective, efficient, focused, participative, interdisciplinary, credible, integrated, transparent, and systematic the assessment is. The operational principles include the following: screening, scoping, examination of alternatives, impact analysis, evaluation of significance, preparation of environmental impact statement (EIS) or report, review of the EIS, decision-making, and follow-up.

^2. Beanlands and Duinker (1983) coined the term ‘valued ecosystem components’ and defined them as ‘environmental attributes or components identified as a result of a social scoping exercise … (which) may be determined on the basis of perceived public concerns related to social, cultural, economic or aesthetic values’ (p. 18).