15th October, 2018

ZEMA/INS/103/4/4
The Director
Kabula Exploration Limited,
P.O Box 60773
Livingstone.

Dear Sir,

RE: DRAFT ENVIRONMENTAL PROJECT BRIEF (EPB) REPORT FOR THE PROPOSED
MINING OF AGATES IN KABULA BY KABULA EXPLORATIONS LIMITED

The Zambia Environmental Management Agency (ZEMA) is in receipt of your draft Environmental
Project Brief (EPB) for the above mentioned project that was submitted on 5th of October,, 2018.

The Agency herein wishes to inform you that, in accordance with the provisions of the
Environmental Impact Assessment Regulations, Statutory Instrument No. 28 of 1997, your draft
EPB has been reviewed.

Kabula Exploration Limited should now proceed with the following:

i. Revision of the draft EPB as requested in the attached comments.

ii. Aligning the EPB to the current EPB format. To guide you find attached the EPB format
iii. Preparation of an action list showing revisions made in the EPB and where those (pages
and sections) revisions are to be found in the revised EPB.
iv. Submission of the revised EPB for checking appropriateness and adequacy

Please do not hesitate to contact the undersigned should there be any issue you may need to be
clarified.

Yours sincerely,

Lillian Chama Kalenge (Ms)

Principal Inspector (Head) – Livingstone Office
For/Director General
ZAMBIA ENVIRONMENTAL MANAGEMENT AGENCY
 ZAMBIA ENVIRONMENTAL MANAGEMENT AGENCY

TITLE: DRAFT ENVIRONMENTAL PROJECT BRIEF (EPB) REPORT FOR THE PROPOSED
MINING OF AGATES IN KABULA BY KABULA EXPLORATIONS LIMITED

AUTHORISED BY:

NAME: Lillian Chama Kalenge TITLE: Principal Inspector – Southern Region

DETAILS:
COMPANY/ LIS CODE
PROJECT PROPONENT Kabula Explorations Limited
PROJECT TITLE Draft Environmental Project Brief (EPB) report for the proposed Mining
of Agates in Kabula by Kabula Explorations Limited
SECTOR Mining
PROPOSED PROJECT Province: Western
LOCATION: District:---
Physical: Kabula

DEVELOPER’S CONTACT Physical Address: Ellaine Britell, plot 2644/26

DETAILS Postal address: P.O. Box
Telephone (Land/mobile): +260 0978203988
Fax:
Email: jo@bunduadventures.com

DETAILS OF CONTACT Name: Johannes Stallmann

PERSON Designation: Managing Director
Physical Address: Ellaine Britell, plot 2644/26.
Postal address:
Telephone (Land/mobile): +260 0978203988
Email: jo@bunduadventures.com

DATE OF SUBMISSION 05/10/2018

DATE OF REVIEW 15/10/2018
DOES THE EPB INCLUDE?

ITEM YES/ COMMENT

NO

 Title of the project No Include a cover page with a title of the

proposed project. In the title indicate which
district the project area is located.
 Table of Content No Include a table of content
EXECUTIVE SUMMARY
 The brief project description for the No Provide the brief project description for the
proposed project proposed project
 Project objectives No Include the Project objectives
 Proposed location No Provide the location
 Investment cost No Include the investment cost
 The alternatives considered No Include the alternatives considered
 Potential impacts (both positive and No Include Potential impacts (both positive and
negative) negative) identified
 Mitigation/enhancement measures No Include the Mitigation/enhancement
measures
 Relevant legislation No Include the Relevant legislation identified
 Environmental Management Plan No Include the Environmental Management Plan
[EMP] and commitments [EMP] and commitments
 Conclusion No Include the conclusion
1. INTRODUCTION
 Project background and objectives yes Done
 Brief introduction of the project yes Done
including its rationale
 Particulars of the shareholders and yes Done
Directors
 Percentage of shareholding by each yes Done
shareholder
 The developer’s physical address and yes Done
the contact person
 Track Record/Previous Experience of yes Done
Enterprise Elsewhere
 Total Project Cost/Investment yes Done
ITEM YES/ COMMENT
NO
 Proposed Project Implementation yes Done
Date and project lifespan
2. POLICY AND INSTITUTIONAL FRAMEWORK
i. Policy and institutional framework relevant to the project
 Policy, legal and institutional Partially  Page 4 (2.1), the cited Act was
framework relevant to the project done repealed and replaced. Recast and
update the paragraph
 Page 5 (2.1.2 to 2.1.4), all cited
regulations (SI No 71 of 1993, SI No
72 of 1993, SI No 125 of 2001), under
these sections were all repealed and
replaced. Recast and update
 Page 6 (2.2, 2.4, 2.6, 2.12,), the cited
Acts were repealed and replaced.
Recast and update

 Specific sections of the cited policy Yes Done

and institutional framework relevant
to the proposed project included
 Relevance of cited legislations to the Yes
proposed project included
 Compliance (how the project Yes
complies or will comply to the cited
sections) included
 General comment
ii. International agreements and conventions
 Relevant international agreements yes
and conventions relevant to the
proposed project included
 Specific sections of the agreements Partially
and conventions relevant to the done
proposed project included.
Done
Done
Pages 4 to 9 (2.0), under legal and policy
frame work, recast the whole section.
Remove all outdated legislation in the EPB.
Identify relevant legislation which is in
force, cite the relevant sections/ parts
and provide how the project will comply
with the cited sections. Make sure all the
relevant legislation are cited in full.
done
For each identified international agreement
and convention, cite Specific sections of the
agreements and conventions relevant to the
proposed project
ITEM YES/
NO
 Relevance of cited sections of the Partially
agreement or convention to the done
proposed development included
 Compliance (how the development Partially
complies/will comply to the cited done
sections) included
3. DESCRIPTION OF THE PROJECT
Location No
 Describe the project location
supported by a location map drawn
to an appropriate scale with a
legend, direction of the True North.
The location map must be printed on
at least “A3” paper size for it to be
clear.
 Provide the spatial extent of the Partially
proposed project site (Province, done
City/Municipality/district, Chiefdom,
specific project site)
 Provide any physical land marks and Yes
their distances from the proposed
site, (provide coordinates of the
proposed site where applicable) to
aid in location of the proposed
project site.
 Describe the project site including Yes
other significant developments
surrounding the project area.
COMMENT
Include relevance of cited sections of the
agreement or convention to the proposed
development
Include how the development complies/will
comply to the cited sections
 Page 9, (3.1), describe the project
location supported by a location map
drawn to an appropriate scale with a
legend, direction of the True North. The
location map must be printed in color on
at least “A3” paper size for it to be clear.
 Include a map showing the site overlaid
on an appropriate base map.
Page 9, under location, Clearly state in which
Province, district, town, area, or Chiefdom,
the project site is located
Done
Done

Project description; No Describe the project in detail

 Describe the project in detail.
 Including the process and
technology to be used (include flow
diagrams, were applicable)

Nature of the Project Yes Done

State the following (if applicable)
 Raw materials (including hazardous
materials and their storage on site)
 Products and by-products (waste
streams)
 Production capacity
ITEM YES/ COMMENT
NO
Main activities of the project Yes Done
State the main activities to be
undertaken during:
 Site preparation phase
 Construction phase
 Operation phase
Others N/A
4 CONSIDERATION OF ALTERNATIVES
i. Identification of alternatives such as Yes Done
but not limited to:

 Project need
 Site location
 Design
 Technology
 Process
 Raw materials
 Justification for the selected
option(s)
ii. Analysis of each of the identified Yes Done
alternatives
iii. List of chosen alternatives in order of Yes Done
preference
iv. Reasons for choosing the preferred Yes Done
alternatives and rejecting the other
alternatives.
5. DESCRIPTION OF THE BASELINE ENVIRONMENT
5.1 Ecological Resources
a. Fauna Yes Done
 Terrestrial species (Include
common names and respective
scientific names)
 Aquatic species (include
common names and respective
scientific names)
 Categorise threats to species or
taxa, using the IUCN red list
data.

b. Flora Yes Done

ITEM YES/ COMMENT
NO
 Terrestrial species (Include
common names and respective
scientific names)
 Aquatic species (Include
common names and respective
scientific names) As above
5.2 Geology Yes Done
5.3 Drainage/Hydrology/surface Yes Done
water regime
5.4 Climate/ Yes Done
temperature/precipitation/e
vaporation/winds etc.
5.5 Landscape and Topography Yes Done
5.6 Soils Yes Done
5.7 Ground /Hydrogeology Air Yes Done
quality and Noise
5.8 Social, Economic and Cultural Yes Done
Issues
5.9 Built Environment/Landuse Partially Include the built environment
done
6.ENVIRONMENTAL IMPACTS OF THE PROJECT
Identify and discuss Yes Done

6.1 Methodology of Impact

Evaluation
(Refer to some examples of
impact evaluation methodologies,
Leopold matrix, Battelle
Environmental Evaluation system
or overlays approaches)

Evaluation of impacts should combine:

 the frequency of occurrence of
the impact
 the duration of the impact
 the severity of impact
 the spatial extent of the impact
 the sensitivity of the element
being impacted.
ITEM YES/ COMMENT
NO
6.2 Positive Impacts Yes Done
6.2.1 Socio-economic environment
6.2.2 Physical environment
6.2.3 Biological environment
6.3 Negative Impacts Partially  Identify all major impacts of the
6.3.1 Socio-economic environment done project e.g. surface and ground water
6.3.2 Physical environment pollution, air pollution, water
6.3.3 Biological environment pollution, soil contamination etc.
State the mitigation  Page 19 (6.2), provide mitigation
measures to the stated measures for all the identified
impacts. negative impacts
7. ENVIRONMENTAL-SOCIAL MANAGEMENT PLAN
(State the Environmental Management Commitments for mitigating negative Environmental
Impacts identified in Section 6.0 and measures for enhancing positive impacts.
7.1 Environmental Monitoring Plan Partially Present the information in the table below
(These should include done
environmental management cost
estimates, responsible personnel
and the frequency of monitoring)

Aspe Imp Mitigatio Frequency Time Performance Respon Cost

ct act n/ of frame indicator sible
Enhance Monitoring person
ment
measure

8. DECOMMISIONING PLAN
State activities associated with Yes Done
Decommissioning and Closure Phase of the
project.
(If not applicable, state decommissioning
activities of works, construction camps or any
other activity used to undertake the project).
9. Declaration of authenticity of Yes Final report must be signed by the developer
report contents (signed by the
project proponent)
ITEM YES/ COMMENT
NO
10. BIBLIOGRAPHY Partia  Include the bibliography
APPENDICES lly
 Maps and satellite images done  Include the mining licence
 List of Figures (tables, charts,
graphs, models, photographs);
 Certificate of Incorporation
 Investment Licence
 Title deeds or lease agreements
 Certificates of Incorporation
 Agreements
 Asset valuation reports
 Approval documents
 Any other relevant supporting
documents or information that
cannot be presented in the main
report
11. OTHER OBSERVATIONS OR 1. Include the executive summary and table of
COMMENTS contents
2. Correct all formatting, grammatical and
typographical errors.
3. All figures and tables in the document should
be correctly titled and numbered
systematically