Nkunzana Prospecting Right Project

NKUNZANA PROSPECTING RIGHT PROJECT

BASIC ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME

Submitted in support of a Prospecting Right Application

Prepared on Behalf of: WRE BASE METALS (PTY) LTD (Subsidiary of White Rivers Exploration (Pty) Ltd)

DMR REFERENCE NUMBER: KZN 30/5/1/1/2/10722 PR

27 JULY 2018

Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR

NKUNZANA PROSPECTING RIGHT PROJECT

BASIC ASSESSMENT REPORT AND EVIRONMENTAL MANAGEMENT PROGRAMME

Compiled by: Ms Nangamso Zizo Siwendu Environmental Consultant, Shango Solutions Cell: 076 859 2686 E-mail: [email protected]

Ms Mmakoena Adelaide Mmola Geological Consultant, Shango Solutions Cell: 076 714 7937 E-mail: [email protected]

Reviewed by: Dr Jochen Schweitzer Principal Consultant, Shango Solutions Cell: 082 448 2303 E-mail: [email protected]

Ms Stefanie Weise Principal Consultant, Shango Solutions Cell: 081 549 5009 E-mail: [email protected]

DOCUMENT CONTROL Revision Date Report

1 27 June 2018 Draft Basic Assessment Report and Environmental Management Programme

2 27 July 2018 Final Basic Assessment Report and Environmental Management Programme

DISCLAIMER & TERMS OF USE

This report has been prepared by Dunrose Trading 186 (Pty) Ltd t/a Shango Solutions using information provided by its client as well as third parties, which information has been presumed to be correct. Shango Solutions does not accept any liability for any loss or damage which may directly or indirectly result from any advice, opinion, information, representation or omission, whether negligent or otherwise, contained in this report. Shango Solutions does not accept any liability for any loss or damage, whether direct, indirect or consequential, arising out of circumstances beyond the control of Shango Solutions, including the use and interpretation of this report by the client, its officials or their representative agents.

This document contains information proprietary to Shango Solutions and as such should be treated as confidential unless specifically identified as a public document by law. Shango Solutions owns all copyright and all other intellectual property rights in this report. The document may not be copied, reproduced in whole or in part, or used for any manner without prior written consent from Shango Solutions. Copyright is specifically reserved in terms of the Copyright Act 98 of 1987 including amendments thereto. By viewing this disclaimer and by accepting this document, you acknowledge that you have read and accepted these Terms of Use and undertake to keep the information herein confidential and not to do any act or allow any act which is in breach of these Terms of Use.

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EXECUTIVE SUMMARY

WRE Base Metals (Pty) Ltd (hereafter referred to as WRE Base Metals, the Applicant) submitted an application for a Prospecting Right and an Environmental Authorisation in order to prospect for the following commodities:

 Silver  Iron  Gold  Manganese  Cobalt  Molybdenum  Diamond (Alluvial)  Nickel  Rare Earths  Platinum Group Metals  Uranium  Sulphur  Zinc  Tungsten  Lead  Copper

The application for a Prospecting Right was accepted by the Department of Mineral Resources – KwaZulu-Natal Regional Office on the 20th December 2017. In addition, receipt of the application for an Environmental Authorisation was acknowledged by the Department on the 22nd November 2017. The proposed project will be known as the Nkunzana Prospecting Right and it will aim to explore and quantify potential mineral resources. In order to undertake prospecting activities, WRE Base Metals require a Prospecting Right in terms of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002). WRE Base Metals is also required to obtain an Environmental Authorisation in terms of the National Environmental Management Act, 1998 (Act 107 of 1998) which involves the submission of a Basic Assessment Report, an Environmental Management Programme as well as undertaking a Public Participation Process. Shango Solutions have been appointed by WRE Base Metals as the Environmental Assessment Practitioner to assist in complying with these requirements.

Purpose of this Document This document has been compiled in support of the Prospecting Right and Environmental Authorisation applications and aims to assess any impacts associated with prospecting. It is important that Interested and Affected Parties are provided with an opportunity to review and comment on the assessment report, thereby contributing to the environmental impact assessment process and assisting in identifying any additional risks or impacts that may be experienced. As such, a public consultation was undertaken for this application. The draft report was made available to Interested and Affected Parties for a period of 30 days ending on the 26th July 2018. The final report includes the results of consultation for submission to the Competent Authority (the Department of Mineral Resources) for decision-making.

Project Location The area of interest occupies a total of approximately 2 069.06 hectares and is located approximately 92 kilometres west of Richards Bay, in the KwaZulu-Natal Province of South Africa. The proposed prospecting area is located in the Magisterial District of Nkandla and falls under the Nkandla Local Municipality, within the King Cetshwayo District Municipality. Two farm portions extend over the application area.

Project Activities Invasive and non-invasive prospecting activities will be undertaken as part of the proposed Prospecting Work Programme. The Prospecting Work Programme will be based on a phased approach over approximately five years. Continuation of the prospecting activities will be dependent on the successful completion of tasks constituting an orderly geological investigation. The scope of these activities is as follows:

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The first two years of the proposed five (5) year programme will be limited to non-invasive techniques, namely (i) desktop studies, (ii) data QA/QC, (iii) digitisation and database compilation, (iv) an initial field visit, (v) geological mapping and (vi) preliminary target generation and target prospectivity ranking. Years 3 and 4 will comprise a combination of invasive and non-invasive techniques, namely (i) stream sediment sampling, (ii) underground sampling of the historical mine, (iii) surface electromagnetic geophysical surveys, (iv) grid sampling, (v) further target or prospectivity ranking as well as (vi) excavation of six (6) trenches, including mapping and sampling of the excavated trenches.

During the final year of prospecting, diamond core or percussion drilling will take place to a depth of approximately 150 metres. The project will involve drilling of six (6) diamond drillholes, with each drill pad disturbing an area of up to 10 metres x 10 metres. Upon completion of the drilling programme, the recovered core will be logged and sampled. The drillhole information will be captured into a database and integrated into the final geological model. Thereafter, a code-compliant resource estimate will be performed utilising the finalised geological model.

Prospecting Targets The main targets for prospecting are the amphibolite schists of the Mfongosi Group. Gold in the application area is hosted in shear zones and mineralisation occurs in the sericite and chlorite schists of the Mfongosi Group of the Natal Thrust Belt.

Environmental Specialist Studies

\ A comprehensive assessment was undertaken in support of the Nkunzana Prospecting Right application. Three specialist studies were undertaken, namely:

 Heritage and Palaeontological Assessment.   Ecological (fauna and flora) Assessment.   Wetland Assessment. 

 Based on the specialist assessments, it was determined that a number of sensitive features exist within the application area.

Summary of Key Findings The application area is rugged and characterised by hills and steeply incised valleys. It falls within the Pongola- Mtamvuna Water Management Area, which includes rivers such as the Pongola, Mhlatuze, Mfolozi, Mkuze, Thukela, Mvoti, Umgeni, Umkomazi, Umzimkulu and Mtamvuna rivers. The Pongola-Mtamvuna Water Management Area comprises 21 tertiary catchment areas and the application area is specifically situated in the V40D Quaternary Catchment. The climate is characterised by summer rainfall (November – March) with a mean annual precipitation of 500 millimetres.

Ecological and Wetland Assessment

The Ecology and Wetland Assessment was conducted on a desktop level and a field survey was undertaken to increase the confidence in the information obtained from desktop studies. Based on the assessment, the application area is situated within a Critical Biodiversity Area: Irreplaceable and a Critical Biodiversity Area: Optimal, and it occurs adjacent to the Nkandla Forest Reserve Complex. The application area overlaps with a portion of the Mome Nature Reserve and the north-western portion of the area intersects with the Dhlabe Nature Reserve. The Nsuze River, a Freshwater Ecosystem Priority Area River, occurs within the 500 metre Water Use

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Licence Application buffer around the project area. One wetland Unit was identified on-site as well as a number of Species of Conservation Concern, most of which are regarded as sensitive.

According to Mucina and Rutherford (2006) and Ezemvelo KwaZulu-Natal Wildlife (2013), the project area is situated across several different vegetation types, namely (i) Moist Coast Hinterland Grassland (Gs20) (which constitutes the majority of the area) listed as Vulnerable, (ii) Eastern Valley Bushveld (SVs 6) listed as Least Threatened, (iii) Scarp Forest (FOz 5) listed as Least Threatened and (iv) Midlands Mistbelt Grassland (Gs9) listed as Endangered.

Heritage and Palaeontological Assessment A Heritage Impact Assessment (inclusive of a Palaeontological study) was undertaken over the application area. A field survey was conducted on foot and a vehicle was utilised to gain access to (i) the farm properties within the application area and (ii) the locations of the proposed unpaved access road, drillholes and trenches. Four cemeteries, including one possible cemetery were identified during the field survey. In addition, one grave belonging to the Zulu Royal House (the King Cetshwayo Grave) was identified approximately 1.5 km west of the proposed prospecting activities. The six identified heritage resources have been allocated the following Unique Site Reference Numbers:

 Nku-Cem 01.  Nku-Cem 02.  Nku-Cem 03.  Nku-Cem 04 (possible cemetery).  Nku-Cem 05.  Nku-Cem 06 (King Cetshwayo Grave).

The surface geology of the project area consists of rocks of the Namaqua-Natal Metamorphic Complex. These rocks are not known to contain any palaeontological fossils. As such, there is no need to conduct any other palaeontological studies or have a monitoring programme to rescue palaeontological fossils during invasive prospecting. According to the Palaeontological Sensitivity Map developed by the South African Heritage Resources Agency, the area is classified as non-sensitive in terms of fossil sensitivity.

Alternatives

The identification of alternatives is a key aspect of the success of the Basic Assessment process. All reasonable and feasible alternatives must be identified and screened to determine the most suitable alternatives to consider in this application. However, there are some constraints that have to be taken into account when identifying alternatives for a project depending on the scope. Such constraints include financial, social and environment related constraints. Two site alternatives have been considered for this project (Alternative 1 and Alternative 2). The need and justification for the alternative that was recommended by the Environmental Assessment Practitioner was specifically guided by the relatively low sensitivity of the receiving socio-economic and biophysical environment as well as the geology.

Environmental Impact Assessment This Basic Assessment was undertaken in order to identify all of the potential risks and impacts associated with each phase of prospecting. Each of the identified risks and impacts were assessed following the impact methodology described in the body of this report. The assessment criteria include nature, extent, duration, magnitude/intensity, reversibility, probability, public response, cumulative impact, and irreplaceable loss of resources. Based on the impact assessment conducted by the Environmental Assessment Practitioner and the iii

Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR various specialists, the environmental impacts associated with the prospecting activities are expected to be localised and of low to medium significance, with one impact being of high significance in the planning phase. The identified impacts can be reduced to medium and low significance provided all recommended mitigation measures are implemented correctly.

Environmental Management Programme Mitigation Measures The Environmental Management Programme has identified appropriate mechanisms for avoidance and mitigation of negative impacts. These mitigation measures and monitoring programmes have been included as commitments in the Environmental Management Programme. It is anticipated that the implementation of the mitigation measures stipulated in the Environmental Management Programme will result in effective mitigation of the negative impacts. Conversely the implementation of the mitigation measures designed to maximise the positive aspects of the project will result in a significant positive influence as a result of the prospecting operation.

Need and Desirability of the Project

The minerals being prospected for are silver, gold, cobalt, copper, diamond (alluvial), iron, manganese, molybdenum, nickel, lead, Platinum Group Metals, rare earths, sulphur, uranium, tungsten and zinc. The proposed Nkunzana Prospecting Right, if granted, will allow WRE Base Metals to determine if any economically viable resources are present in the area.

Should prospecting prove successful and a resource quantified, it would indicate a potential viable economic activity in the form of mining that is likely to contribute greatly to the socio-economic status quo in the form of increased income, employment and other benefits that would cascade through the local, regional and national levels.

Conclusion

The application area has been selected based on the historical data and geological information available, which indicates the potential for economically viable minerals to occur. The prospecting footprint is expected to be a fraction (up to 1 hectare) of the application area size, which is estimated to be 2 069 hectares. The geology is the primary driver in determining the location for prospecting. The preferred site (Alternative 1) is located close to the historical and defunct Nkunzana Mine. However, it is situated in an area that is highly sensitive. To avoid areas of high sensitivity, it is recommended that the prospecting target areas be relocated to areas of low sensitivity (Alternative 2A to 2D) collectively referred to as Alternative 2 in this report.

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BASIC ASSESSMENT REPORT

AND

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

SUBMITTED FOR ENVIRONMENTAL AUTHORISATIONS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).

PREPARED BY:

NAME OF APPLICANT: WRE BASE METALS (PTY) LTD

Tel: 011 431 1191

Fax: 011 431 1193

Postal Address: P.O. Box 2591, Cresta

Physical Address: HHK House, Corner Ruth Crescent and Ethel Ave, Northcliff Ext 12

File Reference Number SAMRAD: KZN 30/5/1/1/2/10722 PR

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IMPORTANT NOTICE

In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as amended), the Minister must grant a prospecting or mining right if among others the mining “will not result in unacceptable pollution, ecological degradation or damage to the environment”.

Unless an Environmental Authorisation can be granted following the evaluation of an Environmental Impact Assessment and an Environmental Management Programme report in terms of the National Environmental Management Act (Act 107 of 1998) (NEMA), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological degradation or damage to the environment.

In terms of Section 16(3)(b) of the EIA Regulations, 2014, any report submitted as part of an application must be prepared in a format that may be determined by the Competent Authority and in terms of Section 17)1)(c) the Competent Authority must check whether the application has taken into account any minimum requirements applicable or instructions or guidance provided by the Competent Authority to the submission of applications.

It is therefore the instruction that the prescribed reports required in respect of application for an environmental authorisation for listed activities triggered by an application for a right or a permit are submitted in the exact format of, and provide all the information required in terms of, this template. Furthermore please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the Regulation and will lead to the Environmental Authorisation being refused.

It is furthermore an instruction that the Environmental Assessment Practitioner must process and interpret his/her research and analysis and use the findings thereof to compile the information requested herein. (Unprocessed supporting information may be attached as appendices). The EAP must ensure that the information required is placed correctly in the relevant sections of the report, in order, and under the provided headings as set out below, and ensure that the report is not cluttered with un-interpreted information and that it unambiguously represents the interpretation of the Applicant.

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OBJECTIVE OF THE BASIC ASSESSMENT PROCESS

The objective of the basic assessment process is to, through a consultative process-

a) Determine the policy and legislative context within which the activity is located and document how the proposed activity complies with and responds to the policy and legislative context.

b) Identify the alternatives considered, including the activity, location, and technology alternatives.

c) Describe the need and desirability of the proposed alternatives.

d) Through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which focused on determining the geographical, physical, biological, social, economic, heritage, and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and the technology alternatives on the these aspects to determine:

i. The nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and

ii. The degree to which these impacts-

(aa) Can be reversed.

(ba) May cause irreplaceable loss of resources.

(ca) Can be managed, avoided or mitigated.

e) Through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will impose on the sites and location identified through the life of the activity to –

i. Identify and motivate a preferred site, activity and technology alternative.

ii. Identify suitable measures to manage, avoid or mitigate identified impacts.

iii. Identify residual risks that need to be managed and monitored.

This report has been designed to meet the requirements for a Basic Assessment Report and Environmental

Management Programme as stipulated in the 2014 Environmental Impact Assessment Regulations (as amended) promulgated under the National Environmental Management Act, 1998 (Act 107 of 1998). The adjudicating authority for this application is the Department of Mineral Resource and this report has been compiled in accordance with the applicable Department of Mineral Resources Guidelines and Basic Assessment Report and

Environmental Management Programme template.

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TABLE OF CONTENTS

PART A: BASIC ASSESSMENT REPORT

1. INTRODUCTION ...... 1 1.1 Location of the Activity ...... 2 1.2 Locality Map ...... 3 1.3 Details of the Environmental Assessment Practitioner ...... 4 1.4 Expertise of the EAP...... 4 2. DESCRIPTION AND SCOPE OF THE PROPOSED ACTIVITY ...... 6 2.1 Listed and Specified Activities ...... 9 2.2 Description of Activities to be Undertaken ...... 10 2.3 Activities Associated With Planned Prospecting ...... 11 2.4 Description of Site Activities ...... 13 2.5 Geological Formation and Prospecting Targets ...... 14 3. POLICY AND LEGISLATIVE CONTEXT ...... 15 3.1 Environmental Authorisation Process ...... 16 4. NEED AND DESIRABILITY OF THE PROPOSED ACTIVITIES ...... 22 5. MOTIVATION FOR THE OVERALL PREFERRED DEVELOPMENT FOOTPRINT ...... 22 6. FULL DESCRIPTION OF THE PROCESS FOLLOWED TO REACH THE PROPOSED PREFERRED ALTERNATIVES WITHIN THE SITE ...... 23 6.1 Location Alternative ...... 23 6.2 Activity Alternatives...... 25 6.3 Design or Layout Alternative ...... 25 6.4 Technology Alternatives ...... 25 6.5 Operational Aspects ...... 26 6.6 No Action Alternative (“No-Go”) ...... 26 7. DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED ...... 26 7.1 Public Participation Methodology ...... 26 7.2 Notification of I&APs ...... 28 7.3 Issues and Responses ...... 30 8. ENVIRONMENTAL ATTRIBUTES AND ASSOCIATED ALTERNATIVES ...... 54 8.1 The Baseline Receiving Environment ...... 54 8.2 Environmental Aspects Which May Require Protection and/or Remediation ...... 79 8.3 Description of Specific Environmental Features and Infrastructure On-Site ...... 80 9. IMPACTS AND RISKS IDENTIFIED...... 81 9.1 The Impact Assessment Methodology ...... 83 9.2 Assessment and Evaluation of Potential Project Impacts and Mitigation Measures ...... 87 10. MOTIVATION WHERE ALTERNATIVE SITES WERE CONSIDERED ...... 149 11. STATEMENT MOTIVATING THE ALTERNATIVE DEVELOPMENT LOCATION WITHIN THE OVERALL SITE...... 149 12. FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY, ASSESS AND RANK THE IMPACTS AND RISKS THE ACTIVITY WILL IMPOSE ON THE PREFERRED SITE (IN RESPECT OF THE FINAL SITE LAYOUT PLAN) THROUGH THE LIFE OF THE ACTIVITY ...... 150

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13. IMPACT ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND RISK ...... 150 14. SUMMARY OF SPECIALIST REPORTS ...... 157 15. ENVIRONMENTAL IMPACT STATEMENT ...... 159 16. FINAL SITE MAP ...... 161 17. SUMMARY OF POSITIVE AND NEGATIVE IMPLICATIONS AND RISKS ...... 162 18. PROPOSED IMPACT MANAGEMENT OBJECTIVES AND OUTCOMES ...... 162 19. ASPECTS FOR INCLUSION AS CONDITIONS OF AUTHORISATION ...... 170 20. DESCRIPTION OF ANY ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE ...... 170 20.1 Heritage and Palaeontology Assessment ...... 170 20.2 Ecology and Wetland Assessment ...... 171 21. REASONED OPINION AS TO WHETHER THE PROPOSED ACTIVITY SHOULD OR SHOULD NOT BE AUTHORISED ...... 171 22. PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED ...... 171 23. UNDERTAKING ...... 171 24. FINANCIAL PROVISION ...... 172 25. SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY ...... 172 26. COMPLIANCE WITH THE PROVISIONS OF SECTIONS 24(4)(A) AND (B) READ WITH SECTION 24(3)(A) AND (7) OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (ACT 107 OF 1998) THE BAR REPORT MUST INCLUDE THE: ...... 172 26.1 IMPACT ON THE SOCIO-ECONOMIC CONDITIONS OF ANY DIRECTLY AFFECTED PERSON ...... 172 26.2 IMPACT ON ANY NATIONAL ESTATE REFERRED TO IN SECTION 3(2) OF THE NATIONAL HERITAGE RESOURCES ACT ...... 173 27. OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A) AND (B) OF THE ACT ...... 173 28. INTRODUCTION ...... 174 28.1 Details of the EAP ...... 174 28.2 Description of the Aspects of the Activity ...... 174 29 ENVIRONMENTAL MANAGEMENT PRINCIPLES ...... 174 29.1 Holistic Principle ...... 174 29.2 Best Practicable Environmental Option ...... 174 29.3 Sustainable Development ...... 174 29.4 Preventative Principles ...... 175 29.5 The Precautionary Principles ...... 175 29.6 Duty of Care and Cradle to Grave Principle ...... 175 29.7 POLLUTER PAYS PRINCIPLE ...... 176 29.8 Duty of Care Responsibilities ...... 176 29.9 Failure to comply with Environmental Considerations ...... 177 30 DESCRIPTION OF IMPACT MANAGEMENT OBJECTIVES INCLUDING MANAGEMENT STATEMENTS178 30.1 Determination of Closure Objectives ...... 178 30.2 Volumes and Rate of Water Use Required for the Operation ...... 179 30.3 Has A Water Use Licence Been Applied For? ...... 179 30.4 Impacts To Be Mitigated in their Respective Phases ...... 180 30.5 Impact Management Actions And Outcomes ...... 192 31 FINANCIAL PROVISION ...... 197 31.1 Other Guidelines ...... 198

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32 DESCRIBE THE CLOSURE OBJECTIVES AND THE EXTENT TO WHICH THEY HAVE BEEN ALIGNED TO THE BASELINE ENVIRONMENT DESCRIBED UNDER THE REGULATION ...... 198 33 CONFIRM SPECIFICALLY THAT THE ENVIRONMENTAL OBJECTIVES IN RELATION TO CLOSURE HAVE BEEN CONSULTED WITH LANDOWNER AND INTERESTED AND AFFECTED PARTIES ...... 199 34 REHABILITATION PLAN ...... 199 34.1 Integrated Rehabilitation And Closure Plan ...... 199 34.2 Phase 1: Making Safe...... 200 34.3 Phase 2: Landform Design, Erosion Control And Revegetation ...... 200 34.4 Phase 3: Monitoring And Maintenance ...... 201 34.5 Post-Closure Monitoring And Maintenance ...... 201 35 EXPLAIN WHY IT CAN BE CONFIRMED THAT THE REHABILITATION PLAN IS COMPATIBLE WITH THE CLOSURE OBJECTIVES ...... 202 36 CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION REQUIRED TO MANAGE AND REHABILITATE THE ENVIRONMENT IN ACCORDANCE WITH THE APPLICABLE GUIDELINE ... 202 37 CONFIRM THAT THE FINANCIAL PROVISION WILL BE PROVIDED AS DETERMINED ...... 205 38 MECHANISMS FOR MONITORING COMPLIANCE ...... 206 39 INDICATE THE FREQUENCY OF THE SUBMISSION OF THE PERFORMANCE ASSESSMENT/ ENVIRONMENTAL AUDIT REPORT ...... 209 40 ENVIRONMENTAL AWARENESS PLAN AND TRAINING ...... 209 40.1 Manner In Which Employees Will Be Informed of Environmental Risks ...... 210 40.2 Manner In Which Risks Will Be Dealt With To Avoid Pollution or Degradation ...... 210 41 SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY ...... 210 42 UNDERTAKING ...... 211 43 REFERENCES ...... 212

LIST OF TABLES

Table 1: Proposed prospecting activities...... 1 Table 2: Locality details...... 2 Table 3: Listed and specified activities...... 9 Table 4: Planned invasive and non-invasive activities...... 10 Table 5: Activities associated with planned prospecting...... 12 Table 6: Policy and legislative context...... 15 Table 7: Advantages and disadvantages of Site Alternative 1 and Site Alternative 2...... 24 Table 8: Summary of issues raised by I&APs...... 31 Table 9: Minutes of the Heritage Public Participation Meeting...... 49 Table 10: Cemeteries identified within the application area (source: NGT, 2018)...... 59 Table 11: Summary of the wetland PES...... 65 Table 12: The EIS results for the identified wetland...... 67 Table 13: The Eco-Services being provided by the wetland unit...... 67 Table 14: The direct and indirect benefits provided by the wetland unit...... 67 Table 15: Plant Species of Conservation Concern (SCC) expected to occur in the project area...... 71 Table 16: Animal groups considered in this study...... 72 Table 17: Animal groups identified in the project area during the field survey...... 76

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Table 18: List of potential impacts per activity...... 80 Table 19: List of potential impacts per activity...... 81 Table 20: Criteria for determination of impact Consequence...... 83 Table 21: Probability scoring...... 84 Table 22: Determination of Environmental Risk...... 84 Table 23: Significance classes...... 85 Table 24: Criteria for the determination of prioritisation...... 85 Table 25: Determination of prioritisation factor...... 86 Table 26: Environmental significance rating...... 86 Table 27: Comparative assessment of alternatives...... 149 Table 28: Impact significance table...... 151 Table 29: Impacts to be mitigated...... 180 Table 30: Impact management actions and outcomes...... 192 Table 31: Quantum for financial provision...... 203 Table 32: Mechanisms for monitoring compliance...... 206

LIST OF FIGURES

Figure 1: Locality map indicating the farm portions...... 3 Figure 2: A typical drill rig...... 8 Figure 3: Typical diamond drill bits...... 8 Figure 4: Typical excavator utilised for excavation of a trench...... 8 Figure 5: Surface geological map of the Namaqua-Natal Metamorphic Complex...... 15 Figure 6: Modified prospect areas considering environmental sensitivity...... 23 Figure 7: Miss Zetu Damane with some of the community members...... 53 Figure 8: The affected local municipality and wards...... 54 Figure 9: Distribution of rock-types within the application area...... 55 Figure 10: Quartz veining visible in fresh and weathered rocks of the Khomo Formation of the NNZ...... 56 Figure 11: Land cover within and around the application area...... 57 Figure 12: Culture and heritage sites within the application area...... 58 Figure 13: Area proposed for drilling ...... 60 Figure 14: Area proposed for test trench ...... 60 Figure 15: Culture and heritage sensitivity map...... 60 Figure 16: Map depicting the sensitivity of the underlying geology in relation to the occurrence of fossils ...... 61 Figure 17: Water Management Areas of central, eastern and northern South Africa...... 62 Figure 18: Quaternary Catchment Areas of the study and surroundings...... 62 Figure 19: Image depicting the wetlands and other drainage lines recorded in the study area...... 63 Figure 20: Channelled valley bottom features the wetland on-site ...... 63 Figure 21: Identified wetland indicators: A) Setaria spp. and B) Katspruit soil form ...... 64 Figure 22: Delineated wetlands relative to the proposed positions of the six drillholes and trenches ...... 64 Figure 23: 500 m WULA buffer in relation to the proposed six drillholes and trenches...... 65 Figure 24: The erosional impacts within the landscape ...... 66 Figure 25: Wetland sensitivity in relation to the proposed six drillhole sites and trenches...... 66 Figure 26: Vegetation of the project area ...... 68

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Figure 27: The project area in relation to defined IBAs...... 73 Figure 28: The various vegetation areas identified during the field work ...... 75 Figure 29: The project area showing the ecosystem threat status of the associated terrestrial ecosystems ...... 77 Figure 30: The project area showing the level of protection of terrestrial ecosystems...... 77 Figure 31: The project area superimposed on the KZN Biodiversity Sector Plan...... 78 Figure 32: The project area in relation to the formally protected areas...... 79 Figure 33: Composite map of the application area...... 161

APPENDICES

Appendix A: Environmental Authorisation Application Form Appendix B: Prospecting Work Programme Appendix C: Details and Experience of EAP Appendix D: Maps Appendix E: Public Participation Appendix F: Specialist Reports Appendix G: Impact Assessment Calculations

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Definitions

Abbreviation Definition EA Environmental Authorisation. This constitutes the approval or dismissal of a project as issued by the relevant Competent Authority. Applicant The person or party applying for Environmental Authorisation for a listed activity and who is responsible for ensuring the development complies with all relevant legislation whether or not they are the land owner. BAR and EMPR Basic Assessment Report and Environmental Management Programme. DMR document for joint BAR and EMP related for mineral applications. CA Competent Authority. DEA The National Department of Environmental Affairs. DMR The Department of Mineral Resources. CA in South Africa for mineral right applications. DWS The Department of Water and Sanitation – both national offices and their various regional offices, which are divided across the country on the basis of water catchment areas. DWAF BPG Department of Water Affairs and Forestry Best Practice Guidelines. EAR Environmental Audit Report.

EAP Environmental Assessment Practitioner.

ECO Environmental Control Officer.

EIA Regulations Environmental Impact Assessment Regulations. EIR and EMP Environmental Impact Report and Environmental Management Programme. DMR document for joint EIR and EMP related to mineral applications.

Environment The Environment is defined in terms of the National Environmental Management Act (Act 107 of 1998) as the surroundings within which humans exist and that are made up of: The land, water and atmosphere of the earth: Micro-organisms, plant and animal life, any part or combination of the first three items and the inter-relationships between them the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and wellbeing.

Financial Provision Regulations pertaining to the financial provision for prospecting, exploration, mining or production Regulations operations No. 1147 (effective 20 November 2015).

FRDCP Final Rehabilitation, Decommissioning and Closure Plan. Fauna All living biological creatures, usually capable of motion, including insects and predominantly of protein- based consistency.

Fence A physical barrier in the form of posts and barbed wire or any other concrete construction, (“palisade”- type fencing included), constructed with the purpose of keeping humans and animals within or out of defined boundaries.

Flora All living plants, grasses, shrubs, trees, etc., usually incapable of easy natural motion and usually capable of photosynthesis. GN Government Notice. HSE Health, Safety and Environment. I&AP Interested and Affected Parties. MEC Member of the Executive Council. MPDRA Minerals and Petroleum Development Act, No 28 of 2002. MHSC Mine Health and Safety Council. NEMWA National Environmental Management Waste Act. NWA National Water Act. NHRA National Heritage Resources Act No 25 of 1999. OSHA Occupational Health and Safety Act 85 of 1993. PR Prospecting Right in terms of the MPRDA. SAHRA South African Heritage and Resources Act, No25 of 1999. SAMRAD The web-based portal for mineral right applications and management – managed by the DMR. SANS South African National Standards.

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PART A:

SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT

1. INTRODUCTION

WRE Base Metals (Pty) Ltd (hereafter referred to as WRE Base Metals, the Applicant) have identified potentially exploitable mineral resources over the Remaining Extent of portions 24 and 26 of the farm Reserve No. 19 15839 GU in the KwaZulu-Natal Province of South Africa. The minerals of interest are as follows:

WRE Base Metals submitted applications for a Prospecting Right and Environmental Authorisation (Appendix A) in order to prospect for these commodities. The application for the Prospecting Right was accepted by the Department of Mineral Resources (DMR) – KwaZulu-Natal Regional Office on the 20th December 2017. In addition, receipt of the application for an Environmental Authorisation was acknowledged by the Department on the 22nd November 2017. The proposed project will be known as the Nkunzana Prospecting Right and it will aim to explore and quantify potential mineral resources. In order to undertake prospecting activities, WRE Base Metals require a Prospecting Right in terms of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002). WRE Base Metals is also required to obtain an Environmental Authorisation in terms of the National Environmental Management Act, 1998 (Act 107 of 1998) which involves the submission of a Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) as well as undertaking a Public Participation Process (PPP). Shango Solutions have been appointed by WRE Base Metals as the Environmental Assessment Practitioner (EAP) to assist in complying with these requirements.

It is anticipated that the following invasive and non-invasive activities (Table 1) will be undertaken, based on information presented in the associated Prospecting Work Programme (Appendix B):

Table 1: Proposed prospecting activities. Non-invasive prospecting activities Invasive prospecting activities

Desktop studies  Drilling Acquisition and synthesis of data  Trenching Target generation and prospectivity ranking Grid sampling  Field visit and mapping Stream sediment sampling Surface electromagnetic and geophysical surveys Underground sampling of the historical mine  Geological modelling Concept study and resource estimation

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1.1 Location of the Activity The area of interest occupies a total of 2 069.06 hectares (ha) and is located approximately 92 kilometres (km) west of Richards Bay, in the KwaZulu-Natal Province of South Africa. Two (2) farm portions extend over the application area. Table 2 indicates the property details within the Prospecting Right application area. The proposed prospecting area is located in the Magisterial District of Nkandla and falls under the Nkandla Local Municipality, within the King Cetshwayo District Municipality (Figure 1).

Table 2: Locality details.

Farm Name Reserve No. 19 15839 GU: Remaining Extent (RE) of portions 24 and 26

Application Area (Ha) The application area extends over two farm portions with a total area of 2 069.06 ha

Magisterial District Nkandla Magisterial District

Distance and direction The Nkunzana Prospecting Right application area is located approximately from nearest town 20 km south of the town of Nkandla, 46 km southeast of Eshowe, 55 km north- east of Melmoth, 62 km southwest of Greytown and 92 km west of Richards Bay, in the KwaZulu-Natal Province. The application area can be accessed via Newcastle using the N11, the R68 to Melmoth, the R66 to Eshowe, the R34 from Richards Bay, and the R74 from Greytown to Stanger branching off on the Main Road to the town of Kranskop.

21 digit Surveyor General Farm Name: Portion: SG Code: Code for each Portion Reserve No. 19 15839 GU RE (of 24) N0GU00000001583900024

Reserve No. 19 15839 GU RE (of 26) N0GU00000001583900026

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1.2 Locality Map

Figure 1: Locality map indicating the farm portions (Refer to Appendix D for an enlarged map).

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1.3 Details of the Environmental Assessment Practitioner

Shango Solutions was appointed by WRE Base Metals as the EAP to compile this report. The contact details of the Shango Solutions consultants who compiled this report are as follows:

 Name of the EAP: Shango Solutions

 Contact persons: Zizo Siwendu or Mmakoena Mmola

 Tel No.: 011 678 6504

 Fax No.: 011 678 9731

 E-mail address: [email protected] or [email protected]

1.4 Expertise of the EAP

1.4.1 Qualifications of the EAP In terms of Regulation 13 of the NEMA 2014 EIA Regulations (Government Notice 326), an independent EAP must be appointed by the Applicant to manage the application. Shango Solutions have been appointed by the Applicant as the EAP and are compliant with the definition of an EAP as defined in the 2014 EIA Regulations and the NEMA. This includes, inter alia, the requirement that Shango Solutions are:

 Objective and independent.

 Have expertise in conducting EIAs.

 Comply with the NEMA, the Regulations and all other applicable legislation.

 Take into account all relevant factors relating to the application.

 Provide full disclosure to the Applicant and the relevant environmental authority.

Zizo holds a B.Sc. Honours Degree in Environmental Management. She has extensive auditing and environmental management experience, specifically in the mining environment. She has compiled several environmental studies in support of mineral right applications for Sungu Sungu Gas (Pty) Ltd, Motuoane Energy (Pty) Ltd, African Exploration, Mining and Finance Corporation, Evander Gold Mining (Pty) Ltd, Barberton Mines (Pty) Ltd, Palm Chrome (Pty) Ltd, Goosebay Farms (Pty) Ltd, Atoll Metal Recovery, Mafuri Mining and Construction (Pty) Ltd and Tetra 4 (previously known as Molopo South African Exploration).

Mmakoena holds a B.Sc. Honours Degree in Geochemistry. She has compiled environmental studies in support of mineral right applications for White Rivers Exploration (Pty) Ltd and Evander Gold Mining (Pty) Ltd.

1.4.2 Summary of EAP‟s Past Experience Shango Solutions, registered as Dunrose Trading 186 (Pty) Ltd and established in April 2004, provides a diverse range of services to the mineral and mining sectors. Currently, 27 permanent multi-disciplinary employees and about 24 nationally and internationally recognised affiliates are employed. The company has a track record of successful project management and leadership, including complex multi-disciplinary assignments.

Consultancy activities straddle the entire mining value chain from exploration to beneficiation, thereby providing the client with complete solutions. Activities are performed in multi-disciplinary teams. Areas of specialisation include target generation, exploration, geodatabase compilation and management, geological modelling, resource estimation, mineral asset valuations, due diligences, desktop project reviews and technical reporting. The company services the majority of the major mining houses, but also junior exploration companies, mineral

Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR resource investment firms, government institutions and departments and the artisanal and small-scale mining sectors. Shango Solutions collaborates closely with local and international experts in the mining and corporate industries. This, in conjunction with our affiliations with academic and parastatal institutions, ensures provision of the most innovative and appropriate solutions to clients.

Shango has completed in excess of 400 projects, of which the majority were located in Africa. The company consequently has extensive ground-based mining related experience throughout Africa, especially southern, eastern and north-west African states. Our extensive knowledge of the African minerals industry has attracted some of the largest names in mineral extraction to our client base. The project portfolio highlights our cross- sectorial approach and capability.

Shango incorporates in excess of 500 years of Africa-based mining and exploration experience. This includes, but is not limited to, gold, platinum, rare earth elements, base metals, uranium, coal, natural gas, ferrochrome, aggregate, heavy mineral sands and diamonds. Over the last decades, we have established comprehensive 2D Geographic Information Systems (GIS) databases throughout Africa, which consider geological and geophysical data, mineral occurrences, defunct and existing mines, infrastructure and mining statistics. Zizo‟s experience lies mainly with environmental assessments for the mining and energy industry, including the compilation of BAR‟s, EIA‟s, EMPR‟s, and undertaking compliance monitoring and Environmental and Financial Audit Reports. Mmakoena‟s experience is limited and lies mainly with environmental assessments for the mining industry, including the compilation of BAR‟s, EIA‟s, EMPR‟s, and Environmental and Financial Audit Reports.

The declaration of independence of the EAP and the Curricula Vitae (indicating the experience with environmental impact assessment and relevant application processes) of the consultants that were involved in the Basic Assessment process and the compilation of this report are attached as Appendix C.

1.4.3 Specialist Consultants The following specialist consultants provided inputs into this report:

 Ecological (fauna and flora) Assessment: The Biodiversity Company.

 Wetland Assessment: The Biodiversity Company.

 Heritage and Palaeontological Assessment: NGT Holdings.

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2. DESCRIPTION AND SCOPE OF THE PROPOSED ACTIVITY

Invasive and non-invasive prospecting activities will be undertaken as part of the proposed Prospecting Work Programme. The scope of these activities is as follows:

Phase 1

1.1 Data Acquisition: [Phase/s: Year One; Duration: 12 months] All historical data detailing the position and economic potential of the target orebodies will be acquired. The data obtained will be in the form of historical drillhole information, cadastral and geological maps, and geophysical surveys (all available existing published gravimetric, radiometric, magnetic, seismic data, remote sensing data, as well as any information pertaining to previous exploration or mining will be consulted and integrated). The data will be scrutinised and verified (QA/QC procedure). Relevant academic studies pertaining to the area will also be examined.

1.2 Database Compilation and Development of Preliminary Geological Model: [Phase/s: Year One, Duration: 6 months]

The above data will be compiled into a geological database for the area that will be utilised to present the relevant geological data in useable GIS digital map format. These different data sets will be plotted on a base map of the project and surrounding areas in order to develop a preliminary geological model. This model will be used to further refine the exploration programme for the target area.

1.3 Initial Field Visit: [Phase/s: Year One; Duration: 1 week] A field visit will be undertaken to familiarise the Applicant with surface features (such as historical mines, infrastructure, outcrops, water bodies and wetlands) in the project area and to meet the surface landowners. During this visit, farm boundaries within the project area and farming activities will be verified. An effort will be made to identify any factors that may impact the exploration program.

Phase 2

2.1 Field Visit and Mapping: [Phase/s: Year Two; Duration: 1 week] A second field visit will be conducted whereby the geology, structure and mineralised reef horizons will be mapped. A field-based map will be compiled highlighting the relevant stratigraphic units in the project area. The geological model will be updated using this information.

2.2 Preliminary Target Generation and Prospectivity Ranking: [Phase/s: Year Two; Duration: 12 months] Information collected will be analysed and interpreted. Targets will be delineated and ranked according to appropriate prospectivity parameters i.e. geological, structural, historic mining production, etc. for further exploration work. An exploration strategy will thereafter be devised for the project area.

Phase 3

3.1 Electromagnetic Geophysical Survey: [Phase/s: Year Three; Duration: 12 months] Electromagnetic geophysical surveys that have been conducted by mining companies could be acquired without the need for further surveys, if available. Based on a favourable outcome of the work in Year Two, the decision will be taken to purchase this survey and interpret this information in conjunction with the drillhole and other data. Should the surveys not be available, ground-based electromagnetic geophysical investigations will be carried out.

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3.2 Data Compilation and Interpretation: [Phase/s: Year Three; Duration: 12 months] The electromagnetic geophysical surveys will be integrated with the geological database and presented in useable GIS digital map formats.

3.3 Refinement of Geological Model: [Phase/s: Year Three; Duration: 6 months]

The preliminary geological model will be refined by incorporating information from the updated database. Targets that were initially generated and ranked will be reviewed accordingly.

3.4 Stream Sediment Sampling and Target Generation: [Phase/s: Year Three; Duration: 12 months] Approximately two (2) kilograms samples will be collected from sediments at non-perennial stream intersections (sample when the stream is dry). The sampling points will be recorded using a Geographical Positioning System (GPS). The samples will comprise of sand and silt only, with gravel and boulders being excluded. Small pits will be dug to bedrock using hand held shovels in order to obtain the samples. These pits will be filled once the samples have been collected. As these samples will be collected from within the dry river beds, no negative environmental impact will accrue. This work will be performed under the direct control of a trained supervisor who will ensure all aspects of Safety and Environmental Management.

3.5 Underground Sampling of the Historical Mine: [Phase/s: Year Three; Duration: 6 months] Should the historical mine be located, the adits and reef-drives will be sampled to determine grade variability in the orebodies. Following collection, the samples will be sent to a laboratory for assaying. Upon receipt of the results, these will be plotted and targets for further investigation will be generated. Maps indicating the sample positions, the assayed grades and the target areas will be plotted into a Geographical Information System (GIS).

Phase 4

4.1 Detailed Grid Sampling on Identified Targets: [Phase/s: Year Four; Duration: 4 months]

Should the stream sediment sampling return positive results, targets will be identified for more detailed sampling. Grid sampling on these targets will be conducted utilising a 50 metres grid spacing initially. These samples will be taken from the surface soil to a depth of no more than 30 centimetres. Such sampling collected using hand held shovels will be limited to about 1 - 2 kilograms and will have no negative environmental impact. As with the stream sediment sampling, this work will be performed under the direct control of a trained supervisor who will ensure all aspects of safety and environmental management.

4.2 Trench, Mapping and Sampling: [Phase/s: Year Four; Duration: 6 months]

Six trenches are proposed for this phase of prospecting. The trenches will be excavated utilising a bulldozer or a mechanical digger (Figure 4). Each trench will be excavated to a depth of 3 metres. Exposures will be mapped and sampled. The information acquired will be captured into a database and presented in useable GIS digital map formats. This information will then be integrated into the geological model in order to define the orebodies. Similarly to grid sampling, this activity will be conducted under the direct control of a trained supervisor who will ensure all aspects of safety and environmental management.

Phase 5

5.1 Drilling of 6 drillholes to a depth of 150 m: [Phase/s: Year Five; Duration: 12 months] Depending on the initial geological model established, a drilling programme comprising of approximately six drillholes will be undertaken. Percussion or diamond drilling will be considered for this phase.

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Drilling will be conducted in a competent and environmentally responsible manner including rehabilitation of the drill sites to their original state and will be undertaken utilising a drill rig (Figure 2), mounted on a vehicle. The drill rig will consist of a power driven rotary drill with a diamond studded bit (Figure 3). Plastic lining will be placed underneath the rig motors to prevent oil seepage. It is noted that no drilling fluids other than water for dust suppression, will be utilised in the case of diamond drilling. Environmental rehabilitation measures will be included in the contract with the drilling company and environmental rehabilitation costs will be included in the drilling costs. Programme. Should the drilling programme prove to be successful, additional drillholes will be drilled. This will be indicated in the form of a S102 application together with the proposed revised prospecting plan and BAR and EMPR.

5.2 Data Compilation and Interpretation: [Phase/s: Year Five; Duration: 12 months] The information acquired during drilling will be stored in a database and presented in useable GIS digital map formats. This information will be integrated into the geological model in order to further define the ore bodies intersected by the drilling.

5.3 Concept Study and Resource Estimation: [Phase/s: Year Five; Duration: 12 months]

Based on the refined geological model, the estimation of a code-compliant resource will commence.

Figure 2: A typical drill rig. Figure 3: Typical diamond drill bits.

Figure 4: Typical excavator utilised for excavation of a trench.

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2.1 Listed and Specified Activities The legal requirement for Environmental Authorisation for prospecting came into effect after the promulgation of the NEMA 2014 EIA Regulations on the 8th December 2014. Prior to this, Prospecting Rights were subjected to the provisions of the MPRDA (2002). In this regard, a Prospecting Right and Environmental Authorisation are required in terms of the MPRDA (2002) and NEMA 2014 EIA Regulations (as amended), respectively. The applicable NEMA listed activities anticipated to be triggered by this project are outlined in Table 3.

Table 3: Listed and specified activities.

Name of Activity Aerial extent of Listed Applicable listing activity (Ha or activity notice m2)

Any activity including the operation of that activity which 2 069.06 ha X Activity 20 of GN requires a prospecting right in terms of Section 16 of the 327 (of 2017) Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002), including (a) associated infrastructure, structures and earthworks, directly related to prospecting of a mineral or (b) the primary processing of a mineral resource including winning, extraction, classifying, concentrating, crushing, screening or washing; but excluding the secondary processing of a mineral resource, including the smelting, beneficiation, reduction, refining, calcining, or gasification of the mineral resource.

The project will involve drilling of six (6) diamond core 0.06 ha X Activity 20 of GN drillholes. The establishment of a drill pad will disturb an 327 (of 2017) area of up to 10 x 10 m per site. As such, the total/maximum of 6 drillholes would disturb an area covering approximately 600 m2 or 0.06 ha.

Excavation of six (6) trenches (4 trenches: each 3 m 0.08 ha X Activity 20 of GN deep, 2 m wide, 50 m long and 2 trenches : each 3 m 327 (of 2017) deep, 2 m wide, 100 m long)

The proposed activity will include the clearance of 0.50 ha X Activity 12(d) indigenous vegetation in KwaZulu-Natal. Within the (iv)(v)(viii)(xi)(xii) cleared area, the drill rig and drilling rods will be located. of GN 324 (of Ablution facilities, eating and sleeping quarters, waste 2017) (general and hazardous) storage as well as any other equipment will also be stored within cleared area.

The clearance of an area of 1 hectares or more, but less Up to 1 ha X Activity 27 of GN than 20 hectares of indigenous vegetation, except where 327 (of 2017) such clearance of indigenous vegetation is required for (i) the undertaking of a linear activity; or (ii) maintenance purposes undertaken in accordance with a maintenance management plan. Establishment of temporary unpaved access roads Shorter than X Activity 20 of GN 1 km 327 (of 2017)

Stream sediment sampling 2 kg X Activity 20 of GN 327 (of 2017)

Grid sampling 1 – 2 kg X Activity 20 of GN 327 (of 2017)

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Name of Activity Aerial extent of Listed Applicable listing activity (Ha or activity notice m2)

Desktop studies 2 069.06 ha X Activity 20 of GN 327 (of 2017)

Synthesis of historical drillhole data Up to 201.05 m X Activity 20 of GN in depth 327 (of 2017) Underground sampling of the historical mine 0.04 ha X Activity 20 of GN 327 (of 2017) Surface electromagnetic geophysical surveys 103 ha X Activity 20 of GN 327 (of 2017) Concept study and resource estimation 2 069.06 ha X Activity 20 of GN 327 (of 2017)

2.2 Description of Activities to be Undertaken It is anticipated that invasive and non-invasive prospecting activities will be undertaken, based on information presented in the Prospecting Work Programme over a 5 year period (Table 4). The primary targets of the prospecting activities are the metamorphosed rocks of the Nkomo and Tugela nappes of the Tugela terrane and the Natal Thrust Belt of the Namaqua-Natal Metamorphic Complex and the Natal Group. Small areas within the application area are overlain by Quaternary Sediments. The type of minerals to be prospected for include silver, gold, cobalt, copper, diamond (alluvial), iron, manganese, molybdenum, nickel, lead, platinum group metals, rare earths, sulphur, uranium, tungsten and zinc.

Table 4: Planned invasive and non-invasive activities. Year Activity Timeframe Outcome Timeframe for outcome 1 Non–Invasive Prospecting 12 months Establishment of Month 12 databases, preliminary Desktop studies geological model of the Locate and acquire all available gold area and locate historic (gold by products and base metals) and mine coal, geological and geophysical data relevant to prospect

Data QA/QC, digitisation and database compilation

Initial field visit 2 Non–Invasive Prospecting 12 months Compile a field-based Month 24 structural and stratigraphic Field visit and mapping map, rank preliminary targets Preliminary target generation target prospectivity ranking 3 Invasive Prospecting 12 months If indications are Month 36 favourable following Year Stream sediment sampling Two, electromagnetic Collect and assay stream sediments geophysical surveys, (non-perennial streams), plot results. stream sediment sampling Targets will be delineated for further and underground historic investigation mine sampling will be carried out

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Year Activity Timeframe Outcome Timeframe for outcome Underground sampling of the historical mine Maps with sampling points, Historic adits and reef-drives will be results and delineated sampled to determine the grade- target areas will be plotted variability in the orebodies. in GIS

Non–Invasive Prospecting

Surface electromagnetic geophysical surveys Possibility of surface electromagnetic geophysical surveys

Data synthesis, interpretation and development of provisional geological model 4* Invasive Prospecting 12 months Further refinement of the Month 48 geological model based on Grid sampling the grid sampling and Detailed grid sampling on identified revised trench sampling targets and refinement of geological model

Target / prospectivity ranking

Trenching, mapping and sampling Excavate 6 trenches (4 trenches – 3 m deep, 2 m wide, 50 m long; 2 trenches – 3 m deep, 2 m wide, 100 m long) , sample to identify and map mineralised outcrops 5* Invasive Prospecting 12 months Code compliant resource Month 60

Drilling 6 diamond core or percussion drillholes drilled to a depth of approximately 150 m

Final data synthesis and finalisation of geological model

Determination of a code-complaint resource will be carried out

*Activities for Years 4 and 5 are dependent on the outcome of exploration results from Years 1 to 3. Should the proposed exploration activity change, this will be indicated in the form of a S102 Application together with the proposed revised prospecting plan.

2.3 Activities Associated With Planned Prospecting The activities associated with each phase of prospecting operations are described in Table 5.

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Table 5: Activities associated with planned prospecting.

Main activity/action/process Ancillary activity

Planning

Site visit Vehicle and foot traffic on site

Construction

General management Human resource management Employment Interaction with local community Road construction, site preparation and site Vehicle and foot traffic on-site establishment Clearance and preparation of soil stockpile areas Construction of temporary unpaved access road Dust suppression Fencing Hazardous substances management Site security Soil management Utilisation of portable toilets and generation of sewage Vegetation clearance Waste management

Operation

General management Employment Human resource management Interaction with local community

Drilling of six (6) drillholes and excavation of six (6) Site security trenches Employment Soil management Noise management Dust management Vegetation clearance Waste management Vehicle and foot traffic on-site Hazardous substances management Interaction with local community

Soil surface grid sampling Vehicle and foot traffic on-site Soil management

Stream sediment sampling Vehicle and foot traffic on-site Water management

Surface electromagnetic geophysical surveys Vehicle and foot traffic on-site Noise management

Decommissioning

General management Employment Human resource management Interaction with local community

General decommissioning activities Dust suppression Removal of waste

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Main activity/action/process Ancillary activity

Infrastructure removal Dismantling, removal and rehabilitation of unnecessary infrastructure Removal of fencing

Rehabilitation and Closure

General surface rehabilitation Profiling of all areas Replacement of subsoil and topsoil Ripping of roads and other compacted areas Managing the site for all post prospecting impacts to prevent any further pollution Vehicle and foot traffic on-site Re-vegetation Dust suppression Fertilisation Seeding with local indigenous species Post closure monitoring and maintenance Alien vegetation management Environmental monitoring of rehabilitated areas Erosion control measures

2.4 Description of Site Activities 2.4.1 Access Roads Access will be required for on-site prospecting operations. The site is only accessible by foot. Therefore, temporary unpaved access roads will be established in order to access the site. The temporary roads created to gain access to site will be rehabilitated on completion of the prospecting operations, to the satisfaction of the relevant landowner.

2.4.2 Water Supply It is not known if there are any water boreholes located close to the drill sites and trench sites, and whether access and supply will be granted by the landowner. It is anticipated that water brought onto the sites will be sourced from the Local Municipality. Water will be trucked from these sources to the identified sites. Water bowsers will be deployed to these sites in order to prevent dust pollution on the untarred temporary roads.

Continuous water supply will be required during drilling. An on-site water storage tank with a capacity of at least 15 000 litres will be required. Additional water requirements relate to the potable water supply for employees and workers. A temporary 260 litre on-site vertical water storage tank for drinking water and general use will be provided at the drill and trench sites.

2.4.3 Ablution Ablution facilities at the drill sites and trench sites will be required and may involve the installation of drum or tank type portable toilets. The toilets should be emptied twice every week through the services of a registered sewage waste service provider. The ablution facilities must be provided at a ratio of 15: 1, i.e. 15 people per 1 toilet.

2.4.4 Temporary Office Area A temporary shaded site office area may be erected on site. The office must be established away from the water drainage lines. No on-site electricity generation through the use of generators will be undertaken. There will be no heating and/or cold storage facilities provided at the site. The employees as well as the workers may bring to site their own meals. A shaded eating area may be provided.

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2.4.5 Accommodation Accommodation will be provided on-site for staff and workers. Night security staff may be employed to guard the staff and workers as well as equipment stationed on-site. No fires will be allowed on-site.

2.4.6 Storage of Dangerous Goods During the diamond drilling and trenching activities, limited quantities of diesel fuel, oil and lubricants may be stored on-site. A maximum amount of 60 m3 may be stored in above ground diesel storage tanks with elevated bunded walls.

2.4.7 Equipment and/or Technology That May Be Used

 Drill rig/s.  Excavator or an impactor.  A water tanker.  Bakkie/s.  Geological modelling software.

2.5 Geological Formation and Prospecting Targets The surface geology of the prospecting area consists of rocks of the Namaqua-Natal Metamorphic Complex (Figure 5). Lithologies of the Natal Metamorphic Complex have been interpreted to be an ophiolite complex derived from oceanic rock which was thrust northwards onto the southernmost edge of the Kaapvaal Craton (Cornell et al., 2006).

Although KwaZulu-Natal is well known for its coal resources, the application area is more prospective for shear zone-hosted gold. The primary targets of the prospecting activities are the metamorphosed rocks of the Nkomo and Tugela nappes of the Tugela Terrane and the Natal Thrust Belt of the Namaqua-Natal Metamorphic Complex and the Natal Group.

Gold mineralisation, historic exploration and mining in the application area have been documented in literature (Wilson and Ward, 1998, Hatch, 1910 and Council for Geosciences, 2016). The mineralisation is hosted in sericite and chlorite schists of the Mfongosi Group of the Natal Thrust Belt. The quartz veins hosting the gold are developed along a shear zone striking east-west. Two abandoned workings produced 22 kilograms (kg) of gold at an average grade of 3.17 g/t (Wilson and Ward, 1998, Hatch, 1910 and CGS, 2016).

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Figure 5: Surface geological map of the Namaqua-Natal Metamorphic Complex (Refer to Appendix D for an enlarged map).

3. POLICY AND LEGISLATIVE CONTEXT

The Nkunzana Prospecting Right application requires authorisation in terms of the following interlinked pieces of legislation:

 The Mineral and Petroleum Resources Development Act, 2002 (MPRDA, Act 28 of 2002), as amended.

 The National Environmental Management Act, 1998 (NEMA, Act 107 of 1998), as amended.

These pieces of core legislation stipulate the required studies, reports and legal processes to be conducted and the results thereof submitted to the relevant authorities for approval prior to commencement.

In addition to the above, there are various pieces of legislation which govern certain aspects of the prospecting operations and these are summarised in Table 6, together with the main legislative requirements mentioned above.

Table 6: Policy and legislative context.

Applicable legislation and Reference where applied How does this development guidelines comply with and respond to the

legislation and policy context

National Environmental This entire report is prepared as part of In terms of the National Management Act, 1998 (Act the Application for Environmental Environmental Management Act an 107 of 1998) Authorisation under the NEMA. Application for Environmental Authorisation subject to a Basic Assessment Process has been applied for.

Minerals and Petroleum This entire report is prepared as part of In terms of the Mineral and Resources Development the Prospecting Right Application under Petroleum Resources Development Act, 2002 (Act 28 of 2002) the MPRDA. Act a Prospecting Right Application

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Applicable legislation and Reference where applied How does this development guidelines comply with and respond to the

legislation and policy context

has been applied for.

National Environmental A framework for management of waste is This report has been drafted in with Management Waste Act, presented in this report. due consideration to this Act. 2014 (Act 26 of 2014)

National Environmental A framework for management of alien The management of alien invasive Management Biodiversity invasive species is presented in this species is governed under the Act, 2004 (Act 10 of 2004) report. NEMBA. This report includes a framework for the management of alien and invasive species. The holder of a right will be required to develop a detailed alien invasive species management plan. National Water Act, 1998 Due to the nature of the proposed In terms of the National Water Act, (Act 36 of 1998) Section 21 prospecting activities no Section 21 no Water Use License has been water uses will be triggered, therefore applied for. there is no requirement to apply for Water Use authorisation in terms of the NWA. National Heritage Resources The framework for a Heritage A specialist heritage impact study Act, 1999 (Act 25 of 1999) Management Plan is provided in this has been undertaken in support of EMPR. this Prospecting Right application.

3.1 Environmental Authorisation Process

3.1.1 Mineral and Petroleum Development Act In terms of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002), a Prospecting Right must be issued prior to the commencement of any prospecting activities. As per Section 79(4)(a) and (b) of the MPRDA, the Applicant is required to conduct an Basic Assessment and submit an EMPR for approval as well as to notify in writing and consult with Interested and Affected Parties (I&APs) within 90 days of acceptance of the application. The MPRDA also requires adherence with related legislation, chief amongst them is the National Environmental Management Act, 1998 (Act 107 of 1998, NEMA) and the National Water Act, 1998 (Act 36 of 1998, NWA).

Several amendments have been made to the MPRDA. These include, but are not limited to, the amendment of Section 102, concerning amendment of rights, permits, programmes and plans, to requiring the written permission of the Minister for any amendment or alteration; and the section 5A(c) requirement that landowners or land occupiers receive twenty-one (21) days‟ written notice prior to any activities taking place on their properties. One of the most recent amendments requires all mining related activities to follow the full NEMA process as per the 2014 EIA Regulations, which came into effect on 8th December 2014.

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A Prospecting Right is exclusive, transferable, valid for 5 years, and renewable for a maximum of 3 years. Prospecting allows the holder of the right to conduct activities as per the Prospecting Work Programme to establish the presence of economically viable mineral resources. A Prospecting Right does not grant the holder the right to conduct any mining related activities.

3.1.2 National Environmental Management Act The main aim of the National Environmental Management Act, 1998 (Act 107 of 1998) (NEMA) is to provide for co-operative governance by establishing decision-making principles on matters affecting the environment. In terms of the NEMA Environmental Impact Assessment (EIA) regulations, the proponent is required to appoint an environmental assessment practitioner (EAP) to undertake the EIA 9 as well as the public participation process. In South Africa, EIA became a legal requirement in 1997 with the promulgation of regulations under the Environmental Conservation Act (ECA). Subsequently, NEMA was passed in 1998. Section 24(2) of NEMA empowers the Minister and any MEC, with the concurrence of the Minister, to identify activities which must be considered, investigated, assessed and reported on to the competent authority responsible for granting the relevant environmental authorisation. On 21 April 2006 the Minister of Environmental Affairs and Tourism promulgated regulations in terms of Chapter 5 of the NEMA.

The objective of the Regulations is to establish the procedures that must be followed in the consideration, investigation, assessment and reporting of the activities that have been identified. The purpose of these procedures is to provide the competent authority with adequate information to make decisions which ensure that activities which may impact negatively on the environment to an unacceptable degree are not authorised, and that activities which are authorised are undertaken in such a manner that the environmental impacts are managed to acceptable levels.

The aim of the EIA process is to identify and assess the potential impacts associated with the proposed project and to develop measures through which potential negative biophysical and socio-economic impacts can be mitigated and positive benefits can be enhanced. The EIA will ensure that all issues are integrated into the lifecycle of the mining operation and its infrastructure. This will occur during the planning, construction, operation and decommissioning and site closure phases.

The Basic Assessment Report and the associated EMPR will indicate how the identified impacts will be avoided, mitigated and/or managed by setting environmental objectives and goals. The EMPR will further outline the implementation programme for the environmental objectives and goals. The EMPR is a legal requirement of the MPRDA and all mines, existing or new, are required to possess an approved EMPR prior to initiating any prospecting operations. The EMPR is legally binding and the proponent is required to meet the requirements specified in the document.

3.1.3 National Environmental Management: Waste Amendment Act On the 2nd June 2014 the National Environmental Management: Waste Amendment Act, 2014 (Act 26 of 2014) came into force. Waste is accordingly no longer governed by the MPRDA, but is subject to all the provisions of the National Environmental Management: Waste Act, 2008 (NEMWA). Section 16 of the NEMWA must also be considered which states as follows:

1. “A holder of waste must, within the holder‟s power, take all reasonable measures to:

 Avoid the generation of waste and where such generation cannot be avoided, to minimise the toxicity and amounts of waste that are generated.  Reduce, re-use, recycle and recover waste.

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 Where waste must be disposed of, ensure that the waste is treated and disposed of in an environmentally sound manner.  Manage the waste in such a manner that it does not endanger health or the environment or cause a nuisance through noise, odour, or visual impacts.  Prevent any employee or any person under his or her supervision from contravening the Act.  Prevent the waste from being used for unauthorised purposes.

These general principles of responsible waste management are incorporated into the requirements in the EMPR to be implemented for this project.

Schedule 3: Defined Wastes have been broken down into two categories: Category A being hazardous wastes and category B being general wastes. Under Category A (hazardous wastes) the act makes allowance for “wastes resulting from exploration, mining, quarrying, and physical and chemical treatment of minerals”.

In order to attempt to understand the implications of this it is important to ensure that the definitions of all the relevant terminologies are defined:  Hazardous waste: means “any waste that contains organic or inorganic elements or compounds that may, owning to the inherent physical, chemical or toxicological characteristic of that waste, have a detrimental impact on health and the environment and includes hazardous substances, materials or objects within business waste, residue deposits and residue stockpiles.”  Residue deposits: means “any residue stockpile remaining at the termination, cancellation or expiry of a prospecting right, mining right, mining permit, exploration right or production right.”  Residue stockpile: means “any debris, discard, tailings, slimes, screening, slurry, waste rock, foundry sand, mineral processing plant waste, ash or any other product derived from or incidental to a mining operation and which is stockpiled, stored or accumulated within the mining area for potential re-use, or which is disposed of, by the holder of a mining right, mining permit or, production right or an old order right, including historic mines and dumps created before the implementation of this Act.”

Various regulations have been drafted in support of the NEMWA, as discussed below:

 Proposed Regulations regarding the planning and management of waste from a prospecting, mining, exploration or production operations (2014) - Chapter 2, Section 3 states the identification and assessment of any environmental impacts, including those on groundwater, arising from waste must be done as part of the Environmental Impact Assessment (EIA) conducted in terms of the National Environmental Management Act, 1998 (Act 107 of 1998) (hereafter referred to as the NEMA). The pollution control barrier system shall be defined by the (a) Waste Classification and Management Regulations (2013); (b) National Norms and Standards for the Assessment of Wastes for Landfill Disposal (2013); and (c) National Norms and Standards for Disposal of Waste to Landfill (2013)

- Waste Characterisation must be done in terms of physical and chemical composition as well as content. The classification must be done in terms of the health and safety classification and the environmental classification.

 Proposed Regulations to exclude a waste stream or a portion of a waste stream from the definition of a waste (2014) - This regulation will give the holder of the right the opportunity to exclude a waste stream, or a portion of a waste stream from the definition of a waste. Chapter 2, Section 4 of this Regulation, Sub-section (1) states that any portion of a waste generated from a source listed in Category A of

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Schedule 2 of the NEMWA, may be excluded from being defined as hazardous on demonstration that such portion of waste in non-hazardous in accordance with the Waste Management and Classification Regulations of 2013.

- The application process will be in the form of a prescribed process and application must be made to the Minister.

- This Regulation is however not yet in force.

 National Norms and Standards for the assessment of waste for landfill disposal (23 August 2013) - These norms and standards prescribe the requirements for the assessment of waste prior to disposal to landfill.

- The aim of the waste classification tests is to characterise the material to be deposited or stored in terms of the above-mentioned waste classification guidelines set by the Department of Environmental Affairs (DEA).

 The outcomes of the tests provide the necessary information in terms of:

- Identification of chemical substances present in the waste.

- Determination of the total concentrations (TC) and leachable concentrations (LC) of the elements and chemical substances that have been identified in the waste and that are specified in Section 6 of the above-mentioned Regulations. The obtained TC and LC values of the waste material will be compared to the threshold limits for total concentrations (TCT limits) and leachable concentrations (LCT limits) specified in Section 6 of the above-mentioned Regulations. Based on the TC and LC values of the elements and chemical substances in the waste exceeding the corresponding TCT and LCT limits respectively, the specific type of waste for disposal to landfill will be determined in terms of Section 7 of the Regulations.

3.1.4 The National Environmental Management: Biodiversity Act The National Environmental Management: Biodiversity Act, 2004 (Act 10 of 2004, NEMBA), “provides for: the management and conservation of South Africa‟s biodiversity within the framework of the NEMA; the protection of species and ecosystems that warrant national protection; the sustainable use of indigenous biological resources; the fair and equitable sharing of benefits arising from bio-prospecting involving indigenous biological resources; the establishment and functions of a South African National Biodiversity Institute (SANBI); and for matters conducted therewith”.

 In terms of the Biodiversity Act, the applicant has a responsibility for: The conservation of endangered ecosystems and restriction of activities according to categorization of the area (not just by listed activity as specified in the EIA regulations); - Promote the application of appropriate environmental management tools in order to ensure integrated environmental management of activities thereby ensuring that all developments within the area are in line with ecological sustainable development and protection of biodiversity.

- Limit further loss of biodiversity and conserve endangered ecosystems.

Regulations published under the NEMBA also provide a list of protected species, according to the Act (GNR 151 dated 23 February 2007, as amended in GNR 1187 dated 14 December 2007). Section 57 of NEMBA identifies restricted activities involving threatened or protected species. Restricted activities include the gathering, collecting, cutting, uprooting, damaging or destroy a listed species.

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3.1.5 The National Environmental Management: Protected Areas Act The National Environmental Management: Protected Areas Act, 2003 (Act 57 of 2003, NEMPAA) serves to: “provide for the protection and conservation of ecologically viable areas representative of South Africa‟s biological biodiversity and its natural landscapes and seascape; for the establishment of a national register of all national, provincial and local protected areas; for the management of those areas in accordance with national norms and standards; for intergovernmental co-operation and public consultation in matters concerning protected areas; for the continued existence, governance and functions of South African National Parks; and for matters in connection therewith.

 The objectives of this Act are –

a) To provide, within the framework of the national legislation, including the National Environmental Management Act, for the declaration and management of protected areas.

b) To provide for co-operation governance in the declaration and management of protected areas.

c) To effect a national system of protected areas in South Africa as part of a strategy to manage and conserve its biodiversity.

d) To provide for a diverse and representative network of protected areas on state land, private land, communal land and marine water.

e) To promote sustainable utilisation of protected areas for the benefit of people, in a manner that would preserve the ecological character of such areas.

f) To promote participation of local communities in the management of protected areas, when appropriate.

g) To provide for the continued existence of South African National Parks.

3.1.6 National Water Act The National Water Act, 1998 (Act 36 of 1998, NWA) makes provision for two types of application for water use licences, namely individual applications and compulsory applications. The NWA also provides that the responsible authority may require an assessment by the Applicant of the likely effect of the proposed licence on the resource quality, and that such assessment be subject to the EIA regulations. A person may use water, if the use is-  Permissible as a continuation of an Existing Lawful Water Use (ELWU).  Permissible in terms of a general authorisation (GA).  Permissible under Schedule 1.  Authorised by a License.

The NWA defines 11 water uses. A water use may only be undertaken if authorised. Water users are required to register certain water uses that actually took place on the date of registration, irrespective of whether the use was lawful or not.

Section 21 of the National Water Act 1998 lists the following 11 water uses which can only be legally undertaken through the water use authorisation issued by the Department of Water and Sanitation (DWS):

 Taking water from a water resource.  Storing water.  Impeding or diverting the flow of water in a watercourse.

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 Engaging in a stream flow reduction activity contemplated in Section 36.  Engaging in a controlled activity identified as such in Section 37(1) or declared under Section 38(1).  Discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall or other conduits.  Disposing of waste in a manner which may detrimentally impact on a water resource.  Disposing in any manner of water which contains waste from, or which has been heated in, any industrial or power generation process.  Altering the bed, banks, course or characteristics of a watercourse.  Removing, discharging or disposing of water found underground if it is necessary for the efficient continuation of an activity or for the safety of people.  Using water for recreational purposes.

In terms of the National Water Act, no Water Use Licence has been applied for this project.

3.1.7 National Heritage Resources Act The National Heritage Resources Act, 1999 (Act 25 of 1999, NHRA) stipulates that cultural heritage resources may not be disturbed without authorization from the relevant heritage authority. Section 34(1) of the NHRA states that, “no person may alter or demolish any structure or part of a structure which is older than 60 years without a permit issued by the relevant provincial heritage resources authority…” The NHRA is utilised as the basis for the identification, evaluation and management of heritage resources and in the case of CRM those resources specifically impacted on by development as stipulated in Section 38 of NHRA, and those developments administered through NEMA and MPRDA legislation. In the latter cases the feedback from the relevant heritage resources authority is required by the State and Provincial Departments managing these Acts before any authorizations are granted for development.

The last few years have seen a significant change towards the inclusion of heritage assessments as a major component of Environmental Impacts Processes required by NEMA and MPRDA. This change requires us to evaluate the Section of these Acts relevant to heritage (Fourie, 2008b): The NEMA 23(2)(b) states that an integrated environmental management plan should, “…identify, predict and evaluate the actual and potential impact on the environment, socio-economic conditions and cultural heritage”.

A study of subsections (23)(2)(d), (29)(1)(d), (32)(2)(d) and (34)(b)and their requirements reveals the compulsory inclusion of the identification of cultural resources, the evaluation of the impacts of the proposed activity on these resources, the identification of alternatives and the management procedures for such cultural resources for each of the documents noted in the Environmental Regulations. A further important aspect to be taken account of in the Regulations under NEMA is the Specialist Report requirements laid down in Section 33 (Fourie, 2008b).

MPRDA defines „environment‟ as it is in the NEMA and therefore acknowledges cultural resources as part of the environment. Section 39(3)(b) of this Act specifically refers to the evaluation, assessment and identification of impacts on all heritage resources as identified in Section 3(2) of the National Heritage Resources Act that are to be impacted on by activities governed by the MPRDA. Section 40 of the same Act requires the consultation with any State Department administering any law that has relevance on such an application through Section 39 of the MPRDA. This implies the evaluation of Heritage Assessment Reports in Environmental Management Plans or Programmes by the relevant heritage authorities (Fourie, 2008b).

In accordance with the legislative requirements and EIA rating criteria, the regulations of the South African Heritage Resources Agency (SAHRA) and Association of Southern African Professional Archaeologists (ASAPA)

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4. NEED AND DESIRABILITY OF THE PROPOSED ACTIVITIES

5. MOTIVATION FOR THE OVERALL PREFERRED DEVELOPMENT FOOTPRINT

 Activity Alternatives.  Location Alternatives.  Design or Layout Alternatives.  Technology Alternatives.  Operational Alternatives.  No-Action Alternative (“No-Go”).

For any alternative to be considered feasible, such an alternative must meet the need and purpose of the development proposal without presenting significantly high associated impacts. Alternatives are typically distinguished into discrete or incremental alternatives. Discrete alternatives are overall development options, which are typically identified during the pre-feasibility, feasibility and/or Basic Assessment process. Incremental alternatives typically arise during the Basic Assessment process and are usually suggested as a means of addressing/mitigating identified impacts (drilling and trenching in low sensitivity areas). These alternatives are closely linked to the identification of mitigation measures and are therefore not specifically identified as distinct alternatives.

For the purpose of this project the need and justification for alternatives was specifically guided by the relatively low sensitivity of the receiving socio-economic and biophysical environment as well as the geology. The types of alternatives considered are presented below.

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6. FULL DESCRIPTION OF THE PROCESS FOLLOWED TO REACH THE PROPOSED PREFERRED ALTERNATIVES WITHIN THE SITE

The development footprint is expected to be a fraction (0.98 ha) of the overall area size, which is estimated to be 2 069.06 ha. The geology is the primary driver in determining the location for prospecting. The area to be invasively prospected is in the vicinity of the historical and defunct Nkunzana Mine.

6.1 Location Alternative The application area has been selected based on historical data available for the region, which indicates the potential for economically viable mineral resources to occur. The rocks in the application area are predominantly those of the Mesoproterozoic Natal Metamorphic Province (NMP). These rocks have been thrust northwards over the older Kaapvaal Craton. The NMP contains a nappe and thrust belt, the Natal Nappe Zone (NNZ) and the Natal Thrust Front (NTF). The rocks of the NTF (the Mfongosi Group) have been subjected to high pressure greenschist facies metamorphism during the northwards thrusting of the NMP to form amphibolite schists. The NNZ Khomo Formation (Tugela Group) are deeper rocks thrust on top of the Mfongosi Group with higher temperature and pressure amphibolite facies metamorphism. The Tugela Group was also intruded by granites (including the Halumbu Granite) during these higher temperature conditions.

Although KwaZulu-Natal is well known for its coal resources, the application area is more prospective for shear zone-hosted gold. Gold mineralisation, historic exploration and mining in the application area have been documented in literature (Wilson and Ward, 1998; Hatch, 1910; Council for Geosciences, 2016). The mineralisation is hosted in sericite and chlorite schists of the Mfongosi Group of the Natal Thrust Belt. The quartz veins hosting the gold are developed along a shear zone striking east-west. Two abandoned workings produced 22 kg of gold at an average grade of 3.17 g/t (Wilson and Ward, 1998; Hatch, 1910; CGS, 2016).

Two site alternatives were identified within the application area, namely the (i) Preferred prospecting site (Alternative 1) and the (ii) Alternative prospecting site (Alternative 2A – 2D), collectively referred to as Alternative 2 in this report (Figure 6).

Figure 6: Modified prospect areas considering environmental sensitivity.

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6.1.1 Preferred Prospecting Site (Alternative 1) The site has been selected based predominantly on historical data available, which indicates the potential for gold mineralisation to occur. The Nkandla district of KwaZulu-Natal is auriferous and has been historically explored and mined. Prospecting activities began in the Nkandla district between the Tugela and the Mhlatuze rivers in 1892 and continued sporadically for three decades. Many gold-bearing occurrences across the district were found. The historical and defunct Nkunzana Mine is found in close proximity to this site. The application area has been selected as the preferred site based on its close proximity to the historical and defunct Nkunzana mine. However, a number of sensitive features were identified on-site during field surveys conducted by the specialists.

6.1.2 Alternative Prospecting Site (Alternative 2) According to the specialist field surveys that were conducted, areas of low sensitivity were also identified within the project application area. As such, areas of low sensitivity (Alternative sites 2A, 2B, 2C and 2D) are presented as an alternative site and they are collectively referred to as Alternative 2 in this report. The advantages and disadvantages of both sites are tabulated below (Table 7).

Table 7: Advantages and disadvantages of Site Alternative 1 and Site Alternative 2.

Alternative 1

Advantages Disadvantages

The geology indicates the correct rock host Occurs within a Critical Biodiversity Area (CBA): type (Mfongosi Group amphibolite schist). Irreplaceable. A field survey confirmed the ecological integrity of the CBA as well as the presence of Threatened species.

Mineralisation is indicated by the presence of Falls within two ecosystems listed as Vulnerable and Least the historical Nkunzana Mine. Threatened which are both still sensitive.

Known point from which exploration can Overlaps with a formally Protected Area (Nkandla Forest commence, thus shortening the time to identify Complex) and falls within the 5 km buffer zone the possibility of mineralisation. recommended for Protected Areas.

Occurs within a 500 m Water Use License Application buffer zone of the Nzuse River which triggers the application for General Authorisation.

Three avifaunal (bird) Species of Conservation Concern (SCC) were recorded during the survey.

6 Graves were identified with the vicinity of the planned prospecting site.

Area has a high ecological and heritage sensitivity score.

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Alternatives 2A to 2D

Occurs within a Critical Biodiversity Area: Located further from the historical Nkunzana Mine. Optimal. A field survey confirmed that the area has been altered by anthropogenic impacts (roads, power lines, livestock grazing, dwellings and water reservoirs).

Area has a low ecological and heritage Prospecting may disturb inhabitants due to proximity to sensitivity score. dwellings to target areas.

Alternative site 2A and 2B contain the same Gold mineralisation has not been proven in the Khomo rocks (Mfongosi Group amphibolite schist) that Group of the Tugela Formation, although significant hosts gold mineralisation in the Nkuzana Mine. mineralisation occurs in other groups of the Tugela Formation. Alternative site 2C and 2D contain quartz veined rocks of the Tugela Group which has been found to be mineralised to the east of the area.

6.2 Activity Alternatives Due to the unavailability of extensive historical drillhole datasets, invasive prospecting activities such as drilling, trenching and sampling as well as non-invasive activities such as desktop studies, field visits and mapping, target generation, target prospectivity ranking, surface electromagnetic geophysical surveys, geological modelling and resource estimation, will be conducted during prospecting. No bulk sampling work is to be carried out during the prospecting programme.

6.3 Design or Layout Alternative Specific areas within the application area have been identified for drilling and trenching in order to minimise land destruction during prospecting. The extent of the application area considered is illustrated in Figure 1.

6.4 Technology Alternatives The technologies listed in the Prospecting Work Programme have been selected as they have proven to be effective in the determination of resource viability within the proposed prospecting area. Some of the techniques employed in the non-invasive prospecting will include desktop studies, field visits and mapping, target generation, target prospectivity ranking, surface electromagnetic geophysical surveys, geological modelling and resource estimation.

Invasive technology alternatives have also been considered. It is hereby noted that the different phases and timeframes of the prospecting herein envisaged are, by their nature, dependent on the results obtained during the preceding phases of such prospecting. Invasive prospecting activities are dependent on the outcome of the non- invasive prospecting activities. Should the proposed exploration activity change, this will be indicated in the form of a Section 102 Amendment Application (of the MPRDA) together with the proposed revised prospecting plan.

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6.5 Operational Aspects Operational aspects that have been considered for the effective implementation of the Prospecting Work Programme include financial arrangements, appropriate equipment available and the technical skills available. An amount of R3 730 691 will be required to finance the Prospecting Work Programme. The Creasy Group of companies has committed to finance the prospecting costs as detailed in the Prospecting Work Programme. This group is a long-standing investor in the South African minerals industry. The long term strategy of WRE Base Metals is to be listed at the South African and Australian stock exchanges.

6.6 No Action Alternative (“No-Go”) If the Prospecting Right is not granted, the potential to identify economically viable mineral resources could be lost. Historical prospecting and mining activities have taken place in the vicinity of the proposed Prospecting Right area and as such, the proposed prospecting activities would represent a continuation of a historic land-use.

7. DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED

7.1 Public Participation Methodology The Public Participation Process (PPP) is a requirement of several pieces of South African Legislation and aims to ensure that all relevant Interested and Affected Parties (I&APs) are consulted, involved and their opinions are taken into account and a record included in the reports submitted to Authorities. The process ensures that all stakeholders are provided this opportunity as part of a transparent process which allows for a robust and comprehensive environmental study.

A database/I&AP register was compiled. The list includes various stakeholders, authorities, landowners and land occupiers. Notification documents were compiled in English and IsiZulu. The notification documents were distributed on the 8th January 2018. I&APs were provided a period of 30 days to register and comment on the proposed activity and application.

7.1.1 Identification of I&APs An initial I&AP database was compiled using WinDeed searches, internet searches and previous BA projects in the vicinity of the study area. The I&AP database was compiled containing the following categories of stakeholders:  National, provincial and local government.  Agricultural sector.  Organised business.  Host and adjacent communities.  Land claimants.  Other organisations, clubs, communities, and unions.  Various Non-Government Organisations (NGOs).

7.1.2 List of Authorities Identified and Notified The following authorities have been identified and notified of the proposed Nkunzana Prospecting Right:  Nkandla Local Municipality.  King Cetshwayo District Municipality.  KwaZulu-Natal Department of Economic Development, Tourism, Environmental Affairs and Small Business.

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 KwaZulu-Natal Department of Agriculture and Rural Development.  KwaZulu-Natal Department of Cooperative Governance, Traditional Affairs and Human Settlements.  KwaZulu-Natal Department of Water and Sanitation.  KwaZulu-Natal Department of Agriculture, Forestry and Fisheries.  KwaZulu-Natal Department of Transport and Roads.  KwaZulu-Natal Department of Public Works.  KwaZulu-Natal Department of Mineral Resources.  National Department of Mineral Resources.  National Department of Agriculture, Forestry and Fisheries.  National Department of Rural Development and Land Reform.  National Development Agency.  Catchment Management Agency.  South African National Roads Agency Ltd (SANRAL).  Ezemvelo KZN Wildlife.  The Council for Scientific and Industrial Research (CSIR).  Eskom SOC Limited.  Transnet SOC Limited.  Telkom SA Limited.

7.1.3 List of Key Stakeholders Identified and Notified The following key stakeholders have been identified and notified of the proposed Nkunzana Prospecting Right:  Wildlife and Environment Society of South Africa (WESSA).  Birdlife South Africa.  Endangered Wildlife Trust.  Council for Geo-Sciences.  KZN Conservancies.  AMAFA.  Federation for a Sustainable Development.

7.1.4 List of Surface Rights/Landowners Identified and Notified The Ingonyama Trust has been identified as the surface right/landowner of the area under application and has been notified of the proposed Nkunzana Prospecting Right.

7.1.5 List of Adjacent Landowners Notified The Nkandla Forest Complex adjoins the application area. This forest complex incorporates the following protected areas:  Nkandla Forest Reserve.  Dhlabe Nature Reserve.  Edodweni Nature Reserve.  Mndunduzeli Nature Reserve.  Mome Nature Reserve.  Sibudeni Nature Reserve.  Vungwini Nature Reserve.

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The KwaZulu-Natal Nature Conservation Board, established in terms of the KwaZulu-Natal Nature Conservation Management Act, 1997 (Act 9 of 1997), was appointed by the KwaZulu-Natal MEC: Agriculture and Environmental Affairs as the management authority for all provincial protected areas in KwaZulu-Natal. The Board‟s implementing agency is the Ezemvelo KZN Wildlife. As the implementing agency, Ezemvelo KZN Wildlife was identified as the representative of the adjacent landowner of the area under application and has been notified of the proposed Nkunzana Prospecting Right.

7.2 Notification of I&APs This section provides details on the notification that was distributed as part of the BA process to date.

7.2.1 Initial Notification The PPP commenced on the 8th January 2018 with an initial notification and call to register period ending on the 8th February 2018. Initial notification was given in the following manner.

7.2.2 Registered Letters, Faxes and E-mails Notification letters, faxes and e-mails were distributed to all pre-identified I&APs including affected and adjacent surface landowners, government organisations, NGOs, relevant municipalities, ward councillors and other organisations that might be affected. The notification letters included the following information:  List of anticipated activities to be authorised.  Scale and extent of activities to be authorised.  Sufficient detail of the intended operation (to enable I&APs to assess/surmise what impact the activities will have on them or on the use of their land).  The purpose of the proposed project.  Details of the affected properties (including a locality map).  Details of the MPRDA and NEMA Regulations that must be adhered to.  Date by which any request to register as an I&AP must be forwarded through to Shango Solutions.  Contact details of the EAP.

In addition, a questionnaire was included in the registered letters, e-mails and facsimiles sent which requested the following information from I&APs:  Information on any potential impacts from the proposed project.  Suggestions on potential mitigation measures for the anticipated impacts.  Information on current land uses and their location within the area.  Information on the location of any environmental features of note within and in the vicinity of the study area.  Details of the landowner and information (contact details) of lawful property occupiers, if any.  Details of any other I&APs that should be notified.  Details on any land developments proposed in the near future.  Any specific comments or concerns regarding the application.

7.2.3 Background Information Document (BID) A Background Information Document (BID) was prepared. The BID includes the following information:

 Project name.  Applicant name.

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 Project location.  Map of affected project area.  Description of the application process.  Information on document review.  Relevant Shango Solutions contact person for the project.

7.2.4 Newspaper Advertisement Two newspaper advertisements describing the proposed project and BA process were placed in two local newspapers with adequate circulation in the area. The advertisements were placed in the Isolezwe (in isiZulu) and Mercury (in English) newspapers on the 11th January 2018. The newspaper adverts included the following information:

 Project name.  Applicant name.  Project location.  Nature of the activity.  Relevant Shango Solutions contact person for the project.

7.2.5 Site Notice Placement 12 A2 Correx site notices (in English and isiZulu) were placed along and within the perimeter of the proposed project area on the 11th January 2018. The on-site notices included the following information:  Project name.  Applicant name.  Project location.  Map of proposed project area.  Project description.  Legislative requirements.  Relevant Shango Solutions contact person for the project.

7.2.6 Poster Placement A3 posters (in isiZulu) were placed at 5 local public gathering places (KwaNxamalala Post Office and Police Station, Nkandla Forest Reserve Office notice board and two local shops within the application area). The notices and written notification afforded all pre-identified I&APs the opportunity to register for the project as well as to submit their issues/queries/concerns and indicate the contact details of any other potential I&APs that should be contacted. The contact person at Shango Solutions, contact number, e-mail and fax were clearly stated on the notification. Comments/concerns and queries were encouraged to be submitted in either of the following manners:  Electronically (fax, e-mail).  Telephonically.  Written letters.

7.2.7 Availability of Draft Bar and EMPR Notification The draft BAR and EMPR was made available for public review and comment for a total period of 30 days, from the 27th June 2018 to the 26th July 2018. All registered I&APs were notified of the availability of the draft BAR and

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EMPR and where to locate it. I&APs were informed to provide comment either in writing or telephonically, to Shango Solutions by no later than the 26th July 2018.

Notification regarding the availability of the draft BAR and EMPR was given in the following manner:  Notification letters (in English and IsiZulu), faxes and/or e-mails were distributed to all pre-identified I&APs, I&APs registered during the initial notification period and the BA notification period, as well as affected and adjacent surface landowners.

The draft BAR and EMPR has been placed at the Nkandla Local Municipality for perusal and comment by all I&APs. Furthermore, the report has been uploaded onto the Shango Solutions website for download.

7.2.8 Public Participation Open Days/Meetings During the draft BAR+ EMPR review period, an Open Day was held to present findings of the Basic Assessment. The Open Day took place on the 19th July 2018 at the King Cetshwayo Community Service Centre from 10am to 1:30pm. During the Open Day session, informative A2 posters were displayed on the walls by Shango Solutions (the EAP) prior to the open session. English A4 versions of the Open Day poster as well as IsiZulu versions of the BID were provided to I&APs. The EAP was available during the Public Open Day for one-on-one discussions and questions from the public.

7.3 Issues and Responses The Public Participation Process was initiated on the 8th January 2018. I&APs were given until the 9th February 2018, a period of 30 days, to register for this project. The draft BAR+EMPR was made available from the 27th June 2018 to the 26th July 2018 and I&APs were given an opportunity to comment on the draft BAR+EMPR. All comments or issues received from I&APs during the project registration and draft BAR+EMPR review period have been included in this Basic Assessment Report.

7.3.1 How Issues Raised Were Addressed Comments raised were addressed in a transparent manner and included in the compilation of the BAR+EMPR in the following manner:  Issues raised were used quantitatively to calculate the significance of impacts both real and perceived.  Issues raised were used to provide further suggestions and recommendations with regard to technical management options for impacts.

7.3.2 Summary of Issues Raised by I&APs Table 8 details comments received by Shango Solutions to date and these comments have been included in the Comments and Responses Report (Appendix E) as part of the report submission to the DMR (the competent authority).

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Table 8: Summary of issues raised by I&APs.

I&AP Consulted Date Comment received Response issued comments received

Key Stakeholders

Landowner/s

Ingonyama Trust- X 13 February Dear Sir/Madam, Dear Tashveer Trustees 2018 Your correspondence relating to the above subject Thank you for your correspondence. matter refers. Please could you confirm if a Yes, a notification letter was sent to the Ingonyama Landowner Notification form has been sent to the ITB Trust Board (ITB). Judge Sipho Jerome Ngwenya for completion? If not, why has this not been done and Ms Ellis Suewellan were sent initial landowner and when will it be forthcoming? notification (attached) via e-mail, fax and registered Do you perhaps also have any Title Deed confirming mail. ownership of the land? Was the local traditional Attached herewith, please receive the title deeds for council approached in terms of this project and what the affected two properties. has been their view thereof? COGTA – KwaZulu-Natal was sent notification In order for us to provide feedback accordingly, regarding this project. please could you shed some light on the questions above? Should you have any further questions in this regard, please do not hesitate to contact me.

22 February Good afternoon Mr Siwendu The Prospecting Right acceptance letter issued by 2018 the DMR for this project was forwarded. The KZN We refer to your documents submitted to our office on DMR representatives (Karoon Moodley and Sandile 10 January 2018 and advice accordingly. Njapha) were included in this correspondence and Firstly we are not aware of any application being asked to provide comment regarding this matter. received by Department of Mineral Resources. We

note this is so due to the fact that no compliance has been met in terms of Section 10 in respect of the Mining Resource Act. Until such compliance have been met we will not be giving an consent in respect of Environmental Impact Assessment. In the interest

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of the applicant to make it in so far as compliance with Section 10 we suggest you contact the Department of Mineral Resources.

Lawful Occupier/s

Lindah Mdunge X 31 January Good Afternoon Dear Lindah, 2018 I Mr Lindelani (L.G.S) Mdunge ,a citizen under the Thank you for your correspondence and for showing place called Nkunzana at Nkandla, nearby interest on this project. Nxamalala, my co. ICEBOLEZIZWE (PTY)LTD As requested, you and your company 2016/450183/07, I‟m hereby applying/registering as (ICEBOLEZIZWE (PTY) LTD 2016/450183/07) have interested member in business to work with your been added as Interested and affected Parties to company as a born grew and having co. I want to the project database and you will be kept informed benefit in terms of activities may happen ,my email about the project as it progresses. [email protected],cellno.0720458156/07628 08187,Postal Address P.O Box 18,Kwa Nxamalala Shango Solutions will not be involved in the 3825 appointment of any service providers for this project. However, your correspondence will be forwarded to the Applicant (WRE Base Metals (Pty) Ltd), for their consideration.

Moses Shezi X 03 February Good day Zizo, Dear Mr Shezi, 2018 I trust you are well. I am interested in the above. Both Thank you for your mail and for showing interest on as a member of the Chube (Zimbidla) community and this project. a business person. You have been added as an Interested and Affected I am interested on the details of this project. Party (I&AP) for this project will be kept informed about the project as it progresses. Attached herewith, kindly receive the initial project notification. Should you have any further questions in this

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regard, please do not hesitate to contact me.

Moses Shezi X 10 July 2018 Good day, This correspondence is acknowledged. Thank you for you update. We shall look at it.

Zintle Ngema X 11 January Requesting information about vacancies Shango Solutions informed Ms. Zintle Ngema that 2018 they will not be involved in the appointment of any service providers for this project. However, her request will be forwarded to the Applicant (WRE Base Metals (Pty) Ltd), for their consideration.

Adjacent Landowners

Ezemvelo KZN Wildlife X 29 January Good morning Ms Zizo Siwendu, Good day, 2018 Ezemvelo‟s IEM Planning division has been informed Thank you for your correspondence. that WRE Base Metals have submitted a prospecting As requested, a hardcopy of the application for the right application, to the Department of Mineral proposed project will be couriered to Ezemvelo KZN Resources. Given that the proposed application area Wildlife‟s IEM planning division, using the is adjacent to one of our Protected Areas (Nkandla information provided. Forest), we would appreciate it if you could forward a hardcopy of the proposed application to our offices, for review and comment.

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Hi Zizo. 20 February Dear Dominic, 2018 (01:16 I have chatted with some of my colleagues about this PM) application, and some common concerns were Thank you very much for your response. shared. At this stage of the process, I think it would be Would it be possible to arrange for a meeting out on preferable from my side for you to undertake the site site, in order for Ezemvelo‟s District Ecologist and visit, and provide me with feedback. myself to familiarize ourselves with the proposal on

site, and inform Ezemvelo‟s response to the DMR for We have initiated the Public Participation Process. this application? The Biodiversity specialist appointed for this project Kindly revert with some available dates, unless it will undertake the assessment in March. The would be preferable from your side for us to visit the Biodiversity study will be included in the Basic site and then feedback to you through the official Assessment Report, which will be made available to comment framework? I&APs upon completion in May, for public review. An Open Day will be scheduled during the Basic

Assessment Report review period, to present the

findings of the Basic Assessment. An invitation to

attend the Open Day will be extended to KZN

Ezemvelo Wildlife. Should you wish to meet with the project team (including the project Biodiversity specialist) during this period, kindly inform me so we can schedule the meeting.

20 February Hi Zizo. Dear Dominic, 2018 (2:04 PM) Great, I will liaise with my staff then to undertake the Thank you very much for the handbook. I will site visit, and provide you with feedback. definitely forward it to the appointed Biodiversity Specialist. I thought it might be helpful for you to take a look at the attached which we put together a couple of years back (we are hoping to update it this coming financial year with some additional information regarding

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recently developed CBA areas etc) with assisting EAPs in the province with undertaking specialist studies for EIA specialist studies in terms of a suggested terms of reference for said studies. It may be useful for you, given that we are quite a diverse province in terms of biodiversity.

I trust it will be of some assistance. It did receive a favourable response from EAPs and the various competent authorities alike here.

Ezemvelo KZN Wildlife X 27 June 2018 Good morning Mmakoena, Dear Nerissa,

Thank you for your email notification. Please note Your request is noted. that an application is processed and attended to, once the hardcopies of the relevant documentation A hardcopy of the Basic Assessment Report and are received by our offices. Please find outlined Environmental Management Programme will be below the courier/delivery details: couriered to your offices in due course.

Postal: P O Box 13053 Cascades 3202

Courier: Queen Elizabeth Park 1 Peter Brown Drive Montrose 3201

Please feel free to contact this office should you require anything further.

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Ezemvelo KZN Wildlife X 27 June 2018 Dear Ms Nerissa Pillay, RE: FINAL BASIC ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT FOR THE NKUNZANA PROSPECTING RIGHT PROJECT (KZN 30/5/1/1/2/10722 PR)

As requested please find attached a hardcopy of the Final Basic Assessment Report and Environmental Management Programme for the Nkunzana Prospecting Right Project (KZN 30/5/1/1/2/10722 PR). Should you have any comments or queries or require any additional information in this regard please do not hesitate to contact the undersigned.

09 July 2018 Ezemvelo KZN Wildlife X Dominic Wieners from Ezemvelo KZN Wildlife Dear Dominic, telephoned and requested an electronic copy of the Thank you for your phone call. Ecological and Wetland Specialist Report for the Nkunzana Prospecting Right project. As requested, please find herewith attached the Ecological and Wetland Specialist Report for the Nkunzana Prospecting Right Project. If you have any questions in this regard, please do not hesitate to contact me. May you have a wonderful day further.

Local Municipality – Nkandla Local Municipality

Executive Mayor (A.T. X No comment received to date. Ntuli)

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Municipal Manager (N. X No comment received to date. Jili)

Speaker (SO Sibiya) X No comment received to date.

Ward 11 Councillor X No comment received to date. (Thokozana Ntombela)

Ward 14 Councillor (B.S. X 20 January Thank you I have received it. This email was acknowledged. Mbambo) 2018

District Municipality – King Cetshwayo District Municipality

Municipal Manager X No comment received to date. (Charmaine Rheeders)

Traditional Leaders

Chief Vusimuzi X No comment received to date. Nxamalala

Chief Vincent Magwaza X No comment received to date.

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Chief Bhekisabelo Shezi X 31 January The representative of the chief (Mr B. Shezi) Mr B. Shezi was informed that a meeting will be 2018 requested a meeting with the project team. scheduled during the Basic Assessment Report public review period in order to present the findings of the Basic Assessment.

All registered I&APs including Chief Bhekisabelo Shezi will be notified of the meeting and will be invited to attend.

Organs of State

National Department of X No comment received to date. Mineral Resources

National Department of X 10 January Dear Sir / Madam Dear Vela, Rural Development and 2018 I acknowledge receipt of your correspondence. I will Your e-mail is acknowledged, thank you. Land Reform forward it to my colleagues in Pietermaritzburg for their attention.

National Department of X 30 January Good day Dear Lesley, Agriculture, Forestry and 2018 Kindly send us the title deed, locality map and power Thank you for your correspondence. Fisheries of attorney to finalise your application. Please find herewith attached title deeds of the two affected properties by this project, as well the project locality map. May you kindly advise what kind of power of attorney you are requesting, so I may be able to assist?

01 February Power of attorney must be submitted to the Dear Lesley, 2018 Department (if applying on behalf of farm owner)

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I&AP Consulted Date Comment received Response issued comments received

Power of attorney is a written document in which the Thank you for your mail. farm owner appoints another person to act as an The Applicant is not the landowner. The Applicant is agent on his or her behalf, thus conferring authority a company called WRE Base Metals (Pty) Ltd. The on the agent to perform certain acts or functions on Prospecting Right and Environmental Authorisation behalf the farm owner. application area is located on land that is owned by the Ingonyama Trust, as per title deeds provided to you.

Department of Rural X 01 February Good day Dear Lynn, Development and Land 2018 Please find attached letter in response to your Your correspondence is acknowledged, thank you. Reform enquiry. Dear Sir/Madam REQUEST FOR INFORMATION PROPERTY: LAND CLAIM We acknowledge receipt of your enquiry received on 23 January 2018 and advise that our records indicate that no claim for restitution in terms of the Restitution of Land Rights Act, 22 of 1994 (as amended) has been lodged in respect of the property described as the farm Reserve No. 19 No. 15839.

Whilst great care is taken to verify the accuracy of the information regarding all claims, the Regional Land Claims Commission will not be held responsible for any damage or loss suffered as a result of information furnished in this regard as there are claims lodged with the Commission which are not yet captured in our database as they are not yet published in the relevant government gazette.

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I&AP Consulted Date Comment received Response issued comments received

South African National X 20 February Dear Sir/Madam This correspondence was noted. Roads Agency Ltd 2018 PROPOSED APPLICATION FOR A PROSPECTING (SANRAL)-Provincial RIGHT AND ENVIRONMENTAL AUTHORISATION ON THE FARM RESERVE NO. 19 15839 GU WITHIN THE NKANDLA LOCAL MUNICIPALITY The application referred to this office for comment on 8 January 2018 refers. Please note that the SA National Roads Agency SOC Ltd (SANRAL) is not affected by the above mentioned application and it may be dealt with without further reference to this office.

South African National X 27 June 2018 Dear Mmakoena, Dear Stacey, Roads Agency Ltd (8:15 AM) Our letter dated 19 April 2018, addressed to Zizo As requested please find herewith attached a (SANRAL)-Provincial Siwendu refers. Kindly provide us with a locality map locality map and KMZ file of the project area. in relation to the National Road in order for SANRAL If you have any further requests or questions in this to confirm the impact of affect. regard, please do not hesitate to contact the undersigned.

South African National X 27 June 2018 Dear Mmakoena, This correspondence is noted. Roads Agency Ltd (11:08 AM) Thanks for providing the locality. SANRAL hereby (SANRAL)-Provincial confirm that the National Road Network is not affected by this BAR and EMP – you may therefore proceed without further reference to this office. A formal letter in this regard will be provided before the week ends.

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KwaZulu-Natal X No comment received to date. Department of Agriculture and Rural Development

KwaZulu-Natal X No comment received to date. Department of Transport and Roads

KwaZulu-Natal X No comment received to date. Department of Cooperative Governance, Traditional Affairs and Human Settlements

KwaZulu-Natal X No comment received to date. Department of Economic Development, Tourism, Environmental Affairs and Small Business

KwaZulu-Natal X No comment received to date. Department of Public Works

KwaZulu-Natal X No comment received to date. Department of Water and Sanitation

KwaZulu-Natal X No comment received to date. Department of Agriculture, Forestry and

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Fisheries

X KwaZulu-Natal No comment received to date. Department of Mineral Resources

X National Development No comment received to date. Agency

X Catchment Management No comment received to date. Agency

X The Council for Scientific 10 January Dear colleague, I‟m currently out of office. Kindly This email was acknowledged and the documents and Industrial Research 2018 contact Dr Mark Gush for an queries at: 021-888- were forwarded to the relevant party. (CSIR) 2659 (w) or 082-748-8820 (mobile); email:[email protected]

Eskom SOC Limited X No comment received to date.

Transnet SOC Limited X 18 January Dear Zizo, Dear Willie, 2018 The office has no objection to the proposed Thank for your correspondence and for providing application for Prospecting rights near Nkandla, the comment. Prospecting rights did not affect Transnet land and is Your comment that Transnet has no objection to the approximate 13,4 km South of Transnet land in proposed project as the project does not affect Nkandla. Transnet property is well noted.

Telkom SA Limited X No comment received to date.

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I&AP Consulted Date Comment received Response issued comments received

Other Affected Parties

Council for Geo-sciences X No comment received to date.

Wildlife and Environment X No comment received to date. Society of South Africa (WESSA)

KZN Conservancies X No comment received to date.

Amafa KZN Heritage X 15 January Amafa requested payment fee before they can Payment would be made upon completion of the 2018 comment on the project Heritage Impact Assessment and submission of the study to Amafa. Payment was made and the Section 30 NID Form was completed and sent to Amafa KZN Heritage. Kindly refer to Appendix E for proof of submission.

Federation for a X No comment received to date. Sustainable Development

Birdlife South Africa X 10 January Simon Gear left Birdlife South Africa‟s employ on 10 This correspondence was acknowledged and the 2018 April 2017. Messages send to this address will not be documents were forwarded to the relevant party. auto-forwarded, please send emails to either [email protected] or [email protected]

Endangered Wildlife X No comment received to date. Trust

Registered Interested and Affected Parties

John Phipson X 11 January Good Afternoon Grace Dear John,

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I&AP Consulted Date Comment received Response issued comments received

2018 As discussed this morning, I transmit herewith a short Thank you very much for your call and the email form CV and an indication of the range of projects with your CV and project experience documents. I that I am competent to engage in. have forwarded your information to the Nkunzana project team. It is always beneficial to have as much My most recent mining assessment was an detailed knowledge of the site and environment as agricultural impact desktop study for a prospecting possible. licence for a 6 000 ha site in the Free State, undertaken during December. I live in Mthunzini, I trust we will be in contact in the future with regards about halfway between Richards Bay and Nkandla. to Nkunzana. I am thoroughly familiar with the soils, topography and Thank you once again. vegetation of the proposed site as I travel through the Xamalala Traditional Authority area several times a year. I am also familiar with the history of the Nkandla area, dating back to the times of King Shaka. As I am semi-retired my rates are reasonable and my availability usually good. I am fully fluent and literate in isiZulu Please feel free to contact me, should my services be of interest to yourselves

Ann McDonnell X 11 January Dear sir Dear Ann, 2018 Please register me as IAP for this prospecting EIA. Thank you for your correspondence and for your interest in the WRE Nkunzana Prospecting Right ANN MCDONNELL project. 0605602939 As requested, you have been registered as an [email protected] Interested and Affected Party for this project and will be kept informed of the Basic Assessment process My interest is that I am the DA constituency head of as it progresses. the King Ceteswayo District under which this area falls. Should you have any further questions in this regard, please do not hesitate to contact me.

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Ann McDonnell X 26 June 2018 Dear sir Dear Ann, (12:29 PM) Many thanks for the notification of the availability of Thank you for your mail. the BA and notice of public meetings. We have no knowledge of the location of the blue I am not sure I will be able to attend, so please would butterfly sanctuary and breeding ground. May you you advise me of the location of the blue butterfly kindly advise why you ask? sanctuary and breeding ground. The owner of the Nkunzana Prospecting Right I would also like to know who the owner of the land is application area is the Ingonyama Trust-Trustees. - Ingoynama Trust or private. If you have any further questions, please do not hesitate to contact me. Dear Ann, Further to the e-mail below, a thesis on the blue butterfly written by Sheng-Shang Lu (Lu, S., 2002. Biology and conservation of the threatened Karkloof blue butterfly Orachrysops ariadne (Butler) (Lepidoptera: Lycaenidae). University of Natal) formed part of the comprehensive desktop study that was conducted for the ecological and wetland assessment (attached). However, field work assessment focused mainly on the following:

 Mammals species expected to occur in the Project area  Floral species expected to occur in the Project area  Avifaunal species expected to occur in the Project area  Amphibian and reptiles species expected to occur in the Project area

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I&AP Consulted Date Comment received Response issued comments received

Although the Karkloof blue butterflies and invertebrates were considered in the desktop study, only invertebrates were identified within the application area during the field survey. According to the ecological and wetland assessment, the following was mentioned regarding the Karkloof blue butterfly (found within the Nkandla Forest Complex that is adjacent to the Nkunzana Prospecting Right application area): “The forest has very high species diversity and is home to more than 150 different bird species, as well as a large number of rare plant species (Bennet & Kruger, 2015). It is also one of the few places in South Africa where the threatened and endemic Karkloof blue butterfly, Orachrysops ariadne can be found (Lu, 2002).” Furthermore, the EMPR proposes mitigation measures for threatened and endangered species that may be found within the application area during invasive prospecting activities. If you have any further questions, please do not hesitate to contact me.

Ann McDonnell X 26 June 2018 Dear Mmakoena This correspondence is acknowledged. (2:52 PM) The blue butterfly is found on a tribal authority's land in Nkandla and is very rare so worthy of protection. I will try and get some co-ordinates from Ezemvelo KZN Wildlife. As a member of the Environmental Affairs portfolio in the KZN Legislature, the mining industry is of interest

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to the Province.

Craig Burne X 17 January Apologies Mr Siwendu Dear Craig, 2018 I mistakenly wrote Mr Njapha below, but I see he is Thank you for your correspondence and for your (10:01 AM) the DMR contact. interest on this project. Dear Mr Njapha The application is made in terms of both the MPRDA and NEMA. Prospecting for minerals is In terms of the public notice in the Mercury, dated administered under the MPRDA. Prospecting is also Thursday 11th January 2018 with the a listed activity (Activity 20 of GN R. 983) under the abovementioned project details, please can you NEMA and therefore, triggers an application for register me as an I&AP. Environmental Authorisation. As such, an My interest in the project is to better understand the application for a Prospecting Right under the details of a project of this nature and how the MPRDA and an application for Environmental application process for environmental authorisation Authorisation under NEMA are required. The will proceed in terms of both NEMA and the MPRDA. process that is followed for Prospecting is the NEMA Basic Assessment. If there are any public meetings relating to this Basic Assessment, please let me know when and where A Public Meeting/Open Day will be scheduled in due these are scheduled to take place. course to present the findings of the Basic Assessment. You have been registered as an Please also inform me when the applicable reports & Interested and Affected Party (I&AP) for this project. documentation (e.g. BID, draft BAR and any specialist As a registered I&AP, you will be notified about the studies) relating to the project become available and details of the upcoming Public Meeting/Open Day. where electronic copies can be obtained/downloaded to review. The Background Information Document and a I&AP registration form are obtainable from the Shango Would Shango Solutions be able to email these Solutions website (http://www.shango.co.za/public- documents? documents/). The Basic Assessment Report, As an I&AP, I would need to review and understand including specialist studies will also be made these documents before being able to make any available on the Shango Solution website in due comments or ask any questions - if I were to have any course and registered I&APs will be notified of its at all. availability.

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I&AP Consulted Date Comment received Response issued comments received

As requested, please receive herewith attached notification that was sent out to pre-identified I&APs. If you have any further questions in this regard, please do not hesitate to contact me.

Craig Burne X 17 January Thanks Zizo Shango Solutions thanked Mr Craig Burne for the 2018 completed and signed registration form. Please see attached the signed registration form. (01:03 PM) Mr Craig Burne stated that he does not have specific concerns, comments or objections at this stage. He may provide any general comments either at any public meetings, and/or after reviewing the application (Draft BAR and specialist studies).

Michaeal Bhengu X 7 February My name is Michael Bhengu I wish to register as Dear Michael, 2018 I&AP for this project [WRE Nkunzana Prospecting Thank you for your mail and for showing interest on Right] and please notify me for further notice and this project. opportunities for involvement in this process. As requested, you have been registered as an I am very sorry for not using prospecting form for I got Interested and Affected Party (I&AP) for this project. it late as nearly to the closing date for posting it. I am Your contact information will be captured in the looking foward to hearing from your respond through project database. As a registered IAP, you will be this e mail address and my number 064 9603328. kept informed about the project as it progresses.

The Public Participation Process will continue throughout all the project phases. You are welcome to submit your comments during the course of the Basic Assessment process.

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7.3.3 Minutes from Heritage Public Participation Meeting A public meeting was held on the 13th April 2018 and community members were given the platform to raise their concerns and provide comment on the Nkunzana Prospecting Right project. During the public meeting, Zetu from NGT Holdings compiled meeting minutes, and the critical and social issues that were raised are highlighted in Table 9.

Table 9: Minutes of the Heritage Public Participation Meeting.

MINUTES OF THE HERITAGE PUBLIC PARTICIPATION MEETING

Project Nkunzana Prospecting Right

Meeting Venue Nkunzana Project Application Area, Nkandla, KwaZulu- Natal Province

Date 13 April 2018

Language Minutes have been transcribed from Zulu to English

MEETING ATTENDEES

Nkosinathi Tomose (NGT Holdings)

Zetu Damane (NGT Holdings)

Mr Shezi (Community member and Chief)

Community members (approximately 30)

DISCUSSIONS

Question Response

Mr. Shezi, a chief in the area, opened the meeting The NGT Holdings specialist briefly explained the role by introducing the NGT Holdings team to members of Environmental Impact Assessments (EIA) and the of the community. role of Heritage Impact Assessments (HIA) within the broader EIA process. The specialist further outlined

the specific purpose of the visit from an HIA perspective which is mainly to survey for tangible and intangible heritage resources that might be impacted by the proposed prospecting activities for mineral resources.

Mr. Shezi wanted to understand at what distance a The NGT Holdings specialist explained that the hypothetical grave would need to be in relation to distance for this project was not yet finalised. the proposed prospecting areas for it to be However, a buffer of 10 to 20 meters from the considered “affected”. He also wanted to affected grave is often established. The specialist understand what would happen should a grave be further explained that should the affected graves not considered „affected‟. be mitigated in terms of a buffer, they are relocated in a respectful and culturally appropriate manner.

Permits are applied with relevant authorities and once permits have been received then the exhumation process starts. He also explained that the financial implications of relocation are borne by the developer/project proponent.

A community member enquired as to how families The NGT Holdings specialist explained that families are compensated for the space where graves lie. could not be compensated for graves as the law prohibits anyone from placing monetary value on a

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grave; he again stressed that all costs of relocation or fencing would be borne by the developer/project proponent.

Another community member wanted to understand NGT Holdings specialist briefly explained the principals the potential impacts on affected households and of a Social Impact Assessment (SIA) and Relocation how they would be compensated should mining Action Plan (RAP) in cases where the development activities start and the whole area becomes a mine. encroach and affect households. He also briefly explained the public participation and social

consultation process as part of the SIA and RAP. He explained that the issue of compensation for relocated households falls under the auspices of the social impact assessment which he is not part of but give clarification based on past projects. He further explained that once the SIA, consultations and RAP are been carried out; negotiated settlements are then reached between affected families/households and the developer for those households that need to be relocated.

A community member explained the importance of The NGT Holdings specialist explained that there are Nkunzana River to the daily lives of the community. laws that govern and regulate mining activity so that Indeed; as we spent two days in close proximity to they can have minimal impact on the receiving the river; the specialists observed cars and clothes environment; for example, the National Environmental being washed, livestock being fed, children playing Management Act, which sets norms and standards for and women collecting water from this critical river. the protection and conservation of environment and He explained that in the past mining prospecting communities. He explained that companies must activity had polluted river and affected communities adhere to these laws or risk losing their mining downstream. He wanted to know what precautions licenses. He explained that since the promulgation of would be put in place to ensure the water is not these laws; developers are now very careful and act contaminated during the current prospecting activities responsibly towards communities and the environment. as it had been in the past.

A community member asked about how the The NGT Holdings specialist explained that the community may benefit from the project. He gave a question is outside his scope as a heritage specialist hypothetical example of a community member with a and will be best addressed by the lead CK document and trucks. He wanted to know if there environmentalist employed by the developer who is in would be opportunities for sub-contracting for such charge of community issues. He did however explain community members. the role of community trusts and how they exist to uplift community members should the project proceed to

mining stages.

A community member wanted to understand how The NGT Holdings specialist explained that this falls indirect impacts such as trucks that might traverse under the auspices of the SIA and would be addressed and damage their properties, grazing and plough by that SIA specialist who will be appointed on the fields would be addressed. He also wanted to project once the project reaches mining rights understand the possible impact of fences that might application. restrict their access to areas within their community.

A community member felt it would be beneficial to the The NGT Holdings specialist agreed that this is a good community if the specialists came as a full multi- suggestion that will be discussed with the lead disciplinary team for a comprehensive meeting so environmentalist and project proponent should the that all their queries would be addressed. project proceed to mining rights application.

They also requested that meetings should be set up well ahead of time so that community members who are out of town can be informed and are able to make

Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR arrangements to attend the meetings.

Finally a community member recounted the story of This comment was noted. the neighbouring Nqutu Community where a mining development caused tensions between the chieftaincy and the community. Essentially, the community members were paid for land; he felt that community members cannot be paid for land as the land belongs to the King. He wanted to ensure that the Ngonyama Trust was properly informed and an integral part of the process for Nkunzana mine.

KEY SOCIAL ISSUES

The below lists the key social issues that emerged out of the engagement with community members. The list is by no means extensive or exhaustive.

Community Upliftment This is a key issue that comes up in every poor community in which we have conducted social impact assessments in the past. Expectations for “intuthuko” (upliftment) and “ibhodo eliconsayo” economic improvement” are very high amongst community members. These expectations need to be managed very carefully as they are often the root cause for tensions between developers and communities as projects progress. For example, on the Eskom Medupi project, we found community members tended to be unskilled; which necessitated bringing in external Labour that agitated local community workers. We also found that the definition of a „local‟ was not clearly defined and many migrant unskilled labourers from outside the local community and indeed from various provinces; further created tensions. The SIA will need to design ways to ensure that local community members who tend to be unskilled are able to derive real benefit from the project should it proceed to mining stages.

Damage to Key Social Resources The damage to key social resources such as the river needs to prevented and mitigated against. Other key social resources that could be impacted need to be identified and clear a plan to protect these resources needs to be designed.

Gender Issues There were several women who were part of the meeting; but none spoke. The perspective of women in these communities is critical; but in meetings with men, patriarchy and traditional gender roles might prevent them from talking. This will deprive the public participation process from potentially valuable insights. Should the project proceed to mining stages, we recommend that mechanisms that allow for women to have their own meetings should be devised so that they can speak freely without any constraints.

Urbanisation The lack of job opportunities in rural areas means that the majority of economically active and able community members typically migrate to the city in search of employment. The old women are often alone with grandchildren; receiving remittances from the young who work in the cities. This dynamic often means that decision makers are often away and come home on weekends or long weekends such as Easter. Public Participation needs to take this into account and develop a system to allow the decision makers time to travel to meetings and make use of mobile telephone to communicate with migrant community members.

Change in Patterns of Life and Sense of Place Communities highlighted indirect impacts that might change their patterns of life and sense of place. Trucks being a regular feature in their environments and fences which restrict their access to key areas were highlighted. Mining activity typically changes the face and structure of a community dramatically, typically urbanising and invigorating sleepy rural towns. While this might bring positive changes from jobs, to employment to economic boom, it also comes with urban challenges such as prostitution, immigration and puts pressure on local infrastructure to provide for population booms. Through a comprehensive social impact assessment several other socio-cultural change processes and impacts will be identified mitigated against or leveraged.

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Social Impact of Relocation and a Relocation Action Plan The social impacts of relocation for affected households needs to be investigated and mitigated against should the project proceed to mining stages. The compensation structure needs to consider the social circumstances of the communities. For example, we conducted a SIA for a project within a rural community within KwaZulu-Natal for Eskom and the African Development Bank - very similar to the Nkandla community. The Project required the relocation of approximately 160 households. Our research showed that the International Financial Corporations warns that cash compensation may not be adequate for land based assets or economically displaced persons whose livelihoods are land-based. Short-term consumption of cash compensation can result in hardship for subsistence-based economies or poorer households. 70% of the households within the study were worried about losing some kind of land based assets such as gardens and fruit trees. Poor numeracy and financial skills within communities with very low education levels also make cash compensation challenging. The community was replete with the infirm; women and old are at a particular disadvantage in terms of their competency to build themselves new homes. The social issues in that community strongly cautioned against cash based compensation.

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Figure 7: Miss Zetu Damane with some of the community members that received the NGT team on site and had a meeting with (source: NGT, 2018).

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8. ENVIRONMENTAL ATTRIBUTES AND ASSOCIATED ALTERNATIVES

8.1 The Baseline Receiving Environment This section describes the baseline receiving environment of the prospecting area. Information in this section is based on desktop studies by the EAP, a site visit, input from the public through the I&AP questionnaire and specialist studies undertaken in support of this application. As such, the descriptions below of environmental features represent a consolidation of relevant information to the application area.

8.1.1 Socio-Economic

The application area is situated in the northern KwaZulu-Natal (KZN) Province of South Africa, approximately 92 km west of Richards Bay. It can be found in Wards 11 and 14 of the Nkandla Local Municipality which forms part of the King Cetshwayo District Municipality (Figure 8).

Figure 8: The affected local municipality and wards (Refer to Appendix D for an enlarged map).

The municipality is 1 828 km2 in aerial extent and has a population of 114 416 (Statistics SA: Census 2011). According to the Nkandla Local Municipality Integrated Development Plan (IDP) 2017/2018, the Nkandla Local Municipality remains one of the poorest local municipalities within the King Cetshwayo District Municipality. The dominating economic activities in Nkandla are subsistence agriculture, which is practised on communal land and trading of livestock. The majority of people in Nkandla rely solely on government social grants for survival. As such, there is a great deal of movement of people to other areas of the district and the province as a whole in search of employment opportunities.

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80% of the land in Nkandla is held by the Traditional Authority while the remaining 20% of the land is held under trust farms. According to the KZN Spatial Economic Development Strategy, (2008/9), Nkandla is one of the local municipalities which contain wards which constitute the 50 most deprived areas in the province.

The municipality is faced with a number of development challenges which are caused by various factors, most of which cannot be addressed by the municipality alone but require intervention from other role players and stakeholders including government departments and the private sector (Nkandla Local Municipality IDP, 2015/16). Central to the development dilemma, the municipality also faces a challenge to provide basic services to the communities of Nkandla. This is due to the fact that the municipality does not have sufficient revenue and funding to cater for the demand of service delivery. In addition, the natural topography of the municipality is undulating, making investments in infrastructure a costly process.

8.1.2 Geology The rocks in the application area are predominantly those of the Mesoproterozoic Natal Metamorphic Province (NMP). These rocks have been thrust northwards over the older Kaapvaal Craton. The NMP contains a nappe and thrust belt, the Natal Nappe Zone (NNZ) and the Natal Thrust Front (NTF). The rocks of the NTF (the Mfongosi Group) have been subjected to high pressure greenschist facies metamorphism during the northwards thrusting of the NMP to form amphibolite schists. The NNZ Khomo Formation (Tugela Group) are deeper rocks thrust on top of the Mfongosi Group with higher temperature and pressure amphibolite facies metamorphism. The Tugela Group was also intruded by granites (including the Halumbu Granite) during these higher temperature conditions. The distribution of these rocks in the application area is shown in Figure 9.

Figure 9: Distribution of rock-types within the application area (Refer to Appendix D for an enlarged map).

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Gold mineralisation is present both in the greenschist facies of the Natal Thrust Front (NTF) and the amphibolite facies of the Natal Nappe Zone (NNZ). The majority of the occurrences are however concentrated within NTF. The historical gold mine is located within the Mfongosi Group rocks of the NTF. Extensive quartz veining is visible in the Khomo Formation amphibolites of the NNZ (Figure 10). The abundant vein quartz veins may be mineralised in certain places.

Figure 10: Quartz veining visible in fresh and weathered rocks of the Khomo Formation of the NNZ.

8.1.3 Topography The topography of the application area is rugged and characterised by hills and steeply incised valleys varying in altitude between 900 and 1 400 metres above mean sea level (MAMSL) (IDP, 2016/17).

8.1.4 Climate The climate of the application area is characterised by summer rainfall (November – March) with a mean annual precipitation (MAP) of 500 mm. The area experiences temperatures in excess of 30°C during the summer months.

8.1.5 Air Quality The Nkandla municipal area is characterised by good air quality as there are no factories and/or light industries in the area.

8.1.6 Land Type and Soils

The dominant lithologies encountered in the project area are serpentinite, metagabbro, amphibolite and granite gneiss of the Tugela Complex. According to the land type database (Land Type Survey Staff, 1972 - 2006), the project falls within the Fa108 land type. This land type is dominated by the mid-slope landscape unit with steep slopes in excess of 20%. The dominant soils in the mid-slope positions are expected to be shallow Mispah and Glenrosa soil forms, with some Hutton and Shortlands in places. The Valley bottom wetlands are expected to be dominated by Dundee, Katspruit, and Oakleaf soil forms.

8.1.7 Land Uses and Land Capability The land in the application area is predominantly utilised for subsistence farming. Other land uses surrounding the project area consist mainly of rural land with associated houses and livestock as well as infrastructure such

Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR as secondary tar roads and gravel roads. The application area is covered by indigenous forest, thicket or dense bush, woodland or open bush, an urban village, grassland as well as plantations (Figure 11).

Figure 11: Land cover within and around the application area (Refer to Appendix D for an enlarged map).

8.1.8 Heritage and Palaeontological Assessment A heritage Impact Assessment (inclusive of a Palaeontology study) was undertaken over the application area. Please refer to Appendix F1 for the Heritage Specialist Report. The survey was conducted on foot and a vehicle was utilised to gain access to (i) the farm properties within the application area and (ii) the locations of the proposed unpaved access road, drillholes and trenches for Site Alternative 1.

According to a review (NGT, 2018); the first Khoi herders and Nguni-speaking agro-pastoralists immigrated from northern Africa to southern Africa during the Late Stone Age period. These groups had contact with the Later Stone Age people who were already residing in the area, thus resulting in them migrating to the Kalahari Desert or being assimilated into the Nguni speaking cultural groups. The arrival of the Nguni speaking farming communities in southern Africa from western Africa during the first half of the 1st millennium AD marks the end of the Stone Age (Badenhorst, 2010).

The Early Iron Age is characterised by the arrival of farming communities who domesticated animals, produced various ceramic vessels and smelted iron for weapons and tools. These Early Iron Age farming communities originated from the Great Lake region of East Africa where Urewe ceramics are the earliest form of the Chifumbaze complex (Mitchell, 2002; Phillipson, 1994). The Iron Age farmers began to migrate around the second century AD, resulting in a spread which is known today as the Nkope branch of the Urewe tradition, which spread through a wide area extending southward towards Tanzania, Mozambique, Malawi, eastern Zambia and Zimbabwe into the northern parts of South Africa, Swaziland and KwaZulu-Natal. The Later Iron Age communities in KwaZulu-Natal are the direct ancestors of the present-day Zulu people.

During the early 1800‟s, the Zulu people were ruled by Senzangakhona (Ommer-Cooper, 1993). His son Shaka was born in 1787 and established the Zulu Kingdom in the early 1800‟s (Greaves, 2013). During the historical

Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR period, the KwaZulu-Natal region was often left in turmoil as a result of wars and conflict between the different cultural groups that settled in the area.

In 1879, the British invaded Zululand which resulted in the Anglo-Zulu War, with the Zulus being defeated at Ulundi. King Cetshwayo was captured by the British in the Ngome Forest and Zululand was divided into 13 districts. During the 1883 Civil War, King Cetshwayo stayed at the Sigananda Shezi residence near the Nkandla Forest. He died in 1884 and his grave is located within the application area, west of the proposed prospecting activities.

The proposed application area is situated in a rich cultural landscape in terms of the historic period. There are several cultural and heritage sites located within the application area. The fact that the King Cetshwayo grave is situated in within the area may raise alarms to both AMAFA KwaZulu-Natal and the Royal House.

8.1.8.1 Heritage Study The foot survey that was undertaken within the ridge where the proposed six drillholes and trenches are located established that no archaeological and built environment heritage resources occur where the proposed drillholes and trenches are located for Site Alternative 1 The survey identified a total of five cemeteries and one possible cemetery within the application area (Figure 12). The five cemeteries, including the possible cemetery, have been allocated the following Unique Site Reference Numbers (USRN) and are described in Table 10:  Nku-Cem 01.  Nku-Cem 02  Nku-Cem 03.  Nku-Cem 04 (possible cemetery site).  Nku-Cem 05.  Nku-Cem 06 (King Cetshwayo Grave).

Figure 12: Culture and heritage sites identified within the application area (Refer to Appendix D for an enlarged map).

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Table 10: Cemeteries identified within the application area (source: NGT, 2018). Site Name Description Type Approximate Age Co-ordinates Image

The cemetery belongs to the Shezi family and it contains three graves all in soil mound with no grave markers. Nku-Cem 01 Burial ground and grave site Less than 10 years 28°45'18.00"S 31° 5'30.10"E Image not found It is situated on the south-western slope of the affected ridge for the proposed prospecting activities.

The cemetery is covered in thick vegetation and it belongs to the Dilamuka Khumalo family. It contains nine graves which are all in soil Nku-Cem 02 Burial ground and grave site Less than 60 years 28°45'14.90"S 31° 5'30.80"E mound. It is situated on the south-western slope of the ridge proposed for prospecting activities.

The Mkhwanzi family cemetery is situated on the crest of the affected ridge and contains two graves with an east-west orientation. The Nku-Cem 03 Burial ground and grave site Less than 60 years 28°45'12.20"S 31° 5'56.80"E cemetery is situated approximately 41 m from the access road to the ridge as well as borehole number 4 and 37 m from trench number 4.

The site is known to have been settled by the Nzuza family who relocated to a new settlement site over 10 years ago. The team of locals who accompanied the NGT team on the survey confirmed that the Nzuza family indeed buried in the area are uncertain about the Less than 60 years (based on Possible Burial Ground and Nku-Cem 04 exact location of the burial grounds. As such, the area has known time of the Nzuza 28°45'15.50"S 31° 6'4.10"E Grave Site beenmarked as a potential burial site. It is covered in the same family settlement of the area) vegetation that covered the Shezi and Khumalo family graves. This possible cemetery site is situated 18.3 m from borehole number 5 and 10.6 m from the proposed access road

The Shezi family cemetery contains eight graves which have soil mounds and are covered in vegetation. It is situated on the northern slope of another ridge where the proposed access road is located. Of Nku-Cem 05 Burial ground and grave site Less than 60 years 28°45'30.20"S 31° 6'19.40"E all the cemeteries identified on-site, this cemetery is at high risk as the proposed access road is located within a metre away from the cemetery.

The grave of King Cetshwayo is fenced off from the surrounding and has a granite dressing with two slabs of granite cover (Figure 11 and Older than 60 years (134 Nku-Cem 06 Figure 12). It is situated west of the proposed prospecting ridge across Burial ground and grave site 28°45'27.54"S 31° 4'47.92"E years) the Nkunzana River. This grave falls outside of the current prospecting area and will not be directly impacted by prospecting activities.

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As previously stated, the locations of the proposed trenches and drillholes for Site Alternative 1 were assessed during the foot survey. Below are images (Figures 13 and 14) that were taken at some of the proposed drillhole and trench locations.

Figure 13: Area proposed for drilling (source: Figure 14: Area proposed for test trench (source: NGT, 2018). NGT, 2018).

8.1.8.2 Heritage sensitivity The five cemeteries, including the possible cemetery identified within the application area are considered as high sensitive heritage features (Figure 15). Based on the Heritage Impact Assessment, the only cemetery that is at high risk from invasive prospecting activities is Nku-Cem 05 as it is located within a metre from the proposed unpaved access road. However, the unpaved access road has subsequently been moved and Nku-Cem 05 now lies 35 m from the proposed unpaved access road. The remaining cemeteries will not be impacted by the proposed prospecting activities as they are located a distance away from the proposed trenches, drillholes and unpaved access road. Nku-Cem 03 is situated 42 m from the proposed unpaved access road and drillhole 4, and 37 m from trench 4. Nku-Cem 04 is located 18.23 m from drillhole 5, and 10.6 m from the proposed unpaved access road. The unpaved access road has subsequently been moved and Nku-Cem 04 now lies 36 m from the proposed unpaved access road. Nku-Cem 01 and Nku-Cem 02 are located on the south-western slope of the affected ridge and away from the proposed activities. Nku-cem 06 (King Cetshwayo grave) is located approximately 1.5 km west of the proposed prospecting activities and will not be directly impacted by prospecting.

Figure 15: Culture and heritage sensitivity map (Refer to Appendix D for an enlarged map).

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8.1.8.3 Palaeontological Impact Study and Sensitivity The surface geology of the project area consists of rocks of the Namaqua-Natal Metamorphic Complex. These rocks are not known to contain palaeontological fossils. Therefore, there is no need to conduct any other palaeontological studies or have a monitoring programme to rescue palaeontological resources during invasive prospecting. According to the Palaeontological Sensitivity Map developed by the South African Heritage Resources Agency, the area is classified as non-sensitive (Figure 16).

Figure 16: Map depicting the sensitivity of the underlying geology in relation to the occurrence of fossils (Refer to Appendix D for an enlarged map).

Notice of the application for a Prospecting Right and Environmental Authorisation has been uploaded on the AMAFA KZN website. AMAFA requested a payment fee before they can comment on the project. Payment was made upon completion of the Heritage Impact Assessment and submission of the study to AMAFA. No comment has been received to date. Kindly refer to Appendix E for proof of submission.

8.1.9 Wetland Assessment A Wetland Assessment (Appendix F2) was undertaken by The Biodiversity Company. The assessment focused on the infrastructure location points and the 500 m assessment boundary requirement. Below is a summary of the specialist findings.

Surface Hydrology The application area falls within the Pongola-Mtamvuna Water Management Area (Figure 17), which includes rivers such as the Pongola, Mhlatuze, Mfolozi, Mkuze, Thukela, Mvoti, Umgeni, Umkomazi, Umzimkulu and Mtamvuna rivers.

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Figure 17: Water Management Areas of central, eastern and northern South Africa (Refer to Appendix D for an enlarged map).

The Pongola-Mtamvuna Water Management area comprises 21 tertiary catchment areas, and the application area is specifically situated in the V40D Quaternary Catchment (Figure 18).

Figure 18: Quaternary Catchment Areas of the study and surroundings (Refer to Appendix D for an enlarged map).

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One Freshwater Ecosystem Priority Area (FEPA) river occurs within and around the project area, namely the Nsuze River. In addition, various non-perennial streams occur within the application area which ultimately feed into the Nsuze River (Figure 19).

Figure 19: Image depicting the wetlands and other drainage lines recorded in the study area (Refer to Appendix D for an enlarged map).

One wetland type was identified within the application area, namely the channelled valley bottom (HGM 1) (Figure 20). The wetland drains from the edge of the project area towards the west. The channelled valley bottom is narrow, with slight damming occurring at the low-level crossings on the existing roads outside the project area. The slopes in the project area are steep with the dominant hydrological process being runoff.

Figure 20: Channelled valley bottom features the wetland on-site A) Valley bottom topography, B) Defined channel with bank overflow features, and C) Riparian vegetation with channel area (source: The Biodiversity Company, 2018).

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Wetland Vegetation and Soils The wetland vegetation is generally poor in the application area with only small areas of Setaria spp. established (Figure 21A). Two dominant soil forms were encountered in the establishment of the wetland boundaries in the study area. These are the Dundee and Katspruit soil forms (Figure 22B).

Figure 21: Identified wetland indicators: A) Setaria spp. and B) Katspruit soil form (source: The Biodiversity Company, 2018).

Wetland Delineation and Buffer Zone The wetland areas were delineated in accordance with the DWAF (2005) guidelines. The outer edges of the wetland areas were identified by considering four indicators, namely the (i) Terrain Unit Indicator, (ii) Soil Form Indicator, (iii) Soil Wetness Indicator, and (iv) Vegetation Indicator. A map presented where the proposed six drillhole sites, trenches and unpaved access road are currently positioned (Figure 22) in relation to the delineated wetlands.

Figure 22: Delineated wetlands relative to the proposed positions of the six drillholes and trenches (Refer to Appendix D for an enlarged map). 64

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A 500 m Water Use Licence Application (WULA) buffer from the boundary of the wetlands was delineated and mapped (Figure 23). According to Section 21 of the National Water Act, 1998 (Act 36 of 1998), any activity occurring within a watercourse, within the 1:100 flood-line of any watercourse and/or within 500 m of the boundary of any wetland is required to be registered and licenced. As such, a General Authorisation for water use in terms of Section 39 of the NWA, 1998 (Act 36 of 1998) is required in this regard.

Figure 23: 500 m WULA buffer in relation to the proposed six drillholes and trenches (Refer to Appendix D for an enlarged map).

Present Ecological Status (PES) The Present Ecological Status (PES) score was determined by quantifying the impacts of human activity or clearly visible impacts on the wetland health, and then converting the impact scores to a PES score. The PES for the assessed wetland is presented in Table 11. The overall wetland health was determined to be Moderately Modified (C).

Table 11: Summary of the wetland PES. Hydrology Geomorphology Vegetation Wetland Rating Score Rating Score Rating Score

C: Moderately C: Moderately D: Largely HGM 1 3.5 2.1 4.7 Modified Modified Modified

Overall PES Score 3.4 Overall PES Class C: Moderately Modified

A summary for the respective modules is as follows:

 The hydrological component for the wetland was rated as Moderately Modified (Class C) and has been altered by the development of roads and houses on the upper catchment. The slopes are steep with large erosion gullies already present.

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 The geomorphology component for the wetlands assessed was Moderately Modified (Class C) with the hydrological impacts altering the rating. Erosion is a significant risk for the wetland as result of steep slopes.  The vegetation component for wetlands was rated as Largely Modified (Class D) due to decreased vegetation cover on the slopes, erosion, and sedimentation within the wetlands. There is also encroachment of alien vegetation into the wetland areas.

The erosion impacts are presented in Figure 24.

Figure 24: The erosional impacts within the landscape (Refer to Appendix D for an enlarged map).

Ecological Importance and Sensitivity (EIS) The EIS assessment was applied to the wetland in order to assess the levels of sensitivity and ecological importance of the wetland. The results of the assessment are shown in Table 12. The Ecological Importance and Sensitivity of the area was rated as High (Class B), the ecological findings show the sensitivity within this area. The Hydrological Importance was rated as Moderate (Class C). The Human Importance was rated as Low (Class D). Figure 25 below shows the wetland sensitivity in relation to the proposed drillholes and trenches.

Figure 25: Wetland sensitivity in relation to the proposed six drillhole sites and trenches (Refer to Appendix D for an enlarged map).

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Table 12: The EIS results for the identified wetland. Wetland Importance and Sensitivity

HGM 1 Importance Ecological Importance & Sensitivity 3.0 Hydrological/Functional Importance 1.7 Direct Human Benefits 0.5

Ecosystem Services Assessment The Ecosystem services provided by the wetland identified within the project area was assessed and rated using the WET-EcoServices method (Kotze et al., 2009). The summarised results for the wetland are shown in Table 13, with the direct, indirect benefits being summarised in Table 14.

The wetland showed an overall Intermediate level of service with flood attenuation, sediment control, and biodiversity maintenance showing moderately high levels of service. The indirect benefits related to water quality enhancement was rate as Intermediate with the direct benefits related to the community being rated as Moderately Low. The maintenance of biodiversity is rated as moderately high as this area is in a protected area and the valley bottom areas provide cover for animals.

Table 13: The EcoServices being provided by the wetland unit. Wetland Unit HGM 1 2.3

Flood attenuation

Streamflow regulation 1.2

Sediment trapping 2.2

Wetlands Phosphate assimilation 1.5 Nitrate assimilation 1.1

benefits Toxicant assimilation 1.5

Regulatingand

Water Quality enhancement

IndirectBenefits Erosion control 2.0 supportingbenefits Carbon storage 1.7

Biodiversity maintenance 2.1

Provisioning of water for human use 1.7

Provisioning of harvestable resources 1.2

ning ning benefits Provisio Provisioning of cultivated foods 1.2 Cultural heritage 1.0

DirectBenefits Tourism and recreation 1.7

Ecosystem Services Supplied by Supplied EcosystemServices Cultural benefits Education and research 0.3 Overall 22.6 Average 1.5

Table 14: The direct and indirect benefits provided by the wetland unit. Direct & Indirect Benefits Summary HGM 1

Indirect Benefits 1.7

Direct Benefits 1.2 Biodiversity Maintenance 2.1

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8.1.10 Biodiversity Assessment Biodiversity refers to the variety of different species in a region and the variety of ecosystems and functions such as energy flow and matter cycling needed for the survival of those species (Miller and Spoolman, 2012). Conservation could be defined as the practical application of ecology and refers to the mechanisms and tools needed to achieve conservation goals, such as the protection of biodiversity.

The Biodiversity specialist study (Appendix F2) was undertaken by The Biodiversity Company. The biodiversity assessment was conducted on a desktop level and the field survey, during which the floral and faunal communities within the prospecting footprint, within the project area, were assessed, was conducted on the 6th, 9th, 10th and 11th May 2018.

The biodiversity study discussed the following components:

 Vegetation Assessment.  Faunal Assessment.  Ecosystem Threat Status and Protection Level.  Critical Biodiversity Areas and Habitat Sensitivity.

8.1.10.1 Desktop Assessment

Vegetation Assessment According to Mucina and Rutherford (2006) and Ezemvelo KwaZulu-Natal Wildlife (2013), the project area is situated across several different vegetation types, namely (i) Moist Coast Hinterland Grassland (Gs20) (which constitutes the majority of the area) listed as Vulnerable, (ii) Eastern Valley Bushveld (SVs 6) listed as Least Threatened, (iii) Scarp Forest (FOz 5) listed as Least Threatened and (iv) Midlands Mistbelt Grassland (Gs9) listed as Endangered (Figure 26).

Figure 26: Vegetation of the project area (Refer to Appendix D for an enlarged map).

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Moist Coast Hinterland Grassland Mucina and Rutherford (2006) describe the properties of Moist Coast Hinterland Grassland and Dry Coast Hinterland Grassland under a combined single vegetation type, SVs 4 – Ngongoni Veld, Ezemvelo KZN Wildlife have refined the description and separated it into the two further vegetation types, one being Moist Coast Hinterland Grassland.

Moist Coast Hinterland Grassland, which is the most dominant vegetation type within the project area, can be found in the KwaZulu-Natal and Eastern Cape Provinces at an altitude of 450 – 900 MAMSL. This vegetation type typically occurs across rolling and hilly landscapes and is a dense, tall grassland that is overwhelmingly dominated by unpalatable, wiry Ngongoni grass (Aristida junciformis), with this monodominance, associated with low species diversity. Termitaria support bush clumps with Vachellia/Senegalia species, Cussonia spicata, Ziziphus mucronata, Coddia rudis and Ehretia rigida (Mucina & Rutherford, 2006).

Important plant taxa are those species that have a high abundance, a frequent occurrence or are prominent in the landscape within a particular vegetation type (Mucina and Rutherford, 2006).

The following species are important in the Moist Coast Hinterland Grassland vegetation type:

 Small Trees: Vachellia natalitia, V. nilotica, V. sieberiana var. woodii.  Low Shrubs: Agathisanthemum bojeri, Euryops laxus, Gnidia anthylloides.  Graminoids: Aristida junciformis subsp. junciformis, Bothriochloa insculpta, Eragrostis curvula, Hyparrhenia hirta, Panicum maximum, Paspalum scrobiculatum, Sporobolus africanus, S. pyramidalis, Themeda triandra.  Herbs: Chamaecrista mimosoides, Conostomium natalense, Gerbera ambigua, Helichrysum allioides, Hermannia grandistipula, Pentanisia prunelloides, Selago tarachodes, Senecio exuberans, Vernonia galpinii.  Geophytic Herbs: Hypoxis argentea, Watsonia densiflora.  Succulent Herb: Aloe minima.

Moist Coast Hinterland Grassland is considered Vulnerable. Of the National Conservation Target of 25%, less than 1% of the unit is statutorily conserved in the Ophathe and Vernon Crookes Nature Reserves. Approximately 39% of the vegetation unit has been transformed for cultivation, plantations and urban development.

Eastern Valley Bushveld Eastern Valley Bushveld is described by Mucina and Rutherford (2006) as being semi deciduous savanna woodlands with pockets of thickets in a mosaic pattern, often succulent and dominated by Euphorbia and Aloes. It can be found in KwaZulu-Natal and the Eastern Cape Provinces. Deeply incised river valleys run through this vegetation.

The following species are important in the Eastern Valley Bushveld vegetation type:  Tall Trees: Acacia robusta, Sclerocarya birreasubsp. caffra.  Small Trees: Acacia natalitia, A. nilotica, Combretum molle, Spirostachys africana, Acacia tortilis subsp. heteracantha, Berchemia zeyheri, Boscia albitrunca, Brachylaena elliptica, Cussonia spicata, Dombeya rotundifolia, Encephalartos natalensis, E. villosus, Hippobromus pauciflorus, Schotia brachypetala, Ziziphus mucronata.  Succulent Trees: Euphorbia tirucalli, Aloe marlothii subsp. marlothii, A. rupestris, Euphorbia ingens, E. triangularis.

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 Tall Shrubs: Dichrostachyscinerea, Calpurnia aurea, Coddia rudis, Ehretia rigida subsp. rigida, Euclea crispa subsp. crispa, Grewia occidentalis, Olea europaea subsp. africana.  Succulent Shrubs: Aloe arborescens, Euphorbia grandicornis, Kleinia fulgens.  Soft Shrubs: Hypoestes aristata, Peristrophe cernua.  Woody Climber: Acacia brevispica subsp. dregeana. Herbaceous Climber: Ischnolepis natalensis.  Graminoids: Aristida congesta, Eragrostis curvula, Hyparrhenia hirta, Melinis repens, Panicum maximum, Themeda triandra, Cymbopogon pospischilii, Eragrostis superba, Heteropogon contortus, Panicum deustum, Sporobolus fimbriatus, S. pyramidalis, Tristachya leucothrix, Urochloa mosambicensis.  Herbs: Achyranthes aspera,Hibiscus pedunculatus.  Geophytic Herb: Sansevieria hyacinthoides.

Eastern Valley Bushveld currently retains the conservation status of being Least Threatened. Of the National Conservation Target of 25%, only 0.8% is statutorily conserved. This vegetation unit is underlain by the sediments of the Karoo Supergroup with the mudstones and sandstones of the Adelaide and Tarkstad subgrous (Beaufort Group) as well as Ecca Group shale.

Scarp Forest Scarp Forest is located within the Forest Biome and it is described by Mucina and Rutherford (2006) as a tall (15 – 25 m), species-rich and structurally diverse, multi-layered forest, with well-developed canopy and under storey tree layers, but a poorly developed herb layer. Buttressed stems are common in the Scarp Forest. It can be found in the Eastern Cape, KwaZulu-Natal and Mpumalanga Provinces (and possibly also in Mozambique) at low altitudes of between 50 and 600 MAMSL.

The following species are important in the Scarp Forest vegetation type:

 Tall Trees: Buxus natalensis, Drypetes gerrardii, Englerophytum natalense, Harpephyllum caffrum, Heywoodia lucens, Rothmannia globosa, Commiphora harveyi, C. woodii, Drypetes arguta, Manilkara discolor, Nectaropetalum capense, Nuxia congesta, Olinia emarginata, Ptaeroxylon obliquum, Pterocelastrus tricuspidatus, Vitellariopsis marginata.  Small Trees: Buxus macowanii, Rinorea angustifolia, Dombeya cymosa, Encephalartos natalensis, E. villosus, Ochna natalitia, Strychnos henningsii, S.mitis.  Herbaceous Climbers: Flagellaria guineensis, Thunbergia alata. Tall Shrubs: Memecylon natalense, Eugenia natalitia.  Low Shrub: Stangeria eriopus.  Soft Shrub: Piper capense.  Herbs: Begonia dregei, B. homonyma, Streptocarpus grandis, S. johannis.  Geophytic Herb: Clivia miniata.

Scarp Forest currently has the conservation status of being Least Threatened. Of the 40% National Conservation Target, more than 20% is statutorily conserved. Almost 5% of this vegetation unit has been transformed for cultivation or plantations. Collapse of traditional authorities in both Eastern Cape (especially in Transkei) and in KwaZulu-Natal has led to uncontrolled use of forests formerly protected under the authority of headmen and chiefs. Bark stripping, muthi collection, deadwood extraction, and land-claims may become other major sources of threat to the existence of some forest patches.

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Midlands Mistbelt Grassland Midlands Mistbelt Grassland is characterised by a hilly and rolling landscape mainly associated with a discontinuous east-facing scarp formed by dolerite intrusions and can be found in the KwaZulu-Natal and Eastern Cape Provinces (Mucina and Rutherford, 2006).

The following species are important in the Midlands Mistbelt Grassland vegetation type:

 Graminoids: Andropogon appendiculatus, Aristida junciformis subsp. galpinii, Diheteropogon filifolius, Eragrostis plana, Hyparrhenia hirta, Sporobolus africanus, Themeda triandra, Tristachya leucothrix, Alloteropsis semialata subsp. eckloniana, Andropogon schirensis, Brachiaria serrata, Cymbopogon caesius, C. nardus, Digitaria diagonalis, D. tricholaenoides, Diheteropogon amplectens, Elionurus muticus, Eragrostis capensis, E. curvula, E. racemosa, Eulalia villosa, Harpochloa falx, Heteropogon contortus, Loudetia simplex, Microchloa caffra, Monocymbium ceresiiforme, Panicum aequinerve, P. ecklonii, P. natalense, Paspalum dilatatum, P. scrobiculatum, P. urvillei, Setaria nigrirostris, S. sphacelata, Sporobolus centrifugus, Trachypogon spicatus.  Herbs: Acalypha glandulifolia, Acanthospermum australe, Berkheya rhapontica subsp. aristosa, B. setifera, Commelina africana, Conyza pinnata, riosema salignum, Helichrysum cephaloideum, H. simillimum, Indigastrum fastigiatum, Kohautia amatymbica, Nidorella auriculata, Pentanisia prunelloides subsp. latifolia, Sebaea sedoides var. schoenlandii, Spermacoce natalensis, Thunbergia atriplicifolia, Vernonia dregeana, V. natalensis, Wahlenbergia undulata.  Herbaceous Climber: Vigna nervosa. Geophytic  Herbs: Pteridium aquilinum, Corycium nigrescens, Drimia macrocentra, Eriospermum ornithogaloides, Gladiolus ecklonii, Habenaria dives, H. dregeana, Hypoxis multiceps, H. rigidula var. pilosissima, Rhodohypoxis baurii var. baurii, R. baurii var. platypetala, Satyrium longicauda.  Low Shrubs: Helichrysum sutherlandii, Leonotis ocymifolia, Otholobium caffrum.

Midlands Mistbelt Grassland currently has the conservation status of being Endangered (Mucina and Rutherford, 2006). Of the National Conservation Target of 23%, only a fraction (0.5%) is statutorily conserved in a number of reserves such as Ngeli, Impendle, Blinkwater, Qudeni, Doreen Clark, Karkloof and Queen Elizabeth Park. More than half of this vegetation unit has been transformed for plantations, cultivated land or by urban sprawl. Uncontrolled fires and poorly regulated grazing by livestock add to threats to this unique grassland.

Plant Species of Conservation Concern Based on the Plants of Southern Africa (BODATSA-POSA, 2016) database, 775 plant species are expected to occur in the project area. Of the 775 plant species, ten (10) species are listed as being Species of Conservation Concern (SCC) (Table 15).

Table 15: Plant Species of Conservation Concern (SCC) expected to occur in the project area (BODATSA- POSA, 2016). Family Taxon IUCN status Likelihood of Occurrence

Apocynaceae Pachycarpus rostratus CR Moderate Apocynaceae Schizoglossum ingomense EN Moderate Asteraceae Helichrysum pannosum EN Moderate Asteraceae Senecio ngoyanus VU Moderate Apocynaceae Brachystelma christianeae VU Moderate Asteraceae Cineraria atriplicifolia VU Moderate

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Rubiaceae Alberta magna NT Moderate

Apocynaceae Brachystelma modestum NT Moderate Asphodelaceae Aloe dominella NT Moderate Gasteria batesiana var. Asphodelaceae NT Moderate batesiana

IUCN conservation Status:

 CR: Critically Endangered.  EN: Endangered.  VU: Vulnerable.  NT: Near Threatened.

Faunal Assessment The Faunal desktop assessment included compilation of expected species and identified species as well as identification of any Red Data or species of conservation concern (SCC) present or potentially occurring in the area. The characteristics of the site and the prominent features surrounding it play a key role in whether an animal would theoretically inhabit the study area. Ecosystems present in the study area showed the potential to host a number of reptile, mammal, amphibian and bird species of conservation concern, most of which are regarded as sensitive. Table 16 summarises the diversity of fauna that is expected to occur in the study area.

Table 16: Animal groups considered in this study along with the total species possibly occurring in or near the study area and how many of these species are species of conservation concern. Animal Group Total Species Species of Conservation Concern Avifauna 269 17 Mammals 99 15 Reptiles 43 4 Amphibians 41 3

Avifauna Based on the South African Bird Atlas Project, Version 2 (SABAP2) database, 269 bird species are expected to occur in the vicinity of the project area (pentads 2840_3100; 2840_3105; 2840_3110, 2845_3100, 2845_3105, 2845_3110, 2850_3100, 2850_3105, 2850_3110). Of the expected bird species, seventeen (17) species are listed as species of conservation concern on a regional scale.

The species of conservation concern include the following:

 Seven (7) species that are listed as Endangered (EN) on a regional basis.  Six (6) species that are listed as Vulnerable (VU) on a regional basis.  Two (2) species that are listed as Near Threatened (NT) on a regional basis.

Important Bird Areas Important Bird Areas (IBAs) are sites of international significance for the conservation of the world's birds and other conservation significant species as identified by BirdLife International. These sites are also all Key Biodiversity Areas; sites that contribute significantly to the global persistence of biodiversity (Birdlife, 2017).

According to BirdLife International (2017), the selection of Important Bird and Biodiversity Areas (IBAs) is achieved through the application of quantitative ornithological criteria, grounded in up-to-date knowledge of the sizes and trends of bird populations. The criteria ensure that the sites selected as IBAs have true significance for 72

Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR the international conservation of bird populations and provide a common currency that all IBAs adhere to, thus creating consistency among, and enabling comparability between, sites at national, continental and global levels.

No IBAs occur within, or adjacent to, the proposed project area. The closest IBA is the Entumeni Nature Reserve which is situated approximately 42 km south-east of the project area (Figure 25).

Figure 27: The project area in relation to defined IBAs (Refer to Appendix D for an enlarged map).

Mammals The IUCN Red List Spatial Data (IUCN, 2018) lists 99 mammal species that could be expected to occur within the project area. Of these species, 3 are medium to large conservation dependant species, such Ceratotherium simum (Southern White Rhinoceros) and Equus quagga (Plains Zebra) that, in South Africa, are generally restricted to protected areas such as game reserves. These species are not expected to occur in the project area and are removed from the expected SCC list.

Of the remaining 96 small to medium sized mammal species, fifteen (15) are listed as being of conservation concern on a regional or global basis:

The list of potential species includes:  One (1) that is listed as Endangered (EN) on a regional basis.  Six (6) that are listed as Vulnerable (VU) on a regional basis.  Eight (8) that are listed as Near Threatened (NT) on a regional scale.

Herpetofauna (Reptiles and Amphibians) Based on the IUCN Red List Spatial Data (IUCN, 2017) and the Reptile Map database provided by the Animal Demography Unit (ADU, 2017), 43 reptile species are expected to occur in the project area. Four (4) reptile species of conservation concern are expected to be present in the project area.

There are recent records for two of these threatened reptile species (Bradypodion thamnobates and Bradypodion nemorale) occurring in, or adjacent to, the project area and both species have a high likelihood of occurrence.

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Bradypodion nemorale occurs only in the Nkandla forest and the nearby Qudeni Forest, making this area one of the last strongholds for this species. Chamaesaura macrolepis is a species of grass lizard that prefers higher altitude open grasslands and ridges. This species has a high likelihood of occurrence within the project area.

Pelusios rhodesianus (Variable Hinged Terrapin) has not been recorded on this section of the Nsuze River and prefers open pans and coastal sands, and therefore has a low likelihood of occurrence.

Based on the IUCN Red List Spatial Data (IUCN, 2017) and the Amphibian Map database provided by the Animal Demography Unit (ADU, 2018) 41 amphibian species are expected to occur in the project area.

Three (3) amphibian species of conservation concern could be present in the project area. There are recent records for all three species occurring within, or adjacent to, the project area and therefore all three species have a high likelihood of occurrence.

8.1.10.2 Field Survey

Vegetation Assessment The vegetation assessment was conducted throughout the extent of the project prospecting footprint and the following areas were identified based on the results of the fieldwork (Figure 26):

„Riparian‟ area: The „Riparian‟ area (green area in Figure 26) is characterised by the presence of a perennial river with associated pristine natural woodland. There is minor disturbance to this vegetation area due to the presence of cattle, but the impact is minimal at this stage. The overall state of the area is mainly undisturbed. The function of the area is still considered intact and critical as it is defined in the biodiversity sector plan. If left undisturbed it will continue to function as an important habitat for various faunal and floral forest species including multiple species of conservation concern.

„Mountain Grassland‟ area: The „Mountain Grassland‟ area (brown area in Figure 26) comprises of the expected dominant grass species, namely Aristida junciformis subsp. junciformis, which is known to dominate this vegetation type, along with trees such as Vachellia sieberiana var. woodii and Sclerocarya birrea subsp. caffra. The ecological state of the area is primary, although somewhat disturbed by cattle. Ground cover and phytomass are extensive resulting in almost pristine habitat for fauna.

„Altered‟ Area: The „Altered‟ areas (purple area in Figure 28) have been transformed, mainly due to anthropogenic impacts. Roads, homesteads, livestock and informal settlements associated with human presence have had a negative effect on the ecological state of the area. Weeds such as Lantana camara, Bidens pilosa, Cirsium vulgare and Tagetes minuta occurred on the site and are most likely to dominate areas of bare soil, most of the alien invader plants occurred within this area. Even though the area has been altered, it is minimal compared to the overall size of the area and corridors and natural patches still occur which fauna will utilise.

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Figure 28: The various vegetation areas identified during the field work (Refer to Appendix D for an enlarged map).

A total of 55 tree, shrub and herbaceous plant species were recorded in the project area during the field assessment.

Protected Tree One (1) protected tree species was recorded in the project area, namely Sclerocarya birrea subsp. caffra (Marula Tree). This tree species is protected by law and if any of the planned development, or any other future development, may infringe on the abovementioned Act, an application for a permit of removal or translocation will be necessary. Four (4) individual trees, and several saplings, from the list of protected species were observed. It is expected that more individuals of this species occur within the proposed prospecting area.

Alien and Invasive Plants Declared weeds and invader plant species have the tendency to dominate or replace the canopy or herbaceous layer of natural ecosystems, thereby transforming the structure, composition and function of these systems. Therefore, it is important that these plants are controlled and eradicated by means of an eradication and monitoring programme. Some invader plants may also degrade ecosystems through superior competitive capabilities to exclude native plant species.

Eight (8) Category 1b invasive plant species were recorded within the project area and must therefore be removed by implementing an alien invasive plant management programme in compliance with section 75 of the National Environmental Management: Biodiversity Act, 2004 (Act 10 of 2004) (NEMBA).

Below is a brief explanation of Category 1b invasive species in terms of the NEMBA, 2004 (Act 10 of 2004):

 Category 1b: Invasive species requiring compulsory control as part of an invasive species control programme. Remove and destroy. These plants are deemed to have such a high invasive potential that

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infestations can qualify to be placed under a government sponsored invasive species management programme. No permits will be issued.

Faunal Assessment The field survey component of the faunal assessment utilised a variety of sampling techniques including, but not limited to, visual observations, identification of tracks and signs as well as utilisation of local knowledge. Table 17 below summarises the diversity of fauna that was identified in the project area during the field survey.

Table 17: Animal groups identified in the project area during the field survey. Animal Group Total Species Species of Conservation Concern Avifauna 63 3 Mammals 8 0 Reptiles 4 0 Amphibians 6 0

Avifauna Sixty-three (63) bird species were recorded in the project area during the field survey based on either direct observations, vocalisations, or the presence of visual tracks & signs.

Three avifaunal (bird) Species of Conservation Concern (SCC) were recorded during the survey, namely African Crowned Eagle, Spotted Ground-thrush and Martial Eagle, and based on the presence of pristine, suitable habitat, and the nearby Nkandla forest, there is a high probability that many other bird SCC occur within the project area.

Mammals Overall, mammal diversity in the project area was moderate, with eight (8) mammal species being recorded during the field survey based on direct observations, camera trap photographs and/or the presence of visual tracks & signs.

Herpetofauna (Reptiles & Amphibians) Herpetofauna diversity was considered to be high with four (4) reptile species and six (6) amphibian species being observed or recorded in the project area during the field survey.

Invertebrates Although not part of the original scope of work, a number of invertebrates were encountered during the field survey. The invertebrates were encountered at random whilst surveying for reptile and amphibian species.

Ecosystem Threat Status Ecosystem threat status outlines the degree to which ecosystems are still intact or alternatively losing vital aspects of their structure, function and composition, on which their ability to provide ecosystem services ultimately depends (Driver at al., 2012).

Ecosystem types are categorised as Critically Endangered (CR), Endangered (EN), Vulnerable (VU) or Least Threatened (LT), based on the proportion of each ecosystem type that remains in good ecological condition (Driver at al., 2012).

The proposed project was superimposed on the terrestrial ecosystem threat status (Figure 29). As seen in Figure 27, the project area falls across two ecosystems, which are listed as Vulnerable (VU) and Least Threatened (LT), the former making up the majority of the project area.

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Figure 29: The project area showing the ecosystem threat status of the associated terrestrial ecosystems (Refer to Appendix D for an enlarged map).

Ecosystem Protection Level Ecosystem protection level tells us whether ecosystems are adequately protected or under-protected. Ecosystem types are categorised as not protected, poorly protected, moderately protected or well protected, based on the proportion of each ecosystem type that occurs within a protected area recognised in the Protected Areas Act (Driver at al., 2012).

The project area was superimposed on the ecosystem protection level map to assess the protection status of terrestrial ecosystems associated with the development (Figure 30). Based on Figure 30, the terrestrial ecosystems associated with the proposed project area are rated mainly as not protected, with a small area in the project area rated as either moderately protected or poorly protected.

Figure 30: The project area showing the level of protection of terrestrial ecosystems (Refer to Appendix D for an enlarged map). 77

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Critical Biodiversity Areas The KwaZulu-Natal (KZN) Biodiversity Sector Plan (BSP) provides a spatial representation of land and coastal marine areas required to ensure the persistence and conservation of biodiversity and biodiversity targets within KZN, reflected as Critical Biodiversity Areas (CBA) and Ecological Support Areas (ESA).

A CBA is considered a significant and ecologically sensitive area and needs to be kept in a pristine or near- natural state to ensure the continued functioning of ecosystems. A CBA represents the best choice for achieving biodiversity targets. ESAs are not essential for achieving targets, but they play a vital role in the continued functioning of ecosystems.

Based on this assessment it can be concluded that the proposed prospecting activities are likely to impact on: CBA: Irreplaceable (or CBA1), CBA Optimal (or CBA2) as well as being situated in very close proximity to a protected area (Figure 31). The intended prospecting footprint, including the unpaved access road, falls entirely within an area defined as a CBA: Irreplaceable.

According to the conservation plan, „local corridors‟ have also been identified to ensure uninhibited movement of wildlife between landscapes and important biodiversity areas (including PAs, CBAs and stewardship sites). Based on the spatial file for the KZN C-Plan it can be concluded that the proposed development will not impact on a „local corridor‟.

Figure 31: The project area superimposed on the KZN Biodiversity Sector Plan (Refer to Appendix D for an enlarged map).

Habitat Sensitivity As per the terms of reference for the project, a GIS sensitivity map is required in order to identify sensitive features in terms of the relevant specialist discipline/s within the project area, especially in reference to the defined prospecting footprint and unpaved access road. The sensitivity scores identified during the field survey for each habitat were then visually mapped.

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Areas that were classified as having low or moderate sensitivities are those areas which were deemed by the specialists to have been most impacted upon and/or were modified from their original condition due to factors such as over-grazing, human activity and/or presence of alien invasive species.

The areas given a very high sensitivity rating are those areas with existing natural vegetation. These areas are classified as a functional CBA or areas that have the capacity to serve as habitat or important corridors for various species (especially potential SCC).

For this project, the southern portions of the project area, although altered, were given a moderate-high sensitivity rating due to the important role this area functions as from an ecological point (corridor and an ESA).

8.1.11 Project Area in Relation to Protected Areas Figure 32 shows the location of formally protected areas in relation to the project area. Formally protected areas refer to areas protected either by national or provincial legislation. Based on the SANBI (2010) Protected Areas Map and the National Protected Areas Expansion Strategy (NPAES) the project area overlaps with a formally protected area, namely a portion of the Mome Nature Reserve (which forms part of the Nkandla Forest Complex) (Figure 32). Furthermore, the northern boundary of the project area is situated directly adjacent to the Nkandla Forest Reserve. The Dhlabe Nature Reserve also intersects with the north-western portion of the project area. Based on the above information and the location of the proposed development, the project is likely to have an impact on various formally protected areas.

Figure 32: The project area in relation to the formally protected areas (Refer to Appendix D for an enlarged map).

8.2 Environmental Aspects Which May Require Protection and/or Remediation There are features on site that may require protection. Environmental aspects, both within the application and surrounding area, which may require protection or remediation, are listed in Table 18. These aspects have been identified and are based on the information contained in the description of the baseline receiving environment as

Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR well as the impact assessment. These environmental aspects that may require protection or remediation have been included in the action plan and technical management measures contained in this report.

Table 18: List of potential impacts per activity.

Aspect Feature

Topography Surface drainage lines

Ground water resources Ground water Ground water quality and quantity

Surface water resources (such as streams and pans)

Surface water Surface water quality and quantity

Wetlands and pans

Species of concern (flora and fauna)

Biodiversity Primary vegetation units

Wetlands and pans

Stockpiled soils Soils Soils of moderate to high agricultural potential

Livestock grazing

Land-use Cultivation

Homesteads

Agricultural potential Land capability Grazing potential

Air quality Ambient air quality

Noise Ambient noise levels

Social Livelihoods

Economic Employment

Heritage resources (cemeteries, graves, structures older than

Heritage and cultural 60 years)

Paleontological features

8.3 Description of Specific Environmental Features and Infrastructure On-Site Drainage lines, wetlands, rivers and streams, homesteads, roads, cemeteries, water reservoirs, Eskom servitudes, telephone lines, bridges, a communication tower and various buildings occur within the proposed prospecting area. These features have been verified and updated during the Public Participation Process. They

Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR should be avoided during invasive prospecting and where avoidance is not possible, impacts must be appropriately managed and remedied.

9. IMPACTS AND RISKS IDENTIFIED

Impacts and risks were identified based on the proposed prospecting activities to take place on-site. Table 19 lists the potential impacts related to each of the significant activities related to the prospecting operation.

Table 19: List of potential impacts per activity.

Aspect Potential Impacts

Planning and Preparation Safety and security risks to landowners and lawful occupiers Social Interference with existing land uses

Construction and Operation: Excavation of 6 trenches, 6 diamond core drillholes, establishment of a unpaved access road Interference with existing land uses Sense of place Safety and security risks to landowners and lawful occupiers Perceptions and expectations

Social Expropriation of land and displacement of landowners Job creation Discovery of economically viable minerals Training of unskilled labourers Disturbance/damage/destruction of homesteads (Imizi) Disturbance/damage/destruction of heritage sensitive areas Heritage Disturbance/damage/destruction of the King Cetshwayo Grave Loss and fragmentation of the vegetation community Clearance of vegetation Displacement of faunal community (including threatened or protected species) due to habitat loss, disturbance and/or direct mortalities Degradation and/or destruction of wetland habitats

Ecology and wetlands Continued encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive species Continued displacement and fragmentation of the faunal community (including threatened or protected species) due to on-going anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching) Introduction of alien invasive species

Surface and groundwater Contamination of surface and groundwater Soil compaction Soils Soil pollution/contamination

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Aspect Potential Impacts Increased runoff and sedimentation

Environmental Spillage of oils, fuels and chemicals Air quality Fugitive dust emissions Noise Noise

Decommissioning Soil compaction Soils Soil pollution/contamination

Erosion and sedimentation

Surface and groundwater Contamination of surface and groundwater Environmental pollution Spillage of oils, fuels and chemicals Air quality Fugitive dust emissions from decommissioning activities Social Job creation Noise Noise Disturbance/damage/destruction of heritage sensitive areas Heritage Disturbance/damage/destruction of the King Cetshwayo Grave Continued encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive plant species

Ecology and wetlands Continued displacement of the faunal community (including threatened or protected species) due to on-going anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching)

Rehabilitation and Closure Soil instability

Soils Increased runoff and sedimentation Soil pollution/contamination

Encroachment and displacement of an indigenous and

vulnerable vegetation community by alien invasive species,

potential re-establishment of natural species that were

removed, the nature of the erosion will depend on the amount

of successful vegetation establishment Ecology Displacement of the faunal community (including threatened or protected species) due to rehabilitation of the anthropogenic disturbances and habitat degradation, rehab resulting in the faunal species potentially re-establishing within the area Environmental pollution Generation and disposal of waste Heritage Disturbance/damage/destruction of heritage sensitive areas Disturbance/damage/destruction of the King Cetshwayo Grave

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Each of the identified risks and impacts for these phases was assessed utilising the assessment methodology described in section 9.1. The assessment criteria include the nature, extent, duration, magnitude/intensity, reversibility, probability, public response, cumulative impact and irreplaceable loss of resources. The full scoring of each impact is provided in the impact assessment table provided in Appendix G.

A summary of the impacts and their significance before and after mitigation is provided in Section 13 of this report (Table 28).

In order to calculate the significance of an impact, probability, duration, extent and magnitude will be used. The pre and post mitigation scores will provide an indication of the extent to which an impact can be mitigated.

9.1 THE IMPACT ASSESSMENT METHODOLOGY

The subsections below present the approach to assessing the identified potential environmental impact with the aim of determining the relevant environmental significance.

9.1.1 Method of Assessing Impacts

The impact assessment methodology is guided by the requirements of the NEMA (2014) EIA Regulations (as amended). The broad approach to the significance rating methodology is to determine the Environmental Risk (ER) by considering the Consequence (C) of each impact (comprising Nature, Extent, Duration, Magnitude, and Reversibility) and relate this to the Probability/likelihood (P) of the impact occurring. This determines the Environmental Risk. In addition, other factors, including cumulative impacts, public concern, and potential for irreplaceable loss of resources, are used to determine a Prioritisation Factor (PF) which is applied to the ER to determine the overall Significance (S).

9.1.2 Determination of Environmental Risk

The significance (S) of an impact is determined by applying a Prioritisation Factor (PF) to the Environmental Risk (ER).

The Environmental Risk is dependent on the Consequence (C) of the particular impact and the Probability (P) of the impact occurring. Consequence is determined through the consideration of the Nature (N), Extent (E), Duration (D), Magnitude (M) and Reversibility (R) applicable to the specific impact.

For the purpose of this methodology the Consequence of the impact is represented by:

C = (E+D+M+R) x N 4 Each individual aspect in the determination of the Consequence is represented by a rating scale as defined in Table 20.

Table 20: Criteria for determination of impact Consequence.

Aspect Score Definition Nature - 1 Likely to result in a negative/ detrimental impact +1 Likely to result in a positive/ beneficial impact Extent 1 Activity (i.e. limited to the area applicable to the specific activity) 2 Site (i.e. within the development property boundary), 3 Local (i.e. the area within 5 km of the site),

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Aspect Score Definition

4 Regional (i.e. extends between 5 and 50 km from the site 5 Provincial / National (i.e. extends beyond 50 km from the site) Duration 1 Immediate (<1 year) 2 Short term (1-5 years) 3 Medium term (6-15 years) 4 Long term (the impact will cease after the operational life span of the project), 5 Permanent (no mitigation measure of natural process will reduce the impact after construction). Magnitude/ 1 Minor (where the impact affects the environment in such a way that natural, Intensity cultural and social functions and processes are not affected) 2 Low (where the impact affects the environment in such a way that natural, cultural and social functions and processes are slightly affected) 3 Moderate (where the affected environment is altered but natural, cultural and social functions and processes continue albeit in a modified way) 4 High (where natural, cultural or social functions or processes are altered to the extent that it will temporarily cease) or 5 Very high / don‟t know (where natural, cultural or social functions or processes are altered to the extent that it will permanently cease) Reversibility 1 Impact is reversible without any time and cost 2 Impact is reversible without incurring significant time and cost 3 Impact is reversible only by incurring significant time and cost 4 Impact is reversible only by incurring prohibitively high time and cost 5 Irreversible Impact

Once the C has been determined the ER is determined in accordance with the standard risk assessment relationship by multiplying the C and the P. Probability is rated/scored as per Table 21.

Table 21: Probability scoring. 1 Improbable (the possibility of the impact materialising is very low as a result of

design, historic experience, or implementation of adequate corrective actions;

<25%),

2 Low probability (there is a possibility that the impact will occur; >25% and <50%),

3 Medium probability (the impact may occur; >50% and <75%), Probability 4 High probability (it is most likely that the impact will occur- > 75% probability), or 5 Definite (the impact will occur),

The result is a qualitative representation of relative ER associated with the impact. ER is therefore calculated as follows:

ER= C x P

Table 22: Determination of Environmental Risk.

5 5 10 15 20 25 4 4 8 12 16 20

3 3 6 9 12 15 uence Conseq 2 2 4 6 8 10

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1 1 2 3 4 5 1 2 3 4 5

Probability

The outcome of the environmental risk assessment will result in a range of scores, ranging from 1 through to 25. These ER scores are then grouped into respective classes as described in Table 23.

Table 23: Significance classes.

Environmental Risk Score Value Description

< 10 Low (i.e. where this impact is unlikely to be a significant environmental risk),

≥ 10; < 20 Medium (i.e. where the impact could have a significant environmental risk),

≥ 20 High (i.e. where the impact will have a significant environmental risk).

The impact ER will be determined for each impact without relevant management and mitigation measures (pre- mitigation), as well as post implementation of relevant management and mitigation measures (post-mitigation). This allows for a prediction in the degree to which the impact can be managed/ mitigated.

9.1.3 Impact Prioritisation

In accordance with the requirements of Appendix 3(1)(j) of the NEMA (2014) EIA Regulations (as amended) (GN 326 of 2017), and further to the assessment criteria presented in the Section above, it is necessary to assess each potentially significant impact in terms of cumulative impacts and the degree to which the impact may cause irreplaceable loss of resources.

In addition it is important that the public opinion and sentiment regarding a prospective development and consequent potential impacts is considered in the decision making process.

In an effort to ensure that these factors are considered, an impact Prioritisation Factor (PF) will be applied to each impact ER (post-mitigation). This prioritisation factor does not aim to detract from the risk ratings but rather to focus the attention of the decision-making authority on the higher priority/ significance issues and impacts. The PF will be applied to the ER score based on the assumption that relevant suggested management/ mitigation impacts are implemented.

Table 24: Criteria for the determination of prioritisation. Public response Low (1) Issue not raised in public response. (PR) Medium (2) Issue has received a meaningful and justifiable public response. High (3) Issue has received an intense meaningful and justifiable public response. Cumulative Impact Low (1) Considering the potential incremental, interactive, sequential, and (CI) synergistic cumulative impacts, it is unlikely that the impact will result in spatial and temporal cumulative change. Medium (2) Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is probable that the impact will result in spatial and temporal cumulative change. High (3) Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is highly probable/definite that the impact will result in spatial and temporal cumulative change.

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Irreplaceable loss Low (1) Where the impact is unlikely to result in irreplaceable loss of resources. of resources (LR) Medium (2) Where the impact may result in the irreplaceable loss (cannot be replaced or substituted) of resources but the value (services and/or functions) of these resources is limited. High (3) Where the impact may result in the irreplaceable loss of resources of high value (services and/or functions).

The value for the final impact priority is represented as a single consolidated priority, determined as the sum of each individual criterion. The impact priority is therefore determined as follows:

Priority = PR + CI + LR

The result is a priority score which ranges from 3 to 9 and a consequent PF ranging from 1 to 2 (Table 25).

Table 25: Determination of prioritisation factor. Priority Ranking Prioritisation Factor 3 Low 1 4 Medium 1.17 5 Medium 1.33 6 Medium 1.5 7 Medium 1.67 8 Medium 1.83 9 High 2

In order to determine the final impact significance the PF is multiplied by the ER of the post mitigation scoring. The ultimate aim of the PF is to be able to increase the post mitigation environmental risk rating by a full ranking class, if all the priority attributes are high (i.e. if an impact comes out with a medium environmental risk after the conventional impact rating, but there is significant cumulative impact potential, significant public response, and significant potential for irreplaceable loss of resources, then the net result would be to upscale the impact to a high significance.

Table 26: Environmental significance rating. Environmental Significance Rating Value Description < -10 Low negative (i.e. where this impact would not have a direct influence on the decision to develop in the area). ≥ -10 < -20 Medium negative (i.e. where the impact could influence the decision to develop in the area). ≥ -20 High negative (i.e. where the impact must have an influence on the decision process to develop in the area). 0 No impact < 10 Low positive (i.e. where this impact would not have a direct influence on the decision to develop in the area). ≥ 10 < 20 Medium positive (i.e. where the impact could influence the decision to develop in the area). ≥ 20 High positive (i.e. where the impact must have an influence on the decision process to develop in the area)

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9.2 ASSESSMENT AND EVALUATION OF POTENTIAL PROJECT IMPACTS AND MITIGATION MEASURES

The following potential impacts were identified during the Basic Assessment. Mitigation measures have also been provided for each environmental aspect assessed.

The draft BAR+EMPR was made available to I&APs for review and comment and their comments and concerns have been addressed in this final report that is submitted to the DMR for adjudication. The impact scores themselves include the results of the public response and comment. The results of the public consultation were used to update the impact scores upon completion of the public review period. Furthermore, it should be noted that the results of the public consultation were also used to update the proposed potential mitigation measures.

9.2.1 Planning Phase Assessment of significance on the potential impacts associated with the proposed invasive prospecting activities (pre-and-post mitigation) for the planning phase.

Impact Name Safety and security risks to landowners and lawful occupiers Alternative Alternative 1 and Alternative 2 Phase Planning Environmental Risk Pre- Post- Pre- Attribute Attribute Post-mitigation mitigation mitigation mitigation Magnitude of Nature of Impact -1 -1 2 2 Impact Reversibility of Extent of Impact 2 2 3 2 Impact Duration of Impact 2 1 Probability 3 2 Environmental Risk (Pre-mitigation) -6.75 Mitigation Measures  Prior to accessing any portion of land, the Applicant must enter into formal written agreements with the affected landowner. This formal agreement should additionally stipulate the landowner‟s special conditions which would form a legally binding agreement.  All homestead gates must be closed immediately upon entry/exit.  Vehicles used must be in a roadworthy condition. Speed limits must be adhered to and all local, provincial and national regulations with regards to road safety and transport. Environmental Risk (Post-mitigation) -3.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Cumulative Impacts 1 Low: Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is unlikely that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 2 The impact may result in the irreplaceable loss (cannot be replaced or substituted) of resources but the value (services and/or functions) of these resources is limited. Prioritisation Factor 1.17 Final Significance -4.08

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Impact Name Interference with existing land uses Alternative Alternative 1 and Alternative 2 Phase Planning Environmental Risk Pre- Post- Pre- Attribute Attribute Post-mitigation mitigation mitigation mitigation Magnitude of Nature of Impact -1 -1 3 2 Impact Reversibility of Extent of Impact 2 1 3 2 Impact Duration of Impact 2 2 Probability 3 3 Environmental Risk (Pre-mitigation) -7.50 Mitigation Measures  The Applicant must enter into formal written agreements with the affected landowners and provide compensation for any loss of revenue due to the prospecting activities. Environmental Risk (Post-mitigation) -5.25 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -5.25

Impact Name Disturbance/damage/destruction of the King Cetshwayo grave Alternative Alternative 1 Phase Planning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 5 4 Reversibility of Extent of Impact 5 4 4 3 Impact Duration of 4 3 Probability 4 4 Impact Environmental Risk (Pre-mitigation) -23.00 Mitigation Measures  Although the grave site is situated a distance away from the ridge proposed for prospecting activity, it has a high-risk impact. To mitigate the risks, the project proponent should develop a formal written letter to Amafa and the Royal House to guarantee that there will be no prospecting in close proximity the grave of King Cetshwayo and that the prospecting will only be limited to the ridge located east of Nkunzana River. This letter will ensure that during the assessment of the current Heritage Impact Assessment document, the project is not taken out of context and be equated to mining in the area. It will also ensure that the issue of prospecting is not politicised. Environmental Risk (Post-mitigation) -14.00 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 3

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High: Issue has received an intense meaningful and justifiable public response.

The impact may result in the irreplaceable loss of resources of high value.

Prioritisation Factor 1.67 Final Significance -18.00

Impact Name Disturbance/damage/destruction of the King Cetshwayo grave Alternative Alternative 2 Phase Planning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 4 Reversibility of Extent of Impact 4 3 4 3 Impact Duration of 3 3 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -15.00 Mitigation Measures  Although the grave site is situated a distance away from the proposed invasive prospecting site, it has a high-risk impact. To mitigate the risks – the project proponent should develop a formal written letter to Amafa and the Royal House to guarantee that there will be no prospecting in the area in close proximity to the grave of King Cetshwayo and that the prospecting will only be limited to the ridge located east of the Nkunzana River. This letter will ensure that during the assessment of the current HIA document, the project is not taken out of context and be equated to mining in the area. It will also ensure that the issue of prospecting is not politicised. Environmental Risk (Post-mitigation) -9.75 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact may result in the irreplaceable loss of resources of high value.

Prioritisation Factor 1.67 Final Significance -16.25

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9.2.2 Construction Phase

Assessment of significance on the potential impacts associated with the proposed invasive prospecting activities (pre-and-post mitigation) for the construction phase.

Impact Name Safety and security risks to landowners and lawful occupiers Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 3 Reversibility of Extent of Impact 3 2 3 2 Impact Duration of 2 1 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -8.25 Mitigation Measures  Ensure construction activities are consistent with occupational and health safety requirements.  Prior to accessing any portion of land, the Applicant must enter into formal written agreements with the affected landowner. This formal agreement should additionally stipulate the landowner‟s special conditions which would form legally binding agreement.  All homestead gates must be closed immediately upon entry/exit.  Vehicles used must be in a roadworthy condition and their loads secured. Speed limits must be adhered to and all local, provincial and national regulations with regards to road safety and transport. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Impact Name Interference with existing land uses Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Attribute Attribute Post-mitigation mitigation mitigation mitigation Magnitude of Nature of Impact -1 -1 3 2 Impact Reversibility of Extent of Impact 3 1 3 2 Impact Duration of Impact 2 1 Probability 3 2 Environmental Risk (Pre-mitigation) -8.25 Mitigation Measures  The Applicant must enter into formal written agreements with the affected landowners and provide compensation for any loss of revenue due to the prospecting activities.

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Environmental Risk (Post-mitigation) -3.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Low: Issue not raised in public responses.

Cumulative Impacts 1 Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is unlikely that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 1

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.17 Final Significance -3.50

Impact Name Sense of place Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Attribute Attribute Post-mitigation mitigation mitigation mitigation Magnitude of Nature of Impact -1 -1 3 2 Impact Reversibility of Extent of Impact 3 3 3 2 Impact Duration of Impact 2 2 Probability 3 2 Environmental Risk (Pre-mitigation) -8.25 Mitigation Measures  The Applicant must enter into formal written agreements with the affected landowners and provide compensation for any loss of revenue due to the prospecting activities. Environmental Risk (Post-mitigation) -4.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -4.50

Impact Name Clearance of vegetation Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 1 1 3 3 Impact 91

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Duration of 2 2 Probability 5 4 Impact Environmental Risk (Pre-mitigation) -11.25 Mitigation Measures  Minimise clearing to areas that are required for invasive works. Where possible, cut vegetation instead of clearing to minimise soil disturbance.  Where possible, locate drill sites as close to existing access roads to minimise the extent of vegetation disturbance caused by temporary access roads.  Rehabilitate all disturbed areas following invasive prospecting activities to the conditions that existed prior to prospecting. Environmental Risk (Post-mitigation) -8.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public response.

The impact may result in the irreplaceable loss of resources of high value.

Prioritisation Factor 1.17 Final Significance -9.33

Impact Name Soil compaction Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 2 3 2 Impact Duration of 2 2 Probability 4 2 Impact Environmental Risk (Pre-mitigation) -10.00 Mitigation Measures

 All areas that are compacted as a result of prospecting activities must be assessed by the ECO and where necessary, scarifying must take place to loosen the soil.

Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public response.

The impact may result in the irreplaceable loss of resources of high value.

Prioritisation Factor 1.17

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Final Significance -4.67

Impact Name Noise Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Attribute Attribute Post-mitigation mitigation mitigation mitigation Magnitude of Nature of Impact -1 -1 3 2 Impact Reversibility of Extent of Impact 3 1 1 1 Impact Duration of Impact 2 2 Probability 3 2 Environmental Risk (Pre-mitigation) -6.75 Mitigation Measures  All vehicles and machinery must be maintained in good working order.  When working or travelling past noise sensitive receptors, no unnecessary hooting or noise should occur. Environmental Risk (Post-mitigation) -3.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -3.00

Impact Name Fugitive dust emissions Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Attribute Attribute Post-mitigation mitigation mitigation mitigation Magnitude of Nature of Impact -1 -1 3 2 Impact Reversibility of Extent of Impact 3 3 2 2 Impact Duration of Impact 2 1 Probability 3 3 Environmental Risk (Pre-mitigation) -7.50 Mitigation Measures  All vehicles utilising gravel roads must adhere to speed limits.  By minimising the removal of vegetation and topsoil in affected areas, this will minimise the potential for dusty conditions.  Prospecting activities (including drill sites) must be located 100 m away from farm dwellings. Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

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Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -6.00

Impact Name Contamination of surface and groundwater Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 3 Reversibility of Extent of Impact 4 3 4 3 Impact Duration of 4 3 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -16.00 Mitigation Measures  Ensure that detailed baseline water quality and quantity samples are obtained and analysed for reference purposes.  Ensure that all mitigation measures as stipulated in the EMPR relating to the Diamond Core drilling (specifically technical specifications) as well as the MPRDA regulations are adhered to. Environmental Risk (Post-mitigation) -9.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Low: Issue not raised in public response.

The impact may result in the irreplaceable loss of resources of high value.

Prioritisation Factor 1.33 Final Significance -12.00

Impact Name Loss and fragmentation of the vegetation community Alternative Alternative 1 Phase Construction Environmental Risk Pre- Post- Pre- Attribute Attribute Post-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 5 3 Extent of Impact 3 2 Reversibility of Impact 4 3 Duration of 4 3 Probability 4 4 Impact Environmental Risk (Pre-mitigation) -16.00

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Mitigation Measures  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity. As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted (this is not plausible given the current, pristine ecological condition). It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on flora.  Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further or used as an area for dumping of waste. Environmental Risk (Post-mitigation) -11.00 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Cumulative Impacts 3 High: Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is highly probable/definite that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 3

The impact may result in the irreplaceable loss of resources of high value (services and/or functions).

Prioritisation Factor 1.67 Final Significance -18.33

Impact Name Loss and fragmentation of the vegetation community Alternative Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Attribute Attribute Post-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Extent of Impact 2 2 Reversibility of Impact 4 3 Duration of 3 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -13.00 Mitigation Measures  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity. As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted. It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on flora.  Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further or used as an area for dumping of waste. Environmental Risk (Post-mitigation) -6.75 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

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Low: Issue not raised in public responses.

The impact may result in the irreplaceable loss of resources of high value (services and/or functions).

Prioritisation Factor 1.67 Final Significance -11.25 Displacement of faunal community (including threatened or protected species) due Impact Name to habitat loss, disturbance and/or direct mortalities Alternative Alternative 1 Phase Construction Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 2 Extent of Impact 3 2 Reversibility of Impact 4 2 Duration of Impact 3 2 Probability 4 4 Environmental Risk (Pre-mitigation) -14.00 Mitigation Measures  No more than two weeks in advance of any vegetation clearance that will commence during the breeding season a qualified Zoologist must conduct a pre-prospecting survey of all potential special- status birds nesting habitat in the vicinity of the project area, and within the project area.  If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.  During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas.  Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery.  Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals.  No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals.  On-site staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process.  Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river systems, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling and servicing of equipment is to take place in demarcated areas outside of the project area. Environmental Risk (Post-mitigation) -8.00 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 2

Low: Issue not raised in public responses.

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Degree of potential irreplaceable loss of resources 3

The impact may result in the irreplaceable loss of resources of high value (services and/or functions).

Prioritisation Factor 1.83 Final Significance -14.67

Displacement of faunal community (including threatened or protected species) due Impact Name to habitat loss, disturbance and/or direct mortalities Alternative Alternative 2 Phase Construction Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Extent of Impact 2 2 Reversibility of Impact 4 2 Duration of Impact 2 2 Probability 3 3 Environmental Risk (Pre-mitigation) -8.25 Mitigation Measures  No more than two weeks in advance of any vegetation clearance that will commence during the breeding season a qualified Zoologist must conduct a pre-prospecting survey of all potential special- status birds nesting habitat in the vicinity of the project area, and within the project area.  If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.  During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas.  Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery.  Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals.  No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals.  On-site staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process.  Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river systems, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling and servicing of equipment is to take place in demarcated areas outside of the project area. Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact may result in the irreplaceable loss of resources of high value (services and/or functions).

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Prioritisation Factor 1.67 Final Significance -10.00

Impact Name Increased runoff and sedimentation Alternative Alternative 1 Phase Construction Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 2 Extent of Impact 3 2 Reversibility of Impact 4 2 Duration of 3 2 Probability 4 4 Impact Environmental Risk (Pre-mitigation) -14.00 Mitigation Measures  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated. Environmental Risk (Post-mitigation) -8.00 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 2

Medium: Issue has received a meaningful and justifiable public response.

Cumulative Impacts 2 Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is probable that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 1

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -10.67

Impact Name Increased runoff and sedimentation Alternative Alternative 2 Phase Construction Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 3 Extent of Impact 3 2 Reversibility of Impact 3 3 Duration of 2 1 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -12.00 Mitigation Measures  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting

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should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated. Environmental Risk (Post-mitigation) -6.75 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Medium: Issue has received a meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -9.00

Impact Name Disturbance/damage/destruction of heritage sensitive areas Alternative Alternative 1 Phase Construction Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Extent of Impact 3 2 Reversibility of Impact 3 3 Duration of 3 2 Probability 4 2 Impact Environmental Risk (Pre-mitigation) -12.00 Mitigation Measures  It is proposed that a 20 m buffer be maintained around cemeteries and that no material be placed near the cemeteries. Environmental Risk (Post-mitigation) -4.50 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -6.00

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Impact Name Disturbance/damage/destruction of heritage sensitive areas Alternative Alternative 2 Phase Construction Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Extent of Impact 2 2 Reversibility of Impact 3 3 Duration of 2 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -7.50 Mitigation Measures  It is proposed that a 20 m buffer be maintained around cemeteries and that no material be placed near the cemeteries. Environmental Risk (Post-mitigation) -4.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -6.00

Impact Name Disturbance/damage/destruction of the King Cetshwayo Grave Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Extent of Impact 2 2 Reversibility of Impact 3 3 Duration of 2 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -7.50 Mitigation Measures  It is recommended that no machinery be placed near the grave of „Isilo‟ King Cetshwayo site. The site is situated 1.5 km from the proposed prospecting activities. However, to avoid any false alarms, no machinery should be place near the grave site of Isilo or site camp be established nearby. Environmental Risk (Post-mitigation) -4.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

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The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -6.00

Impact Name Spillage of oils, fuels and chemicals Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 3 Extent of Impact 2 2 Reversibility of Impact 4 3 Duration of 2 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -11.00 Mitigation Measures  Drip trays must be placed under vehicles.  Any spills or leaks must immediately be cleaned up and the contaminated soil suitably disposed of.  During refuelling of vehicles or equipment, drip trays must be utilised to prevent spills or leaks.  Spill clean-up equipment must be available on site at all times.  In the event of large spills, this must be reported to the authorities and a specialist spill contractor immediately sought to assist with the clean-up. Environmental Risk (Post-mitigation) -7.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -7.50

Impact Name Soil contamination/pollution Alternative Alternative 1 and Alternative 2 Phase Construction Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 3 Extent of Impact 2 2 Reversibility of Impact 4 3 Duration of 2 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -11.00 Mitigation Measures  Machinery to be used for the operation will be of good working conditions.  Any hydrocarbon spill from the site establishment will be remediated as soon as possible. Environmental Risk (Post-mitigation) -7.50

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Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Cumulative Impacts 2 Medium: Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is probable that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 2 The impact may result is the irreplaceable loss (cannot be replaced or substituted) of resources but the value (services and/or functions) of these resources is limited. Prioritisation Factor 1.33 Final Significance -10.00 Impact Name Degradation and/or destruction of wetland habitats Alternative Alternative 1 Phase Construction Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 2 Extent of Impact 2 1 Reversibility of Impact 3 2 Duration of 2 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -6.75 Mitigation Measures

 The 15 m and 25 m buffer zones recommended by the biodiversity specialist should be strictly adhered to. Buffer areas must be strictly adhered to and managed as “No-Go” areas.  Prospecting areas should be demarcated, and wetland areas marked as “restricted” in order to prevent the unnecessary impact to and loss of these systems.  Careful separation of soil types/strata as identified.  No vegetation should be cleared prior to stripping of topsoil, and vegetation must be stripped with the topsoil to retain a seedbank.  Topsoil must be stripped to a depth of at least 300 mm and managed for rehabilitation of impacted areas.  If any spoil is generated this must be transported to another location and re-used if it is required, or removed to a licensed facility, or offered to the landowner. Environmental Risk (Post-mitigation) -3.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Impact Name Degradation and/or destruction of wetland habitats Alternative Alternative 2

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Phase Construction Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 1 Extent of Impact 1 1 Reversibility of Impact 2 2 Duration of 2 2 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -3.50 Mitigation Measures

 The 15 m and 25 m buffer zones recommended by the biodiversity specialist should be strictly adhered to. Buffer areas must be strictly adhered to and managed as “No-Go” areas.  Prospecting areas should be demarcated, and wetland areas marked as “restricted” in order to prevent the unnecessary impact to and loss of these systems.  Careful separation of soil types/strata as identified.  No vegetation should be cleared prior to stripping of topsoil, and vegetation must be stripped with the topsoil to retain a seedbank.  Topsoil must be stripped to a depth of at least 300 mm and managed for rehabilitation of impacted areas.  If any spoil is generated this must be transported to another location and re-used if it is required, or removed to a licensed facility, or offered to the landowner. Environmental Risk (Post-mitigation) -3.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -3.50

9.2.3 Operation Phase

Assessment of significance on the potential impacts associated with the proposed invasive prospecting activities (pre-and-post mitigation) for the operation phase.

Impact Name Safety and security risks to landowners and lawful occupiers Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 2 Extent of Impact 2 2 Reversibility of Impact 3 2 Duration of 2 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -9.00 Mitigation Measures  Ensure invasive prospecting activities are consistent with occupational health and safety

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requirements.  Prior to accessing any portion of land, the Applicant must enter into formal written agreements with the affected landowners. This formal agreement should additionally stipulate the landowner‟s special conditions which should form a legally binding agreement.  All homestead gates must be closed immediately upon entry/exit.  Vehicles used must be in a roadworthy condition and their loads secured. Speed limits must be adhered to and all local, provincial and national regulations with regards to road safety and transport. Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Cumulative Impacts 1 Low: Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is unlikely that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 2 The impact may result is the irreplaceable loss (cannot be replaced or substituted) of resources but the value (services and/or functions) of these resources is limited. Prioritisation Factor 1.17 Final Significance -7.00

Impact Name Interference with existing land uses Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 2 Extent of Impact 2 1 Reversibility of Impact 3 2 Duration of 2 2 Probability 3 3 Impact Environmental Risk (Pre-mitigation) -8.25 Mitigation Measures  Avoid farm lands actively used for farming.  Ensure that negotiations on compensation are undertaken before invasive activities can commence. This will include any other conditions that the landowner may deem necessary for the prospecting operation.  Use sites that are unused and in a degraded state. Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.17 Final Significance -7.00

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Impact Name Degradation and/or destruction of wetland habitats Alternative Alternative 1 Phase Operation Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 1 Extent of Impact 2 1 Reversibility of Impact 2 2 Duration of 2 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -6.00 Mitigation Measures

 The 15 m and 25 m buffer zones recommended by the biodiversity specialist should be strictly adhered to. Buffer areas must be strictly adhered to and managed as “No-Go” areas.  Where wetlands may be encroached upon by proposed activities, the edge of the wetland must be clearly demarcated in the field with pegs or poles that will last for the duration of the construction phase.  Sanitary facilities must be made available to prospecting workers to prevent urine and human waste entering the wetlands.  The Environmental Control Officer (ECO) must continually monitor the activities for erosion/sedimentation and ensure that suitable mitigation measures are implemented where necessary (e.g.: hay bales, silt traps, etc.).  Prospecting machinery and associated vehicles may not be allowed to enter wetlands. Strictly no re- fuelling of vehicles or machinery should be allowed to take place in any area close to a wetland.

Environmental Risk (Post-mitigation) -3.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Impact Name Degradation and/or destruction of wetland habitats Alternative Alternative 2 Phase Operation Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 1 1 Extent of Impact 1 1 Reversibility of Impact 2 1 Duration of 2 2 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -3.00 Mitigation Measures

 The 15 m and 25 m buffer zones recommended by the biodiversity specialist should be strictly adhered to. Buffer areas must be strictly adhered to and managed as “No-Go” areas.

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 Where wetlands may be encroached upon by proposed activities, the edge of the wetland must be clearly demarcated in the field with pegs or poles that will last for the duration of the construction phase.  Sanitary facilities must be made available to prospecting workers to prevent urine and human waste entering the wetlands.  The Environmental Control Officer (ECO) must continually monitor the activities for erosion/sedimentation and ensure that suitable mitigation measures are implemented where necessary (e.g.: hay bales, silt traps, etc.).  Prospecting machinery and associated vehicles may not be allowed to enter wetlands. Strictly no re- fuelling of vehicles or machinery should be allowed to take place in any area close to a wetland. Environmental Risk (Post-mitigation) -2.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -2.50

Impact Name Expropriation of land and displacement of landowners Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 3 Extent of Impact 1 1 Reversibility of Impact 3 2 Duration of 2 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -7.50 Mitigation Measures  Ensure that negotiations on compensation are undertaken before invasive activities can commence. This will include any other conditions that the landowner may deem necessary for the prospecting operation. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Low: Issue not raised in public responses.

The impact may result in the irreplaceable loss of resources of high value (services and/or functions).

Prioritisation Factor 1.50 Final Significance -6.00

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Impact Name Job creation Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact 1 1 Magnitude of Impact 3 3 Extent of Impact 3 3 Reversibility of Impact 2 3 Duration of 2 3 Probability 4 5 Impact Environmental Risk (Pre-mitigation) 10.50 Mitigation Measures  Where possible, the Applicant and contractors will source local labour. However, the number of jobs would not be substantial and duration thereof would be short lived. Environmental Risk (Post-mitigation) 15.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Medium: Issue has received a meaningful and justifiable public response.

Cumulative Impacts 2 Medium: Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, probable that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 1

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance 20.00

Impact Name Perceptions and expectations Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 2 Extent of Impact 4 3 Reversibility of Impact 2 2 Duration of 2 2 Probability 5 4 Impact Environmental Risk (Pre-mitigation) -12.50 Mitigation Measures  Adhere to an open and transparent communication procedure with stakeholders at all times.  Ensure that accurate and regular information is communicated to I&APs.  Ensure that information is communicated in a manner which is understandable and accessible to I&APs.  Enhance project benefits and minimise negative impacts through intensive consultation with stakeholders. Environmental Risk (Post-mitigation) -9.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

Medium: Issue has received a meaningful and justifiable public response.

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The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -12.00

Impact Name Training of unskilled labourers Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact 1 1 Magnitude of Impact 2 2 Extent of Impact 3 4 Reversibility of Impact 2 2 Duration of 1 2 Probability 4 5 Impact Environmental Risk (Pre-mitigation) 8.50 Mitigation Measures  Where possible, the Applicant will source local unskilled labourers to train. Environmental Risk (Post-mitigation) 12.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.17 Final Significance 14.58

Impact Name Clearance of vegetation Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 2 Reversibility of Extent of Impact 1 1 3 3 Impact Duration of 2 2 Probability 5 4 Impact Environmental Risk (Pre-mitigation) -12.50 Mitigation Measures  Minimise clearing to areas that are required for invasive works. Where possible, cut vegetation instead of clearing to minimise soil disturbance.

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 Where possible, locate drill sites and trenches as close to existing access roads to minimise the extent of vegetation disturbance caused by temporary access roads.  Rehabilitate all disturbed areas following invasive prospecting activities to the conditions that existed prior to prospecting. Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1,17 Final Significance -9.33

Impact Name Soil compaction Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 2 3 2 Impact Duration of 2 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -10.00 Mitigation Measures  All areas that are compacted as a result of prospecting activities must be assessed by the ECO and where necessary, scarifying must take place to loosen the soil.

Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.17 Final Significance -7.00

Impact Name Soil pollution/contamination Alternative Alternative 1 and Alternative 2 Phase Operation

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Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 2 4 2 Impact Duration of 2 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -11,00 Mitigation Measures  Drip trays must be placed under vehicles.  Any spills or leaks must immediately be cleaned up and the contaminated soil suitably disposed of.  Drilling fluids (mud) must be contained in the steel sumps and any spills or leaks must be cleaned up. Environmental Risk (Post-mitigation) -6,00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Cumulative Impacts 2 Medium: Considering the potential incremental, interactive, sequential and synergistic cumulative impacts, it is probable that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 2 The impact may result in the irreplaceable loss (cannot be replaced or substituted) of resources but the value (services and/or functions) of these resources is limited. Prioritisation Factor 1.17 Final Significance -8.00

Impact Name Increased runoff and sedimentation Alternative Alternative 1 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 2 3 3 Impact Duration of 2 2 Probability 3 1 Impact Environmental Risk (Pre-mitigation) -8.25 Mitigation Measures  Clearing of vegetation or topsoil must be minimised as far as possible.  A suitably qualified specialist must monitor that no drilling and trenching are undertaken on or within 100 m of a watercourse and within 1:100 year of a floodline.  All disturbed areas must be suitably rehabilitated on completion of the works to ensure that erosion does not result. Environmental Risk (Post-mitigation) -2.25 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 2

Medium: Issue has received a meaningful and justifiable public response.

Cumulative Impacts 2

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Medium: Considering the potential incremental, interactive, sequential and synergistic cumulative impacts, it is probable that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 1

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -3.00

Impact Name Increased runoff and sedimentation Alternative Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 2 2 3 Impact Duration of 2 2 Probability 3 1 Impact Environmental Risk (Pre-mitigation) -7.50 Mitigation Measures  Clearing of vegetation or topsoil must be minimised as far as possible.  A suitably qualified specialist must monitor that no drilling and trenching are undertaken on or within 100 m of a watercourse and within the 1:100 year of a floodline.  All disturbed areas must be suitably rehabilitated on completion of the works to avoid erosion. Environmental Risk (Post-mitigation) -2.25 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 2

Medium: Issue has received a meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -3.00

Impact Name Spillage of oils, fuels and chemicals Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 3 Reversibility of Extent of Impact 2 2 4 3 Impact Duration of 3 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -12.00 Mitigation Measures

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 Drip trays must be placed under vehicles.  Any spills or leaks must immediately be cleaned up and the contaminated soil suitably disposed of.  During refuelling of vehicles or equipment, drip trays must be utilised to prevent spills or leaks.  Spill clean-up equipment must be available on site at all times.  In the event of large spills, this must be reported to the authorities and a specialist spill contractor immediately sought to assist with the clean-up. Environmental Risk (Post-mitigation) -7.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -7.50

Impact Name Contamination of groundwater and surface water Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 3 Reversibility of Extent of Impact 4 3 4 3 Impact Duration of 4 3 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -16.00 Mitigation Measures  Ensure that detailed baseline water quality and quantity samples are obtained and analysed for reference purposes.  Ensure that all mitigation measures as stipulated in the EMPR relating to the diamond core drilling (specifically technical specifications) as well as the MPRDA regulations are adhered to.  It is proposed that the following conditions for Environmental Authorisation be set from a groundwater perspective: o No development should take place within 100 m of the rivers and streams. o No drillholes should be drilled in the immediate vicinity of any existing private boreholes that are in use. If this cannot be avoided, the landowner should be provided with an alternative borehole or water resource. Environmental Risk (Post-mitigation) -9.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Low: Issue not raised in public responses.

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The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -12.00

Impact Name Fugitive dust emissions Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 3 Reversibility of Extent of Impact 3 3 2 3 Impact Duration of 2 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -10.00 Mitigation Measures  All vehicles utilising public gravel roads must adhere to the speed limits.  By minimising the removal of vegetation and topsoil in affected area, this will minimise the potential for dusty conditions.  Prospecting activities (including drill and trench sites) must be located away from dwellings as far as possible. Environmental Risk (Post-mitigation) -8.25 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -8.25

Impact Name Noise Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 1 3 1 Impact Duration of 2 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -6.00 Mitigation Measures  All vehicles and machinery must be maintained in good working order.  When working or traveling past noise sensitive receptors, no unnecessary hooting or noise should occur.

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Environmental Risk (Post-mitigation) -3.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -3.00

Disturbance/damage/destruction of archaeological sites and heritage sensitive Impact Name areas Alternative Alternative 1 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 2 3 2 Impact Duration of 4 2 Probability 4 2 Impact Environmental Risk (Pre-mitigation) -12.00 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near the prospecting activities.  At least a 20 m buffer must be established from cemeteries. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -5.33

Disturbance/damage/destruction of archaeological sites and heritage sensitive Impact Name areas Alternative Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation

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Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 2 3 2 Impact Duration of 4 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -9.00 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near the prospecting activities.  At least a 20 m buffer must be established from cemeteries. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -5.33

Impact Name Disturbance/damage/destruction of the King Cetshwayo Grave Alternative Alternative 1 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 2 2 2 Impact Duration of 4 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -8.25 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near the prospecting activities.  At least a 20 m buffer must be established from cemeteries. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33

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Final Significance -5.33

Impact Name Disturbance/damage/destruction of the King Cetshwayo Grave Alternative Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 2 2 2 Impact Duration of 4 2 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -5.50 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near the prospecting activities.  At least a 20 m buffer must be established from cemeteries. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -5.33

Impact Name Disturbance/damage/destruction of homesteads (imizi) structure Alternative Alternative 1 and Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Extent of Impact 2 2 Reversibility of Impact 3 3 Duration of 2 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -7.50 Mitigation Measures  All heritage structures must be suitably identified prior to invasive prospecting works proceeding and suitably demarcated and avoided. Environmental Risk (Post-mitigation) -4.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Low: Issue not raised in public responses.

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The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -5.25

Impact Name Discovery of economically viable minerals Alternative Alternative 1 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 5 Reversibility of Extent of Impact 5 5 4 5 Impact Duration of 4 4 Probability 5 5 Impact Environmental Risk (Pre-mitigation) 20.00 Mitigation Measures  None. Environmental Risk (Post-mitigation) 23.75 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1,33 Final Significance 31.67

Impact Name Discovery of economically viable minerals Alternative Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 5 Reversibility of Extent of Impact 5 4 4 5 Impact Duration of 4 4 Probability 4 4 Impact Environmental Risk (Pre-mitigation) 16.00 Mitigation Measures  None. Environmental Risk (Post-mitigation) 18.00

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Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1,33 Final Significance 24.00

Continued encroachment and displacement of an indigenous and vulnerable Impact Name vegetation community by alien invasive species Alternative Alternative 1 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 2 Reversibility of Extent of Impact 3 2 4 3 Impact Duration of 4 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -15.00 Mitigation Measures  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity. As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted. It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated.  Drilling areas and dumping areas should completely avoid any trees, where possible (especially any protected tree species).  An experienced road engineer must be consulted during the planning, construction and closure phases for the development of the unpaved access road.  The areas rated as highly sensitive in the project area as defined in this report should be declared a „“No-Go”‟ area during the construction and operational phases and all efforts must be made to prevent access to this area from workers, machinery, domestic animals and the general public.  Where possible, existing access routes and walking paths must be made use of, and new routes limited.

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 All laydown, storage areas etc. should be restricted to within the project area.  A qualified environmental control officer must be on site when prospecting begins to identify species that will be directly disturbed and to relocate fauna/flora that is found during prospecting (including all reptiles and amphibians).  All livestock (including cattle, pigs, goats, domestic dogs and cats) must be kept out of the project area at all times.  All staff and visitors to the site must undergo an induction process and must be made aware of the sensitive nature of the environment and floral species which occur there.  Rehabilitation of the trenches and unpaved access road must be made a priority (and be concurrent). Due to the sensitive nature of the soil layer and extreme risk of erosion, rehabilitation must include refilling of the open trenches with appropriate rock and soils and suitably compacted. Top soils must also be utilised, and the area must be re-vegetated with plant and grass species which are endemic to this exact vegetation type: o Rehabilitation measures that are implemented must be continually monitored for a minimum period of four years to ensure that proper succession has occurred and that there is no erosion occurring.  Areas that are denuded during prospecting need to be re-vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species.  Compilation of and implementation of an alien vegetation management plan for the entire site. Environmental Risk (Post-mitigation) -6.75 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Cumulative Impacts 3 Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is highly probable/definite that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 2 The impact may result in the irreplaceable loss (cannot be replaced or substituted) of resources but the value (services and/or functions) of these resources is limited. Prioritisation Factor 1.50 Final Significance -10.13

Continued encroachment and displacement of an indigenous and vulnerable Impact Name vegetation community by alien invasive species Alternative Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 1 2 3 2 Impact Duration of 3 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -7.50 Mitigation Measures  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity. As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted (this is not plausible given the current, pristine ecological condition). It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing

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movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.  Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further or used as an area for dumping of waste.  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the unpaved road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated.  Drilling areas and dumping areas should completely avoid any trees, where possible (especially any protected tree species).  An experienced road engineer must be consulted during the planning, construction and closure phases for the development of the unpaved access road.  The areas rated as highly sensitive in the project area as defined in this report should be declared a „“No-Go”‟ area during the construction and operational phases and all efforts must be made to prevent access to this area from workers, machinery, domestic animals and the general public.  Where possible, existing access routes and walking paths must be made use of, and new routes limited.  All laydown, storage areas etc. should be restricted to within the project area.  A qualified environmental control officer must be on site when prospecting begins to identify species that will be directly disturbed and to relocate fauna/flora that is found during prospecting (including all reptiles and amphibians).  All livestock (including cattle, pigs, goats, domestic dogs and cats) must be kept out of the project area at all times.  All staff and visitors to the site must undergo an induction process and must be made aware of the sensitive nature of the environment and floral species which occur there.  Rehabilitation of the trenches and unpaved access road must be made a priority (and be concurrent). Due to the sensitive nature of the soil layer and extreme risk of erosion, rehabilitation must include refilling of the open trenches with appropriate rock and soils and suitably compacted. Top soils must also be utilised, and the area must be re-vegetated with plant and grass species which are endemic to this exact vegetation type: o Rehabilitation measures that are implemented must be continually monitored for a minimum period of four years to ensure that proper succession has occurred and that there is no erosion occurring.  Areas that are denuded during prospecting need to be re-vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species.  Compilation of and implementation of an alien vegetation management plan for the entire site. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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Prioritisation Factor 1.50 Final Significance -6.00

Continued displacement and fragmentation of the faunal community (including Impact Name threatened or protected species) due to ongoing anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching) Alternative Alternative 1 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 2 3 2 Impact Duration of 3 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -12.00 Mitigation Measures  No more than two weeks in advance of any vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status birds nesting habitat in the vicinity of the project area, and within the project area: o If active nests are found, avoidance procedures must be implemented on a case-by-case basis. Avoidance procedures may include the implementation of buffer zones, relocation of birds, or seasonal avoidance. If buffers are created, a no disturbance zone must be created around active nests during the breeding season by a suitably qualified Zoologist.  Similarly, regarding amphibians, no more than two weeks in advance of vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status amphibians that may be calling within the project area. This person should have specialist knowledge of the Plain Stream Frog, Spotted Shovel Snout and Natal Leaf Folding Frog.  Any individuals found should be relocated to a suitable area that is undisturbed, such as the nearby Nkandla Forest Reserve.  In addition, the following measures are recommended: o If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action. o The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora. o During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas. o Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery. o Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals. o Fencing should be erected around the project area to prevent workers and members of the public from entering the surrounding farm portions and environments. This fence should have small openings to allow wildlife to pass through. o Waste management must be a priority and all waste must be collected and stored adequately. It is recommended that all waste be removed from site on a weekly basis to prevent rodents and pests entering the site. o No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals. o During the construction phase noise must be kept to an absolute minimum to reduce the

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impact of the development on the fauna residing on the site. o Furthermore, during the operational phase, noise must be kept to an absolute minimum during the evenings and at night to minimise all possible disturbances to amphibian species and nocturnal mammals. o Staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process. o The avoidance and protection of the river and forest areas must be included into a site induction. Contractors and employees must all undergo the induction and made aware of the sensitive areas to be avoided. o The induction must include a focus on amphibian, bird and reptile species, especially known SCC that may occur within the project area. o Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling and servicing of equipment is to take place in demarcated areas outside of the project area. Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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pre-prospecting survey of all potential special-status amphibians that may be calling within the project area. This person should have specialist knowledge of the Plain Stream Frog, Spotted Shovel Snout and Natal Leaf Folding Frog.  Any individuals found should be relocated to a suitable area that is undisturbed, such as the nearby Nkandla Forest Reserve.  In additional to this the following measures are recommended: o If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action. o The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora. o During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas. o Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery. o Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals. o Fencing should be erected around the project area to prevent workers and members of the public from entering the surrounding farm portions and environments. This fence should have small openings to allow wildlife to pass through. o Waste management must be a priority and all waste must be collected and stored adequately. It is recommended that all waste be removed from site on a weekly basis to prevent rodents and pests entering the site. o No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals. o During the construction phase noise must be kept to an absolute minimum to reduce the impact of the development on the fauna residing on the site. o Furthermore, during the operational phase, noise must be kept to an absolute minimum during the evenings and at night to minimise all possible disturbances to amphibian species and nocturnal mammals. o Staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process. o The avoidance and protection of the river and forest areas must be included into a site induction. Contractors and employees must all undergo the induction and made aware of the sensitive areas to be avoided. o The induction must include a focus on amphibian, bird and reptile species, especially known SCC that may occur within the project area. o Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling and servicing of equipment is to take place in demarcated areas outside of the project area. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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Final Significance -6.00

Impact Name Introduction of alien invasive species Alternative Alternative 1 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 2 Reversibility of Extent of Impact 2 2 4 2 Impact Duration of 2 1 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -9.00 Mitigation Measures  Undertake activities in previously disturbed areas.  Locate activities on the boundaries of existing disturbance.  Use existing access roads as much as possible.  Rehabilitate disturbed areas as soon as possible.  Manage alien plants within close proximity to prospecting activities. Environmental Risk (Post-mitigation) -3.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -6.00

Impact Name Introduction of alien invasive species Alternative Alternative 2 Phase Operation Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 2 Reversibility of Extent of Impact 2 2 4 2 Impact Duration of 2 1 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -6.00 Mitigation Measures  Undertake activities in previously disturbed areas.  Locate activities on the boundaries of existing disturbance.  Use existing access roads as much as possible.  Rehabilitate disturbed areas as soon as possible.  Manage alien plants within close proximity to prospecting activities.

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Environmental Risk (Post-mitigation) -3.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -6.00

9.2.4 Decommissioning Phase

Assessment of significance on the potential impacts associated with the proposed invasive prospecting activities (pre-and-post mitigation) for the decommissioning phase.

Impact Name Job creation Alternative Alternative 1 and Alternative 2 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 3 Reversibility of Extent of Impact 3 2 2 3 Impact Duration of 2 2 Probability 4 5 Impact Environmental Risk (Pre-mitigation) 10.00 Mitigation Measures  Where possible, the Applicant and contractors will source local labour however the number of jobs would not be substantial and duration thereof would be short lived. Environmental Risk (Post-mitigation) 12.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1,50 Final Significance 18.75

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Impact Name Spillage of oils, fuels and chemicals Alternative Alternative 1 and Alternative 2 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 3 4 3 Impact Duration of 2 2 Probability 4 2 Impact Environmental Risk (Pre-mitigation) -11.00 Mitigation Measures  Drip trays must be placed under vehicles.  Any spills or leaks must immediately be cleaned up and the contaminated soil suitably disposed of.  During refuelling of vehicles or equipment, drip trays must be utilised to prevent spills or leaks.  Spill clean-up equipment must be available on site at all times.  In the event of large spills, this must be reported to the authorities and a specialist spill contractor immediately sought to assist with the clean-up. Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -6.00

Impact Name Noise Alternative Alternative 1 and Alternative 2 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 1 3 1 Impact Duration of 2 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -7.50 Mitigation Measures  All vehicles and machinery must be maintained in good working order.  When working or traveling past noise sensitive receptors, no unnecessary hooting or noise should occur. Environmental Risk (Post-mitigation) -3.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

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Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -3.00

Impact Name Contamination of groundwater and surface water Alternative Alternative 1 and Alternative 2 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 2 Reversibility of Extent of Impact 4 3 4 3 Impact Duration of 3 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -15.00 Mitigation Measures  Ensure that detailed baseline water quality and quantity samples are obtained and analysed for reference purposes.  Ensure that all mitigation measures as stipulated in the EMPR relating to the Diamond Core drilling (specifically technical specifications) as well as the MPRDA regulations are adhered to. Environmental Risk (Post-mitigation) -7.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 2

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -10.00

Impact Name Fugitive dust emissions Alternative Alternative 1 and Alternative 2 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 1 1 3 2 Impact Duration of 1 2 Probability 3 2 Impact

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Environmental Risk (Pre-mitigation) -6.00 Mitigation Measures  All vehicles utilising public gravel roads must adhere to the speed limits.  By minimising the removal of vegetation and topsoil in affected area, this will minimise the potential for dusty conditions.  Prospecting activities (including drill and trench sites) must be located away from dwellings as far as possible. Environmental Risk (Post-mitigation) -3.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -3.00

Continued encroachment and displacement of an indigenous and vulnerable Impact Name vegetation community by alien invasive species Alternative Alternative 1 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 2 4 2 Impact Duration of 4 3 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -10.50 Mitigation Measures  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity .As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted (this is not plausible given the current, pristine ecological condition). It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.  Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further or used as an area for dumping of waste.  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation

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system to hold surface water and release it slowly into the surrounding environment must be investigated;  Drilling areas and dumping areas should completely avoid any trees, where possible (especially any protected tree species).  An experienced road engineer must be consulted during the planning, construction and closure phases for the development of the unpaved access road.  The areas rated as highly sensitive in the project area as defined in this report should be declared a „“No-Go”‟ area during the construction and operational phases and all efforts must be made to prevent access to this area from workers, machinery, domestic animals and the general public.  Where possible, existing access routes and walking paths must be made use of, and new routes limited.  All laydown, storage areas etc. should be restricted to within the project area.  A qualified environmental control officer must be on site when prospecting begins to identify species that will be directly disturbed and to relocate fauna/flora that is found during prospecting (including all reptiles and amphibians).  All livestock (including cattle, pigs, goats, domestic dogs and cats) must be kept out of the project area at all times.  All staff and visitors to the site must undergo and extensive induction process and must be made aware of the sensitive nature of the environment and floral species which occur there.  Rehabilitation of the trenches and unpaved access road must be made a priority (and be concurrent). Due to the sensitive nature of the soil layer and extreme risk of erosion, rehabilitation must include refilling of the open trenches with appropriate rock and soils and suitably compacted. Top soils must also be utilised, and the area must be re-vegetated with plant and grass species which are endemic to this exact vegetation type: o Rehabilitation measures that are implemented must be continually monitored for a minimum period of four years to ensure that proper succession has occurred and that there is no erosion occurring.  Areas that are denuded during prospecting need to be re-vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species.  Compilation of and implementation of an alien vegetation management plan for the entire site. Environmental Risk (Post-mitigation) -4.50 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Continued encroachment and displacement of an indigenous and vulnerable Impact Name vegetation community by alien invasive species Alternative Alternative 2 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 3 Extent of Impact 3 2 Reversibility of 3 3

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Impact Duration of 4 2 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -6.50 Mitigation Measures  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity. As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted (this is not plausible given the current, pristine ecological condition). It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.  Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further or used as an area for dumping of waste.  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated;  Drilling areas and dumping areas should completely avoid any trees, where possible (especially any protected tree species).  An experienced road engineer must be consulted during the planning, construction and closure phases for the development of the unpaved access road.  The areas rated as highly sensitive in the project area as defined in this report should be declared a „“No-Go”‟ area during the construction and operational phases and all efforts must be made to prevent access to this area from workers, machinery, domestic animals and the general public.  Where possible, existing access routes and walking paths must be made use of, and new routes limited.  All laydown, storage areas etc. should be restricted to within the project area.  A qualified environmental control officer must be on site when prospecting begins to identify species that will be directly disturbed and to relocate fauna/flora that is found during prospecting (including all reptiles and amphibians).  All livestock (including cattle, pigs, goats, domestic dogs and cats) must be kept out of the project area at all times.  All staff and visitors to the site must undergo and extensive induction process and must be made aware of the sensitive nature of the environment and floral species which occur there.  Rehabilitation of the trenches and unpaved access road must be made a priority (and be concurrent). Due to the sensitive nature of the soil layer and extreme risk of erosion, rehabilitation must include refilling of the open trenches with appropriate rock and soils and suitably compacted. Top soils must also be utilised, and the area must be re-vegetated with plant and grass species which are endemic to this exact vegetation type: o Rehabilitation measures that are implemented must be continually monitored for a minimum period of four years to ensure that proper succession has occurred and that there is no erosion occurring.  Areas that are denuded during prospecting need to be re-vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species.  Compilation of and implementation of an alien vegetation management plan for the entire site. Environmental Risk (Post-mitigation) -5.00

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Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Cumulative Impacts 1 Low: Considering the potential incremental, interactive, sequential and synergistic cumulative impacts, it is unlikely that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 2 The impact may result in the irreplaceable loss (cannot be replaced or substituted) of resources but the value (services and/or functions) of these resources is limited. Prioritisation Factor 1.17 Final Significance -5.83

Continued displacement and fragmentation of the faunal community (including Impact Name threatened or protected species) due to on-going anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching) Alternative Alternative 1 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 2 3 2 Impact Duration of 3 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -9.00 Mitigation Measures  No more than two weeks in advance of any vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status birds nesting habitat in the vicinity of the project area, and within the project area: o If active nests are found, avoidance procedures must be implemented on a case-by-case basis. Avoidance procedures may include the implementation of buffer zones, relocation of birds, or seasonal avoidance. If buffers are created, a no disturbance zone must be created around active nests during the breeding season by a suitably qualified Zoologist.  Similarly, regarding amphibians, no more than two weeks in advance of vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status amphibians that may be calling within the project area. This person should have specialist knowledge of the Plain Stream Frog, Spotted Shovel Snout and Natal Leaf Folding Frog.  Any individuals found should be relocated to a suitable area that is undisturbed, such as the nearby Nkandla Forest Reserve.  In additional to this the following measures are recommended: o If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action. o The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora. o During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas. o Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery.

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o Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals. o Fencing should be erected around the project area to prevent workers and members of the public from entering the surrounding farm portions and environments. This fence should have small openings to allow wildlife to pass through. o Waste management must be a priority and all waste must be collected and stored adequately. It is recommended that all waste be removed from site on a weekly basis to prevent rodents and pests entering the site. o No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals. o During the construction phase noise must be kept to an absolute minimum to reduce the impact of the development on the fauna residing on the site. o Furthermore, during the operational phase, noise must be kept to an absolute minimum during the evenings and at night to minimise all possible disturbances to amphibian species and nocturnal mammals. o Staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process. o The avoidance and protection of the river and forest areas must be included into a site induction. Contractors and employees must all undergo the induction and made aware of the sensitive areas to be avoided. o The induction must include a focus on amphibian, bird and reptile species, especially known SCC that may occur within the project area. o Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling and servicing of equipment is to take place in demarcated areas outside of the project area. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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Mitigation Measures  No more than two weeks in advance of any vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status birds nesting habitat in the vicinity of the project area, and within the project area: o If active nests are found, avoidance procedures must be implemented on a case-by-case basis. Avoidance procedures may include the implementation of buffer zones, relocation of birds, or seasonal avoidance. If buffers are created, a no disturbance zone must be created around active nests during the breeding season by a suitably qualified Zoologist.  Similarly, regarding amphibians, no more than two weeks in advance of vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status amphibians that may be calling within the project area. This person should have specialist knowledge of the Plain Stream Frog, Spotted Shovel Snout and Natal Leaf Folding Frog.  Any individuals found should be relocated to a suitable area that is undisturbed, such as the nearby Nkandla Forest Reserve.  In additional to this the following measures are recommended: o If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action. o The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora. o During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas. o Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery. o Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals. o Fencing should be erected around the project area to prevent workers and members of the public from entering the surrounding farm portions and environments. This fence should have small openings to allow wildlife to pass through. o Waste management must be a priority and all waste must be collected and stored adequately. It is recommended that all waste be removed from site on a weekly basis to prevent rodents and pests entering the site. o No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals. o During the construction phase noise must be kept to an absolute minimum to reduce the impact of the development on the fauna residing on the site. o Furthermore, during the operational phase, noise must be kept to an absolute minimum during the evenings and at night to minimise all possible disturbances to amphibian species and nocturnal mammals. o Staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process. o The avoidance and protection of the river and forest areas must be included into a site induction. Contractors and employees must all undergo the induction and made aware of the sensitive areas to be avoided. o The induction must include a focus on amphibian, bird and reptile species, especially known SCC that may occur within the project area. o Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling and servicing of equipment is to take place in demarcated areas outside of the project area. Environmental Risk (Post-mitigation) -5.00 Degree of confidence in impact prediction: Medium

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Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Disturbance/damage/destruction of archaeological sites and heritage sensitive Impact Name areas Alternative Alternative 1 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 2 Reversibility of Extent of Impact 2 1 2 2 Impact Duration of 2 2 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -4.00 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near the prospecting activities.  At least a 20 m buffer must be established from cemeteries. Environmental Risk (Post-mitigation) -3.50 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -4.67

Disturbance/damage/destruction of archaeological sites and heritage sensitive Impact Name areas Alternative Alternative 2 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 2 Extent of Impact 1 1 Reversibility of 2 2

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Impact Duration of 1 1 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -3.00 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near to the prospecting activities.  At least a 20 metre buffer must be established from cemeteries. Environmental Risk (Post-mitigation) -3.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -4.00

Impact Name Disturbance/damage/destruction of the King Cetshwayo Grave Alternative Alternative 1 and Alternative 2 Phase Decommissioning Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 2 Reversibility of Extent of Impact 2 2 2 2 Impact Duration of 2 2 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -4.00 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near the prospecting activities.  At least a 20 m buffer must be established from cemeteries. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -5.33

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9.2.5 Rehabilitation and Closure Phase Assessment of significance on the potential impacts associated with the proposed invasive prospecting activities (pre-and-post mitigation) for the rehabilitation and phase.

Encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive species, potential re-establishment of natural species Impact Name that were removed, the nature of the erosion will depend on the amount of successful vegetation establishment Alternative Alternative 1 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 4 2 Reversibility of Extent of Impact 4 2 4 2 Impact Duration of 4 2 Probability 4 3 Impact Environmental Risk (Pre-mitigation) -16.00 Mitigation Measures  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity. As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted (this is not plausible given the current, pristine ecological condition). It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.  Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further or used as an area for dumping of waste.  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated.  Drilling areas and dumping areas should completely avoid any trees, where possible (especially any protected tree species).  An experienced road engineer must be consulted during the planning, construction and closure phases for the development of the unpaved access road.  The areas rated as highly sensitive in the project area as defined in this report should be declared a „“No-Go”‟ area during the construction and operational phases and all efforts must be made to prevent access to this area from workers, machinery, domestic animals and the general public.  Where possible, existing access routes and walking paths must be made use of, and new routes limited.  All laydown, storage areas etc. should be restricted to within the project area.  A qualified environmental control officer must be on site when prospecting begins to identify species that will be directly disturbed and to relocate fauna/flora that is found during prospecting (including all reptiles and amphibians).  All livestock (including cattle, pigs, goats, domestic dogs and cats) must be kept out of the project

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area at all times.  All staff and visitors to the site must undergo and extensive induction process and must be made aware of the sensitive nature of the environment and floral species which occur there.  Rehabilitation of the trenches and unpaved access road must be made a priority (and be concurrent). Due to the sensitive nature of the soil layer and extreme risk of erosion, rehabilitation must include refilling of the open trenches with appropriate rock and soils and suitably compacted. Top soils must also be utilised, and the area must be re-vegetated with plant and grass species which are endemic to this exact vegetation type: o Rehabilitation measures that are implemented must be continually monitored for a minimum period of four years to ensure that proper succession has occurred and that there is no erosion occurring.  Areas that are denuded during prospecting need to be re-vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species.  Compilation of and implementation of an alien vegetation management plan for the entire site. Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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the period of disturbance on fauna and flora.  Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further or used as an area for dumping of waste.  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated;  Drilling areas and dumping areas should completely avoid any trees, where possible (especially any protected tree species).  An experienced road engineer must be consulted during the planning, construction and closure phases for the development of the unpaved access road.  The areas rated as highly sensitive in the project area as defined in this report should be declared a „“No-Go”‟ area during the construction and operational phases and all efforts must be made to prevent access to this area from workers, machinery, domestic animals and the general public.  Where possible, existing access routes and walking paths must be made use of, and new routes limited.  All laydown, storage areas etc. should be restricted to within the project area.  A qualified environmental control officer must be on site when prospecting begins to identify species that will be directly disturbed and to relocate fauna/flora that is found during prospecting (including all reptiles and amphibians).  All livestock (including cattle, pigs, goats, domestic dogs and cats) must be kept out of the project area at all times.  All staff and visitors to the site must undergo and extensive induction process and must be made aware of the sensitive nature of the environment and floral species which occur there.  Rehabilitation of the trenches and unpaved access road must be made a priority (and be concurrent). Due to the sensitive nature of the soil layer and extreme risk of erosion, rehabilitation must include refilling of the open trenches with appropriate rock and soils and suitably compacted. Top soils must also be utilised, and the area must be re-vegetated with plant and grass species which are endemic to this exact vegetation type: o Rehabilitation measures that are implemented must be continually monitored for a minimum period of four years to ensure that proper succession has occurred and that there is no erosion occurring.  Areas that are denuded during prospecting need to be re-vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species.  Compilation of and implementation of an alien vegetation management plan for the entire site. Environmental Risk (Post-mitigation) -6.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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Final Significance -8.00

Encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive species, potential re-establishment of natural species Impact Name that were removed, the nature of the erosion will depend on the amount of successful vegetation establishment Alternative Alternative 2 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 2 3 2 Impact Duration of 4 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -9.75 Mitigation Measures  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity. As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted (this is not plausible given the current, pristine ecological condition). It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.  Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further.  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the unpaved for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated.  Drilling areas and dumping areas should completely avoid any trees, where possible (especially any protected tree species).  An experienced road engineer must be consulted during the planning, construction and closure phases for the development of the unpaved access road.  The areas rated as highly sensitive in the project area as defined in this report should be declared a „“No-Go”‟ area during the construction and operational phases and all efforts must be made to prevent access to this area from workers, machinery, domestic animals and the general public.  Where possible, existing access routes and walking paths must be made use of, and new routes limited.  All laydown, storage areas etc. should be restricted to within the project area.  A qualified environmental control officer must be on site when prospecting begins to identify species that will be directly disturbed and to relocate fauna/flora that is found during prospecting (including all reptiles and amphibians).  All livestock (including cattle, pigs, goats, domestic dogs and cats) must be kept out of the project area at all times.  All staff and visitors to the site must undergo and extensive induction process and must be made

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aware of the sensitive nature of the environment and floral species which occur there.  Rehabilitation of the trenches and unpaved access road must be made a priority (and be concurrent). Due to the sensitive nature of the soil layer and extreme risk of erosion, rehabilitation must include refilling of the open trenches with appropriate rock and soils and suitably compacted. Top soils must also be utilised, and the area must be re-vegetated with plant and grass species which are endemic to this exact vegetation type: o Rehabilitation measures that are implemented must be continually monitored for a minimum period of four years to ensure that proper succession has occurred and that there is no erosion occurring.  Areas that are denuded during prospecting need to be re-vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species.  Compilation of and implementation of an alien vegetation management plan for the entire site. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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and Natal Leaf Folding Frog.  Any individuals found should be relocated to a suitable area that is undisturbed, such as the nearby Nkandla Forest Reserve.  In additional to this the following measures are recommended: o If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action. o The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora. o During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas. o Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery. o Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals. o Fencing should be erected around the project area to prevent workers and members of the public from entering the surrounding farm portions and environments. This fence should have small openings to allow wildlife to pass through. o Waste management must be a priority and all waste must be collected and stored adequately. It is recommended that all waste be removed from site on a weekly basis to prevent rodents and pests entering the site. o No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals. o During the construction phase noise must be kept to an absolute minimum to reduce the impact of the development on the fauna residing on the site. o Furthermore, during the operational phase, noise must be kept to an absolute minimum during the evenings and at night to minimise all possible disturbances to amphibian species and nocturnal mammals. o Staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process. o The avoidance and protection of the river and forest areas must be included into a site induction. Contractors and employees must all undergo the induction and made aware of the sensitive areas to be avoided. o The induction must include a focus on amphibian, bird and reptile species, especially known SCC that may occur within the project area. o Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling and servicing of equipment is to take place in demarcated areas outside of the project area. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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Displacement and fragmentation of the faunal community (including threatened or Impact Name protected species) due to on-going anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching) Alternative Alternative 1 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 2 3 2 Impact Duration of 4 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -9.75 Mitigation Measures  No more than two weeks in advance of any vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status birds nesting habitat in the vicinity of the project area, and within the project area: o If active nests are found, avoidance procedures must be implemented on a case-by-case basis. Avoidance procedures may include the implementation of buffer zones, relocation of birds, or seasonal avoidance. If buffers are created, a no disturbance zone must be created around active nests during the breeding season by a suitably qualified Zoologist.  Similarly, regarding amphibians, no more than two weeks in advance of vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status amphibians that may be calling within the project area. This person should have specialist knowledge of the Plain Stream Frog, Spotted Shovel Snout and Natal Leaf Folding Frog.  Any individuals found should be relocated to a suitable area that is undisturbed, such as the nearby Nkandla Forest Reserve.  In additional to this the following measures are recommended: o If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action. o The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora. o During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas. o Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery. o Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals. o Fencing should be erected around the project area to prevent workers and members of the public from entering the surrounding farm portions and environments. This fence should have small openings to allow wildlife to pass through. o Waste management must be a priority and all waste must be collected and stored adequately. It is recommended that all waste be removed from site on a weekly basis to prevent rodents and pests entering the site. o No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals. o During the construction phase noise must be kept to an absolute minimum to reduce the impact of the development on the fauna residing on the site. o Furthermore, during the operational phase, noise must be kept to an absolute minimum during the evenings and at night to minimise all possible disturbances to amphibian species and nocturnal mammals.

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o Staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process. o The avoidance and protection of the river and forest areas must be included into a site induction. Contractors and employees must all undergo the induction and made aware of the sensitive areas to be avoided. o The induction must include a focus on amphibian, bird and reptile species, especially known SCC that may occur within the project area. o Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling and servicing of equipment is to take place in demarcated areas outside of the project area. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Impact Name Soil instability Alternative Alternative 1 and Alternative 2 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 2 Reversibility of Extent of Impact 1 2 3 2 Impact Duration of 2 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -6.00 Mitigation Measures  Reinstate the topography to match the surroundings.  Reinstate vegetation cover to match the surroundings.  Monitor the reinstated areas to ensure that erosion does not occur.  Any contaminated soils are to be collected and removed from site and suitably disposed of.  Vegetation regrowth must be monitored to ensure that it matches the surrounding areas. Environmental Risk (Post-mitigation) -3.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -4.67

Impact Name Increased runoff and sedimentation Alternative Alternative 1 Phase Rehab and closure Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 2 3 3 Impact Duration of 2 2 Probability 3 1 Impact Environmental Risk (Pre-mitigation) -8.25 Mitigation Measures  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated. Environmental Risk (Post-mitigation) -2.25 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 2

Medium: Issue has received a meaningful and justifiable public response

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -3.00

Impact Name Increased runoff and sedimentation Alternative Alternative 2 Phase Rehab and closure Environmental Risk Pre- Post- Post- Attribute Attribute Pre-mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 3 2 2 3 Impact Duration of 2 2 Probability 3 1 Impact Environmental Risk (Pre-mitigation) -7.50 144

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Mitigation Measures  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated. Environmental Risk (Post-mitigation) -2.25 Degree of confidence in impact prediction: High Impact Prioritisation Public Response 2

Medium: Issue has received a meaningful and justifiable public response

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -3.00

Impact Name Soil pollution/contamination Alternative Alternative 1 and Alternative 2 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 1 1 2 2 Impact Duration of 2 2 Probability 3 3 Impact Environmental Risk (Pre-mitigation) -6.00 Mitigation Measures  Drip trays must be placed under vehicles.  Any spills or leaks must immediately be cleaned up and the contaminated soil suitably disposed of.  Drilling fluids (mud) must be contained in the steel sumps and any spills or leaks must be cleaned up. Environmental Risk (Post-mitigation) -3.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

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The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -4.67

Disturbance/damage/destruction of archaeological sites and heritage sensitive Impact Name areas Alternative Alternative 1 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 1 1 Reversibility of Extent of Impact 2 2 1 1 Impact Duration of 2 2 Probability 2 1 Impact Environmental Risk (Pre-mitigation) -3.00 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near to the prospecting activities. Environmental Risk (Post-mitigation) -1.50 Degree of confidence in impact prediction: Low Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -1.50

Disturbance/damage/destruction of archaeological sites and heritage sensitive Impact Name areas Alternative Alternative 2 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 1 1 Reversibility of Extent of Impact 1 2 1 1 Impact Duration of 2 2 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -2.50 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near to the prospecting activities.

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Environmental Risk (Post-mitigation) -2.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.00 Final Significance -2.50

Impact Name Disturbance/damage/destruction of the King Cetshwayo Grave Alternative Alternative 1 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 2 Reversibility of Extent of Impact 2 2 2 2 Impact Duration of 2 2 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -4.00 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near to the prospecting activities. Environmental Risk (Post-mitigation) -4.00 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -5.33

Impact Name Disturbance/damage/destruction of the King Cetshwayo Grave Alternative Alternative 2 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 2 2

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Reversibility of Extent of Impact 1 1 2 2 Impact Duration of 2 2 Probability 2 2 Impact Environmental Risk (Pre-mitigation) -3.50 Mitigation Measures  Demarcate and protect any archaeological sites and heritage sensitive areas near to the prospecting activities. Environmental Risk (Post-mitigation) -3.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 1

Low: Issue not raised in public responses.

Cumulative Impacts 2 Low: Considering the potential incremental, interactive, sequential and synergistic cumulative impacts, it is unlikely that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 1

The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.33 Final Significance -4.67

Impact Name Generation and disposal of waste Alternative Alternative 1 and Alternative 2 Phase Rehab and closure Environmental Risk Pre- Post- Pre- Post- Attribute Attribute mitigation mitigation mitigation mitigation Nature of Impact -1 -1 Magnitude of Impact 3 2 Reversibility of Extent of Impact 2 1 3 2 Impact Duration of 3 2 Probability 3 2 Impact Environmental Risk (Pre-mitigation) -8.25 Mitigation Measures  Any excess or waste material or chemicals, including drilling muds etc. must be removed from the site and must preferably be recycled (e.g. oil and other hydrocarbon waste products).  Any waste materials or chemicals that cannot be recycled must be disposed of at a suitably licensed waste facility.  All permanent facilities must be removed from site upon closure. This will include the associated equipment, material and waste on site.  Under no circumstances is any form of waste to be disposed of on site. Environmental Risk (Post-mitigation) -3.50 Degree of confidence in impact prediction: Medium Impact Prioritisation Public Response 3

High: Issue has received an intense meaningful and justifiable public response.

Cumulative Impacts 1 Medium: Considering the potential incremental, interactive, sequential and synergistic cumulative impacts, it is probable that the impact will result in spatial and temporal cumulative change. Degree of potential irreplaceable loss of resources 1

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The impact is unlikely to result in irreplaceable loss of resources.

Prioritisation Factor 1.17 Final Significance -4.08

Refer to Appendix G for a summary of the full scoring for each of the assessed impacts.

10. MOTIVATION WHERE ALTERNATIVE SITES WERE CONSIDERED

The application area has been selected based on the historical data and geological information available, which indicates the potential for economically viable minerals to occur. The prospecting footprint is expected to be a fraction of the application area size, which is estimated to be 2 069 ha. The geology is the primary driver in determining the location of prospecting. The preferred site (Alternative 1) lies next to the historical and defunct Nkunzana Mine. However, Alternative 1 is located in an area that is highly sensitive. To avoid areas of high sensitivity, it is recommended that the prospecting target areas be relocated to areas of low sensitivity (Alternative 2A – 2D), collectively referred to as Alternative 2 (Figure 6).

11. STATEMENT MOTIVATING THE ALTERNATIVE DEVELOPMENT LOCATION WITHIN THE OVERALL SITE

As discussed above, two site alternatives were identified and assessed in this report, namely Alternative 1 and Alternative 2. The identified impacts were assessed and compared for each alternative. Table 27 provides a comparison of the post-mitigation significance scores applicable to each alternative. Please note that only impacts which are likely to result in different impact significance scores for the alternatives have been included. All other impacts were assessed to have a similar significance regardless of the alternative selected.

Table 27: Comparative assessment of alternatives.

Final Impact Significance Impact Alternative 1 Alternative 2

Planning Phase Disturbance/damage/destruction of the King Cetshwayo Grave -23.33 -16.25 Construction Phase Loss and fragmentation of the vegetation community -18.33 -11.25 Displacement of faunal community (including threatened or protected -14.67 -10.00 species) due to habitat loss, disturbance and/or direct mortalities Increased runoff and sedimentation -10.67 -9.00 Degradation and/or destruction of wetland habitats -4.67 -3.00 Operation Phase Degradation and/or destruction of wetland habitats -4.00 -2.50 Discovery of economically viable minerals 31.67 24.00 Continued encroachment and displacement of an indigenous and -10.13 -6.00 vulnerable vegetation community by alien invasive species

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Final Impact Significance Impact Alternative 1 Alternative 2

Continued displacement and fragmentation of the faunal community (including threatened or protected species) due to(litter, road mortalities, -9.00 -6.00 poaching) Decommissioning Phase Continued encroachment and displacement of an indigenous and -6.00 -5.83 vulnerable vegetation community by alien invasive plant species Continued displacement of the faunal community (including threatened or protected species) due to on-going anthropogenic disturbances and habitat -6.67 -5.33 degradation (litter, road mortalities, poaching) Disturbance/damage/destruction of heritage sensitive areas -4.67 -4.00 Rehabilitation and Closure Phase Encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive species, potential re-establishment -8.00 -5.33 of natural species that were removed, the nature of the erosion will depend on the amount of successful vegetation establishment Disturbance/damage/destruction of heritage sensitive areas -1.50 -2.50 Disturbance/damage/destruction of the King Cetshwayo Grave -5.33 -4.67 TOTAL -95.3 -67.66

Based on the findings of the specialist studies and this assessment, it is recommended the proposed invasive prospecting activities be relocated from Alternative 1 to Alternative 2 (lower sensitivity areas within the Prospecting Right application area).

12. FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY, ASSESS AND RANK THE IMPACTS AND RISKS THE ACTIVITY WILL IMPOSE ON THE PREFERRED SITE (IN RESPECT OF THE FINAL SITE LAYOUT PLAN) THROUGH THE LIFE OF THE ACTIVITY

The impact assessment process may be summarised as follows:

 Identification of proposed prospecting activities including their nature and duration.  Screening of activities likely to result in impacts or risks.  Utilisation of the above mentioned methodology to assess and score preliminary impacts and risks identified.  Inclusion of I&AP comment regarding impact identification and assessment.  Finalisation of impact identification and scoring.

13. IMPACT ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND RISK

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Table 28: Impact significance table.

Pre- Post- Final Impact Alternative Phase Mitigation Mitigation Score ER ER

Planning Phase

Safety and security risks to landowners and lawful occupiers Alternative 1 Planning -6.75 -3.50 -4.08

Safety and security risks to landowners and lawful occupiers Alternative 2 Planning -6.75 -3.50 -4.08

Interference with existing land uses Alternative 1 Planning -7.50 -5.25 -5.25

Interference with existing land uses Alternative 2 Planning -7.50 -5.25 -5.25

Disturbance/damage/destruction of the King Cetshwayo Grave Alternative 1 Planning -23.33 -14.00 -18.00

Disturbance/damage/destruction of the King Cetshwayo Grave Alternative 2 Planning -15.00 -9.75 -16.25

Construction Phase

Safety and security risks to landowners and lawful occupiers Alternative 1 Construction -8.25 -4.00 -4.67

Safety and security risks to landowners and lawful occupiers Alternative 2 Construction -8.25 -4.00 -4.67

Interference with existing land uses Alternative 1 Construction -8.25 -3.00 -3.50

Interference with existing land uses Alternative 2 Construction -8.25 -3.00 -3.50

Sense of place Alternative 1 Construction -8.25 -4.50 -4.50

Sense of place Alternative 2 Construction -8.25 -4.50 -4.50

Clearance of vegetation Alternative 1 Construction -11.25 -8.00 -9.33

Clearance of vegetation Alternative 2 Construction -11.25 -8.00 -9.33

Soil compaction Alternative 1 Construction -10.00 -4.00 -4.67

Soil compaction Alternative 2 Construction -10.00 -4.00 -4.67

Noise Alternative 1 Construction -6.75 -3.00 -3.00

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Pre- Post- Final Impact Alternative Phase Mitigation Mitigation Score ER ER

Noise Alternative 2 Construction -6.75 -3.00 -3.00

Fugitive dust emissions Alternative 1 Construction -7.50 -6.00 -6.00

Fugitive dust emissions Alternative 2 Construction -7.50 -6.00 -6.00

Contamination of surface and ground water Alternative 1 Construction -16.00 -9.00 -12.00

Contamination of surface and ground water Alternative 2 Construction -16.00 -9.00 -12.00

Loss and fragmentation of the vegetation community Alternative 1 Construction -16.00 -11.00 -18.33

Loss and fragmentation of the vegetation community Alternative 2 Construction -13.00 -6.75 -11.25

Displacement of faunal community (including threatened or protected species) due to habitat loss, disturbance and/or direct mortalities Alternative 1 Construction -14.00 -8.00 -14.67

Displacement of faunal community (including threatened or protected species) due to habitat loss, disturbance and/or direct mortalities Alternative 2 Construction -8.25 -6.00 -10.00

Increased runoff and sedimentation Alternative 1 Construction -14.00 -8.00 -10.67

Increased runoff and sedimentation Alternative 2 Construction -12.00 -6.75 -9.00

Disturbance/damage/destruction of heritage sensitive areas Alternative 1 Construction -12.00 -4.50 -6.00

Disturbance/damage/destruction of heritage sensitive areas Alternative 2 Construction -7.50 -4.50 -6.00

Disturbance/damage/destruction of the King Cetshwayo Grave Alternative 1 Construction -7.50 -4.50 -6.00

Disturbance/damage/destruction of the King Cetshwayo Grave Alternative 2 Construction -7.50 -4.50 -6.00

Spillage of oils, fuels and chemicals Alternative 1 Construction -11.00 -7.50 -7.50

Spillage of oils, fuels and chemicals Alternative 2 Construction -11.00 -7.50 -7.50

Soil contamination/pollution Alternative 1 Construction -11.00 -7.50 -10.00

Soil contamination/pollution Alternative 2 Construction -11.00 -7.50 -10.00

Degradation and/or destruction of wetland habitats Alternative 1 Construction -6.75 -3.50 -4.67

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Pre- Post- Final Impact Alternative Phase Mitigation Mitigation Score ER ER

Degradation and/or destruction of wetland habitats Alternative 2 Construction -3.50 -3.00 -3.00

Operation Phase

Safety and security risks to landowners and lawful occupiers Alternative 1 Operation -9.00 -6.00 -7.00

Safety and security risks to landowners and lawful occupiers Alternative 2 Operation -9.00 -6.00 -7.00

Interference with existing land uses Alternative 1 Operation -8.25 -6.00 -7.00

Interference with existing land uses Alternative 2 Operation -8.25 -6.00 -7.00

Degradation and/or destruction of wetland habitats Alternative 1 Operation -6.00 -3.00 -4.00

Degradation and/or destruction of wetland habitats Alternative 2 Operation -3.00 -2.50 -2.50

Expropriation of land and displacement of landowners and livestock Alternative 1 Operation -7.50 -4.00 -6.00

Expropriation of land and displacement of landowners and livestock Alternative 2 Operation -7.50 -4.00 -6.00

Job creation Alternative 1 Operation 10.00 15.00 20.00

Job creation Alternative 2 Operation 10.00 15.00 20.00

Perceptions and expectations Alternative 1 Operation -12.50 -9.00 -12.00

Perceptions and expectations Alternative 2 Operation -12.50 -9.00 -12.00

Training of unskilled labourers Alternative 1 Operation 8.00 12.50 14.58

Training of unskilled labourers Alternative 2 Operation 8.00 12.50 14.58

Clearance of vegetation Alternative 1 Operation -12.50 -8.00 -9.33

Clearance of vegetation Alternative 2 Operation -12.50 -8.00 -9.33

Soil compaction Alternative 1 Operation -10.00 -6.00 -7.00

Soil compaction Alternative 2 Operation -10.00 -6.00 -7.00

Soil pollution/contamination Alternative 1 Operation -11.00 -6.00 -8.00

Soil pollution/contamination Alternative 2 Operation -11.00 -6.00 -8.00

Increased runoff and sedimentation Alternative 1 Operation -8.25 -2.25 -3.00

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Pre- Post- Final Impact Alternative Phase Mitigation Mitigation Score ER ER

Increased runoff and sedimentation Alternative 2 Operation -7.50 -2.25 -3.00

Spillage of oils, fuels and chemicals Alternative 1 Operation -12.00 -7.50 -7.50

Spillage of oils, fuels and chemicals Alternative 2 Operation -12.00 -7.50 -7.50

Contamination of surface water and groundwater Alternative 1 Operation -16.00 -9.00 -12.00

Contamination of surface water and groundwater Alternative 2 Operation -16.00 -9.00 -12.00

Fugitive dust emissions Alternative 1 Operation -10.00 -8.25 -8.25

Fugitive dust emissions Alternative 2 Operation -10.00 -8.25 -8.25

Noise Alternative 1 Operation -6.00 -3.00 -3.00

Noise Alternative 2 Operation -6.00 -3.00 -3.00

Disturbance/damage/destruction of heritage sensitive areas Alternative 1 Operation -12.00 -4.00 -5.33

Disturbance/damage/destruction of heritage sensitive areas Alternative 2 Operation -9.00 -4.00 -5.33

Disturbance/damage/destruction of the King Cetshwayo Grave Alternative 1 Operation -8.25 -4.00 -5.33

Disturbance/damage/destruction of the King Cetshwayo Grave Alternative 2 Operation -5.50 -4.00 -5.33

Disturbance/damage/destruction of (Imizi) homesteads Alternative 1 Operation -7.50 -4.50 -4.50

Disturbance/damage/destruction of homesteads Alternative 2 Operation -7.50 -4.50 -4.50

Discovery of economically viable minerals Alternative 1 Operation 20.00 23.75 31.67

Discovery of economically viable minerals Alternative 2 Operation 16.00 18.00 24.00

Continued encroachment and displacement of an indigenous Alternative 1 Operation -15.00 -6.75 -10.13 and vulnerable vegetation community by alien invasive species

Continued encroachment and displacement of an indigenous Alternative 2 Operation -7.50 -4.00 -6.00 and vulnerable vegetation community by alien invasive species

Continued displacement and Alternative 1 Operation -12.00 -6.00 -9.00 fragmentation of the faunal community (including threatened or

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Pre- Post- Final Impact Alternative Phase Mitigation Mitigation Score ER ER protected species) due to ongoing anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching)

Continued displacement and fragmentation of the faunal community (including threatened or Alternative 2 Operation -8.25 -4.00 -6.00 protected species) due to ongoing anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching) Introduction of alien invasive species Alternative 1 Operation -9.00 -3.50 -3.50

Introduction of alien invasive species Alternative 2 Operation -6.00 -3.50 -3.50

Decommissioning Phase

Job creation Alternative 1 Decommissioning 10.00 12.50 18.75

Job creation Alternative 2 Decommissioning 10.00 12.50 18.75

Spillage of oils, fuels and chemicals Alternative 1 Decommissioning -11.00 -6.00 -6.00

Spillage of oils, fuels and chemicals Alternative 2 Decommissioning -11.00 -6.00 -6.00

Noise Alternative 1 Decommissioning -7.50 -3.00 -3.00

Noise Alternative 2 Decommissioning -7.50 -3.00 -3.00

Contamination of groundwater and surface water Alternative 1 Decommissioning -15.00 -7.50 -10.00

Contamination of groundwater and surface water Alternative 2 Decommissioning -15.00 -7.50 -10.00

Fugitive dust emissions Alternative 1 Decommissioning -6.00 -3.00 -3.00

Fugitive dust emissions Alternative 2 Decommissioning -6.00 -3.00 -3.00

Continued encroachment and displacement of an indigenous and Alternative 1 Decommissioning -10.50 -4.50 -6.00 vulnerable vegetation community by alien invasive plant species

Continued encroachment and displacement of an indigenous and Alternative 2 Decommissioning -6.50 -5.00 -5.83 vulnerable vegetation community by alien invasive plant species

Continued displacement of the faunal community (including Alternative 1 Decommissioning -9.00 -4.00 -5.33 threatened or protected species) due to ongoing anthropogenic

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Pre- Post- Final Impact Alternative Phase Mitigation Mitigation Score ER ER disturbances and habitat degradation (litter, road mortalities, poaching)

Continued displacement of the faunal community (including threatened or protected species) due to ongoing anthropogenic Alternative 2 Decommissioning -6.50 -5.00 -6.67 disturbances and habitat degradation (litter, road mortalities, poaching)

Disturbance/damage/destruction of heritage sensitive areas Alternative 1 Decommissioning -4.00 -3.50 -4.67

Disturbance/damage/destruction of heritage sensitive areas Alternative 2 Decommissioning -3.00 -3.00 -4.00

Disturbance/damage/destruction of the King Cetshwayo Grave Alternative 1 Decommissioning -4.00 -4.00 -5.33

Disturbance/damage/destruction of the King Cetshwayo Grave Alternative 2 Decommissioning -4.00 -4.00 -5.33

Rehabilitation and Closure Phase

Encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive species, potential Alternative 1 Rehab and closure -16.00 -6.00 -8.00 re-establishment of natural species that were removed, the nature of the erosion will depend on the amount of successful vegetation establishment

Encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive species, potential re-establishment of natural species that were removed, the nature Alternative 2 Rehab and closure -9.75 -4.00 -5.33 of the erosion will depend on the amount of successful vegetation establishment

Displacement of the faunal community (including threatened or protected species) due to rehabilitation of the anthropogenic disturbances and habitat Alternative 1 Rehab and closure -13.00 -4.00 -5.33 degradation, rehab resulting in the faunal species potentially re- establishing within the area

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Pre- Post- Final Impact Alternative Phase Mitigation Mitigation Score ER ER

Displacement of the faunal community (including threatened or protected species) due to rehabilitation of the anthropogenic disturbances and habitat Alternative 2 Rehab and closure -9.75 -4.00 -5.33 degradation, rehab resulting in the faunal species potentially re- establishing within the area

Soil instability Alternative 1 Rehab and closure -6.00 -3.50 -4.67

Soil instability Alternative 2 Rehab and closure -6.00 -3.50 -4.67

Increased runoff and sedimentation Alternative 1 Rehab and closure -8.25 -2.25 -3.00

Increased runoff and sedimentation Alternative 2 Rehab and closure -7.50 -2.25 -3.00

Soil pollution/contamination Alternative 1 Rehab and closure -6.00 -3.50 -4.67

Soil pollution/contamination Alternative 2 Rehab and closure -6.00 -3.50 -4.67

Disturbance/damage/destruction of heritage sensitive areas Alternative 1 Rehab and closure -3.00 -1.50 -1.50

Disturbance/damage/destruction of heritage sensitive areas Alternative 2 Rehab and closure -2.50 -2.50 -2.50

Disturbance/damage/destruction of the King Cetshwayo grave Alternative 1 Rehab and closure -4.00 -4.00 -5.33

Disturbance/damage/destruction of the King Cetshwayo grave Alternative 2 Rehab and closure -3.50 -3.50 -4.67

Generation and disposal of waste Alternative 1 Rehab and closure -8.25 -3.50 -4.08

Generation and disposal of waste Alternative 2 Rehab and closure -8.25 -3.50 -4.08

Refer to Appendix G for a summary of the full scoring for each of the assessed impacts.

14. SUMMARY OF SPECIALIST REPORTS

Ecological and Wetland Assessment The project area is in a fairly pristine condition and has been minimally altered both historically and at present. Current impacts include secondary roads, the proximity of rural developments and associated human activity, including: dumping of rubble, livestock, litter and infringement by people and livestock into natural areas via footprints and roads. However, despite these impacts, the remaining natural habitats, which cover the majority of the project area, exhibit healthy ecological functionality, integrity and an appropriate balance between various herbaceous plants and associated fauna. This diversity is indicative of the importance of these systems to collectively provide refugia, food and corridors for dispersal in and through the surrounding area.

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 The proposed prospecting area is situated within identified CBAs (Irreplaceable and Optimal) borders the Nkandla Forest Reserve Complex (a vulnerable forest type). Field surveys confirmed the integrity of this CBA, as well as the presence of multiple threatened species.  The prospecting right area falls within the 5 km buffer which is recommended around protected areas.  According to the NBA (2011) terrestrial ecosystem threat status, the project area covers two ecosystems, which are listed as Vulnerable (VU) and Least Threatened (LT), the former making up the majority of the project area.  The project area is situated across several different vegetation types, namely (i) Moist Coast Hinterland Grassland (Gs20) (which constitutes the majority of the area), (ii) Eastern Valley Bushveld (SVs 6), (iii) Scarp Forest (FOz 5) and(iv) Midlands Mistbelt Grassland (Gs9) (Mucina and Rutherford, 2006).  One (1) protected tree species was recorded in the project area as well as eight (8) invasive plant species.  The project area falls within the Pongola-Mtamvuna Water Management Area which includes rivers such as the Pongola, Mhlatuze, Mfolozi, Mkuze, Thukela, Mvoti, Umgeni, Umkomazi, Umzimkulu and Mtamvuna rivers. The Pongola-Mtamvuna Water Management Area comprises 21 tertiary catchment areas, and the application area is specifically situated in the V40D Quaternary Catchment.  One (1) Freshwater Ecosystem Priority Area (FEPA) river occurs within and around the project area, namely the Nsuze River. In addition, various non-perennial streams occur within the application area which ultimately feed into the Nsuze River.  One (1) wetland unit (the channelled valley bottom (HGM 1)) was identified within the application area. The wetland buffer zone tool was utilised to calculate the appropriate buffer required for prospecting. The required buffers after mitigation measures have been applied were found to be 25 m for the construction phase and 15 m for the operational phase. Therefore, prospecting activities will have moderate to low impacts on the identified wetland.  Eight (8) mammal species, four (4) reptile species and six (6) amphibian species were observed and recorded in the project area.  Sixty-three (63) bird species were recorded in the project area. Three (3) avifaunal (bird) Species of Conservation Concern (SCC) were recorded during the survey, namely African Crowned Eagle, spotted Ground-thrush and Martial Eagle, and based on the presence of pristine, suitable habitat, and the nearby Nkandla Forest, there is a high probability that other bird SCC occur within the project area and may be affected by the proposed prospecting activities.

 No archaeological and built environment heritage resources were identified along the ridge where the proposed six drillholes and trenches are located.

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 A total of five cemeteries and one possible cemetery were identified. The possible cemetery is located in a thick vegetated area known to have been occupied by the Nzuza family who are also buried in the area.  Thee identified cemetery sites, including the possible site, are graded to be of High heritage significance.  The five cemeteries, including the possible cemetery, have been allocated the following Unique Site Reference Numbers (USRN): o Nku-Cem 01. o Nku-Cem 02. o Nku-Cem 03. o Nku-Cem 04 (possible cemetery). o Nku-Cem 05. o Nku-Cem 06 (King Cetshwayo Grave).

 Nku-Cem 01, Nku-Cem 02 and Nku-Cem 06 will not be directly impacted by the proposed prospecting activities as they are located a distance away from the proposed activities and associated infrastructure. Nku-Cem 03, Nku-Cem 04 and Nku-Ce05 are more at risk to be affected by the proposed prospecting activities.  The presence of the King Cetshwayo grave (Nku-Cem 06) within the application area might raise alarms for both Amafa KwaZulu-Natal and the Royal House. Royal burial grounds are accorded a significant status in the province and the matter will have to be dealt with in a very sensitive, socio-cultural and political manner.  The surface geology of the receiving environment consists of rocks of the Namaqua-Natal Metamorphic Complex. These rocks are not known to contain palaeontological fossils. Therefore, there is no need to conduct any other palaeontological studies or have a monitoring programme to rescue palaeontological resources during invasive prospecting activities. According to the Palaeontological Sensitivity Map developed by the South African Heritage Resources Agency, the area is classified as non-sensitive.

15. ENVIRONMENTAL IMPACT STATEMENT

Based on the impact assessment conducted by the various specialists, the environmental impacts associated with the prospecting activities are expected to be localised and of low to medium significance, with one impact being of high significance in the planning phase, if mitigation measures are implemented. Mitigation measures have been recommended by the EAP and specialists in order to eliminate and/or reduce environmental impacts. These mitigation measures and monitoring programmes have been included as commitment in the Environmental Management Programme. The Environmental Management Programme aims to present management measures that will eliminate, offset or reduce adverse environmental impacts, as well as to provide the framework from environmental monitoring. The primary purpose of the Environmental Management Programme is to ensure that negative environmental impacts of the proposed project are effectively managed within acceptable limits and that the positive impacts are enhanced.

In terms of site sensitivities, the most sensitive features which will require protection on site may be summarised as follows:  Critical Biodiversity Areas.  Ecological Support Areas.

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 Protected Areas.  Important Bird Areas.  National Freshwater Ecosystem Priority Areas.  Watercourses and wetlands.  Heritage sites (cemeteries).

In terms of positive impacts, the identification of mineral deposits within the application area provides an opportunity for a potential viable economic activity in the form of mining. Mining will contribute greatly for local economic stimulation through direct employment, future business opportunities, royalties and tax revenues.

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16. FINAL SITE MAP

Figure 33: Composite map of the application area.

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17. SUMMARY OF POSITIVE AND NEGATIVE IMPLICATIONS AND RISKS

The positive implications of the Nkunzana Prospecting Right are (i) job creation during prospecting operations, (ii) training of unskilled labourers prior to commencement of prospecting operations and (iii) discovery of economically viable mineral resources. In terms negative impacts, a number of potential environmental risks on surface water, groundwater, heritage features and ecology were identified and include the following:  Safety and security risks to landowners and lawful occupiers.  Interference with existing land uses.  Sense of place.  Clearance of vegetation  Disturbance/damage/destruction of the King Cetshwayo Grave.  Disturbance/damage/destruction of heritage sensitive areas.  Noise.  Fugitive dust emissions.  Soil compaction.  Soil instability.  Spillage of oils, fuels and chemicals.  Displacement of landowners.  Encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive species.  Displacement and fragmentation of the faunal community (including threatened or protected species) due to on-going anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching).  Introduction of alien invasive species.  Contamination of surface and groundwater.  Degradation and/or destruction of wetland habitats.  Loss and fragmentation of the vegetation community.  Displacement of faunal community (including threatened or protected species) due to habitat loss, disturbance and/or direct mortalities.  Increased runoff and sedimentation.  Soil contamination/pollution.  Perceptions and expectations.  Disturbance/damage/destruction of homesteads.  Generation and disposal of waste. 18. PROPOSED IMPACT MANAGEMENT OBJECTIVES AND OUTCOMES

The following potential mitigation measures and residual risks apply to both the preferred prospecting site and the alternative prospecting site, and have been provided for each environmental aspect assessed. This report was made available to I&APs for review and comment, and their comments and concerns are addressed in this final report that is submitted to the DMR for their decision-making.

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Safety and security risks to landowners and lawful occupiers:  Ensure prospecting is consistent with occupational health and safety requirements.  Prior to accessing any portion of land, the Applicant must enter into formal written agreements with the affected landowner. This formal agreement should additionally stipulate landowner‟s special conditions which would form a legally binding agreement.  All homestead gates must be closed immediately upon entry/exit.  All vehicles using public roads must be in a roadworthy condition and their loads secured. Speed limits must be adhered to and all local, provincial and national regulations with regards to road safety and transport.

Interference with existing and uses:  The Applicant must enter into formal written agreements with the affected landowners and provide compensation for any loss of revenue due to the prospecting activities.  Avoid farm lands actively used for farming.  Ensure that negotiations on compensation are undertaken before invasive activities can commence. This will include any other conditions that the landowner may deem necessary for the prospecting operation.  Use sites that are unused and that re in the degraded state.

Sense of place:  The Applicant must enter into formal written agreements with the affected landowners and provide compensation for any loss of revenue due to the prospecting activities.

Perceptions and expectations:  Ensure that service detection or identification is undertaken prior to invasive prospecting activities commencing.  Adhere to an open and transparent communication procedure with stakeholders at all times.  Ensure that accurate and regular information is communicated to I&APs.  Ensure that information is communicated in a manner which is understandable and accessible to I&APs.  Enhance project benefits and minimise negative impacts through intensive consultation with stakeholders.  Assemble adequate, accurate, appropriate, and relevant socio-economic information relating to the context of the operation.

Training of unskilled labourers:  Where possible, the Applicant and contractors will source local unskilled labourers to train.

Expropriation of land and displacement of landowners:  Ensure that negotiations on compensation are undertaken before invasive activities can commence. This will include any other conditions that the landowner may deem necessary for the prospecting operation.

Job creation:  Where possible, the Applicant and contractors will source local labour however the number of jobs would not be substantial and duration thereof would be short lived.

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Discovery of economically viable minerals:  None.

Clearance of vegetation:  Minimise clearing to areas that are required for invasive works. Where possible, cut vegetation instead of clearing to minimise soil disturbance.  Where possible, locate drill sites and trenches as close to existing access roads to minimise the extent of vegetation disturbance caused by temporary access roads.  Rehabilitate all disturbed areas following invasive prospecting activities to the conditions that existed prior to prospecting.

Soil compaction:  All areas that are compacted as a result of prospecting activities must be assessed by the ECO and where necessary, scarifying must take place to loosen the soil.

Soil contamination/pollution:  Drip trays must be placed under vehicles.  Drilling fluids (mud) must be contained in the steel sumps and any spills or leaks must be cleaned up.  Machinery to be used for the operation will be of good working conditions.  Any hydrocarbon spill from the site establishment will be remediated as soon as possible.

Increased runoff and sedimentation:  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated.  Clearing of vegetation or topsoil must be minimised as far as possible.  A suitably qualified specialist must monitor that no drilling and trenching are undertaken on or within 100 m of a watercourse and within the 1:100 year of a floodline.  All disturbed areas must be suitably rehabilitated on completion of the works to ensure that erosion does not occur.

Spillage of oils, fuels and chemicals:  Drip trays must be placed under vehicles.  Any spills or leaks must immediately be cleaned up and the contaminated soil suitably disposed of.  During refuelling of vehicles or equipment, drip trays must be utilised to prevent spills or leaks.  Spill clean-up equipment must be available on site at all times.  In the event of large spills, this must be reported to the authorities and a specialist spill contractor immediately sought to assist with the clean-up.

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Contamination of surface and groundwater:  Ensure that detailed baseline water quality and quantity samples are obtained and analysed for reference purposes.  Ensure that all mitigation measures as stipulated in the EMPR relating to the Diamond Core drilling (specifically technical specifications) as well as the MPRDA regulations are adhered to.  It is proposed that the following conditions for Environmental Authorisation is set from a groundwater perspective: o No development should take place within 100 m of the rivers and streams. o No drillholes should be drilled in the immediate vicinity of any existing private boreholes that are in use. If this cannot be avoided, the landowner should be provided with an alternative borehole or water resource.

Fugitive Emissions (Dust):  All vehicles utilising public gravel roads must adhere to the speed limits.  By minimising the removal of vegetation and topsoil in affected area, this will minimise the potential for dusty conditions.  Prospecting activities (including drill and trench sites) must be located away from dwellings as far as possible.

Noise:  All vehicles and machinery must be maintained in good working order.  When working or traveling past noise sensitive receptors, no unnecessary hooting or noise should occur.

Disturbance/damage/destruction of archaeological sites and heritage sensitive areas:  It is proposed that a 20 m buffer be maintained around cemeteries and that no material be placed near the cemeteries. The prospecting site should also be located a distance away from the cemeteries.  Demarcate and protect any archaeological sites and heritage sensitive areas near to the prospecting activities.

Disturbance/damage/destruction of the King Cetshwayo grave:  Demarcate and protect any archaeological sites and heritage sensitive areas near the prospecting activities.  At least a 20 m buffer must be established from cemeteries.  Although the grave site is situated a distance from the ridge proposed for prospecting activity, it has a high-risk impact. To mitigate the risks – the project proponent to should develop a form written letter to Amafa and the Royal House to guarantee that there will be no prospecting in the area around the grave of King Cetshwayo and that the prospecting will only be limited to the ridge located east of the Nkunzana River. This letter will ensure that during the assessment of the current HIA document, the project is not taken out of context and be equated to mining in the area. It will also ensure that the issue of prospecting is not politicised.  It is recommended that no machinery should be placed near the grave of „Isilo‟ King Cetshwayo site. The site is situated 1.5 km from the current proposed prospecting activities. However, to avoid any false alarms, no machinery should be place near the grave site of Isilo or site camp be established near the burial site of Isilo.

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Disturbance/damage/destruction of homestead (Imizi) structures:  All heritage structures must be suitably identified prior to invasive prospecting works proceeding and suitably demarcated and avoided.

Displacement of faunal community (including threatened or protected species) due to habitat loss, disturbance and/or direct mortalities:

 No more than two weeks in advance of any vegetation clearance that will commence during the breeding season a qualified Zoologist must conduct a pre-prospecting survey of all potential special- status birds nesting habitat in the vicinity of the project area, and within the project area.  If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.  During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas.  Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery.  Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals.  No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals.  Staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process.  Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling and servicing of equipment is to take place in demarcated areas outside of the project area.

Encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive species, potential re-establishment of natural species that were removed, the nature of the erosion will depend on the amount of successful vegetation establishment:  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity. As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted (this is not plausible given the current, pristine ecological condition). It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora.

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 Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further or used as an area for dumping of waste.  Due to the sensitivity of the soil layer, the steep topography and the associated high risk of erosion, the unpaved access road should be constructed during the dry season and ideally all prospecting should occur only in this season in order to prevent all run-off and erosion.  All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion.  Appropriate speed humps and mitre drains must be constructed along the road for every three metres of elevation in order to slow the flow of water run-off from the road surface. All methods to slow the flow of water off the road surface must be implemented and the feasibility of building an attenuation system to hold surface water and release it slowly into the surrounding environment must be investigated;  Drilling areas and dumping areas should completely avoid any trees, where possible (especially any protected tree species).  An experienced road engineer must be consulted during the planning, construction and closure phases for the development of the unpaved access road.  The areas rated as highly sensitive in the project area as defined in this report should be declared a „“No-Go”‟ area during the construction and operational phases and all efforts must be made to prevent access to this area from workers, machinery, domestic animals and the general public.  Where possible, existing access routes and walking paths must be made use of, and new routes limited.  All laydown, storage areas etc. should be restricted to within the project area.  A qualified environmental control officer must be on site when prospecting begins to identify species that will be directly disturbed and to relocate fauna/flora that is found during prospecting (including all reptiles and amphibians).  All livestock (including cattle, pigs, goats, domestic dogs and cats) must be kept out of the project area at all times.  All staff and visitors to the site must undergo and extensive induction process and must be made aware of the sensitive nature of the environment and floral species which occur there.  Rehabilitation of the trenches and unpaved access road must be made a priority (and be concurrent). Due to the sensitive nature of the soil layer and extreme risk of erosion, rehabilitation must include refilling of the open trenches with appropriate rock and soils and suitably compacted. Top soils must also be utilised, and the area must be re-vegetated with plant and grass species which are endemic to this exact vegetation type: o Rehabilitation measures that are implemented must be continually monitored for a minimum period of four years to ensure that proper succession has occurred and that there is no erosion occurring.  Areas that are denuded during prospecting need to be re-vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species.  Compilation of and implementation of an alien vegetation management plan for the entire site.

Displacement and fragmentation of the faunal community (including threatened or protected species) due to on-going anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching):  No more than two weeks in advance of any vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey

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of all potential special-status birds nesting habitat in the vicinity of the project area, and within the project area: o If active nests are found, avoidance procedures must be implemented on a case-by-case basis. Avoidance procedures may include the implementation of buffer zones, relocation of birds, or seasonal avoidance. If buffers are created, a no disturbance zone must be created around active nests during the breeding season by a suitably qualified Zoologist.  Similarly, regarding amphibians, no more than two weeks in advance of vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status amphibians that may be calling within the project area. This person should have specialist knowledge of the Plain Stream Frog, Spotted Shovel Snout and Natal Leaf Folding Frog.  Any individuals found should be relocated to a suitable area that is undisturbed, such as the nearby Nkandla Forest Reserve.  In additional to this the following measures are recommended: o If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate specialist should be consulted to identify the correct course of action. o The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on fauna and flora. o During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas. o Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery. o Fauna species such as frogs and reptiles that have not moved away should be carefully and safely removed to a suitable location beyond the extent of the development footprint by a suitably qualified ECO trained in the handling and relocation of animals. o Fencing should be erected around the project area to prevent workers and members of the public from entering the surrounding farm portions and environments. This fence should have small openings to allow wildlife to pass through. o Waste management must be a priority and all waste must be collected and stored adequately. It is recommended that all waste be removed from site on a weekly basis to prevent rodents and pests entering the site. o No trapping, killing or poisoning of any wildlife is to be allowed on site, including snakes, birds, lizards, frogs, insects or mammals. o During the construction phase noise must be kept to an absolute minimum to reduce the impact of the development on the fauna residing on the site. o Furthermore, during the operational phase, noise must be kept to an absolute minimum during the evenings and at night to minimise all possible disturbances to amphibian species and nocturnal mammals. o Staff should be educated about the sensitivity of faunal species and measures should be put in place to deal with any species that are encountered during the prospecting process.

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o The avoidance and protection of the river and forest areas must be included into a site induction. Contractors and employees must all undergo the induction and made aware of the sensitive areas to be avoided. o The induction must include a focus on amphibian, bird and reptile species, especially known SCC that may occur within the project area.

o Prospecting activities and vehicles could cause spillages of lubricants, fuels and material which could then be transported to river, impacting on the water quality and potentially the functioning of the systems. All vehicles and equipment must be maintained and all re-fuelling

and servicing of equipment is to take place in demarcated areas outside of the project area.

Loss and fragmentation of the vegetation community:  Prior to the commencement of invasive prospecting activities, an Ecology survey must be done to verify areas of high sensitivity. As far as possible, the proposed prospecting should be placed in areas that have already been disturbed, and no further loss of primary or secondary vegetation should be permitted (this is not plausible given the current, pristine ecological condition). It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon (including fencing off the defined project area) and preventing movement of workers into sensitive forest ecotones.  The duration of the prospecting should be minimised to as short term as possible, in order to reduce the period of disturbance on flora.  Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further or used as an area for dumping of waste.

Introduction of alien species:  Undertake activities in previously disturbed areas.  Locate activities on the boundaries of existing disturbance.  Use existing access roads as much as possible.  Rehabilitate disturbed areas as soon as possible.  Manage alien plants within close proximity to prospecting activities.

Soil instability:  Reinstate the topography to match the surroundings.  Reinstate vegetation cover to match the surroundings.  Monitor the reinstated areas to ensure that erosion does not occur.  Any contaminated soils are to be collected and removed from site and suitably disposed of.  Vegetation regrowth must be monitored to ensure that it matches the surrounding areas.

Generation and disposal of waste  Any excess or waste material or chemicals, including drilling muds etc. must be removed from the site and must preferably be recycled (e.g. oil and other hydrocarbon waste products).  Any waste materials or chemicals that cannot be recycled must be disposed of at a suitably licensed waste facility.  All permanent facilities must be removed from site upon closure. This will include the associated equipment, material and waste on site.  Under no circumstances is any form of waste to be disposed of on site.

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19. ASPECTS FOR INCLUSION AS CONDITIONS OF AUTHORISATION

 The approval of the project is for prospecting only. The approval excludes any mining activities.  Areas of high ecological and heritage sensitivity must be regarded as “No-Go” areas.  The Applicant is to appoint a suitably qualified Environmental Control Officer (ECO) who must oversee the invasive prospecting activities and monitor compliance with the EMPR and relevant legislation.  The 1 km buffer zone around the Nkandla Nature Reserve must be regarded as a no go area for invasive prospecting activities.  A 100 m buffer zone around watercourses must be regarded as a no go area for invasive prospecting activities.  A 50 m buffer zone around existing structures (such as homesteads, dwellings; cultivated fields, gravesites, any fences, etc.) must be regarded as no go areas for invasive prospecting activities.  Stakeholder engagement will continue throughout the prospecting activities to ensure the community and landowners are kept informed and allowed to raise issues. These issues will then be addressed through a grievance mechanism.  Arrangements for financial provision for the decommissioning, closure and rehabilitation must be made.  The Applicant should adhere to the conditions of the EA, EMPR and the specialist reports for this project.

20. DESCRIPTION OF ANY ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE

Certain assumptions, limitations, and uncertainties are associated with the BAR. These are detailed for each aspect below:

20.1 Heritage and Palaeontological Assessment The following assumptions, limitations and gaps in knowledge apply to this assessment:

 The BAR Public Participation Process will address issues of heritage consent and Interested and Affected Parties (I&APs) will be allowed space to provide input towards the strengthening of this Heritage Impact Assessment document should there be such requirements from the I&APs.  The identified heritage resources represent the total number of heritage resources within the prospecting footprint with exception to those resources that are subterranean in nature such as the unmarked burial grounds and graves.  The area that is marked as a potential cemetery site which could not be properly surveyed due to thick vegetation cover does represent a place of a former homestead and will definitely contain graves.  In the case of subterranean resources, if any such resources, not visible on the earth‟s surface are discovered during prospecting activities they will be treated as chance finds. However, it is generally assumed that the EAP will ensure that it implements all heritage specialist recommendations which include appointing an archaeologist to monitor prospecting activities for the proposed unpaved access road as well as site clearing in the eastern portion of the affected ridge.

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20.2 Ecology and Wetland Assessment The following assumptions, limitations and gaps in knowledge apply to this assessment:

 As per the scope of work, the fieldwork component of the assessment comprised of one assessment only, which was conducted during the late-wet season. This study has not assessed any temporal trends for the respective seasons.  The proposed Prospecting Right application and Environmental Authorisation, if successful, is only applicable to the areas and impacts outlined in this report. If the prospecting finds economically feasible and mineable resources, a Mining Right application will need to be applied for and a full environmental impact assessment will need to be conducted.  The assessment was based on the results of a single wetland survey only, and information provided should be interpreted accordingly.  Field assessments were completed to assess as much of the site as possible with focus on the proposed directly impacted and downstream areas.  Many wetland plants had shed their flowering portions and could not be identified.  The GPS used for water resource delineations is accurate to within five meters. Therefore, the wetland delineation plotted digitally may be offset by at least five meters to either side.

21. REASONED OPINION AS TO WHETHER THE PROPOSED ACTIVITY SHOULD OR SHOULD NOT BE AUTHORISED

Should prospecting prove successful and a resource quantified, it would indicate a potential viable economic activity in the form of mining. Mining will contribute greatly to the socio-economic status quo in the form of increased income, employment and other benefits that would cascade through the local, regional and national levels.

The EMPR aims to present management measures that will eliminate, offset or reduce adverse environmental impacts, as well as to provide the framework for environmental monitoring.

Based on the impact assessment, the recommended Alternative Prospecting Site (Alternative 2), as well as the mitigation measures put forward in this report, it is the opinion of the EAP that this activity should be authorised with the conditions attached.

22. PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED

The Environmental Authorisation is required for five (5) years.

23. UNDERTAKING

It is confirmed that the undertaking required to meet the requirements of this section is provided at the end of the EMPR and is applicable to both the BAR and the EMPR.

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24. FINANCIAL PROVISION

The Regulations pertaining to the Financial Provision for Prospecting, Mining and Production Operations promulgated under Section 44(A) (e), (f), (g), (h) read with sections 24(5)(b)(ix), 24(5)(d), 24N, 24P and 24R of the National Environmental Management Act, 1998 (Act 107 of 1998) (20 November 2015) have been considered and this is anticipated to result in an increase in the rehabilitation costs estimated using the above mentioned quantum.

The amount that is required to both manage and rehabilitate the environment in respect of rehabilitation is reflected in the quantum of financial provision in Section 35 (Part B) of the report. 25. SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY

No additional information has been requested from the Competent Authority.

26. COMPLIANCE WITH THE PROVISIONS OF SECTIONS 24(4)(A) AND (B) READ WITH SECTION 24(3)(A) AND (7) OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (ACT 107 OF 1998) THE BAR REPORT MUST INCLUDE THE:

26.1 IMPACT ON THE SOCIO-ECONOMIC CONDITIONS OF ANY DIRECTLY AFFECTED PERSON

The potential impacts on the socio-economic conditions have the potential to include:

 Safety and security risks to landowners and lawful occupiers:

o The potential exists for a group of unfamiliar workers to enter the project area during the prospecting activities. This impact could potentially affect the local communities. However, the impact will be minimal as people on site will be limited to the Applicant, contractors and geologists.

 Interference with existing land uses:

o Access to the application area when conducting prospecting activities will be required which may interrupt the existing land uses, such as livestock grazing, residential developments and game activities. However, this impact will be minimal as no heavy equipment will be brought on site and it is of short duration.

 Perceptions and expectations:

o The proposed Prospecting Right may create interest, particularly in the potential for employment and concerns over damage to natural resources. However, the impact will be minimal as there will be on-going, open and transparent communication with affected stakeholders, communities and landowners.

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 Expropriation of land and displacement of landowners:

o At present this impact is not anticipated and is considered improbable. However, should it occur, negotiations with affected landowners will be undertaken and any loss of revenue caused by the prospecting works will be reasonably compensated in order to minimise this impact.

 Job creation

o Where possible, the Applicant and contractors will source local labour. This will enable the use of the local labour force and as such create employment for locals. Due to the technical skills required to undertake prospecting works, the number of jobs would not be substantial and duration thereof would be short lived. In this regard, the nature of this impact is rated as positive. However, the significance thereof is relatively low.

 Discovery of economically viable minerals

o Should prospecting prove successful and a resource quantified, it would indicate a potential for a viable economic activity in the form of mining. Mining will contribute greatly for local economic stimulation through direct employment, future business opportunities, royalties and tax revenues.

The consultation process will allow directly affected parties to raise their concerns. Further to this, it must be noted that I&APs, including directly affected parties such as landowners, were given the opportunity to review and comment on the draft BAR+EMPR. The results of the public consultation have been included in the final report submitted to the Department for adjudication.

26.2 IMPACT ON ANY NATIONAL ESTATE REFERRED TO IN SECTION 3(2) OF THE NATIONAL HERITAGE RESOURCES ACT

Notice of the proposed Prospecting Right Application has been uploaded onto the South African Heritage Resources Agency‟s (SAHRA) website, South African Heritage Information System (SAHRIS). At this stage no comments regarding the draft BAR+EMPR have been received.

27. OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A) AND (B) OF THE ACT

There are no other matters required in terms of Section 24(4)(A) and (B) of the Act.

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PART B: ENVIRONMENTAL MANAGEMENT PROGRAMME

28. INTRODUCTION 28.1 DETAILS OF THE EAP

The details and expertise of the EAP are detailed in Sections 1.3 and 1.4 above as required.

28.2 DESCRIPTION OF THE ASPECTS OF THE ACTIVITY

A description of the aspects of the activity covered by the EMPR below is included in Section 2 above. 29. ENVIRONMENTAL MANAGEMENT PRINCIPLES

It is extremely important for effective environmental management that the Applicant be aware of the general principles upon which sound environmental management is based and that these principles are considered in all aspects of the prospecting operation. NEMA has established a general framework for environmental law, in part by prescribing national environmental management principles that must be applied when making decisions that may have a significant impact on the environment. These principles are briefly summarised in the sections that follow.

29.1 HOLISTIC PRINCIPLE

The Holistic principle, as defined by NEMA (Section 2(4)(b) requires that environmental management must be integrated, acknowledging that all elements of the environment are linked and inter-related and it must take into account the effect of decisions on all aspects of the environment and all people in the environment by pursuing the selection of the best practicable environmental option (defined below). Holistic evaluation does not mean that a project must be looked at as a whole. It rather means that it must be accepted that there is a whole into which a project introduced. If the indications are that the project could have major adverse effects, the project must be reconsidered and where appropriate re-planned or relocated to avoid an adverse impact or to ensure a beneficial impact.

29.2 BEST PRACTICABLE ENVIRONMENTAL OPTION

When it is necessary to undertake any action with environmental impacts, the different options that could be considered for the purpose must be identified and defined. The Best Practicable Environmental Option (BPEO) is defined in NEMA as “the option that provides the most benefit or causes the least damage to the environment as a whole, at a cost acceptable to society, in the long term as well as in the short term.” Other guidelines typically used for environmental management in terms of other legislation include: BPM which is the Best Practicable Means and BAT which is the Best Available Technology.

29.3 SUSTAINABLE DEVELOPMENT

The concept of sustainable development was introduced in the 1980‟s with the aim to ensure that the use of natural resources is such that our present needs are provided without compromising the ability of future

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29.4 PREVENTATIVE PRINCIPLES

The preventative principle is fundamental to sustainable development and requires that the disturbance to ecosystems and the pollution, degradation of the environment and negative impacts on the environment be avoided, or, where they cannot be altogether avoided, are minimised and remedied.

29.5 THE PRECAUTIONARY PRINCIPLES

The precautionary principle requires that where there is uncertainty, based on available information, that an impact will be harmful to the environment, it is assumed, as a matter of precaution, that said impact will be harmful to the environment until such time that it can be proven otherwise. The precautionary principle requires that decisions by the private sector, governments, institutions and individuals need to allow for and recognise conditions of uncertainty, particularly with respect to the possible environmental consequences of those decisions. In South Africa, the DWA (then DWAF, now DWS) adopted a BPEO guideline in 1991 for water quality management and in 1994 in the Minimum Requirements document for waste management.

In terms of DWAF Minimum Requirements for the Handling and Disposal of Hazardous Waste, 1994, the precautionary principle is defined as, “Where a risk is unknown; the assumption of the worst case situation and the making of provision for such a situation.” Here the precautionary principle assumes that a waste or an identified contaminant of a waste is “both highly hazardous and toxic until proven otherwise.”

In the context of the EIA process in South Africa, the precautionary principle also translates to a requirement to provide sound, scientifically based, information that is sufficient to provide the decision making authority with reasonable grounds to understand the potential impacts on the environment, the extent thereof and how impacts could be mitigated. If such information is not adequate for this purpose, the relevant authority cannot be satisfied as is required and then the authority should require that further information be collected and provided.

29.6 DUTY OF CARE AND CRADLE TO GRAVE PRINCIPLE

In terms of the NEMA Section 28, “Every person who causes, has caused or may cause significant pollution or degradation of the environment must take reasonable measures to prevent such pollution or degradation from occurring, continuing or recurring, or, in so far as such harm to the environment is authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify such pollution or degradation of the environment.”

By way of example, the principle of “duty of care” in terms of waste management emphasises the responsibility to make sure that waste is correctly stored and correctly transported, as it passes through the chain of custody to final point of disposal. This means that waste must always be stored safely and securely. The company removing and disposing of waste also holds the responsibility to hold the relevant licenses, and that waste is transported alongside the necessary paperwork.

“Cradle to Grave” refers to the responsibility a company takes for the entire life cycle of a product, service or program, from design to disposal or termination. In terms of the DWAF Minimum Requirements for the Handling and Disposal of Hazardous Waste, 1994, “any person who generates, transports, treats or disposes of waste

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Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR must ensure that there is no unauthorised transfer or escape of waste from his control. Such a person must retain documentation describing both the waste and any related transactions. In this way, he retains responsibility for the waste generated or handled.” This places responsibility for a waste on the Generator, and is supported by the "Cradle to Grave" principle, according to which a "manifest" accompanies each load of Hazardous Waste until it is responsibly and legally disposed. This manifest is transferred from one transporter to the next along with the load, should more than one transporter be involved. Once the waste is properly disposed of at a suitable, permitted facility, a copy of the manifest must be returned to the point of origin.” Duty of Care offers one strategy to implement sustainable development.

29.7 POLLUTER PAYS PRINCIPLE

The "polluter pays principle" holds that the person or organisation causing pollution is liable for any costs involved in cleaning it up or rehabilitating its effects. It is noted that the polluter will not always necessarily be the generator, as it is possible for responsibility for the safe handling, treatment or disposal of waste to pass from one competent contracting party to another. The polluter may therefore not be the generator, but could be a disposal site operator or a transporter. Through the 'duty of care' principle, however, the generator will always be one of the parties held accountable for the pollution caused by the waste. Accordingly, the generator must be able to prove that the transferral of management of the waste was a responsible action. The polluter pays principle acceding to NEMA dictates that “the cost of remedying pollution, environmental degradation and consequent adverse effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment.”

29.8 DUTY OF CARE RESPONSIBILITIES

The principle of duty of care is especially important to understand when it comes to pollution that arises as a result of mining. Notwithstanding any licences or permits that may exist, the mine still has a responsibility to take suitable measures should pollution arise as a result of the mining activities.

Training and awareness should be fostered in all staff working to ensure that they can perform their duties. Failure to comply with the provisions in the EMPR and NEMA would be a contravention of the Act. The relevant sections of NEMA are provided below, to outline the duty of care and responsibility that the applicant and all employees have towards the environment. The National Environmental Management Act (Act 107 of 1998) (NEMA) Section 28 makes provision for Duty of care and remediation of environmental damage. The binding principals are described below:  Every person who causes, has caused or may cause significant pollution or degradation of the environment must take reasonable measures to prevent such pollution or degradation from occurring, continuing or recurring, or, in so far as such harm to the environment is authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify such pollution or degradation of the environment.  Without limiting the generality of the duty in subsection (1), the persons on whom subsection (1) imposes an obligation to take reasonable measures, include an owner of land or premises, a person in control of land or premises or a person who has a right to use the land or premises on which or in which- o any activity or process is or was performed or undertaken or o any other situation exists, which causes, has caused or is likely to cause significant pollution or degradation of the environment  The measures required in terms of subsection (1) may include measures to-

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o investigate, assess and evaluate the impact on the environment o inform and educate employees about the environmental risks of their work and the manner in which their tasks must be performed in order to avoid causing significant pollution or degradation of the environment o cease, modify or control any act, activity or process causing the pollution or degradation; o contain or prevent the movement of pollutants or the cause of degradation o eliminate any source of the pollution or degradation or o remedy the effects of the pollution or degradation  No person may- o unlawfully and intentionally or negligently commit any act or omission which causes significant or is likely to cause significant pollution or degradation of the environment o unlawfully and intentionally or negligently commit any act or omission which detrimentally affects or is likely to affect the environment in such manner or o refuse to comply with a directive issued under this section

Any person who contravenes or fails to comply with subsection (14) is guilty of an offence and liable on conviction to a fine not exceeding R1million or to imprisonment for a period not exceeding 1 year or to both such a fine and such imprisonment.

29.9 FAILURE TO COMPLY WITH ENVIRONMENTAL CONSIDERATIONS

Within the provisions of the relevant environmental legislation, there are a number of penalties for non- compliance or offences. Below a few extracts are presented for information purposes, however these must not be read in isolation and the reader is reminded that there are other acts that may be applicable to the relevant project:

 NEMA Section 24F(2): It is an offence for any person to fail to comply with or to contravene the conditions applicable to any environmental authorization granted for that listed activity. 24F(4) A person convicted for an offence under subsection 2 is liable to a fine not exceeding 5 million rand or to imprisonment not exceeding 10 years or to both such a fine and imprisonment  NEMA Section 34(6): Whenever any manager, agent or employee does or omits to do an act which it had been his or her task to do, or to refrain from doing on behalf of the employer and which would be an offence under any provision listed in Schedule 3 (relates to all environmental related acts) for the employer to do or omit to do, he or she shall be liable to be convicted and sentenced in respect thereof as if he or she were the employer  NWA Section 151 (1): “No person may fail to comply with any condition attached to a permitted water use (Water Use License)”  NWA Section 151 (2): “Any person who contravenes any provision of subsection 1 is guilty of an offence and liable, on the first conviction, to a fine or imprisonment for a period not exceeding 5 years or to both a fine and such imprisonment (10 years for second conviction)”  In addition, if anyone is convicted of an offence under the act which has resulted in harm, loss or damage to any other person, the court may award damages to be paid by the accused or convicted  NWA Section 154: Makes provision that it‟s not only the applicant that may be liable but also an employee or agent acting on their behalf  In terms of the MPRDA, Section 98, any person is guilty of an offence if he or she fails to comply with the requirements of the issued mining permit

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 MPRDA Section 99 (1a): any person convicted of an offence in terms of the MPRDA is liable to a fine not exceeding R100, 000 or to imprisonment to a period not exceeding 2 years or to both such fine and imprisonment.

It is recommended that a procedure for non-compliances (i.e. incentives or disincentives for conformance and non-conformance with the EMPR requirements) must be employed to ensure that the EMPR is adequately implemented. The system to be used must be determined before mining commences, included in the tender documents and contracts, and made clear to all project workers. The system may include that the independent ECO can be authorised to impose spot fines on the Contractor and/or his subcontractors for any of the transgressions detailed below:  Littering on site  Lighting of illegal fires on site  Persistent or un-repaired oil leaks  Any persons, vehicles or equipment related to the Contractor‟s operations found within the designated “No – go” areas  Any vehicles being driven in excess of designated speed limits  Removal and/or damage to fauna, flora or heritage objects on site  Legal contraventions

Such fines should be issued in addition to any remedial costs incurred as a result of non-compliance with the Environmental Specifications and or legal obligations.

30. DESCRIPTION OF IMPACT MANAGEMENT OBJECTIVES INCLUDING MANAGEMENT STATEMENTS

30.1 DETERMINATION OF CLOSURE OBJECTIVES

The vision, and consequent objective and targets for rehabilitation, decommissioning and closure, aim to reflect the local environmental and socio-economic context of the project, and to represent both the corporate requirements and the stakeholder expectations.

The receiving environment within which the prospecting activities will be undertaken includes the following key land uses:

 Subsistence farming.  Rural land with associated houses.  Livestock grazing.  Infrastructure such as secondary tar roads, gravel roads as well as homesteads.

Concerns raised by the stakeholders consulted during the public participation process for the basic assessment have been taken into consideration and will be included in the final BAR and EMPR which will be submitted to the DMR.

In practice the post closure land-use will depend on the pre-prospecting land-use applicable to the specific location of the invasive prospecting activities. Considering that the exact locations of the planned prospecting have been identified and assessed, it can be said that the closure plan will sufficiently address the objectives for

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Nkunzana BAR+EMPR KZN 30/5/1/1/2/10722 PR the preferred alternative. This EMP does, however, aim to address the key closure objectives which are likely to remain consistent for the majority of the prospecting activities.

The EMPR includes a monitoring and a rehabilitation plan. The plan shall outline the closure objectives which are aimed at reinstating the landform, land use and vegetation units to the same as before prospecting operations take place unless a specific, reasonable alternate land use is requested by the landowner. As such, the intended end use for the disturbed prospecting areas and the closure objectives will be defined in consultation with the relevant landowner. Proof of such consultation will be submitted together with the Application for Closure Certificate. The overall aim of the rehabilitation plan is to rehabilitate the environment to a condition as close as possible to that which existed prior to prospecting. This shall be achieved with a number of specific objectives.

 Making the area safe. i.e. Decommission prospecting activities so as to ensure that the environment is safe for people and animals. This entails refilling excavations, sealing drillholes, etc.  Recreating a free draining landform. This entails earthworks infilling, reshaping, levelling, etc. to recreate as close as possible the original topography and to ensure a free draining landscape.  Re-vegetation. This involves either reseeding or allowing natural succession depending on the area, climate etc.  Storm water management and erosion control. Management of storm water and prevention of erosion during rehabilitation. E.g. cut off drains, berms etc. and erosion control where required.  Verification of rehabilitation success. Entails monitoring of rehabilitation.  Successful closure. Obtain closure certificate

30.2 VOLUMES AND RATE OF WATER USE REQUIRED FOR THE OPERATION

Limited water will be consumed by the surface dust suppression activities (water mist added for dust suppression when required), approximately <500 litres per day. For diamond drilling, it is estimated that up to 40 000 litres per day could be required.

30.3 HAS A WATER USE LICENCE BEEN APPLIED FOR?

No invasive prospecting activity will occur within identified watercourses. No water use licence has been applied for as part of this this Prospecting Right application, however, it is anticipated that abstraction related water uses may be applicable. It is recommended that this be confirmed with the Department of Water and Sanitation (DWS) prior to commencement of the invasive prospecting activities that require water and should any of the National Water Act (NWA) Section 21 water uses become applicable, then the Applicant will need to apply for the relevant water uses from the DWS prior to undertaking such activities.

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30.4 IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES

Table 29: Impacts to be mitigated. Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

Site clearance  Construction  Up to 1 ha  Maintain a buffer of at least 20 m around heritage sensitive  NEMA  Throughout areas. No material should be placed near these areas construction and  Operation  Short term and  MPRDA operation localised  Sensitive areas should be demarcated, fenced off and  NEMBA treated as “No-Go” areas  NEMAQA  No more than two weeks in advance of any vegetation clearance that will commence during the breeding season  Dust (1 September – 1 March) a qualified Zoologist must conduct regulations a pre-prospecting survey of all potential special-status birds nesting habitat in the vicinity of the project area, and within  NHRA the project area:  NWA

o If active nests are found, avoidance procedures  DWAF Best must be implemented on a case-by-case basis. Practice Avoidance procedures may include the Guidelines implementation of buffer zones, relocation of birds, or seasonal avoidance. If buffers are created, a no disturbance zone must be created around active nests during the breeding season by a suitably qualified Zoologist

 Similarly, regarding amphibians, no more than two weeks in advance of vegetation clearance that will commence during the breeding season (1 September – 1 March) a qualified Zoologist must conduct a pre-prospecting survey of all potential special-status amphibians that may be calling within the project area. This person should have specialist knowledge of the Plain Stream Frog, Spotted Shovel Snout and Natal Leaf Folding Frog

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

 During vegetation clearance, methods should be employed to minimise potential harm to fauna species. Clearing has to take place in a phased and slow manner, commencing from the interior of the site progressing outwards towards the boundary to maximise potential for mobile species to move to adjacent areas

 Prior and during vegetation clearance any larger fauna species noted should be given the opportunity to move away from the machinery

 Identification and relocation of protected species by a qualified ecologist (and application or the relevant biodiversity permits where required)

 Areas of indigenous vegetation, even secondary communities, should under no circumstances be fragmented or disturbed further

 Utilise local labour if possible

 Minimise removal of vegetation. Where possible, cut vegetation instead of clearing to minimise soil disturbance

 Minimise dust generation

 Limit vehicle access

 Implement alien vegetation management

 On-going identification of risks and impacts

 Emergency preparedness

 Monitoring and review

 No trapping, killing or poisoning of any wildlife is to be allowed on site

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

Site access  Construction  2 069.06 ha  All employees and visitors to the site must undergo a site  NEMA  Throughout induction which shall include basic environmental awareness construction and  Operation  Short term and  OSH and and site specific environmental requirements (e.g. site operation localised MHSA sensitivities and relevant protocols/procedures). This induction should be presented or otherwise facilitated by the Contractor‟s Environmental Officer wherever possible

Establishment  Construction  Up to 1 ha  Vehicles and machinery must make use of existing access  NEMA  Throughout of site routes, before adjacent areas are considered for access construction  Short term and  MPRDA infrastructure localised  Contractors used for the project should have spill kits available to ensure that any fuel or oil spills are cleaned up  NEMBA and discarded correctly  NEMAQA  It is preferable that prospecting takes place during the dry season to reduce the erosion potential of the exposed  Dust surfaces regulations  If any faunal species are recorded during prospecting, activities should temporarily cease, and an appropriate  NEMWA specialist should be consulted to identify the correct course of action  NWA

 A qualified ECO must be on site when prospecting begins to  DWAF Best identify species that will be directly disturbed and to relocate Practice fauna/flora that is found during prospecting Guidelines  Minimise physical footprint of prospecting activities  NHRA  Ensure prospecting is consistent with occupational health and safety requirements  Minimise vegetation clearance

 Ensure proper and adequate drainage

 Waste management must be a priority and all waste must be

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

collected and stored adequately. All waste should be removed from site on a weekly basis

 Establish waste storage areas for recycling

 Ensure adequate containment of waste to prevent pollution

 Minimise dust generation

 Limit vehicle access to approved access roads

 Prepare contingency plans for spillage and fire risks

 During the construction phase, noise must be kept to an absolute minimum to reduce the impact of the development on the fauna residing on the site

 Staff should be educated about the sensitivity of faunal species and measures should be put into place to deal with any species that are encountered during the prospecting process

 All necessary road mitigation measures must be put in place to slow (or stop) run-off from the proposed unpaved access road. This is a vital mitigation measure to prevent erosion

Storage of  Construction  Up to 1 ha  Any equipment that may leak and does not have to be  NWA  Throughout construction transported regularly must be placed on watertight drip trays construction and  Operation  Short term and  DWAF Best vehicle to catch any potential spillages of pollutants. The drip trays operation localised Practice must be of a size that the equipment can be placed inside it Guidelines  Drip trays must be cleaned regularly and shall not be allowed to overflow. All spilled hazardous substances must be collected and adequately disposed of at a suitably licensed facility

 Compacting of soil must be avoided as far as possible, and the use of heavy machinery must be restricted in areas

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

outside of the proposed prospecting sites to reduce the compaction of soils

 Storage areas must be beyond the buffer areas

Transportation/  Construction  Up to 1 ha  Where possible, drill sites should be located along existing  NEMA  Throughout access roads to reduce the requirement for additional construction and access to and  Operation  Short term and  NEMBA access roads operation from drill and localised  CARA trench sites  Any new temporary access routes to a drill site should result in minimal disturbance to existing vegetation  NEMAQA

 Prior to accessing any portion of land, the Applicant must  Dust enter into formal written agreements with the affected Regulations landowner. This formal agreement should additionally stipulate landowners special conditions which would form a  Road Traffic legally binding agreement Act

 All property gates must be closed immediately upon entry/exit

 Under no circumstances may the contractor damage any property gates, fences, etc.

 On-site vehicles must be limited to approved access routes and areas on the site so as to minimise excessive environmental disturbance to the soil and vegetation on site, and to minimise disruption of traffic (where relevant)

 All vehicles using public roads must be in a roadworthy condition and their loads secured. They must adhere to the speed limits and all local, provincial and national regulations with regards to road safety and transport

 Damage caused to public roads as a result of the prospecting activities must be repaired in consultation with the relevant municipal authorities

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

 All measures should be implemented to minimise the potential of dust generation

Storage of  Construction  Up to 1 ha  All hazardous substances (e.g. fuel, grease, oil, brake fluid,  NWA  Throughout hydraulic fluid) must be handled, stored and disposed of in a construction and hazardous  Operation  Short term and  DWAF Best safe and responsible manner so as to prevent pollution of operation substances localised Practice the environment or harm to people or animals. Appropriate Guidelines measures must be implemented to prevent spillage and appropriate steps must be taken to prevent pollution in the  NEMWA event of a spill in a way that does not pose any danger of pollution even during times of high rainfall  NEMA

 Adequate spill prevention and clean up procedures should be developed and implemented during the prospecting activities

 Should any major spills of hazardous materials take place, such should be reported in terms of Section 30 of the NEMA

 All chemical and toxicants to be used during prospecting must be stored outside the wetland system and in a bunded area

Waste  Construction  Short term and  Waste generated on site must be recycled as far as  DWAF  Throughout localised possible. Recyclable waste must not be stored on site for Minimum construction and management  Operation excessive periods to reduce risk of environmental requirements operation contamination for waste disposal  Drill muds, formation water (if encountered), etc. would constitute waste and must be classified and ranked in terms  NEMWA of relevant legislation for correct disposal

 A Waste Management System must be implemented, and provide for adequate waste storage (in the form of enclosed containers) waste separation for recycling, and frequent

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

removal of non-recyclable waste for permanent disposal at an appropriately licensed waste disposal facility. No waste material is to be disposed of on site

 Waste must be collected and stored adequately. All waste should be removed from site on a weekly basis to present rodents an pests entering the site

 No dumping of material on-site may take place

 Prospecting  Construction  0.14 ha  Vegetation clearing for prospecting sites should be kept to a  SANS 10103  Throughout drillholes minimum in order to reduce the disturbance footprint construction,  Operation  Short term and  ECA Noise and operation and localised  The duration of the prospecting should be minimised to as Regulations trenches decommissioning short term as possible, in order to reduce the period of  NEMAQA disturbance on fauna and flora  Dust  The recommended buffer zones should be strictly adhered Regulations to. Buffer areas must be visibly demarcated and managed as “No-Go” areas  NWA

 Adequate sanitary ablution facilities on the servitude must be  NEMBA provided for all personnel throughout the project area  OHS and  Have action plans on site, and training of contractors and MHSA employees in the event of spills, leaks and other impacts to the aquatic systems  NEMWA

 Compaction of soil must be avoided as far as possible and the use of heavy machinery must be restricted in areas outside of the proposed prospecting sites to reduce the compaction of soils

 All measures should be implemented to minimise the potential of dust generation

 Local residents should be notified of any potentially noisy

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

activities or work and these activities should be undertaken at reasonable times of the day. These works should not take place at night or on weekends

 Noise attenuation on engines must be adequate and the noisy activities must be restricted as far as is possible to times and locations whereby the potential for noise nuisance is reduced

 When working near a potential sensitive area, the contractor must limit the number of simultaneous activities to the minimum

 Ensure proper storage of fuels

 Workforce should be kept within defined boundaries and to agreed access routes

 No invasive prospecting activities are to be undertaken within 100 m of a watercourse

 Should any watercourse be affected, then the necessary water use licences should be obtained from the Department of Water and Sanitation

 No ablution or site laydown areas are to be located within 100 m of a watercourse

 Where shallow aquifers are encountered, a survey of the drinking water/livestock watering boreholes should be undertaken (within 5 km of the prospecting drillhole sites). A detailed groundwater monitoring programme should be

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

developed for these drinking water/livestock watering boreholes and pre and post prospecting water quality samples should be taken

 Where drinking water/ livestock watering boreholes are to be affected, and where a pollution event occurs at a particular borehole, then the advice of a geo-hydrologist should be sought with regards to the need for plugging and casing of the prospecting drillholes

 Workers must be easily identifiable by clothing and ID badges. Workers should carry with them, at all times a letter from the applicant stating their employment, title, role and manager contact details

 All removed soil and material must not be stockpiled within the system. Stockpiling should take place outside of the watercourse. All stockpiles must be protected from erosion; stored on flat areas where run-off will be minimised, and be surrounded by bunds

 Drilling and trenching areas should completely avoid any trees where possible (especially any protected tree species)

Re-fuelling  Construction  Short term and  Refuelling may only take place within demarcated areas that  NWA  Throughout localised are subject to appropriate spill prevention and containment construction and  Operation  DWAF BPG measures refuelling and transfer of hazardous chemicals operation and other potentially hazardous substances must be carried out so as to minimise the potential for leakage and to prevent spillage onto the soil

 Drip trays should be utilised in relevant locations (inlets, outlets, points of leakage, etc.) during transfer so as to prevent such spillage or leakage. Any accidental spillages must be contained and cleaned up promptly

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

Maintenance  Construction  Short term and  Trucks, machinery and equipment must be regularly  NWA  Throughout localised serviced to ensure they are in proper working condition and construction and and repair  Operation  DWAF BPG to reduce risk of leaks. All leaks must be cleaned up operation immediately using spill kits or as per the emergency  NEMA response plan. For large spills, a hazardous materials specialist shall be utilised

 Accidental hydrocarbon spillages must be reported immediately, and the affected soil should be removed, and rehabilitated or if this is not possible, disposed of at a suitably licenced waste disposal facility

Drillhole  Decommissioning  Short term and  Maintain a buffer of at least 20 m around heritage sensitive  NWA  Throughout localised areas. No material should be placed near these areas decommissioning closure  Closure  DWAF BPG and Closure  Where groundwater is encountered during drilling, all  NHRA affected prospecting drillholes that will not be required for later monitoring or other useful purposes should be plugged and sealed with cement to prevent possible cross flow and contamination between aquifers

 Cement and liquid concrete are hazardous to the natural environment on account of the very high pH of the material, and the chemicals contained therein. As a result, the contractor shall ensure that: o Concrete shall not be mixed directly on the ground o The visible remains of concrete, either solid, or from washings, shall be physically removed immediately and disposed of as waste, (Washing of visible signs into the ground is not acceptable) o All excess aggregate shall also be removed

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

Removal of  Decommissioning  Short term and  All infrastructure, equipment, and other items used during  MPRDA  Decommissioning localised prospecting will be removed from the site surface  Rehab Plan infrastructure  Compaction of soil must be avoided as far as possible. The use of heavy machinery must be restricted in areas outside of the proposed prospecting sites to reduce the compaction of soils

Removal of  Decommissioning  Short term and  Any excess or waste material or chemicals, including drilling  NWA  Decommissioning localised muds etc. must be removed from the site and must waste  DWAF BPG preferably be recycled (e.g. oil and other hydrocarbon waste products). Any waste materials or chemicals that cannot be  NEMWA recycled must be disposed of at a suitably licensed waste facility

Rehabilitation  Rehabilitation  All disturbed  Restoration and rehabilitation of disturbed areas must be  MPRDA  Rehabilitation areas implemented as soon as prospecting activities are Rehab Plan completed  NEMA  All debris and contaminated soils must be removed and suitably disposed of

 Contours and natural surrounding must be reformed

 Natural drainage patterns must be restored

 All surface infrastructure on site must be removed

 Temporary access routes/roads must be suitably rehabilitated

 Sites must be monitored by the ECO (including relevant specialist‟s inputs if, necessary) for adequate rehabilitation until the desired rehabilitation objectives have been achieved.

 Rehabilitation of the trenches and unpaved access road

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must be made a priority (and be concurrent). Due to the sensitive nature of the soil layer and extreme risk of erosion, rehabilitation must include re-filling of the open trenches with appropriate rock and soils and suitably compacted. Top soils must also be utilised, and the area must be re-vegetated with plant and grass species which are endemic to this exact vegetation type: o Rehabilitation measures that are implemented must be continually monitored for a minimum period of four years to ensure that proper succession has occurred and that there is no erosion occurring

 Areas that are denuded during prospecting need to be re- vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species

 Compilation and implementation of an alien vegetation management plan for the entire site

Consultation  Planning  Medium term,  Stakeholder engagement will continue throughout the  NEMA  Throughout localised prospecting activities to ensure the community and Planning,  Construction  OHS and landowners are kept informed and allowed to raise issues. construction and MHSA  Operation The Applicant shall attend applicable community meetings operation with the affected communities. Any issues raised will then be addressed through a grievance mechanism

Monitoring of  Post operation  All rehabilitation  The post-operational monitoring and management period  MPRDA  Post operation rehabilitated areas following decommissioning of prospecting activities must be Rehab Plan implemented by a suitable qualified independent party for a sites minimum of four (4) years unless otherwise specified by the Competent Authority. The monitoring activities during this period will include but not be limited to: o Biodiversity monitoring

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Activities Phase Size and scale of Mitigation measures Compliance Time period for disturbance with standards implementation

o Re-vegetation of disturbed areas where required. Provision must be made to monitor any unforeseen impact that may arise as a result of the proposed prospecting activities and incorporated into post closure monitoring and management

30.5 IMPACT MANAGEMENT ACTIONS AND OUTCOMES

Table 30: Impact management actions and outcomes.

Activity Potential impact Aspects affected Phase Mitigation type Standard to be achieved

Site clearance  Interference with existing land uses  Topography  Construction  Avoid and control  NEMA through  Disturbance/damage/destruction of the King  Soil  Operation  NEMBA implementation of Cetshwayo Grave  Air quality EMP mitigation  CARA  Sense of place measures (e.g.  Surface water speed limit  Threatened Protected  Fugitive dust emissions Species (TOPS)  Groundwater enforcement, regulations  Noise vehicle  Social maintenance)  NEMAQA  Loss and fragmentation of the vegetation  Ecology community  Dust regulations  Wetlands  Displacement of faunal community (including  NWA threatened or protected species) due to  Noise  DWAF best Practice habitat loss, disturbance and/or direct Guidelines mortalities  Heritage

 Disturbance/damage/destruction of heritage sensitive areas

 Increased runoff and sedimentation

 Degradation and/or destruction of wetland

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Activity Potential impact Aspects affected Phase Mitigation type Standard to be achieved habitats

 Contamination of surface and ground water

 Displacement of landowners and livestock

Storage of construction  Soil compaction  Surface water  Construction  Avoid through  NWA implementation of vehicles  Contamination of surface and ground water  Groundwater  Operation  DWAF best Practice EMP mitigation  Spillage of oils, fuels and chemicals  Soils measures Guidelines

 Soil contamination/pollution  Control through  NEMA implementation of ESMS

Transportation to and  Soil compaction  Soil  Construction  Avoid through  Protected Species from drill and trench implementation of (TOPS)  Loss and fragmentation of the vegetation  Ecology  Operation sites EMP mitigation community  regulations  Air quality measures (e.g.  Fugitive dust emissions speed limit  NEMAQA  Noise enforcement,  Noise  Dust regulations  Pollution vehicle  Spillage of oils, fuels and chemicals maintenance)  NWA

 DWAF best Practice Guidelines

Storage of hazardous  Spillage of oils, fuels and chemicals  Surface water  Construction  Avoid through  NEMA substances implementation of  Groundwater  Operation  NEMBA EMP mitigation  Soil measures  NWA

 Pollution  DWAF best Practice Guidelines

Waste management  Generation and disposal of waste  Pollution  Construction  Avoid through  DWAF minimum implementation of requirement for waste

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Activity Potential impact Aspects affected Phase Mitigation type Standard to be achieved EMP mitigation disposal  Operation measures

Prospecting drillholes  Safety and security risks to landowners and  Ecology  Construction  Avoid through  SANS10103 and trenches lawful occupiers implementation of  Wetlands  Operation  ECA Noise Regulations EMP mitigation  Interference with existing land uses  Topography  Decommissioning measures  NEMAQA  Degradation and/or destruction of wetland  Soil  Dust regulations habitats  Noise  NWA  Expropriation of land and displacement of landowners and livestock  Air Quality  NEMBA

 Job creation  Groundwater

 Training of unskilled labourers  Surface water

 Discovery of economically viable minerals  Social

 Clearance of vegetation  Pollution

 Soil pollution/contamination  Heritage  Increased runoff and sedimentation

 Spillage of oils, fuels and chemicals

 Contamination of surface water and groundwater

 Fugitive dust emissions

 Noise

 Disturbance/damage/destruction of heritage sensitive areas

 Disturbance/damage/destruction of the King Cetshwayo Grave

 Disturbance/damage/destruction of (Imizi)

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Activity Potential impact Aspects affected Phase Mitigation type Standard to be achieved homesteads

 Continued encroachment and displacement of an indigenous and vulnerable vegetation community by alien invasive species

 Continued displacement and fragmentation of the faunal community (including threatened or protected species) due to on- going anthropogenic disturbances and habitat degradation (litter, road mortalities, poaching)

 Introduction of alien invasive species

Refuelling  Spillage of oils, fuels and chemicals  Pollution  Construction  Avoid through  NWA implementation of  Surface water and groundwater  Surface water  Operation  DWAF best Practice EMP mitigation contamination Guidelines  Groundwater measures  Soil contamination/pollution  Soil

Maintenance and  Spillage of oils, fuels and chemicals  Pollution  Construction  Control through  NWA repair implementation of  Surface water and groundwater  Surface water  Operation EMPR mitigation contamination  Groundwater measures  Soil contamination/pollution  Soil

Drillhole closure  Potential pollution of habitats with cement  Pollution  Decommissioning  Control through  NWA residue that may be exposed to runoff implementation of  Groundwater  NEMBA EMPR mitigation  Groundwater pollution measures

Removal of surface  Soil compaction  Noise  Decommissioning  Control through  MPRDA in accordance infrastructure implementation of with Rehabilitation Plan  Soil contamination/pollution  Soils EMPR mitigation  Noise measures

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Activity Potential impact Aspects affected Phase Mitigation type Standard to be achieved

Rehabilitation  Encroachment and displacement of an  Topography  Rehabilitation  Control through  MPRDA in accordance indigenous and vulnerable vegetation implementation of with Rehabilitation Plan  Land use community by alien invasive species, EMPR mitigation potential re-establishment of natural species  Soil measures that were removed, the nature of the erosion will depend on the amount of successful  Ecology vegetation establishment  Heritage  Displacement of the faunal community (including threatened or protected species) due to rehabilitation of the anthropogenic disturbances and habitat degradation, rehab resulting in the faunal species potentially re- establishing within the area

 Soil instability

 Increased runoff and sedimentation

 Soil pollution/contamination

 Disturbance/damage/destruction of heritage sensitive areas

 Disturbance/damage/destruction of the King Cetshwayo Grave

 Generation and disposal of waste

Monitoring of  Soil compaction  Soil  Post-operation  Control through  MPRDA and rehabilitated sites implementation of regulations  Soil contamination/pollution  Social EMPR mitigation  Safety and security risks to landowners and measures lawful occupiers

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31. FINANCIAL PROVISION

The requirement for final rehabilitation, decommissioning and closure stems primarily from the legislative requirements of the MPRDA and NEMA. On 20th of November 2015 the Minister promulgated the Financial Provisioning Regulations under the NEMA. The Regulations aim to regulate the determination of financial provision as contemplated in the NEMA for the costs associated with the undertaking of management, rehabilitation and remediation of environmental impacts from prospecting, mining or production operations through the lifespan of such operations and latent or residual environmental impacts that may become known in the future. These regulations provide for, inter alia:

• Determination of financial provision: An Applicant or holder of a right or permit must determine and make financial provision to guarantee the availability of sufficient funds to undertake rehabilitation and remediation of the adverse environmental impacts of prospecting, prospecting, mining or production operations, as contemplated in the Act and to the satisfaction of the Minister responsible for mineral resources.

• Scope of the financial provision: Rehabilitation and remediation; decommissioning and closure activities at the end of operations; and remediation and management of latent or residual impacts.

• Regulation 6: Method for determining financial provision – An applicant must determine the financial provision through a detailed itemisation of all activities and costs, calculated based on the actual costs of implementation of the measures required for:

- Annual rehabilitation – annual rehabilitation plan.

- Final rehabilitation, decommission and closure at end of life of operations – rehabilitation, decommissioning and closure plan.

- Remediation of latent defects.

• Regulation 10: An applicant must-

- ensure that a determination is made of the financial provision and the plans contemplated in regulation 6 are submitted as part of the information submitted for consideration by the Minister responsible for mineral resources of an application for environmental authorisation, the associated environmental management programme and the associated right or permit in terms of the Mineral and Petroleum Resources Development Act, 2002.

- Provide proof of payment or arrangements to provide the financial provision prior to commencing with any prospecting, prospecting, mining or production operations.

• Regulation 11: Requires annual review, assessment and adjustment of the financial provision. The review of the adequacy of the financial provision including the proof of payment must be independently audited (annually) and included in the audit of the EMPR as required by the EIA Regulations.

Appendix 4 of the Financial Provisioning Regulations provides the minimum content of a final rehabilitation, decommissioning and closure plan (FRDCP).

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31.1 OTHER GUIDELINES The following additional guidelines which relate to financial provisioning and closure have been published in the South African context:

• Best Practice Guideline G5: Water Management Aspects for Mine Closure: This guideline was prepared by the DWS and aims to provide a logical and clear process that can be applied by mines and the competent authorities to enable proper mine closure planning that meets the requirements of the relevant authorities. This guideline is aimed primarily at larger scale mines and does not specifically address closure issues related to closure of prospecting activities, however certain principles related to closure and water management are relevant. The following technical factors which should be considered during closure, and which are likely to relate to prospecting activities, have been considered: - Land use plan: directly interlinked with water management issues insofar as water is required to support the intended land use- in this regard the surrounding communities and the land uses implemented rely on available ground and surface water to be sustained. Management of water quality and quantity has been identified as an aspect to be covered in the FRDCP.

- Public participation and consultation: consultation is fundamental to closure and there is a need for full involvement of stakeholders in the development of the final closure plans, and in the agreement of closure objectives- in this regard this FRDCP has been made available through the Basic Assessment public participation process for comment by relevant stakeholders.

• Guideline for the Evaluation of the Quantum of Closure Related Financial Provision Provided by a Mine: The objectives of the guideline include the need to improve the understanding of the financial and legal aspects pertaining to the costing of remediation measures as a result of mining activities. Whilst this guideline predates the recent NEMA Financial Provisioning Regulations, it does contain certain principles and concepts that remain valid and have been considered in the FRDCP. 32. DESCRIBE THE CLOSURE OBJECTIVES AND THE EXTENT TO WHICH THEY HAVE BEEN ALIGNED TO THE BASELINE ENVIRONMENT DESCRIBED UNDER THE REGULATION

Considering the relatively limited impact of the proposed prospecting activities, the closure objectives are aimed at re-instating the landform, land use and vegetation units to the same as before prospecting operations take place unless a specific, reasonable alternate land use is requested by the landowner. As such, the intended end use for the disturbed prospecting areas and the closure objectives will be defined in consultation with the relevant landowner. Proof of such consultation will be submitted together with the Application for Closure Certificate. The overall aim of the rehabilitation plan is to rehabilitate the environment to a condition as close as possible to that which existed prior to prospecting. This shall be achieved with a number of specific objectives

1. Making the area safe. i.e. Decommission prospecting activities so as to ensure that the environment is safe for people and animals. This entails refilling excavations, sealing drillholes, etc. 2. Recreating a free draining landform. This entails earthworks infilling, reshaping, levelling, etc. to recreate as close as possible the original topography and to ensure a free draining landscape. 3. Re-vegetation. This involves either reseeding or allowing natural succession depending on the area. climate etc.

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4. Storm water management and erosion control. Management of storm water and prevention of erosion during rehabilitation. E.g. cut off drains, berms etc. and erosion control where required. 5. Verification of rehabilitation success. Entails monitoring of rehabilitation. 6. Successful closure. Obtain Closure Certificate.

33. CONFIRM SPECIFICALLY THAT THE ENVIRONMENTAL OBJECTIVES IN RELATION TO CLOSURE HAVE BEEN CONSULTED WITH LANDOWNER AND INTERESTED AND AFFECTED PARTIES

The Public Participation Process (PPP) is a requirement of several pieces of the South African legislation and aims to ensure that all relevant Interested and Affected Parties (I&APs) are consulted, involved and their opinions are taken into account and a record included in the reports submitted to Authorities. The process ensures that all stakeholders are provided this opportunity as part of a transparent process which allows for a robust and comprehensive environmental study. The PPP which forms part of the Prospecting Right application needs to be managed sensitively and according to best practises in order to ensure and promote:  Compliance with national legislation.  Establish and manage relationships with key stakeholder groups.  Encourage involvement and participation in the environmental study and authorisation/approval process.

As such, the purpose of the PPP and stakeholder engagement process is to:  Introduce the proposed project.  Explain the environmental authorisations required.  Explain the environmental studies already completed and yet to be undertaken (where applicable).  Determine and record issues, concerns, suggestions and objections to the project.  Provide opportunity for input and gathering of local knowledge.  Establish and formalise lines of communication between the I&APs and the project team.  Identify all significant issues for the project.  Identify possible mitigation measures or environmental management plans to minimise and/or prevent negative environmental impacts and maximise and/or promote positive environmental impacts associated with the project.

Landowners and I&APs have been consulted and provided an opportunity to comment on the draft Basic Assessment Report, EMPR including all decommissioning, closure and rehabilitation plans.

34. REHABILITATION PLAN 34.1 INTEGRATED REHABILITATION AND CLOSURE PLAN The main aim in developing this rehabilitation plan is to mitigate the impacts caused by the prospecting activities and to restore land back to a satisfactory standard. It is best practice to develop the rehabilitation plan as early as possible so as to ensure the optimal management of rehabilitation issues that may arise. It is important that the project‟s closure plan is defined and understood before starting the process and is complementary to the rehabilitation goals. Rehabilitation and closure objectives need to be tailored to the project and be aligned with the EMPR. The overall rehabilitation objectives for this project are as follows:

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 Maintain and minimise impacts to the ecosystem within the study area.  Re-establishment of the pre-developed land capability to allow for a suitable post-mining land use.  Prevent soil, surface water and groundwater contamination.  Comply with the relevant local and national regulatory requirements.  Maintain and monitor the rehabilitated areas.

Successful rehabilitation must be sustainable, requires an understanding of the basic baseline environment and project management to ensure that the rehabilitation program is a success.

It is noted that an application for environmental authorisation must be submitted for closure in accordance with Listing Notice 1 Activity 22:

The decommissioning of any activity requiring –

I. a closure certificate in terms of Section 43 of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002).

II. A prospecting right, mining permit, production right or exploration right, where the throughput of the activity has reduced by 90% or more over a period of 5 years excluding where the competent authority has in writing agreed that such reduction in throughput does not constitute closure .

34.2 PHASE 1: MAKING SAFE In line with the DWAF (2008) Best Practice Guideline A6: Water Management for Underground Mines. All prospecting drillholes that will not be required for later monitoring or other useful purposes should be plugged and sealed with cement to prevent possible cross flow and contamination between aquifers. Cement and liquid concrete are hazardous to the natural environment on account of the very high pH of the material, and the chemicals contained therein. As a result, the contractor shall ensure that:

 Concrete shall not be mixed directly on the ground.  The visible remains of concrete, either solid, or from washings, shall be physically removed immediately and disposed of as waste, (washing of visible signs into the ground is not acceptable).  All excess aggregate shall also be removed.

34.3 PHASE 2: LANDFORM DESIGN, EROSION CONTROL AND REVEGETATION Landform, erosion control and re-vegetation is an important part of the rehabilitation process. Landform and land use are closely interrelated, and the landform should be returned as closely as possible to the original landform. Community expectations, compatibility with local land use practices and regional infrastructure, or the need to replace natural ecosystems and faunal habitats all support returning the land as closely as possible to its original appearance and productive capacity. This requires the following:

 Shape, level and de-compact the final landscape after removing all the project infrastructure, dress with topsoil and, where necessary, vegetate with indigenous species. Commission specialists to assist in planning re-vegetation and the management of environmental impact, as required.  Remove access roads with no beneficial re-use potential by deep ripping, shaping and levelling after the removal and disposal of any culverts, drains, ditches and/or other infrastructure. Natural drainage patterns are to be reinstated as closely as possible.  Shape all channels and drains to smooth slopes and integrate into the natural drainage pattern.

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 Construct contour banks and energy dissipating structures as necessary to protect disturbed areas from erosion prior to stabilisation.  Promote re-vegetation through the encouragement of the natural process of secondary succession.  Natural re-vegetation is dependent on de-compaction of sub-soils and adequate replacement of the accumulated reserves of topsoil (for example, over the drillhole sites), so as to encourage the establishment of pioneer vegetation.  Remove alien and/or exotic vegetation.  Undertake a seeding programme only where necessary, and as agreed with the re-vegetation specialist.

34.4 PHASE 3: MONITORING AND MAINTENANCE The post-operational monitoring and management period following decommissioning of prospecting activities must be implemented by a suitable qualified independent party for a minimum of four (4) years unless otherwise specified by the Competent Authority.

The monitoring activities during this period will include but not be limited to:

 Biodiversity monitoring.  Re-vegetation of disturbed areas where required.

Provision must be made to monitor any unforeseen impact that may arise as a result of the proposed prospecting activities and incorporated into post closure monitoring and management.

34.5 POST-CLOSURE MONITORING AND MAINTENANCE Prior to decommissioning and rehabilitation activities, a monitoring programme shall be developed and submitted to the relevant authority for approval, as a part of the Final Rehabilitation Plan. The programme is to include proposed monitoring during and after the closure of the prospecting drillhole sites and related activities. It is recommended that the post-closure monitoring include the following

 Confirmation that any waste, wastewater or other pollutants that is generated as a result of decommissioning will be managed appropriately, as per the detailed requirements set out in the Final Rehabilitation Plan.  Confirmation that all de-contaminated sites are free of residual pollution after decommissioning.  Confirmation that acceptable cover has been achieved in areas where natural vegetation is being re- established. „Acceptable cover‟ means re-establishment of pioneer grass communities over the disturbed areas at a density similar to surrounding undisturbed areas, non-eroding and free of invasive alien plants.  Confirmation that the prospecting drillhole sites are safe and are not resulting in a pollution hazard.

Annual environmental reports will be submitted to the Designated Authority and other relevant Departments for at least one year post-decommissioning. The frequency and duration of this reporting period may be increased to include longer term monitoring, at intervals to be agreed with the Designated Authority.

The monitoring reports shall include a list of any remedial action necessary to ensure that infrastructure that has not been removed remains safe and pollution free and that rehabilitation of project sites are in a stable, weed and free condition.

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35. EXPLAIN WHY IT CAN BE CONFIRMED THAT THE REHABILITATION PLAN IS COMPATIBLE WITH THE CLOSURE OBJECTIVES

The rehabilitation plan is compatible with the closure objectives in that is seeks to ensure that negative impacts on the receiving environment that could not be prevented or mitigated during prospecting are rehabilitated. The use of indigenous species during re-vegetation will ensure that ecosystem restoration is initiated and prevent invasion by alien species. The capping of drillholes will prevent future environmental issues related to fluid leakage or lateral movement through the drillhole, as well as protect water resources. The appropriate disposal of waste will ensure that land is usable and in alignment with surrounding land uses and that no hazardous materials are left on site post-prospecting.

36. CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION REQUIRED TO MANAGE AND REHABILITATE THE ENVIRONMENT IN ACCORDANCE WITH THE APPLICABLE GUIDELINE

Table 31 details the quantum for financial provision for the Final Rehabilitation, Decommissioning and Closure Plan.

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Table 31: Quantum for financial provision. CALCULATION OF THE QUANTUM Prospecting Right Applicant: WRE Base Metals (Pty) Ltd Project name: Nkunzana Prospecting Right Date: July-2018 A B C D E=A*B*C*D No. Description Unit Quantity Master Multiplication Weighting Amount rate factor factor 1 (ZAR)

Dismantling of processing plant and related structures R 0.00 1 m3 0 R 13.38 1 1 (including overland conveyors and powerlines) 2 2 m 0 R 184.76 1 1 R 0.00 (A) Demolition of steel buildings and structures 2 2 m 0 R 272.30 1 1 R 0.00 (B) Demolition of reinforced concrete buildings and structures 2 3 Rehabilitation of unpaved access road m 3 000 R 33.05 1 1 R 99,150.00 4 m 0 R 320.91 1 1 R 0.00 (A) Demolition and rehabilitation of electrified railway lines 4 m 0 R 175.05 1 1 R 0.00 (A) Demolition and rehabilitation of non-electrified railway lines 2 5 Demolition of housing and/or administration facilities m 0 R 370.69 1 1 R 0.00 6 Opencast rehabilitation including final voids and ramps ha 0 R 193,714.14 1 1 R 0.00 3 7 Sealing of shafts adits and inclines m 0 R 99.19 1 1 R 0.00 8 ha 0 R 129,142.75 1 1 R 0.00 (A) Rehabilitation of overburden and spoils 8 Rehabilitation of processing waste deposits and evaporation ponds (non-polluting ha 0 R 160,844.97 1 1 R 0.00 (B) potential) 8 ha 0 R 467,170.04 1 1 R 0.00 (C) Rehabilitation of processing waste deposits and evaporation ponds (polluting potential) 9 Rehabilitation of subsided areas ha 0 R 108,137.61 1 1 R 0.00 10 General surface rehabilitation: ha 0 R 102,302.84 1 1 R 0.00 Sealing and capping 6 drillholes m 6 R 120.00 1 1 R 720.00 3 Earthworks: backfilling excavations, reshaping and topsoil replacement m 2 400 R 11.00 1 1 R 26,400.00 Removal and disposal of waste Per site 12 R 3,000.00 1 1 R 36,000.00 Re-vegetation (apply fertiliser and seed) ha 1 R 21,000.00 1 1 R 20,580.00 11 River diversions ha 0 R 102,302.84 1 1 R 0.00 12 Fencing m 0 R 116.69 1 1 R 0.00

13 Water management ha 0 R 38,898.42 1 1 R 0.00 14 2 to 3 years of maintenance and aftercare ha 0.5 R 13,614.45 1 1 R 6,807.22

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15 Sum 0 1 R 0.00 (A) Specialist study 15 Sum 0 1 R 0.00 (B) Specialist study R 189,657.22 Weighting Factor 2 1 Sub Total 1 R 189,657.22 1. Preliminary and General 12% R 22,758.87 2. Contingency 10% R 18,965.72 Sub Total 2 R 231,381.81 VAT - 15% R 32,393.45 Grand Total R 263,775.26 ENVIRONMENTAL SENSITIVITY Medium (High = H, Medium = M, Low = L) RISK CLASS C (A, B, C)

WEIGHTING FACTOR 1 Flat (Flat; Undulating; Rugged)

WEIGHTING FACTOR 2 Remote (Urban; Peri-urban; Remote)

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37. CONFIRM THAT THE FINANCIAL PROVISION WILL BE PROVIDED AS DETERMINED

The Creasy Group of companies has committed to finance the prospecting costs. This Group is a long-standing investor into the South African minerals industry. The longer term strategy of WRE (Pty) Ltd is to list at the South African and Australian stock exchanges. Arrangements to provide the estimated financial provision prior to commencing with any prospecting operations will be made.

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38. MECHANISMS FOR MONITORING COMPLIANCE

Table 32: Mechanisms for monitoring compliance.

Source activity Impacts requiring monitoring Functional requirements for Roles and responsibilities Monitoring and reporting programmes monitoring frequency and time periods for implementation

Desktop studies and acquisition of  None  None  None  None historic data

Field mapping and surface  All impacts identified in the  Site inspections and  Contactor‟s environmental  Daily inspections and electromagnetic geophysical EMPR checklists representative checklists surveys  Complaints register  ECO

Stream sediment, underground  All impacts identified in the  Site inspections and  Contactor‟s environmental  Daily inspections and mine and grid sampling EMPR checklists representative checklists

 Complaints register  ECO

Site clearance  Possession of permits for  Document control  Contractors Environmental  Once-off control of protected species Representative documents, site visit and  Site inspections and reporting  Relocation of protected checklists  Environmental specialist species  Monthly site visit  Report review and  ECO  Alien vegetation  Monthly Reports for annual  Development of actions  Senior Environmental management Environmental Audit plans Management Assessment  Implement the

recommendations of the heritage specialist report and the Heritage Management Plan (See Appendix F1)

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Establishment of unpaved access  Alien vegetation  Site Inspections and  Contractors Environmental  Once-off control of road, drilling and excavation of management checklists Representative documents, site visit and trenches reporting  Noise (if any complaints are  Report review and  Environmental specialist registered by residents) development of corrective  Monthly site visit  ECO action plans  Air quality (if complaints are  Monthly Reports for annual  Senior Environmental registered)  Inspection of surface water Environmental Audit Report Management features  Surface and groundwater  Prior to invasive prospecting  Geo-hydrologist (if required) management  Survey of groundwater activities and monitoring

users and use within 5 km of post- prospecting.  Impacts on heritage features the invasive prospecting sites

 Demarcation of sensitive areas

Data compilation  None  None  None  None

Access routes  All impacts identified in the  Site inspections and  Contactor‟s environmental  Daily inspections and EMPR checklists representative checklists

 Complaints register  ECO

Environmental screening by ECO  All impacts identified in the  Site inspections and  Contactor‟s environmental  Daily inspections and EMPR checklists representative checklists

 Complaints register  ECO

Temporary general waste storage  All impacts identified in the  Site inspections and  Contactor‟s environmental  Daily inspections and (General/domestic waste - Wheelie EMPR checklists representative checklists bin)  Complaints register  ECO

Temporary hazardous waste  All impacts identified in the  Site inspections and  Contactor‟s environmental  Daily inspections and storage (Hazardous waste – EMPR checklists representative checklists Sealed Container)  Complaints register  ECO

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Undertake decommissioning and  Alien vegetation  Site Inspections and  Contractors Environmental  Monthly site visit management Noise (if any checklists; Representative rehabilitation as per the  Monthly Reports for annual complaints are registered by rehabilitation plan  Report review and  Environmental specialist Environmental Audit Report residents) development of corrective  ECO  Air quality (if complaints are action plans registered)  Senior Environmental

Management

 Surface water specialist

Monitoring of rehabilitation efforts  All impacts identified in the  Site inspections and  ECO  Continually monitor for a EMPR checklists minimum period of four (4)  Independent Environmental years  Complaints register Auditor

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39. INDICATE THE FREQUENCY OF THE SUBMISSION OF THE PERFORMANCE ASSESSMENT/ ENVIRONMENTAL AUDIT REPORT

The result of environmental monitoring and compliance to the approved EMPR will be undertaken every second year and submitted to the DMR in the form of an environmental performance assessment. Included in the report will be the following relevant information:

 The period when the performance assessment was conducted.  The scope of the assessment.  The procedures used for conducting the assessment.  Interpreted information gained from monitoring the EMPR.  Evaluation criteria used during the assessment.  Results of the assessment are to be discussed and mention must be made of any gaps in the EMPR and how it can be rectified.  Yearly updated layout plans.

Any emergency or unforeseen impacts will be reported immediately to the DMR and other relevant government departments. 40. ENVIRONMENTAL AWARENESS PLAN AND TRAINING

No Training and environmental awareness is an integral part of a complete EMPR. The overall aim of the training will be to ensure that all site staff is informed of their relevant requirements and obligations pertaining to the relevant authorisations, licences, permits and the approved EMPR and protection of the environment.

The applicant and contractor must ensure that all relevant employees are trained and capable of carrying out their duties in an environmentally responsible and compliant manner, and are capable of complying with the relevant environmental requirements. To obtain buy-in from staff, individual employees need to be involved in:

 Identifying the relevant risks.  Understanding the nature of risks.  Devising risk controls.  Given incentive to implement the controls in terms of legal obligations.

The applicant shall ensure that adequate environmental training takes place. All employees shall have been given an induction presentation on environmental awareness. Where possible, the presentation needs to be conducted in the language of the employees. All training must be formally recorded and attendance registers retained. The environmental training should, as a minimum, include the following:

 General background and definition to the environment.  The environmental impacts, actual or potential, of their work activities.  Compliance with mitigation measures proposed for sensitive areas.  The environmental benefits of improved personal performance.  Their roles and responsibilities in achieving compliance with the environmental policy and procedures and with the requirement of the applicant‟s environmental management systems, including emergency preparedness and response requirements.

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 The potential consequences (legal and/or other) of departure from specified operating procedures.  The mitigation measures required to be implemented when carrying out their work activities.  All operational risks must be identified and processes established to mitigate such risk, proactively. Thus, the applicant needs to inform the employees of any environmental risks that may result from their work, and how these risks must be dealt with in order to avoid pollution and/or degradation of the environment.  In the case of new staff (including contract labour) the contractor / applicant shall keep a record of adequate environmental induction training. he importance of compliance with all environmental policies.

40.1 MANNER IN WHICH EMPLOYEES WILL BE INFORMED OF ENVIRONMENTAL RISKS Environmental awareness could be fostered by induction course for all personnel on site, before commencing site visits. Personnel should also be alerted to particular environmental concerns associated with their tasks for the area in which they are working. Courses must be given by suitably qualified personnel and in a language and medium understood by personnel. The environmental awareness training programme will include the following:

1. Occupational Health and Safety Training (OHS).

2. Environmental Awareness Training EMPR management actions.

Environmental awareness training will focus on the following specific aspects and be undertaken in “Tool box talk “topics prior to site access:

1. Waste collection and disposal.

2. EMPR management options and application.

40.2 MANNER IN WHICH RISKS WILL BE DEALT WITH TO AVOID POLLUTION OR DEGRADATION The broad measures to control or remedy any causes of pollution or environmental degradation as a result of the proposed prospecting activities taking place are provided below:  Contain potential pollutants and contaminants (where possible) at source.  Handling of potential pollutants and contaminants (where possible) must be conducted in bunded areas and on impermeable substrates.  Ensure the timeous clean-up of any spills.  Implement a waste management system for all waste present on site.  Investigate any I&AP claims of pollution or contamination as a result of mining activities.  Implement the impact management objectives, outcomes and actions, as described in Section 12 above.

It is of critical importance that the broad measures to control or remedy any causes of pollution or environmental degradation are applied during onsite prospecting activities. 41. SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY

No additional information was requested or is deemed necessary.

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42. UNDERTAKING

The EAP herewith confirms:

(a) The correctness of the information provided in the reports.

(b) The inclusion of comments and inputs from stakeholders and I&APs.

(d) That the information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested and affected parties are correctly reflected herein.

Signature of the applicant / Signature on behalf of the applicant:

Shango Solutions

Name of company (if applicable):

27 July 2018

Date:

The Applicant herewith confirms:

(a) The person whose name is stated below is the person authorised to act as representative of the Applicant in terms of the resolution submitted with the application.

(b) The Applicant undertakes to execute the Environmental Management Programme as proposed.

Signature of the environmental assessment practitioner:

WRE Base Metals (Pty) Ltd

Name of company:

27 July 2018

Date:

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