BORROW PITS D660/1, D660/2 AND D639/2 NEAR CEDARVILLE AND MATATIELE, PROVINCE

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

DMR REF: EC30/5/1/3/3/2/1/00083BP (EM)

Prepared for:

Prepared by:

EOH Coastal & Environmental Services EAST LONDON 25 Tecoma Street, Berea East London, 5214 043 726 7809 Also in Johannesburg, Grahamstown, Port Elizabeth, Cape Town and Maputo(Mozambique) www.cesnet.co.za | www.eoh.co.za

July 2017

Environmental Impact Assessment Report – July 2017 This Report should be cited as follows: EOH Coastal & Environmental Services, May 2017: Borrow Pits D660/1, D660/2 and D639/2 near Cedarville and Matatiele, Eastern : Draft Environmental Impact Assessment Report, EOH, East London.

REVISIONS TRACKING TABLE

EOH Coastal & Environmental Services

Report Title: Borrow Pits D660/1, D660/2 and D639/2 near Cedarville and Matatiele, Eastern Cape Province: Draft Environmental Impact Assessment Report

Report Version: Draft

Project Number:267

Name Responsibility Date

R de Kock Report writer & Project Manager May 2017

Reviewer July 2017

COPYRIGHT INFORMATION This document contains intellectual property and proprietary information that is protected by copyright in favour of Coastal & Environmental Services (Pty) Ltd. and the specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of Coastal & Environmental Services. Although this document is prepared exclusively for submission to the Department of Mineral Resources, Coastal & Environmental Services (Pty) Ltd retains ownership of the intellectual property and proprietary information contained herein, which is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of .

EOH Coastal & Environmental Services i Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 THE PROJECT TEAM

The following table provides the names and responsibilities of the project team.

EOH Coastal & Environmental Services team and responsibilities Name Role/Responsibility Project Leader Dr Alan Carter Report Reviewer Report writer Mr Roy de Kock Ecological Impact Specialist Project Manager Mr Peter De Lacy Client Liaison Public Participation Umlando South Africa Name Role/Responsibility Mr Gavin Anderson Heritage Impact Assessor

EOH Coastal & Environmental Services ii Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 LIST OF ACRONYMS

The following acronyms have been used in this report:

BID Background Information Document CA Competent Authority CBA Critical Biodiversity Area DEDEAT Department of Economic Development, Environmental Affairs and Tourism DSR Draft Scoping Report DWS Department of Water and Sanitation EAP Environmental Assessment Practitioner ECO Environmental Control Officer ECPHRA Eastern Cape Provincial Heritage Resources Authority EIA Environmental Impact Assessment EIR Environmental Impact Report EMPr Environmental Management Programme GN Government Notice I&AP Interested and Affected Party MEC Member of the Executive Council NEMA National Environmental Management Act NFEPA National Freshwater Ecosystem Priority Area NDP National Development Plan PoS Plan of Study PPP Public Participation Process SAHRA South African Heritage Resources Agency SANBI South African National Biodiversity Institute SIA Social Impact Assessment SCC Species of Conservation Concern WULA Water Use License Application

EOH Coastal & Environmental Services iii Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 TABLE OF CONTENTS

1. INTRODUCTION ...... 1 1.1 Background to the Study ...... 1 1.2 Environmental and Mining Authorisation in South Africa ...... 1 1.3 The Environmental Impact Assessment Process ...... 2 1.4 Scoping Phase ...... 3 1.5 The Environmental Impact Assessment Phase ...... 3 1.6 Mining Right Application ...... 4 1.7 Nature and Structure of this Scoping Report ...... 4 1.8 Assumptions and Limitations ...... 4 1.9 Details and Expertise of the Environmental Assessment Practitioner ...... 4 1.9.1 Details of the EAP...... 5 1.9.2 Expertise of the study team ...... 5 2. PROPERTY DESCRIPTION AND ACTIVITY LOCATION ...... 7 2.1 Property Locality ...... 7 3. PROJECT DESCRIPTION ...... 10 3.1 Description of Proposed Activity ...... 10 3.2 Listed activities triggered ...... 16 4. RELEVANT LEGISLATION ...... 17 4.1 Relevant Legislation and Guidelines used in the Compilation of this Scoping Report .... 17 4.2 Relevant policy ...... 19 4.2.1 National Policy ...... 19 4.2.2 Provincial Policy ...... 20 4.3 Municipal by-laws and planning ...... 20 4.3.1 The MLM SDF (June 2014) ...... 20 5. PROJECT NEED & DESIRABILITY ...... 21 6. PROJECT ALTERNATIVES ...... 22 6.1 Reasonable and Feasible Alternatives ...... 22 6.2 Fundamental Alternatives ...... 22 6.3 Incremental Alternatives ...... 22 6.4 No-Go development ...... 22 6.5 Analysis of alternatives ...... 23 7. PUBLIC PARTICIPATION ...... 27 7.1 Notification of Interested and Affected Parties ...... 27 7.1.1 Public Participation ...... 27 7.1.2 Newspaper advertisement ...... 27 7.1.3 On-site Notice ...... 27 7.1.4 Stakeholders and I&APs ...... 27 7.1.5 Background information document ...... 27 7.1.6 Proof of notification ...... 28 7.1.7 Issues raised by stakeholders/ I&APs ...... 28 8. DESCRIPTION OF THE ENVIRONMENT ...... 29 8.1 The Bio-Physical Environment ...... 29 8.1.1 Current land use ...... 29 8.1.2 Climate ...... 29 8.1.3 Topography ...... 30 8.1.4 Geology and soils ...... 31 8.1.5 Rivers and wetlands ...... Error! Bookmark not defined. 8.1.6 Vegetation ...... 32 8.2 Conservation planning ...... 35 8.2.1 NEMBA – Threatened Ecosystems ...... 35 8.2.2 The National Protected Areas Expansion Strategy ...... 36 8.2.3 Eastern Cape Biodiversity Conservation Plan ...... 37 8.3 Socio-Economic Profile...... 39 8.3.1 Population ...... 39 8.3.2 Employment ...... 39

EOH Coastal & Environmental Services iv Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

8.3.3 Education ...... 39 9. MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED ...... 40 9.1 General Impact Assessment ...... 40 9.2 Specialist Impact Assessment ...... 40 9.3 Methodology for Assessing Impacts and Alternatives ...... 40 9.3.1 Description of criteria ...... 41 10. KEY FINDINGS OF THE SPECIALIST STUDIES ...... 44 10.1 Specialists studies ...... 44 10.1.1 Aquatic and Wetland Impact Assessment ...... 44 10.1.2 Ecological Impact Assessment ...... 46 10.1.3 Heritage Impact Assessment ...... 48 10.2 Sensitivity assessment ...... 53 11. IMPACT ASSESSMENT ...... 55 11.1 Possible Environmental Issues and Impacts ...... 55 11.1.1 General Impact Assessment ...... 55 11.1.2 Specialist Impact Assessment ...... 56 12. IMPACT STATEMENT ...... 59 12.1 Environmental impact statement ...... 59 12.1.1 Comparative assessment of impacts ...... Error! Bookmark not defined. 12.2 Overall site sensitivity ...... 61 12.3 Consideration of alternatives ...... 63 12.3.1 Location alternatives ...... 63 12.3.2 Technology alternatives ...... 63 12.3.3 Layout alternatives ...... 63 13. CONCLUSIONS, EAP AND RECOMMENDATIONS ...... 64 13.1 Description of the proposed activity ...... 64 13.2 Assumptions, uncertainties and gaps ...... 64 13.3 Opinion of the EAP ...... 65 13.4 Recommendations of the EAP ...... 65 13.4.1 Recommended mitigation measures ...... 66 13.5 Declaration by the EAP...... 69 14. ADDITIONAL INFORMATION ...... 70 14.1 Financial provisions for rehabilitation ...... 70 15. REFERENCES ...... 71 16. APPENDICES ...... 72 16.1 Appendix A: Public participation documents ...... 72 16.2 Appendix B ...... 83 16.2.1 Impact assessment ...... 83 16.3 APPENDIX C: Specialist Volume ...... 99 16.4 Appendix D: Environmental Management Programme ...... 102

LIST OF FIGURES

Figure 1.1: The EIA process...... 2 Figure 2.1: Location map of the proposed quarry site east of Cedarville, Eastern Cape...... 9 Figure 2.2: Aerial Image of the proposed quarry site...... Error! Bookmark not defined. Figure 3.1 Proposed layout of the quarry...... 15 Figure 8.1: Land use for the quarry site and surrounding areas...... 29 Figure 8.2: Average climate conditions for Cedarville, Eastern Cape (SAExplorer)...... 30 Figure 8.3: Topography for BP01 and surrounding areas...... 30 Figure 8.4: Simplified geology map of the quarry site area...... Error! Bookmark not defined. Figure 8.5: Simplified SOTER soil map of the quarry area...... Error! Bookmark not defined. Figure 8.8: Surface hydrology for the quarry site and surrounding areas...... 32 Figure 8.9: Vegetation for the quarry site and surrounding areas (Mucina & Rutherford, 2006)...... Error! Bookmark not defined.

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Figure 8.10: NEMBA Threatened Ecosystems for BP01 and surrounding areas...... 36 Figure 8.11 identifies the following critical biodiversity areas occurring within the proposed quarry site: ...... 37 Figure 8.11: ECBCP for the proposed quarry site and surrounding areas...... 38 Figure 10.1: shows the water resources associated with Matatiele R56 Road Upgrade...... 45 Figure 10.1.2: Spatial display of the identified archaeological and cultural heritage resources in relation to Matatiele R56 Road study site...... 49 Figure 10.1.3: the digital photographs of the identified archaeological and cultural sites in the proposed Matatiele R56 study site, Eastern Cape...... 52 Figure 10.2: Sensitivity map of the study area...... 53 Figure 12.1 Sensitivity map of the study area...... Error! Bookmark not defined.

LIST OF TABLES

Table 2.1: Property details ...... 7 Table 3.1. Size of quarry...... Error! Bookmark not defined. Table 3.2: Listed activities triggered by the proposed 3 x Borrow pits ...... 16 Table 4.1: Environmental legislation considered in the preparation this Scoping Report...... 17 Table 6.1: The alternatives considered for the proposed quarry site ...... 24 Table 7.1. Issues raised during site meetings ...... 28 Table 9.1: Significance Rating Table ...... 41 Table 9.2 Impact Severity Rating ...... 41 Table 11.1 Summary of the issues identified and their applicability in each phase...... 56 Table 11.2. Summary of all General and Specialist Impacts...... 57 Table 12.1 High impacts identified for the proposed dolerite quarry...... 59 Table 12.2 Comparative Assessment of General Impacts occurring in all phases for the proposed quarry (+ = beneficial impact) ...... 61 Table 12.3 Comparative Assessment of Heritage Impacts occurring in all phases for the proposed quarry (+ = beneficial impact) ...... Error! Bookmark not defined. Table 12.4 Comparative Assessment of Ecological Impacts occurring in all phases for the proposed quarry (+ = beneficial impact) ...... Error! Bookmark not defined. Table 12.5 Impacts associated with the No-go alternative...... 61

EOH Coastal & Environmental Services vi Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 1. INTRODUCTION

1.1 Background to the Study

The South African National Roads Agency Soc. Ltd. (SANRAL) will be constructing various safety improvements on Section 8 of the National Route R56 from Matatiele (km 130.15) to the KZN border (km 168.71) in the Eastern Cape Province. GIBB Engineering, the project managers, contracted EOH Coastal & Environmental Services (EOH CES) as the Environmental Assessment Practitioner (EAP) to undertake the Environmental Impact Assessment for this project. The South African National Roads Agency SOC Limited (SANRAL) has received Environmental Authorisation, from the Department of Environmental Affairs (DEA) (DEA Reference: 14/12/16/3/3/2/940), for the Rehabilitation of National Route R56 Section 8 from Matatiele (km 130, 15) to the KZN border (km 168, 71), in the Eastern Cape Province.

The proposed road rehabilitation requires three (3) borrow pits to supply the necessary rock material for the road construction. Suitable borrow pits have been identified on Portion 2 and the Remainder of Farm 182 and the Remainder of Farm 186 in the Matatiele Local Municipality.

In terms of Section 106 of the Mineral and Petroleum Resources Development Act (Act No. 28 of 2002; MPRDA) SANRAL is exempted from the application for a Mining Right for the quarry but is not exempted from the application for environmental authorisation for the quarry. EOH has been appointed by SANRAL as the EAP to undertake the EIA for the proposed quarry.

1.2 Environmental and Mining Authorisation in South Africa

The primary legislation regulating Environmental Impact Assessments (EIA) within South Africa is the National Environmental Management Act (NEMA, Act 107 of 1998). NEMA makes provision for the Minister of Environmental Affairs to identify activities which may not commence prior to authorisation from either the Minister or the provincial Member of the Executive Council (MEC). In addition to this, NEMA also provided for the formulation of regulations in respect of such authorisations.

The EIA Regulations (2017) allow for a Basic Assessment process for activities with limited environmental impact (listed in GNR. 327 and 325, 2017) and a more rigorous two-tiered approach for activities with potentially greater environmental impact (listed in GNR. 325, 2017). This two- tiered approach includes both a Scoping and EIR process (Figure 1.1).

The proposed borrow pit requires a Full Scoping and EIR due to the following triggers:

Government Activity Activity Description Relevance to this project Notice Number Any activity including the operation of The project involves the that activity which requires a mining development of a dolerite right as contemplated in Section 22 quarry and this requires that an application for of the MPRDA (2002), including environmental authorisation be associated infrastructure, structures GNR 325 submitted to DMR (as per 17 and earthworks, directly related to GNR 325 No. 17). the extraction of a mineral resource, including the primary processing of a mineral resource including winning, extraction, classifying, concentrating, screening or washing.

The Department of Mineral Resources (DMR) is the competent authority for this EIA application.

EOH Coastal & Environmental Services 1 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

1.3 The Environmental Impact Assessment Process

The EIA process is guided by regulations made in terms of Chapter 5 of NEMA, published as Government Notice No R 326 in Government Gazette No 40772 of 7 April 2017. The regulations set out the procedures and criteria for the submission, processing and consideration of decisions on applications for environmental authorisation.

Contextualise Proposed Development

Pre-Application Planning

Adopt the Scoping & Environmental Impact Assessment Process

Submit Application to Relevant Authority

Conduct Public Participation Process

Scoping Report and Plan of Study for the EIA

Public Review of Scoping Report and Plan of Study of the EIA

Authority Review of Scoping Request Report and Plan of Study of the EIA Amendments

Accept

Conduct Environmental Impact Assessment. Compile EIR and EMPr

Public Review of EIR and EMPr

Authority Review of EIR and EMPr Request Amendments

Accept

Issue Environmental Authorisation and notify applicant of conditions and appeal provisions

Notify I&APs of Environmental Authorisation and appeal provisions

Consider Appeals if any

Figure 1.1: The EIA process.

EOH Coastal & Environmental Services 2 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 1.4 Scoping Phase

A detailed description of the Scoping Phase for the proposed borrow pit sites and the outcomes thereof is included in: “EOH Coastal and Environmental Services, Borrow Pits D660/1, D660/2 and D639/2 near Cedarville and Matatiele, Eastern Cape Province, Scoping Report, EOH CES, East London”.

A Plan of Study (PoS) for the detailed EIA phase was submitted to the Department of Mineral Resources (DMR) together with the Final Scoping Report (FSR), in fulfilment of Appendix 2 in GNR 326 of the EIA Regulations (2017).

1.5 The Environmental Impact Assessment Phase

The Environmental Impact Assessment (EIA) is a comprehensive evaluation and study phase that addresses all the issues raised in the Scoping Phase. It is a substantial phase that has seven key objectives:

 Describe the biophysical and socio-economic environment that is likely to be affected by the proposed borrow pits.  Assess the significance of impacts that may occur from the proposed borrow pits.  Assess the alternatives proposed during the Scoping Phase.  Provide details of mitigation measures and management recommendations to reduce the significance of impacts.  Provide a framework for the development of the Environmental Management Programme (EMPr).  Continue with the public participation process.

This EIA phase includes the following steps:

1. Specialist studies

Specialist studies are undertaken to provide a detailed and thorough examination of key issues and environmental impacts. Specialists gather relevant data to identify and assess environmental impacts that might occur on the specific component of the environment that they are studying (for instance waste management, air quality, noise, vegetation, water quality, pollution, waste management). Once completed, these studies are synthesised in, and presented in full as appendices to the Environmental Impact Report (EIR).

2. The Public Participation Process

The public participation process (PPP) initiated at the beginning of the Scoping Phase continues into the EIA Phase. Once again the PPP provides a platform from which all I&APs are able to voice their concerns and raise issues regarding the project.

3. Assessment of the Significance of Impacts

It is necessary to determine the significance, or seriousness, of any impacts on the natural or social environment. It is common practice in the EIA Phase to use a significance rating scale that determines the spatial and temporal extent, and the severity and certainty of any impact occurring, including impacts relating to any project alternatives. This allows the overall significance of an impact or benefit to be determined.

The overall intent of undertaking a significance assessment is to provide the competent authority with information on the potential environmental impacts and benefits, thus allowing them to make an informed, balanced and fair decision.

EOH Coastal & Environmental Services 3 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 4. Mitigation Measures and Recommendations

Critical to any EIA is the recommendation of practical and reasonable mitigation measures and recommendations. These recommendations relate to the actions that are needed in order to avoid, minimise or offset any negative impacts from the borrow pits.

5. Planning input

An effective EIA process should actively engage and contribute to the project planning process so as to mitigate environmental impacts through improved design and layout.

6. Environmental Impact Report

The above-mentioned tasks are synthesised in the EIR. This will allow the assessment of the relationship of environmental impacts to project actions, as well as to assess the overall significance of these impacts. The EIR will also provide sufficient information to allow the competent authority to make an informed decision.

1.6 Mining Right Application

SANRAL is exempted from the application for a Mining Right for the quarry, but it is not exempted from the application for Environmental Authorisation for the quarry. The quarry requires an application for environmental authorisation in terms of NEMA (Act No.107 of 1998) and in terms of the MPRDA (Act NO.28 OF 2002). An application for environmental authorisation was submitted to DMR

1.7 Nature and Structure of this Scoping Report

This EIR fulfils the requirement of the EIA Regulations (2017) for the documentation of the EIR phase. The structure of this report is based on APPENDIX 3 of GNR No. 326, of the EIA Regulations (2017), which clearly specifies the required content of an Environmental Impact Assessment Report.

1.8 Assumptions and Limitations

This EIR is based on currently available information and, as a result, the following limitations and assumptions are implicit:

 The report is based on project information provided by the client.  Descriptions of the natural and social environments are based on limited fieldwork, relevant specialist studies and available literature.

1.9 Details and Expertise of the Environmental Assessment Practitioner

In terms of APPENDIX 3 (3) of the EIA Regulations (2017), an environmental impact

assessment report must contain the information that is necessary for the competent authority to

consider and come to a decision on the application, and must include -

(a) Details of–

(i) The EAP who prepared the report; and

(ii) The expertise of the EAP, including a curriculum vitae;

EOH Coastal & Environmental Services 4 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 In fulfilment of the above-mentioned legislative requirements, the details of the Environmental Assessment Practitioner (EAP) that prepared this draft scoping report as well as the expertise of the individual members of the study team are provided below.

1.9.1 Details of the EAP

EOH has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, State of Environment Reporting (SOER), Integrated Waste Management Plans (IWMP), Environmental Management Plans (EMPs), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes. EOH has been active in all of the above fields, and in so doing have made a positive contribution towards environmental management and sustainable development in the Eastern Cape, South Africa and many other African countries. We believe that a balance between development and environmental protection can be achieved by skilful, considerate and careful planning.

1.9.2 Expertise of the study team

Dr Alan Carter Alan is the executive of the EOH East London Office. He holds a PhD in Marine Biology and is a certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has 25 years‟ experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP). He is also registered as an EAP by the Environmental Assessment Practitioners of South Africa (EAPSA).

EOH Coastal & Environmental Services 5 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Mr Roy de Kock Roy is a Senior Consultant holding a BSc Honours in Geology and an MSc in Botany from the Nelson Mandela Metropolitan University in Port Elizabeth. His MSc thesis focused on Rehabilitation Ecology using an open-cast mine as a case study. He has been working for EOH since 2010, and is based at the East London branch where he focuses on Ecological and Agricultural Assessments, Geological and Geotechnical analysis, Environmental Management Plans, mining applications and various environmental impact studies. Roy has worked on numerous projects in South Africa, Mozambique and Malawi. He is registered as a Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP).

EOH Coastal & Environmental Services 6 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 2. PROPERTY DESCRIPTION AND ACTIVITY LOCATION In terms of APPENDIX 3(3) of the EIA Regulations (2017), an environmental impact assessment report must contain the information that is necessary for the competent authority to consider and come to a decision on the application, and must include –

b) The location of the development footprint of the activity on the approved site as contemplated in the accepted scoping report, including – i. The 21 digit Surveyor General code of each cadastral land parcel; ii. Where available, the physical address and farm name; iii. Where the required information in terms of (i) and (ii) is not available, the coordinates of the boundary or properties; c) A plan which locates the proposed activity or activities applied for at an appropriate scale;

2.1 Property Locality

The proposed borrow pits are located on Portion 2 and the Remainder of Farm 182 and the Remainder of Farm 186 in the Matatiele Local Municipality. Figure 2.1 illustrates the location of the proposed borrow pits.

Property details and the 21 Digit SG code of the affected farm are illustrated in Table 2.1 below. Coordinates of the proposed borrow pits is illustrated in Table 2.2.

Table 2.1: Property details Province Eastern Cape District Municipality Alfred Nzo District Municipality (ANDM) Local Municipality Matatiele Local Municipality Farm numbers Borrow pit 1 (D660/1) 2/182 Borrow pit 1 (D660/2) RE/182 Borrow Pit 3 (D639) RE/186 21 digit SG code Borrow pit 1 (D660/1) C11900000000018200002 Borrow pit 1 (D660/2) C11900000000018200000 Borrow Pit 3 (D639) C09700000000018600000

Table 2.2: Coordinates of the proposed 3 borrow pits. # Latitude (S) (DDMMSS) Longitude (E) (DDMMSS) Borrow pit 1 (D660/1) 1 30°23'33.19"S 29° 7'26.97"E 2 30°23'32.26"S 29° 7'40.80"E 3 30°23'52.47"S 29° 7'42.68"E 4 30°23'55.98"S 29° 7'36.34"E 5 30°23'42.52"S 29° 7'25.74"E Borrow Pit 2 (D660/2) 1 30°23'33.19"S 29° 7'26.97"E 2 30°23'22.38"S 29° 7'28.34"E 3 30°23'22.34"S 29° 7'34.15"E 4 30°23'32.58"S 29° 7'35.59"E Borrow Pit 3 (D639) 1 30°22'55.71"S 28°52'2.53"E 2 30°22'54.32"S 28°52'5.54"E 3 30°22'56.18"S 28°52'5.13"E 4 30°22'56.81"S 28°52'4.63"E 5 30°22'58.08"S 28°52'4.47"E 6 30°22'59.65"S 28°52'5.87"E

EOH Coastal & Environmental Services 7 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 # Latitude (S) (DDMMSS) Longitude (E) (DDMMSS) 7 30°23'0.46"S 28°52'3.42"E 8 30°22'58.64"S 28°52'2.09"E

EOH Coastal & Environmental Services 8 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

BP2

BP3 BP1 Figure 2.1: Location map of the proposed 3 borrow pits.

EOH Coastal & Environmental Services Gibb Engineering9 R56 Mining Application Environmental Impact Assessment Report – July 2017 3. PROJECT DESCRIPTION

In terms of Section APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Assessment Report must include –

d) A description of the scope of the proposed activity, including – (i) All listed and specified activities triggered; (ii) A description of the activities to be undertaken, including associated structures and infrastructure

3.1 Description of Proposed Activity

The South African National Roads Agency Soc. Ltd. (SANRAL) will be constructing various safety improvements on Sections 8 of the National Route R56 from Matatiele (km 130.15) to the KZN border (km 168.71) in the Eastern Cape Province. GIBB Engineering, the project managers, contracted EOH Coastal & Environmental Services (EOH CES) as the Environmental Assessment Practitioner (EAP) to undertake the Environmental Impact Assessment for this project.

Three (3) Borrow Pits sites are required to supply the necessary material for the road construction. Suitable borrow pits have been identified on Portion 2 and the Remainder of Farm 182 and the Remainder of Farm 186 for the rehabilitation of R56 section 8 in the Matatiele Local Municipality.

EOH Coastal & Environmental Services 10 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

BP2

BP1

Figure 3.1: Layout map of Borrow Pit 1 and 2.

EOH Coastal & Environmental Services Gibb Engineering11 R56 Mining Application Environmental Impact Assessment Report – July 2017

Figure 3.2: Layout plan of the Borrow Pit 1 (D660/1).

EOH Coastal & Environmental Services Gibb Engineering12 R56 Mining Application Environmental Impact Assessment Report – July 2017

Figure 3.2: Layout plan of the Borrow Pit 2 (D660/2).

EOH Coastal & Environmental Services Gibb Engineering13 R56 Mining Application Environmental Impact Assessment Report – July 2017

BP3

Figure 3.3: Layout map of Borrow Pit D639.

EOH Coastal & Environmental Services 14 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

Figure 3.4: Layout plan of the Borrow Pit 3 (D639).

EOH Coastal & Environmental Services Gibb Engineering15 R56 Mining Application Environmental Impact Assessment Report – July 2017 3.2 Listed activities triggered

The proposed borrow pits trigger the need for a Full Scoping and EIA process under the NEMA Regulations (2017) in terms of Listing Notices 1, 2 and 3 and published in Government Notices No. R. 327, R. 325 and R.324, respectively. The listed activities that have been applied for are provided in Table 3.3 below.

Table 3.2: Listed activities triggered by the proposed 3 x Borrow pits Government Activity Activity Description Relevance to this project Notice Number The decommissioning of any activity  Decommissioning of the requiring (i) a closure certificate in terms quarry once mining is GNR 327 22(i) of Section 43 of the MPRDA (2002). complete will require a closure certificate. The clearance of an area of 1 hectare or  The quarry may require GNR 327 more, but less than 20 hectares of clearance of more than 1 27 indigenous vegetation. hectare of indigenous vegetation. Any activity including the operation of  The quarry will be used for that activity which requires a mining right mining material to be used in as contemplated in Section 22 of the road construction MPRDA (2002) including associated (approximately 25 ha in size infrastructure, structures and earthworks, total). GNR 325 17(b) directly related to the extraction of a  Any activity which requires a mineral resource, including the primary mining right, including processing of a mineral resource activities for which an including winning, extraction, classifying, exemption has been issued, require that an application for concentrating, screening or washing. environmental authorisation be submitted to DMR.

EOH Coastal & Environmental Services 16 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 4. RELEVANT LEGISLATION

In terms of APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Report must include –

e) A description of the policy and legislative context within which the development is located and an explanation of how the proposed development complies with and responds to the legislation and policy context.

4.1 Relevant Legislation and Guidelines used in the Compilation of this Scoping Report

The table below (Table 4.1) summarises the legislation and policy guidelines that are relevant to the proposed borrow pits site.

Table 4.1: Environmental legislation considered in the preparation of this Environmental Impact Assessment Report. Title of Environmental Legislation, Policy or Implications for the proposed quarry Guideline Constitution Act  Obligation to ensure that the quarry site will not result in pollution (108 of 1996) and ecological degradation; and  Obligation to ensure that the proposed quarry site is ecologically This is the supreme law of sustainable, while demonstrating economic and social the land. As a result, all development. laws, including those pertaining to the proposed quarry, must conform to the Constitution.

National Environmental  The developer must be mindful of the principles, broad liability and Management Act (NEMA) implications associated with NEMA and must eliminate or mitigate (107 of 1998) any potential impacts.  The developer must also be mindful of the principles, broad liability The objective of NEMA is: and implications of causing damage to the environment. “To provide for co-  The developer must also comply with the EIA Regulations (2014) operative environmental in the terms of the Act which specifies when an environmental governance by authorisation is required and the nature of the EIA process. establishing principles for decision-making on matters affecting the environment, institutions that will promote co- operative governance and procedures for coordinating environmental functions exercised by organs of state; and to provide for matters connected therewith.”

Mineral and Petroleum  The purpose of the Act is to regulate the prospecting for and the Resources Development optimal exploitation, processing and utilization of minerals; to

EOH Coastal & Environmental Services 17 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Title of Environmental Legislation, Policy or Implications for the proposed quarry Guideline Act (Act No. 28 of 2002) regulate the orderly utilization and the rehabilitation of the surface of land during and after prospecting and mining operations; and to The Mineral and provide for matters connected therewith. Petroleum Resources  SANRAL is exempted from the application for a Mining Development Act (No. 28 Permit/Right, but is not exempted from an application for of 2002) (MPRDA) makes Environmental Authorisation and EMPr. provision for equitable  Any activities requiring extraction of material for construction access to and sustainable purposes will require the submission of an application to DMR for development of South Environmental Authorisation and mining authorisation. Africa‟s mineral and petroleum resources and to provide for matters connected therewith.

National Environmental  The proponent must ensure that all activities associated with the Management: Waste Act project address waste related matters in compliance with the (59 of 2008) requirements of the Act.

The objects of the Act are (amongst others) to: Protect health, well-being and the environment by providing reasonable measures for:  Minimising the consumption of natural resources.  Avoiding and minimising the generation of waste.  Reducing, re-using, recycling and recovering waste.  Treating and safely disposing of waste as a last resort.  Preventing pollution and ecological degradation. Securing ecologically sustainable development while promoting justifiable economic and social development.

National Water Act  Appropriate measures must be taken to prevent the pollution of (36 of 1998) watercourses.  Riparian zones must be protected. The purpose of the Act is  Any mining activity that takes place within a watercourse or within to ensure that the nation‟s 500 m of a wetland will require a water use licence (section 21(c) water resources are and (i) of the National Water Act). protected, managed and controlled.

National Heritage  The Act requires all developers (including mines), to undertake Resources Act (Act No. 25 cultural heritage studies for any development exceeding 5000 m2

EOH Coastal & Environmental Services 18 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Title of Environmental Legislation, Policy or Implications for the proposed quarry Guideline of 1999) in size. It also provides guidelines for impact assessment studies to be undertaken whenever cultural resources may be destroyed The protection of by development activities. archaeological and  ECPHRA/ SAHRA needs to be informed of the project. paleontological resources  Should heritage resources be identified during mining, appropriate is the responsibility of a measures must be undertaken to involve ECPHRA/ SAHRA and to provincial heritage protect these resources. resources authority and all archaeological objects, paleontological material and meteorites are the property of the State.

Mine Health and Safety  The key objectives of the Act are to provide for the health and Act (Act No. 29 of 1996) safety of persons at work and in connection with the use of plants and machinery. The purpose of this Act is  This Act will be applicable during all phases of the project and to provide for protection of therefore necessary measures should be taken to ensure the health and safety of compliance. employees and other persons at mines. Air Quality Act (Act No. 39  The purpose of this Act is to provide for national norms and of 2004) standards regulating air quality monitoring, management and control. The objective of the Air  This Act will be applicable during all phases of the project. The Quality Act is to protect necessary measures must be taken to ensure compliance. the environment by providing the necessary legislation for the prevention of air pollution.

National Environmental  Threatened or Protected Species List: Management: Biodiversity  Identifying any protected animal and plant that will be Act (Act No. 10 of 2004) impacted and remove to a safe natural area.  Alien and invasive Species list: The purpose of this Act is  If any declared weed and/or invader species listed in terms of to provide the this Act is present on site, it must be removed. management and conservation of South Africa‟s biodiversity.

4.2 Relevant policy

4.2.1 National Policy

The National Development Plan (NDP) (also referred to as Vision 2030) is a detailed plan produced by the National Planning Commission in 2011 that is aimed at reducing and eliminating poverty in South Africa by 2030. The NDP represents a new approach by Government to promote sustainable and inclusive development in South Africa, promoting a decent standard of living for all, and includes key focus areas, such as improvement of roads and transport facilities.

EOH Coastal & Environmental Services 19 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 4.2.2 Provincial Policy

The Eastern Cape Vision 2030 Provincial Development Plan sets out nine key challenges that need to be addressed in the Eastern Cape. The challenge relevant to the proposed project has been extracted below:

“(3) Infrastructure is poorly located, under-maintained and insufficient to foster higher growth and spatial transformation. • The road network is severely stressed and deteriorating”.

“…Because there are existing plans for the major arterial routes in the province, the programme will focus on building feeder and secondary roads, particularly rural and access roads, to ensure that no village is without a well-maintained connection to national roads and service centres by 2030.”

4.3 Municipal by-laws and planning

4.3.1 The MLM SDF (June 2014)

The MLM SDF highlights the fact that there are serious road infrastructure challenges in the MLM. Some of the issues mentioned are that roads are in a poor condition and existing roads are not safe.

EOH Coastal & Environmental Services 20 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 5. PROJECT NEED & DESIRABILITY

In terms of Section APPENDIX 2(2) of the EIA Regulations (2017), a Scoping Report must

include –

f) A motivation for the need and desirability for the proposed development including the

need and desirability of the activity in the context of the preferred location.

The proposed quarry will be used for construction material for the upgrade of Route 56 Section 8 between Matatiele & the KZN border. This proposed road upgrade has received environmental authorisation from DEA (DEA Reference: 14/12/16/3/3/2/940).

The need and desirability of this project is supported by National, Provincial and Municipal policy documents.

 The road upgrade speaks directly to the National Development Plan for 2030. The vision statement of the NDP specifically mentions transport and improvement of roads.

 The Eastern Cape Vision 2030 Provincial Development Plan (PDP) emphasises the challenge of road networks in the Eastern Cape and explains that roads are severely stressed and deteriorating. The PDP continues to explain that there are existing plans for the major arterial routes in the province and focus should be given to the construction of feeder and secondary roads. This is to ensure that no village is without a well-maintained connection to national roads.

 The MLM SDF (June 2014) highlights the need for an improvement in the safety and condition of roads in the local municipality.

EOH Coastal & Environmental Services 21 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 6. PROJECT ALTERNATIVES

In terms of APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Assessment Report must include –

h) A full description of the process followed to reach the proposed preferred activity, site and location within the approved site as contemplated in the accepted scoping report, including – (i) Details of all the alternatives considered;

One of the objectives of an EIA is to investigate alternatives to the proposed project. There are two types of alternatives: Fundamental Alternatives and Incremental Alternatives.

6.1 Reasonable and Feasible Alternatives

Alternatives should include consideration of all possible means by which the purpose and need of the proposed activity could be accomplished. The no-go alternative must also in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment.

“Alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to; - a) the property on which or location where it is proposed to undertake the activity. b) the type of activity to be undertaken. c) the design or layout of the activity. d) the option of not implementing the activity.

6.2 Fundamental Alternatives

Fundamental alternatives are developments that are totally different from the proposed project description and usually include the following:

 Alternative property or location where it is proposed to undertake the activity.  Alternative type of activity to be undertaken.  Alternative technology to be used in the activity.

6.3 Incremental Alternatives

Incremental alternatives relate to modifications or variations to the design of a project that provide different options to reduce or minimise environmental impacts. There are several incremental alternatives that can be considered, including:

 Alternative design or layout of the activity.  Alternative technology to be used in the activity.  Alternative operational aspects of the activity

6.4 No-Go development

The EIA process is obligated to assess the status quo (i.e. the “No-Go” option). The No-Go alternative provides the assessment with a baseline against which predicted impacts resulting from the proposed development may be compared. A „‟No-Go” alternative has been assessed for the quarry site.

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6.5 Analysis of alternatives

Table 6.1 illustrates the methodology used to assess the identified alternatives. The table assesses the advantages and disadvantages, and provides further comments on the selected alternatives.

It should be noted that the assessment of alternatives does not consider those alternatives that are not deemed to be either reasonable or feasible.

EOH Coastal & Environmental Services 23 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Table 6.1: The alternatives considered for the proposed borrow pit sites Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment Property or location Alternative location  The geology in  Loss of YES YES The main (Fundamental 1 - Current proposed these locations is agricultural land determining factors location alternative) site (preferred ideal for the (although no for selecting the alternative). dolerite material farming proposed locations required. activities occur were:-  A portion of the onsite).  Appropriate site has already  Removal of geology of the been impacted by approximately area. mining activities 10 hectares of  Location of the (existing Borrow indigenous site relative to Pit as well as a vegetation. the road Brickworks. upgrade site.  The sites are located in close proximity to the road portion that will be upgraded. Alternative location N/A N/A N/A N/A  Alternative 2 – None identified. locations for the proposed quarry are limited and probably not reasonable or feasible due to inappropriate geology.  The appropriate geology was considered a critical aspect.  No alternative location will be assessed for each site in the

EOH Coastal & Environmental Services Gibb Engineering24 R56 Mining Application Environmental Impact Assessment Report – July 2017 Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment impact assessment. Type of technology Alternative  Time effective, i.e.  Increase in YES YES This is the preferred This refers to the technology 1 – shorter time noise levels on and feasible mining fundamental Crushing and required for site and method. technology options screening area on site processing possible required to operate (preferred alternative) material disturbance to the borrow pit sites  Cost effective surrounding areas.  Dust disturbance the surrounding areas especially during windy conditions. Alternative  Less noise and  Higher cost to YES NO This mining method technology 2 – dust generated on have a will not be assessed Crushing and site. crushing and further in the impact screening area offsite screening area assessment process offsite. due to the high costs  Materials will involved in have to be transporting material transported to an offsite crusher. from the quarry site to be processed.

EOH Coastal & Environmental Services Gibb Engineering25 R56 Mining Application Environmental Impact Assessment Report – July 2017 Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment Layout alternative Alternative layout 1  The proposed  Smaller mining YES YES This is the preferred Incremental – Current proposed layout of the area available. layout and will be alternative. layout (preferred borrow pits sites is assessed further in alternative). ideal based on the impact geological assessment. The conditions and a proposed layout has lower heritage been subjected to sensitivity. environmental screening.

No-go option Current land use of - Area will not be - Less job creation. YES YES Will be assessed This refers to the the proposed sites is disturbed by - Area will suffer further in the impact current status quo agriculture. mining operations extensive erosion assessment and the risks and - Less damage to due to grazing. process. impacts associated the environment with it.

EOH Coastal & Environmental Services Gibb Engineering26 R56 Mining Application Environmental Impact Assessment Report – July 2017 7. PUBLIC PARTICIPATION

In terms of APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Assessment Report and must include –

h) A full description of the process followed to reach the proposed preferred activity, site and location within the approved site as contemplated in the accepted scoping report, including – (ii) Details of the public participation process undertaken in terms of regulation 41 of the Regulations, including copies of the supporting documents and inputs; (iii) A summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated, or the reasons for not including them.

7.1 Notification of Interested and Affected Parties

7.1.1 Public Participation

Public consultation is a legal requirement throughout the EIA process. The proponent is required to conduct public consultation throughout the Scoping and EIR phase. Formal EIA documents are required to be made available for public review and comment by the proponent, these include the Project Brief, Scoping Report and Terms of Reference for the EIA, the draft and final EIA reports and the decision of the Competent Authority. The method of public consultation to be used depends largely on the location of the development and the level of education of those being impacted on by the project. Required means of public consultation include:

• Site notice/s; • Newspaper advertisements; • Letter of Notification to affected landowner(s), stakeholders and registered I&APs; • Background Information Document (BID) distribution; • Focus group site meeting (Attendance register and meeting minutes); • Authority and Stakeholder engagement (DMR, DEA, DEDEAT, DWS).

7.1.2 Newspaper advertisement

The proposed activity was advertised in the Daily Dispatch on the 10th June 2016; which provided an overview of the details of the proposed development and provided Interested & Affected Parties (I&AP‟s) with the opportunity to register. Please see Appendix A.

Note: The proposed development will be re-advertised according to the guidelines stipulated in the amended NEMA regulations of 2014.

7.1.3 On-site Notice

A notice was placed on site and has been attached in Appendix A.

7.1.4 Stakeholders and I&APs

A full list of stakeholders and I&APs (who registered) is available in Appendix A. Any new I&APs that register during the EIR phase will be added to this list.

7.1.5 Background information document

The Background information document was circulated to all stakeholders and has been attached in Appendix A.

EOH Coastal & Environmental Services 27 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 7.1.6 Proof of notification

All stakeholders were notified of the EIA and availability of the Draft for public review via email with the Letter of Notification and the BID attached. Please see Appendix A for the email proof of notification.

7.1.7 Issues raised by stakeholders/ I&APs

No comments have been received from the Scoping Phase. The EIR will be available for public comment from the 31 July 2017 to the 20 August 2017.

Table 7.1. Issues raised during site meetings

To be included after the public review period

EOH Coastal & Environmental Services 28 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 8. DESCRIPTION OF THE ENVIRONMENT

In terms of APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Report must include –

h) A full description of the process followed to reach the proposed development footprint within the approved site, including- (iv) The environmental attributes associated with the development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects;

8.1 The Bio-Physical Environment

8.1.1 Current land use

The current land use in the vicinity of the proposed borrow pit sites is indicated in (Figure 8.1). Borrow Pits D660/1 and D660/2 are situated on cultural land which has existing roads. The property on which the existing borrow pit, Borrow Pit D660/2, is located falls within a wetland area and an area considered as a vulnerable ecosystem. The property also contains a residential dwelling. Existing Borrow Pit D639/2 is situated on a property which contains cultivated land, rivers and river tributaries and a residential dwelling as indicated in Figure 8.1. The socio-economic environment that may be affected by the proposed borrow pit sites consists of farms that are mainly used for cultivation.

Figure 8.1: Land use map of the proposed Borrow Pits and surrounding areas.

8.1.2 Climate

The proposed borrow pits are located on Portion 2 and the Remainder of Farm 182 and the Remainder of Farm 186 in the Matatiele Local Municipality of the Eastern Cape Province.

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The climate in Matatiele can be classified as mild with summer rainfall. According to the average monthly temperatures, January is the hottest month at an average of 19.8°C and June is the coldest month with an average temperature of 11.1°C (Figure 8.2a). The average annual temperature is 15.9°C in Matatiele and the average annual rainfall is 710 mm, as indicated in Figure 8.2b below.

` Figure 8.2a: Matatiele average monthly temperatures (°C) and 8.2b: Matatiele average monthly temperatures (°C) and rainfall (mm) (Adapted from http://en.climate- data.org/location/27178/).

8.1.3 Topography

The topography of the borrow pit D660 site is characterised by gently undulating plains to the south and east and a low kopje to the north-northwest of the site. Elevations range from 1460 to 1500 meters above sea level. The topography of the borrow pit D639 site is characterised by steep sloped landscapes. Elevations range from 1660 to 2000 meters above sea level (masl; Figure 8.3).

Figure 8.3: Topography of the proposed Borrow Pits and surrounding areas.

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8.1.4 Geology and soils

Matatiele and Cedarville area falls within the Beaufort Group and Tarkastad Subgroup of the Karoo Supergroup (Figure 8.4). The materials consist of medium- to fine-grained sandstone and mudstones. Geotechnical Soil Profiles were created by Outeniqua Lab (Pty) Ltd. in 2011 for Borrow Pit D660 and Borrow pit D639.

Figure 8.4: Geology map of the proposed Borrow Pits and surrounding areas.

8.1.5 Hydrology

Portion 2 of Farm 182 does not contain any wetlands, rivers or drainage lines but it falls within the 500 metres regulatory buffer of a wetland. The Remainder of Farm 182 contains a large natural wetland area, a river tributary and a drainage line as indicated in Figure 8.5. The Remainder of Farm 186 contains numerous river tributaries.

Authorisation, in accordance with the National Water Act, 1998 (Act No. 36 of 1998), is required from the Department of Water and Sanitation prior to the commencement of any mining or construction activities within the 500 metre regulatory buffer from a wetland and within 50 metres from rivers and drainage lines.

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Figure 8.5: Hydrology map of the proposed borrow pits.

8.1.6 Vegetation

Mucina and Rutherford (2012) have developed the National Vegetation map as part of a South African National Biodiversity Institute (SANBI) funded project: “to provide floristically based vegetation units of South Africa, Lesotho and Swaziland at a greater level of detail than had been available before.” The map was developed using a wealth of data from several contributors and has resulted in the best national vegetation map to date, the previous being that of Adcocks developed over 50 years ago. This map forms the base of finer scale bioregional plans such as Sub-tropical Thicket Ecosystem Plan (STEP).

The map and accompanying book describe each vegetation type in detail, along with the most important species including endemic species and those that are biogeographically important and is the most comprehensive data for vegetation types in South Africa.

Mucina and Rutherford (2006) classify the vegetation at Borrow Pit D660/1 as Mabela Sandy Grassland and the vegetation at Borrow Pit D660/2 as Mabela Sandy Grassland and Eastern Temperate Freshwater Wetlands as indicated in Figure 8.6. Mucina and Rutherford (2006) classify the vegetation at Borrow Pit D639/2 as East Griqualand Grassland.

EOH Coastal & Environmental Services 32 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

Table 8.1: Vegetation types (Mucina & Rutherford, 2006). Vegetation Type Mabela Sandy Grassland (Gs13) Colour in Figure 2.2 Light Yellow Biome Grassland Biome NSBA Conservation Status Vulnerable NSBA Protection Status Hardly protected Remaining % from NSBA 78.7% % of farm portion containing the vegetation Approximately 70% Vegetation Type Eastern Temperate Freshwater Wetlands (AZf3) Colour in Figure 2.2 Bright Green Biome Azonal Vegetation NSBA Conservation Status Least threatened NSBA Protection Status Poorly protected Remaining % from NSBA 85.1% % of farm portion containing the vegetation Approximately 30% Vegetation Type East Griqualand Grassland (Gs12) Colour in Figure 2.2 Dark Green Biome Grassland Biome NSBA Conservation Status Vulnerable NSBA Protection Status Hardly protected Remaining % from NSBA 74.4% % of farm portion containing the vegetation 100%

Borrow Pit D660/1, D660/2 and D639/2 are existing borrow pit sites on Portion 2 and the Remainder of Farm 182 and on the Remainder of Farm 186. The vegetation has already been disturbed by mining activities and it is not in a pristine condition on the proposed sites.

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Figure 8.6: SANBI (2012) Vegetation map of the proposed borrow pits.

This vegetation type sis classified as a Sub-escarpment Grassland, which is a subdivision of the Grassland Biome of South Africa. This grassland type is associated with the foothills of the region & Northern Escarpment.

Mabela Sandy Grassland

This vegetation type is found in flat valley basins with a high proportion of poorly drained soils with low nutrient status. It is dominated by species-poor, low-tussock dominated, sour grassland without any indigenous trees. Indicator species include Sporobolus puramidalis and Aristida junciformis. The vegetation type is considered as VULNERABLE by SANBI while only a small part are statutorily conserved in the Ongeluksnek Wildlife Reserve. More than 20% has already been transformed for cultivation and urban sprawl. Threats to this vegetation unit include heavy selective grazing by livestock, particularly in communal areas. Overgrazing increase this risk of local erosion.

East Griqualand Grassland

This vegetation type is found in hilly country with slopes covered by grassland in places, with patches of bush clumps with Leucosidea siricea (only in wet sites) or Diospyros lycioides, Acacia karroo and Ziziphus mucronata in low-lying and very dry sites. The vegetation type is considered as VULNERABLE by SANBI while only a small part are statutorily conserved in the Ongeluksnek Wildlife Reserve and Mount Currie Nature Reserve. Over one quarter of the area has already been transformed for cultivation (maize), plantations and by urban sprawl. Acacia dealbata and A.Mearnsii are invading these grasslands. Erosion is low (31%), very low (30%) and moderate (30%).

EOH Coastal & Environmental Services 34 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

Eastern Temperate Freshwater Wetlands

This vegetation is found in flat landscapes or shallow depressions filled with (temporary) water bodies supporting zoned systems of aquatic and hygrophilous vegetation of temporarily flooded grasslands and ephemeral herblands. The vegetation is considered as LEAST THREATHNED By SANBI while about 5% is statutorily conserved in the Blesbokspruit, Hogsback, Marievale, Olifantsvlei, Seekoevivlei, Wakkerstroom qwetland, Umgeni Vlei, Umvoti Vleiand Pamula Park Nature Reserves. It is also protected in private nature reserves such as the Korsman Bird Sanctuary and Langfontein. Some15% has been transformed to cultivated land, urban areas or plantations. In places intensive grazing and use of lakes and freshwater pans as drinking pools for cattle or sheep cause major damage to the wetland vegetation.

8.2 Conservation planning

8.2.1 NEMBA – Threatened Ecosystems

The National Environmental Management Biodiversity Act (NEMBA; No. 10 of 2004) identified on a national scale a list of threatened terrestrial ecosystems with an exceptionally high conservation value that requires preserving (GN. R. 10 02; 2011).

No Critical, Endangered or Vulnerable ecosystem was identified within or in close proximity of the proposed borrow pit D639/2. Vulnerable ecosystem (Eastern Temperate Freshwater Wetlands) was identified within or in close proximity of the proposed borrow pit D660/2, as indicated in Figure 8.7 below.

Figure 8.7: NEMBA Threatened Ecosystems map for the Borrow Pits and surrounding areas.

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8.2.2 The National Protected Areas Expansion Strategy

South Africa‟s protected area network currently falls far short of sustaining biodiversity and ecological processes. In this context, the goal of the National Protected Area Expansion Strategy (NPAES 2008) is to achieve cost-effective protected area expansion for ecological sustainability and increased resilience to climate change. The NPAES highlights ways in which we can become more efficient and effective in allocating the scarce human and financial resources available for protected area expansion. It sets targets for protected area expansion, provides maps of the most important areas for protected area expansion, and makes recommendations on mechanisms for protected area expansion. The common set of targets and spatial priorities provided by the NPAES enable co-ordination between the many role players involved in protected area expansion.

Figure 8.8 below indicates areas identified by the NPAES as future potential threatened ecosystems.

Figure 8.8: Protected Areas map for the Borrow Pits and surrounding areas.

Southern Berg Griqualand

The Southern Berg Griqualand focus area in the Eastern Cape represents one of the few opportunities for large formal protected areas in the highly threatened Grassland Biome, and contains some of the few examples left of inland free-flowing rivers. It was also identified as a key national priority in the Maloti-Drakensberg and Grasslands systematic biodiversity plans.

EOH Coastal & Environmental Services 36 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 8.2.3 Eastern Cape Biodiversity Conservation Plan

The main outputs of the Eastern Cape Biodiversity Conservation Plan (ECBCP) are the identification of “critical biodiversity areas” or CBAs, which are allocated the following management categories: (1) CBA 1 = Maintain in a natural state and (2) CBA 2 = Maintain in a near-natural state. The ECBCP portrays CBAs based on extensive biological data and input from key stakeholders. The ECBCP, although mapped at a finer scale than the National Spatial Biodiversity Assessment (Driver et al., 2005), is still relatively high-levelled. It is therefore imperative that the status of the environment, for any proposed development MUST first be verified before the management recommendations associated with the ECBCP are considered (Berliner and Desmet, 2007).

The recommended land use objectives for these areas are as follows:

 CBA 1: Maintain Natural State Areas: The recommended land use objective for the biodiversity in these areas is to be maintained in as natural a state as possible. All these areas are found close or next to wetlands and rivers, and must be managed with no biodiversity loss.  CBA 2: Maintain Near Natural State Areas: The recommended land use objective for the “maintain near natural state” classification is for biodiversity to be maintained in a near natural state with minimal loss of ecosystem integrity, and that no transformation of natural habitat should be permitted. The recommended land uses for this classification are conservation, game farming and communal livestock farming.

Portion 2 of Farm 182, Borrow Pit D660/1, falls within a Terrestrial and an Aquatic CBA 2 area and it is recommended that these areas are maintained in a near natural state. The Remainder of Farm 182, Borrow Pit D660/2, primarily falls within a Terrestrial and Aquatic CBA 2 area with an area to west that falls within a Terrestrial CBA1. It is recommended that the CBA1 areas are maintained in a natural state. The Remainder of Farm 186, Borrow Pit D639/2, falls within a Terrestrial CBA 1 area and an Aquatic CBA 2 area with an Aquatic CBA 1 area to the south of the property. The three borrow pit sites fall within both Terrestrial and Aquatic CBAs which are degraded because the natural area has been transformed by the existing borrow pit sites. Figure 8.9a identifies the terrestrial critical biodiversity areas occurring within the proposed borrow pit sites and Figure8.9b identifies the aquatic critical biodiversity areas occurring within the proposed borrow pit sites.

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Figure 8.9a: Terrestrial CBA map of the proposed borrow pits.

Figure 8.9b: Aquatic CBA map of the proposed borrow pits.

EOH Coastal & Environmental Services 38 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 8.3 Socio-Economic Profile

The proposed R56 borrow pit sites fall within the Matatiele Local Municipality (M LM) in the Alfred Nzo District Municipality (AN DM). The M LM covers an area of approximately 4,352 km2. The discussion below provides a brief socio-economic profile of the municipal area.

8.3.1 Population

According to StatsSA 2011, the local municipality has a total population of 203 843. The population demographic based on the 2011 census was 98, 1% black, 0, 7% white, 0, 9% coloured and 0.3% Indian/Asian. The gender distribution shows the high percentage of females than males, 54% are females and males 46%. Age distribution revealed that there is a relatively high youth component of the population, with 71% that are younger than 35 years of age and 7% over 65 years of age.

8.3.2 Employment

In the M LM 39 406 people are economically active (employed or unemployed but looking for work), and of these 38.7% are unemployed. Of the 20 932 economically active youth (15 – 34 years) in the area, 47.2% are unemployed (Statistics South Africa).

8.3.3 Education

According to StatsSA 2011, 8.2% of people aged 20 years have completed primary school, 38, 4% have some secondary education, 12,8% have completed matric and 5, 8% have some form of higher education.

EOH Coastal & Environmental Services 39 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 9. MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED

In terms of Section APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Assessment Report must include –

h) A full description of the process followed to reach the proposed development footprint within the site as contemplated in the accepted scoping report, including – (vi) The methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks.

In line with the above-mentioned legislative requirement, this chapter of the EIR details the approach to the EIA phase of the proposed dolerite quarry with a particular focus on the methodology that was used when determining the significance of potential environmental impacts.

9.1 General Impact Assessment

A general impact assessment was conducted based on site visits and information relating to the planning and design, construction, operation and decommissioning/closure of the proposed dolerite quarry.

9.2 Specialist Impact Assessment

A series of specialist studies were conducted during the EIA for the proposed road upgrade. These specialist studies included the proposed dolerite quarry site in their assessment. The outcomes will be summarised in this EIR. Specialist studies that will be incorporated in this EIR:

 Ecological Impact Assessment  Heritage Impact Assessment

9.3 Methodology for Assessing Impacts and Alternatives

Introduction

Identified impacts will be assessed against the following criteria:

 Temporal scale  Spatial scale  Risk or likelihood  Degree of confidence or certainty  Severity or benefits  Significance

The relationship of the issue to the temporal scale, spatial scale and the severity are combined to describe the overall importance rating, namely the significance of the assessed impact.

EOH Coastal & Environmental Services 40 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 9.3.1 Description of criteria

Table 9.1: Significance Rating Table

Significance Rating Table

Temporal Scale (The duration of the impact) Short term Less than 5 years (Many construction phase impacts are of a short duration). Medium term Between 5 and 20 years.

Long term Between 20 and 40 years (From a human perspective almost permanent). Permanent Over 40 years or resulting in a permanent and lasting change that will always be there. Spatial Scale (The area in which any impact will have an affect) Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area. Study area The proposed site and its immediate environs.

Municipal Impacts affect the local municipality(s), or any towns within them.

Regional Impacts affect the wider district municipality or the province as a whole. National Impacts affect the entire country. International/Global Impacts affect other countries or have a global influence.

Likelihood (The confidence with which one has predicted the significance of an impact) Definite More than 90% sure of a particular fact. Should have substantial supportive data. Probable Over 70% sure of a particular fact, or of the likelihood of that impact occurring. Possible Only over 40% sure of a particular fact, or of the likelihood of an impact occurring. Unsure Less than 40% sure of a particular fact, or of the likelihood of an impact occurring.

Table 9.2 Impact Severity Rating Impact severity (The severity of negative impacts, or how beneficial positive impacts would be on a particular affected system or affected party) Very severe Very beneficial An irreversible and permanent change to the A permanent and very substantial benefit to affected system(s) or party(ies) which cannot be the affected system(s) or party(ies), with no mitigated. For example the permanent loss of real alternative to achieving this benefit. For land. example the vast improvement of sewage effluent quality. Severe Beneficial Long term impacts on the affected system(s) or A long term impact and substantial benefit to

EOH Coastal & Environmental Services 41 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 party(ies) that could be mitigated. However, this the affected system(s) or party(ies). Alternative mitigation would be difficult, expensive or time ways of achieving this benefit would be consuming, or some combination of these. For difficult, expensive or time consuming, or example, the clearing of forest vegetation. some combination of these. For example an increase in the local economy. Moderately severe Moderately beneficial Medium to long term impacts on the affected A medium to long term impact of real benefit to system(s) or party (ies), which could be mitigated. the affected system(s) or party(ies). Other For example constructing a sewage treatment ways of optimising the beneficial effects are facility where there was vegetation with a low equally difficult, expensive and time conservation value. consuming (or some combination of these), as achieving them in this way. For example a „slight‟ improvement in sewage effluent quality. Slight Slightly beneficial Medium or short term impacts on the affected A short to medium term impact and negligible system(s) or party(ies). Mitigation is very easy, benefit to the affected system(s) or party(ies). cheap, less time consuming or not necessary. For Other ways of optimising the beneficial effects example a temporary fluctuation in the water are easier, cheaper and quicker, or some table due to water abstraction. combination of these. No effect Don‟t know/Can‟t know The system(s) or party(ies) is not affected by the In certain cases it may not be possible to proposed development. determine the severity of an impact.

Table 9.3 Overall Significance Rating Overall Significance (The combination of all the above criteria as an overall significance) VERY HIGH NEGATIVE VERY BENEFICIAL These impacts would be considered by society as constituting a major and usually permanent change to the (natural and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects. Example: The loss of a species would be viewed by informed society as being of VERY HIGH significance. Example: The establishment of a large amount of infrastructure in a rural area, which previously had very few services, would be regarded by the affected parties as resulting in benefits with VERY HIGH significance. HIGH NEGATIVE BENEFICIAL These impacts will usually result in long term effects on the social and/or natural environment. Impacts rated as HIGH will need to be considered by society as constituting an important and usually long term change to the (natural and/or social) environment. Society would probably view these impacts in a serious light. Example: The loss of a diverse vegetation type, which is fairly common elsewhere, would have a significance rating of HIGH over the long term, as the area could be rehabilitated. Example: The change to soil conditions will impact the natural system, and the impact on affected parties (such as people growing crops in the soil) would be HIGH. MODERATE NEGATIVE SOME BENEFITS These impacts will usually result in medium to long term effects on the social and/or natural environment. Impacts rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium term change to the (natural and/or social) environment. These impacts are real but not substantial. Example: The loss of a sparse, open vegetation type of low diversity may be regarded as MODERATELY significant. LOW NEGATIVE FEW BENEFITS These impacts will usually result in medium to short term effects on the social and/or natural environment. Impacts rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly unimportant and usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely to have little real effect.

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Example: The temporary changes in the water table of a wetland habitat, as these systems are adapted to fluctuating water levels. Example: The increased earning potential of people employed as a result of a development would only result in benefits of LOW significance to people who live some distance away. NO SIGNIFICANCE There are no primary or secondary effects at all that are important to scientists or the public. Example: A change to the geology of a particular formation may be regarded as severe from a geological perspective, but is of NO significance in the overall context. DON‟T KNOW In certain cases it may not be possible to determine the significance of an impact. For example, the primary or secondary impacts on the social or natural environment given the available information. Example: The effect of a particular development on people‟s psychological perspective of the environment.

EOH Coastal & Environmental Services 43 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 10. KEY FINDINGS OF THE SPECIALIST STUDIES

In terms of APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Report must include-

(k) A summary of the findings and recommendations of any specialist report complying with Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final assessment report.

The following discussion summarises the key findings of the specialist studies. Full reports have been attached in Appendix C of the EIR. The relevant impacts and mitigation measures from these specialist studies have been included in the Impact Assessment of this report.

10.1 Specialists studies

The following Specialist Studies have been completed for the EIA Phase:

 Baseline Aquatic Biodiversity Assessment (Byron Bester from GIBB)  Ecological Impact Assessment (Robyn Phillips from GIBB)  Heritage Impact Assessment (DR Gideon Groenewald from PGS Heritage)

Please note that these Specialist Studies were developed for the R56 road upgrade EIA but the studies included the original quarry sites investigated.

10.1.1 Aquatic and Wetland Impact Assessment

Aquatic Specialist

GIBB was appointed by SANRAL to investigate the potential impacts that the proposed Matatiele R56 road upgrade could have on the aquatic ecosystem.

Approach to study

To enable an adequate description and the determination of the Present Ecological State (or Ecological Category) and Ecological Importance and Sensitivities associated with the aquatic ecosystem, the following indicators were evaluated as part of the study:

 Stressor Indicators: o In situ water quality (Temperature, pH, Electrical Conductivity, and Dissolved Oxygen);  Habitat Indicators: o Adapted Invertebrate Habitat Assessment System (IHAS, Version 2.2); o Index for Habitat Integrity (IH, Version 2);  Response Indicators: o Aquatic macro-invertebrates with the use of the South African Scoring System (SASS, Version 5) rapid bio-assessment protocol and the Macro-Invertebrate Response Assessment Index (MIRAI); o Ichthyofauna with the use of the Fish Response Assessment Index (FRAI); and o Determination of the integrated EcoStatus.

The field survey was conducted from the 11th to 15th of April 2016. The samples for assessing the aquatic and wetland conditions were taken from six watercourses associated with the road crossings. The figure 10.1 shows the points where the samples were taken.

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Figure 10.1: shows the water resources associated with Matatiele R56 Road Upgrade.

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Of the six selected sample sites, site T3KINI-USMAT and site T3MZIM-CMPSN were dry during the field survey, this could be linked with drought conditions within the area thus the level of water in the selected water crossing were relatively low.

Results

Based on results obtained during the April 2016 field survey, it was determined that unnamed tributaries of the Mzimvubu River each represented an integrated EcoStatus of largely modified (Ecological Category D; i.e. Site T3MZIm-ALING and Site T3MZIM-STRYD;) and largely-to- seriously modified (Ecological D/E; i.e. Site T3MZIM-EDNDL) conditions. These conditions were attributed to an absence of fish along each of the assessed watercourses, which may have been facilitated by the fragmented habitat created by established farm dams within the study area, and a poor habitat availability for micro-invertebrate colonisation, which was likely to a result of the inherent nature of the suspected channelled valley-bottom wetlands systems (i.e. Site T3MZIM- EDNDL and Site T3MZIM-ALING). With respect to the larger perennial systems, it was determined that the integrated EcoStatus was representative of moderately modified (Ecological Category C) at Site T3MZIM-STRYDand a largely modified (Ecological Category D) conditions at Site T3MZIM- DSR56 conditions.

However it was suspected that the instream biological integrity was skewed at the time of the current survey as a result of low water levels and subsequent lack of niche habitat, especially along the main stem Mzimvubu River. Nevertheless, these systems were still believed to support the established aquatic communities within the study area and to effectively provide refugia habitat during periods low rainfall (or drought), as observed at the time of survey.

Recommendations

With reference to wetland-related features, it is strongly recommended that a wetland assessment be conducted by a recognised wetland specialist. It is also recommended that the financial provisions also be set aside for the upgrade of various cattle underpasses, included those observed at the time of the survey.

10.1.2 Ecological Impact Assessment

Ecological Specialist

The Environmental Specialist at GIBB was appointed by SANRAL to investigate the potential impacts that the proposed Matatiele R56 road upgrade could have on the ecological ecosystem.

Approach to study

The project comprises of the rehabilitation and reseal of National Route R56 Section 8, from the intersection of East Street and the R56 in Matatiele to the Kwazulu- border near . The Ecological assessment includes an overview of the Environmental features in the landscape and sensitivities associated with a 1km wide corridor (500m on either side of the centre line) around the proposed section of road to be upgraded; and the collection and analyses of the results taken during the field survey.

EOH Coastal & Environmental Services 46 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Results

The study is located within the Grassland Biome, which is characterised by high summer rainfall and dry winters. A large number of Rare and Threatened plant species in the summer rainfall regions of South Africa are restricted to high-rainfall grassland, making this the vegetation type in most urgent and need of conservation. Four vegetation types are associated with the study area, namely East Griqualand Grassland, Mabela Sandy Grassland, Eastern Temperature Freshwater Wetlands, and Highveld Alluvial Vegetation. East Griqualand Grassland and Mabela Sandy Grassland are both currently classified as vulnerable while Eastern Temperature Freshwater Wetlands and Highveld Alluvial Vegetation are currently classified as Least Threatened, although poorly protected.

The footprint of the proposed road rehabilitation project is relatively narrow (50m) and contained mainly the existing road reserve where little or natural vegetation remained. It mostly comprised transformed areas, and secondary grassland disturbed by previous road-related construction activities. The greater study area comprised s mosaic of grassland and farmland, with watercourses, wetlands, pans and dams interspersed amongst agricultural fields and pastures. A few rocky outcrops and ridges occurred with associated rocky grassland. Stands of exotic trees were found in various places along the route.

While the habitats within the footprint of the proposed road reserve were generally transformed or disturbed, the areas surrounding Matatiele and Cedarville are recognised as important ecological habitat that supports many floral and faunal species of conservation concern. Bird species such as Blue Crane, Grey Crowned Crane, Wattled Crane, Secretarybird, Denham‟s Bustard and African Marsh Harrier frequent the grasslands, dams, wetlands in the area. Highly sensitive Habitat associated with the study area therefore included any riparian or wetland habitat (including farm dams) within the 500m and within the road reserve. Rocky areas such as ridges and koppies were also classified as highly sensitive.

Recommendations

While the construction footprint will be relatively narrow, impacts on the greater study area may be high due to the sensitive nature of the landscape. In order to minimise the impacts on the surrounding areas, the following activities must take place prior to construction:

1. A full wetland delineation and functional assessment must be undertaken by a suitably qualified wetland specialist. The report must include an assessment of impacts with mitigation measures and rehabilitation plans. 2. Prior to construction, a walk-down of the entire route must be undertaken by suitably qualified ecologist or botanist to identify plant species present in the road reserve that may require rescue and relocation. This must be undertaken in the summer during the peak flowering period between November and March. 3. Prior to construction, night-time surveys must be undertaken by a suitably qualified ecologist or herpetologist to identify the presence of chameleon species of conservation concern along the route. If found, individuals will need to be rescued and relocated to suitably habitat away from the site, by a suitably qualified specialist, prior to construction commencing. 4. Furthermore, as construction commences along the route, regular searches of the construction footprint should take place for chameleons. If animals are encountered by construction staff during construction, the ECO must be notified immediately. No animals are to be harmed, handled, or interfered with by construction staff. A suitably qualified ecologist or herpetologist should therefore to be on stand-by throughout the duration of the project. 5. It is recommended that construction begin in the dry winter months so as to minimise disturbance to breeding fauna, especially amphibian species breeding in temporary roadside pools.

EOH Coastal & Environmental Services 47 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 10.1.3 Heritage Impact Assessment

Heritage Specialist

PGS Heritage (PGS) was appointed by GIBB (Pty) Ltd to investigate the potential impacts that the proposed Matatiele R56 road upgrade could have on the local heritage features.

The Heritage assessment includes the study of the legal requirements relating to Heritage Sites (SAHRA), the study of the physical environment (physical survey which was conducted from Monday 11th April 2016 to Wednesday, 13th April 2016) and collection and analysing of relevant heritage data as well as mapping and recommendations.

Heritage Features in the Study Area

The area has nine (10) archaeological and cultural heritage Sites, none within 500m of any of the proposed 3 mining sites. Figure 10.2 below shows the identified heritage sites

Recommendations

Due to the subterranean nature of many of the lithic sites identified during the fieldwork, it is recommended that an archaeological watching brief be implemented during the course of the construction work on the project. The watching brief should comprise a site visit by a suitably qualified and experienced archaeologist once every three weeks during the duration of the construction.

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Figure 10.2: Spatial display of the identified archaeological and cultural heritage resources in relation to Matatiele R56 Road study site.

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Sample of lithics identified at MAT1. Sample of lithics identified at MAT 2.

The north-eastern end of the bridge, showing the date MAT3. Sample of lithics identified at MAT4.

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Sample of lithics identified at MAT5 Sample of lithics identified at MAT6

Sample of lithics identified at MAT7 Identified old house at MAT8

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Identified old church at MAT8 Sample of lithics identified at MAT9

Sample of lithics identified at MAT10 Figure 10.3: the digital photographs of the identified archaeological and cultural sites in the proposed Matatiele R56 study site, Eastern Cape.

EOH Coastal & Environmental Services Gibb Engineering52 R56 Mining Application Environmental Impact Assessment Report – July 2017 10.2 Sensitivity assessment

A sensitivity map of the 3 mining areas is provided in Figure 10.4 and 10.5 below. These maps were developed based on site visits and the relevant specialist reports. Borrow pit D660/1 and D660/2 and the area surrounding the borrow pit has a moderate sensitivity with highly impacted areas within D660/1 (old BP excavations) that was classified a low sensitivity.

Figure 10.4: Sensitivity map of the proposed Borrow Pits 1 & 2 and surrounding areas.

The proposed borrow pit D639/2 site and area immediately surrounding the site is considered to have a moderate sensitivity.

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Figure 10.5: Sensitivity map of the proposed Borrow Pit 3 and surrounding areas.

EOH Coastal & Environmental Services 54 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 11. IMPACT ASSESSMENT

In terms of APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Assessment Report must include –

h) A full description of the process followed to reach the proposed development footprint within the approved site as contemplated in the accepted scoping report, including – (v) The impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts –  Can be reversed;  May cause irreplaceable loss of resources; and  Can be avoided, managed or mitigated; (vii) Positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; i) A full description of the process undertaken to identify, assess and rank the impacts that the activity and associated structures and infrastructure will impose on the preferred location through the life of the activity, including –  A description of all environmental issues and risks that were identified during the environmental impact process; and  An assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures. (j) An assessment of each identified potentially significant impact and risk, including –  Cumulative impacts;  The nature, significance and consequences of the impact and risk;  The extent and duration of the impact and risk;  The probability of the impact and risk occurring;  The degree to which the impact and risk can be reversed;  The degree to which the impact and risk may cause irreplaceable loss of resources;  The degree to which the impact and risk can be mitigated.

11.1 Possible Environmental Issues and Impacts

The impact assessment for the proposed quarry was conducted in two parts:

• General Impact Assessment • Specialist Impact Assessment

The general impact assessment and specialist impact assessments were combined into one table per phase and a detailed assessment of all impacts and mitigation measures is available in Appendix C.

11.1.1 General Impact Assessment

The general impact assessment identified and assessed impacts across four phases of quarry development:

• Planning & Design Phase • Construction Phase • Operational or Mining Phase • Decommissioning/Closure Phase

Issues identified were not covered in the specialist studies such as:

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• Waste management • Quarry design • Sanitation • Hazardous substances • Dust and noise issues • Socio-economic impacts • General construction impacts • Stormwater management • Visual impacts

11.1.2 Specialist Impact Assessment

The specialist impact assessment covered issues identified by the following specialist studies:

• Ecological Impact Assessment • Heritage Impact Assessment

Summary of findings

The various issues and impacts that were identified are summarised in table 11.1 and 11.2 below.

Table 11.1 Summary of the issues identified and their applicability in each phase. IMPACTS TABLE PLANNING & CONSTRUCTION OPERATIONAL DECOMMISSIONING CATEGORY DESIGN PHASE PHASE PHASE PHASE Legislation and Policy X Compliance Eastern Cape Biodiversity X Conservation Plan (ECBCP) National Environmental Management: Biodiversity Act: X Threatened or Protected Species Job Creation X X Health and safety risk associated X with fires Water and X Sanitation Rehabilitation, Alien Vegetation X X and Erosion Management Litter X management Visual X X Air pollution X X (dust) Noise pollution X X Palaeontological X X Findings

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Site contamination X due to hazardous substances Water Bodies X X Loss of indigenous X vegetation Species of Conservation X Concern Water Quality X Final rehabilitation and X decommissioning Closure X

Table 11.2. Summary of all General and Specialist Impacts. Theme Description of impact Planning and Design Phase GENERAL IMPACTS Compliance with relevant During the planning and design phase failure to comply with existing environmental legislation and policies and legal obligations could lead to the project conflicting with policy local, provincial and national policies, legislation etc. This could result in legal non-compliance, fines, overall project failure or delays in mining activity and undue disturbance to the natural environment. Eastern Cape Biodiversity During the planning and planning phase, the Terrestrial and Aquatic Conservation Plan (ECBCP) Critical Biodiversity Areas (CBAs), which occur within the proposed site, could be adversely affected if the planning and design of the proposed borrow pits is not consistent with the ECBCP recommendations for Critical Biodiversity Areas (CBAs). National Environmental The inappropriate expansion of Borrow Pit D660/1 could lead to the Management: Biodiversity loss of identified and unidentified plant and animal SCC. Act: Threatened or Protected Species Job Creation The proposed borrow pits and the related mining activities will create temporary employment opportunities during the various phases of development. Construction Phase GENERAL IMPACTS Air pollution (dust) Air pollution, in the form of dust, caused by construction activities, such as grading and levelling exposed land, can cause a nuisance to traffic on the farm roads and to the farm owners and neighbouring farmers. Noise pollution Noise pollution caused by construction activities could potentially be a nuisance to farm owners and neighbouring farmers. Rehabilitation, Alien The lack of an effective Rehabilitation, Alien Vegetation and Erosion Vegetation and Erosion Management Plan could lead to erosion and large scale alien plant Management invasion. Visual The construction of the borrow pit areas will have a limited visual impact and the borrow pit areas should only be visible to immediate landowners and road users on the D660 and D639. Water bodies The construction of the borrow pits could adversely affect rivers, wetlands and drainage systems in proximity to the borrow areas. Site contamination due to Poorly maintained machinery could lead to soil pollution during the hazardous substances construction phase.

EOH Coastal & Environmental Services 57 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Theme Description of impact Health and safety risk Inadequate attention to fire safety awareness and fire safety associated with fires equipment during the construction phase could result in runaway fires, an unsafe working environment and the loss of property. Water and sanitation Failure to provide adequate onsite sanitation and clean drinking water during the construction phase may result in runoff transferring contaminants into the surrounding environment and/or pose a risk to the health of the construction workers. Litter management Litter onsite may attract vermin, detract from the appearance of the area, and pollute the surrounding areas during the construction phase. Water quality During the construction phase, accidental chemical spills or other spills (such as sewage) in the vicinity of the rivers and/or drainage lines will result in water pollution, adversely affecting the aquatic ecosystems. Species of Conservation The uncontrolled clearing of vegetation during the construction Concern phase could lead to the loss of identified and unidentified plant and animal SCC. Job creation Temporary employment opportunities will be created during the construction phase. Palaeontological Findings Sensitive palaeontological findings could be damaged or destroyed by construction activities during the construction phase. Loss of indigenous The clearing of vegetation for the borrow areas during the vegetation construction phase will result in the loss of indigenous vegetation. Operation (Mining) Phase GENERAL IMPACTS Rehabilitation, Alien The lack of an effective Rehabilitation, Alien Vegetation and Erosion Vegetation and Erosion Management Plan, post-construction, could lead to erosion and large Management scale alien plant invasion during the operational phase. Job creation Temporary employment opportunities will be created during the operation of the borrow pits. Visual The operation of the borrow pit areas will have a limited visual impact and the borrow pit areas should only be visible to immediate landowners and road users on the D660 and D639. Water bodies The mining activities in the borrow pits could adversely affect rivers, wetlands and drainage systems in proximity to these borrow areas. Palaeontological Findings Sensitive palaeontological findings could be damaged or destroyed by mining activities during the operational phase. Air pollution (dust) Air pollution, in the form of dust, caused by construction activities, such as grading and levelling exposed land, can cause a nuisance to traffic on the farm roads and to the farm owners and neighbouring farmers. Noise pollution Noise pollution caused by construction activities could potentially be a nuisance to farm owners and neighbouring farmers. Decommissioning/Closure Phase GENERAL IMPACTS Final rehabilitation and During the decommissioning phase failure to decommission and decommissioning rehabilitate the mining site properly could result in soil erosion, storm water issues, safety risks and invasion of alien plant species. Closure During the decommissioning phase failure to comply with the closure requirements could result in unnecessary environmental degradation and failure to obtain a closure certificate from DMR.

EOH Coastal & Environmental Services 58 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 12. IMPACT STATEMENT

In terms of APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Assessment Report must include:

(l) An environmental impact statement which contains – (i) A summary of the key findings of the environmental impact assessment; (ii) A map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred development footprint on the approved site as contemplated in the accepted scoping report indicating any areas that should be avoided, including buffers; and (iii) A summary of the positive and negative impacts and risks of the proposed activity and identified alternatives;

(n) The final proposed alternatives which respond to the impact management measures, avoidance, and mitigation measures identified throughout the assessment;

In line with the above-mentioned legislative requirement, this chapter of the EIR provides an Environmental Impact Statement which summarises the environmental impact assessment findings. This chapter of the EIR also includes a sensitivity map and a summary of the alternatives investigated.

12.1 Environmental impact statement

The HIGH negative impacts that were identified are summarised in Table 12.1 below. These impacts can all be reduced through the recommended mitigation measures to LOW or MODERATE post-mitigation impacts.

Table 12.1 High impacts identified for the proposed borrow pit sites. Theme Description of impact Planning and Design Phase GENERAL IMPACTS Eastern Cape Biodiversity During the planning and planning phase, the Terrestrial and Conservation Plan (ECBCP) Aquatic Critical Biodiversity Areas (CBAs), which occur within the proposed site, could be adversely affected if the planning and design of the proposed borrow pits is not consistent with the ECBCP recommendations for Critical Biodiversity Areas (CBAs). National Environmental The inappropriate expansion of Borrow Pit D660/1 could lead Management: Biodiversity to the loss of identified and unidentified plant and animal SCC. Act: Threatened or Protected Species Construction Phase GENERAL IMPACTS Rehabilitation, Alien The lack of an effective Rehabilitation, Alien Vegetation and Vegetation and Erosion Erosion Management Plan could lead to erosion and large Management scale alien plant invasion. Water bodies The construction of the borrow pits could adversely affect rivers, wetlands and drainage systems in proximity to the borrow areas. Health and safety risk Inadequate attention to fire safety awareness and fire safety associated with fires equipment during the construction phase could result in runaway fires, an unsafe working environment and the loss of property.

EOH Coastal & Environmental Services 59 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Theme Description of impact Species of Conservation The uncontrolled clearing of vegetation during the construction Concern phase could lead to the loss of identified and unidentified plant and animal SCC. Palaeontological Findings Sensitive palaeontological findings could be damaged or destroyed by construction activities during the construction phase. Operation (Mining) Phase GENERAL IMPACTS Rehabilitation, Alien The lack of an effective Rehabilitation, Alien Vegetation and Vegetation and Erosion Erosion Management Plan, post-construction, could lead to Management erosion and large scale alien plant invasion during the operational phase. Water bodies The mining activities in the borrow pits could adversely affect rivers, wetlands and drainage systems in proximity to these borrow areas. Palaeontological Findings Sensitive palaeontological findings could be damaged or destroyed by mining activities during the operational phase. Decommissioning/Closure Phase GENERAL IMPACTS Final rehabilitation and During the decommissioning phase failure to decommission decommissioning and rehabilitate the mining site properly could result in soil erosion, storm water issues, safety risks and invasion of alien plant species. Closure During the decommissioning phase failure to comply with the closure requirements could result in unnecessary environmental degradation and failure to obtain a closure certificate from DMR.

12.1.1 Comparative assessment of impacts

Below is an assessment of the impacts in terms of the number of impacts identified for each phase. The breakdown of the impact assessments in Table 12.2 to 12.5 below provides insight into the key issues of all phases (including the no-go option) of the proposed dolerite quarry.

GENERAL IMPACT ASSESSMENT

An analysis of the distribution of General impacts identified indicates that the bulk of the mitigation effort should be placed on the Planning and Design, Construction Phase. The HIGH impacts identified in the planning and design phase and construction phase relate to compliance with legislation, Rehabilitation, Alien Vegetation and Erosion Management, water bodies, Health and safety risk associated with fires, Species of Conservation Concern and Paleontological Findings.

Both HIGH and MODERATE identified impacts can be significantly reduced through the recommended mitigation measures resulting in predominantly LOW post-mitigation impacts.

One impact was identified as being positive impacts. This impact related to the socio-economic benefit of the proposed development in terms of job creation.

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Table 12.2 Comparative Assessment of General Impacts occurring in all phases for the proposed quarry (+ = beneficial impact) PRE-MITIGATION POST-MITIGATION VERY VERY LOW MODERATE HIGH LOW MODERATE HIGH HIGH HIGH Planning & Design 0 2 3 0 5 0 0 0 Construction 0 2(+1) 2 0 4 +1 0 0 Operation 0 6(+1) 3 0 9 +1 0 0 Decommissioning 0 0 2 0 2 0 0 0 TOTAL 0 10(+2) 10 0 20 (+2) 0 0

NO-GO IMPACT ASSESSMENT

The negative impacts identified when assessing the NO-GO alternative related to communities in the project area (possibly 32 800 households) not having sufficient access to potable water. Socio- economic development in the study area would also be inhibited.

Table 12.5 Impacts associated with the No-go alternative. PRE-MITIGATION POST-MITIGATION VERY VERY LOW MODERATE HIGH LOW MODERATE HIGH HIGH HIGH TOTAL +1 1(+1) 1 0 +1 1(+1) 1 0

12.2 Overall site sensitivity

The entire site has been assessed by various specialists, and this information has been analysed spatially and then used to inform the most environmentally acceptable layout for the borrow pits. This final layout is based on an overall sight rate of MODERATE AND LOW sensitivity (Figure 12.1 below).

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Figure 12.1 Sensitivity maps of the study area.

EOH Coastal & Environmental Services 62 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 12.3 Consideration of alternatives

Chapter 6 provides a detailed comparison of alternatives for the proposed dolerite quarry. It should be noted that the assessment of alternatives does not consider those alternatives that are not deemed to be either reasonable or feasible.

12.3.1 Location alternatives

The current location (preferred alternative) is the only alternative assessed in the impact assessment process. Alternative locations for the proposed borrow pits are limited and probably not reasonable or feasible due to inappropriate geology (critical aspect).

12.3.2 Technology alternatives

The technology alternatives considered in Chapter 6 are a crushing and screening area on site (preferred) and a crushing and screening area offsite (not feasible). Only the former is assessed in the impact assessment as the latter is not considered to be economically viable. Dolerite material would have to be transported significant distances in order to get processed.

12.3.3 Layout alternatives

The current layout (preferred alternative) is the only layout alternative assessed in the impact assessment. The proposed layout has been subjected to environmental screening and is based on ideal geological conditions and lower heritage sensitivity.

EOH Coastal & Environmental Services 63 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 13. CONCLUSIONS, EAP AND RECOMMENDATIONS

In terms of APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Assessment Report must include –

(m) Based on the assessment, and where applicable, recommendations from specialist reports, the recording of proposed impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation; (o) Any aspects which were conditional to the findings of the assessment either by the EAP or specialist which are to be included as conditions of authorisation. (p) A description of any assumptions, uncertainties and gaps in knowledge which relate to the assessment and mitigation measures proposed; (q) A reasoned opinion as to whether the proposed activity should or should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation; (r) Where the proposed activity does not include operational aspects, the period for which the environmental authorisation is required and the date on which the activity will be concluded and the post construction monitoring requirements finalised; (s) An undertaking under oath or affirmation by the EAP in relation to:  The correctness of the information provided in the reports;  The inclusion of comments and inputs from stakeholders and I&APs;  The inclusion of inputs and recommendations from the specialist reports where relevant; and  Any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested or affected parties;

In line with the above-mentioned legislative requirement, this Chapter of the EIR provides the recommended mitigation measures, uncertainties or gaps in knowledge, the EAP‟s opinion as to whether or not the activity should be authorised and the reason(s) for this opinion as well as an undertaking by the EAP.

13.1 Description of the proposed activity

SANRAL will be constructing various safety improvements on Section 8 of the R56 Route from Matatiele (km 130.15), passing through Cedarville to KwaZulu-Natal Border (km 168.71) in the Eastern Cape Province. GIBB Engineering, the project managers, contracted EOH as the EAP to undertake the EIA for this project. SANRAL was granted environmental authorisation for this road upgrade.

The proposed road rehabilitation requires a hard rock (dolerite) to supply the necessary rock material for the road construction. Suitable borrow pits have been identified on Portion 2 and the Remainder of Farm 182 and the Remainder of Farm 186 in the Matatiele Local Municipality.

The proposed borrow pits consist of the following components:

• Construction of a perimeter fence • Crushing and screening area • Mining area • Stockpile areas.

13.2 Assumptions, uncertainties and gaps

The following assumptions have been made during the EIA process:

EOH Coastal & Environmental Services 64 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

 The information provided by SANRAL and their respective consultants (GIBB) is assumed to be correct.  The layout provided by GIBB is preliminary, and might undergo changes in response to the recommendations contained in this report.

13.3 Opinion of the EAP

Although a number of significant impacts are associated with the proposed borrow pits and associated infrastructure, it is the professional opinion of EOH and the specialists that:

 The vast majority of environmental impacts identified can be adequately mitigated to reduce the impacts to an acceptable level, provided mitigation measures recommended in this report are implemented and maintained throughout the life of the project.  The implementation of mitigation measures and recommendations must be consistently monitored by a fulltime onsite Environmental Manager (EM) during construction/operation.  Annual environmental audits must be conducted by an independent Environmental Officer (EO). These audits must be submitted to DMR for review.  The recommendations made by all specialists and the EAP in the EMPr (Appendix D) must be implemented.  The information in the report is sufficient to allow DMR to make an informed decision.

It is the opinion of EOH that NO FATAL FLAWS are associated with the proposed mining sites.

13.4 Recommendations of the EAP

It is the opinion of EOH that the proposed mining sites should be approved provided that appropriate mitigation measures are implemented and that the EMPr is implemented, maintained and adapted to incorporate relevant legislation, standard requirements and audit reporting, throughout the life of the quarry.

The mitigation measures for all impacts identified in the EIA are provided in the detailed impact assessment in Appendix B and have been incorporated into the EMPr (Appendix D).

The EMPr must be implemented by the relevant parties during all phases of development of the project i.e. Planning & Design, Construction, Operational (or Mining) and Closure/Decommissioning phase.

Inclusions, additions and adaptations of the EMPr, as well as all final plan drawings and maps must be submitted to DMR (Port Elizabeth) for final approval.

EOH Coastal & Environmental Services 65 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 13.4.1 Recommended mitigation measures Theme Mitigation measure Planning and Design Phase GENERAL Compliance with relevant • The proposed borrow pit sites must also be in accordance environmental legislation with the Matatiele Local Municipality and Alfred Nzo and policy District Municipality policies and guidelines. • All legal matters pertaining to permitting must be completed prior to any construction activity. In particular, all necessary Water Use Licenses must be in order for any construction activities within 50m of a watercourse and within 500m of a wetland. Eastern Cape Biodiversity • The planning and design of the proposed borrow pits must Conservation Plan (ECBCP) adhere to the recommendations of the ECBCP, where possible. National Environmental • The expansion of Borrow Pit D660/1 must avoid areas Management: Biodiversity where plant and animal SCC have been identified. Act: Threatened or Permits must be obtained from the relevant departments Protected Species in order to remove plant and animal SCC from the development area prior to construction. • Prior to expansion of Borrow Pit D660/1, a suitability qualified ecologist or botanist must undergo a site visit to identify plant species that may require rescue and relocation. Job Creation • Local individuals, from near Cedarville and Matatiele, should be contracted for unskilled and semi-skilled employment opportunities, where possible. Construction Phase GENERAL Air pollution (dust) • Cleared surfaces must be dampened whenever possible, especially during dry and windy conditions, to avoid excessive dust generation.

Noise pollution • Construction activity, which includes the movement of construction vehicles, should be restricted to normal working hours (7:00am – 17:00pm).

Rehabilitation, Alien • A Rehabilitation, Alien Vegetation and Erosion Vegetation and Erosion Management Plan must be compiled and implemented Management during the construction phase.

Water Bodies • Construction activities which occur within 50m from rivers and drainage lines as well as within 500m from wetlands must not commence prior to authorization from the Department of Water and Sanitation.

Site contamination due to • Hazardous Chemical Substances Regulations hazardous substances promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to. This applies to solvents and other chemicals possibly used during the construction process. • Oil trays must be placed under machinery to avoid soil contamination. • The ECO and/or Contractor must determine the precise method of treatment of polluted soil. This could involve the application of soil absorbent materials, oil-digestive powders to the contaminated soil or the excavation of the

EOH Coastal & Environmental Services 66 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Theme Mitigation measure contaminated soil depending on the nature of the spill.

Health and safety risk • The ECO and/or Contractor must ensure that operational associated with fires firefighting equipment is present on site at all times as per the Occupational Health and Safety Act. • All flammable substances must be stored in dry areas which do not pose an ignition risk to the said substances. • No open fires must be allowed on site unless in a demarcated area identified by the ECO. • No smoking must be permitted near flammable substances. Water and Sanitation • Adequate sanitary and ablution facilities must be provided for construction workers during the construction phase. • The facilities must be serviced regularly to reduce the risk of surface or groundwater pollution. • Contaminated wastewater must be managed by the Contractor to ensure the existing water resources on and/or near the site are not contaminated. All wastewater from general activities in the camp must be collected and removed from the site for appropriate disposal at a licensed facility. Litter management • The ECO must monitor the sanitation of the work sites for litter and waste. • All waste must be removed from the site and transported to the closest licensed landfill site. Species of Conservation • Animals must not be harmed, handled, or interfered with Concern by construction staff during the construction phase. • Natural vegetation must not be harvested by construction staff. Job Creation • Local individuals, from near Matatiele and Cedarville, should be contracted for unskilled and semi-skilled employment, where possible, during the construction phase. Palaeontological Findings • The ECO and the Contractor must be notified of any palaeontological findings that are excavated during the construction phase and a suitable palaeontological specialist must be contacted. Palaeontological findings must not be impacted on. Loss of indigenous • Vegetation clearing during the construction phase must be vegetation restricted to the demarcated borrow areas. Operation Phase GENERAL Rehabilitation, Alien • The Rehabilitation, Alien Vegetation and Erosion Vegetation and Erosion Management Plan must be implemented during the Management operational phase. Job Creation • Local individuals, from near Matatiele and Cedarville, should be contracted for unskilled and semi-skilled employment, where possible, during the operational phase. Visual • All mining activities should take place within the demarcated areas to ensure that the visual impacts of the proposed borrow pits remain of low significance. Water Bodies • Mining activities which occur within 50m from rivers and drainage lines as well as within 500m from wetlands must not commence prior to authorization from the Department

EOH Coastal & Environmental Services 67 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Theme Mitigation measure of Water and Sanitation. Palaeontological Findings • The ECO and the Contractor must be notified of any palaeontological findings that are excavated during the operational phase and a suitable palaeontological specialist must be contacted. Palaeontological findings must not be impacted on. Air pollution (dust) • Cleared surfaces must be dampened whenever possible, especially during dry and windy conditions, to avoid excessive dust generation. Noise pollution • Mining activities, which include the movement of vehicles, should be restricted to normal working hours (7:00am – 17:00pm). Decommissioning/Closure Phase GENERAL Final rehabilitation and • All infrastructure, equipment, machinery and other items decommissioning used during the mining period must be removed from the site. • Rehabilitation must be completed in such a manner that the land can be optimally used post-mining. • The site must be covered with locally occurring grass and shaped/ levelled correctly. • Mining areas must be inspected weekly for soil stability until rehabilitation is complete. • Alien invasive plant species must be eradicated until rehabilitation is complete. • The closed quarry must pose no safety risks. • Rehabilitation must be completed in such a manner that the land can be optimally used post-mining. • Final rehabilitation must be completed within a period specified by the Regional Manager (DMR). Closure • Closure must comply with the MPRDA (Act 28 of 2002), NEMA (Act 107 of 1998) and the NEMA Regulations (2014) requirements for mine closure. • A closure plan must be compiled using the guidelines described in Appendix 5 of the NEMA Regulations (2014) and submitted to DMR. • A closure certificate must be obtained from the Minister of Mineral Resources.

EOH Coastal & Environmental Services 68 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 13.5 Declaration by the EAP

I, ______declare that:

 I act as the independent environmental practitioner in this application;  I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;  I declare that there are no circumstances that may compromise my objectivity in performing such work;  I have expertise in conducting environmental impact assessments, including knowledge of the Act, regulations and any guidelines that have relevance to the proposed activity;  I will comply with the Act, Regulations and all other applicable legislation;  I have no, and will not engage in, conflicting interests in the undertaking of the activity;  I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority;  All the particulars furnished by me in this report are true and correct; and  I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act.

Signature of the specialist:

Name of company (if applicable):

Date:

EOH Coastal & Environmental Services 69 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 14. ADDITIONAL INFORMATION

In terms of APPENDIX 3(3) of the EIA Regulations (2017), an Environmental Impact Assessment Report must include –

(t) Where applicable, details of any financial provision for the rehabilitation, closure and ongoing post decommissioning management of negative environmental impacts; (u) An indication of any deviation from the approved scoping report, including the plan of study, including-  Any deviation from the methodology used in determining the significance of potential environmental impacts and risks;  And a motivation for the deviation. (v) Any specific information that may be required by the competent authority; (w) Any other matters required in terms of section 24(4) (a) and (b) of the Act.

14.1 Financial provisions for rehabilitation

SANRAL are required to submit an undertaking and commitment to rehabilitation. This includes a quantum calculation for financial provision for rehabilitation (based on the DMR “Guideline Document for the Evaluation of the Quantum of Closure-Related Financial Provision provided by a mine”, 2005). This financial provision will be submitted with the final EIR to DMR.

EOH Coastal & Environmental Services 70 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 15. REFERENCES

AGIS online (www.agis.agric.za/agisweb/agis.html).

Conservation and Agricultural Resources Act (No. 43 of 1983).

Constitution Act (No. 108 of 1996).

Eastern Cape Vision 2030 Provincial Development Plan.

Hazardous Substances Act (No. 15 of 1973).

Integrated Development Plan (2013/2014). KSD Local Municipality.

Mineral and Petroleum Resources Development Act (No. 28 of 2002).

Mucina, L. & Rutherford, M.C. (eds). 2006. The vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria.

NPC National Development Plan 2030.

National Environmental Management Act (No. 107 of 1998).

National Environmental Management: Air Quality Act (No. 39 of 2004).

National Environmental Management: Biodiversity Act (No. 10 of 2004).

National Environmental Management: Protected Areas Act (No. 57 of 2003).

National Environmental Management: Waste Management Act (No. 59 of 2008).

National Forests Act (No. 84 of 1998).

National Heritage Resource Act (No. 25 of 1999).

National Water Act (No. 36 of 1998).

Occupational Health and Safety Act (No. 85 of 1993).

StatsSA (http://www.statssa.gov.za/).

EOH Coastal & Environmental Services 71 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 16. APPENDICES

16.1 Appendix A: Public participation documents

Newspaper advert:

To be included

EOH Coastal & Environmental Services 72 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Background Information Document:

EOH Coastal & Environmental Services 73 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

EOH Coastal & Environmental Services 74 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

EOH Coastal & Environmental Services 75 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

EOH Coastal & Environmental Services 76 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

EOH Coastal & Environmental Services 77 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

EOH Coastal & Environmental Services Gibb Engineering78 R56 Mining Application Environmental Impact Assessment Report – July 2017

EOH Coastal & Environmental Services 79 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 Notice board

Site Notice Location: 30°23'51.80" S; 29°07'45.40" E

EOH Coastal & Environmental Services Gibb Engineering80 R56 Mining Application Environmental Impact Assessment Report – July 2017 Letter of notification

EOH Coastal & Environmental Services 81 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

Attendance registers for meetings held

To be included.

Notification of the availability of the draft Scoping Report for public review:

Email notification:

To be included

Delivery of Draft Scoping Reports to DMR (Port Elizabeth):

To be included

Delivery of draft Scoping Report to DEDEAT (Mthatha):

To be included

Delivery of draft Scoping Report at the KSD Municipal Offices:

To be included

Delivery of draft Scoping Report to DWS (East London):

To be included

SMS notification of the availability of the draft Scoping Report for public review was sent to the following contacts:

To be included

Interested and affected parties database

To be included

EOH Coastal & Environmental Services 82 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 16.2 Appendix B

16.2.1 Impact assessment

Impacts associated with the planning and design phase of the proposed borrow pit sites. PLANNING & DESIGN PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi Likelih Severit Significan Significan Impact Description of Temporal Spatial Mitigation t ood y ce ce Impact

The proposed borrow pit sites must also be in accordance with the During the planning and design Matatiele Local phase non-compliance with the Municipality and Alfred legislation and policies of South Nzo District Municipality

Africa, as they pertain to the severe Moderately policies and guidelines.

environment, could lead to Term Medium

Study Area Study Legislation damage to the environment, Probable MODERAT All legal matters Direct LOW and Policy unnecessary delays in E pertaining to permitting NEGATIVE Compliance construction activities, and NEGATIVE must be completed prior

to any construction potentially criminal cases, based on the severity of the non- activity. In particular, all

compliance, being brought necessary Water Use against the proponent and the Licenses must be in order contractors. for any construction activities within 50m of a watercourse and within 500m of a wetland.

EOH Coastal & Environmental Services Gibb Engineering83 R56 Mining Application Environmental Impact Assessment Report – July 2017

PLANNING & DESIGN PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi Likelih Severit Significan Significan Impact Description of Temporal Spatial Mitigation t ood y ce ce Impact

The Terrestrial and Aquatic Critical Biodiversity Areas (CBAs), Eastern which occur within the proposed The planning and design Cape Permanent

Regional

Possible

site, could be adversely affected if Severe of the proposed borrow MODERAT Biodiversity Direct HIGH the planning and design of the pits must adhere to the E Conservation NEGATIVE NEGATIVE

proposed borrow pits is not recommendations of the

Plan

consistent with the ECBCP ECBCP, where possible. (ECBCP) recommendations for Critical Biodiversity Areas (CBAs).

EOH Coastal & Environmental Services Gibb Engineering84 R56 Mining Application Environmental Impact Assessment Report – July 2017

PLANNING & DESIGN PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi Likelih Severit Significan Significan Impact Description of Temporal Spatial Mitigation t ood y ce ce Impact

The expansion of Borrow Pit D660/1 must avoid areas where plant and animal SCC have been identified. Permits must be obtained from the National Environment relevant departments in order to remove plant and al The inappropriate expansion of

Permanent

Possible

National animal SCC from the Management Borrow Pit D660/1 could lead to Severe Direct HIGH development area prior to LOW : Biodiversity the loss of identified and NEGATIVE construction. NEGATIVE

Act: unidentified plant and animal

Threatened SCC. Prior to expansion of or Protected Borrow Pit D660/1, a Species suitability qualified ecologist or botanist must undergo a site visit to identify plant species that may require rescue and relocation.

Moderately Beneficial Moderately Local individuals, from near Cedarville and The proposed borrow pits and the

Short Term

Probable Matatiele, should be

Regional

related mining activities will create Indire Direct SOME contracted for unskilled BENEFICI Job Creation temporary employment BENEFITS and semi-skilled AL

ct

opportunities during the various

employment

phases of development. opportunities, where possible.

EOH Coastal & Environmental Services Gibb Engineering85 R56 Mining Application Environmental Impact Assessment Report – July 2017

Impacts associated with the construction phase of the proposed borrow pit sites. CONSTRUCTION PHASE WITHOUT MITIGATION WITH MITIGATION

Nature of Spatia Likelihoo Severit Significan Significan Issue/Benefit Impact Description Temporal Mitigation Impac l d y ce ce t

Air pollution, in the form of dust, caused by construction severe Moderately Cleared surfaces must be

Short Term

Study Ar Study

activities, such as grading and Probable dampened whenever MODERAT Air pollution leveling exposed land, can Direct possible, especially during LOW E (dust) cause a nuisance to traffic on dry and windy conditions, NEGATIVE NEGATIVE

the farm roads and to the farm ea to avoid excessive dust

owners and neighbouring generation.

farmers.

Construction activity, Noise pollution caused by which includes the

Short Term

Localised construction activities could Probable movement of construction

Direct Slight LOW LOW Noise pollution potentially be a nuisance to vehicles, should be NEGATIVE NEGATIVE

farm owners and neighbouring restricted to normal

farmers. working hours (7:00am – 17:00pm).

The lack of an effective A Rehabilitation, Alien

Study Area Study Moderately

Long Term Long

Rehabilitation, Rehabilitation, Alien Probable Vegetation and Erosion

Indirect Severe MODERAT Alien Vegetation Vegetation and Erosion Direct HIGH Management Plan must E and Erosion Management Plan could lead NEGATIVE be compiled and NEGATIVE

Management to erosion and large scale implemented during the

alien plant invasion. construction phase.

EOH Coastal & Environmental Services Gibb Engineering86 R56 Mining Application Environmental Impact Assessment Report – July 2017

CONSTRUCTION PHASE WITHOUT MITIGATION WITH MITIGATION

Nature of Spatia Likelihoo Severit Significan Significan Issue/Benefit Impact Description Temporal Mitigation Impac l d y ce ce t

The construction of the borrow To ensure that the visual pit areas will have a limited impacts of the proposed

Short Term

Study Area Study

visual impact and the borrow Definite borrow pits remain of low

Direct Slight LOW LOW Visual pit areas should only be visible significance, an adequate NEGATIVE NEGATIVE

to immediate landowners and layout, design and

road users on the D660 and operational plans must be D639. adhered to.

Construction activities which occur within 50m The construction of the borrow from rivers and drainage

Short Term

Municipal

Possible

Indirect pits could adversely affect Severe lines as well as within MODERAT Direct HIGH Water Bodies rivers, wetlands and drainage 500m from wetlands must E NEGATIVE NEGATIVE

systems in proximity to the not commence prior to

borrow areas. authorization from the Department of Water and Sanitation.

EOH Coastal & Environmental Services Gibb Engineering87 R56 Mining Application Environmental Impact Assessment Report – July 2017

CONSTRUCTION PHASE WITHOUT MITIGATION WITH MITIGATION

Nature of Spatia Likelihoo Severit Significan Significan Issue/Benefit Impact Description Temporal Mitigation Impac l d y ce ce t

Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to. This applies to solvents and other chemicals possibly used during the construction process.

Moderately Moderately

Site Term Medium

Localised Oil trays must be placed contamination Poorly maintained machinery Possible MODERAT Direct under machinery to avoid LOW due to could lead to soil pollution E soil contamination. NEGATIVE

Severe NEGATIVE

hazardous during the construction phase.

substances The ECO and/or

Contractor must determine the precise method of treatment of polluted soil. This could involve the application of soil absorbent materials, oil-digestive powders to the contaminated soil or the excavation of the contaminated soil depending on the nature of the spill. EOH Coastal & Environmental Services Gibb Engineering88 R56 Mining Application Environmental Impact Assessment Report – July 2017

CONSTRUCTION PHASE WITHOUT MITIGATION WITH MITIGATION

Nature of Spatia Likelihoo Severit Significan Significan Issue/Benefit Impact Description Temporal Mitigation Impac l d y ce ce t

The ECO and/or Contractor must ensure that operational firefighting equipment is present on site at all times as per the Occupational Health and Safety Act. Inadequate attention to fire All flammable substances safety awareness and fire Medium Health and Area Study

Possible must be stored in dry

Indirect safety equipment during the Severe MODERAT safety risk Direct HIGH construction phase could result areas which do not pose E

associated with NEGATIVE Term an ignition risk to the said NEGATIVE

in runaway fires, an unsafe

fires substances.

working environment and the loss of property. No open fires must be allowed on site unless in a demarcated area identified by the ECO.

No smoking must be permitted near flammable substances.

EOH Coastal & Environmental Services Gibb Engineering89 R56 Mining Application Environmental Impact Assessment Report – July 2017

CONSTRUCTION PHASE WITHOUT MITIGATION WITH MITIGATION

Nature of Spatia Likelihoo Severit Significan Significan Issue/Benefit Impact Description Temporal Mitigation Impac l d y ce ce t

Adequate sanitary and ablution facilities must be provided for construction workers during the construction phase.

The facilities must be Failure to provide adequate serviced regularly to

onsite sanitation and clean Severe Moderately reduce the risk of surface drinking water during the or groundwater pollution.

Short Term

Localised construction phase may result Possible MODERAT Water and Direct LOW in runoff transferring E Contaminated wastewater Sanitation NEGATIVE contaminants into the NEGATIVE must be managed by the

Contractor to ensure the

surrounding environment and/or pose a risk to the health existing water resources

of the construction workers. on and/or near the site are not contaminated. All wastewater from general activities in the camp must be collected and removed from the site for appropriate disposal at a licensed facility.

EOH Coastal & Environmental Services Gibb Engineering90 R56 Mining Application Environmental Impact Assessment Report – July 2017

CONSTRUCTION PHASE WITHOUT MITIGATION WITH MITIGATION

Nature of Spatia Likelihoo Severit Significan Significan Issue/Benefit Impact Description Temporal Mitigation Impac l d y ce ce t

The ECO must monitor the sanitation of the work Litter onsite may attract

Short Term

Localised

Possible sites for litter and waste. vermin, detract from the

Direct Litter Slight LOW LOW appearance of the area, and management NEGATIVE All waste must be NEGATIVE

pollute the surrounding areas removed from the site and

during the construction phase. transported to the closest licensed landfill site.

Animals must not be harmed, handled, or The uncontrolled clearing of interfered with by vegetation during the Permanent

Possible

National

Species of Severe MODERAT Direct construction staff during construction phase could lead HIGH Conservation E to the loss of identified and NEGATIVE the construction phase. Concern NEGATIVE

unidentified plant and animal

Natural vegetation must SCC. not be harvested by construction staff.

Moderately Beneficial Moderately Local individuals, from near Matatiele and

Short Term

Municipal Cedarville, should be

Definite Temporary employment Indirect Direct SOME contracted for unskilled BENEFICI Job Creation opportunities will be created BENEFITS and semi-skilled AL

during the construction phase.

employment, where

possible, during the construction phase.

EOH Coastal & Environmental Services Gibb Engineering91 R56 Mining Application Environmental Impact Assessment Report – July 2017

CONSTRUCTION PHASE WITHOUT MITIGATION WITH MITIGATION

Nature of Spatia Likelihoo Severit Significan Significan Issue/Benefit Impact Description Temporal Mitigation Impac l d y ce ce t

The ECO and the Contractor must be notified of any Sensitive palaeontological palaeontological findings

Permanent

Localised

Possible

findings could be damaged or Severe that are excavated during MODERAT Palaeontological Direct HIGH destroyed by construction the construction phase E Findings NEGATIVE NEGATIVE

activities during the and a suitable

construction phase. palaeontological specialist must be contacted. Palaeontological findings must not be impacted on.

Moderatel

Localised

Probable

y Severe y

The clearing of vegetation for Medium

Direct

Term Vegetation clearing during Loss of the borrow areas during the MODERAT the construction phase LOW indigenous construction phase will result E must be restricted to the NEGATIVE

vegetation in the loss of indigenous NEGATIVE

demarcated borrow areas. vegetation.

Impacts associated with the operational (mining) phase of the proposed borrow pit sites. OPERATIONAL PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi of Spatia Likelihoo Severit Significan Significan Impact Description Temporal Mitigation t Impac l d y ce ce t

EOH Coastal & Environmental Services Gibb Engineering92 R56 Mining Application Environmental Impact Assessment Report – July 2017

OPERATIONAL PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi of Spatia Likelihoo Severit Significan Significan Impact Description Temporal Mitigation t Impac l d y ce ce t

The lack of an effective Rehabilitatio Rehabilitation, Alien Vegetation The Rehabilitation, Alien

Study Area Study

Long Term Long

Probable

Indirect n, Alien and Erosion Management Plan, Severe Vegetation and Erosion MODERAT Direct HIGH Vegetation post-construction, could lead to Management Plan must E NEGATIVE and Erosion erosion and large scale alien plant be implemented during NEGATIVE

Management invasion during the operational the operational phase. phase.

Moderately Beneficial Moderately Local individuals, from near Matatiele and

Short Term

Temporary employment Municipal Cedarville, should be

Definite

Indirect opportunities will be created Direct SOME contracted for unskilled BENEFICI Job Creation during the operation of the borrow BENEFITS and semi-skilled AL

pits. employment, where

possible, during the operational phase.

All mining activities should The operation of the borrow pit take place within the

Short Term areas will have a limited visual Area Study Definite demarcated areas to

Direct impact and the borrow pit areas Slight LOW LOW Visual ensure that the visual should only be visible to NEGATIVE NEGATIVE

impacts of the proposed

immediate landowners and road

borrow pits remain of low users on the D660 and D639. significance.

EOH Coastal & Environmental Services Gibb Engineering93 R56 Mining Application Environmental Impact Assessment Report – July 2017

OPERATIONAL PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi of Spatia Likelihoo Severit Significan Significan Impact Description Temporal Mitigation t Impac l d y ce ce t

Mining activities which occur within 50m from rivers and drainage lines

Short Term

The mining activities in the borrow Municipal

Possible

Indirect Severe as well as within 500m MODERAT Water pits could adversely affect rivers, Direct HIGH from wetlands must not E Bodies wetlands and drainage systems in NEGATIVE NEGATIVE

commence prior to

proximity to these borrow areas.

authorization from the Department of Water and Sanitation.

The ECO and the Contractor must be notified of any palaeontological findings

Permanent

Sensitive palaeontological Localised

Possible

Severe that are excavated during MODERAT Palaeontolog findings could be damaged or Direct HIGH the operational phase and E ical Findings destroyed by mining activities NEGATIVE NEGATIVE

a suitable

during the operational phase.

palaeontological specialist must be contacted. Palaeontological findings must not be impacted on.

Cleared surfaces must be Air pollution, in the form of dust,

Short Term

Study Area Study Moderately

Probable dampened whenever

caused by mining activities can severe MODERAT Air pollution Direct possible, especially during LOW cause a nuisance to traffic on the E (dust) dry and windy conditions, NEGATIVE farm roads and to the farm NEGATIVE

to avoid excessive dust

owners and neighbouring farmers. generation.

EOH Coastal & Environmental Services Gibb Engineering94 R56 Mining Application Environmental Impact Assessment Report – July 2017

OPERATIONAL PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi of Spatia Likelihoo Severit Significan Significan Impact Description Temporal Mitigation t Impac l d y ce ce t

Mining activities, which

Short Term

Localised

Noise pollution caused by mining Probable include the movement of

Direct Noise activities could potentially be a Slight LOW vehicles, should be LOW pollution nuisance to the farm owners and NEGATIVE restricted to normal NEGATIVE

neighbouring farmers. working hours (7:00am –

17:00pm).

DECOMMISSIONING PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi of Spatia Likelihoo Severit Significan Significan Impact Description Temporal Mitigation t Impac l d y ce ce t

EOH Coastal & Environmental Services Gibb Engineering95 R56 Mining Application Environmental Impact Assessment Report – July 2017

DECOMMISSIONING PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi of Spatia Likelihoo Severit Significan Significan Impact Description Temporal Mitigation t Impac l d y ce ce t

All infrastructure, equipment, machinery and other items used during the mining period must be removed from the site.

Rehabilitation must be completed in such a manner that the land can be optimally used post- mining. Failure to decommission and

Long

Localised Localised

Final Possible

S

rehabilitate the mining site Direct Mining areas must be rehabilitation evere MODERAT HIGH

properly could result in soil inspected weekly for soil and term E erosion, storm water issues, NEGATIVE stability until rehabilitation

decommissio NEGATIVE

safety risks and invasion of alien is complete. ning plant species. Final rehabilitation must be completed within a period specified by the Regional Manager (DMR).

EOH Coastal & Environmental Services Gibb Engineering96 R56 Mining Application Environmental Impact Assessment Report – July 2017

DECOMMISSIONING PHASE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi of Spatia Likelihoo Severit Significan Significan Impact Description Temporal Mitigation t Impac l d y ce ce t

Closure must comply with the MPRDA (Act 28 of 2002), NEMA (Act 107 of 1998) and the NEMA Regulations (2014) requirements for mine closure.

Long

Localise

Failure to comply with the closure Possible

S

Direct

requirements could result in evere A closure plan must be MODERAT

- HIGH

Closure unnecessary environmental term compiled using the E NEGATIVE

d degradation and failure to obtain a guidelines described in NEGATIVE

closure certificate from DMR. Appendix 5 of the NEMA Regulations (2014) and submitted to DMR.

A closure certificate must be obtained from the Minister of Mineral Resources.

No-go impacts associated with the proposed borrow pit sites. NO-GO ALTERNATIVE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi of Spatia Likelihoo Severit Significan Significan Impact Description Temporal Mitigation t Impac l d y ce ce t

EOH Coastal & Environmental Services Gibb Engineering97 R56 Mining Application Environmental Impact Assessment Report – July 2017

NO-GO ALTERNATIVE WITHOUT MITIGATION WITH MITIGATION

Nature Issue/Benefi of Spatia Likelihoo Severit Significan Significan Impact Description Temporal Mitigation t Impac l d y ce ce t

Moderately severe Moderately

Short term Short

Municipal

Definite

Loss of Direct The no-go option would not create MODERAT MODERAT employment any new employment E No mitigation proposed. E opportunities

opportunities. NEGATIVE NEGATIVE

Loss of

Short Term

Moderately Moderately material The no-go option entails no Municipal

Definite

severe sources for material sources for the National Direct MODERAT MODERAT the National Route R56 Section 8 road E No mitigation proposed. E

NEGATIVE NEGATIVE

Route 56 upgrade and material would have

Section 8 to be sourced elsewhere. road upgrade

EOH Coastal & Environmental Services Gibb Engineering98 R56 Mining Application Environmental Impact Assessment Report – July 2017 16.3 APPENDIX C: Specialist Volume

Aquatic and Wetland Impact Assessment

EOH Coastal & Environmental Services 99 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

Ecological Impact Assessment

EOH Coastal & Environmental Services 100 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017

Heritage Impact Assessment

EOH Coastal & Environmental Services 101 Gibb Engineering R56 Mining Application Environmental Impact Assessment Report – July 2017 16.4 Appendix D: Environmental Management Programme

EOH Coastal & Environmental Services 102 Gibb Engineering R56 Mining Application