FINAL Environmental Impact Report and Environmental Management Programme for Coega Mining, NMBM

Report prepared for

722 Sardinia Bay Road P.O. Box 5780 Sardinia Bay Walmer Port Elizabeth Port Elizabeth South Africa South Africa Report prepared by 6070 6065 No.2 Deer Park Lane ; Deer Park Estate ; Port Elizabeth ; 6070 PO Box 16501 ; Emerald Hill ; 6011 Telephone : +27 (0) 41 379 1899 Mobile : +27(0) 82 653 2568 Facsimile : +27 (0) 86 657 7703 e-mail : [email protected]

Coega Mining (PTY) LTD

Contents Table of Figures ...... 5

List of Tables ...... 5

Acronyms and Abbreviations ...... 7

1. The objective of the scoping process is to, through a consultative process— ...... 10

2. Contact Person and correspondence address ...... 11

a) Details of ...... 11

Details of the EAP ...... 11

Expertise of the EAP...... 11

b) Description of the property ...... 11

c) Locality map ...... 12

d) Description of the scope of the proposed overall activity...... 14

Listed and specified activities ...... 14

Description of the activities to be undertaken ...... 14

e) Policy and Legislative Context ...... 17

f) Need and desirability of the proposed activities...... 19

g) Description of the process followed to reach the proposed preferred site...... 21

Details of the development footprint alternatives considered...... 21

Details of the Public Participation Process Followed ...... 24

Summary of issues raised by I&APs ...... 26

The Environmental attributes associated with the sites...... 38

ii. African Penguin ...... 49

iii. African Black Oystercatcher ...... 50

Impacts and risks identified ...... 63

Methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks; ...... 69

The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected...... 70

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viii) The possible mitigation measures that could be applied and the level of risk. ... 74

ix) Motivation where no alternative sites were considered...... 75

x) Statement motivating the preferred site...... 76

h) Full description of the process Impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts ...... 76

i) Assessment of each identified potentially significant impact and risk ...... 76

j) Summary of specialist reports...... 86

k) Environmental impact statement ...... 93

l) Proposed impact management objectives and the impact management outcomes for inclusion in the EMPr; ...... 95

m) Final proposed alternatives ...... 96

n) Aspects for inclusion as conditions of Authorisation...... 96

o) Description of any assumptions, uncertainties and gaps in knowledge...... 96

p) Reasoned opinion as to whether the proposed activity should or should not be authorised ...... 97

q) Period for which the Environmental Authorisation is required...... 97

r) Undertaking ...... 97

s) Financial Provision ...... 97

t) Deviations from the approved scoping report and plan of study...... 98

Deviations from the methodology used in determining the significance of potential environmental impacts and risks...... 98

Motivation for the deviation...... 98

u) Other Information required by the competent Authority...... 98

v) Other matters required in terms of sections 24(4)(a) and (b) of the Act...... 99

PART B ...... 100

DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT ...... 100

1. Draft environmental management programme...... 100

a) Details of the EAP, ...... 100

b) Description of the Aspects of the Activity ...... 100

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c) Composite Map ...... 100

d) Description of Impact management objectives including management statements .... 100

Determination of closure objectives...... 100

The process of managing any environmental damage, pollution, pumping and treatment of extraneous water or ecological degradation as a result of undertaking a listed activity...... 101

Potential risk of Acid Mine Drainage ...... 101

Steps taken to investigate, assess and evaluate the impact of acid mine drainage...... 101

Engineering or mining design solutions to be implemented to avoid or remedy acid mine drainage...... 101

Measures that will be put into place to remedy any residual or cumulative impact that may result from acid mine drainage...... 101

Volumes and rate of water use required for the operation...... 101

Has a water use licence has been applied for? ...... 102

Impacts to be mitigated in their respective phases ...... 103

e) Impact Management Outcomes ...... 116

f) Impact Management Actions ...... 117

Financial Provision ...... 119

g) Monitoring of Impact Management Actions ...... 124

h) Monitoring and reporting frequency ...... 124

i) Responsible persons ...... 124

j) Time period for implementing impact management actions ...... 124

k) Mechanism for monitoring compliance ...... 124

l) Indicate the frequency of the submission of the performance assessment/ environmental audit report...... 126

m) Environmental Awareness Plan ...... 126

(1) Manner in which the applicant intends to inform his or her employee of any environmental risk which may result from their work...... 126

(2) Manner in which risks will be dealt with in order to avoid pollution or the degradation of the environment...... 127

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n) Specific information required by the Competent Authority ...... 127

2) UNDERTAKING ...... 127

References ...... 130

Appendix ...... 132

Appendix A CV of EAP ...... 133

Appendix B Site Layout Plan ...... 135

Appendix C ...... 136

Appendix C1 Newspaper advert ...... 137

Appendix C2 Site Notice ...... 139

Appendix C3 Background Information Document ...... 141

Appendix C4 Register of Interested and Affected Parties ...... 152

Appendix C5 Minutes of meeting ...... 167

Appendix C6 Correspondence with Interested and Affected Parties ...... 169

Appendix D ...... 204

Appendix D1 Biodiversity Assessment...... 205

Bird List for the area around the proposed Coega Mining Right ...... 210

APPENDIX D2 AVIFAUNAL SPECIALIST REPORT ...... 215

APPENDIX D3 BOTANICAL SPECIALIST REPORT ...... 216

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Table of Figures Figure 1 Locality Map for Coega Mining in the Coega SEZ, NMBM...... 13 Figure 2 Ownership structure of Coega Mining (Pty) Ltd...... 15 Figure 3 Wind rose (m/s) for the Coega IDZ, according to the Air Quality Specialist Assessment, LAQS, 2016...... 39 Figure 4 Topography of the Coega Mining mining right area site...... 40 Figure 5 Extract of the 1:250 000 geological map (3324 Port Elizabeth) showing dominant geological formations of the mining right area...... 41 Figure 6 Coega Mining is not near any identifiable conservation features, including rivers, wetlands and Threatened Ecosystems...... 42 Figure 7 Dominant vegetation types of the mining site, according to Mucina & Rutherford (2012)...... 43 Figure 8 Dominant vegetation types at the proposed mining site, according to Stewart (2010)...... 44 Figure 9 Vegetation types of Coega Mining Mining Right Area...... 46 Figure 10 Global Important Bird Areas, in relation to the Coega Mining mining right area. .. 53 Figure 11 Proposed mining site in relation to Terrestrial Critical Biodiversity Areas identified by ECBCP (2007)...... 57 Figure 12 Proposed mining site in relation to Aquatic Critical Biodiversity Areas identified by ECBCP (2007)...... 58 Figure 13 Coega OSMP, including the proposed Aquaculture Development Zone...... 59 Figure 14 Neighbouring mining operations and other activities...... 60 Figure 15 Environmental and Current Land Use Map of the proposed mining right area of Coega Mining...... 62 Figure 16 Final Mine Schedule Plan for Coega Mining. Light blue line indicates the Damara Tern buffer area that is designated a No-Go Area...... 72 Figure 17 Overlapping area between the Coega ADZ and proposed Coega Mining Mining Right area. Red is Phase 1, Blue is Phase 2 of the ADZ. Light blue line indicates the Damara Tern buffer area that is designated a No-Go Area...... 73

List of Tables Table 1 Listed and Other Activities associated with the proposed Coega Mining ...... 14 Table 2 Policy and Legislative Context of Coega Mining ...... 17 Table 3 List of Comments/Objections raised by Interested & Affected Parties ...... 27

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Table 4 Monthly precipitation data at the Coega Weather Station, according to the South African Weather Service...... 38 Table 5 Temperature data for the nearby Coega Weather Station, according to the South African Weather Services...... 38 Table 6 List of Threatened Birds found within 2 km of the Coega Mining mining right area in the Coega IDZ, including endemic species...... 50 Table 7 List of possible reptile species present on the proposed mining site...... 53 Table 8 List of possible Threatened species present on the proposed mining site. 54 Table 9 Potential Impacts relating to the proposed mining right application...... 65 Table 10 Methodology for rating significance of proposed activities...... 69 Table 11 Impacts of proposed sand mine...... 77 Table 12 Environmental Management Impacts due to Coega Mining...... 103 Table 13 Financial provision for rehabilitation at Coega Mining...... 123 Table 14 Environmental Monitoring Programme for Coega Mining...... 125 Table 15 List of possible mammal species present on the proposed mining site...... 205 Table 16 List of possible frog species present on the proposed mining site...... 207 Table 17 List of possible butterfly species present on the proposed mining site...... 207

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Acronyms and Abbreviations ACME Algoa Consulting Mining Engineers ADZ Aquatic Development Zone AIPs Alien Invasive Plants BAR Basic Assessment Report BID Background Information Document BP Bioregional Plan DAFF Department of Agriculture, Forestry and Fisheries DMR Department of Mineral Resources DRDAR Department of Rural Development and Agrarian Reform DWS Department of Water Affairs and Sanitation EA Environmental Authorisation EAP Environmental Assessment Practitioner ECDRPW Eastern Cape Department of Roads and Public Works ECECB Eastern Cape Environmental Conservation Bill ECPHRA Eastern Cape Provincial Heritage Resources Agency ECPTA Eastern Cape Parks and Tourism Agency EIA Environmental Impact Assessment EIR Environmental Impact Report I&APs Interested and Affected Parties IDP Integrated Development Plan IDZ Industrial Development Zone MPRDA Mineral and Petroleum Resources Development Act 28 of 2002 NAAQS National Ambient Air Quality Standards (Government Gazette No. 32816) NMBM Nelson Mandela Bay Municipality NEMA National Environmental Management Act 107 of 1998 as amended NEMA: AQA National Environmental Management: Air Quality Act 39 of 2004 NEM:BA National Environmental Management: Biodiversity Act 10 of 2004 NEM: ICMA National Environmental Management: Integrated Coastal Management Act 24 of 2008 NHRA National Heritage Resources Act 29 of 1999 OEM Original Equipment Manufacturer S&EIAR Scoping and Environmental Impact Report SAHRA South African Heritage Resources Agency SCC Species of Conservation Concern SEZ Special Economic Zone

ALL CHANGES TO THE DRAFT EIAR AND EMPR ARE IN RED

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ENVIRONMENTAL IMPACT REPORT And ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

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

NAME OF APPLICANT: COEGA MINING (PTY) LTD

TEL NO.:(041) 366 1917

FAX NO.:(086) 615 7937

PHYSICAL ADDRESS: PO BOX 5780, Walmer, Port Elizabeth, South Africa, 6065

POSTAL ADDRESS:722 Sardinia Bay Rd, Sardinia Bay, Port Elizabeth, South Africa, 6070

FILE REFERENCE NUMBER SAMRAD: EC 30/5/1/2/2/10049MR

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

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

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

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

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

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OBJECTIVE OF THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

1. The objective of the scoping process is to, through a consultative process— (a) identify the relevant policies and legislation relevant to the activity; (b) motivate the need and desirability of the proposed activity, including the need and desirability of the activity in the context of the preferred location; (c) identify and confirm the preferred activity and technology alternative through an impact and risk assessment and ranking process; (d) identify and confirm the preferred site, through a detailed site selection process, which includes an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all the identified alternatives focusing on the geographical, physical, biological, social, economic, and cultural aspects of the environment; (e) identify the key issues to be addressed in the assessment phase; (f) agree on the level of assessment to be undertaken, including the methodology to be applied, the expertise required as well as the extent of further consultation to be undertaken to determine the impacts and risks the activity will impose on the preferred site through the life of the activity, including the nature, significance, consequence, extent, duration and probability of the impacts to inform the location of the development footprint within the preferred site; and (g) identify suitable measures to avoid, manage, or mitigate identified impacts and to determine the extent of the residual risks that need to be managed and monitored.

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2. Contact Person and correspondence address a) Details of

Details of the EAP

Name of the practitioner: Mr Clayton Weatherall-Thomas Tel no.: 041 379 1899 Fax no.: 086 657 7703 e-mail address: [email protected]

Expertise of the EAP. The qualifications of the EAP (with evidence).

Mr Clayton Weatherall-Thomas

EDUCATION  MSc (Botany) Nelson Mandela Metropolitan University – 2009  BSc Hons (Botany) Nelson Mandela Metropolitan University – 2006  BSc (Biological Sciences) Nelson Mandela Metropolitan University – 2005

Please see EAP CV attached to this report as Appendix A.

Summary of the EAP’s past experience. (In carrying out the Environmental Impact Assessment Procedure) Clayton Weatherall-Thomas has been practising as an EAP for the last two and a half years, specialising in the mining industry. He has done multiple EIAs for both sand and hard rock quarries in the Eastern Cape, and a wind tower factory in the Northern Cape. Clayton has done Environmental Control Officer (ECO) and Environmental Auditing in the mining industry as well. Before that, he gained experience working as an environmental officer at WESSA, and within the Environmental Management Department of the Nelson Mandela Bay Municipality (NMBM), as NMBMOSS co-ordinator. Clayton has been doing botanical specialist reports for 8 years as well.

b) Description of the property

Farm Name: Erf 220 and Erf 221 Coega Application area (ha) 41.6553 ha.

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Magisterial district: Port Elizabeth Distance and direction from Situated approximately 9 kms north-east of the suburb of nearest town Wells Estate, Port Elizabeth, Nelson Mandela Bay Municipality 21 digit Surveyor General C07600230000022100000 Code for each farm portion C07600230000022000000 c) Locality map

(show nearest town, scale not smaller than 1:250000). The locality map can be seen in Figure 1.

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Figure 1 Locality Map for Coega Mining in the Coega SEZ, NMBM..

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Coega Mining (PTY) LTD d) Description of the scope of the proposed overall activity.

Provide a plan drawn to a scale acceptable to the competent authority but not less than 1: 10 000 that shows the location, and area (hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site

Listed and specified activities Table 1 Listed and Other Activities associated with the proposed Coega Mining

NAME OF Aerial extent of the LISTED ACTIVITY APPLICABLE ACTIVITY Activity Mark with an X where LISTING NOTICE (All activities including Ha or m² applicable or affected. ( GNR 544 , GNR 545 or activities not listed) GNR 546 ) or NOT (E.g. Excavations, blasting, LISTED stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc…etc…etc.) Clearance of 41,7 ha X GNR 327 (27) vegetation GNR 324 (12) Mining & Excavations 41,7 ha X GNR 325 (17) GNR 327(19A) Load ; Haul & transport 1500 m² X GNR 327 (12) GNR 327 (17) GNR 327 (24) GNR 327 (56) GNR 324 (4) Mobile Screening Plant 100 m2

Ablution facilities 10 m2

Topsoil Stockpiles 100 m2

Rehabilitation & 41,7 ha X GNR 327 (18) Decommissioning GNR 327 (22)

Description of the activities to be undertaken Coega Mining (Pty) Ltd is a privately owned company whose shareholding consists of three entities (Figure 2). In compliance with the requirements of a mining right application, the ownership structure includes 44% ownership by HDSA, this includes Glendore Community Empowerment Trust that will support community projects, and Glendore Employment Empowerment Trust. All materials produced by Coega Mining will be marketed, sold and

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Coega Mining (PTY) LTD transported to clients by Glendore Sand & Stone, a long-established local construction materials company.

GLENDORE COMMUNITY C BARNARD FAMILIE LJ DU PLOOY FAMILY DEVELOPMENT (PTY) LTD BELEGGINGS (PTY) LTD INVESTMENTS (PTY) LTD 44% 28% 28%

SAYSTER HOLDINGS (PTY) LTD 63% GLENDORE EMPLOYMENT COEGA MINING (PTY) LTD EMPOWERMENT TRUST (APPLICANT) 18,5% GLENDORE COMMUNITY EMPOWERMENT TRUST 18,5%

Figure 2 Ownership structure of Coega Mining (Pty) Ltd.

Coega Mining has applied for a mining right application on Erf 220 and 221 Coega, in Zone 10 of the Coega Special Economic Zone (SEZ), situated in the Nelson Mandela Bay Municipality (NMBM), Eastern Cape. The proposed mining right area is found within 1 km of the coastline, within the littoral active zone, thereby triggering multiple listed activities, according to the EIA Regulations of 2014, as amended, of NEMA, Act 107 of 1998. The proposed activity entails the mining of sand, building sand, stone aggregate and gravel for the construction industry in the Nelson Mandela Bay Municipality (NMBM). The minerals are all found on the surface and only opencast, open pit mining methods will be deployed, i.e. all minerals will be free dug by means of excavators and front end loaders. The minerals will be placed onto dump trucks, and either transported to stockpiles, or directly to customers. It is proposed that the majority of the mining right application of 41,7 ha will be mined. The outer boundary of the mining right area will be demarcated with clearly visible markers, as fencing will not be feasible. Sign boards will be erected at the entrance of the mine, and will contain the information required by the EMPr, as well as any other legislative requirements. The site would be accessed via the existing road network within the Coega SEZ. The road network within the neighbouring Mandela Bay Sunshine Coast Quarry, operating as Sonop Quarry, will be extended in an easterly direction to access the proposed mining right area (see Site Layout Plan, Appendix 2). The entrance of the existing quarry will operate as the entrance to Coega Mining as well. This entrance to the site will consist of a mobile mine

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Coega Mining (PTY) LTD manager’s office, a gate for access control, a chemical ablution facility, all relevant signage and a water tank for the wetting of loads on the back of the vehicles, as well as wetting all roads, for dust suppression purposes. The mining methods do not utilise electricity, as all machinery and equipment are self-

Photo 1 An example of a sand mine, including the excavation, hauling and screening of the material using a mobile screening plant. propelled diesel driven vehicles. The site office is powered using solar photovoltaic panels and batteries, with a diesel generator as a backup. The use of alternative energy for the mobile screening plant is not considered an option. Water for drinking purposes will be supplied by an existing pipeline connected to a municipal supply source. Desalinised water for dust suppression will be supplied by Cerebos via an aboveground 40 mm HTPE irrigation pipe. Cerebos, a producer of table salt in the Coega SEZ, is situated in the nearby Coega Estuary and produces desalinised water as a by-product of salt production. The water is evaporated from brine in an evaporator, and collected for re-use, or disposed into the Sundays River Estuary. The municipal source will provide a backup if any issues arise with the water supply agreement with Cerebos.

Site Preparation Phase  Constructing a new vehicular access point to allow access for dump trucks  Demarcating the boundary of the site with clearly visible markers  Clearing vegetation and mulching it to be used for rehabilitation  Removing topsoil and storing it in stockpiles on site  Setting up the mobile diesel-driven screening plant

Excavation Phase

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 Minerals will be free dug by means of excavators and front end loaders  The excavator will transport the mineral to a mobile screening plant  A mobile screening plant will be used to remove organic material if necessary  A solution of water and other inert chemicals (mostly builder’s lime) will be added to the mineral during the screening process  Screened minerals will be placed onto dump trucks and transported off site, or directly collected by customers  Mineral loads carried by all vehicles will be weighed and wetted with water before leaving the site  Clearing of Alien Invasive Plants (AIPs) will occur on a regular basis  Rehabilitation will occur concurrently with mining

Post-closure Phase  Rehabilitation will occur concurrently with mining  All equipment and infrastructure will be removed  Rehabilitation will occur by replacing available topsoil with added mulch on the mined areas, and sowing a grass seed mix  Invasive Alien Plant clearing and monitoring of rehabilitation will continue for two years

e) Policy and Legislative Context

Table 2 Policy and Legislative Context of Coega Mining

APPLICABLE REFERENCE WHERE HOW DOES THIS LEGISLATION AND APPLIED DEVELOPMENT COMPLY GUIDELINES USED TO (i.e. Where in this document has it WITH AND RESPOND TO COMPILE THE REPORT been explained how the THE POLICY AND (A description of the policy and development complies with and LEGISLATIVE CONTEXT legislative context within which responds to the legislation and (E.g. In terms of the National the development is proposed policy context) Water Act:-Water Use License including an identification of all has/has not been applied for). legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable to this activity and are to be considered in the assessment process); A Mining Right Application, in Mineral and Petroleum All matters relating to any terms of Section 22 of the Act, Resources Development mining activities must be has been lodged with the

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Amendment Act, 49 of 2008 authorized in accordance with competent authority, the (MPRDA), including the the requirements of this Act. Department of Mineral Mineral and Petroleum Resources (DMR) Resources Development Regulations of 2004, as amended An application for National Environmental Environmental Authorisation All Listed Activities triggered by Management Act, 107 of 1998 (EA), as well as a Scoping & the mining right application is (NEMA), and Environmental Impact report listed in Table 1. The Scoping (S&EIR), and Environmental Environmental Impact Report document is based on Management Programme Assessment (EIA) Regulations the EIA Regulations of 2014, (EMPr), have been prepared in of 2014, as amended, and including public participation compliance with Regulation 19 Listing Notices 324, 325 and (Section B) h)) 327 and Appendix 1 and 4 the EIA Regulations of 2014. National Environmental Management: Air Quality Act, 39 of 2004 (NEM:AQA), including the List of activities which result in atmospheric emissions which have or may have a significant detrimental effect on the environment, including health, social conditions, economic Mitigation Measures includes Registration and reporting to conditions, ecological in the EMPr include registration NMBM (relevant air quality conditions or cultural heritage with NMBM as the relevant officer) and implementation of of 2013 (GNR 893) and authority for air quality dust fallout monitoring plan National Dust Control Regulations (GNR. 827) and National Atmospheric Emission Reporting Regulations of 2015 (GNR 283) and National Ambient Air Quality Standards (Government Gazette No. 32816) (NAAQS) National Environmental Management: Waste Act, 59 of 2008, including the National Waste Information Regulations of 2012 (GN No stockpiles will be kept for R625) and more than a day on site. Good A Waste Licence is NOT Housekeeping practices will be Regulations regarding the required for this sand mine. planning and management of instituted to ensure a clean residue stockpiles and residue environment. deposits from a prospecting, mining, exploration or production operation of 2015 (GNR 632) National Water Act, 36 of 1998 Complies with National Water The principles of water use, (NWA) and Act Protection of water resources, Regulations on use of water for see Table 6 The source of water for this mining and related activities development is not a

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aimed at the protection of recognised water resource as water resources of 1999 (GN defined by the NWA R1091) Safety and security for local Road Traffic Act, 93 of 1996 Design of access road inhabitants, see Table 5 HIA of the Coega ADZ has National Heritage Resources been integrated into this report, All specialist studies Act 25 of 1999 as well as all relevant recommendations The development is not taking National Environmental Identification of sensitive areas place within a protected area Management: Protected Areas and Baseline Environment or Protected Area expansion Act No 57 of 2003 strategy areas National Forests Act, Act No. 84 of 1998 and Application for permits to No Protected trees occur within Regulations on the National remove Protected Tree species the mining right area Forests Act, 1998 of 2009 (GN R466) National Environmental Management: Biodiversity Act No. 10 of 2004 and Threatened or protected species regulations of 2015 (GN R255) and List of Critically Endangered, All Threatened or Protected Endangered, Vulnerable and Species, Threatened Ecosystems and Alien Invasive Protected Species of 2007 and All necessary permits will be Species were identified and List of Ecosystems that are applied for integrated into the Baseline Threatened or in need of Environment and Mitigation Protection of 2011 and measures of Table 12 Alien and invasive species regulations of 2014 and Publishing of the final bioregional plan for the Nelson Mandela Bay Municipality of 2015 Nelson Mandela Bay Municipality Integrated Integration into the Baseline

Development Plan 2017-2022 Environment (NMBM IDP) Coega Open Space All identified CBAs were Relevant mitigation measures Management Plan (OSMP) of integrated into Baseline and 2014 Environment f) Need and desirability of the proposed activities.

The proposed Coega Mining sand mine is necessary for the economical and reliable supply of sand to the construction industry of the Nelson Mandela Bay Municipality (NMBM). Other sources in NMBM of sand, being the riverine sand mined from the Swartkops River, and coastal sand from the Driftsands area, are becoming increasingly exhausted and new

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Coega Mining (PTY) LTD sources have to be identified and developed in the short term. The quality of the mineral resource in the coastal areas in Zone 10 of the Coega SEZ is ideal for the construction of housing and pipelines. Sand and Aggregates for construction is a highly competitive industry with low profit margins. The distance to market and cost of transport determines the financial viability of an operation. Location of a mine is thus important for its sustainability. The contractor Glendore Sand & Stone operates at an existing mining operation in Zone 10 of the Coega SEZ. This mineral resource is expected to be depleted in the next two years at the present rate of production. The sand from this operation mostly goes to the construction of subsidised housing in the Motherwell area, construction works in the Coega IDZ, as well as the Bluewater Bay and Swartkops area. Previously, the existing mine has supplied sand for the laying of pipes and the construction of wind turbines. Alternative supply of sand, including operators in the Swartkops River and the Driftsands area, are a considerable distance away and will result in inflated cost of the mineral resource for the market. The formal sector would not be affected negatively by the proposed Coega Mining development, but to the contrary would benefit greatly due to the much needed direct- and indirect employment opportunities. Readymix concrete is a useful indicator of the growth of the building and construction sector. Coega Mining would mainly supply the market needs of building sand and general sand. Currently, 5 readymix concrete plants operate in the Nelson Mandela Bay Municipal area. All operations supply solely to NMBM. The annual collective consumption of readymix concrete for 2018 was 227 057 m3 in the NMBM area. The equivalent production of readymix produced over the past 5 years in NMBM was 1 401 853 m3. Concrete sand makes up on average 19% by volume of the readymix concrete. Hence, the readymix concrete consumed collectively about 43550 m3 sand for the past year. This equates to about 400 m3 of sand per work day. There are 7 direct employment opportunities created by the proposed Coega Mining project, serving a further 200 downstream employment opportunities in the local readymix concrete industry. This mining right is essential for the supply of material for the contractor, Glendore Holdings, who currently operate in Zone 10 of the Coega SEZ. Glendore Holdings support 31 staff, both at their sand pits and their offices. These jobs will be threatened by not securing a source of sand in the vicinity. This development will result in the retention of jobs, more than the creation of new ones. The mining right area is within the Coega SEZ, an industrial zone that is meant to encourage development, albeit sustainably. The SEZ is zoned Special Purposes that allows for mining.

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Mining, along with Aquaculture and power generation, are the designated industrial acitivities in Zone 10 of the Coega IDZ (SRK 2006). Although the mine is highly desirable from an economic point of view, it is located in an environmentally sensitive area. Identified as a CBA by the NMBM Bioregional Plan (2014), the area has been excluded as a CBA by the Coega OSMP (2015), which takes precedence, and is now part of the “Coastal Cluster” of Zone 10. However, it remains in the littoral active zone of Algoa Bay, and is a recognised Ecological Process Area (EPA). A population of the critically endangered Damara Tern is also found nearby to the proposed mining right area. These environmental factors will be taken into account in the design of the mine. Mining is also desirable in terms of preparing the area identified as the “Coastal cluster” in Zone 10 to be developed. Mining will allow the mobile sand to be removed, preventing the problems associated with loose sand and sand blasting. This will allow any development in the coastal cluster to take place on the underlying calcrete layer instead of unconsolidated levelled sand. g) Description of the process followed to reach the proposed preferred site.

NB!! – This section is not about the impact assessment itself; It is about the determination of the specific site layout having taken into consideration (1) the comparison of the originally proposed site plan, the comparison of that plan with the plan of environmental features and current land uses, the issues raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout as a result.

Details of the development footprint alternatives considered. With reference to the site plan provided as Appendix 5 and the location of the individual activities on site, provide details of the alternatives considered with respect 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 technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity

(a) Location No alternative sites were assessed. There are few alternatives to the location of the sand mine, as it is dependent on the presence of an economically exploitable mineral ore body. The number of easily exploitable sand sources around NMBM is fast diminishing. The dune fields between the Coega and Sundays Rivers is a good source of sand, and is largely degraded due to historic human disturbances and invasion by alien plant species. It remains a sensitive environment though, and there endemic and threatened plant species in the neighbouring indigenous vegetation. The location of any mine is primarily determined by the location of the mineral resource. Secondarily it is controlled by the cost of transport to the market that is mainly influenced by

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Coega Mining (PTY) LTD the price of diesel. This requires a mine to be as close to its clients as possible, particularly in a competitive market such as the supply of sand to the construction industry. The particle size of the sand resource is important as well. Aeolian sands have a higher percentage of finer particles, making it suitable for building sand and low strength concrete required for the foundations of houses. It is not suitable for engineering concrete used in the construction of factories and other developments that require heavy loads. There are two main sources of sand within the Nelson Mandela Bay Municipality (NMBM), Quaternary Aeolian or windblown sand along the coast and alluvial or river-deposited sand in the Swartkops and, to a lesser extent, the Coega River. Aeolian sand dunes are present along much of the coastline, but occur mostly along the southern coast between Van Stadens River Mouth and Cape Recife, and between the Coega and Sundays River where it forms an extension of the Alexandria Dunefield. The most accessible sand occurs in the previous Driftsands Mobile Dunefield that was historically not vegetated. Both of these areas are classified as Sand Movement Corridors, as they provide the ecological service of transporting sand, allowing the rejuvenation of beaches and sand dunes. There are currently three operational sand mines in Quaternary sand deposits in the south of NMBM and two in the Coega IDZ, of which many are coming to the end of their mineral deposits. Alluvial sand occurs in the floodplains of the Swartkops and to a lesser extent the Coega River Valleys. It is generally mixed with a range of larger stones and pebbles. The stone aggregate is used for the production of concrete and road construction. There are currently seven mining operations in the Swartkops River and one in the Coega River. These two rivers are ecological corridors as well and are highly sensitive to mining related disturbances. Apart from these two sources of sand, one operator is mining the Upper Van Stadens River Dam that has become silted up. The mining right area identified for Coega Mining consists largely of the last remaining unvegetated tall dunes in the Coega SEZ that do not fall within a CBA. The proposed area has a limited impact on the vegetation of the area, as well as being as far away as possible from the CBA designed to protect the breeding population of the Damara Tern. The site neighbours existing sand mines, as well as an existing access road. The proposed contractor has a long history of operating in the area, and has established clients. A suggestion was made by the Environmental Manager of Coega SEZ to consider mining the dumps located in the Coega SEZ. However, this was not investigated as a mineral resource has to be considerably free of impurities to consider being used for building sand, in particular when used in the production of concrete, and the dumps have high levels of mixed materials, making it uneconomical.

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(b) Type of Activity No alternative activities were assessed. All Listed activities are related to the mining of sand, and the construction of roads to facilitate the mining. The area where the proposed sand mine will occur is situated within a developable area of the Coega SEZ. It is presently unutilized, but is zoned for Special Purposes and is mostly included in the Aquaculture Development Zone (ADZ), that has received an EA from DEDEAT. It is not situated within a CBA and will not be used for conservation or residential purposes. The ADZ requires the removal of the dunes as part of the site preparation, as indicated in the approved EMP.

(c) Layout Alternatives No layout alternatives will be assessed. The area identified for the Coega Mining Mining Right Area was the remaining contiguous area of dunefield found in Zone 10 of the Coega SEZ, outside of a CBA, including a 200 m buffer area identified around the CBA for Damara Terns. The majority of the mining right site is covered in high sand dunes and will be mined. Existing infrastructure of a neighbouring mining operation, Sonop Quarry, will be utilised and extended in the easterly direction. Very little permanent infrastructure will be developed on site. A more direct access point to the mining right area via existing dirt roads cannot be constructed, due to overlapping construction of the ground infrastructure for the Coega ADZ. The access to the proposed mine has to be further negotiated with Coega SEZ, as well as the contractor who will be appointed to lay the ground infrastructure for the Coega ADZ. The existing access road and entrance to Sonop Quarry which will be utilised for Coega Mining, will more than likely be presently maintained, with the entrance point being moved to where the access road crosses the route of the proposed road in the ADZ, to manage traffic. Once all infrastructure has been installed, it can be negotiated with Coega SEZ to move the access point to the newly constructed tar road through the ADZ, to shorten transport distance on dirt roads.

(d) Alternative Technologies No alternative technologies were assessed, as there as the applicant will use their patented technology to acquire the grain size, required by the client, if any primary processing of the mineral is necessary to provide a product required by the market. The solution added to the material is patented but does not include any toxic polluting chemicals.

(e) Alternative operations

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No operational alternatives exist for sand mining, apart from open cast free digging, using an excavator and dump trucks. Alternative mine schedules were proposed and assessed during the EIA, to reduce the impact of mining on the environment, as well as on the other operations (ADZ) in the area. Two mine schedule options: Mining from the north in a southerly direction: The existing access road and mining operations make this alternative the originally preferred option. Mining from the east in a westerly direction: The existing access road to the abandoned SeaArk Facility and Abalone Farm provides access to the easterly side of the Mining Right Area.

(f) No-Go Alternative The No-Go alternative will result in the site remaining in a similar state as present. There will be increased encroachment on the existing infrastructure, including the abandoned road and telephone poles, as well as the Algoa Dune Thicket and Algoa Strandveld that exists both inland and downwind from the proposed mining area. There may be an increase in the cover of rooikranz (Acacia cyclops), although this is likely to be limited due to the high mobility of the dunes. Not developing the sand mine will more than likely result in a shortage of building sand in NMBM, particularly in the northern half of the metro. It could alternatively result in the increased cost of building sand due to the higher associated transport costs, and increased truck traffic on the roads of NMBM in the south. This may result in fewer social housing opportunities for the construction industry in the northern parts of NMBM, and in particular the smaller SMMEs, as well as a reduction in the provision of housing for service delivery. Apart from these wider economic consequences to NMBM, there will be negative economic consequences for the mining contractor and will result in job losses when the sand mines operating in the area become exhausted. This will result in a loss of rates and taxes for NMBM and national government as well. The site may be cleared of sand irrespectively in the future due to the development of the ADZ, but this sand may not be able to be utilized optimally without the presence of a mining permit or right.

Details of the Public Participation Process Followed Describe the process undertaken to consult interested and affected parties including public meetings and one on one consultation. NB the affected parties must be specifically consulted regardless of whether or not they attended public meetings. (Information to be provided to affected parties must include sufficient detail of the intended operation to enable them to assess what impact the activities will have on them or on the use of their land.

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Public participation activities that have been / are to be undertaken to inform the public, stakeholders and Organs of State of the applications and availability of the reports are listed below.  Newspaper Advert published on the 27 May 2019 in The Herald (English) (see copy of the advert as Appendix C1).  Site notices (English) placed at the following location on the 27th May 2019 at the entrance to the site; the entrance of the current sand mine that will be the entrance of the proposed operation (33°46'39.02"S 25°42'25.04"E), and the turnoff on and the gravel road turnoff at the traffic circle on the main road in Zone 10 off the N2 (33°46'10.74"S 25°42'15.12"E). Proof of placement of the site notices and contents of the site notices can be seen as Appendix C2.  Written notification via email to landowner, Coega Development Corporation (CDC)  Minutes and feedback from previous consultations with the CDC, and in particular Andrea Shirley, were integrated into the Scoping Report  Meeting was held with Dr Paul Martin regarding the Damara Tern breeding population in Zone 10 of the Coega SEZ  A Background Information Document (BID) with a comment and registration form was sent to all I&AP’s as identified on 18 April 2019. Specifically, the authorities that were e-mailed are:

NMBM: Environmental Management: Godfrey Murrel NMBM: Environmental Management: George Brandford NMBM: Senior Director: Water and Sanitation: Barry Martin NMBM: Director Strategic Planning: Schalk Potgieter Eskom: Manager: Lands & Rights: Howard Blane Eskom: Manager: Environmental Management: Angelina Shalang ECPRHA: Sello Mokhanya ECPTA: Shane October AgriEC: Teresa Barkhuizen AgriEC: Brent McNamara DMR:Health & Safety: Terence Doyle DRDAR: Thembani Nyokana DEDEAT: Dayalan Govender DWS: Marisa Bloem ECDRPW Peter Lotter

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DAFF: Thabo Nokoyo

 This communication was sent electronically via email. Copies of the BID mentioned above can be seen as Appendix C3. The I&AP database is attached as Appendix C4. Meetings of minutes with the landowner Coega SEZ can be found in Appendix C5. Evidence of communications with Interested and Affected Parties is found in Appendix C6.  Attendance of two Coega ELC meetings to inform the committee of the proposed mining activity on the 23rd May 2019, and 21st November, 2019  An email to registered I&APs, landowners, ward councillors and commenting authorities has been sent on the 28 May 2019 to notify these parties of the application and availability of the Draft Scoping Report for 30-day commenting period. Comments received during the 30day public participation period will be incorporated in the Final Report which will be submitted to the competent Authority (DMR) for their decision.  Hard copies of the draft Scoping Report were supplied to the DMR as competent authority, and DEDEAT and DWS as commenting authorities. Acknowledgment of receipt of the draft reports are provided in Appending C6  Numerous consultations via e-mail and meetings with CDC, including Andrea Shirley and Graham Taylor, to discuss the development, as well as any potential conflicts or complementary activities for the Coega ADZ  An email to registered I&APs, landowners, ward councillors and commenting authorities has been sent on the 29 November 2019 to notify these parties of the application and availability of the Draft Environmental Impact Assessment Report and Environmental Management Programme (EIAR & EMPR) for 30-day commenting period. Comments received during the 30day public participation period will be incorporated in the Final Report which will be submitted to the competent Authority (DMR) for their decision.  Hard copies of the draft EIAR & EMPR were supplied to the DMR as competent authority, and DEDEAT and DWS as commenting authorities. Acknowledgment of receipt of the draft reports are provided in Appending C6

Summary of issues raised by I&APs Please see Appendix C4 for the register of Interested & Affected Parties. All comments received are listed in Table 3, as well as the relevant response.

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Table 3 List of Comments/Objections raised by Interested & Affected Parties

Where in report Name Comment Response addressed AUTHORITIES RESPONSES TO BID

NA NA

RESPONSES TO SCOPING REPORT ELC (meeting held on 23 May 1. Can you design this project to not have a high cumulative impact on 1. Alternative sources have been identified but the cost of delivery of 2019) the Damara terns? Alternative sources of building sand in the NMBM? sand is a big component and makes for uneconomical operations. Mining of existing stockpiles and Eastern Reclamation in the Port of Dr. Paul Martin, the avifaunal expert who did the specialist study, Ngqura? indicated that the Cumulative Impact can be reduced from High to 2. What would happen if Paul’s study said the impact on Damara terns Medium by implementing buffers and doing annual population will be too high and you can’t mine in the area monitoring. MBS&S has moved their operational area, and 200 m 3. Is this application only for sand? Not stone, aggregate and gravel? But away from any nesting site, and is now in compliance with their the resource you are looking at there is sand. EMP. 4. How does this mining right impact on existing mines and applications? 2. We would probably have to redesign the area to avoid the It seems there may be some overlap. breeding site 5. You indicated that you will use the specialist studies done for the ADZ. 3. In the application we clearly specify what minerals are going to be Those studies were done a while ago. You will need to check the mined and state all their different definitions, namely sand, stone relevance of those studies’ findings, and if not, you will have to update aggregate and gravel. If you start mining and you start getting them and/or have them reviewed. some pebbles, aggregate and gravel, then you will have to leave

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Where in report Name Comment Response addressed 6. Is the 3-year rehabilitation a normal requirement or is it a commitment it behind. Which then becomes a residue stockpile which triggers made by the company? What is it based on? the Waste Act. There is a market for stone, aggregate and gravel. 7. Looking into the sand itself; is it dune vs river vs beach sand? Which is If it does occur then we’ll use it. more suitable as building sand? 4. The current operations are all coming to the end of their lives. 8. Does the mining right application include the existing area that you’re This mining right application will ensure supply of sand. applying for for Ngqura Sand? 5. I understand that they include relevant mitigations and findings. 9. If the CDC initiates an investment in the ADZ, how will this affect the 6. The 3 years was a recommendation from Dr Martin. The DMR mining operations? recommendations are not specific in terms of times required. 10. Where would you start working from? 7. With addition of calcium carbonate during primary processing, 11. Would you work towards the terns first or towards the vegetated area? dune sand can be made into preferable building sand. 12. Once the right has been approved is there going to be a need to apply 8. No, they are not allowed to do that; cannot have overlapping for a license? mining rights and permits. 13. Will the area you are applying for change as a result of your specialist 9. That will form part of the negotiations with the land owner and it studies? has been raised before that the mining schedule will have to be 14. From what I understand, the required source is building sand. There designed around the development of the ADZ. We can start in the are other areas within the SEZ where there are stockpiles of subsoil area that they plan to develop soonest and hopefully find a and topsoil. Could that be a viable resource to consider mining? compromise. 15. ASh (CDC): SANParks must be included as an IAP. 10. That has not been identified yet 16. The statement “the African Penguin shouldn’t be affected too badly”. 11. That will have to be agreed upon by all specialists. What does this mean? There should not be any negative impact on the 12. No. Mining license is an old term. It is now divided into a 5ha African Penguin colony. mining permit valid for 2 years and can be renewed three times, and a mining right for an area greater than 5ha and is valid for up to 30 years 13. Yes, it could change. 14. For some applications, yes. For your primary plants you can’t have contamination with various mineral resources because it

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Where in report Name Comment Response addressed affects the strength of the end-product and leads to failures on site. 15. Noted 16. Issue is that the dust could affect the penguins on the islands, but it has been found that dust will not likely reach the islands as a result of the mining. Dr. Paul Martin assessed the impact of dust on the African penguins, and determined that the impact will be negligible.

RESPONSES TO DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT ELC comments (meeting held 1. There is a potential for conflict of access control once the construction of 1. Negotiations have taken place between the architects appointed on 21 November 2019) roads for the ADZ commences. Explain how this aspect will be managed for the ADZ, CDC and the applicant, and future negotiations will and include in the EMP include the construction contractors. Alternative routes were 2. Does the dust management plan make provision for the dust fall discussed, but the best solution was to keep the existing gravel monitoring programme? access route to the current sand mining operations in Zone 10. 3. In terms of phasing and timing, when are investors anticipated? What is However, the access control point, that consists of a boom and the life-span of this mine, anticipating volumes of sand? security guard hut, will be moved from its current location, to 4. The buffers around the mobile dunes. Which mobile dunes are going to where the gravel road intersects with the proposed Coega ADZ remain? I also want to understand the statement about the Damara terns road network. This will allow for traffic management at the not being there in 10 years, what is that based on? potential point of conflict. Constant communication between the 5. Can we go to the table that shows the difference between population applicant and the ADZ will be necessary to prevent and potential sizes over the years? If I understand it correctly, it says that the only site conflict. they are currently breeding is the site where your mining activity is 2. There is an existing dust fallout monitoring programme for proposed existing mines which will just be extended to include the haul road 6. The buffers and mobile dunes you are talking about, where are they (on as well as downwind of the Coega Mining area. the presentation)? What is the timing of the ADZ development in the 3. The mining schedule has been designed for site clearance of area? Phase 1 Coega ADZ operator’s sites that overlap the mining right

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Where in report Name Comment Response addressed 7. What happens to the dunes after mining? What will be the eventual to occur early in the life of the mine. It is unclear when profile after mining? development of the ADZ will start, but it is expected that service 8. How is the risk of mobile dunes into the ADZ going to be managed? infrastructure is completed in 1.5 years. The volume estimated mineral resource of the site is 4.3 million tonnes of sand and 426 000 tonnes of stone aggregate and gravel. At current expected demand of 110 000 tonnes p.a., the life span of the mine should be 32 years. 4. Mobile dunes outside of the Mining Right Area will not be mined, namely between the coast and the Mining Right area. In terms of the Damara Terns, it was not said that the population will be extinct in 10 years. The statement related to the declaration of buffer areas. The areas within 300 m of the Damara Terns nests were declared no go areas, instead of the mining right area being amended and those specific areas being excluded. If the breeding population in Hougham Park ( on average 2-3 breeding pairs) does go extinct due to disturbance, loss of breeding habitat or simply random events, and population monitoring indicates that no breeding has taken place for a number of years, then these no go areas may be mined by the applicant. This will ensure the optimal mining of the resource, as well as improved management of the surrounding area. Competing mining applications in any excluded areas would greatly complicate management of the area, and increase negative impacts on the surrounding areas. The findings on the table are preliminary and based on a single early season sampling trip. Monitoring is going to be done until February. It is not clear why the other two sites have not been used by the Damara terns for breeding.

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Where in report Name Comment Response addressed 5. The 50 m buffer is a recommendation in the Coega ADZ EMP. 6. The majority of the dunes will be mined, with only a thin baselayer remaining for rehabilitation and development. The profile will be flat, due to the underlying flat calcrete layer. 7. The dunes migrating into the mining right area will be mined. The remaining dunes outside the mining right area that could impact the ADZ will have to be stabilised or removed in a legal manner. The 50 m buffer that will be periodically cleared should protected the ADZ from sand inundation.

Lyndon Mardon (Eastern Cape 1.The dust impacts from this activity is not moderate but serious and the 1. It is uncertain why the dust impacts from this activity is considered Air Emissions Officer) proposed mitigation issues were wholly inadequate. Dust and PM10 pose serious. Mining will occur in an unvegetated dune area, with natural both a nuisance and health hazard to both the environment and human high levels of dust. However, particle size is mostly large, health. This brings into question whether the mitigation measures are dominated by quartz and calcium carbonate, and sand grains will effective. enough to reduce the impacts from high to moderate? The not travel more than 100 m. No receptors are currently nearby. The mitigation issues with regards to the suppression of wind blown dust from the mining should not increase current dust emissions from the mining face and disturbed areas is not mentioned. dunefield. No concerns regarding dust impacts have been received 2.Wetting of roads in a drought scenario is not environmentally feasible and from current mining operators in Zone 10. Dust emissions from the poses a serious risk to the sustainability of the water supply of the mining face cannot be mitigated as it would be unfeasible to use municipality which is a significant climate change risk. Which leads to the water to suppress dust, and attempting to plant vegetation in the second issue that of climate change. I do not concur with the author that the dunes would be unsuccessful due to environmental conditionsl. No climate change mitigation and adaptation measures can be so effective as blasting with explosives takes place. Dust is emitted from the haul to lower the mitigation measures from low to very low because: road which is approximately 1.5 km long, and a maximum of a) The energy use of desalinated water is extremely high. another 1.5 km internal roads. Dust emissions from the road will be b) The use of heavy diesel driven equipment will not decrease the carbon monitored and dust suppression done on roads when necessary. footprint. Personnel Dust Monitoring is required by the DMR, and reports are

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Where in report Name Comment Response addressed c) Organic dust suppressants by their very nature have a carbon component produced quarterly. Current mining operations in the area result in which will breakdown to release greenhouse gasses once again. very low PM10 numbers. d) The consideration of climate impacts and the adaptation to these impacts 2. The water proposed to be used for dust suppression is not potable is not discussed in the document. water, but it high quality water from Cerebos that is a by-product of e) We know from previous studies in the area that the soil contains calcium their salt production activities. Water is evaporated from brine and carbonate as a result of its proximity to the ocean and crustaceous . collected for reuse. Currently it is being pumped into the Will the mining of this material not release GHG into the atmosphere? estuary/ocean. a. As discussed above. b. Acknowledged. Currently, no economic alternatives exist for the use of diesel engines and Internal Combustion Engine Vehicles (ICEV) for the hauling of the mineral product. South Africa’s electricity production is dominated by coal, and Electric

Vehicles (EVs) will not substantially reduce COs emissions. Until technologies that promote alternative fuels and engine technology are economically viable, this impact is unmitigatable. The offices run off solar panels and batteries. c. Acknowledged. The organic dust suppressant will reduce the amount of water required for dust suppression, and only

produce minor quantities of CO2 during breakdown. d. Climate Change is an impact identified and addressed in the Impact Assessment. e. Calcium Carbonate is a very stable compound, and will not release Carbon Dioxide during the mining of sand.

OTHER STAKEHOLDERS

RESPONSES TO NEWSPAPER ARTICLE AND BID

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Where in report Name Comment Response addressed LANDOWNER: CDC: ANDREA 1. CDC has been integrally involved in all the mining permit applications 1. Thank you for your comments. a. EMPr and traffic SHIRLEY and we have provided detailed comments on each application. Our a. The EMPr will include recommendations to enforce speed impact in Table 11 comments also apply to the Coega Mining Right application and include: limits and the rules of the road for the mining operation. b. Section 1 h) iv) This will include the erection of traffic signs, necessary Baseline a. Traffic safety measures, specifically along the road from the off-ramp traffic calming measures, and integration of traffic into environment: at the N2, to the mine entrance. There is substantially more traffic in environmental awareness training. Co-operation will be Avifauna and this Zone now that OTGC and TNPA have commenced construction in necessary with CDC as some independent customers Specialist Reports the Zone. It has been observed that trucks to and from the mine are come to fetch sand directly from the mine. Required taking a short-cut around the traffic circle. This aspect must be raised b. An avifaunal specialist study will be done by Dr Paul c. EMPr with the mine manager to ensure that suitable measures are Martin and all recommendations will be included in the d. Section 1 d) implemented to avoid an accident. Note also that the CDC has a EMPr. As part of the EMPr, the monitoring programme will Description of stockpile area in Zone 7, opposite the Sonop electrical substation. This include specific conditions to monitor the implementation Activities and EMPr area will be utilized more often and trucks will be entering and exiting of mitigation measures to ensure minimum disturbance to e. Section 1 d) the stockpile area. Speed limits along that road must be observed. the breeding population of Damara Terns. Description of

b. Damara tern breeding sites – please ensure that all recommendations c. Portable toilets will be provided in walking distance at the Activities made by Dr Paul Martin are observed, included and implemented. operational area, including the sand pit and mobile 2. Appendix C6 screening plant. Environmental Awareness Training will c. Portable toilets – a toilet has been provided at the Mine entrance include encouraging staff to use these toilets. Monitoring boom. Thank you. A toilet must also be provided at the mine site, requirements will monitor the non-use of the toilets. specifically where the mining is taking place. d. Your comments are noted. e. Negotiations are underway between Cerebos and Coega d. Rehabilitation – our previous comments remain as per the Mining to utilise desalinised water for dust suppression, if rehabilitation of the mined out areas. necessary

e. Water use for dust suppression – potable water should not be used for 2. A letter of notification will be drafted and sent to CDC dust suppression. We have previously engaged Glendore Sand on regarding the mining right application on CDC-owned land using water from Cerebos and it was understood that this would be implemented. However, from our discussion earlier today, it seems as

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Where in report Name Comment Response addressed if this is not taking place. Please provide clarity and if there is a problem preventing the use of Cerebos’s water.

2. Please provide the CDC with a letter notifying us formally of the Mining Right application. I will distribute the letter to the CDC team and enquire from them if they would like to meet to discuss the project.

COMMENTS ON DRAFT SCOPING REPORT Dr Phil Wittington 1. Page 34, under heading Geohydrology: the third sentence, beginning Your comments regarding the Scoping Report for the Mining Right 1. Baseline “This aquifer” requires re-writing. Application by Coega Mining (Pty) Ltd (Ref. no. 30/5/1/2/2/10049MR) Environment: 2. A key/legend needs to be given to some of the flora/fauna species lists. are acknowledged. Thank you for taking the time to review the report Geohydrology (page For instance, what is the relevance of “(d)” in the floral lists and “Ra” in comprehensively. Your comments will be addressed in the Final 34) Table 7? Scoping Report that will be uploaded onto the ACME website after 2. Baseline 3. A lot of supposition is being made with species that may be present in the 30 day consultation period is complete. However, please be Environment: Flora the application area that have been or could be recorded in the relevant aware that the DMR is the sole competent authority since 2014, as and Fauna Sections quarter degree square. Specialist studies are required in the actual per the EIA Regulations of 2014. Concerning the layout of the report, 3. NA application area to ascertain exactly what is there. This is a basic the DMR provides a template that must be adhered to. 4. NA necessity for floral, faunal and heritage aspects. 1. Noted. 5. Table 11 4. It is pointless putting Table 11 in the document before the explanatory 2. Noted and included. (d) is dominant and Ra is rare. 6. Section sections currently starting on page 65. The explanation of the figures 3. The species data recorded on a quarter-degree square format is 7. NA used for extent, duration, probability and intensity and the details of how part of the desktop study of the Scoping Phase to identify any 8. Table 14 significance is calculated are necessary before one can interpret the conservation priorities for this development. The EAP has a good 9. Reference Section information in Table 11. knowledge of the area, and a number of previous surveys and EIAs

5. The headings for Table 11 need to be carried to each separate page on have been done in the vicinity. Using the quarter-degree data allows which the table appears. One doesn’t want to have to keep going back to the EAP to be over-cautious, and implement the precautionary the top to be reminded what each column represents. principle. Relevant specialist studies, namely avifauna and

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Where in report Name Comment Response addressed 6. On page 57, it is stated that impacts of site preparation will result in loss vegetation, will be done and included in the Environmental Impact of species of conservation concern (SCC) and their habitat. However, Report (EIR). Table 11 (row 14) states that no floral SCCs occur on site. This would 4. It is required of the EAP to utilise the template for a Scoping Report, seem to be a contradiction. Is there expected to be a loss of faunal SCCs provided by the DMR, and therefore changes cannot be made to and their habitat only? This needs clarification. the order of required points. 7. I am somewhat bewildered by the fact that the Department of Mineral 5. Noted and implemented. Resources should be the competent authority for this application. Surely 6. There is no contradiction as the term ‘biodiversity’ includes both DEDEAT or DEA would be more appropriate? flora and fauna. Presently no floral SCCs have been recorded from 8. Table 14 talks of prohibiting hunting and collecting. These must be the site, whereas it is well known that a breeding population of the prevented, not just prohibited. Enforcement of the regulations and of the Critically Endangered Damara Tern occurs within the vicinity of the mitigatory procedures must be carried out. mining right. 9. The Minter et al. reference is in the wrong place. It should follow the 7. DMR was appointed by government gazette as the competent DEDEAT reference. The first reference in the list should be Albertyn, authority for the granting of environmental authorisation for all which comes before . You cannot use the same citation for more mining activities in 2014. than one reference, e.g. ADU (2017) cannot be used for four different 8. The inclusion of the term prevention is included. references. They should be cited as ADU (2017a), ADU (2017b), etc. 9. Thank you for your comments. The relevant changes will be made to the reference section. RESPONSES TO DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT Paul Martin P5: 2 Titles refer to other mining projects (similar copy & paste errors need All comments have been addressed and necessary revisions made to to be checked throughout the document) the Final EIAR and EMPr

Top p15 highlight: Grammar (phrase makes no sense)

Table 3 p27. The meeting date should be included in the left hand column (as some questions were addressed in the Draft EIR). P28: Avifauna rpt assessed dust impacts on penguins to be negligible P30: Better wording for potential loss of Damara Tern colony P31: Check facts of what Cerebos is doing with their RO water – they have a bottling facility

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Where in report Name Comment Response addressed P45: Document needs checking for latest names of Govn Departments (also abbreviations) P46: ECECB acronym P46: References to flora under fauna heading

P47: Appendix B is in Avifauna Rpt. Table 6 has the info

P48: Damara Tern is globally Vulnerable (2016) – see under (i) on p47

P57: Ngqura Sand permit status

P68 & p69: Fig.17 could be misleading wrt buffers. The light blue line in Fig.17 denotes the 200m N & 300m W buffers – not the “200m buffer” to the mining right boundary written on Fig 17. The EMPr p105 correctly states the situation.

P73: Reference to Coega ECO

P75: Repeated para

P77: Search & Rescue only applies to flora, not SSC fauna P77: Damara Tern colony to be monitored. 200m (N) & 300m (E) buffer from nests to be included here

P92: Impact Management Objective should include minimising impacts on the Damara Tern colony

P93: Important to get wording of any condition in the Authorisation correct. See p106 for guide to the correct wording. Elsewhere in the document the term buffer and not No-Go area is used.

If during the Environmental Audit / EMPPA, no Damara Terns have been recorded at the breeding colony adjacent to the Mining Right for a period of three (3) consecutive years, this indicates that the colony has been abandoned. In these circumstances the 300m buffer to the east and 200m buffer to the north will fall away, allowing mining upto the boundaries of the Mining Right

P93: I undertook multiple visits for Damara Tern monitoring purposes

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Where in report Name Comment Response addressed P101: Search & Rescue only for Flora SSC

P110-111: Numerous references to another project (cut & paste errors)

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The Environmental attributes associated with the sites. (The environmental attributes described must include socio-economic, social, heritage, cultural, geographical, physical and biological aspects)

Baseline Environment

(a) Type of environment affected by the proposed activity.

(its current geographical, physical, biological, socio- economic, and cultural character). 1) Climate

The mining site falls within the Nelson Mandela Bay Municipality which is regarded as having a complex climate as it falls within the confluence of several climatic regimes, the most important of which are temperate and subtropical. The area has a warm temperate climate and the temperature ranges are not extreme. Snow is absent and frost is uncommon. NMBM is also a transition zone between the winter rainfall and the summer rainfall areas of South Africa, with relatively low rainfall occurring intermittently throughout the year, although bimodal peaks in Spring and Autumn observed. Average annual rainfall across NMBM ranges from 820 mm along the south coast, to 400 mm in the Coega River. The average annual rainfall measured at the Ngqura (Coega) weather station by the South African Weather Service is 416 mm (Table 4).

Table 4 Monthly precipitation data at the Coega Weather Station, according to the South African Weather Service.

Data Jan Feb March Apr May June July Aug Sep Oct Nov Dec Avg (mm)

Average 24.7 36.9 38.1 35.4 32.9 40.2 26.5 29.7 17.3 57.7 33.2 39.8 34.3

The mean annual temperature for the Coega area is 17.9 °C. The monthly mean, maximum and minimum temperatures for the Ngqura (Coega) weather station for the period of 2003 to 2010 can be seen in Table 5.

Table 5 Temperature data for the nearby Coega Weather Station, according to the South African Weather Services.

Data Jan Feb March Apr May June July Aug Sep Oct Nov Dec Avg (°C)

Mean 21.4 22.0 20.6 18.8 16.9 14.7 14.2 14.6 15.4 17.2 18.9 19.9 17.9

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Max 25.5 26.2 25.5 24.4 23.1 21.6 21.4 21.3 21.4 22.1 23.6 24.4 23.4

Min 17.4 17.8 15.6 13.2 10.6 7.8 7.0 7.8 9.3 12.3 14.2 15.4 12.4

The dominant wind direction is west to south-south-westerly winds and blows throughout the year (Albertyn 2016). Easterly winds dominate the summer months, and north-westerly winds or Berg winds occur during Autumn. These three winds represent 70%, 24% and 6% of the wind energy for the Coega area respectively. The annual wind rose for the Coega area as measured at the Coega Development Corporation’s (CDC) Saltworks Air Quality monitoring station can be seen in Figure 3.

Figure 3 Wind rose (m/s) for the Coega IDZ, according to the Air Quality Specialist Assessment, LAQS, 2016.

2) Geographical

The Peninsula formation forms the bedrock in the Port Elizabeth area. These sandstones of the Table Mountain Group consist of coarse-grained super-mature quartzitic sandstone. This formation is overlain by the Sundays River formation (marine mudstone) and the Kirkwood formation (fluvial mudstone) of the Uitenhage Group. The Alexandria formation, consisting of calcareous sandstone, sandy limestone and conglomerate was deposited as a thin capping over an elevated marine terrace, on top of the Uitenhage Group. During the Late Tertiary Period, the Alexandria formation was deposited over a shallow sea floor that was subsequently raised to over 300 m above present sea level.

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The upper visible dune sands of the area forms part of the Schelm Hoek formation. These recent Aeolian (windblown) sands, denoted as Qw on the Geological Maps as published by the Council for Geoscience, is the dominant geological formation in the area. The sand is cohesionless and loose (Figure 5). The Coega fault runs west of the Groendal dam eastwards the coast outside of the mining right area, dipping at between 30 and 60° for about 120 km. It is classified as a normal tensional fault with a vertical southward flow of between 500 and 100m. Topographically, the coastal section between the Coega River and the Sundays River is dominated by a transgressive dune field made up of a number of active dunes (sandsheets) that move through an area of vegetated dunes (Figure 4). A transverse dune crosses the site in a north-south direction. It has been estimated that the yearly sand budget in this dune field is about 18 x 103 m3y-1. Due to pulses in sand supply, the average annual rate is about half of this over the last 6500 years, when it is believed that the sand was deposited. The sands are well sorted and have a mean grain size of 0.19 mm. It consists of 62% quartz, 38% calcium carbonate and less than 1% heavy minerals, consisting mostly of ilmenite (Illenberger, 2018).

Figure 4 Topography of the Coega Mining mining right area site.

The soil of the site is dominated by imperfectly drained, greyish sandy soil that is regarded as highly erodible.

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Figure 5 Extract of the 1:250 000 geological map (3324 Port Elizabeth) showing dominant geological formations of the mining right area.

3) Geohydrology

The site falls within the south of the Algoa Basin region (63) of the Department of Water Affairs classification of groundwater. The shallow groundwater consists of a fractured aquifer with a yield of 0.1-0.5 L/s. A deeper aquifer, the Coega Ridge Aquifer is a vital source of freshwater inflow and nutrients to the coastal zone of Algoa Bay, and is expected to be exploited in the future as a source of potable water for the Nelson Mandela Bay Municipality (NMBM). It is regarded as being the only important artesian system of practical importance in South Africa and is currently regulated due to past overexploitation. The Aquifer is formed by sandstones and quartzites of the Table Mountain Group and is confined by a succession of eastward-thickening Cretaceous formations up to 1 200 m thick near the coast. The groundwater flows in an easterly direction and is approximately 3 to 5 m below the surface, just above the surface of the permeable sands and the underlying impermeable clays. It flows in a southeasterly direction, mirroring surface flow. Shallow groundwater has a high salinity and total dissolved solids content, and is not exploited for usage.

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4) Hydrology

The site is located within the Algoa subwater Catchment Area of the Fish to Tsitsikamma Water Management Area. It is not found within a National Freshwater Ecosystem Protection Area (NFEPA). There are no natural wetlands, and the Coega River is found over 2 kms away, as the crow flies (Figure 6). The nearby abandoned Sea Ark culturing facilities are identified as an artificial wetland.

Figure 6 Coega Mining is not near any identifiable conservation features, including rivers, wetlands and Threatened Ecosystems.

5) Flora

The Vegetation Map for South Africa, Lesotho and Swaziland (VegMap) by Mucina & Rutherford (2009) is most widely accepted classification of South Africa’s vegetation. It includes information on the conservation status and indicator species for each recognised vegetation type in the country. This biodiversity planning product also forms the basis for the NEM Biodiversity Act list of Threatened Ecosystems. The 2018 version of the VegMap has recently been released. This version resulted in a comprehensive re-classification of the Thicket biome, affecting the vegetation types recorded on site. Previously the vegetation

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Coega Mining (PTY) LTD was classified as Algoa Dune Strandveld, whereas now it is St. Francis Dune Thicket (Figure 7).

Figure 7 Dominant vegetation types of the mining site, according to Mucina & Rutherford (2012).

St. Francis Dune Thicket occurs on flat to moderately undulating coastal dunes as a mosaic of low (1 - 3 m) thicket, occurring in small bush clumps dominated by small trees and woody shrubs, in a mosaic of low (1 - 2 m) asteraceous fynbos (Grobler et al. 2018). Thicket clumps are best developed in fire-protected dune slacks, and the fynbos shrubland occurs on upper dune slopes and crests. The vegetation type is considered poorly protected, but is found in the nearby Sardinia Bay Nature Reserve, Nelson Mandela University Private Nature Reserve and Cape Recife Nature Reserve. It is threatened with mining, alien invasion by Acacia cyclops and urban sprawl, with 14.13% having been transformed. The conservation target for St. Francis Dune Thicket is 19%. Cape Seashore Vegetation is found in the Western Cape and Eastern Cape Provinces, along the temperate coasts of the Atlantic Ocean (Olifants River mouth to Cape Agulhas) and Indian Ocean (Cape Agulhas to East London). It is characterised by Beaches, coastal dunes, dune slacks and coastal cliffs of open grassy, herbaceous and to some extent also dwarf-shrubby (sometimes succulent) vegetation, often dominated by a single pioneer species. Various plant communities reflect the age of the substrate and natural disturbance regime (moving dunes), distance from the upper tidal mark and the exposure of dune slopes (leeward versus seaward). Young coastal sandy sediments forming beaches and dunes

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(Strandveld Formation), exposed to reworking by relentless winds and frequent sea storms The climate diagram is largely uniform with all-year precipitation pattern. The vegetation type is considered Least Threatened, and has a conservation target of 20%. Almost half of the area statutorily conserved in the West Coast, Cape Peninsula, Agulhas, proposed Garden Route and Greater Addo Elephant National Parks. Only about 1.7% has been transformed, mainly by urban development. The NMBM Conservation Assessment and Plan (2009) formed the basis for the NMBM Bioregional Plan (DEDEAT 2015), which provides a spatial framework for development in the municipal area (Figure 8). The assessment identifies sensitive areas (Critical Biodiversity Areas) that impose certain biodiversity related constraints on development.

Figure 8 Dominant vegetation types at the proposed mining site, according to Stewart (2010).

Three vegetation or habitat types occur within the mining right area. Sandy beaches dominate the coastline, grading into Algoa Dune Thicket on the vegetated sand dunes. Protected milkwoods (Sideroxylon inerme) and candlewood (Pterocelastrus tricuspidatus) dominate the Thicket, with Waxberry (Morella quercifolia) and the Endangered Cotyledon adscendens characteristic as well. Further inland, Colchester Strandveld occurs, consisting of Algoa Dune Thicket clumps surrounded by honey thorn (Lycium cinereum) and grasses such as quick grass (Cynodon dactylon). Sandy beaches are considered Least Threatened, and Algoa Dune Thicket and Colchester Strandveld being classified as Vulnerable.

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The site can be considered a disturbed example of Coastal or Cape Seashore Vegetation, with its number of seral stages. The majority of the site is dominated by unvegetated, tall sand dunes (Figure 9). These dunes are in the process of migrating in a north-easterly direction, transgressing over the existing bushclumps between the dunes, as well as the established vegetation to the east and north-east of the site. Occasional plant species occur, mostly annual species such as Gomphocarpus physocarpus, as well as fast growing shrubs including Searsia crenata which is able to tolerate the sand inundation to a certain extent. Rocky flats occur either naturally between the dunes and support a very specific but variable community, or as previously mined areas in the north where limited to no rehabilitation has taken place. The individual patches are usually dominated by only one or a few species, such as Chrysocoma rigidula, Euphorbia sp., Ficinia dunensis, Sporobolus virginicus, Lessertia frutescens. Around the rocky flats, where low dunes occur, species such as Ehrharta villosa, Helichrysum asperum, Morella cordifolia, Psoralea repens, Indigofera sp. nov. 'sinusalgoae' and Seriphium sp. nov. "dunensis" as well as Carpobrotus deliciosus, Passeria rigida and Zygophyllum maritimum. Two currently undescribed species, Indigofera sp. nov. 'sinusalgoae' and Seriphium sp. nov. "dunensis" were found in the rocky flats and shallow dune sands. Both these species have limited distributions, most likely dune endemics limited to the south-eastern coast of the Eastern Cape, from Oyster Bay to Alexandria (pers. comms. Adriaan Grobler). Throughout the site, and particularly along the coast, dense stands of Acacia cyclops occur. These were either planted a number of years ago to stabilise the sand, or has naturally invaded the surrounding area, establishing bushclumps between the dunes. Indigenous species have colonised these patches, including tall shrubs and trees such as Searsia crenata, S. glauca, Sideroxylon inerme and Tarchonanthus maritimus, as well as climbers (Cynanchum spp.) The area along the eastern boundary is classified as strandveld, and is more than likely a secondary vegetation type. Previously, the area consisted of mobile dune fields, but the sand was lost when fences were erected to the west, resulting in the current tall sand dunes to the east. This bare area was then stabilised by Acacia cyclops, and then colonised by indigenous species. These species include shrubs such as Anthospermum aethiopicum, Felicia erigeroides, Helichrysum cymosum, H. teretifolium, Indigofera verrucosa, Metalasia muricata, Osteospermum moniliferum, Zygophyllum maritimum, and graminoids (Cynodon dactylon, Eragrostis curvula, Imperata cylindrica, Stipagrostis zeyheri and Restio microcarpa). Bushclumps consist of typical dune species, including Euclea racemosa, Olea exasperata, Searsia spp., A high cover of Acacia cyclops is still present, particularly closer to the coast, but is currently being actively cleared.

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In the north-east and north of the site, more natural strandveld, or St. Francis Dune Thicket, vegetation is found, but this is also quite invaded by A. cyclops and is rather species poor.

Figure 9 Vegetation types of Coega Mining Mining Right Area.

There were 69 plant species recorded from the proposed mining permit area. Of these, 5 were exotic species recorded on site (Appendix 3), and 3 declared invaders under the National Environmental Management: Biodiversity Act No. 10 of 2004 – Alien and Invasive Species Lists (published 29 July 2016). The dominant invasive species are Acacia cyclops,

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Photo 2 Top: Tall Sand dunes migrating over and burying the existing secondary strandveld vegetation. Top: Presence of bushclumps, shallow sand areas and rocky flats between the tall dunes.

A. saligna and Opuntia humifusa. These species must form part of the alien management plan. All Category 1b species should be eradicated immediately. One Species of Conservation Concern (SCCs) was recorded on site (Appendix 3). Psoralea repens is classified as Near Threatened, as it is endemic to the Cape Seashore Vegetation along the south coast. One tree species are listed under the National Forests Act No. 84 of 1998, namely milkwood (Sideroxylon inerme). These may not be removed or damaged without the relevant permits from DAFF.

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Seven species are protected under Schedule 4 of the Nature and Environmental Conservation Ordinance of 1974. These are Aloe africana, Carpobrotus deliciosus, Cynanchum africanum, C. ellipticum, C. obtusifolium, Elegia microcarpa, Mesembryanthemum aitonis. Even though these are all particularly common species, permits are required from DEDEAT for their clearance. Apart from these species, Chironia baccifera, Euclea racemosa and Rhoicissustridentata are Protected under Eastern Cape Environment Conservation Bill (ECECB).

Please note that the Eastern Cape Environment Conservation Bill of 2003 has not been gazetted to date and therefore cannot be enforced.

6) Fauna

South Africa uses the internationally endorsed IUCN Red List Categories and Criteria in the Red Listing of South African species (SANBI 2017). This scientific system is designed to measure species' risk of extinction. The purpose of this system is to highlight those species that are most urgently in need of conservation action. All species are classified, according to their level of threat from extinction, as the following categories: Extinct (EX), Extinct in the Wild (EW), Regionally Extinct (RE), Critically Endangered, Possibly Extinct (CR PE), Critically Endangered (CR), Endangered (EN), Vulnerable (VU), Near Threatened (NT), Critically Rare, Rare (Ra), Least Concern (LC), Data Deficient - Insufficient Information (DDD) Data Deficient - Taxonomically Problematic (DDT) and Not Evaluated (NE).

Threatened species are species that are facing a high risk of extinction. Any species classified in the IUCN categories Critically Endangered, Endangered or Vulnerable is a threatened species. Species of conservation concern are species that have a high conservation importance in terms of preserving South Africa's high floristic diversity and include not only threatened species, but also those classified in the categories Extinct in the Wild (EW), Regionally Extinct (RE), Near Threatened (NT), Critically Rare, Rare, Declining and Data Deficient - Insufficient Information (DDD).

a. Mammals

A species list from MammalMap (ADU 2017a) was extracted for the Quarter Degree Square (QDS) of 3325DC. A desktop assessment indicates that 63 mammal species are present within the Coega IDZ area (CES 2000, SRK 2006, Ethical Exchange 2017, MammalMap 2017c).

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Twenty five species of mammals have been collected in the QDS 3325, and none have been classified as Threatened (Table 4). The honey badger (Mellivora capensis), classified as Near Threatened, may occur on site. Specific mention must be made of the local population of the Pygmy hairy-footed Gerbil (Gerbilliscus paeba), regarded as genetically distinct and previously recognised as a separate sub-species. It is only found in the dunes and beach areas between St. George’s Strand and Sundays River Mouth. b. Birds

Bird species that are known to regularly occur within approximately 2 km of the Coega Mining Right or that may be impacted by the proposed project are listed in Table 6. The list comprises of 153 bird species, including ten species listed in one of the threat categories in the South African Red Data Book – Birds (Taylor et al. 2015) or IUCN Red List. Of these, seven species are associated with the marine and coastal environments. Of the 30 species on the list that are endemic or near-endemic to southern Africa, 23 occur in the thicket and bontveld vegetation types (Table 6). Most of the Coega Mining Right is on a mobile sand dune where bird numbers and diversity are low. However, there are some species of conservation concern that may be impacted by the proposed mining operation and these are discussed below. i. Damara Tern

There is a colony of Damara Terns, Critically Endangered in South Africa and Vulnerable globally, that breed in the dune slacks among the sand dunes adjacent to the Coega Mining Right. This is potentially the greatest risk to avifauna posed by the proposed mine and is dealt with in detail in the next section.

ii. African Penguin The African Penguin (Endangered) population is decreasing by approximately 6.4% per year. The South African population was 56,000 breeding pairs in 2001, 20,000 in 2011 and 15,000 in 2018 (B Dyer in litt). Approximately 5400 pairs breed on St Croix Island (35% of the global population) 4.8 km SE of the Coega Mining Right and 230 pairs on Jahleel Island 2.9 km to the SW (Taylor et al. 2015; Marnewick et al 2015; B Dyer 2019 in litt). SANParks has raised concerns that increases in the incidences of aspergillosis (a fungal lung infection) in the penguin population on St Croix may be related to increases in dust from the Coega SEZ.

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iii. African Black Oystercatcher This species has been down listed and is now categorized as of Least Concern in South Africa and Globally. Approximately six pairs of African Black Oystercatchers nest along the coast in the vicinity of the Coega Mining Right. The mitigation recommendations applicable to the Damara Terns will similarly benefit the oystercatchers. iv. Blue Crane

There is often a pair of Blue Cranes (globally Vulnerable, Near-Threatened in South Africa) in Zone 10 of the Coega SEZ. They bred (unsuccessfully) on the sand dunes on the eastern boundary of the Coega SEZ in 2016. However they have not been seen on the dunes in the project area and the proposed mine is not expected to have an impact on this pair of Blue Cranes. v. Knysna Woodpecker

A pair of Knysna Woodpecker (Near-Threatened) occupies the Algoa Dune Thicket east of the Coega Mining Right. A small area of Algoa Dune Thicket is expected to be impacted during the proposed mining operation. However impacts on this species are expected to be negligible as relatively large areas of suitable habitat will remain on the primary and secondary dune systems within the Coega OSMP area. There is not expected to be any storm water run-off or pollution into the sea from the Coega Mining Right. Therefore no impacts are expected on the other marine and coastal bird species of conservation concern listed in Table 6. Similarly, impacts on the terrestrial species listed in Appendix B can be adequately minimised by applying general mitigation measures. The bird species most threatened by the sand mining development is the (regionally) Critically Endangered Damara Tern (Sterna balaenarum), listed as Vulnerable in the 2016 Global Status. In South Africa they breed in coastal dunes and are threatened by habitat loss and human disturbance. The species is experiencing a downward trend in South Africa, as the population estimate in 2000 was 120 to 150 breeding areas, decreasing to potentially as low as 36 pairs. Adult birds are long-lived and faithful to their breeding colony, and the probability of a breeding bird moving to another colony is low. According to Dr Paul Martin’s survey of Damara Terns in the area, a number of pairs nest near to the old abalone farm in the high shifting sand dunes area (See Appendix D1). These nests are situated a few hundred metres away from the mining right area, and do fall within the OSMP. Table 6 List of Threatened Birds found within 2 km of the Coega Mining mining right area in the Coega IDZ, including endemic species.

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Common Name Scientific Name IUCN SA Endemic Habitat Notes

Penguin, African Spheniscus En En NE Marine Breed St Croix demersus

Gannet, Cape Morus capnesis En Vu NE Marine Breed Bird Isle Cormorant, Phalacrocorax En En NE Marine, Breed St Croix Cape capensis Coastal

Secretarybird Sagittarius Vu Vu Bontveld serpentarius

Buzzard, Jackal Buteo rufofuscus E Terrestrial

Crane, Blue Anthropoides Vu NT E Bontveld, Pair bred in paradiseus Dunes dunes

Oystercatcher, Haematopus moquini E Coastal Breed on coast African Black

Gull, Hartlaub’s Chroicocephalus E Coastal hartlaubii

Tern, Caspian Sterna caspia LC Vu Coastal Tern, Roseate Sterna dougallii LC En Marine, Breed islands Coastal

Tern Damara Sterna balaenarum Vu CR NE Coastal Breed dunes. Migrant

Woodpecker, Campethera notata NT NT E Thicket Pair in thicket Knysna near mine

Lark, Cape Mirafra apiata E Bontveld Clapper

Bulbul, Cape Pycnonotus capensis E Thicket Scrub-robin, Cercotrichas E Thicket Karoo coryphoeus Cisticola, Cloud Cisticola textrix NE Bontveld

Cisticola, Grey- Cisticola E Bontveld, backed subruficapilla Thicket

Prinia, Karoo Prinia maculosa E Thicket Flycatcher, Sigelus silens E Thicket Fiscal

Longclaw, Cape Macronyx capensis E Bontveld Boubou, Laniarius ferrugineus E Thicket Southern

Tchagra, Tchagra tchagra E Thicket Southern

Bush-shrike, Telophorus olivaceus E Thicket Olive

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Bokmakierie Telophorus zeylonus NE Terrestrial

Starling, Pied Lamprotornis bicolor E Terrestrial Starling, Cape Lamprotornis nitens E Terrestrial Glossy

Sunbird, Greater Cinnyris afer E Thicket Double-collared

Sunbird, Cinnyris chalybeus E Thicket Southern Double-collared

White-eye, Cape Zosterops virens E Thicket Sparrow, Cape Passer melanurus E Terrestrial

Weaver, Cape Ploceus capensis E Terrestrial Waxbill, Swee Coccopygia melanotis E Thicket

Canary, White- Crithagra albogularis E Thicket throated

There are three Global Important Bird Areas (IBAs) close to the Coega SEZ (Marnewick et al. 2015) (Figure 10). These are areas that regularly hold significant numbers of globally threatened species or are of importance to species with restricted ranges: a) Woody Cape Section: Addo Elephant National Park. This IBA starts at the Sundays River 13 km E of the Coega Mining Right and stretches 60 km E to Cannon Rocks. It includes the Alexandria Coastal Dunefield and Alexandria Forest. Of consequence to the mining project is that the dune system between the Port of Ngqura and Sundays River is an extension of the Alexandria dunefield. The mobile dunes support breeding Damara Terns and African Black Oystercatchers, two of the trigger species for the IBA. The dune thicket supports a variety of Southern African endemic species including Knysna Woodpecker, Cape Bulbul, Olive Bush- Shrike, Swee Waxbill. b) Algoa Bay Islands: Addo Elephant National Park. This IBA includes Jahleel and St Croix Islands 2.9 km SW and 4.8 km SE of the Coega Mining Right. St Croix has the largest breeding population (approximately 5400 pairs) of African Penguins Spheniscus demersus in the world (approximately 35% of the world population) and Jahleel Island has approximately 230 pairs (B Dyer in litt, 2018 data). Several other endangered species, including Cape Cormorants, breed on the islands. Of consequence to the Coega Mining Right is that dust from the mainland has been identified as a possible cause of increased incidents of aspergillosis (a fungal lung infection) in the penguin population.

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c) Swartkops Estuary, Redhouse and Chatty Saltpans 11 km SW of the site. Important for its coastal wetlands, this IBA is of little consequence to the Coega Mining Right.

Figure 10 Global Important Bird Areas, in relation to the Coega Mining mining right area.

Reptiles A species list from ReptileMap (ADU 2017b) was extracted for the Quarter Degree Square (QDS) of 3325DC. There have been 44 reptile species collected in the QDS 3325DA since 1980, of which 5 are Species of Conservation Concern (Table 7). However habitat on site supports none of these species, as three are marine turtles, Bradypodion taeniabronchum (Elandsberg Dwarf Chameleon) occurs in mountain fynbos of the Elandsberg, and Tetradactylus fitzsomonsi (Fitzsimons Long-tailed Seps) occurs in sandy fynbos habitats along the coastline. One reptile excluded from the ReptileMap list is the Albany Adder, due to it being classified as Critically Endangered. According to Branch and Turner (2014) in the Reptile Red List of South Africa, Lesotho and Swaziland (2014), The Albany Adder is only found in bontveld vegetation on limestone and calcareous paleodunes between Port Elizabeth and Grahamstown. It is considered extinct at two historical localities, with only one known population remaining. Recent sightings have occurred within the Coega IDZ.

Table 7 List of possible reptile species present on the proposed mining site.

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Atlas Common Red list Family Genus Species Subspecies region name category endemic

Elandsberg Endangered Chamaeleonidae Bradypodion taeniabronchum Dwarf Yes (SARCA 2014) Chameleon

Loggerhead Vulnerable Cheloniidae Caretta caretta Turtle (SARCA 2014)

Near Cheloniidae Chelonia mydas Green Turtle Threatened (SARCA 2014)

Olive Ridley Data Deficient Cheloniidae Lepidochelys olivacea Turtle (SARCA 2014)

Leatherback Endangered Dermochelyidae Dermochelys coriacea Turtle (SARCA 2014)

FitzSimons' Vulnerable Gerrhosauridae Tetradactylus fitzsimonsi Long-tailed Yes (SARCA 2014) Seps

Amphibians A species list from FrogMAP (ADU 2017c) was extracted for the Quarter Degree Square (QDS) of 3325DC. Thirteen species of frogs were recorded from the QDS 3325DC. None of them are classified as Threatened. A species list from LepiMAP (ADU 2017d) was extracted for the Quarter Degree Square (QDS) of 3325DC. 88 Butterfly species have previously been collected in 3325DC (Table 8). Three species are classified as Threatened, the Coega Copper (Aloeides clarki) and the Common opal (Chilades trochylus) are listed as Endangered, and the Sand-dune Opal Chrysoritis pyroeis subsp. hersaleki) as Vulnerable. The Wineland Blue ( bacchus) is considered Rare. Populations of A. clarki and L. bacchus have been recorded in the Coega IDZ and their populations included in the Coega Open Space Management Plan (OSMP).

Table 8 List of possible Threatened butterfly species present on the proposed mining site.

Atlas region Family Genus Species Subspecies Common name Red list category endemic Aloeides clarki Coega copper Endangered Yes

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Chrysoritis pyroeis hersaleki Sand-dune opal Vulnerable Yes Chrysoritis thysbe whitei Common opal Endangered Yes Lepidochrysops bacchus Wineland blue LC (R–HS, LD) Yes

5)Socio-economic The mining right application site is located in the Nelson Mandela Bay Municipality, the sixth largest metro in South Africa, and has an area of 1 950 km2 and a population of 1,152,115, consisting of 325 292 households (Census 2011). The largest urban centre is Port Elizabeth, with Uitenhage and Despatch being other important towns. Females make up 52% of the population, translating into a sex ratio of 92,3. Black people make up the largest population group at 60.1%, followed by Coloured (23.6%), White (14.4%) and Indian (1.1%) people. IsiXhosa is the most widely spoken home language, spoken by 53.2% of the residents, followed by Afrikaans (28.9%) and English (13.3%) The population is relatively young, with 25.5% being under the age of 14 and only 6% over the age of 65, giving a dependency ratio of 46. The largest economic sectors in the Nelson Mandela Metro are manufacturing, finance, community services and transport. Community services, trade and manufacturing sectors are the sectors that create the most employment in the metro. The GDP growth rate was 2.1% in 2010 and the GDP per capita is R52 147. The unemployment rate is 36,6% for the whole population, whereas youth unemployment is 47,3%. In total, 30,5% have a matric certificate, and 12% have some form of tertiary education.

6)Cultural & Heritage During the Stone Age (1.5 million to 2 000 years ago), divided into the Early, Middle and Late Stone Age periods, the area was occupied by a series of hunter-gatherer societies with increasing levels of technology and cultural complexity. These periods can be identified by various stone tools and other achaeological artefacts that have been identified in the area, mostly along the Van Stadens River to Noordhoek coastline. Shell middens dating to this period have also been identified. From around 2000 years ago, the Khoekhoen hunter-gatherers would have migrated into the area with their domestic animals, supplanting previous hunter-gatherer societies. Their occupation is generally identified through grave sites, pottery and shell middens. After the arrival of the British 1820 Settlers, the area would have been exposed to new impacts, including graves, houses and other buildings and agricultural infrastructure. According to SAHRIS (2011), Middle and Later Stone Age and Holocene sites have been identified in Zone 10 of the Coega IDZ by previous and current surveys and assessments (Binneman 2010). Scatters consisting of locally available quartzite cobbles and black

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Coega Mining (PTY) LTD hornfels occur along the western beach adjacent dune fringe. These are considered low significance. A number of archaeological features were recorded along the shifting dune areas, including:  three small low sensitivity shell midden scatters of Perna perna  a scatter of very likely KhoeSan pottery fragments along the grass on a large deflation bay with few fragments of Donax serra nearby  a Perna perna shell scatter with few associated bone fragments  a Perna perna shell midden scatter with few associated possibly KhoeSan pottery fragments and stone tools  a scatter of few quartzite stone tools and pottery fragments.

A few of these sites have been subsequently covered by the shifting sand dunes.

7) Conservation Status ii) Eastern Cape Biodiversity Conservation Plan (ECBCP) (2007) The Eastern Cape Biodiversity Conservation Plan (Berliner & Desmet 2007) is a regional systematic biodiversity conservation plan for the Eastern Cape (Figure 11). The plan set certain development guidelines based on calculated biodiversity score for different landscapes. Basically the terrestrial areas covers by the plan are designated as Critical Biodiversity 1, 2, or 3 areas, each with specific development recommendations.

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Figure 11 Proposed mining site in relation to Terrestrial Critical Biodiversity Areas identified by ECBCP (2007).

The proposed mining area falls within the Terrestrial Critical Biodiversity (CBA) Area 2 – T2, indicated by the Eastern Cape Biodiversity Conservation Plan (2007). This is due to the site falling within a 1 km buffer strip of the coast. Within the Terrestrial CBA 2 T2 areas, there are Biodiversity Land Management Class (BLMC) that are included. BLMC 2 are for near-natural landscapes. Each BLMC has specific land use objectives. It is recommended that land in BLMC 2 is maintained in a near natural state with minimal loss of the ecosystem integrity. In addition, there should be no transformation of the natural habitat should be permitted.

The ECBCP identified Aquatic CBAs as well, with the site being classified as an Aquatic CBA 3 (A3b), falling within hydrological primary catchment area for an E2 estuary (Figure 12). The Aquatic BLMC (ABLMC) is 2a, with the recommended land use objective is to manage for sustainable development, keeping natural habitat intact in wetlands, and riparian zones. Environmental Authorisations should support ecosystem integrity.

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Figure 12 Proposed mining site in relation to Aquatic Critical Biodiversity Areas identified by ECBCP (2007).

The Coega SEZ has developed an Open Space Management Plan as a requirement for operation (Figure 13). The latest Coega OSMP was approved by DEA in 2014. The OSMP is a network of CBAs for both the Coega SEZ, as well as the Port of Ngqura. CBAs were defined as areas for the protection of species and preservation of ecological processes, and consist of environmentally sensitive areas like Bontveld conservation areas, dense Mesic Succulent Thicket on steep slopes, butterfly habitat, grave sites, riparian zone, portions of the primary and secondary dunefields, and areas below the 1:100 year floodline. The CBA areas identified in the Coega OSMP are managed as a sub category of CBA in the NMBM Bioregional Plan and no conflicts should exist.

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Figure 13 Coega OSMP, including the proposed Aquaculture Development Zone.

(b) Description of the current land uses.

The mining right area is located in Zone 10 of the Coega SEZ, which is zoned Special Purposes. The area is currently unutilized, but is integral to a number of proposals in the SEZ. It occurs in the proposed Aquaculture Development Zone (ADZ) as identified by the Coega SEZ, as well as the “coastal cluster” of developable land where industries such as power generation from Liquid Natural Gas (LNG), mining and aquaculture are proposed (See Figure 14 and 15). The Coega ADZ received an EA in, and currently is tendering for the construction of service infrastructure, including roads, electricity and substations. As there is considerable overlap between the coastal section of the ADZ and the proposed mining right area, constant negotiations and communication must take place between the ADZ, including the individual contractors and operators, to prevent any possible conflict during both the construction and operation phase. This includes the management of traffic, especially on the haul road. The present access control will be moved to the location where the current access road overlaps the proposed road network for the ADZ, to manage traffic at the crossing and reduce any potential conflict. The access control point, as well as any access or haul roads, may move as the development of the ADZ progresses.

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The site is surrounded by a number of operational and exhausted sand mines, The Sunshine Coast Quarry mining right, commonly known as Sonop Quarry, and the Mandela Bay Sand & Stone mining permit is operational, and Ngqura Sand mining permit is currently being assessed. Dove Mining Services mining permit is currently applying for mine closure. Crews Quarry mining right is only mined intermittently, and PPC has a mining right for the calcrete in and under the sand.

Figure 14 Neighbouring mining operations and other activities.

(c) Description of specific environmental features and infrastructure on the site.

The proposed mining right area is dominated by medium to tall unvegetated mobile dunes. Infrastructure on site is limited to an old access road and Telkom phone lines that runs along the north-eastern edge of the mining right area, to the abandoned Sea Ark prawn farm and Hougham Park abalone farm. This road and telephone lines is slowly being inundated by the shifting dunes. The eastern and north-eastern edges are vegetated with predominantly secondary vegetation, including Alien Invasive Plants such as Acacia cyclops.

During the initial EIA for the Remainder of the Coega IDZ, a heritage impact assessment was done that the assess the heritage resources of the area and to guide future development plans in the IDZ. The Impact Assessment consisted of three separate

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studies, an Archaeological Impact Assessment (Binneman 2010), a Palaeontological Heritage Assessment (Almond 2010) and a Historical Assessment (Bennie 2010). A review comment on these reports, produced by SAHRA (SAHRA 2011), provided recommendations to mitigate any potential heritage impacts for developments within each zone of the Coega IDZ. Therefore, no new Heritage Impact Assessment was necessary. The recommendations for Zone 10 are: .A number of archaeological features were recorded along the shifting dune areas, including:  three small low sensitivity shell midden scatters of Perna perna  a scatter of very likely KhoeSan pottery fragments along the grass on a large deflation bay with few fragments of Donax serra nearby  a Perna perna shell scatter with few associated bone fragments  a Perna perna shell midden scatter with few associated possibly KhoeSan pottery fragments and stone tools  a scatter of few quartzite stone tools and pottery fragments.

Before they can be impacted, each of them needs to be recorded and a report from the recording must be sent to SAHRA. After this, the developer shall apply for a destruction permit from SAHRA. If from the recording of the site, its significance seems to be higher than expected, it will be necessary for the archaeologist to apply for a Phase II permit to allow for the gathering of more information and further evaluation of the site. After completion of the Phase II report, a destruction permit can be requested from SAHRA by the developer. Along the shifting dune areas a scatter of few quartzite stone tools and pottery fragments were also recorded. A destruction permit needs to be applied for by the developer before destruction of the site. All these recommendations were summarised and included in the EMPr.

(d) Environmental and current land use map.

(Show all environmental and current land use features)

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The environmental sensitivities and current land uses surrounding the proposed mining right application area of Coega Mining can be seen in Figure 15.

Figure 15 Environmental and Current Land Use Map of the proposed mining right area of Coega Mining.

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Impacts and risks identified (Provide a list of the potential impacts identified of the activities described in the initial site layout that will be undertaken, as informed by both the typical known impacts of such activities, and as informed by the consultations with affected parties together with the significance, probability and duration of the impacts. All potential impacts for activities associated with the proposed sand mining are identified in Table 9.

The operation of a sand mine is the constant removal of sand from an open pit. Roads are extended as the open pit moves across the landscape, and rehabilitation is done concurrently with mining. Due to this nature of sand mining, the activities cannot be divided easily into pre-construction, construction, operation and post- operation/rehabilitation phases. Instead Site Preparation, Excavation and Post- Closure Phases are more accurate.

The activities identified for the Site Preparation (Construction) Phase:  Search and Rescue for any Threatened species  Clearing of vegetation and levelling of landscape for the proposed access road  Clearing of vegetation for water pipeline  Clearing of any vegetation of the mining footprint  Demarcating the mining right area with clearly marked beacons  Digging of trench, laying of pipeline and backfilling of trench for water pipeline  Stripping of 30 cm of topsoil, where available, and stockpiling topsoil in topsoil stockpile area  Demarcating no-go areas  Erection of mobile screening plant, including generator and water tanks  Erection of ablution facilities and other necessary infrastructure

The impacts from the activities are: 1. Site clearing will result in a loss of biodiversity, including the loss of SCCs and their habitat. No floral SCCs recorded from the site as yet, but there will be a loss of habitat for the Damara Tern, a Critically Endangered bird species. 2. Site clearing will result in increased surface erosion. However, this is currently high due to the site consisting mostly of unconsolidated dune sand 3. Site clearing will result in increased surface stormwater flow 4. Loss of topsoil will result in the loss of agricultural potential of the area. However, this is already low, due to site being mostly unconsolidated dune sand within a Special Economic Zone

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5. Any vehicles or machinery used in the site preparation process poses a risk to groundwater due to potential spillages or oil leaks

The activities associated with the Excavation (Operation) Phase:  Excavation of open pit for sand mining  Loading and Hauling of sand  Primary processing of sand with a mobile screening plant  Clearing of AIPs  Replacement of topsoil, sowing of seeds and irrigation of mined areas  Utilisation of ablution and other facilities

The impacts from these activities are: 1. Loss of existing mineral resource 2. Change in topography of the local area 3. Change in visual character of the local area 4. Potential change in the sediment dynamics of the coast of Algoa Bay 5. Reduction of water infiltration and increased surface flow caused by the loss of sand dunes 6. Contamination of groundwater by greywater produced by the ablution facilities 7. Contamination of groundwater by hydrocarbon spills produced by vehicles and machinery 8. Contamination of surface water by greywater produced by the ablution facilities 9. Contamination of surface water by hydrocarbon spills produced by vehicles and machinery 10. Increased human presence increases environmental risks such as littering and disturbance of nearby breeding Damara Terns 11. Increased traffic could result in the direct loss of fauna, through vehicle collisions and hunting 12. Increased dust emissions from excavation and loading and hauling of sand. However, the present unconsolidated dune sand and high wind conditions results in high baseline dust conditions 13. Increased gaseous emissions from generator and vehicles 14. Increased noise from generator and vehicles 15. Increase in AIPs as a result of surface disturbance of the area 16. Potential loss of heritage resources 17. Provision and retention of employment 18. Supply of sand to the local construction industry

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The activities associated with the Post-Closure Phase:  Replacement of topsoil, sowing of seeds and irrigation of mined areas  Rehabilitation of roads, if desired by landowner  Monitoring and removal of AIPs  Removal and rehabilitation of all infrastructure

The impacts of these activities are: 1. Rehabilitation of mining area 2. Removal of AIPs

Table 9 Potential Impacts relating to the proposed mining right application.

Significance

Probability

Duration Intensity

Extent Phase Activity Impact

GEOLOGY & GEOGRAPHY 1. Loss of geological resource Operation MEDIUM Excavation All the material above the calcrete layer will be 2 4 3 3 (72) Post-Closure removed during the mining process in the mining right area. Operation 2. Change in Topography Mining of the sand resource will result in the levelling MEDIUM Excavation of the sand dunes that are up to 25 m tall. However, 2 4 3 2 Post-closure these higher dunes were artificially created. This is (48) potentially a positive impact as it can be considered site preparation for future proposed development. Operational Site clearing 3. .Loss of soil fertility and agricultural potential LOW and Post- The area consists mostly of unvegetated dunes and 1 5 3 1 Excavation (15) closure has an existing very limited agricultural potential. 4. Change in sediment dynamics of the area MEDIUM Operational Excavation 3 4 2 4 A loss of the sand dunes will result in a reduction in (48) the supply of sand to the upwind dune system. GEOHYDROLOGY 5. Reduction in water infiltration into the shallow Site clearing aquifer Operational The removal of the dunes will increase surface flow LOW and Post- 2 5 2 2 and decrease the slow infiltration of water into the (40) closure Excavation surface aquifer. There should be no impact on the Coega Aquifer as the underlying is impermeable. 6. Contamination of groundwater by hydrocarbon Excavation spills and builder’s lime Hydrocarbon spills from mining vehicles and the generator for the mobile screen plant could Loading, Construction contaminate and groundwater. No surface water, hauling and MEDIUM and either wetlands or rivers, have been identified on site. 2 4 2 4 transporting (64) Operation No diesel, diesel or other hydrocarbons will be stored on site. Builder’s lime and a proprietary chemical, added to the sand during primary processing are inert and can be handled and thus poses no risks.

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Significance

Probability

Duration Intensity

Extent Phase Activity Impact

7. Contamination of groundwater by waste and grey water Construction Very limited waste water will be produced on site. All MEDIUM and Ablution 2 4 2 4 vehicles will be maintained off site, and only portable (64) Operational chemical ablutions will be provided. Ablutions will be serviced by a reputable company. 8. HYDROLOGY 9. Contamination of surface water by hydrocarbon Excavation spills and builder’s lime Hydrocarbon spills from mining vehicles and the generator for the mobile screen plant could Loading, Construction contaminate and groundwater. No surface water, VERY hauling and and either wetlands or rivers, have been identified on site. 2 4 1 3 LOW transportating Operational No diesel, diesel or other hydrocarbons will be stored (24) on site. Builder’s lime and a proprietary chemical, added to the sand during primary processing are inert and can be handled and thus poses no risks. 10. Contamination of surface water by waste and grey water Construction VERY Very limited waste water will be produced on site. All and Ablution 2 4 1 3 LOW vehicles will be maintained off site, and only portable Operational (24) chemical ablutions will be provided. Ablutions will be serviced by a reputable company. 11. BIODIVERSITY 12. Disturbance to and loss of vegetation cover and Site clearing Construction habitat MEDIUM and Site preparation will result in the clearing of 2 5 3 3 (60) Operational Roads vegetation and the permanent loss of Cape Seashore Vegetation (LT) and Algoa Dune Strandveld (LT). 13. Loss of floral Species of Conservation Concern Construction, Site clearing and their associated habitat VERY Operational 1 SSC and a number of Protected species are found 2 4 1 1 LOW and Post- Excavation on site, as well as 2 undescribed species. (8) Closure Roads 14. .Loss of and disturbance to fauna and their Site clearing associated habitat, particularly faunal SCCs Clearing of vegetation and removal of sand dunes will Operational result in the loss of habitat for a number of animal HIGH and Post- species, specifically breeding Damara Terns 3 5 2 4 Excavation (120) Closure (Sternula balaenarum), Duthie’s Golden Mole (Chlorotalpa duthiae) and the pygmy hairy-footed gerbil (Gerbillurus paeba exilis). Roads 15. Direct loss of fauna Loading, Mining staff and traffic may result in the direct loss of MEDIUM Operational hauling and 2 4 3 3 fauna, through traffic accidents, hunting and other (72) transporting associated activities. The site neighbours a Critical Biodiversity Area (CBA). 16. Increased Environmental Risks Site clearing Excavating Increased number of people in the area will result in MEDIUM Operational Loading, the possible increase in certain risks without proper 2 4 3 3 (72) hauling and management, for example fires, poaching, illegal transporting plant collecting and harvesting, trampling of vegetation in no-go areas, littering.

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Significance

Probability

Duration Intensity

Extent Phase Activity Impact

17. .Impact on ecological processes that facilitate the persistence of biodiversity and ecosystem functioning, especially in a sand movement corridor Operational Site clearance and the removal of vegetation will MEDIUM and Post- Site clearing cause the fragmentation of the sand movement 3 4 2 3 (72) Closure Excavating corridor that forms part of a contiguous sand corridor Loading, stretching from the Swartkops to Sundays Rivers, and hauling and forms part of the Alexandria Dunefield. This transporting fragmentation will have genetic and population level Rehabilitation impacts on the biodiversity that inhabits the dunefield. 18. Disturbance of the surface resulting in increased Site clearing risk of AIPs Operational Construction of infrastructure and operation of the MEDIUM and Post- 2 4 3 3 mine will result in soil disturbance, greatly increasing (72) Closure Excavating the chance of the establishment of alien invasive plants such as rooikrans (Acacia cyclops) AIR QUALITY Site clearing 19. .Increase in dust emissions Mining will result in the increase of windblown sand in Excavating the area, although the increase may not be significant MEDIUM Operational 2 4 2 3 as the existing dunes are already exposed (48) Loading, hauling and transporting Site clearing 20. .Increase in gaseous emissions Gaseous emissions from the excavator, dump trucks Construction Excavating and mobile screen generator will cause air pollution, MEDIUM and 2 4 3 2 but those should be relatively negligible. (48) Operational Loading, hauling and transporting NOISE Site clearing 21. Increase in noise Noise from the excavator, dump trucks and mobile screen generator will cause air pollution, but those Construction Excavating should be relatively negligible. The area is also MEDIUM and 2 4 3 2 isolated and the nuisance factor of any noise (48) Operational produced will be low. Loading, hauling and transporting VISUAL Site clearing 22. Change in the visual character of the area Although there are a number of abandoned and existing industrial operations occurring in the surrounding area, it largely maintains its natural Operational character, especially as seen from any tourism Excavating MEDIUM and Post- operators in Algoa Bay. Mining of the sand dunes 2 5 3 3 (90) Closure should not materially affect this as very little infrastructure is being established and no permanent pit will be excavated. Loading, hauling and transporting HERITAGE

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Significance

Probability

Duration Intensity

Extent Phase Activity Impact

Site clearing 23. Loss of Heritage Resources Operational Heritage and Archaeological artefacts identified in the MEDIUM and Post- area include shell middens, stone tools and houses. 2 5 2 3 Excavation (60) Closure There is a good chance that artefacts may be uncovered during the process of mining. TRAFFIC 24. Increase in Traffic Truck traffic on the roads within the Coega IDZ, as well as on the N2, will not greatly increase as the proposed sand mine will largely replace an existing Loading, neighbouring mine that will be exhausted in the near MEDIUM Operational hauling and 3 4 3 2 future. An overlapping period where both mines will (72) transporting be operational will not greatly increase traffic either, unless demand increases. Potential conflict will arise during the construction phase of the ADZ, in terms of the haul road crossing ADZ roads under construction. SOCIO-ECONOMIC Excavation 25. Supply of sand to the construction industry Sand mined is crucial for the supply of building sand Loading, HIGH Operational for concrete and plaster to the construction industry. 3 4 2 4 hauling and (96) The construction industry has a large multiplier effect transporting on the economy. Excavation 26. Job creation and preservation MEDIUM Operational Loading, The proposed sand mine is essential for the 3 4 3 2 hauling and economic sustainability of the mining contractor that (72) transporting currently employs 26 people. CLIMATE CHANGE 27. Climate Change Impacts Potential climate change impacts are limited to sea level change and COs emissions. Although a large Site clearing portion of the mining right is below the coastal Excavation setback line, there should not be any impact by Operational Loading, increase in sea-level. Main impact relates to carbon 3 4 3 2 Very Low hauling and emissions from vehicles and generators. Until transporting alternative fuel vehicles become more economic and electricity production is dominated by coal, Internal Combustion Engine Vehicles (ICEV) will continue to be used. CUMULATIVE Site clearing 28. Cumulative Impacts There has been a cumulative loss of both primary and secondary coastal dunes and vegetation along the Algoa Bay coast, dating back to the establishment of Port Elizabeth, and especially locally since the construction of the Port of Ngqura. This has impacted Operational Excavation sand budgets in the area and the replenishment of and Post- beaches. The loss of connectivity between coastal 3 5 3 4 High Closure habitats and populations will increase as well. However a coastal strip exists that should preserve beach connectivity. Associated is the loss of breeding habitat for the Damara Tern. Loading, hauling and transporting

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Methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks; (Describe how the significance, probability, and duration of the aforesaid identified impacts that were identified through the consultation process was determined in order to decide the extent to which the initial site layout needs revision). The ranking of impacts / determination of significance is estimated consider the factors / criteria listed in the legislation. The definitions of each of the Assessment Criteria are provided below: i. Extent of impact :

A spatial indication of the area impacted (i.e., how far from activity the impact is realised). ii. Duration of impact :

A temporal indication of how long the effects of the impact will persist, assuming the activity creating the impact ceases. For example, the impact of noise is short lived (impact ceases when activity ceases) whereas the impact of removing topsoil exists for a much longer period of time. iii. Probability of impact occurring:

An estimated indication of the potential for an impact to occur. iv. Intensity of the impact:

The magnitude of the impact in relation to the sensitivity of the receiving environment, taking into consideration the degree to which the impact may cause irreplaceable loss of resources. v. Significance of an impact:

Considering the factors defined above, Significance is an indication of how serious a negative impact is anticipated to be and how beneficial a positive impact may be.

Table 10 Methodology for rating significance of proposed activities.

Category Category Rating Description

Site only 1 Project site Local 2 Effects immediate surrounding areas Extent Municipal 3 Effects municipal area Regional 4 Effects regional area National 5 Effects R.S.A. Very short term 1 Less than 1 year Short term 2 1 to 5 years Duration Medium term 3 5 to 20 years Long term 4 Longer than 20 years

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Permanent 5 Permanent

Improbable 0 Less than 30% chance Possible 1 Probability / 30 to 50% chance Likelihood Probable 2 50 to 75% chance Definite 3 Greater than 75% chance

Very low 1 No effect on natural, cultural or social conditions Low 2 Marginal effect on natural, cultural or social conditions Moderate 3 Intensity Modification of natural, cultural or social conditions Temporary threat to existence of natural, cultural or social High 4 conditions Permanent Threat to existence of natural, cultural or Very high 5 social conditions Very low 0 to 24 Low 25 to 47 The Significance is a measurement of the product of the Significance Medium 48 to 94 individual ratings of the Extent, Duration, Probability and High 95 to 188 Intensity. Very high 189 to 375

The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected. (Provide a discussion in terms of advantages and disadvantages of the initial site layout compared to alternative layout options to accommodate concerns raised by affected parties) No alternatives are being assessed for this mining right application. The shape and layout of the mining right area is determined by the distribution of the mineral resource, i.e. the sand, as well as the neighbouring existing sand mining operations. All CBAs, and especially the breeding area of the Damara Tern, and other vegetated dune areas were excluded from the mining right area, due to their environmental sensitivity. The remaining area of sand dunes in Zone 10 was included. Alternatives to the operations and technology used by the proposed sand mine was not assessed due to it being a simple open pit operation using standard mining vehicles and a mobile screening plant.

POSITIVE benefits of the mining activity include:  The local supply of building sand at a cost effective price to the construction industry of NMBM and surrounding area  The retention and creation of 5 jobs connected to the mining activity, and another 25 jobs connected to supporting services supplied the contractor

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 The payment of rates and taxes to NMBM and state coffers  Site preparation for future development within Zone 10 of Coega SEZ  The removal of Alien Invasive Plants (AIPs)  The provision of skills in the mining industry via internships and bursaries, as per the mine’s Social and Labour Plan (SLP)  Potential to manage the impacts on the Damara Tern colony in Zone 10 of the Coega SEZ in a strategic manner

NEGATIVE impacts of the mining activity include:  Change in topography of the site with the loss of large dunes  Change in the visual character of the site  Increased disturbance to the remaining vegetation and fauna of the area during the operation of the mine  Cumulative loss of sand dunes along the coast of Algoa Bay, and disruption to the sand movement corridor  Potential impact on the breeding population of the critically endangered Damara Tern  Potential loss of heritage artefacts  Increased traffic on roads

Mine Schedule Plan The mine schedule is a plan that indicates the proposed sequence of mining of blocks of roughly equal volume of the mineral resource. The blocks do not necessarily indicate years, but rather consecutive order, based on demand. Two mine schedule options were assessed: 1. Mining from the north in a southerly direction: The existing access road and mining operations make this alternative the originally preferred option. 2. Mining from the east in a westerly direction: The existing access road to the abandoned SeaArk Facility and Abalone Farm provides access to the easterly side of the Mining Right Area.

The final and preferred mine schedule plan (Figure 16) commences mining in the north and then progresses to mining on the easterly side of the Mining Right area, where Phase 1 of the ADZ overlaps with the MR (Figure 17). Mining progresses in a westerly direction, leaving the Damara Tern buffer area until last. If no Damara Terns are counted for three consecutive years in the neighbouring CBA area, the buffer area can be mined.

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The ADVANTAGES of the preferred mine schedule are:  Mining from the north where existing mining operations and access roads are located, limiting conflict with the construction activities of the ADZ  The eastern section of the MR that overlaps Phase 1 of the MR will be mined relatively early in the life of the mine, allowing the legal clearance of the sand for site establishment of the ADZ operators  Mining will occur in the opposite direction of the prevailing wind (south-westerly), limiting any further progression of the dunefield into vegetated areas  The buffers identified to preserve the breeding population of Damara Tern in the neighbouring dunefield (200 m north and 300 m west) are scheduled to be mined last. Mining in these buffer areas will only occur if no Damara Terns are located as part of the population monitoring in the neighbouring area.

The DISADVANTAGES of the preferred mining schedule are:  Mining in a south-easterly direction may result in the dunefield migrating at a quicker rate

Figure 16 Final Mine Schedule Plan for Coega Mining. Light blue line indicates the Damara Tern buffer area that is designated a No-Go Area.

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Figure 17 Overlapping area between the Coega ADZ and proposed Coega Mining Mining Right area. Red is Phase 1, Blue is Phase 2 of the ADZ. Light blue line indicates the Damara Tern buffer area that is designated a No-Go Area.

No alternatives are being assessed for this mining right application. The shape and layout of the mining right area is determined by the distribution of the mineral resource, i.e. the sand, as well as the neighbouring existing sand mining operations. All CBAs, and especially the breeding area of the Damara Tern, and other vegetated dune areas were excluded from the mining right area, due to their environmental sensitivity. The remaining area of sand dunes in Zone 10 was included. Alternatives to the operations and technology used by the proposed sand mine was not assessed due to it being a simple open pit operation using standard mining vehicles and a mobile screening plant.

POSITIVE benefits of the overall mining activity/ies include:  The local supply of building sand at a cost effective price to the construction industry of NMBM and surrounding area  The retention and creation of 5 jobs connected to the mining activity, and another 25 jobs connected to supporting services supplied the contractor  The payment of rates and taxes to NMBM and state coffers  Site preparation for future development within Zone 10 of Coega SEZ  The removal of Alien Invasive Plants (AIPs)

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 The provision of skills in the mining industry via internships and bursaries, as per the mine’s Social and Labour Plan (SLP)  Potential to manage the impacts on the Damara Tern colony in Zone 10 of the Coega SEZ in a strategic manner

NEGATIVE impacts of the mining activity include:  Change in topography of the site with the loss of large dunes  Change in the visual character of the site  Increased disturbance to the remaining vegetation and fauna of the area during the operation of the mine  Cumulative loss of sand dunes along the coast of Algoa Bay, and disruption to the sand movement corridor  Potential impact on the breeding population of the critically endangered Damara Tern  Potential loss of heritage artefacts  Increased traffic on roads

viii) The possible mitigation measures that could be applied and the level of risk. (With regard to the issues and concerns raised by affected parties provide a list of the issues raised and an assessment/ discussion of the mitigations or site layout alternatives available to accommodate or address their concerns, together with an assessment of the impacts or risks associated with the mitigation or alternatives considered). Issues raised by affected parties are: Breeding population of Damara Terns Dr Paul Martin raised concerns regarding the impact of the proposed sand mining on the Damara Tern population in Zone 10 of Coega SEZ. The Damara Tern is a Critically Endangered bird species whose population is increasing concentrated in the Algoa Bay area. A number of breeding pairs have been recorded in the coastal section of Zone 10. A CBA has been declared as part of the Coega OSMP to protect this population. The proposed mining will result in the loss of habitat of the Damara Tern, as well as the disturbance of breeding pairs, resulting in failed reproduction in the area. A number of mitigation measures are proposed, including  An avifaunal specialist study, focussing on the Damara Tern, by Dr Paul Martin  A 200 m buffer to the north and 300 m to the east around the breeding population  Strict control of access into the Damara Tern CBA

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The risk of sand mining will be the local extinction of the Damara Tern population in Zone 10. This is seen as increasingly likely due to the planned developments in the immediate vicinity. However, studies by Dr Martin has shown an increase in breeding pairs in other breeding areas in Algoa Bay, resulting in a reduced negative impact on the Damara Tern on a species level. The impact on the Damara Tern population, and possible mitigation measures, will be comprehensively assessed after the completion of the specialist study during the EIR and EMPr phase. Coega ADZ EMP The Coega ADZ that overlaps a large area of the mining right has received an EA and has an approved EMP. A number of mitigation measures of the EMP has been included in this assessment, to reduce any possible future conflict. The relevant mitigation measures included, mostly relating to dust emissions and control, are:  No development of ADZ structures and infrastructure to take place in areas where there are unvegetated dunes until the sand has been be removed. Mining to be in accordance with a valid mining right or mining permit.  The ADZ structures and infrastructure to be developed on the underlying calcrete surface once exposed.  A 50 m wide buffer zone to be maintained around mobile dune areas.  Drift-fences to be erected in the buffer zones to trap sand moving from the mobile dunes.  Build-up of sand in the buffer zones to be controlled by removing the sand every 5 years or as required.  The CDC maintains a 200 m buffer around Damara Tern nesting sites (The ADZ falls outside this buffer zone.  The Coega IDZ ECO conducts monitoring of Damara Tern nesting sites and monitors activities (i.e. existing mining) in the area around the 200 m buffer zone around the Damara Tern nesting sites. (Dr Paul Martin, the previous Coega SEZ ECO, will continue with the population monitoring in his private capacity)

The mining activities will allow for site preparation for the individual ADZ operators, and largely negates the necessity of a 50 m buffer around mobile dune areas, except along the coast and areas outside the mining right area. However, a 50 m buffer zone should be maintained between mining areas and ADZ operators, to reduce the impact of wind-blown sand deposition on the ADZ. These buffers will move with time, as the operational mine area moves, and rehabilitation occurs.

ix) Motivation where no alternative sites were considered. Andrea Shirley, the Coega SEZ Environmental Manager, suggested mining the waste stockpiles generated by site clearing of other developments in the SEZ. However, there are

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too many impurities for this to be considered a viable option for producing sand for the construction industry.

x) Statement motivating the preferred site. (Provide a statement motivating the final site layout that is proposed) The final site layout plan minimises the negative impacts on the environment, and complements the development of the Coega SEZ,and in particular, the Coega ADZ. h) Full description of the process Impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts (Provide a list of the potential impacts identified of the activities described in the initial site layout that will be undertaken, as informed by both the typical known impacts of such activities, and as informed by the consultations with affected parties together with the significance, probability, and duration of the impacts. Please indicate the extent to which they can be reversed, the extent to which they may cause irreplaceable loss of resources, and can be avoided, managed or mitigated). i) Assessment of each identified potentially significant impact and risk

(This section of the report must consider all the known typical impacts of each of the activities (including those that could or should have been identified by knowledgeable persons) and not only those that were raised by registered interested and affected parties).

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Table 11 Impacts of proposed sand mine.

Significance Phase Activity Impact Significance Mitigation Measures after mitigation

GEOLOGY & GEOGRAPHY 1.Loss of geological resource • Optimise mineral extraction through effective mine planning, which results in the reduction of geological waste and the minimisation of the footprint of the mining Operation MEDIUM area MEDIUM Excavation All the material above the calcrete layer will be removed (72) • A system to estimate the volume of sand replenishing the dune system from the (72) Post-Closure during the mining process in the mining right area. beach would be beneficial. Historical and current records of the volumes of sand mined from the dunefield must be kept. Operation 2.Change in Topography Mining of the sand resource will result in the levelling of MEDIUM MEDIUM Excavation the sand dunes that are up to 25 m tall. However, these No mitigation measures possible Post-closure higher dunes were artificially created. This is potentially (48) (48) a positive impact as it can be considered site preparation for future proposed development. Site Site clearing 3. Increase in soil erosion Preparation •Topsoil and overburden removed and stockpiled correctly The clearance of vegetation and topsoil stockpiles will LOW VERY LOW •Constant monitoring of mining area and topsoil stockpiles for erosion cause increased soil erosion. However site consists of (42) (16) Operation Excavation •Remediation of erosion features using most relevant methods unconsolidated dunes with little topsoil, limiting the increase in soil erosion. Operational Site clearing 3.Loss of soil fertility and agricultural potential • Implement a rehabilitation plan that restores the top soil and establishes LOW vegetation cover of the site VERY LOW and Post- The area consists mostly of unvegetated dunes and has Excavation (15) (4) closure an existing very limited agricultural potential. 4.Change in sediment dynamics of the area MEDIUM MEDIUM Operational Excavation No mitigation measures possible A loss of the sand dunes will result in a reduction in the (48) (48) supply of sand to the upwind dune system. GEOHYDROLOGY 5.Reduction in water infiltration into the shallow Operational Site clearing aquifer LOW VERY LOW and Post- • Correct stormwater management principles The removal of the dunes will increase surface flow and (40) (20) closure Excavation decrease the slow infiltration of water into the surface

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Significance Phase Activity Impact Significance Mitigation Measures after mitigation

aquifer. There should be no impact on the Coega Aquifer as the underlying is impermeable. 6.Contamination of groundwater by hydrocarbon • Correct stormwater management principles Excavation spills and builder’s lime • Portable toilets located away from the dunefield (e.g. at the office area), tied Hydrocarbon spills from mining vehicles and the down to prevent them from blowing over, kept clean and emptied regularly (at Loading, generator for the mobile screen plant could contaminate least weekly). Construction • No oil or other chemicals stored on site hauling and and groundwater. No surface water, either wetlands or MEDIUM and • Portable toilets must be supplied at the entrance, the site office and near the VERY LOW transporting rivers, have been identified on site. No diesel, diesel or (64) Operation other hydrocarbons will be stored on site. sand pit (8) • Portable toilets must be serviced regularly by a registered company Builder’s lime and a proprietary chemical, added to the • Suitable emergency spill kit will be available at all times to soak up spills. sand during primary processing are inert and can be • Placement of plastic tarpaulins under breakdown vehicles handled and thus poses no risks. • No fuel will be stored on site 7.Contamination of groundwater by waste and grey •Portable toilets located away from the dunefield (e.g. at the office area), tied down water to prevent them from blowing over, kept clean and emptied regularly (at least Construction Very limited waste water will be produced on site. All MEDIUM weekly). VERY LOW and Ablution vehicles will be maintained off site, and only portable (64) • No oil or other chemicals stored on site (8) Operational chemical ablutions will be provided. Ablutions will be • Portable toilets must be supplied at the entrance, the site office and near the serviced by a reputable company. sand pit HYDROLOGY 8. Contamination of surface water by hydrocarbon Excavation spills and builder’s lime Hydrocarbon spills from mining vehicles and the Loading, generator for the mobile screen plant could contaminate • Correct stormwater management principles Construction hauling and and groundwater. No surface water, either wetlands or VERY LOW • No oil or other chemicals stored on site VERY LOW and transportating rivers, have been identified on site. No diesel, diesel or (24) • Suitable emergency spill kit will be available at all times to soak up spills. (8) Operational other hydrocarbons will be stored on site. • Placement of plastic tarpaulins under breakdown vehicles Builder’s lime and a proprietary chemical, added to the sand during primary processing are inert and can be handled and thus poses no risks. 9.Contamination of urface water by waste and grey • Correct stormwater management principles water • Portable toilets located away from the dunefield (e.g. at the office area), tied Construction down to prevent them from blowing over, kept clean and emptied regularly (at Very limited waste water will be produced on site. All VERY LOW VERY LOW and Ablution least weekly). vehicles will be maintained off site, and only portable (24) (8) Operational • Portable toilets must be supplied at the entrance, the site office and near the chemical ablutions will be provided. Ablutions will be sand pit serviced by a reputable company. • Portable toilets must be serviced regularly by a registered company

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Significance Phase Activity Impact Significance Mitigation Measures after mitigation

BIODIVERSITY • Clearly demarcate mining right area to limit impact on surrounding vegetation 10.Disturbance to and loss of vegetation cover and Site clearing • All identified SSCs and TOPs must be rescued and relocated before site habitat clearance Site preparation will result in the clearing of vegetation • The site must be rehabilitated concurrently with mining using the recommended and the permanent loss of Cape Seashore Vegetation grass seed mix (LT) and Algoa Dune Strandveld (LT). • Prohibit hunting or collecting • Damara Tern must be monitored and its breeding area left undisturbed • Speed Limit 40 km/h Construction • Implement a Waste Management Plan. Domestic and general waste must be MEDIUM LOW and immediately contained in vermin proof containers that must be emptied regularly (60) (30) Operational (at least weekly) and certainly before they are full. Roads • Staff should not be allowed to take their lunches and food to the work areas – they should eat at a central location where refuse facilities are provided and where refuse and waste can be monitored and immediately cleaned up No domestic animals (e.g. feral cats and dogs) are to be tolerated in the mining area. If present they need to be removed to a suitable facility. • Environmental awareness / toolbox talks are required to ensure staff and visitors know how and why they need to correctly manage waste and remain within the site boundaries, etc. 11.Loss of floral Species of Conservation Concern • All identified floral SSCs and TOPs must be rescued and relocated before site Site clearing and their associated habitat clearance 1 SSC and a number of Protected species are found on • The site must be rehabilitated concurrently with mining using the recommended Excavation site, as well as 2 undescribed species. grass seed mix • Prohibit hunting or collecting • Implement a Waste Management Plan. Domestic and general waste must be immediately contained in vermin proof containers that must be emptied regularly Construction, (at least weekly) and certainly before they are full. Operational VERY LOW • Staff should not be allowed to take their lunches and food to the work areas – VERY LOW and Post- (8) they should eat at a central location where refuse facilities are provided and where (3) Closure Roads refuse and waste can be monitored and immediately cleaned up No domestic animals (e.g. feral cats and dogs) are to be tolerated in the mining area. If present they need to be removed to a suitable facility. • Environmental awareness / toolbox talks are required to ensure staff and visitors know how and why they need to correctly manage waste and remain within the site boundaries, etc.

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Significance Phase Activity Impact Significance Mitigation Measures after mitigation

12.Loss of and disturbance to fauna and their •The site must be rehabilitated concurrently with mining using the recommended Site clearing associated habitat, particularly faunal SCCs grass seed mix Clearing of vegetation and removal of sand dunes will • Prohibit hunting or collecting result in the loss of habitat for a number of animal • Implement a Waste Management Plan. Domestic and general waste must be species, specifically breeding Damara Terns (Sternula immediately contained in vermin proof containers that must be emptied regularly Excavation balaenarum), Duthie’s Golden Mole (Chlorotalpa (at least weekly) and certainly before they are full. duthiae) and the pygmy hairy-footed gerbil (Gerbillurus • Staff should not be allowed to take their lunches and food to the work areas – paeba exilis). they should eat at a central location where refuse facilities are provided and where refuse and waste can be monitored and immediately cleaned up No domestic Operational HIGH animals (e.g. feral cats and dogs) are to be tolerated in the mining area. If present MEDIUM and Post- (120) they need to be removed to a suitable facility. (90) Closure • Environmental awareness / toolbox talks are required to ensure staff and visitors know how and why they need to correctly manage waste and remain within the site boundaries, etc. Roads • Damara Tern must be monitored and its breeding area left undisturbed. The identified buffer around the Damara Tern nesting sites (200m north and 300 m east) must not be mined, unless Damara Tern monitoring indicates no individuals are present in the area for three consecutive years

• Speed Limit 40 km/h 13.Direct loss of fauna • Prohibit hunting or collecting Loading, • Speed Limit 40 km/h Mining staff and traffic may result in the direct loss of MEDIUM LOW Operational hauling and  No fauna (especially snakes) should be harmed by mining staff, with an fauna, through traffic accidents, hunting and other (72) (32) transporting associated activities. The site neighbours a Critical experienced animal handler contacted if any fauna are identified for relocation Biodiversity Area (CBA). Site clearing 14.Increased Environmental Risks • Prohibit hunting or collecting • Implement a Waste Management Plan. Domestic and general waste must be Increased number of people in the area will result in the immediately contained in vermin proof containers that must be emptied regularly possible increase in certain risks without proper (at least weekly) and certainly before they are full. Excavating management, for example fires, poaching, illegal plant • Staff should not be allowed to take their lunches and food to the work areas – collecting and harvesting, trampling of vegetation in no- they should eat at a central location where refuse facilities are provided and where go areas, littering. MEDIUM VERY LOW Operational refuse and waste can be monitored and immediately cleaned up No domestic (72) (16) animals (e.g. feral cats and dogs) are to be tolerated in the mining area. If present Loading, they need to be removed to a suitable facility. hauling and • Environmental awareness / toolbox talks are required to ensure staff and visitors transporting know how and why they need to correctly manage waste and remain within the site boundaries, etc. • Damara Tern must be monitored and its breeding area left undisturbed

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Significance Phase Activity Impact Significance Mitigation Measures after mitigation

• Speed Limit 40 km/h • Design an Environmental Awareness Programme that highlights the local environmental sensitivities and risks • Prohibit littering • Clearly designate, using signboards, areas outside of the mining footprint as No- Go areas and prohibit any activities within them • Prohibit the lighting of fires for any reason 15.Impact on ecological processes that facilitate the Site clearing persistence of biodiversity and ecosystem functioning, especially in a sand movement corridor Site clearance and the removal of vegetation will cause the fragmentation of the sand movement corridor that forms part of a contiguous sand corridor stretching from Operational Excavating the Swartkops to Sundays Rivers, and forms part of the MEDIUM • Clearly designate, using signboards, areas outside of the mining footprint as No- MEDIUM and Post- Alexandria Dunefield. This fragmentation will have (72) Go areas and prohibit any activities within them (48) Closure genetic and population level impacts on the biodiversity that inhabits the dunefield. Loading, hauling and transporting Rehabilitation 16.Disturbance of the surface resulting in increased Site clearing risk of AIPs Construction of infrastructure and operation of the mine will result in soil disturbance, greatly increasing the • Produce an Alien Eradication Plan, including dominant alien species, a clearing Operational Excavating schedule and control methods chance of the establishment of alien invasive plants such MEDIUM VERY LOW and Post- • Monitor all areas for alien invasive plants as rooikrans (Acacia cyclops) (72) (8) Closure Loading, • Design an Environmental Awareness Programme that highlights the local hauling and environmental sensitivities and risks transporting Rehabilitation AIR QUALITY Operational Site clearing 17.Increase in dust emissions • Clearance of vegetation and topsoil on calm days

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Significance Phase Activity Impact Significance Mitigation Measures after mitigation

• Clearing will be limited to the mining footprint • Least-water based dust prevention methods should be used on all unpaved roads, stockpiles and material handling areas • Speed limits should be enforced • Implement dust control measures on the haul road. • Prevent sand blowing out of the delivery trucks during transit. • Maintain a complaints register that designates a party and a date to solve the matter Mining will result in the increase of windblown sand in • Speed limits of 40 km/h should be enforced Excavating the area, although the increase may not be significant as • Implementation of a dust monitoring programme to monitor dust impacts the existing dunes are already exposed MEDIUM • Maintain a complaints register that designates a party and a date to solve the LOW (48) matter (32) • The data provider must register on the National Atmospheric Emission Inventory System (NAEIS) within 30 days after commencing of the activity. • Compliance with the dustfall standard as per the National Dust Control Regulations • Should the dust fall standard be exceeded, a dust management plan must be developed and submitted

Loading, hauling and transporting Site clearing 18. Increase in gaseous emissions Gaseous emissions from the excavator, dump trucks and Construction Excavating mobile screen generator will cause air pollution, but MEDIUM • Proper maintenance of all equipment and vehicles according to OEM LOW and those should be relatively negligible. (48) specifications (32) Operational Loading, hauling and transporting NOISE Site clearing 19.Increase in noise • Maintain a complaints register that designates a party and a date to solve the Construction Noise from the excavator, dump trucks and mobile matter MEDIUM VERY LOW and screen generator will cause air pollution, but those • Implementation of a noise monitoring programme to monitor environmental noise (48) (24) Operational Excavating should be relatively negligible. The area is also isolated impacts and the nuisance factor of any noise produced will be • Proper maintenance of all equipment and vehicles according to OEM low.

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Significance Phase Activity Impact Significance Mitigation Measures after mitigation

Loading, specifications hauling and • Only operate machinery during business hours (7 am - 5 pm) transporting VISUAL Site clearing 20. Change in the visual character of the area Although there are a number of abandoned and existing • Clearing will be limited to the mining footprint industrial operations occurring in the surrounding area, it • Speed limits should be enforced largely maintains its natural character, especially as • Clearly designate, using signboards, areas outside of the mining footprint as No- Operational Go areas and prohibit any activities within them Excavating seen from any tourism operators in Algoa Bay. Mining of MEDIUM MEDIUM and Post- • Practice good housekeeping the sand dunes should not materially affect this as very (90) (60) Closure little infrastructure is being established and no • Keep lighting to a minimum permanent pit will be excavated. • Utilize existing roads and if necessary locate new roads in disturbed areas Loading, • Non-water based dust prevention methods should be used on all unpaved roads, hauling and stockpiles and material handling areas transporting HERITAGE Site clearing 21.Loss of Heritage Resources • SAHRA must be informed of all developments in the Coega IDZ • All identified archaeological or palaeontological material must be given to CDC for display, if they desire it • If any palaeontological or archaeological is uncovered during the construction or Operational Heritage and Archaeological artefacts identified in the MEDIUM operation of the sand mine, all work must cease and be reported to ECPHRA, and VERY LOW and Post- area include shell middens, stone tools and houses. (60) a trained person or archaeologist must investigate it (10) Closure Excavation There is a good chance that artefacts may be uncovered • The applicant/ECO/Mine manager must apply for a destruction permit prior to the during the process of mining. commencement of mining activities • Design an Environmental Awareness Programme that highlights the local heritage sites TRAFFIC 22.Increase in Traffic • Appropriate signage must be erected warning other users of the mining activities Truck traffic on the roads within the Coega IDZ, as well • Maintain and repair roads damaged by the mine vehicles Loading, as on the N2, will not greatly increase as the proposed MEDIUM • Ensure that all drivers and their mine vehicles are compliant with the rules of the LOW Operational hauling and sand mine will largely replace an existing neighbouring (72) road (36) transporting mine that will be exhausted in the near future. An • Ensure that vehicle axle loads do not exceed the technical design capacity of the overlapping period where both mines will be operational roads will not greatly increase traffic either, unless demand

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Significance Phase Activity Impact Significance Mitigation Measures after mitigation

increases. Potential conflict during construction phase of  Access control will be moved to where haul road intersects ADZ road, to control Coega ADZ. traffic across this site of potential conflict • Ensure speed limits are adhered to at all times

SOCIO-ECONOMIC Excavation 23.Supply of sand to the construction industry Sand mined is crucial for the supply of building sand for HIGH HIGH Loading, Operational concrete and plaster to the construction industry. The POSITIVE No mitigation measures possible POSITIVE hauling and construction industry has a large multiplier effect on the (96) (96) transporting economy. Excavation 24.Job creation and preservation MEDIUM MEDIUM • Use local employment Operational Loading, The proposed sand mine is essential for the economic POSITIVE POSITIVE • Implement training programmes for employees hauling and sustainability of the mining contractor that currently (72) (72) transporting employs 26 people. CLIMATE CHANGE Site clearing 25.Climate Change Impacts No climate change impacts can be foreseen. Although a large portion of the mining right is below the coastal Excavation setback line, it and should not be impacted by an increase in sea-level. • Minimise the use of fossil fuels Operational Very Low Very Low The use of diesel Internal Combustion Engine Vehicles Investigate the use of vehicles that utilise alternative technology engines, inc (ICEV) to transport sand will result in COs emissions; Loading, however no alternative engine technologies are currently hauling and economically viable. The use of electric vehicles (EVs) transporting will not reduce COs emissions as long as electricity production is dominated by coal. CUMULATIVE Site clearing 26.Cumulative Impacts Operational There has been a cumulative loss of both primary and and Post- secondary coastal dunes and vegetation along the Algoa High Excavation Closure Bay coast, dating back to the establishment of Port Elizabeth, and especially locally since the construction of

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Significance Phase Activity Impact Significance Mitigation Measures after mitigation

the Port of Ngqura. This has impacted sand budgets in the area and the replenishment of beaches. The loss of connectivity between coastal habitats and populations will increase as well. However a coastal strip exists that should preserve beach connectivity. Associated is the loss of breeding habitat for the Damara Tern. Loading, hauling and transporting

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Coega Mining (PTY) LTD j) Summary of specialist reports.

(This summary must be completed if any specialist reports informed the impact assessment and final site layout process and must be in the following tabular form):-

SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION OF RECOMMENDATIONS OF THAT HAVE BEEN LIST OF STUDIES INCLUDED IN THE REPORT WHERE UNDERTAKEN SPECIALIST REPORTS EIA REPORT SPECIALIST RECOMMENDATIONS (Mark with an X HAVE BEEN where applicable) INCLUDED. 1. Design an Environmental Awareness Programme that highlights the local environmental sensitivities and risks. 2. Minimise vegetation clearance for construction and the footprint for the disturbed area as far as possible. 3. Conduct a Search and Rescue for all SCCs and TOPs within the site before the commencement of construction. 4. Avoid all Sideroxylon inerme trees. If they cannot be Botanical avoided, negotiate with DAFF regarding their clearance, and All recommendations Impact included EMPr Assessment apply for permits. 5. Clearly designate, using signboards, areas outside of the mining footprint as No-Go areas and prohibit any activities within them. 6. Ensure no mobile sand transgresses the boundary of the mining permit area and inundates surrounding vegetation. 7. Rehabilitate and revegetate areas as soon as possible using indigenous plant species. 8. Exclude all areas regarded as having high sensitivity.

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SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION OF RECOMMENDATIONS OF THAT HAVE BEEN LIST OF STUDIES INCLUDED IN THE REPORT WHERE UNDERTAKEN SPECIALIST REPORTS EIA REPORT SPECIALIST RECOMMENDATIONS (Mark with an X HAVE BEEN where applicable) INCLUDED. 9. Relevant permits must be applied for to remove all protected species. 10. Topsoil must be correctly stockpiled in designated area and managed for rehabilitation. 11. Produce an Alien Eradication Plan, including dominant alien species, a clearing schedule and control methods. 12. Ensure the mining permit area is monitored for AIPs until mine closure is granted. 13. Mine closure is dependent on the mining permit area being clear of AIPs. 14. Assist in the preservation of the remaining sandy beaches and foredunes of Zone 10 of the Coega SEZ, to preserve the remaining coastal dune habitat..

1. All sand and aggregate extraction operations in the dunefield should move to the northern section of the dunefield, at or adjacent to the Ngqura mine, furthest away Avifaunal from the Damara Tern colony. 2. Granting of the Coega Mining All recommendations Specialist included EMPr Report Right will facilitate the holistic planning of mining operations on the dunefield to minimise impacts (especially on the Damara Tern colony) and maximise benefits (for both the mining company and for future

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SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION OF RECOMMENDATIONS OF THAT HAVE BEEN LIST OF STUDIES INCLUDED IN THE REPORT WHERE UNDERTAKEN SPECIALIST REPORTS EIA REPORT SPECIALIST RECOMMENDATIONS (Mark with an X HAVE BEEN where applicable) INCLUDED. developments in Zone 10 of the Coega SEZ). Mine operations can then be planned to start in the northern section of the dunefield, always keep as far away from the Damara Tern colony as possible, thereby postponing further major impacts on the colony due to mining for probably 15 years.

3. Maintain the 200m no mining buffer north of the current closest Damara Tern nests and 300m east (the latter to allow for future eastward movement of the colony). Review these buffer areas at least every 2 years along with the Environmental Audit / EMPPA using information from the Damara Tern colony annual monitoring that will provide information on the number and location of nest sites.

4. Clearly demarcate the Mine Boundaries and No-Go buffer areas to prevent mining activities and disturbance in No-Go areas. 5. If during the Environmental Audit / EMPPA, no Damara Terns have been recorded at the breeding colony adjacent to the Mining Right for a period of three (3) consecutive years, this indicates that the colony

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SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION OF RECOMMENDATIONS OF THAT HAVE BEEN LIST OF STUDIES INCLUDED IN THE REPORT WHERE UNDERTAKEN SPECIALIST REPORTS EIA REPORT SPECIALIST RECOMMENDATIONS (Mark with an X HAVE BEEN where applicable) INCLUDED. has been abandoned. In these circumstances the 300m buffer to the east and 200m buffer to the north will fall away, allowing mining upto the boundaries of the Mining Right 6. Staff must keep within the areas where there is mining activity. In particular staff should keep away from the vicinity of the Damara Tern breeding colony during the breeding season (early October to late February). Environmental awareness / toolbox talks are required. 7. No machinery that is noisier than what is currently being used during mining operations should be deployed. 8. Coega Mining is responsible for the ongoing monitoring and reporting each year of the Damara Tern colony on the dunefield to determine the numbers of pairs breeding, nest locations and ideally an indication of breeding success. 9. Continued monitoring of the Damara Terns breeding at all of the colonies in Algoa Bay is required to be able to track natural population trends and to determine the medium to long-term effects of developments in the Coega

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SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION OF RECOMMENDATIONS OF THAT HAVE BEEN LIST OF STUDIES INCLUDED IN THE REPORT WHERE UNDERTAKEN SPECIALIST REPORTS EIA REPORT SPECIALIST RECOMMENDATIONS (Mark with an X HAVE BEEN where applicable) INCLUDED. SEZ on the Damara Tern population in Algoa Bay. 10. Off-road vehicles must be prevented from accessing the coastal zone between the Port of Ngqura and old Abalone Farm 11. Implement a Waste Management Plan adhering to the waste hierarchy (reduce, re-use, recycle). Domestic and general waste must be immediately contained in vermin proof containers (e.g. a bin with a well-fitting lid) that must be emptied regularly (at least weekly) and certainly before they are full. This is also a requirement of CDC’s Standard Environmental Specifications – applicable to all tenants in the Coega SEZ. 12. Staff should not be allowed to take their lunches and food to the work areas – they should eat at a central location where refuse facilities are provided and where refuse and waste can be monitored and immediately cleaned up. 13. Toilet facilities are required. If portable toilets are to be used they should be tied down to prevent them from blowing over, kept clean and emptied regularly (at least weekly). 14. Environmental awareness / toolbox talks are required to

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SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION OF RECOMMENDATIONS OF THAT HAVE BEEN LIST OF STUDIES INCLUDED IN THE REPORT WHERE UNDERTAKEN SPECIALIST REPORTS EIA REPORT SPECIALIST RECOMMENDATIONS (Mark with an X HAVE BEEN where applicable) INCLUDED. ensure staff (and visitors) know how and why they need to correctly manage waste 15. A system to estimate the volume of sand replenishing the dune system from the beach would be beneficial. Historical and current records of the volumes of sand mined from the dunefield must be kept 16. No domestic animals (e.g. feral cats and dogs) are to be tolerated in the mining area. If present they need to be removed to a suitable facility. 17. Restrict the removal of vegetation to those areas where mining will take place. 18. If the mined area is not going to be used for development (e.g. aquaculture) within 12 months after each phase of mining is complete, implement an appropriate rehabilitation plan (e.g. replace topsoil, sow a suitable indigenous grass seed mix and plant other suitable indigenous plants). Rehabilitation must be undertaken concurrently with mining. 19. The mining company should be responsible for maintaining the Coega Mining Right area free of alien invasive vegetation for the duration of the Mining Right and for a

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SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION OF RECOMMENDATIONS OF THAT HAVE BEEN LIST OF STUDIES INCLUDED IN THE REPORT WHERE UNDERTAKEN SPECIALIST REPORTS EIA REPORT SPECIALIST RECOMMENDATIONS (Mark with an X HAVE BEEN where applicable) INCLUDED. period of 5 years after mining is completed or until handover of this function to the landowner. 20. Enforce a speed limit of 40 km per hour on the haul road. Truck drivers to receive environmental awareness training. This mitigation measure is the simplest, cheapest and most effective measure that can be employed to control dust but requires enforcement. 21. Implement dust control measures. Spraying with water has short-term results and requires a source of non- potable water (salt water should not be used as it acts as a herbicide on vegetation). Applying chemical binding agents with the water is much more effective and longer lasting. Other methods that have successfully been used in the Coega SEZ include spreading recycled tarmac grit and sealing the road with a bitumen product. 22. Prevent sand blowing out of the trucks by not overloading trucks and covering the load (e.g. with a tarpaulin or shade cloth) or spraying the load with water prior to leaving the mine. 23. No driving at night to prevent collisions with nocturnal bird

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SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION OF RECOMMENDATIONS OF THAT HAVE BEEN LIST OF STUDIES INCLUDED IN THE REPORT WHERE UNDERTAKEN SPECIALIST REPORTS EIA REPORT SPECIALIST RECOMMENDATIONS (Mark with an X HAVE BEEN where applicable) INCLUDED. species (owls and nightjars). Mining should in any case be limited to daylight hours. k) Environmental impact statement

1. Summary of the key findings of the environmental impact assessment;

The Environmental Impact Assessment is Summarised in the Table below:

Impact Significance With Mitigation

MEDIUM NEGATIVE (72) MEDIUM NEGATIVE (72) GEOLOGY AND SOILS

LOW NEGATIVE (40) VERY LOW NEGATIVE (24) HYDROLOGY & GEOHYDROLOGY

HIGH NEGATIVE (120) MEDIUM NEGATIVE (90) BIODIVERSITY

MEDIUM NEGATIVE (48) LOW NEGATIVE (32) AIR QUALITY

MEDIUM NEGATIVE (48) VERY LOW NEGATIVE (24) NOISE

MEDIUM POSITIVE (90) MEDIUM NEGATIVE (60) VISUAL

MEDIUM NEGATIVE (72) LOW NEGATIVE (30) HERITAGE

Impact Significance With Mitigation

MEDIUM NEGATIVE (72) LOW NEGATIVE (36) TRAFFIC

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HIGH POSITIVE (96) HIGH POSITIVE (96) SOCIO-ECONOMIC

LOW NEGATIVE (36) VERY LOW NEGATIVE (24) CLIMATE CHANGE

HIGH NEGATIVE (120) MEDIUM NEGATIVE (90) CUMULATIVE

BEFORE MITIGATION: Majority of impacts are rated as MEDIUM or less; Impacts rated as HIGH are:  Loss of Biodiversity (Damara Tern colony)  Cumulative Impact (relating to Damara Tern Colony)

AFTER MITIGATION: All NEGATIVE environmental impacts can be adequately mitigated and managed jto LOW or VERY LOW, EXCEPT  loss of the geological resource  Loss of Biodiversity  Visual Impact  Cumulative Impact remaining MEDIUM after mitigation.

POSITIVE IMPACTS The majority of MEDIUM environmental impacts after mitigation are POSITIVE socio- economic impacts HIGH

 SUPPLY OF SAND TO CONSTRUCTION INDUSTRY

1. Final Site Map Provide a map at an appropriate scale which superimposes the proposed overall activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers. See Appendix B

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1. Summary of the positive and negative impacts and risks of the proposed activity and identified alternatives; The major positive impacts stemming from the proposed mine will be:  Supply of sand to the local construction industry  Job creation and Skills development  Rehabilitation after mining of a currently environmentally degraded site  Improvement of access control and safety of area

The major negative impacts are:  Loss of current biodiversity  Loss of heritage artefacts  Increased traffic and worsening condition of Victoria Dr

l) Proposed impact management objectives and the impact management outcomes for inclusion in the EMPr;

Based on the assessment and where applicable the recommendations from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation. The aim of the Environmental Management Programme is to manage the positive and negative impacts of the mining activity on the local environment, and on the surrounding community, during the Construction, Operations and Decommissioning phases. This Environmental Management Programme (EMPr) is prepared as part of the requirements of the National Environmental Management Act (NEMA) EIA Regulations published in GNR 983, 984 and 985 on the 4 December 2014 Government Gazette Number 38282. The objectives of the EMPr will be to provide detailed information that will advise the planning design of Driftsands Mining (Pty) Ltd mining activities in order to avoid and/or reduce impacts that may be detrimental to the environment.

The following Impact Management Objectives are recommended for the proposed mining activity: Layout of the mine must limit the environmental impact as much as possible Alien Invasive Plants must be monitored and cleared during all phases of the development, including post-closure Minimise impacts on neighbouring Damara Tern population Limit the impact of dust and sand on the surrounding environment

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Limit noise and air quality impacts Rehabilitate the site to restore the existing sense of place Promote health and safety of workers, as well as skills transfer Avoid to the maximum extent any impact on heritage artefacts and buildings

m) Final proposed alternatives

(Provide an explanation for the final layout of the infrastructure and activities on the overall site as shown on the final site map together with the reasons why they are the final proposed alternatives which respond to the impact management measures, avoidance and mitigation measures identified through the assessment) The mining operational area will move around the mining right area as the various 1 ha areas are mined out. A no-go area or buffer is located in the south-west of the mining right area, to preserve a 300 m buffer around the breeding sub-population of Damara Terns. This buffer may be removed, if monitoring of the Damara Terns population indicates that no breeding has occurred for 3 years. The internal road network will be expanded and rehabilitated concurrently with mining. The access road to the operational mine area will more than likely change, once all service infrastructure, including tar roads, have been installed for the overlapping Coega ADZ. n) Aspects for inclusion as conditions of Authorisation.

Any aspects which must be made conditions of the Environmental Authorisation  Annual population monitoring of Damara Tern population in Zone 10 of Coega SEZ  Maintenance of No-Go area in the south-east of the mining right area  No-Go Area must be enforced until monitoring of Damara Tern population indicates no individuals are present for 3 consecutive years  A revised site layout plan must be submitted to the DMR if any changes occur, including access roads and buffers

o) Description of any assumptions, uncertainties and gaps in knowledge.

(Which relate to the assessment and mitigation measures proposed) A number of assumptions are made in this assessment:  Botanical Impact Assessment included only a single visit to the proposed mining permit site, and therefore may have missed plant species or heritage artefacts.  The success of vegetation rehabilitation, while guided by previous knowledge and experience, and including best practices, cannot be guaranteed to be successful. However monitoring and adaptive management should greatly improve the chances of success.

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 The economic benefits of the sand mine, including job creation, are based on assumptions of previous mines by the applicant. Demand for sand by the construction industry is assumed, but is regarded as a safe assumption.

p) Reasoned opinion as to whether the proposed activity should or should not be authorised

1. Reasons why the activity should be authorized or not. The application for a mining right should be authorized as no fatal flaw was identified in the Environmental Impact Assessment, and all negative impacts should be adequately mitigated. The positive economic benefits, as well as the positive long-term environmental benefits of fynbos rehabilitation and clearing of Alien Invasive Plants outweigh any negative impacts of this activity.

1. ii. Conditions that must be included in the authorisation All conditions to be included in the authorization have been stated in Section A)1)x)i)e) q) Period for which the Environmental Authorisation is required.

Environmental Authorisation is required for the length of a mining right, namely 30 years. r) Undertaking

Confirm that the undertaking required to meet the requirements of this section is provided at the end of the EMPr and is applicable to both the Basic assessment report and the Environmental Management Programme report. The undertaking can be found at the end of the EMPr and is applicable to both the Environmental Impact Report and the Environmental Management Programme report. s) Financial Provision

State the amount that is required to both manage and rehabilitate the environment in respect of rehabilitation.

1. Explain how the aforesaid amount was derived. In case of unforeseen circumstances and premature mine closure, the financial provision for rehabilitation is R169 238.15. These amounts were calculated according to the updated guideline for the Calculation of the Quantum for rehabilitation, as provided by DMR.

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1. Confirm that this amount can be provided for from operating expenditure. (Confirm that the amount, is anticipated to be an operating cost and is provided for as such in the Mining work programme, Financial and Technical Competence Report or Prospecting Work Programme as the case may be).

The mine has made provision in their operational expense for R5000 per month for concurrent rehabilitation. These amounts were calculated according to the updated guideline for the Calculation of the Quantum for rehabilitation as provided by DMR. The mining operation will entail the mining and concurrent rehabilitation on 2 operational areas of 5 hectares. t) Deviations from the approved scoping report and plan of study.

See the undertaking at the end of the document.

Deviations from the methodology used in determining the significance of potential environmental impacts and risks.

((Provide a list of activities in respect of which the approved scoping report was deviated from, the reference in this report identifying where the deviation was made, and a brief description of the extent of the deviation). No deviations from the methodology used in determining the significance of potential environmental impacts and risks

Motivation for the deviation. N/A u) Other Information required by the competent Authority

None.

1. Compliance with the provisions of sections 24(4)(a) and (b) read with section 24 (3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998). the EIA report must include the:- 1. Impact on the socio-economic conditions of any directly affected person. (Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any directly affected person including the landowner, lawful occupier, or, where applicable, potential beneficiaries of any land restitution claim, attach the investigation report as an Appendix . No individuals reside in Zone 10 of the Coega SEZ, and no negative impacts are expected. The socio-economic impact of the proposed mining activities are positive, and include:  Job creation and retention  Skills transfer

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 Supply of sand to the local construction industry, considerably increasing the secondary socio-economic impacts

2. Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act. (Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) with the exception of the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act, attach the investigation report as Appendix 2.19.2 and confirm that the applicable mitigation is reflected in 2.5.3; 2.11.6.and 2.12.herein). A Heritage Impact Assessment was done for the original EIA for the rezoning of the remaining properties for the Coega SEZ. A detailed assessment was done for each zone of the Coega SEZ. The relevant recommendations for Zone 10 of the three reports, were included in this study. v) Other matters required in terms of sections 24(4)(a) and (b) of the Act.

(the EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in sub-regulation 22(2)(h), exist. The EAP must attach such motivation as Appendix 4). No additional matters.

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PART B

DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

Compliance with Section 33 of the EIA Regulations 2014 and Section 24N of the National Environmental Management Act (Act No. 107 of 1998):

1. Draft environmental management programme. a) Details of the EAP,

(Confirm that the requirement for the provision of the details and expertise of the EAP are already included in PART A, section 1(a) herein as required). All relevant details of the EAP are included in Part A section 1(a). b) Description of the Aspects of the Activity

(Confirm that the requirement to describe the aspects of the activity that are covered by the draft environmental management programme is already included in PART A, section (1)(h) herein as required). A full description of activities is described in Part A section 1(h) c) Composite Map

(Provide a map (Attached as an Appendix) at an appropriate scale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that any areas that should be avoided, including buffers) See Appendix B: Site Layout Plan d) Description of Impact management objectives including management statements

Determination of closure objectives.

(ensure that the closure objectives are informed by the type of environment described)

The closure objective for Ngqura Sand mine area must be to rehabilitate the land for future utilisation by the CDC. This has been agreed upon with negotiations with representatives of Coega SEZ, the landowner. The baseline conditions of the site are tall unconsolidated dunes. After mining, the landscape will consist primarily of the underlying unvegetated calcrete. The majority of the mining right area has been designated for future use by the Coega SEZ, and in particular the Coega ADZ. Mining will remove the majority of the unconsolidated dune sand within the mining right area, allowing development to occur on the underlying calcrete

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Coega Mining (PTY) LTD layer. Coega Mining will concurrently rehabilitate the area with a commercially available grass seed mix; this has proven successful in the neighbouring mining operations. Other indigenous plant species will colonise the area naturally, The closure objectives aim to return the site to a natural state to be managed as Open Space for Conservation Purposes. The objectives are: Removal of all infrastructure unwanted by landowner and other anthropogenic impacts Establishment of shallow top soil layer Establishment of plant canopy cover using suitable commercially available grass seed mix Removal of Alien Invasive Plants Preparation of site for future development by Coega SEZ

The process of managing any environmental damage, pollution, pumping and treatment of extraneous water or ecological degradation as a result of undertaking a listed activity. No extraneous water will be produced during the mining of sand.

Potential risk of Acid Mine Drainage

(Include whether or not the mining can result in acid mine drainage). No potential for acid mine drainage occurs.

Steps taken to investigate, assess and evaluate the impact of acid mine drainage. N/A

Engineering or mining design solutions to be implemented to avoid or remedy acid mine drainage. N/A

Measures that will be put into place to remedy any residual or cumulative impact that may result from acid mine drainage. N/A

Volumes and rate of water use required for the operation. No water will be required on site, except for the spraying of roads and topsoil stockpiles.

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Has a water use licence has been applied for? A water use licence has not been applied for as no “water use”, as defined by Section 21 of the National Water Act 36 of 1998, has been identified. Water use will be limited to the primary processing of the mineral, and dust suppression along haul roads, as well as loads on the back of trucks. Reused, desalinated water will be sourced from a nearby operation in Zone 10 of the Coega SEZ.

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Impacts to be mitigated in their respective phases Measures to rehabilitate the environment affected by the undertaking of any listed activity See Table 12. Table 12 Environmental Management Impacts due to Coega Mining.

ACTIVITIES PHASE SIZE AND SCALE of MITIGATION MEASURES COMPLIANCE WITH TIME PERIOD FOR (as listed in 2.11.1) of operation in which activity disturbance (describe how each of the STANDARDS IMPLEMENTATION will take place. (volumes, tonnages and recommendations in (A description of how each Describe the time period State; hectares or m²) herein will remedy the of the recommendations when the measures in the Planning and design, cause of pollution or herein will comply with any environmental Pre-Construction’ degradation and migration prescribed environmental management programme Construction, of pollutants) management standards or must be implemented Operational, practices that have been Measures must be Rehabilitation, identified by Competent implemented when Closure, Post closure. Authorities) required. With regard to Rehabilitation specifically this must take place at the earliest opportunity. With regard to Rehabilitation, therefore state either:-.. Upon cessation of the individual activity or. Upon the cessation of mining, bulk sampling or alluvial diamond prospecting as the case may be. ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S Site clearance 1. Topsoil and overburden removed and Manage soils in and removal of Soil erosion C, O Rehabilitation Plan line with the Soils stockpiled correctly vegetation requirements of the National

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S 2. Vegetation, where present, clearing Norms and Standards for the should occur in in a phased manner in Remediation of accordance with the mining programme to Contaminated Land and Soil minimise erosion and/or run-off. Quality (GN 3. All cleared areas must be re-vegetated 37603 No 331). after mining has been completed.

1. Design an Environmental Awareness C Programme that highlights the local environmental sensitivities and risks 2. Appoint an ECO to monitor and implement EMPr 3. Minimise vegetation clearance for construction and the footprint for the disturbed area as far as possible Environmental Loss of floral and 4. Conduct a Search and Rescue for all floral Continuous Awareness Programme Biodiversity faunal habitat, and loss during and SCCs and TOPs within the site before the of SSCs Operation Rehabilitation Plan commencement of construction 5. Clearly designate, using signboards, areas outside of the mining footprint as No-Go areas and prohibit any activities within them 6. Rehabilitate and revegetate areas as soon as possible using indigenous plant species

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S 7. Mining and rehabilitation should take place sequentially in 5 ha blocks, with never more than 2 blocks of 5 hectares uncovered at any stage. 8. Exclude all areas regarded as having high sensitivity 9. Explore options with the landowner of declaring the mining right area a protected area after mine closure 10. Relevant permits must be applied for to remove all protected species. 11. Topsoil must be correctly stockpiled in designated area and managed for rehabilitation. 12. Population monitoring of the Damara Tern colony in Zone 10, Coega SEZ, must occur annually during the breeding season

1. Produce an Alien Eradication Plan, including dominant alien species, a Continuous clearing schedule and control methods during Rehabilitation and Increased in AIPs Biodiversity 2. Monitor all areas for alien invasive plants Operation and Closure Plan Post-Closure 3. Clearing will be limited to the construction footprint

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S 4. Ensure the mining right area is monitored for AIPs until mine closure is granted 5. Mine closure is dependent on the mining right area being clear of AIPs

1. Clearance of vegetation and topsoil on calm days Dust Generation Air Quality 2. Maintain 50 m buffer between mining and O Rehabilitation Plan neighbouring industrial developments

Loss of agricultural 1. Rehabilitation of soil and vegetation Agriculture O Rehabilitation Plan potential of land 1. Optimise mineral extraction through effective mine planning, which results in Loss of mineral the reduction of geological waste and the Geology O Mine Plan resource minimisation of the footprint of the mining area

Excavation of Alteration of 1. Demarcate mining permit area Topography C Mine Plan mineral resource topography

1. All mining materials including fuels and oil should be stored in demarcated areas that Surface and Geohydrolog are contained within berms / bunds to groundwater O NWA, 36 of 1998 y contamination avoid spread of any contamination. Washing and cleaning of equipment should also be done in berms or bunds, in

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S order to trap any cement and prevent excessive soil erosion. Mechanical plant and bowsers must not be refuelled or serviced within or directly adjacent to any channel. All construction camps, lay down areas, batching plants or areas and any stores should be more than 34m from any demarcated water courses (return effluent canal). 2. Correct stormwater management principles

3. All used hydrocarbons will be taken off site and disposed of at an authorised facility, then the risk of contamination is considered minimal.

4. Adequate portable chemical toilets will be provided at the entrances of the mining area, as well as any operational areas.

5. Portable chemical toilets must be maintained by a registered company

6. Records must be kept of maintenance of portable chemical toilets

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S 1. Mine Schedule implementation should be enforced and monitored, to ensure no impact on Damara Terns 2. Maintain the 200m no mining buffer north of the current closest Damara Tern nests and 300m east (the latter to allow for future eastward movement of the colony). Review these buffer areas at least every 2 years along with the Environmental Audit / EMPPA using information from the Damara Tern colony annual monitoring Loss of Biodiversity and Disturbance to Biodiversity that will provide information on the number Environment and location of nest sites. 3. If during the Environmental Audit / EMPPA, no Damara Terns have been recorded at the breeding colony adjacent to the Mining Right for a period of three (3) consecutive years, this indicates that the colony has been abandoned. In these circumstances the 300m buffer to the east and 200m buffer to the north will fall away, allowing mining upto the boundaries of the Mining Right

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S 4. Staff must keep within the areas where there is mining activity. In particular staff should keep away from the vicinity of the Damara Tern breeding colony during the breeding season (early October to late February). Environmental awareness / toolbox talks are required.

5. No machinery that is noisier than what is currently being used during mining operations should be deployed.

6. Coega Mining is responsible for the ongoing monitoring and reporting each year of the Damara Tern colony on the dunefield to determine the numbers of pairs breeding, nest locations and ideally an indication of breeding success.

7. No driving at night to prevent collisions with nocturnal bird species (owls and nightjars). Mining should in any case be limited to daylight hours.

1. Vegetation clearing should occur in in a During Sense of -Rehabilitation Plan Visual impacts Operation and place phased manner in accordance with the Closure - mining programme

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S 2. A vegetated buffer should be present between any mining operations and public areas, including Victoria Dr and Summerstrand

Compliance with SANS 10103 Acceptable Ambient Levels and SANS 10210 -Sense of Continuous NEM:AQA, 39 of 2004 - Noise pollution of 2004, the place during Section 34: Control of national standard Biodiversity Operation Noise for the calculating and predicting of road traffic noise SANS 10328 of 2008 1. Fallout dust monitoring should be undertaken before mining commences to establish background dust levels, and NEM:AQA, 39 of 2004 - Section 32: Control of continued till rehabilitation after mining is Continuous Dust Dust Generation Air Quality satisfactorily completed. during -Government Notice 827 Operation - National Dust Control 2. 50 m buffer implemented between Regulations mining operations and neighbouring industrial developments 1. Mining company work closely with the author of this report or any other Loss of heritage Heritage Construction building and artefact professional archaeologist of their and Operation choice that once specific mining areas

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S have been identified that the archaeologist conduct a walk-through of the specific area to identify any surface exposed indications of precolonial heritage. 2. A professional archaeologist, familiar with coastal archaeological sites, must be appointed to be on-site and monitor the vegetation clearing and topsoil removal. If required, Phase 2 mitigation in the form of test-pitting/sampling or systematic excavations and collections of the pre-colonial shell middens and associated artefacts will then be conducted to establish the contextual status of the sites and possibly removes the archaeological deposit before mining activities continue. The costs of the phase 2 mitigation will be the on the onus of the developers. 3. If concentrations of pre-colonial archaeological heritage material (such as shell middens and associated material) and/or human remains (including graves and burials) are

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S uncovered during construction, all work must cease immediately and be reported to the Albany Museum (046 622 2312) and/or the Eastern Cape Provincial Heritage Resources Agency (ECPHRA) (043 745 0888) so that systematic and professional investigation/excavation can be undertaken. Phase 2 mitigation in the form of test-pitting/sampling or systematic excavations and collections of the archaeological / heritage site will then be conducted to establish the contextual status of the sites and possibly remove the archaeological deposit before development activities continue. 4. The local historian / representative from Bayworld Museum (Contact person: Mr Lindixinwe Mahlasela, 041 584 0650) should be consulted to assist in identifying any possibly rare or unique historical artefacts that may occur within the area If required to assist with the collection permit, to be determined by

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S the Eastern Cape Provincial Heritage Resources Agency (ECPHRA), a professional archaeologist must be appointed to accompany the historian. 5. A permit for the disturbance of the historical material must be applied for to the Eastern Cape Provincial Heritage Resources Authority (ECPHRA). 6. A person must be trained as a site monitor to report any archaeological sites found during the development. Construction managers/foremen and/or the Environmental Control Officer (ECO) should be informed before construction starts on the possible types of heritage sites and cultural material they may encounter and the procedures to follow when they find sites. 7. All screened materials must be stockpiled and searched through by an appropriated trained person for heritage artefacts.

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S 1. Appropriate signage must be erected Provincial Road standards warning other users of the mining activities 2. Maintain and repair roads damaged by the mine vehicles 3. Ensure that all drivers and their mine vehicles are compliant with the rules of the road Continuous Increased pressure on during Closure Plan Traffic 4. Ensure that vehicle axle loads do not road network Decommissioni Road Maintenance Plan exceed the technical design capacity of ng the roads 5. Access control will be moved to where Transport & haul road intersects ADZ road, to control Hauling traffic across this site of potential conflict 6. Ensure speed limit of 40 km/h are adhered to at all times

1. Implement and maintain a compliant Compliance with SANS 10103 register with a designate responsible Acceptable person to take action and resolve Ambient Levels NEM:AQA, 39 of 2004 - and SANS 10210 -Sense of matters as soon as possible. Noise pollution Continuous Section 34: Control of of 2004, the place during 2. Establish a vehicle speed limit for all Noise national standard Biodiversity Operation OEM Standards for the calculating Plant and Machinery and as far as and predicting of possible maintain roads in a good road traffic noise SANS 10328 of condition. 2008

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S 1. Road surfaces must be well-maintained to minimize dust emissions. NEM:AQA, 39 of 2004 2. Road surfaces must be wetted during -Sense of strong winds; alternately, no traffic Continuous OEM standards Air pollution and Dust place during Generation -Air Quality should be allowed during strong winds. Operation Dust Monitoring Biodiversity 3. Speed limit of 40 km/h enforced Programme 4. Dust Monitoring Programme must be implemented

1. Clearly designate road routes that need to be cleared Continuous Rehabilitation Plan 2. Limit vegetation clearing to proposed road during Site Loss of Biodiversity Biodiversity routes Preparation OEM standards and Operation 3. Good housekeeping 4. Enforce speed limits

1. Suitable emergency spill kit will be available at all times to soak up spills. Surface 2. Placement of plastic tarpaulins under Daily basis Water NWA, 36 of 1998 Geohydrology during contaminatio breakdown vehicles OEM Standards Operation n 3. No fuel will be stored on site

Demolition and 1. Regular clearance and monitoring of AIPs Continuous removal of Establishment and during Biodiversity Rehabilitation Plan infrastructure/eq spread of AIPs Decommissioni uipment ng

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ASPECT MITIGATION MEASURES COMPLIAN PHASE/TI POTENTIAL S STANDARD TO CE WITH ACTIVITY ME IMPACT AFFECT BE ACHIEVED STANDARD PERIOD ED S 1. The rehabilitation plan must be NEM:AQA, 39 of 2004 - concurrently implemented with mining Continuous Section 32: Control of during Dust Dust Generation Air Quality 2. Dust Monitoring Programme must be Decommissioni GN 827 - National Dust implemented ng Control Regulations OEM Standards 1. Regular clearing of AIPs Regular Establishment and Biodiversity intervals during Rehabilitation Plan spread of AIPs Post Closure 1. The rehabilitation plan must be concurrently implemented with mining 2. The grass seed mix used by current mining operations in the area should be Rehabilitation Introduction of and Restoration Biodiversity used for revegetation Post Closure Rehabilitation Plan indigenous species of disturbed 3. An adequate ground cover must be areas established before mine closure is granted

1. A “green” landscape must be re- Sense of place restored Social established Post Closure Rehabilitation Plan

e) Impact Management Outcomes

(A description of impact management outcomes, identifying the standard of impact management required for the aspects contemplated in paragraph ();

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ACTIVITY POTENTIAL IMPACT ASPECTS AFFECTED PHASE MITIGATION TYPE STANDARD TO BE whether listed or not (e.g. dust, noise, drainage In which impact is (modify, remedy, control, ACHIEVED listed. surface disturbance, fly anticipated or stop) (Impact avoided, noise (E.g. Excavations, rock, surface water (e.g. Construction, through levels, dust levels, blasting, stockpiles, contamination, commissioning, (e.g. noise control rehabilitation standards, discard dumps or dams, groundwater operational measures, storm-water end use objectives) etc Loading, hauling and contamination, air Decommissioning, control, dust control, transport, Water supply pollution etc….etc…) closure, post-closure) rehabilitation, design dams and boreholes, measures, blasting accommodation, offices, controls, avoidance, ablution, stores, relocation, alternative workshops, processing activity etc. etc) plant, storm water E.g. control, berms, roads, Modify through pipelines, power lines, alternative method. conveyors, Control through noise etc…etc…etc.). control Control through management and monitoring Remedy through rehabilitation..

Please see Table 12. f) Impact Management Actions

ACTIVITY POTENTIAL PHASE MITIGATION TIME PERIOD FOR COMPLIANCE WITH whether listed or not IMPACT In which impact is TYPE IMPLEMENTATION STANDARDS listed. (e.g. dust, noise, drainage anticipated (modify, remedy, control, Describe the time period (E.g. Excavations, (e.g. Construction, or stop)through (e.g. when the measures in the surface disturbance, fly (A description of how each of the blasting, stockpiles, commissioning, noise control measures, environmental rock, surface water recommendations in 2.11.6 read discard dumps or dams, operational storm-water control, dust management programme contamination, with 2.12 and 2.15.2 herein will Loading, hauling and Decommissioning, control, rehabilitation, must be implemented groundwater comply with any prescribed transport, Water supply closure, post-closure) design measures, Measures must be contamination, air environmental management dams and boreholes, blasting controls, implemented when pollution etc….etc…) standards or practices that have accommodation, offices, avoidance, relocation, required. With regard to been identified by Competent ablution, stores, alternative activity etc. Rehabilitation specifically Authorities) workshops, processing etc) this must take place at plant, storm water E.g. the earliest opportunity. control, berms, roads,

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Coega Mining (PTY) LTD pipelines, power lines, Modify through With regard to conveyors, alternative method. Rehabilitation, therefore etc…etc…etc.). Control through noise state either:-. control Upon cessation of the Control through individual activity management and or. monitoring Upon the cessation of Remedy through mining, bulk sampling or rehabilitation.. alluvial diamond prospecting as the case may be.

Please see Table 12.

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Financial Provision Determination of the amount of Financial Provision. (a) Describe the closure objectives and the extent to which they have been aligned to the baseline environment described under the Regulation. Please see Part B) d)i).

(b) Confirm specifically that the environmental objectives in relation to closure have been consulted with landowner and interested and affected parties. The environmental objectives were included in all documents sent to the landowner NMBM and all I&APs. The closure objectives were discussed in two presentations made to the Coega ELC, a quarterly meeting where all projects within the Coega SEZ are presented to a committee that includes Coega SEZ, Transnet, and all commenting authorities.

(c) Provide a rehabilitation plan that describes and shows the scale and aerial extent of the main mining activities including the anticipated mining area at the time of closure. REHABILITATION PRACTICES Rehabilitation should occur concurrently with mining to fully maximise the chances of success. The following outlines the recommendations for the rehabilitation / restoration of the mined area.  Vegetation restoration / rehabilitation must be overseen by a suitably qualified ECO.  Before sand mining commences a detailed site-plan indicating planned phases of rehabilitation / restoration must be prepared in consultation with the site manager, the person responsible for the implementation of rehabilitation / restoration, and the ECO. Rehabilitation plans must take into consideration the mining schedule and site- plan.  The site-plan should indicate, among other, haul roads, site infrastructure, top-soil stockpile areas, and no-go areas.  Rehabilitation activities should be undertaken in a phased manner in accordance with the above schedule and site-plan.

Topsoil management

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 Before sand mining in a specific phase of the project commences, the top 0.5 m of topsoil must be removed, where available.  Topsoil must be stored separately from overburden, spoil or tailings, in a specifically demarcated portion of the site.  Topsoil must be protected from erosion and degradation by covering with geotextile or plastic sheeting, or covered with vegetation (indigenous grass such as Cynodon dactylon).  Vegetated topsoil stockpiles must be kept free of weeds and invasive exotic vegetation.  Rehabilitation should be undertaken in a phased manner in accordance with a temporal and spatial plan informed by the mining schedule and layout plan.  Topsoil must be used to cover mined areas after excavation and landscaping prior to vegetation restoration / rehabilitation commencing.

Vegetation management The end land use of the site will be for development purposes within the Coega SEZ. Therefore, the natural vegetation will not be restored, but rather an ecologically functional landscape where the established plant cover will provide erosion control. Active rehabilitation with adaptive management is recommended for the restoration of the vegetation at the site. This approach will involve two important facets: 1) Establishment of plant cover 2) Passive establishment of indigenous plant species 3) Control of alien invasive vegetation in intact vegetation at the site as well as in mined areas.

Intact vegetation Little natural vegetation remains on site before mining commences, and will be removed during mining  No firewood, fruit, or flower collection may be permitted in the surrounding sensitive indigenous vegetation on site.  Appropriate signage must be erected to inform personnel and visitors of no-go areas and conduct with respect to indigenous vegetation at the site.  All personnel must be informed of no-go areas and conduct with respect to these areas in the environmental induction for the site.

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Vegetation establishment The natural habitat or ecosystem on site was unvegetated dunefields, of Cape Seashore Vegetation. This included various plant species that could tolerate inundation by sand, as well as bushclumps. This vegetation will not be re-established, rather a secondary grassy shrubland that will facilitate the development of the site.  The seed mix used by the currently operating sand mines in the area should be utilised, due to their observable success at establishing plant cover in the challenging growth conditions  Vegetation establishment should only commence once a mined phase of the site has been shaped to a low undulating morphology (with low-lying areas and dune sand ridges).  The low-lying mined areas must be mulched and seeded with vegetative material from the surrounding vegetation.  Until vegetation cover has been established on the mined areas these portions of the site must be irrigated during windy days, to prevent loss of soil and seeds from the top surface soil layers.  A soil conservation textile layer (such as SoilSaver - woven 100% jute yarn mesh) may be required on sand ridges to stabilise soils until vegetation has become established.  Natural fires at the site must be controlled during this first two years of restoration / rehabilitation.

Control of Alien Invasive Species  The mined areas must be surveyed for emerging exotic plants every three months.  All plants listed as Category 1a, 1b and 2 in the NEMBA Alien Invasive Species Regulations must be controlled / eradicated.  Herbicides must be used conservatively and avoided all together where possible.  Emerging alien invasive plant seedling and samplings (<4cm basal stem diameter) must be removed by hand-pulling or the application of a registered herbicide.  Coppicing (re-sprouting) invasive plants (Acacia saligna) must be destroyed by stump injection and/or foliar application of a registered systemic herbicide.  Alien invasive plant control must be maintained for the duration of rehabilitation, where after the land-owner should be responsible for AIS control in line with the applicable statutory requirement and their Duty of Care in terms of NEMA.

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(d) Explain why it can be confirmed that the rehabilitation plan is compatible with the closure objectives. The rehabilitation plan aims to limit the environmental impact of the mining activity, and rehabilitate the site for future development by the Coega SEZ.

(e) Calculate and state the quantum of the financial provision required to manage and rehabilitate the environment in accordance with the applicable guideline. The quantum of the financial provision is R169 238.15. See Table 12 for the quantum.

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Table 13 Financial provision for rehabilitation at Coega Mining.

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(f) Confirm that the financial provision will be provided as determined. The applicant, Louis du Plooy, representing Coega Mining (Pty) Ltd, confirms that the financial provision will be provided as determined.

Mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon, including g) Monitoring of Impact Management Actions h) Monitoring and reporting frequency i) Responsible persons j) Time period for implementing impact management actions k) Mechanism for monitoring compliance i. Vegetation monitoring The appointed ECO must do regular inspections during the land clearing phase, as well as on a prescribed basis, to ensure no areas outside the proposed mining operational areas are impacted by mining. ii. Damara Tern Population Monitoring An appropriately qualified avifaunal expert must do annual population monitoring of the Damara Tern colony in Zone 10, Coega SEZ. The monitoring must take place during the breeding season, namely October – February. iii. Heritage Monitoring All materials that are removed during the screening process must be stockpiled and search by an appropriately qualified archaeological expert. iv. Noise monitoring

The Appointed Occupational Hygienist measures the noise levels with a calibrated noise level meter. Such readings are then compared to charts indicating acceptable levels of noise. v. Air quality monitoring (Dust fall-out)

The dust buckets measure fall-out dust by placed on a pedestal 2m above the ground. The locations of the dust buckets are discretely selected to measure impacts most probably caused by the dust created by the mining activities not closer than 150m from and not further than 4 km from the mine workings. The dust buckets are located to measure impacts of all 4 wind directions. vi. EA & EMP Performance Assessments The EA & EMPr would be assessed on an bi-annual basis for compliance from the date of issuing of the mining right. The EA & EMPr will be measured against the latest changes in any new legislation that could affect the EA &

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EMPr. The Mitigating measures would be evaluated to establish if they still address the impacts and compared with latest technology of world best practices. Finally, will the actual mine workings and mining practices be evaluated to determine if it does comply with the EA & EMPr. Any shortcomings or non-compliances would be highlighted as an action plan to be rectified.

Table 14 Environmental Monitoring Programme for Coega Mining.

MONITORING AND ROLES AND REPORTING IMPACTS FREQUENCY and FUNCTIONAL RESPONSIBILITIES REQUIRING TIME PERIODS FOR REQUIREMENTS FOR ( FOR THE EXECUTION MONITORING IMPLEMENTING MONITORING OF THE MONITORING PROGRAMMES IMPACT PROGRAMMES ) MANAGEMENT ACTIONS SOURCE ACTIVITY: MINING; ROADS AND TRANSPORT ECO: implementation of EMPr Monitoring must take place on a weekly basis Monitoring of site Mine manager: monitoring by the ECO when site clearance, mining of mitigation activities, Vegetation clearance is occurring. boundaries, nursery, ensuring all findings are Monthly inspections can rehabilitation rectified occur during operation Mine Owner: responsible for phase. compliance with EMPr Monitoring to be Mandatory Occupational Appointed specialist: undertaken monthly, Noise Monitoring Hygiene Noise Level conduct ambient noise followed by biannually monitoring monitoring after 12 months The dust fall-out results Fall-out Dust Buckets would be analysed at an Air Quality Monitoring installed at strategic Quarterly accredited laboratory locations against SANS 1929: 2005 Inspections must take Heritage Specialist: place during site inspections during site clearance Heritage Site inspections clearance Any findings must be ECO: Inspections during reported to ECPHRA operation phase within a week Specialist to undertake monitoring Monitoring of population ECO files all reports and Annual population of Damara Terns in Zone Avifauna (Damara ensures monitoring occurs monitoring to occur 10 of Coega SEZ during Tern) during breeding season breeding season Mine Manager ensures of Damara Terns. (October-February) recommendations of report implemented, buffers maintained

Evaluation of suitability ECO: conducts EMPPA/ EMPPA/Environmental EA & EMP of EMPr and EA to latest Environmental Audit Audit takes place after Performance changes in legislation. Mine Manager: the first year, and then Assessments Evaluation of mitigating Responsible for corrective on a biannual basis measures to latest actions

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technology and world’s Mine Owner: Ensures all All corrective measures best practices. corrective actions take must take place in the Evaluation of mine place time period specified by workings and mining the EMPPA report activities to the EA & EMPr. l) Indicate the frequency of the submission of the performance assessment/ environmental audit report.

The performance assessment/environmental audit report will be conducted after the first year, and then on a biannual basis. m) Environmental Awareness Plan

(1) Manner in which the applicant intends to inform his or her employee of any environmental risk which may result from their work. The Management of Coega Mining undertakes to make every person entering its mine workings aware of the potential environmental impacts associated with their roles and how they can be mitigated through the implementation of the correct management procedures. This training should reduce the potential of occurrence of environmental negative incidents. Mine Manager: responsible for ensuring that the environmental awareness training is implemented to all employees and sub-contractors on the site. Environmental awareness training needs should be identified before the project commences, based on the available and existing capacity of site and project personnel (including the applicant and Contractors) to undertake the required EMPr management actions and monitoring activities. It is vital that all personnel are adequately trained to perform their designated tasks to an acceptable standard. In addition to these parties, general environmental awareness must be fostered among the general workforce to encourage the implementation of environmentally sound practices. This ensures that environmental accidents are minimized and environmental compliance maximized. Environmental awareness could be fostered by induction course for all workers on site, before commencing work on site, as well as during regular “toolbox talks”. Workers should also be alerted to particular environmental concerns associated with their tasks for the area/habitat in which they are working. Courses must be given by suitably qualified personnel and in a language and medium understood by workers/employees. Posters of relevant environmental impacts, including SCCs, heritage impacts and safe practices allowed on site should be erected at the security hut.

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ECO: Is responsible to ensure the Environmental Awareness Plan is adequate and covers all the relevant environmental impacts and risks. The ECO should keep a record of attendance of all employees of attendance of the various sessions. The ECO must ensure that awareness talks take place on a regular basis.

(2) Manner in which risks will be dealt with in order to avoid pollution or the degradation of the environment. In order to mitigate or avoid the negative impacts on the environment caused by any activities undertaken by the proposed sand mine, all mitigation measures included in this EMPr must be implemented. The Environmental Monitoring Programme must be implemented as well. Measures included to ensure compliance with the EMPr include:  Appointment of an ECO  Implementation of Environmental Awareness Programme  Enforcement of EMPr  Complaints register to record any complaints relating to noise, dust, vegetation clearing  Proper waste management, including the supply of adequate bins on site  Implementation of proper housekeeping

Risks will be dealt with by educating employees about possible negative environmental impacts on site, maintaining all equipment and transport vehicles to Original Equipment Manufacturers (OEM) requirements, and providing Spill kits for any oil spills. Contact numbers for relevant experts in the dangerous fauna and heritage fields will always be accessible, as well as the numbers of all local security. n) Specific information required by the Competent Authority

(Among others, confirm that the financial provision will be reviewed annually). All monitoring results will form as an addendum to the annual EA & EMPr performance assessment report. The financial provision will be reviewed annually indicating work that would have been completed and the money used for rehabilitation.

2) UNDERTAKING

The EAP herewith confirms a) the correctness of the information provided in the reports X b) the inclusion of comments and inputs from stakeholders and I&APs ; X

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c) the inclusion of inputs and recommendations from the specialist reports where relevant; X and d) that the information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested and affected. parties are correctly reflected herein. X

Signature of the environmental assessment practitioner:

Algoa Consulting Mining Engineers Name of company:

Date: 22 January 2020

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References

Almond, J. (2010) Palaeontological Heritage Impact Assessment of the Coega IDZ, Eastern Cape Province. Natura Viva cc Report. SAHRIS NID labels: 8875 and 109216.

Animal Demography Unit (2017a). MammalMAP Virtual Museum. Accessed at http://vmus.adu.org.za/?vm=MammalMAP on 2017-06-26

Animal Demography Unit (2017b). ReptileMAP Virtual Museum. Accessed at http://vmus.adu.org.za/?vm=ReptileMAP on 2017-06-26

Animal Demography Unit (2017c). FrogMAP Virtual Museum. Accessed at http://vmus.adu.org.za/?vm=FrogMAP on 2017-06-26

Animal Demography Unit (2017d). LepiMAP Virtual Museum. Accessed at http://vmus.adu.org.za/?vm=LepiMAP on 2017-06-26

Bennie, J. (2010) Historical Assessment (Historical components relating to the built environment and graves). Port Elizabeth Museum Report. HIA. SAHRIS NID label: 132671.

Binneman, J. (2010) A Phase I Archaeological Impact Assessment of the Coega IDZ, near Port Elizabeth, Nelson Mandela Bay Municipality, Eastern Cape. Eastern Cape Heritage Consultants Report. AIA. SAHRIS NID label: 6430.

Branch, W.R. & A.A. Turner (2014) Bitis albanica. In Bates, M.F., Branch, W.R., Bauer, A.M., Burger, M., Marais, J., Alexander G.J. & de Villiers M.S. (eds) Atlas and Red List of the Reptiles of South Africa, Lesotho and Swaziland. Suricata 1. SANBI, Pretoria

CES (2001) Subsequent Environmental Impact Report for the proposed Port of Ngqura, for Coega Development Corporation.

DEDEAT (2007) Eastern Cape Biodiversity Conservation Plan Handbook (compiled by Berliner, D., Desmet, P. and R. Hayes).

Ethical Exchange (2017) Coega Land-Based Aquaculture Development Zone: Final Environmental Impact Report. Report No: X0118/CDC ADZ EIA/01/FEIR/01| March 2017 (Revision 01)

Illenberger & Associates (2018) Ngqura Sand Mining Permit Application, Coega IDZ: Dune Geomorphology Specialist Report.

LAQS (2016) Cumulative Air Quality Impact Assessment of Air Pollutant Emissions on Coega Aquaculture Development Zone. AQIA. Contract No. CDC/687/14

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Marnewick MD, Retief EF, Theron NT, Wright DR, Anderson TA. 2015. Important Bird and Biodiversity Areas of South Africa. Johannesburg: Birdlife South Africa.

Minter LR, Burger M, Harrison JA, Braack HH, Bishop PJ & Kloepfer D (eds). 2004. Atlas and Red Data book of the frogs of South Africa, Lesotho and Swaziland. SI/MAB Series no. 9. Smithsonian Institution, Washington, D.C.

Mecenero, S., J.B. Ball, D.A. Edge, M.L. Hamer, G.A. Hening, M. Krüger, E.L. Pringle, R.F. Terblanche & M.C. Williams (eds). 2013. Conservation assessment of butterflies of South Africa, Lesotho and Swaziland: Red List and atlas. Saftronics (Pty) Ltd., Johannesburg and Animal Demography Unit, Cape Town.

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

SAHRA (2011) Amended Review Comment on Archaeological, Palaeontological and Historical (Burials) Impact Assessments.

South African National Biodiversity Institute (2006-2018). The Vegetation Map of South Africa, Lesotho and Swaziland, Mucina, L., Rutherford, M.C. and Powrie, L.W. (Editors), Online, http://bgis.sanbi.org/Projects/Detail/186, Version 2018.

SRK (2006) Final Revised Scoping Report. Proposed change in land use of the remaining area within the Coega Industrial Development Zone.

StatsSA (2011) Census 2011. Accessed at http://www.statssa.gov.za/?page_id=1021&id=nelson-mandela-bay-municipality

Taylor MR, Peacock F, Wanless RW (eds) 2015. The Eskom Red Data Book of Birds of South Africa, Lesotho and Swaziland. Johannesburg: Birdlife South Africa.

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Appendix

Appendix A Details of EAP

Appendix B Site Layout Plan

Appendix C Evidence of Public Participation

Appendix D Specialist Reports and Biodiversity Assessment

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Appendix A CV of EAP

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Appendix B Site Layout Plan

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Appendix C

Appendix C1 Newspaper Advert C2 Site Poster C3 Background Information Document C4 Register of Interested & Affected Parties C5 Minutes of Meetings C6 Correspondence various I&APs

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Appendix C1 Newspaper advert

The Herald 27 May 2019

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Appendix C2 Site Notice

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Appendix C3 Background Information Document

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Appendix C4 Register of Interested and Affected Parties

Interested & Affected Party Tel. no. Alt no. Fax E-mail address Address

List the names of persons consulted in this column, and Mark with an X where those who must be consulted were in fact consulted.

AFFECTED PARTIES Landowner CDC: Graham Taylor x 041 403 0400 083 228 3055 [email protected] CDC: Andrea Shirley x 041 403 0400 082 657 4648 [email protected] CDC ECO: Habitat Link: Christelle du Plessis x 074 158 5583 [email protected] Lawful occupier/s of the land

PPC: Johan Coetzee x [email protected]

PPC: Robin.Daniels x [email protected] [email protected]

Mandela Bay Sand & Stone: Desmond Eales x a

Dove Mining Services: Gavin Eales x [email protected] [email protected]

Sunshine Quarries: Desmond Eales x a

Kate Crews x 041 360 9682 082 560 0113 [email protected] See Coega SEZ Tenant List x Landowners or lawful occupiers on adjacent properties See Coega SEZ Tenant List x

Municipal councillor [email protected] 17 Kalushe Street,

Ward 53: Ms. Nomazulu Mthi x 073 430 5967 m Motherwell, PE, 6221 Municipaliy: NMBM [email protected].

Municipal Manager: Johann Mettler x za

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Interested & Affected Party Tel. no. Alt no. Fax E-mail address Address [email protected].

NMBM: Environmental Management: Godfrey Murrel x za [email protected]

NMBM: Environmental Management: George Branford x 082 522 0298 ov.za [email protected] NMBM: Director Strategic Planning: Schalk Potgieter

x .za [email protected]

NMBM: Public Health: Air Pollution/Noise Control: Kobus Slabbert x 041 506 5210 079 4900 358 v.za

Organs of state (Responsible for infrastructure that may be affected Roads Department, Eskom, Telkom, DWA)

Other Affected Parties ECPRHA: Sello Mokhanya x 072 017 0072 [email protected]

ECPTA: Shane October x [email protected]

DMR:Health & Safety: Terence Doyle x [email protected] [email protected] thembani.nyokana@dr

DRDAR: District Director: Thembani Nyokana x 083 265 3115 v.za dar.gov.za [email protected]

DEDEAT: Dayalan Govender x v.za

DWS: Marisa Bloem x 041 501 0717 [email protected]

DRPW: Peter Lotter x 041 403 6034 083 397 6792 [email protected]

DAFF: Thabo Nokoyo x 083 654 1177 [email protected] Interested Parties See Coega ELC List x

CEN: Belinda Clark x 0727256400 [email protected]

Birdlife EC: Secretary: Anne Widdows x 082 599 2102 [email protected] [email protected]

SANParks: Cloverley Lawrence x c.za

East London Museum: Phil Wittington x 043 743 0686 [email protected]

Dr Paul Martin x 073 252 4111 [email protected]

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COEGA ELC COMMITTEE Titl First Last Organisatio Physical Postal Cod Telephon Capacity Town email Fax e Name Name n Address Address e e Collegiate House, Cnr of 041- Regional Belmont Terrace Pvt Bag Greenacre 041-

Mr Dayalan Govender DEDEAT 6057 [email protected] 508586 Manager & Castle Hill, X5001 s 5085811 5 opposite the Law Courts in Central Collegiate House, Cnr of 041- Asst. Belmont Terrace Pvt Bag Greenacre 041-

Mr Andries Struwig DEDEAT 6057 [email protected] 508586 Director: IEM & Castle Hill, X5001 s 5085840 5 opposite the Law Courts in Central Provincial Air 043-

Mr Lyndon Mardon Quality DEDEAT Bisho [email protected] 6057128 Officer Coastal East Pier Baijnath- Pollution DEA: Ocean Building, East Cape 021-

Mrs Nitasha PO Box 52126 8002 [email protected] Pillay Management & Coast Pier Road, V&A Town 8192409 Division Waterfront Coastal East Pier Pollution DEA: Ocean Building, East Cape 021-

Mr Reuben Molale PO Box 52126 8002 [email protected] Management & Coast Pier Road, V&A Town 8192493 Division Waterfront Deputy Fedsure Forum Director: 012- Building, 315 086-

Mr Wayne Hector Strategic DEA Pvt Bag X447 Pretoria 0001 [email protected] 320753 Pretorius Street, 1112468 Infrastructure 9 PTA Development Fedsure Forum Environmenta 012- Building, 315 012-

Mrs Pumeza Skepe l Impact DEA Pvt Bag X447 Pretoria 0001 [email protected] 320753 Pretorius Street, 3999374 Management 9 PTA Coega Business Environmenta Centre, Cnr 041- Pvt Bag Port 041-

Mrs Andrea Shirley l Project CDC Alcyon & 6000 [email protected] 403040 X6009 Elizabeth 4030400 Manager Zibuko Str, 1 Coega IDZ

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Coega Business Spatial Centre, Cnr 041- Pvt Bag Port 041-

Mr Graham Taylor Development CDC Alcyon & 6000 [email protected] 403040 X6009 Elizabeth 4030400 Manager Zibuko Str, 1 Coega IDZ Port Admin Environmenta Building, PO Box Bluewater 041- Ms Renee de Klerk TCP 6212 [email protected] l Manager Neptune Road, 612054 Bay 5078657 Port of Ngqura Port Admin Building, PO Box Bluewater 041-

Mr Mpatisi Pantsi SHE Manager TNPA 6212 [email protected] Neptune Road, 612054 Bay 5078449 Port of Ngqura Port Admin 041- Mandilakh Environmenta Building, PO Box Bluewater [email protected] 041- Mr Mdodana TNPA 6212 507823

e l Manager Neptune Road, 612054 Bay t 5078448 2 Port of Ngqura 13th Floor, 041- Environmenta Brister House, Port 041-

Mr Godfrey Murrel NMBM PO Box 11 6000 [email protected] 505449 l Manager Govan Mbeki Elizabeth 5065464 1 Ave, PE 13th Floor, [email protected]; 041- Environmenta Brister House, Port 041- Ms Rosa Blaauw NMBM PO Box 11 6000 [email protected] 505449 l Manager Govan Mbeki Elizabeth 5065206

(cc) 1 Ave, PE NMBM: Air 13th Floor, [email protected]; Air Pollution 041- Pollution & Brister House, Port [email protected]; 041-506 Mr Patrick Nodwele & Noise PO Box 11 6000 585726 Noise Govan Mbeki Elizabeth [email protected]. 5216 Control 1 Control Ave, PE za 11th Floor Starport 041- Water Quality Pvt Bag Port 041-

Ms Thandi Mmachaka DWS Building, 140 6000 [email protected] 586421 Management X6041 Elizabeth 5010704 Govan Mbeki 0 Ave 11th Floor Starport 041- Water Quality Pvt Bag Port 083-

Ms Ncumisa Mnotoza DWS Building, 140 6000 [email protected] 586421 Management X6041 Elizabeth 9533057 Govan Mbeki 0 Ave 086- ASD: Mineral Pier 14, 3rd Pvt Bag Port 041-

Mr Vusi Kubheka DMR 6000 [email protected] 459165 Regulation Floor, 444 X6076 Elizabeth 4036600 3

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Govan Mbeki Ave, PE Executive 146 Lunnon 012-366

Ms Bongi Stofile Manager: SAMSA Road, Hillcrest, [email protected] 2600 Operations 0183

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COEGA SEZ TENANTS COEGA IDZ

ZONE 1: Logistics Cluster 11. DSV 59 Amatye Road EXT

Zone 1 NAME & SURNAME DESIGNATION NO CELL EMAIL Coega IDZ 041 517 BRANCH DANIE GERBER MANAGER 1182 [email protected] 041 517

LORNA PRINCE PA TO DANIE 1182 [email protected] 041 517 PRUNELLA

MGCOKOCA RECEPTIONIST 1182 [email protected]

12. DIGISTICS Suez Road EXT

Coega IDZ NAME & SURNAME DESIGNATION NO CELL EMAIL Zone 1 041 405

Port Elizabeth BRETT WILLIAMS DC MANAGER 0300 [email protected] 041 405 078 893

JACKSON TUTU MANAGER 0300 9690 [email protected] 011 663

KEN SCOTT DIRECTOR 3417 [email protected] RECEPTIONIST AND FINANCE 041 405

TANYA BEKKER ADMINISTRATOR 0300 [email protected]

13. FAMOUS BRANDS 13 Intsimbi Road EXT Zone 3 NAME & SURNAME DESIGNATION NO CELL EMAIL Coega IDZ GUTHRIE MANAGING 041 492 072 592

Port Elizabeth ROBERTSON EXECUTIVE 0220 6299 [email protected] OPERATIONS 041 492 060 988

ARNOLD BARNARD MANAGER 0203 4114 [email protected] REC& LOG 041 492 082 333

GLORIA JANUARY ADMINISTRATOR 0222 2069 [email protected] 041 461

LEISLE ROSS RECEPTIONIST 1366 [email protected]

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14. GMSA 62 Umlambo Street EXT Zone 1 NAME & SURNAME DESIGNATION NO CELL EMAIL Coega IDZ PDC WAREHOUSE 041 407

Port Elizabeth BETH HURR MANAGER 0200 [email protected] 041 407

HEIDI HARMSE PA 0212 [email protected] FINANCIAL CO- 041 407

HAYDIN HANNIE ORDINATOR 0248 [email protected] 011 806

BRIAN LEE OLSON VICE PRESIDENT 4718 [email protected] LLEWELLYN VAN GENERAL 041 407

ANTWERPEN MANAGER 0213 [email protected]

15. PE COLD STORAGE Corner of Bridgewater EXT

Street and Alcyon Road NAME & SURNAME DESIGNATION NO CELL EMAIL Zone 1 GENERAL 041 405 082 800

Coega IDZ CRAIG VAUGHAN MANAGER 0800 8878 [email protected] Port Elizabeth GEORGE 041 581 082 771

EFSTRAPIOU CEO 0907 9351 [email protected] FINANCIAL 041 405

ABRAHAM MARAIS MANAGER 0800 [email protected]

16. APM TERMINALS 129 Amatye Street EXT Coega IDZ NAME & SURNAME DESIGNATION NO CELL EMAIL Zone 1 041 486 083 794

Port Elizabeth PIETER ALLERS 3021 0262 [email protected] MONIQUE FINANCE AND 041 816

OOSTHUIZEN ADMIN CLARK 3609 [email protected] MARINUS 083 799

SCHOEMAN EMI MANAGER 6644 [email protected]

17. VECTOR LOGISTICS Amatye Road, NAME & SURNAME DESIGNATION EXT CELL EMAIL Coega IDZ Zone1, 082 326 Port Elizabeth JURIE SCHOEMAN 0816 ADMINISTRATION 041 402 082 325

SONIA GUNN MANAGER 1502 5416 [email protected]

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RUDO OPERATIONS 041 402 STOLTENKAMP MANAGER 1500 REGIONAL 041 402 084 506

INA BOTHA MANAGER 1501 0642 [email protected]

18. ID LOGISTICS Portion of Erf NAME & SURNAME DESIGNATION EXT CELL EMAIL 233,Coega IDZ ALLISTAIR 041 101 072 903

Zone 1,South STALLENBERG DC MANAGER 0915 8270 [email protected] Corner of Amatye ADMINISTRATION 041 101 [email protected] and Ocean View COOLLEN GRIFFITH MANAGER 0928 South Africa

19. NATIONAL SHIP CHANDLERS 29 Kiel Street Coega IDZ NAME & SURNAME DESIGNATION EXT CELL EMAIL GEORGE 041 484 Zone 1 Port Elizabeth CHARALAMBOUS 7633 [email protected] BUSINESS DEVELOPMENT 031 205 082 802 South Africa ADRO STYLIANOU MANAGER 4221 9108 [email protected]

ZONE 2: Automotive Cluster

20. ZACPACK/CFR Zacpak 87 Nurburgring ROAD NAME & SURNAME DESIGNATION EXT CELL EMAIL 041 405 083 790

Zone 2 Coega IDZ RIAZ ISMAIL DEPOT MANAGER 0600 8174 [email protected] Port ELIZABETH 6100 21. FAW 30 Nurburgring Street EXT Coega IDZ NAME & SURNAME DESIGNATION NO CELL EMAIL Zone 2 DEPUTY 087 700 +86 188 Port Elizabeth LIU SHIJIE DIRECTOR 8006 639 00115 [email protected] 087 702 074 663

HAIYANG YAO ADMIN MANAGER 0558 8388 [email protected]

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ASSISTANT TO CEO AND PLANT 087 700

NADINE FORLEE MANAGER 2949 [email protected] 087 700

ASHLEY MAIN HR GENERALIST 2949 [email protected] 087 700 RECEPTION RECEPTION 2963

ZONE 3: General Industries Cluster

22. DYNAMIC COMMODITIES 13 Intsimbi Road EXT Zone 3 NAME & SURNAME DESIGNATION NO CELL EMAIL Coega IDZ 041 405 082 873

Port Elizabeth ADRIAN VARDY CEO 9888 2214 [email protected] 041 405 082 495

MARC LATER DIRECTOR 9888 7796 [email protected] 041 405 078 035

TILLA DU MONT PA 9888 8884 [email protected] OPERATIONS 041 405 082 040

MURRAY PRINCE MANAGER 9888 1903 [email protected] VINCENT HUMAN 041 405 REDDERING RESOURCES 9888

23. COEGA DAIRY 142 Cable Road EXT Zone 3 NAME & SURNAME DESIGNATION NO CELL EMAIL Coega IDZ 041 405 082 372

VICTOR KORSTEN CEO 0000 7718 [email protected] JOHANN OPERATIONS 041 405 072 114

SCHLEBUSCH MANAGER 0000 3713 [email protected] HUMAN 041 405

YOLISWA MORRIS RESOURCES 0034 [email protected] FINANCIAL 041 405

CECILE KLEYN EXECUTIVE 0000 [email protected] MAINTENANCE 041 405

PIERRE RAUCH MANAGER 0008 [email protected] 041 405

THULISA MLMBISA RECEPTIONIST 0000 [email protected]

24. COEGA CONCENTRATE 35 Intsimbi Road EXT

Zone 3 NAME & SURNAME DESIGNATION NO CELL EMAIL

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Coega IDZ SPECIAL Port Elizabeth PROJECT 081 730

MARK HARRIS EXECUTIVE 4913 [email protected]

25. AIR PRODUCTS SA (PTY) LTD Bumba Road EXT Zone 3 NAME & SURNAME DESIGNATION NO CELL EMAIL Coega Development PLANT Corporation SUPERVISOR- Coega IDZ COEGA ASU 016 986

Port Elizabeth VINCENT NTULI PLANT 8527 [email protected] SENIOR 016 986 082 774

ROBERT DUPISANI ENGINEER 8531 6874 [email protected] MARKETING 011 977

LAURYN KEEL ASSISTANT 6414 [email protected] MANAGING 011 570

MIKE HELLYAR DIRECTOR 5048 [email protected] FINANCIAL 011 570

KEITH FOSTER DIRECTOR 5102 [email protected] NATIONAL SALES 011 977

SACHIN KULKARNI MANAGER - BULK 6430 [email protected] AREA SALES 041 402 082 783

PIERRE FOURIE MANAGER 9920 2456 [email protected]

26. DCD WIND TOWERS Cable Road Zone 3 EXT Coega IDZ NAME & SURNAME DESIGNATION NO CELL EMAIL FINANCIAL 041 405 083 493

ALTA-MARIE GREBE MANAGER 0206 5832 [email protected] HUMAN NATASHA VAN DE RESOURCES 041 405 WALT MANAGER 0203 MARKETING 078 914 HENK SCHOEMAN MANAGER 2709 [email protected] 083 231

DERK ELF DIRECTOR 5650 [email protected]

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27. AFROX 197 Hamile Afrox Road Coega IDZ Zone 3 Port Elizabeth NAME & SURNAME DESIGNATION EXT CELL EMAIL South Africa PROJECT MANAGER- SATISH PROJECT 011 456 082 573

BHUGWATHYPERSAD EXECUTION 3794 1492 [email protected] 6210 THOMAS 073 697

WINDELBAND ENGINEER 5186 [email protected] GENERAL AND REGIONAL 011 456 082 493

RENE NAIDU MANAGER 3794 4159 [email protected] 082 446

WILLIAM DAVY CIVIL WORKS 7656 [email protected] 041 405 084 200

VAL MILLEN RECEPTIONIST 4212 0751 [email protected] 079 521 JEFFREY METH PLANT MANAGER 7411 [email protected] SENIOR ACCOUNT 041 405 076 791

PIENAAR ALLERS MANAGER 4218 1984 [email protected] 041 405 071 453

WONDER MAZENGE PLANT ENGINEER 9644 8503 [email protected]

28. HIMOIN SA A6 Multi User Facility, NAME & SURNAME DESIGNATION EXT CELL EMAIL Zone 3 MANAGING 081 485 Coega IDZ - Port MARTIN FOSTER DIRECTOR 5679 [email protected] Elizabeth, 6100 South Africa

29. ENEL GREEN POWER A6 Multi User Facility, NAME & SURNAME DESIGNTATION EXT CELL EMAIL Zone 3 010 344 Coega IDZ - Port Mapokgole Johannes 0200 ([email protected]) Elizabeth, 6100 South Africa 30. CORROMASTER 89 Zone 3, Cnr. Bumba and Anvil NAME & SURNAME DESIGNATION EXT CELL EMAIL

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Streets, Coega 041 405 084 300

TARRYN SHINN ADMIN MANAGER 0140 8579 [email protected] PORT ELIZABETH 041 405 082 887

SOUTH AFRICA 6000 HERBERT BALL 0140 3635 [email protected]

31. AMBASAAM A6 Multi User Facility, NAME & SURNAME DESIGNATION EXT CELL EMAIL Zone 3 083 262 Coega IDZ - Port PHILIP MORKEL 7226 [email protected] Elizabeth, 6100 CHIEF South Africa OPERATIONS 041 405 082 857

DANIE VOIGT OFFICER 0131 2962 [email protected]

32. FINECORP TRADING A6 Multi User Facility, NAME & SURNAME DESIGNATION EXT CELL EMAIL Zone 3 STANLEY 084 968 Coega IDZ - Port POTGIETER 0164 [email protected] Elizabeth, 6100 South Africa 33. CEREBOS (MULTI-USER) A6 Multi User Facility, NAME & SURNAME DESIGNATION EXT CELL EMAIL Zone 3 MANAGING 041 403 082 654 Coega IDZ - Port JOHN DRINKWATER DIRECTOR 6700 9507 [email protected] Elizabeth, 6100 South Africa 34. Ocean Legacy Marine Engineering (OLME) A6 Multi User Facility, NAME & SURNAME DESIGNATION EXT CELL EMAIL Zone 3 041 586 083 413 Coega IDZ - Port CHARLES LUMSDEN MANAGEMENT 1400 4002 [email protected] Elizabeth, 6100 South Africa ZONE 4: Training & Academic

Cluster 35. DISCOVERY HEALTH BPO Building, Corner EXT of Zibuko Street and NAME & SURNAME DESIGNATION NO CELL EMAIL

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Laleyon Road FACILITIES 041 409 062 295 Zone 4 ELLIAN PETERSON MANAGER 7300 2167 Coega IDZ SERVICE 041 409

HENNIE VAN STADEN EXECUTIVE 7132 [email protected] OPERATIONS 041 409

LLEWELLYN DRIVER EXECUTIVE 7135 [email protected] 041 409

MICHELLE JOUBERT PA 7141 [email protected] OPERATIONS - TAMLYNN ANNE REGIONAL TEAM 041 409 082 797

FERREIRA LEADER 7143 6146 [email protected] DAVID PIERRE- 011 529 082 606

EUGENE DIRECTOR 2231 1335 [email protected] NATASHA JANSEN 011 529

VAN RENSBURG DAVID'S PA 2420 [email protected]

36. WNS BPO Building, Corner NAME & SURNAME DESIGNATION EXT CELL EMAIL of Zibuko Street and FACILITIES 021 819 Laleyon Road CLARESSITA RAMOO MANAGER 6455 0793830423 [email protected] Zone 4 GENERAL Coega IDZ BRIAN WINDSOR MANAGER 0741220665 [email protected]

ZONE 5: Metalurgical Cluster

37. BOSUN BRICK Corner Neptune Drive EXT

and MR 435 NAME & SURNAME DESIGNATION NO CELL EMAIL Coega IDZ GENERAL 041 405

Port Elizabeth NICK MARIOTT MANAGER 0100 [email protected] ASHWIN 041 405 082 517

LANGEVELDT HR MANAGER 0100 8240 [email protected] KOLISWA 041 405 071 922

LUMKWANA RECEPTIONIST 0100 2013 [email protected]

38. SANITECH ERF 318, ALUMINA EXT

ROAD NAME & SURNAME DESIGNATION NO CELL EMAIL ZONE 5, PORT BRANCH 041 453 082 943 ELIZABETH JAN DU PREEZ MANAGER 8996 3279 [email protected] SOUTH AFRICA 6000

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39. KE NAKO

CONCRETE R102 - Zone 5 EXT NAME & SURNAME DESIGNATION NO CELL EMAIL Coega IDZ MANAGING 041 405 082 390 JEROME PERILS DIRECTOR 0151 7639 [email protected] Port Elizabeth 6100 ZONE 6&11: Ferrous Metals

Cluster 40. AGNI STEELS SA Corner of Furnace EXT Close and Ring Road NAME & SURNAME DESIGNATION NO CELL EMAIL Coega IDZ 041 450

Zone 6 KURT WATKINS IR/HR MANAGER 1351 [email protected] Port Elizabeth 041 450 084 628

HASSAN KHAN DIRECTOR 1331 4499 [email protected] 041 450 082 805

SHARAZ KHAN DIRECTOR 1331 5965 [email protected] DHIROSHAN 041 450

MOODLEY DIRECTOR 1331 [email protected] ACCOUNTS 041 450

NORMA BOTHA ASSISTANT 1343 [email protected]

ZONE 7: Chemicals Cluster

41. CEREBOS Zone 7 EXT

Coega IDZ NAME & SURNAME DESIGNATION NO CELL EMAIL Haugham Park MANAGING 041 403 082 654

JOHN DRINKWATER DIRECTOR 6700 9507 [email protected] SIPHOKAZI DANDALA- COMPLIANCE 041 403 083 421

MADOKWE MANAGER 6700 2693 [email protected] 041 403

AZOLA MQOLA RECEPTIONIST 6700 [email protected] FINANCIAL 041 403 082 874

KEITH LISTON DIRECTOR 6729 7488 [email protected] 041 403

AYANDA BANZANA HR MANAGER 6700 073 382 026 [email protected]

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42. LENSION SA Road F, Zone 7, Cboega EXT IDZ, PORT NAME & SURNAME DESIGNATION NO CELL EMAIL ELIZABETH SOUTH 078 803 AFRICA 6001 VINO 2679 [email protected]

ZONE 13: Energy Cluster 43. DEDISA PEAKING POWER Dedisa Peaking Power NAME & SURNAME DESIGNATION EXT CELL EMAIL Coega IDZ Zone 13 FACILITY 041 405 076 810 Port Elizabeth JAMES CLASSEN MANAGER 0511 9090 [email protected] OFFICE 041 405 063 682

MAGRIET LOMBARD ADMINISTRATOR 0501 2367 [email protected]

44. ELECTRAWINDS TITLE NAME & SURNAME DESIGNATION EXT CELL EMAIL 011 135 083 400

MR TREVOR D'OLIVEIRA DIRECTOR 3500 3939 [email protected] 0

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Appendix C5 Minutes of meeting

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Appendix C6 Correspondence with Interested and Affected Parties

LANDOWNER NOTIFICATION

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BID NOTIFICATION TO AUTHORITIES AND LANDOWNER

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LANDOWNER RESPONSE TO BID

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BID NOTIFICATION – OTHER STAKEHOLDERS

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NOTIFICATION OF AVAILABILITY OF DRAFT SCOPING REPORT: AUTHORITIES

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ACKNOWLEDGEMENT OF RECEIPT OF DRAFT SCOPING REPORT

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NOTIFICATION OF AVAILABILITY OF DRAFT SCOPING REPORT: OTHER STAKEHOLDERS

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NOTIFICATION OF AVAILABILITY OF DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME: COMMENTING AUTHORITIES AND OTHER STAKEHOLDERS

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ACKNOWLEDGEMENT OF RECEIPT OF DRAFT EIAR AND EMPR

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CORRESPONDENCE WITH I&APS

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Draft Scoping Report, Mining Right Application by Coega Mining Ltd (Ref: EC 30/5/1/2/2/10049MR) Comments: Dr P.A. Whittington 1. Page 34, under heading Geohydrology: the third sentence, beginning “This aquifer” requires re-writing. 2. A key/legend needs to be given to some of the flora/fauna species lists. For instance, what is the relevance of “(d)” in the floral lists and “Ra” in Table 7? 3. A lot of supposition is being made with species that may be present in the application area that have been or could be recorded in the relevant quarter degree square. Specialist studies are required in the actual application area to ascertain exactly what is there. This is a basic necessity for floral, faunal and heritage aspects. 4. It is pointless putting Table 11 in the document before the explanatory sections currently starting on page 65. The explanation of the figures used for extent, duration, probability and intensity and the details of how significance is calculated are necessary before one can interpret the information in Table 11. 5. The headings for Table 11 need to be carried to each separate page on which the table appears. One doesn’t want to have to keep going back to the top to be reminded what each column represents. 6. On page 57, it is stated that impacts of site preparation will result in loss of species of conservation concern (SCC) and their habitat. However, Table 11 (row 14) states that no floral SCCs occur on site. This would seem to be a contradiction. Is there expected to be a loss of faunal SCCs and their habitat only? This needs clarification. 7. I am somewhat bewildered by the fact that the Department of Mineral Resources should be the competent authority for this application. Surely DEDEAT or DEA would be more appropriate? 8. Table 14 talks of prohibiting hunting and collecting. These must be prevented, not just prohibited. Enforcement of the regulations and of the mitigatory procedures must be carried out. 9. The Minter et al. reference is in the wrong place. It should follow the DEDEAT reference. The first reference in the list should be Albertyn, which comes before Animal. You cannot use the same citation for more than one reference, e.g. ADU (2017) cannot be used for four different references. They should be cited as ADU (2017a), ADU (2017b), etc.

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ELC MINUTES AND RELATED COMMENTS AND CORRESPONDENCE

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Appendix D

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Appendix D1 Biodiversity Assessment

Table 15 List of possible mammal species present on the proposed mining site.

Red list Atlas region Family Genus Species Subspecies Common name category endemic Bovidae Raphicerus melanotis Cape Grysbok Least Concern Yes Bovidae Redunca fulvorufula Mountain Reedbuck Least Concern Yes Herpestidae Atilax paludinosus Marsh Mongoose Least Concern Yes Herpestidae Cynictis penicillata Yellow Mongoose Least Concern Yes Muridae Aethomys namaquensis Namaqua Rock Mouse Least Concern Muridae Desmodillus auricularis Cape Short-tailed Gerbil Least Concern Yes Muridae Gerbilliscus paeba Paeba Hairy-footed Gerbil Least Concern Yes Single-Striped Muridae Lemniscomys rosalia Data Deficient Yes Lemniscomys Southern African Muridae Mastomys coucha Least Concern Yes Mastomys Muridae Mastomys natalensis Natal Mastomys Least Concern Southern African Pygmy Muridae Mus minutoides Least Concern Yes Mouse Muridae Mus musculus musculus Not listed Muridae Otomys irroratus Southern African Vlei Rat Least Concern Yes Muridae Otomys saundersiae Saunders' Vlei Rat Least Concern Yes Muridae Otomys unisulcatus Karoo Bush Rat Least Concern Muridae Rattus norvegicus Brown Rat Least Concern Muridae Rattus rattus Roof Rat Least Concern Xeric Four-striped Grass Muridae Rhabdomys pumilio Least Concern Yes Rat Mustelidae Aonyx capensis African Clawless Otter Least Concern Yes Mustelidae Poecilogale albinucha African Striped Weasel Data deficient Yes Gray African Climbing Nesomyidae Dendromus melanotis Least Concern Yes Mouse Southern African Pouched Nesomyidae Saccostomus campestris Least Concern Yes Mouse Suidae Potamochoerus porcus Red River Hog Not listed Yes Vespertilionidae Neoromicia capensis Cape Serotine Least Concern Yes Viverridae Genetta tigrina Cape Genet Least Concern Yes

Atlas Red list Family Genus Species Subspecies Common name region category endemic Elandsberg Dwarf Endangered Chamaeleonidae Bradypodion taeniabronchum Yes Chameleon (SARCA 2014) Eastern Cape Least Concern Chamaeleonidae Bradypodion ventrale Yes Dwarf Chameleon (SARCA 2014) Vulnerable Cheloniidae Caretta caretta Loggerhead Turtle (SARCA 2014) Near Threatened Cheloniidae Chelonia mydas Green Turtle (SARCA 2014) Olive Ridley Data Deficient Cheloniidae Lepidochelys olivacea Turtle (SARCA 2014) Least Concern Colubridae Crotaphopeltis hotamboeia Red-lipped Snake (SARCA 2014) Least Concern Colubridae Dispholidus typus typus Boomslang (SARCA 2014)

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South Eastern Least Concern Colubridae Philothamnus hoplogaster Green Snake (SARCA 2014) Western Natal Least Concern Colubridae Philothamnus natalensis occidentalis Yes Green Snake (SARCA 2014) Spotted Bush Least Concern Colubridae Philothamnus semivariegatus Snake (SARCA 2014) Least Concern Cordylidae Chamaesaura anguina anguina Cape Grass Lizard Yes (SARCA 2014) Cape Girdled Least Concern Cordylidae Cordylus cordylus Yes Lizard (SARCA 2014) Leatherback Endangered Dermochelyidae Dermochelys coriacea Turtle (SARCA 2014) Least Concern Elapidae Hemachatus haemachatus Rinkhals (SARCA 2014) Yellow-bellied Least Concern Elapidae Hydrophis platurus Sea Snake (SARCA 2014) Least Concern Elapidae Naja nivea Cape Cobra (SARCA 2014) Common Tropical Least Concern Gekkonidae Hemidactylus mabouia House Gecko (SARCA 2014) Common Dwarf Least Concern Gekkonidae Lygodactylus capensis capensis Gecko (SARCA 2014) Least Concern Gekkonidae Pachydactylus maculatus Spotted Gecko (SARCA 2014) FitzSimons' Long- Vulnerable Gerrhosauridae Tetradactylus fitzsimonsi Yes tailed Seps (SARCA 2014) Common Sand Least Concern Lacertidae Pedioplanis lineoocellata pulchella Lizard (SARCA 2014) South African Least Concern Lamprophiidae Duberria lutrix lutrix Yes Slug-eater (SARCA 2014) Spotted Harlequin Least Concern Lamprophiidae Homoroselaps lacteus Yes Snake (SARCA 2014) Aurora House Least Concern Lamprophiidae Lamprophis aurora Yes Snake (SARCA 2014) Olive House Least Concern Lamprophiidae Lycodonomorphus inornatus Yes Snake (SARCA 2014) Dusky-bellied Least Concern Lamprophiidae Lycodonomorphus laevissimus Yes Water Snake (SARCA 2014) Brown Water Least Concern Lamprophiidae Lycodonomorphus rufulus Snake (SARCA 2014) Least Concern Lamprophiidae Lycophidion capense capense Cape Wolf Snake (SARCA 2014) Sundevall's Least Concern Lamprophiidae Prosymna sundevallii Shovel-snout (SARCA 2014) Cross-marked Least Concern Lamprophiidae Psammophis crucifer Grass Snake (SARCA 2014) Spotted Grass Least Concern Lamprophiidae Psammophylax rhombeatus rhombeatus Snake (SARCA 2014) Black Thread Least Concern Leptotyphlopidae Leptotyphlops nigricans Yes Snake (SARCA 2014) Algoa Bay Least Concern Scincidae Acontias lineicauda Yes Legless Skink (SARCA 2014) Cape Legless Least Concern Scincidae Acontias meleagris Yes Skink (SARCA 2014) Eastern Legless Least Concern Scincidae Acontias orientalis Yes Skink (SARCA 2014) Algoa Dwarf Least Concern Scincidae Scelotes anguineus Yes Burrowing Skink (SARCA 2014) Least Concern Scincidae Trachylepis capensis Cape Skink (SARCA 2014) Least Concern Scincidae Trachylepis homalocephala Red-sided Skink Yes (SARCA 2014) Least Concern Testudinidae Chersina angulata Angulate Tortoise (SARCA 2014)

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Parrot-beaked Least Concern Testudinidae Homopus areolatus Yes Tortoise (SARCA 2014) Delalande's Least Concern Typhlopidae Rhinotyphlops lalandei Beaked Blind (SARCA 2014) Snake Least Concern Varanidae Varanus albigularis albigularis Rock Monitor (SARCA 2014) Least Concern Varanidae Varanus niloticus Water Monitor (SARCA 2014) Least Concern Viperidae Bitis arietans arietans Puff Adder (SARCA 2014)

Table 16 List of possible frog species present on the proposed mining site.

Family Genus Species Common name Red list category Atlas region endemic Brevicepitidae Breviceps adspersus Bushveld Rain Frog Least Concern Bufonidae Sclerophrys capensis Raucous Toad Least Concern Bufonidae Sclerophrys pardalis Leopard Toad Least Concern Hyperoliidae Hyperolius marmoratus Painted Reed Frog Least Concern Hyperoliidae Hyperolius semidiscus Yellowstriped Reed Frog Least Concern Hyperoliidae Semnodactylus wealii Rattling Frog Least Concern Pyxicephalidae Amietia delalandii Delalande's River Frog Least Concern Yes Pyxicephalidae Amietia fuscigula Cape River Frog Least Concern Pyxicephalidae Cacosternum boettgeri Common Caco Least Concern Pyxicephalidae Cacosternum nanum Bronze Caco Least Concern Pyxicephalidae Strongylopus fasciatus Striped Stream Frog Least Concern Pyxicephalidae Strongylopus grayii Clicking Stream Frog Least Concern Pyxicephalidae Tomopterna delalandii Cape Sand Frog Least Concern

Table 17 List of possible butterfly species present on the proposed mining site.

Atlas region Family Genus Species Subspecies Common name Red list category endemic AGANAIDAE Asota speciosa speciosa Not Evaluated (NE) ARCTIIDAE Utetheisa pulchella pulchella Not Evaluated (NE) Artitropa erinnys erinnys Bush night-fighter LC Coeliades forestan forestan Striped policeman LC Eretis umbra umbra Small marbled elf LC Yes Gegenes niso niso Common hottentot LC Kedestes lepenula Chequered ranger LC HESPERIIDAE Metisella malgacha malgacha Grassveld sylph LC Yes Metisella metis paris Gold-spotted sylph LC Spialia asterodia Star sandman LC Spialia nanus Dwarf sandman LC Spialia sataspes Boland sandman LC Yes Tsitana uitenhaga Uitenhage sylph LC Yes Zophopetes dysmephila Palm-tree night-fighter LC Unidentified Not listed LYCAENIDAE Actizera lucida Rayed blue LC Aloeides aranda Aranda copper LC Aloeides clarki Coega copper Endangered Yes Aloeides depicta Depicta copper LC Yes Aloeides pierus Dull copper LC Yes LYCAENIDAE Aloeides trimeni trimeni Trimen's copper LC

Anthene amarah amarah Black striped hairtail LC Anthene definita definita Common hairtail LC Black-bordered babul Azanus moriqua LC blue Cacyreus fracta fracta Water geranium bronze LC Common geranium Cacyreus marshalli LC bronze

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Atlas region Family Genus Species Subspecies Common name Red list category endemic Chrysoritis chrysaor Burnished opal LC Yes Chrysoritis pyroeis hersaleki Sand-dune opal Vulnerable Yes Chrysoritis thysbe whitei Common opal Endangered Yes Cupidopsis cissus cissus Common meadow blue LC Durbania amakosa penningtoni Amakoza rocksitter LC Yes Eicochrysops messapus messapus Cupreous blue LC Iolaus mimosae mimosae Mimosa sapphire LC Yes Lachnocnema durbani D'Urban's woolly legs LC Lampides boeticus Pea blue LC Lepidochrysops asteris Brilliant blue LC Yes Lepidochrysops bacchus Wineland blue LC (R–HS, LD) Yes Lepidochrysops ketsi ketsi Ketsi blue LC Yes Lepidochrysops patricia Patricia blue LC Lepidochrysops variabilis Variable blue LC Leptomyrina lara Cape black-eye LC Leptotes Not listed Leptotes pirithous pirithous Common zebra blue LC Myrina silenus ficedula Common fig tree blue LC Oraidium barberae Dwarf blue LC Bowker's marbled Stugeta bowkeri bowkeri LC Yes sapphire Tarucus thespis Vivid dotted blue LC Yes Virachola antalus Brown playboy LC Zizeeria knysna knysna African grass blue LC NOCTUIDAE Agrotis Not listed Sommeria strabonis strabonis Not Evaluated (NE) Acraea Not listed Acraea horta Garden acraea LC Acraea natalica Natal acraea LC Bicyclus safitza safitza Common bush brown LC Cassionympha cassius Rainforest brown LC Yes Catacroptera cloanthe cloanthe Pirate LC Charaxes jahlusa jahlusa Pearl-spotted charaxes LC Yes Charaxes varanes varanes Pearl charaxes LC African monarch, Plain Danaus chrysippus orientis LC tiger Dira clytus eurina Cape autumn widow LC Yes NYMPHALIDAE Junonia hierta cebrene Yellow pansy LC

Junonia oenone oenone Blue pansy LC Junonia orithya madagascariensis Eyed pansy LC Pardopsis punctatissima Polka dot LC Precis archesia archesia Garden commodore LC False silver-bottom Pseudonympha magoides LC Yes brown Pseudonympha magus Silver-bottom brown LC Yes Pseudonympha varii Vari's brown LC Yes Vanessa cardui Painted lady LC Southern short-tailed Vanessa hippomene hippomene LC Yes admiral Papilio demodocus demodocus Citrus swallowtail LC PAPILIONIDAE Green-banded Papilio nireus lyaeus LC swallowtail Belenois aurota Brown-veined white LC Belenois creona severina African common white LC Belenois gidica abyssinica African veined white LC Belenois zochalia zochalia Forest white LC Catopsilia florella African migrant LC Colias electo electo African clouded yellow LC Colotis antevippe gavisa Red tip LC PIERIDAE Colotis euippe omphale Smoky orange tip Least Concern (LC) Colotis evagore antigone Small orange tip LC Dixeia charina charina African small white LC Eronia cleodora Vine-leaf vagrant LC Pinacopteryx eriphia eriphia Zebra white LC Pontia helice helice Common meadow white LC Teracolus eris eris Banded gold tip LC

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Atlas region Family Genus Species Subspecies Common name Red list category endemic SPHINGIDAE Acherontia atropos atropos Not Evaluated (NE)

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Bird List for the area around the proposed Coega Mining Right Birds known to regularly occur within a 2 km radius of the proposed Coega Mining Right giving the Global (IUCN Red List) and SA Red Data Book Threat Status and whether the species is Endemic / Near Endemic to southern Africa (south of the Zambezi River). The preferred habitat of the species in this area of the Coega SEZ is indicated.

Common Name Scientific Name IUC SA Endemic Habitat Notes N Penguin, African Spheniscus demersus En En NE Marine Breed St Croix Gannet, Cape Morus capnesis En Vu NE Marine Breed Bird Isle Cormorant, White- Phalacrocorax carbo Coastal breasted Cormorant, Cape Phalacrocorax En En NE Marine, Breed St Croix capensis Coastal Heron, Grey Ardea cinerea Coastal Heron, Black-headed Ardea melanocephala Bontveld Egret, Little Egretta garzetta Coastal Egret, Western Cattle Bubulcus ibis Bontveld Ibis, African Sacred Threskiornis Overfly Breed Jahleel aethiopicus Ibis, Hadeda Bostrychia hagedash Terrestrial Goose, Egyptian Alopochen Coastal aegyptiacus Secretarybird Sagittarius Vu Vu Bontveld serpentarius Kite, Yellow-billed Milvus aegyptius Terrestrial Migrant Kite, Black-shouldered Elanus caeruleus Terrestrial Buzzard, Steppe Buteo vulpinus Terrestrial Migrant Buzzard, Jackal Buteo rufofuscus E Terrestrial Sparrowhawk, Black Accipiter Terrestrial melanoleucus Osprey, Western Pandion haliaetus Coastal Migrant Falcon, Peregrine Falco peregrinus Terrestrial Falcon, Lanner Falco biarmicus LC Vu Terrestrial Kestrel, Rock Falco rupicolus Terrestrial Spurfowl, Red-necked Pternistis afer Thicket Quail, Common Coturnix coturnix Bontveld Guineafowl, Helmeted Numida meleagris Terrestrial Crane, Blue Anthropoides Vu NT E Bontveld, Pair bred in paradiseus Dunes dunes Oystercatcher, African Haematopus moquini E Coastal Breed on coast Black Plover, Common Ringed Charadrius hiaticula Coastal Migrant Plover, White-fronted Charadrius Coastal Breed on coast marginatus Plover, Kittlitz's Charadrius pecuarius Coastal Breed on coast Plover, Grey Pluvialis squatarola Coastal Migrant Lapwing, Crowned Vanellus coronatus Bontveld

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Common Name Scientific Name IUC SA Endemic Habitat Notes N Lapwing, Blacksmith Vanellus armatus Coastal Turnstone, Ruddy Arenaria interpres Coastal Migrant Greenshank, Common Tringa nebularia Coastal Migrant Sanderling Calidris alba Coastal Migrant Whimbrel, Common Numenius phaeopus Coastal Migrant Thick-knee, Spotted Burhinus capensis Terrestrial Thick-knee, Water Burhinus Coastal vermiculatus Gull, Kelp Larus dominicanus Coastal Breed on coast Gull, Grey-headed Chroicocephalus Coastal cirrocephalus Gull, Hartlaub’s Chroicocephalus E Coastal hartlaubii Tern, Caspian Sterna caspia LC Vu Coastal Tern, Swift Thalassius bergii Marine, Breed islands Coastal Tern, Sandwich Thalassius Coastal Migrant sandvicensis Tern, Common Sterna hirundo Coastal Migrant Tern, Roseate Sterna dougallii LC En Marine, Breed islands Coastal Tern Damara Sterna balaenarum Vu CR NE Coastal Breed dunes. Migrant Dove, Rock Columba livia Terrestrial Pigeon, Speckled Columba guinea Terrestrial Breed in buildings Dove, Red-eyed Streptopelia Terrestrial semitorquata Turtle-dove, Cape Streptopelia capicola Terrestrial Dove, Laughing Streptopelia Terrestrial senegalensis Wood-Dove, Emerald- Turtur chalcospilos Thicket spotted Dove, Namaqua Oena capensis Terrestrial Cuckoo, Black Cuculus clamosus Thicket Breed Migrant Cuckoo, Jacobin Clamator jacobinus Thicket Breed Migrant Cuckoo, Klaas's Chrysococcyx klaas Thicket Breed Migrant Cuckoo, Diderick Chrysococcyx Thicket Breed Migrant caprius Coucal, Burchell's Centropus burchellii Thicket Owl, Western Barn Tyto alba Terrestrial Breed buildings Eagle-owl, Spotted Bubo africanus Terrestrial Nightjar, Fiery-necked Caprimulgus Terrestrial pectoralis Swift, White-rumped Apus caffer Aerial Breed Migrant Swift, Little Apus affinis Aerial Breed Migrant Mousebird, Speckled Colius striatus Terrestrial

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Common Name Scientific Name IUC SA Endemic Habitat Notes N Mousebird, Red-faced Urocolius indicus Terrestrial Kingfisher, Pied Ceryle rudis Coastal Kingfisher, Brown- Halcyon albiventris Terrestrial hooded Hoopoe, African Upupa africana Terrestrial Wood-hoopoe, Green Phoeniculus Thicket purpureus Barbet, Black-collared Lybius torquatus Thicket Barbet, Acacia Pied Tricholaema Thicket leucomelas Honeyguide, Lesser Indicator minor Thicket Woodpecker, Knysna Campethera notata NT NT E Thicket Pair in thicket near mine Woodpecker, Cardinal Dendropicos Thicket fuscescens Lark, Cape Clapper Mirafra apiata E Bontveld Lark, Red-capped Calandrella cinerea Bontveld, Dunes Swallow, Barn Hirundo rustica Aerial Migrant Swallow, White-throated Hirundo albigularis Aerial Breed Migrant Swallow, Pearl-breasted Hirundo dimidiata Bontveld Breed Migrant Swallow, Greater Hirundo cucullata Aerial Breed migrant Striped Swallow, Lesser Striped Hirundo abyssinica Aerial Breed migrant Martin, Rock Hirundo fuligula Aerial Martin, Brown-throated Riparia paludicola Aerial Saw-wing, Black Psalidoprocne Thicket (Southern race) holomelaena Drongo, Fork-tailed Dicrurus adsimilis Thicket Oriole, Black-headed Oriolus larvatus Thicket Crow, Pied Corvus albus Terrestrial Crow, Cape Corvus capensis Terrestrial Raven, White-necked Corvus albicollis Terrestrial Bulbul, Cape Pycnonotus capensis E Thicket Bulbul, Dark-capped Pycnonotus tricolor Thicket Brownbul, Terrestrial Phyllastrephus Thicket terrestris Greenbul, Sombre Andropadus Thicket importunus Thrush, Olive Turdus olivaceus Thicket Chat, Familiar Cercomela familiaris Terrestrial Stonechat, African Saxicola torquatus Bontveld Robin-chat, Cape Cossypha caffra Thicket Scrub-robin, Karoo Cercotrichas E Thicket coryphoeus Scrub-robin, White- Cercotrichas Thicket browed leucophrys

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Common Name Scientific Name IUC SA Endemic Habitat Notes N Tit-babbler, Chestnut- Sylvia subcaerulea Thicket vented Warbler, Willow Phylloscopus Thicket Migrant trochilus Apalis, Bar-throated Apalis thoracica Thicket Apalis, Yellow-breasted Apalis flavida Thicket Crombec, Long-billed Sylvietta rufescens Thicket Camaroptera, Green- Camaroptera Thicket backed brachyura Cisticola, Cloud Cisticola textrix NE Bontveld Neddicky Cisticola fulvicapilla Terrestrial Cisticola, Grey-backed Cisticola E Bontveld, subruficapilla Thicket Prinia, Karoo Prinia maculosa E Thicket Flycatcher, African Muscicapa adusta Thicket Dusky Flycatcher, Fiscal Sigelus silens E Thicket Batis, Cape Batis capensis Thicket Paradise-flycatcher, Terpsiphone viridis Thicket African Wagtail, Cape Motacilla capensis Terrestrial Pipit, African Anthus cinnamomeus Bontveld Longclaw, Cape Macronyx capensis E Bontveld Fiscal, Common Lanius collaris Terrestrial (Southern) Boubou, Southern Laniarius ferrugineus E Thicket Tchagra, Southern Tchagra tchagra E Thicket Bush-shrike, Olive Telophorus olivaceus E Thicket Bokmakierie Telophorus zeylonus NE Terrestrial Starling, Common Sturnus vulgaris Terrestrial Starling, Pied Lamprotornis bicolor E Terrestrial Starling, Wattled Creatophora cinerea Terrestrial Starling, Cape Glossy Lamprotornis nitens E Terrestrial Starling, Red-winged Onychognathus Terrestrial Breed buildings morio Sunbird, Malachite Nectarinia famosa Thicket Sunbird, Greater Cinnyris afer E Thicket Double-collared Sunbird, Southern Cinnyris chalybeus E Thicket Double-collared Sunbird, Grey Cyanomitra veroxii Thicket Sunbird, Collared Hedydipna collaris Thicket Sunbird, Amethyst Chalcomitra Thicket amethystina White-eye, Cape Zosterops virens E Thicket Sparrow, House Passer domesticus Buildings Sparrow, Cape Passer melanurus E Terrestrial

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Common Name Scientific Name IUC SA Endemic Habitat Notes N Sparrow, Southern Grey- Passer diffusus Terrestrial headed Weaver, Spectacled Ploceus ocularis Thicket Weaver, Cape Ploceus capensis E Terrestrial Masked-weaver, Ploceus velatus Terrestrial Southern Quelea, Red-billed Quelea quelea Terrestrial Bishop, Southern Red Euplectes orix Terrestrial Waxbill, Swee Coccopygia E Thicket melanotis Firefinch, African Lagonosticta Thicket rubricata Waxbill, Common Estrilda astrild Terrestrial Whydah, Pin-tailed Vidua macroura Terrestrial Canary, Cape Serinus canicollis Terrestrial Canary, Yellow-fronted Crithagra Thicket mozambicus Canary, Brimstone Crithagra Thicket sulphuratus Canary, White-throated Crithagra E Thicket albogularis Seedeater, Streaky- Crithagra gularis Thicket headed Bunting, Cape Emberiza capensis Bontveld Bunting, Golden- Emberiza flaviventris Thicket breasted

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APPENDIX D2 AVIFAUNAL SPECIALIST REPORT

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APPENDIX D3 BOTANICAL SPECIALIST REPORT

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