SAPPI SOUTHERN AFRICA LIMITED PROPOSED NGODWANA RESERVOIR - 1/3/1/16/1E-226 FINAL BASIC ASSESSMENT REPORT
08 DECEMBER 2019 PUBLIC
PROPOSED NGODWANA RESERVOIR - 1/3/1/16/1E-226 FINAL BASIC ASSESSMENT REPORT
SAPPI SOUTHERN AFRICA LIMITED
TYPE OF DOCUMENT: PUBLIC
PROJECT NO.: 41101600 DATE: DECEMBER 2019
WSP BUILDING C, KNIGHTSBRIDGE 33 SLOANE STREET BRYANSTON, 2191 SOUTH AFRICA
T: +27 11 361 1380 F: +086 606 7121 WSP.COM
WSP Environmental (Pty) Ltd.
QUALITY MANAGEMENT
ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3
Remarks Final BAR
Date December 2019
Prepared by Tutayi Chifadza
Signature
Checked by Anri Scheepers
Signature
Authorised by Nigel Seed
Signature
Project number 41101600
Report number 01
File reference W:\000 NEW Projects\41101600 - Sappi Ngodwana Reservoir\42 ES\2-REPORTS\01- Final\BAR
WSP is an ISO9001:2015, ISO14001:2015 and OHSAS18001:2007 certified company
SIGNATURES
PREPARED BY
Tutayi Chifadza Consultant
REVIEWED BY
Anri Scheepers Principal Consultant This Final Basic Assessment Report (Report) has been prepared by WSP Environmental Proprietary Limited (WSP) on behalf and at the request of Sappi Southern Africa Limited (Client), to provide the Client and all Interested and Affected Parties with an understanding of the impacts associated with the proposed project. Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other than the Client for the contents of, or any omissions from, this Report. To prepare this Report, we have reviewed only the documents and information provided to us by the Client or any third parties directed to provide information and documents to us by the Client. We have not reviewed any other documents in relation to this Report, except where otherwise indicated in the Report.
PRODUCTION TEAM
SAPPI
Project Manager Errol von Berg
Risk Specialist Environmental Andile Mbatha
WSP
Consultant Tutayi Chifadza
Principal Consultant / Project Manager Anri Scheepers
Project Director Nigel Seed
SUBCONSULTANTS
The Biodiversity Company Martinus Erasmus
The Biodiversity Company Michael Adams
GLOSSARY
ABBREVIATION MEANING
BA Basic Assessment
BAR Basic Assessment Report
CBA Critical Biodiversity Area
COD Chemical Oxygen Demand
CRR Comment and Response Report
DEFF Department of Environment, Forestry and Fisheries
DHSWS Department of Human Settlements, Water and Sanitation
EA Environmental Authorisation
EAP Environmental Assessment Practitioner
EC Electrical Conductivity
EMPr Environmental Management Programme
GA General Authorisation
GVA Gross Value Added
HIA Heritage Impact Assessment
IWUL Integrated Water Use License
IWWMP Integrated Water and Waste Management Plan
I&APs Interested and Affected Parties
MAE Mean Annual Evaporation
MAP Mean Annual Precipitation
MAR Mean Annual Runoff
MDARDLEA Mpumalanga Department: Agriculture, Rural Development, Land and Environmental Affairs
MRU Management Resource Unit
ABBREVIATION MEANING
MTPA Mpumalanga Tourism and Parks Agency
NEMA National Environmental Management Act
NEM:WA National Environmental Management: Waste Act
NEM:BA National Environmental Management: Biodiversity Act
NFEPA National Freshwater Ecosystem Priority Areas
NHRA National Heritage Resource Act
NPAES National Protected Areas Expansion Strategy
PCB Polychlorinated Dibenzofuran
PM Particulate Matter
REC Recommended Ecological Category
RISFSA Road Infrastructure Strategic Framework for South Africa
RQO Resource Quality Objectives
SAHRA South African Heritage Resources Agency
SANBI South African National Biodiversity Institute
SCC Species of Conservation Concern
SQ Sub-quaternary
TDS Total Dissolved Solids
TSP Total Suspended Particulates
TSS Total Suspended Solids
TWQR Target Water Quality Range
WMA Water Management Area
WRC Water Resource Classification
WSP WSP Environmental (Pty) Ltd
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ABBREVIATION MEANING
WUL Water Use License
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TABLE OF 1 INTRODUCTION ...... 14 CONTENTS 1.1 Background and Terms of Reference ...... 14 1.2 Purpose of the BA Process ...... 15 1.3 Details of EAP and Project Proponent ...... 15 1.4 Specialists ...... 16 1.5 Competent and Commenting Authority ...... 16 1.6 Assumptions and Limitations ...... 17 1.7 Basic Assessment Report Structure ...... 17
2 GOVERNANCE FRAMEWORK ...... 20
3 BASIC ASSESSMENT PROCESS ...... 23 3.1 Procedural Framework ...... 23 3.2 Application ...... 23 3.3 Baseline Environmental Assessment ...... 23 3.4 Impact Assessment Methodology ...... 24 3.5 Stakeholder Engagement Process ...... 24
4 PROJECT DESCRIPTION ...... 27 4.1 Need and Desirability of the Project ...... 27 4.2 Location of the Proposed Project ...... 27 4.3 Layout and Description ...... 29
5 ALTERNATIVES ...... 32 5.1 Site Location ...... 32 5.2 No-Go Alternative ...... 37
6 BASELINE ENVIRONMENT ...... 38 6.1 Climate ...... 38 6.2 Geology ...... 42 6.3 Surface Water ...... 43 6.4 Groundwater ...... 44 6.5 Land-Use ...... 44
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6.6 Ambient Air Quality ...... 46 6.7 Noise ...... 46 6.8 Biodiversity ...... 48 6.9 Traffic ...... 53 6.10 Socio-Economic ...... 53
7 IMPACT ASSESSMENT ...... 57 7.1 Air Quality ...... 57 7.2 Noise Emissions ...... 58 7.3 Soil Erosion and Contamination ...... 59 7.4 Surface Water ...... 61 7.5 Groundwater ...... 63 7.6 Biodiversity ...... 64 7.7 Traffic ...... 69 7.8 Health and Safety ...... 70 7.9 Socio-Economic ...... 71 7.10 No-Go Alternative ...... 72
8 ENVIRONMENTAL IMPACT STATEMENT...... 73 8.1 Environmental Sensitivities ...... 73 8.2 Specialist Conclusions ...... 74 8.3 Impact Summary ...... 75 8.4 Impact Statement ...... 76
9 CONCLUSION ...... 78
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TABLES TABLE 1-1: DETAILS OF THE EAP ...... 15 TABLE 1-2: DETAILS OF PROPONENT ...... 15 TABLE 1-3: DETAILS OF SPECIALISTS ...... 16 TABLE 1-4: COMPETENT AND COMMENTING AUTHORITIES ...... 16 TABLE 1-5: LEGAL REQUIREMENTS AS DETAILED IN APPENDIX 1 OF GNR 326 OF THE 2014 EIA REGULATIONS, AS AMENDED . 18 TABLE 1-6: INFORMATION REQUESTED BY THE MDARDLEA ...... 19 TABLE 2-1: APPLICABLE LEGISLATION AND POLICIES ...... 20 TABLE 3-1: SITE NOTICE LOCATIONS ...... 25 TABLE 4-1: CADASTRAL INFORMATION OF THE SITE ...... 29 TABLE 4-2: CONSTRUCTION ACTIVITIES ... 30 TABLE 5-1: TECHNICAL, ECONOMIC AND ENVIRONMENTAL EVALUATION OF POTENTIAL ALTERNATIVES ...... 32 TABLE 6-1: AVERAGE TEMPERATURES (°C) AT SAPPI NGODWANA FOR JANUARY 2015 – DECEMBER 2017 ...... 38 TABLE 6-2: AVERAGE MONTHLY RAINFALL (MM) AT SAPPI NGODWANA FOR JANUARY 2015 – DECEMBER 2017 ...... 39 TABLE 6-3: TABLE RESIDENTIAL AREAS ... 44 TABLE 6-4: AVIFAUNAL SPECIES RECORDED ...... 51 TABLE 6-5: POPULATION AND HOUSEHOLD GROWTH ...... 54 TABLE 6-6: MANUFACTURING SECTOR GROWTH (2003 – 2013) ...... 55 TABLE 6-7: EMPLOYMENT GROWTH (2003 – 2013) ...... 56 TABLE 7-1: CONSTRUCTION IMPACT ON GENERATION OF DUST AND PM ...... 57 TABLE 7-2: CONSTRUCTION IMPACT ON NOISE ...... 58 TABLE 7-3: CONSTRUCTION IMPACT ON SOIL EROSION ...... 59 TABLE 7-4: CONSTRUCTION IMPACT ON SOIL CONTAMINATION ...... 60 TABLE 7-5: CONSTRUCTION IMPACT ON CHANGE IN FLOW VOLUMES AND DRAINAGE PATTERNS ..... 61
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TABLE 7-6: CONSTRUCTION IMPACT ON DETERIORATION IN WATER QUALITY ...... 62 TABLE 7-7: CONSTRUCTION IMPACT ON CHANGE IN FLOW VOLUMES ... 63 TABLE 7-8: CONSTRUCTION IMPACT ON DETERIORATION IN WATER QUALITY ...... 63 TABLE 7-9: CONSTRUCTION IMPACT ON LOSS AND FRAGMENTATION OF FLORA ...... 65 TABLE 7-10: CONSTRUCTION IMPACT ON INCREASE IN ALIEN VEGETATION SPECIES ...... 66 TABLE 7-11: DESTRUCTION OF PROTECTED TREE SPECIES ...... 66 TABLE 7-12: CONSTRUCTION IMPACT ON DISPLACEMENT OF FAUNA ..... 67 TABLE 7-13: OPERATIONAL IMPACT ON CONTINUED ENCROACHMENT AND DISPLACEMENT OF FLORA ...... 67 TABLE 7-14: OPERATIONAL IMPACT ON CONTINUED DISPLACEMENT AND FRAGMENTATION OF FAUNA ...... 68 TABLE 7-15: OPERATIONAL IMPACT ON LOSS OF FAUNA ...... 68 TABLE 7-16: OPERATIONAL IMPACT ON HABITAT DEGRADATION ...... 69 TABLE 7-17: CONSTRUCTION IMPACT ON INCREASED LOCAL TRAFFIC ... 70 TABLE 7-18: CONSTRUCTION IMPACT ON EMPLOYEE HEALTH AND SAFETY ...... 70 TABLE 7-19: CONSTRUCTION IMPACT ON EMPLOYMENT OPPORTUNITIES ...... 71 TABLE 8-1: IMPACT SUMMARY ...... 75
FIGURES FIGURE 1-1: SAPPI NGODWANA MILL LOCALITY MAP ...... 14 FIGURE 4-1: SAPPI NGODWANA RESERVOIR LOCATION ...... 28 FIGURE 4-2: MILL WATER PROCESS FLOW DIAGRAM (VAN DER MERWE- BOTHA & WILLE 2017) ...... 29 FIGURE 4-3: EXAMPLES OF STEEL TANK RESERVOIRS ...... 30
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FIGURE 5-1: POTENTIAL LOCATIONS / LAYOUTS ALTERNATIVES ...... 34 FIGURE 5-2: MPUMALANGA BIODIVERSITY SECTOR PLAN ...... 35 FIGURE 5-3: HABITAT DELINEATION...... 35 FIGURE 5-4: RESERVOIR ELEVATION ...... 36 FIGURE 5-5: PROPOSED RESERVOIR LAYOUT...... 36 FIGURE 6-1: AVERAGE, MAXIMUM AND MINIMUM TEMPERATURES (°C) AT SAPPI NGODWANA FOR THE PERIOD JANUARY 2015 – DECEMBER 2017 ...... 38 FIGURE 6-2: MONTHLY RAINFALL (MM) AND AVERAGE HUMIDITY (%) AT SAPPI NGODWANA FOR THE PERIOD JANUARY 2015 – DECEMBER 2017 ...... 39 FIGURE 6-3: PERIOD WIND ROSE AT SAPPI NGODWANA FOR JANUARY 2015 – DECEMBER 2017 ...... 40 FIGURE 6-4: DIURNAL WIND ROSES AT SAPPI NGODWANA FOR THE PERIOD JANUARY 2015 – DECEMBER 2017 ...... 41 FIGURE 6-5: SEASONAL WIND ROSES AT SAPPI NGODWANA FOR THE PERIOD JANUARY 2015 – DECEMBER 2017 ...... 42 FIGURE 6-6: LAND USE ...... 46 FIGURE 6-7: SURROUNDING RESIDENTIAL AREAS ...... 46 FIGURE 6-8: DAYTIME NOISE MONITORING RESULTS. LAEQ IS COMPARED WITH THE SANS 10103 GUIDELINE ...... 47 FIGURE 6-9: NIGHT-TIME NOISE MONITORING RESULTS. LAEQ IS COMPARED WITH THE SANS 10103 GUIDELINE...... 48 FIGURE 6-10: PICTURES REPRESENTING THE 3 HABITAT TYPES IDENTIFIED: A) DENSE MOUNTAIN WOODLAND, B) DEGRADED, C & D) TRANSFORMED ...... 49 FIGURE 6-11: THE PROJECT AREA SUPERIMPOSED ON THE MBSP (MTPA, 2014) ...... 50 FIGURE 6-12: HABITAT SENSITIVITY MAP ...... 52 FIGURE 6-13: RISFSA ROAD CLASSIFICATION ...... 53 FIGURE 6-14: GVA CONTRIBUTION BY ECONOMIC SECTOR, 2013 ...... 54
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FIGURE 6-15: MANUFACTURING SUB-SECTOR GVA, 2013 ...... 55 FIGURE 6-16: EMPLOYMENT STRUCTURE, 2013 ...... 56 FIGURE 8-1: ECOLOGICAL SENSITIVITY ...... 74
APPENDICES A EAP AND SPECIALIST CV A-1 Anri Scheepers A-2 Tutayi Chifadza A-3 Martinus Erasmus A-4 Michael Adams B EAP AND SPECIALIST DECLARATIONS B-1 Anri Scheepers (EAP) B-2 Martinus Erasmus B-3 Michael Adams C STAKEHOLDER DATABASE D MAPS D-1 Locality Map D-2 Layout Map D-3 Land use Map D-4 Rivers and Wetlands Map D-5 Environmental Sensitivity E PUBLIC PARTICIPATION E-1 Comment and Response Report E-2 Advert E-3 Site Notice E-4 Email Notifications E-5 Authority Notification F SPECIALIST STUDIES F-1 Biodiversity Assessment G EMPR H DESIGNS
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I IMPACT ASSESSMENT METHODOLOGY J THE BIODIVERSITY COMPANY SITE LOCATION MOTIVATION
PROPOSED NGODWANA RESERVOIR - 1/3/1/16/1E-226 WSP Project No. 41101600 December 2019 SAPPI SOUTHERN AFRICA LIMITED
1 INTRODUCTION
1.1 BACKGROUND AND TERMS OF REFERENCE
Sappi Southern Africa Limited (Sappi) proposes to construct an above ground 14.4 ML clean water reservoir for supply to the Sappi Ngodwana Mill on Farm Grootgeluk, 477/JT, Portion 0, Ngodwana, Mbombela Local Municipality, Mpumalanga Province. The proposed reservoir requires an environmental authorisation (EA) in terms of the National Environmental Management Act (Act 107 of 1998), as amended (NEMA) and the associated Environmental Impact Assessment (EIA) Regulations, 2014 as amended. WSP Environmental (Pty) Ltd (WSP) was appointed by Sappi as the independent Environmental Assessment Practitioner (EAP) to facilitate the Basic Assessment (BA) process in accordance with the EIA Regulations, 2014, as amended. The Mill uses water from the Ngodwana River, flowing into and stored in the Ngodwana Dam (owned and managed by Sappi). The water from the Ngodwana Dam is then treated at the fresh water treatment facility by flocculation followed by clarification. Lime addition for pH control occurs before the water is filtered through a sand filter. Disinfection is achieved by chlorination. The water from the treatment facility is currently sent to the existing reservoir prior to distribute for use at the mill. The proposed new 14.4ML reservoir is required to increase the buffer capacity in order to support the mill’s processes. Figure 1-1 provides a locality map of the Sappi Ngodwana Mill where the project will occur.
Figure 1-1: Sappi Ngodwana Mill Locality Map
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1.2 PURPOSE OF THE BA PROCESS
The BA process is an interdisciplinary procedure to ensure that environmental and social considerations are included in decisions regarding projects. Simply defined, the process aims to identify the possible environmental and social effects of a proposed activity and how those impacts can be mitigated. In the context of this report, the purpose of the BA process is to inform decision-makers and the public of potential negative and positive consequences of the proposed construction of the reservoir. This provides the competent authority with sufficient information to make an informed decision with regard to granting or refusing the EA applied for.
1.3 DETAILS OF EAP AND PROJECT PROPONENT
WSP was appointed in the role of Independent EAP to undertake the BA process for the proposed construction and operation of the reservoir. The Curriculum Vitae (CV) of the EAP is available in Appendix A. The EAP declaration of interest and undertaking is included in Appendix B. Table 1-1 details the relevant contact details of the EAP. In order to adequately identify and assess potential environmental impacts, the EAP was supported by a number of specialists. Table 1-2 provides the relevant details of the project proponent. Table 1-1: Details of the EAP
EAP WSP ENVIRONMENTAL (PTY) LTD
Company Registration: 1995/08790/07
Contact Person: Anri Scheepers
Postal Address: P.O. Box 98867, Sloane Park 2151, Johannesburg
Telephone: 011 300 6089
Fax: 011 361 1301
Email: [email protected]
Table 1-2: Details of Proponent
PROPONENT: SAPPI SOUTHERN AFRICA LIMITED
Company Registration: 1951/003180/06
Contact Person: Nick Dreyer
Physical Address: N4 National Road Ngodwana 1209
Telephone: 013 734 6210
Email: [email protected]
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1.4 SPECIALISTS
Specialist input was required in support of this application for EA. The details of the specialists are provided in Table 1-3 below. The Curriculum Vitae of the specialists are attached in Appendix A and their declarations in Appendix B. Table 1-3: Details of Specialists
SPECIALIST NAME OF SECTIONS IN REPORT ASSESSMENT SPECIALIST COMPANY REPORT ATTACHED AS
Biodiversity Martinus Erasmus The Biodiversity Company Section 6.8 Appendix F-1 Assessment Michael Adams
1.5 COMPETENT AND COMMENTING AUTHORITY
Table 1-4 provides the relevant details of the competent and commenting authorities on the project. Table 1-4: Competent and Commenting Authorities
COMPETENT / COMMENTING ASPECT AUTHORITY CONTACT DETAILS
Competent Authority: Mpumalanga Department: Agriculture, Robyn Luyt Rural Development, Land and Environmental Environmental Affairs (MDARDLEA) Tel: 013 766 4004 Authorisation [email protected] (Assessing officer to be confirmed)
Commenting Department of Environment, Forestry and Directorate Environmental Assessment Authorities Fisheries (DEFF) Environmental Authorisations Tel: 086 111 2468
DEFF: Biodiversity Conservation Unit Biodiversity Conservation Unit Tel: 012 399 9587 Stanley Tshitwamulomoni [email protected] (Assessing officer to be confirmed)
Mpumalanga Tourism and Parks Agency Lorraine Oosthuizen (MTPA) Executive Secretary – CEO MTPA Tel: 013 759 5300 [email protected]
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COMPETENT / COMMENTING ASPECT AUTHORITY CONTACT DETAILS
Ehlanzeni District Municipality General Manager: Municipal Health and Environmental Management Department Tel: 013 759 8500/8570 Thapelo Shabangu [email protected]
City of Mbombela Local Municipality Environmental Department Mr Sihle Mthembu Tel: (013) 759 2356 [email protected]
Water Use Department of Human Settlements, Water Deputy Director: Authorisation Administration and Sanitation (DHSWS) Water Use Licence Applications Tel: 012 336 8851 [email protected] (Assessing officer to be confirmed)
1.6 ASSUMPTIONS AND LIMITATIONS
General assumptions and limitations relating to the BA process are listed below: — The EAP hereby confirms that they have undertaken to obtain project information from the Client that is deemed to be accurate and representative of the project; — The comments received in response to the public participation process, are representative of comments from the broader community; and — The competent authority would not require additional specialist input, as per the proposals made in this report, in order to make a decision regarding the application. With regard to the Biodiversity Assessment conducted by The Biodiversity Company, the following limitations were noted for the study: — As per the scope of work, the fieldwork component of the assessment comprised of one assessment only, which was conducted during the wet season. This study has not assessed any temporal trends for the respective seasons; and — Despite these limitations, a comprehensive desktop study was conducted, in conjunction with the detailed results from the surveys, and as such there is a high confidence in the information provided. Notwithstanding these assumptions, it is the view of WSP that this BA report provides a sound description of the issues associated with the project and the resultant impacts, and that the Competent Authority would be able to make a decision using this information.
1.7 BASIC ASSESSMENT REPORT STRUCTURE
The Final BA report (this report) was prepared to meet the requirements as described in Appendix 1 of GNR 326 of the NEMA EIA Regulations, 2014, as amended. To demonstrate legal compliance, Table 1-5 cross-references the sections within the BA report with the requirements of Appendix 1 of GNR 326.
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Table 1-5: Legal Requirements as detailed in Appendix 1 of GNR 326 of the 2014 EIA Regulations, as amended
APPENDIX 1 OF RELEVANT REPORT GNR 326 DESCRIPTION SECTION 3(1) (a) Details of the EAP who prepared the report and the expertise of the EAP, Section 1.3 including a curriculum vitae Appendix A 3(1) (b) The location of the activity Section 4.1
3(1) (c) A plan which locates the proposed activity or activities applied for, as well Section 4.2 as associated structures and infrastructure at an appropriate scale 3(1) (d) A description of the scope of the proposed activity Section 4
3(1) (e) A description of the policy and legislative context within which the Section 2 development is proposed 3(1) (f) A motivation for the need and desirability for the proposed development Section 4.3 including the need and desirability of the activity in the context of the preferred location 3(1) (g) A motivation for the preferred site, activity and technology alternative Section 5
3(1) (h) A full description of the process followed to reach the proposed Section 5 alternative within the site 3(1) (i) A full description of the process undertaken to identify, assess and rank Section 3.4 the impacts the activity will impose on the preferred location through the life of the activity 3(1) (j) An assessment of each identified potentially significant impact and risk Section 7 3(1) (k) Where applicable, a summary of the findings and impact management Section 7 measures identified in any specialist report, complying with Appendix 6 to these Regulations, and an indication as to how these findings and recommendations have been included in the final report 3(1) (l) An environmental impact statement Section 8.4 3(1) (m) Based on the assessment, and where applicable, impact management Appendix G measures from specialist reports, the recording of the proposed impact management objectives, and the impact management outcomes for the development for inclusion in the Environmental Management Programme (EMPr). 3(1) (n) Any aspects which were conditional to the findings of the assessment Not applicable either by the EAP or specialist which are to be included as conditions of authorisation. 3(1) (o) A description of any assumptions, uncertainties and gaps in knowledge Section 1.6 which relate to the assessment and mitigation measures proposed 3(1) (p) A reasoned opinion as to whether the proposed activity should or should Section 8 not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation 3(1) (q) Where the proposed activity does not include operational aspects, the Not applicable period for which the environmental authorisation is required, the date on which the activity will be conducted, and the post construction monitoring requirements finalised 3(1) (r) An undertaking under oath or affirmation by the EAP Appendix B
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APPENDIX 1 OF RELEVANT REPORT GNR 326 DESCRIPTION SECTION 3(1) (s) Where applicable, details of any financial provisions for the rehabilitation, Not applicable closure, and ongoing post decommissioning management of negative environmental impacts 3(1) (t) Any specific information that may be required by the competent authority Refer to Table 1-6
3(1) (u) Any other matters required in terms of section 24(4)(a) and (b) of the Act Not applicable
Table 1-6: Information Requested by the MDARDLEA
INFORMATION REQUESTED RELEVANT REPORT SECTION Refer to Appendix D-2 for the The basic assessment report must include a consolidated single layout plan that must be referenced and dated, and' must include a legend and a land use table. You are Layout Map. further' referred to the following provisions of the EIA Regulations 2014: Refer to Appendix D-3 for the Land Use Map. — Appendix 1: 3(1)(c) - A basic assessment report must contain the information that is necessary for the competent authority to consider and come to a decision on the application, and must include - a plan which locates the proposed activity or Refer to Appendix D for the Plans activities. applied for as well as associated structures and infrastructure at an and Appendix H for the Design appropriate scale. Drawings. — Appendix 4: 1(1)(c) - a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the Refer to Appendix D-5 for the environmental sensitivities of the preferred site indicating any areas that should Environmental Sensitivity. be avoided.
The final layout plan was clearly demonstrate that Dense Mountain Woodland habitat Refer to Appendix D for the Plans. or Highly sensitive areas will be avoided.
Refer to Appendix J for the site location motivation. Refer to Appendix E-5 for proof of The Mpumalanga Tourism and Parks Agency must be consulted and provided with an opportunity to comment on the draft report. consultation and submission of a copy of the draft BAR to the MTPA. Refer to Appendix E-2 for proof of A copy of the newspaper advert and proof of site notices must be included in the final basic assessment report. placement of the advert.
Refer to Table 3-1 for proof of placement of site notices. Refer to Appendix E-5 for proof of Please ensure that you provide City of Mbombela with a copy of all draft reports and an opportunity to comment on them. Please liaise with Mr SihleMthembu from consultation and submission of a Mbombela (copied herein) in this regard - he is stationed at 7 Jones Street, Nelspruit, copy of the draft BAR to the City of 1200 Mbombela.
Please refer to Appendix E for proof The final basic assessment report must provide proof that all potential and registered l&APs, including organs of state, were provided with access to and an opportunity to that all E&AP’s were provided with comment on the draft BAR following submission of the application form (Regulation an opportunity to comment of the 40(3)). draft BAR.
Please refer to Appendix E-1 for the The final basic assessment report must include an issues and response report, as well as copies of and responses to comments received from all l&Aps, including these Comment and Response Report. comments.
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2 GOVERNANCE FRAMEWORK
The South African regulatory framework establishes well-defined requirements and standards for environmental and social management of industrial and civil infrastructure developments. Environmental protection functions are carried out by different authorities at both national and regional levels. The applicable legislation and policies are shown in Table 2-1 below. Table 2-1: Applicable Legislation and Policies
APPLICABLE LEGISLATION AND POLICY APPLICABILITY OF LEGISLATION
The Constitution of South The Constitution cannot manage environmental resources as a stand-alone piece of Africa (No. 108 of 1996) legislation, hence additional legislation was promulgated in order to manage the various spheres of both the social and natural environment. Each promulgated Act and associated Regulations are designed to focus on various industries or components of the environment to ensure that the objectives of the Constitution are effectively implemented and upheld in an on-going basis throughout the country. In terms of Section 7, a positive obligation is placed on the State to give effect to the environmental rights.
National Environmental In terms of Section 24(2) of the NEMA, the Minister may identify activities which may not Management Act (No. 107 of commence without prior authorisation. The Minister thus published GNR 327 (Listing Notice 1998) 1), 325 (Listing Notice 2) and 324 (Listing Notice 3) which identify listing activities that may not commence prior to authorisation (7 April 2017). The regulations outlining the procedures required for authorisation are published in GNR 326 [Environmental Impact Assessment Regulations (EIA)] (7 April 2017). Listing Notice 1 identifies activities that require a Basic Assessment (BA) process to be undertaken, in terms of the EIA Regulations, prior to commencement of that activity. Listing Notice 2 identifies activities that require a Scoping and Environmental Impact Reporting (S&EIR) process to be undertaken, in terms of the EIA Regulations, prior to commencement of that activity. Listing Notice 3 identifies activities within specific areas that require a BA process to be undertaken, in terms of the EIA Regulations, prior to commencement of that activity. WSP undertook a review of the listed activities according to the proposed project description to conclude that Listed Activity 2 and 12 of GNR 324 are considered applicable and therefore a BA process must be followed. An EA is required and is being applied for.
Listing Notice 3: GNR 324 Activity 2 – The development of reservoirs, excluding dams, with a capacity of more than 250 cubic metres— f. Mpumalanga (ii) Outside urban areas: (dd) Critical Biodiversity Areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (ff) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of National Environmental Management Protected Areas Act (No. 57 of 2003) (NEMPAA) or from the core area of a biosphere reserve, where such areas comprise indigenous vegetation; or Description: The reservoir will have a capacity of 14 400 cubic metre and will be situated in a Critical Biodiversity Area (CBA) area. Activity 12 – The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan. (f) Mpumalanga (ii) Within Critical Biodiversity Areas identified in bioregional plans.
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APPLICABLE LEGISLATION AND POLICY APPLICABILITY OF LEGISLATION
Description: An area in excess of 300 square metres of indigenous vegetation will be cleared within a CBA.
National Environmental The National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) Management: Waste Act (Act (NEM:WA) is subsidiary and supporting legislation to the NEMA. The Act is a framework No. 59 of 2008) legislation that provides the basis for the regulation of waste management. The Act also contains policy elements and gives a mandate for further regulations to be promulgated. On 29 November 2013 GNR 921 was promulgated (repealing GNR 718) which contains a list of waste management activities that, if triggered, require a Waste Management License (WML) and in turn a Basic Assessment (Category A activities) or S&EIR (Category B activities) process to be undertaken in terms of the NEMA EIA Regulations. Category C activities are required to comply with the Norms and Standards for Storage of Waste 2013 (GN 926) and do not require authorisation. It is anticipated that activities on the site will not trigger the NEM:WA. However, waste handling, storage and disposal during the construction and operational phase of the project must be undertaken in accordance with the requirements of this Act and the Best Practicable Environmental Option which will be incorporated into the site-specific Environmental Management Programme (EMPr)/Environmental Management Systems (EMS).
National Environmental The National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) Management: Biodiversity Act (NEM:BA) was promulgated in June 2004, within the framework of NEMA to provide for (No. 10 of 2004) the management and conservation of national biodiversity. The NEM:BA’s primary aims are for the protection of species and ecosystems that warrant national protection, the sustainable use of indigenous biological resources, the fair and equitable sharing of benefits arising from bioprospecting involving indigenous biological resources. In addition, the NEM:BA provides for the establishment and functions of a South African National Biodiversity Institute (SANBI). SANBI was established in terms of the NEM:BA with the primary purpose to report on the status of the country’s biodiversity and conservation status of all listed threatened or protected species and ecosystems. The construction of the proposed reservoir is located within a CBA. The CBA maps indicate the most efficient selection and classification of land portions requiring safeguarding in order to meet national biodiversity objectives. As such, a Biodiversity Assessment was undertaken as part of the BA process, with mitigation measures proposed.
National Forest Act (Act No. 84 The Act governs the management and protection of trees and forests. A forestry licence is of 1998) required for the removal of any protected tree species of concern. The Biodiversity Assessment conducted by The Biodiversity Company concluded that there are several individual nationally protected Marula trees present at the site. Therefore, a tree permit will be applied for due to the potential impact from the development of the reservoir.
National Water Act (Act No. 36 The National Water Act, 1998 (Act No. 36 of 1998) (NWA) provides the framework to of 1998) protect water resources against over exploitation and to ensure that there is water for social and economic development, human needs and to meet the needs of the aquatic environment. The Act defines a water resource to include watercourses, surface water, estuary or aquifer. A watercourse is defined in the Act as a river or spring, a natural channel in which water flows regularly or intermittently, a wetland, lake or dam into which, or from which, water flows, and any collection of water which the Minister may declare to be a watercourse. Section 21 of the Act outlines a number of categories which require a water user to apply for a Water Use License (WUL) and Section 22 requires a water user to apply for a General Authorisation (GA) with the DHSWS if they are under certain thresholds or meet certain
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APPLICABLE LEGISLATION AND POLICY APPLICABILITY OF LEGISLATION
criteria. The list of water uses applicable, that require a WUL under Section 21, are presented below: i) Storage of water. It is anticipated that a WUL will be required for the storage of water in the proposed reservoir under Section 21(b) of the NWA.
National Heritage Resource Act The National Heritage Resource Act (Act No. 25 of 1999) (NHRA) serves to protect national (Act No. 25 of 1999) and provincial heritage resources across South Africa. The NHRA provides for the protection of all archaeological and palaeontological sites, the conservation and care of cemeteries and graves by the South African Heritage Resource Agency (SAHRA), and lists activities which require any person who intends to undertake an activity/development to notify the responsible heritage resources agency and furnish details regarding the location, nature, and extent of the proposed development. In terms of Section 38 of NHRA, any person who intends to undertake a linear development exceeding 300 m in length or a development that exceeds 5 000 m2 must notify the heritage resources authority and undertake the necessary assessment requested by that authority. The construction area will be 3 933m2 and as such a heritage permit is not required. Construction activities should be conducted carefully, and all activities ceased if any archaeological, cultural and heritage resources are discovered. The SAHRA should be notified and an investigation conducted before any activities can continue.
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3 BASIC ASSESSMENT PROCESS
3.1 PROCEDURAL FRAMEWORK
As defined in Appendix 1 of the EIA Regulations, 2014 as amended, the objective of the impact assessment process is to, through a consultative process: — Determine the policy and legislative context within which the proposed activity is located and how the activity complies with and responds to the policy and legislative context; — Identify the alternatives considered, including the activity, location, and technology alternatives; — Describe the need and desirability of the proposed alternatives; — Through the undertaking of an impact and risk assessment process, inclusive of cumulative impacts, which focused on determining the geographical, physical, biological, social, economic, heritage, and cultural sensitivity of the sites, and locations within sites, and the risk of impact of the proposed activity, as well as technology alternatives on these aspects to determine— The nature, significance, consequence, extent, duration, and probability of the impacts occurring; and The degree to which these impacts— — Can be reversed; — May cause irreplaceable loss of resources; and — Can be avoided, managed or mitigated — Through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will impose on the sites, and location identified through the life of the activity, to— Identify and motivate a preferred site, activity and technology alternative; Identify suitable measures to avoid, manage or mitigate identified impacts; and Identify residual risks that need to be managed and monitored.
3.2 APPLICATION
The application phase consisted of completing the appropriate application form as well as the subsequent submission and registration of the application for EA with the MDARDLEA. MDARDLEA accepted the application and issued reference number 1/3/1/16/1E-226 on 30 September 2019. WSP notified the commenting authorities of the proposed project via a notification letter and by submitting the draft BAR. The commenting authorities include the: — Department of Environment, Forestry and Fisheries (DEFF); — DEFF: Biodiversity and Conservation Unit; — Mpumalanga Tourism and Parks Agency (MTPA); — Inkomati Water Management Area (WMA) Authority; — City of Mbombela Local Municipality; and — Ehlanzeni District Municipality. WSP has collate comments received during the public review phase (11 September 2019 to 14 October 2019) and compiled a Comments and Responses Report (CRR), which is included as Appendix E of this final BAR.
3.3 BASELINE ENVIRONMENTAL ASSESSMENT
The description of the environmental attributes of the project area was compiled through a combination of desktop reviews and site investigations. Desktop reviews made use of available information including existing reports,
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aerial imagery and mapping. Site investigations were undertaken by the specialist team in February and March 2019 to verify the desktop review information.
3.4 IMPACT ASSESSMENT METHODOLOGY
The BAR uses a methodological framework developed by WSP to meet the combined requirements of international best practice and the NEMA, Environmental Impact Assessment Regulations, 2014, as amended (GNR 326). As required by the EIA Regulations (2014) as amended, the determination and assessment of impacts is based on the following criteria: — Nature of the Impact; — Significance of the Impact; — Consequence of the Impact; — Extent of the impact; — Duration of the Impact; — Probability of the impact; — Degree to which the impact: can be reversed; may cause irreplaceable loss of resources; and can be avoided, managed or mitigated. Following international best practice, additional criteria have been included to determine the significant effects. These include the consideration of the following: — Magnitude: to what extent environmental resources are going to be affected; — Sensitivity of the resource or receptor (rated as high, medium and low): by considering the importance of the receiving environment (international, national, regional, district and local), rarity of the receiving environment, benefits or services provided by the environmental resources and perception of the resource or receptor); and — Severity of the impact: measured by the importance of the consequences of change (high, medium, low, negligible) by considering, inter alia; magnitude, duration, intensity, likelihood, frequency and reversibility of the change. It should be noted that the definitions given are for guidance only, and not all the definitions will apply to all of the environmental receptors and resources being assessed. Impact significance was assessed with and without mitigation measures in place. The detailed impact assessment methodology is included in Appendix I.
3.5 STAKEHOLDER ENGAGEMENT PROCESS
Stakeholder engagement (public participation) is a requirement of the BA process. It consists of a series of inclusive and culturally appropriate interactions aimed at providing stakeholders with opportunities to express their views, so that these can be considered and incorporated into the BA decision-making process. Effective engagement requires the prior disclosure of relevant and adequate project information to enable stakeholders to understand the risks, impacts, and opportunities of the proposed project. The objectives of the stakeholder engagement process can be summarised as follows: — Identify relevant individuals, organisations and communities who may be interested in or affected by the proposed project; — Clearly outline the scope of the proposed project, including the scale and nature of the existing and proposed activities;
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— Identify viable proposed project alternatives that will assist the relevant authorities in making an informed decision; — Identify shortcomings and gaps in existing information; — Identify key concerns, raised by Stakeholders that should be addressed in the specialist studies; — Highlight the potential for environmental impacts, whether positive or negative; and — To inform and provide the public with information and an understanding of the proposed project, issues and solutions.
3.5.1 STAKEHOLDER CONSULTATION
Stakeholders were identified and will continue to be identified through several mechanisms. These include: — Networking with local business owners, non-governmental agencies, community-based organisations, and local council representatives; — Field work in and around the project area; — Advertising in the press: — Lowvelder (13 September 2019). — Placement of community notices at the following locations: — Mbombela Public Library; — Along fence of preferred site; — Ngodwana Village; and — Sappi Ngodwana Mill Entrance. Sappi’s existing stakeholder database was used as the basis for public participation with Interested and Affected Parties (I&APs). All stakeholders identified to date have been registered on the project stakeholder database. The EAP endeavoured to ensure that individuals/organisations from referrals and networking were notified of the proposed project. Stakeholders were identified at the horizontal (geographical) and vertical extent (organisations level). A list of stakeholders captured in the project database is included in Appendix C. All concerns, comments, viewpoints and questions (collectively referred to as ‘issues’) that were received, have been documented and responded to in a CRR, which is included as Appendix E of this final BAR. A Biodiversity Assessment was conducted as a specialist study, the findings and recommendations have been incorporated in this final BAR. Table 3-1 below shows details of site notices used for stakeholder notification. Table 3-1: Site Notice Locations
PHOTOGRAPHS LOCATION CO-ORDINATE ZOOMED IN BROADER AREA VIEW Mbombela Public 25°28'22.71"S Library 30°58'33.68"E
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PHOTOGRAPHS LOCATION CO-ORDINATE ZOOMED IN BROADER AREA VIEW Along fence of 25°34'41.92"S preferred site 30°39'56.28"E
Ngodwana 25°34'17.79"S Village 30°40'32.99"E
Sappi Ngodwana 25°34'40.36"S Mill Entrance 30°39'51.54"E
The site notices served to inform the occupiers of the land along with the newspaper advert and existing stakeholder database. In accordance with GN. R 326 41(2)(c) of Chapter 6 an advert was placed in a newspaper, the Lowevelder, published 13 September 2019. The proof of the advert has been attached as Appendix E of this Final BAR.
3.5.2 PUBLIC REVIEW
The draft BAR was placed on public review for a period of 30 days from 11 September to 14 October 2019, at the Sappi Ngodwana Mill and Mbombela Public Library. The report was also made available on the WSP website (http://www.wsp-pb.com/en/WSP-Africa/What-we-do/Services/All-Services-A-Z/Technical-Reports/). All registered stakeholders and authorising/commenting state departments were notified of the public review period as well as the locations of the draft BAR via email. Proof of these notifications are attached in Appendix E. This Final BAR will be submitted to the MDARDLEA for decision making within 107 days on 6 December 2019. It will also be sent to the relevant commenting authorities as well as the interested and affected parties (I&APs) for their perusal. Since the commenting period expired, any comments should be sent directly to the MDARDLEA Case Officer, (Ms M Masango on 013 759 4000).
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4 PROJECT DESCRIPTION
4.1 NEED AND DESIRABILITY OF THE PROJECT
The existing Water Treatment system does not have the capacity to meet the instantaneous water demand of 52 ML/d and calculated medium-term and long-term average demand of 56.4 ML/d, which is to meet the future demand of the Mill. The Water Treatment Plant Project is being handled in a phased approach as follows: — Phase 0 is the replacement of the 350 mm raw water transfer pipeline with a similar size pipe the replacement was completed in 2018. — Phase 1 which includes a pump upgrade and an additional pipeline installation between the treatment plant and the mill reservoir. — Phase 2 is the additional storage reservoir with a balancing line to the existing 4.5 ML mill reservoir. The proposed location of the new reservoir provides additional benefit of free gravitational flow at optimal pressure into the mill. Phase 2 will increase the buffer capacity and increase the current systems residence time of 1.2hrs capacity before plant shutdown (95% to 50%). — Phase 3 is the upgrade of the “Old” plant which includes an additional 11 ML sand filter and 21 ML clarifier. This will improve the treated water quality and increase the installed Water Treatment Plant capacity from 52 ML (“New” plant 42 ML and “Old” plant 10 ML) to 63 ML (“New” plant 42 ML + “Old” plant 10 ML existing + “Old” plant additional sand filter 11ML). This report is applicable to Phase 2 only.
4.2 LOCATION OF THE PROPOSED PROJECT
The reservoir will be situated on Farm Grootgeluk, Portion 0, Number 477 (Figure 4-1). The project area falls within the Ehlanzeni District Municipality in the Ngodwana area, Mpumalanga. The land uses surrounding the project area consists predominately of housing developments and a Sappi paper mill to the north of the project area. A portion of the proposed site has already been cleared as part of the operation of the existing reservoir and the remainder of the site consists mainly of indigenous vegetation. The reservoir will have a footprint of 4 659 m2 and Sappi has made an attempt to avoid the mountain woodlands as far as practicable, however due to the required capacity of the reservoir to meet the demands of the Mill, an area of 616 m2 of mountain woodlands will be impacted on by the reservoir.
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Figure 4-1: Sappi Ngodwana Reservoir Location
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The proposed steel reservoir will be located on the land parcel outlined in Table 4-1 within the confines of the site boundary. Table 4-1: Cadastral Information of the site DETAILS REQUIRED AS PER GNR 326 ANNEX 1 (3) DETAIL
21 Digit Surveyor General Code of each T0JT00000000477000000 Cadastral Land Parcel
Physical Address and Farm Name Farm Grootgeluk, Portion 0, Number 477 Land use Zoning Agricultural
4.3 LAYOUT AND DESCRIPTION
The Mill uses water from the Ngodwana River, flowing into and stored in the Ngodwana Dam (owned and managed by Sappi). The water from the Ngodwana Dam is then treated at the fresh water treatment facility by flocculation followed by clarification (Figure 4-2). Lime addition for pH control occurs before the water is filtered through a sand filter. Disinfection is achieved by chlorination. The water from the treatment facility is currently sent to the existing reservoir prior to distribution for use at the mill. The proposed new 14.4ML reservoir is required, in addition to the existing reservoir, in order to increase the buffer capacity to support the mill’s processes. The design drawings of the proposed reservoir are included in Appendix H, and it is anticipated that the steel reservoir will be similar to the ones depicted in Figure 4-3. It is proposed that the tie in from the proposed reservoir to the existing pipeline will be located directly beneath the reservoir, as per the design drawings.
Figure 4-2: Mill Water Process Flow Diagram (van der Merwe-Botha & Wille 2017)
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Figure 4-3: Examples of Steel Tank Reservoirs
4.3.1 CONSTRUCTION ACTIVITIES
The construction process will follow industry standard methods and techniques. Key activities associated with the construction process are described in Table 4-2. Table 4-2: Construction Activities
ACTIVITY DESCRIPTION Site clearance Site clearance of the small shrubs and grass onsite will be done in order to expose the surface where the reservoir will be constructed. During the construction phase the protected trees present at the site will be cleared and relocated. The topsoil will be stripped and stored at a demarcated area at the Mill for future use. Contractor’s facilities and These will be strictly located within already cleared areas at the existing reservoir. Activities materials lay-down areas within these areas are likely to include: — Temporary offices and administration facilities (e.g. containers, portable cabins). — General materials storage and laydown areas. — Construction of chemicals storage facilities (oil, grease, solvents etc.) and associated infrastructure (bunds, secured / roofed areas etc.). — Chemical toilets and showering facilities (linked to conservancy tanks – removal of contents by exhauster vehicle and disposal at permitted facility). Temporary waste storage areas; these shall be established and managed in accordance with Environmental management Programme (EMPr) requirements. Site access The proposed reservoir site is located South of the Sappi Ngodwana Mill and is close to the N4 Road. Access to the site will be via this N4 road and no new access roads will be required for the project as the proposed reservoir is to be located close to the existing reservoir which already has an access road. Sourcing of construction Bulk materials (aggregate, cement, steel etc.) will be sourced from existing lawful commercial materials and equipment sources; there will be no direct mining, harvesting or extraction of natural resources.
Where possible, equipment will be sourced locally based on the latest information on South African Rand/US Dollar exchange rate. Equipment will be purchased outside of South Africa where this makes commercial sense. Decommissioning of The removal activities may include decontamination and interim storage prior to scrapping or equipment removal off-site.
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ACTIVITY DESCRIPTION Excavation and earthworks Subject to the determination of founding specifications for the reservoir to be constructed, it is envisaged that earthworks will be required. This is likely to entail: — Levelling and compaction using heavy machinery/earthmoving equipment. — Potential for excavations and trenching in order to prepare foundations. — Piling/drilling depending on the identified construction/founding technique. Use of general mechanical This will be undertaken within construction areas and includes the use of generators, cutting equipment and welding equipment, compressors etc. Working Hours Due to the heavy industrial nature of the Mill, it is not envisaged that daytime working hours would need to be adhered to; the exception would be in the case of excessively noisy activities which would be limited to normal daytime working hours, if practical. Water demand, supply and During construction, the site personnel will have a contractor laydown area close to the storage proposed reservoir site. Water for use on the project (contractor’s use) will be supplied from the Sappi Ngodwana Mill and will be stored at the site camp. Electricity demand and The site camp will mainly be constituted of storage containers for materials, ablution facilities Supply and the site office. Power to the main contractor’s camp and site office will be supplied via use of a diesel powered generator.
4.3.2 OPERATIONAL ACTIVITIES
During the operational phase, water is fed to the clean water reservoir from the fresh water treatment facility for storage until it is required at the Mill. Pumps will not be required to feed the Mill as the proposed location is at higher altitude, thereby gravity feeding is undertaken. Activities around the reservoir will be limited to maintenance requirements.
4.3.3 DECOMMISSIONING ACTIVITIES
Decommissioning will be considered as part of the decommissioning of the broader facility which will be subject to a separate authorisation and impact assessment process as per Activity 31 of Listing Notice 1, GNR 327.
4.3.4 WASTE MANAGEMENT
Waste Management at the project site will be undertaken in line with the EMPr to ensure the correct disposal of general and hazardous waste generated on the project. Waste will mainly be generated during both construction and decommissioning activities when contractors spend a considerable amount of time on the site. During operation, contractors are only on the site for a limited amount of time as and when maintenance is required. The following waste types are anticipated to be generated: — Hydrocarbons (Contaminated soil); — Contaminated PPE; — Office waste; and — Food waste.
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5 ALTERNATIVES
In terms of the EIA Regulations, feasible alternatives are required to be considered within this final BAR. All identified, feasible alternatives are required to be evaluated in terms of social, biophysical, economic and technical factors. However, since this section discusses the alternatives and provides key reasons (motivation) for elimination upfront, as they will not be feasible, only the preferred option will be assessed in the impact assessment in Section 7. A key challenge of the Basic Assessment (BA) Process is the consideration of alternatives. Most guidelines use terms such as ‘reasonable’, ‘practicable’, ‘feasible’ or ‘viable’ to define the range of alternatives that should be considered. Essentially, there are two types of alternatives: — Incrementally different (modifications) alternatives to the project; and — Fundamentally (totally) different alternatives to the project. Fundamentally different alternatives are usually assessed at a strategic level, and EIA practitioners recognise the limitations of project-specific BAs to address fundamentally different alternatives.
5.1 SITE LOCATION
The following locations / layout configurations were identified as potential alternatives by Sappi in conjunction with WSP (Figure 5-1): 1 Existing platform located East of the existing reservoir, partially within dense mountain woodland. 2 Area North of the existing platform at the existing reservoir, in the transformed CBA. 3 Adjacent to Water Treatment Works. These potential alternatives were evaluated in terms of a series of pertinent environmental, economic and technical criteria. A simple qualitative ranking system was used to portray whether each alternative was advantageous, disadvantageous, or fatally flawed in terms of the criterion being evaluated. The results of the evaluation are provided in Table 5-1. Table 5-1: Technical, Economic and Environmental Evaluation of Potential Alternatives
ASSESSMENT CRITERIA SITE 1 SITE 2 SITE 3 KEY A = ADVANTAGE / D = DISADVANTAGE / F = FATAL FLAW Environmental: D A Ecological The reservoir will be located The reservoir will be located within a transformed CBA Sensitivity partially within the dense mountain woodlands which is See Figure 5-2 considered an irreplaceable CBA. and Figure 5-3 Environmental: A D D Area of The majority of the proposed site A portion of the proposed site has A portion of the site has already Disturbance has already been cleared and already been cleared and levelled been cleared as part of the Water levelled as part of the as part of the construction and Treatment Works, however the construction and operation of the operation of the existing reservoir majority of the area will have to existing reservoir. The remainder The remainder of the site consists be cleared. The existing access of the site consists mainly of mainly of indigenous vegetation. road will be used. indigenous vegetation. It is Additional vegetation will have to envisaged that the reservoir will be cleared in order to level and be situated on plinths on the stabilise the reservoir and to northern side in order to reduce reroute the existing access road vegetation clearance, refer to (Figure 5-4). Figure 5-5 for the reservoir
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ASSESSMENT CRITERIA SITE 1 SITE 2 SITE 3 KEY A = ADVANTAGE / D = DISADVANTAGE / F = FATAL FLAW layout. The existing access road will be used.
Economics – A D D Construction and Earthworks terracing which was Earthworks terracing for this area Earthworks for this area has not Capital Cost completed during the construction has not been undertaken and been undertaken and additional of the existing reservoir will be significant construction and construction and capital costs will utilised with limited further capital costs will be required in be required. earthworks required. order to situate the reservoir on an area with a steep incline on In addition, additional pumps, which no earthworks have been pipelines and pressure undertaken. management equipment will have to be constructed between the The existing access road will also proposed reservoir and the have to be relocated as there is existing reservoir. insufficient space to place the proposed reservoir between the existing reservoir and the access road. Economics - A D Operational Cost The water from the reservoir will gravity feed to the Mill. There will The water from the reservoir will be minimal operational costs aside from normal maintenance. have to be pumped to the higher elevation in order to gravity feed to the mill along with the water from the existing reservoir. Additional water pressure management equipment will have to be managed at the existing reservoir site. Economics - A D Balancing of The proposed extension will be at the same level as the existing Additional water pressure water between reservoir and therefore no additional pressure/balancing control management equipment will have existing and installations are required to the water system. This reduces the risk if to be installed at the existing proposed water supply failure to the Mill. reservoir site in order to ensure reservoir that the feed to the Mill is balanced. Technical – A D Operational Integration of pipework and controls is facilitated without extensive The installation of additional Complexity additions to the water supply system. pumps and pressure management equipment will result in additional operational complexities.
Increased water supply failure risk to the Mill when there is a power failure, as pumping to the Mill will not be able to take place.
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Based on the analysis provided in the table above, none of the three sites are fatally flawed. — Site 1 is advantageous in terms of all the technical and economic criteria. It is also advantageous in terms of the relatively small area of environmental disturbance. The site is however disadvantaged due to its location within a sensitive ecological environment (dense mountain woodlands). — Site 2 shares most of the technical and economic advantages of Site 1, with the exception that extensive earthworks will be required during construction as well as relocation of the access road. This will significantly increase capital costs and the area of environmental disturbance. Whilst the area of environmental disturbance will be larger, the site is not as ecologically sensitive as Site 1, falling into a transformed CBA. — Site 3 is the most environmentally preferred, having a similar footprint to Site 1 and falling in a transformed CBA. However, this option is disadvantaged in terms of all the economic and technical criteria. Notably, the technical complexity would significantly increase the risk of water supply failure to the Mill, and is therefore not considered a reasonable option. Sappi’s preferred technical and economic option is site 1 on the basis of the evaluations provided above. It is noted that the biodiversity specialist has confirmed in writing (Appendix J) that the net ecological impact associated with the development of site 1 would in fact be lower than the impact on sites 2 and 3 due to the relatively larger extent of vegetation clearance at these sites. On this basis, Site 1 is the most advantageous option across all economic, technical and environmental criteria. Sites 2 and 3 are not reasonable and were therefore not considered as alternatives in the Basic Assessment.
Figure 5-1: Potential Locations / Layouts Alternatives
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Figure 5-2: Mpumalanga Biodiversity Sector Plan
Figure 5-3: Habitat Delineation
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Figure 5-4: Reservoir Elevation
Figure 5-5: Proposed Reservoir Layout
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5.2 NO-GO ALTERNATIVE
Should the reservoir not be constructed, the status quo will remain and there will be an increased risk of down- time to the Mill due to the unavailability of water. This increased down time has an economic impact on Sappi. Should the reservoir not be constructed, none of the anticipated impacts, such as the relocation of protected trees and vegetation clearance, will occur.
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6 BASELINE ENVIRONMENT
This section provides a description of the baseline environment of the project area. The descriptions encompass the geographical, physical, biological, social, economic, heritage and cultural aspects in accordance with Appendix 1 of GNR 326. The data in this section was acquired from the Integrated Water and Waste Management Plan (IWWMP) conducted by WSP in 2018, however, the sections were revised where up-to-date information and data are available.
6.1 CLIMATE
6.1.1 TEMPERATURE
For the period January 2015 to December 2017, an average summer temperature of around 22 °C and an average winter temperature of around 13 °C was recorded (Table 6-1 and Figure 6-1). Minimum temperatures ranged from -2 to 11 °C in winter, with maximum temperatures ranging from 24 to 38°C in summer. Table 6-1: Average temperatures (°C) at Sappi Ngodwana for January 2015 – December 2017
Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2015 23 23 21 18 15 11 13 16 18 21 21 23 2016 23 23 22 19 15 13 12 14 19 20 21 22 2017 22 22 20 19 14 12 13 15 18 19 19 21
Figure 6-1: Average, maximum and minimum temperatures (°C) at Sappi Ngodwana for the period January 2015 – December 2017
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6.1.2 RAINFALL
Monthly rainfall and humidity for the period January 2015 to December 2017 is illustrated in Figure 6-2. Sappi Ngodwana falls within a summer rainfall region, receiving most of its rainfall during the summer months. The lowest rainfall levels are experienced during the winter months (June to August) (Table 6-2). Relative humidity is generally moderate to high, with values ranging from 69% during summer and 79% during winter. Table 6-2: Average monthly rainfall (mm) at Sappi Ngodwana for January 2015 – December 2017
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2015 92 112 40 42 6 1 3 2 32 35 55 107 2016 63 58 68 35 9 1 8 3 2 52 252 221 2017 220 192 58 22 59 8 3 1 11 70 140 168
Figure 6-2: Monthly rainfall (mm) and average humidity (%) at Sappi Ngodwana for the period January 2015 – December 2017
6.1.3 LOCAL WIND FIELD
Figure 6-3 presents the period wind roses for Sappi Ngodwana for the period January 2015 – December 2017. Dominant winds originated from the south (16% of the time) and south-southwest (9% of the time). Wind speeds for the period were moderate to fast, generally exceeding 6 m/s. Calm conditions (wind speeds less than 1 m/s) occurred relatively frequently (29% of the time), as is typical of valley conditions. Wind roses are useful for illustrating the prevailing meteorological conditions of an area, indicating wind speeds and directional frequency distributions. In the following wind roses, the colour of the bar indicates the wind speed while the length of the bar represents the frequency of winds blowing from a certain direction (as a percentage). Lakes Environmental WRPLOT View v7.0.0 was used to depict period, diurnal and seasonal wind roses for Sappi Ngodwana CALMET-ready MM5 data for the period January 2015 – December 2017.
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Figure 6-3: Period wind rose at Sappi Ngodwana for January 2015 – December 2017 Figure 6-4 presents the diurnal variations in winds at Sappi Ngodwana for the period January 2015 – December 2017. Dominant southerly winds occur during the early (00:00 – 06:00) and late (06:00 – 12:00) morning hours. During the afternoon (12:00 – 18:00), dominant north-easterly winds are observed, with a shift to dominant easterly winds in the evening (18:00 – 24:00). Winds are generally faster in the morning, with slower winds noted in the afternoon and evening.
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Diurnal wind roses at Sappi Ngodwana 00:00 – 06:00 06:00 – 12:00
12:00 – 18:00 18:00 – 24:00
Figure 6-4: Diurnal wind roses at Sappi Ngodwana for the period January 2015 – December 2017 Figure 6-5 presents the diurnal variations in winds at Sappi Ngodwana for the period January 2015 – December 2017. Dominant southerly winds occur during autumn (March – May) and winter (June – August) with a shift to dominant north-easterly and easterly winds in spring (September – November) and summer (December – February), respectively.
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Seasonal wind roses at Sappi Ngodwana Summer Autumn
Winter Spring
Figure 6-5: Seasonal wind roses at Sappi Ngodwana for the period January 2015 – December 2017
6.2 GEOLOGY
6.2.1 LOCAL AND SITE GEOLOGY
The proposed project site is underlain by transported colluvial and alluvial soils over residual soils that grade into the sedimentary bedrock of the basal formations of the Transvaal Sequence. The Black Reef Quartzite Formation, which is the lowermost member of the Transvaal Sequence, underlies the site. This resistant, hard rock formation dips fairly steeply to the west. It outcrops at or close to ground surface in the north eastern portion of the site but occurs at depths of greater than 48 metres in the western portion of the site. The Oaktree formation of the Malmani Subgroup of the Chuniespoort Group conformably overlies the Black Reef Quartzite Formation. This formation comprises dolomite with interlayered chert and silicified siltstone and a basal ferruginised sandstone layer. Complete weathering of the Oaktree Formation dolomite, chert and siltstone has resulted in the development of residual soils known as “dolomite chert veriduum” and comprises red silty clays containing chert gravel that grade with depth into angular chert fragments in a clay matrix.
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6.3 SURFACE WATER
Information relating to surface water was acquired from WSP’s IWWMP report on the Sappi Ngodwana site.
6.3.1 WATER MANAGEMENT AREA
The Ngodwana Mill falls within the Inkomati-Usuthu Water Management Area. The primary drainage region is X. The major rivers draining the Inkomati-Usuthu WMA are the Nwanedzi, Crocodile (East), Komati, Sabie and Sand Rivers flowing in an easterly direction to join the Inkomati River in Mozambique. The Mill and its associated waste site and irrigation area are located within the Elands River sub-catchment of the Crocodile River Drainage Basin. The Elands River is a tributary of the Crocodile River, which is regarded as a stressed catchment. The Elands River flows in a north-easterly direction until its confluence with the Crocodile River, approximately 15 km north-east of the Mill. The three related catchments are: — Crocodile River; — Elands River; and — Houtbosloop. The majority of the Mill and the Macro Dump fall within quaternary catchment X21J, with the remainder of the Mill’s activities being located within X21K. The Ngodwana Dam on the Ngodwana River is northeast of the Macro Dump in the adjacent quaternary catchment (X21H) and augments water supply in the catchment. The confluence of the Ngodwana River with the Eland River is downstream of the Mill.
6.3.2 SURFACE WATER HYDROLOGY
As mentioned above, the study area spans three quaternary catchments; X21H, X21J and X21K. Quaternary catchment X21H is mainly drained by the Ngodwana River flowing in a north-westerly direction, joining the Elands River. Quaternary catchment X21J is mainly drained by the Elands River, while quaternary catchment X21K is mainly drained by the Elands River flowing in a north-easterly direction and Lupelule Tributary flowing in an easterly direction, joining the Elands River. Sappi is located on the Elands River upstream of the confluence of the three above-mentioned rivers. A number of unnamed tributaries drain the mountainous areas to the south and north of the valley. There are five springs (named as Allen’s Eye, Fraser’s Eye, Northern Eye, Eye X and Eye Y) in the project area.
6.3.3 SURFACE WATER QUALITY
In April 2013, the DHSWS commenced with the Water Resource Classification (WRC) process for the Inkomati River Catchment. This classification of water resources was undertaken, as it is a requirement of the NWA, in order to establish clear goals relating to the quality of the relevant water resource, while achieving a balance between the need to protect and sustain water resources and the need to develop and use them. This is done by promulgating Resource Quality Objectives (RQOs), which are intended as numerical and/or descriptive statements about the biological, chemical and physical attributes to characterise the water resource for the level of protection defined by its Management Class. The WRC process for the Inkomati Catchment entailed the identification of specific Management Resource Units (MRUs), which are homogenous sub-quaternary (SQ) reaches of a river course that can be grouped into a single unit for the purpose of assigning a management class. On this basis, the SQ reaches upstream (X21G-01073 and X21J-01013) and downstream (X21K-01035 and X21K-00997) of the Mill were evaluated and consequently grouped into a single MRU with the assigned Management Class “Class I: water resource is one which is minimally used, and the overall ecological condition of that water resource is minimally altered from its pre- development condition.”
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6.4 GROUNDWATER
The hydrogeological regime in the area can be broken down into four main aquifer units: — Alluvial and colluvial aquifers — Alluvial and colluvial aquifers are present in all the exploratory boreholes. Groundwater is associated with the gravel and boulder horizons, which produce modest blow yields (less than 5L/s). This is the only aquifer that is in direct hydraulic continuity with the Elands River and can therefore directly recharge the river through baseflow contribution. Due to the areal extent, this aquifer is important for overall groundwater recharge. — Dolerite aquifers — Locally, the dolerite may form an aquifer in weathered or fractured zones. A water strike with a blow yield of 7L/s was encountered in a borehole drilled into the base of completely weathered dolerite. Yields in these types of aquifers tend to be highly variable and are dependent on the degree of fracturing and/or weathering. They are typically limited in horizontal extent. — Contact dolerite/dolomite aquifers — In each of the boreholes where dolerite intrusions were intersected, a water-bearing horizon at the dolerite/dolomite contact was encountered. Blow yields in excess of 5L/s were recorded. This contact aquifer is important since it was encountered in many of the boreholes. — Dolomite aquifer — Dolomite constitutes a major regional aquifer underlying the valley, capable of delivering large volumes of water. Widespread weathering and karstification within the dolomite and faulting have produced highly permeable conditions. Since the dolomite aquifer is in direct hydraulic continuity with the overlying aquifer, the aquifer is vulnerable to contamination from site activities. A number of exploratory boreholes intersected aquifers within the dolomite and chert. Blow yields in excess of 20L/s and as high as 50L/s were recorded. The dolomite aquifer gives rise to the springs originating at the various eyes identified throughout the area. Two groundwater levels have been established within the area; a shallow level of 25 to 50 mbgl, associated with the artificial aquifer within the upper colluvium layer maintained by the irrigation effluent, and a deeper level of about 70 to 80 mbgl associated with the dolomite aquifer. The general groundwater flow direction is from SE to NW, down gradient towards the drainage and, eventually, the Elands River. During their 2015 investigation, Digby Wells found that the groundwater in the project area was not used for human consumption, livestock watering or irrigation.
6.5 LAND-USE
The majority of the land immediately surrounding the Mill is owned by Sappi and used for various activities related to the Mill, such as labour quarters (Table 6-3) and offices. There are a number of privately-owned farms surrounding the Sappi land. These farms vary in uses from grazing and cultivation, to tourism activities (including accommodation and hiking). The N4 national highway passes directly through Ngodwana. The N4 is a primary route for tourists traveling into Mpumalanga, especially to the Kruger National Park, and to Mozambique. Figure 6-6 illustrates the surrounding land uses and Figure 6-7 illustrates the surrounding residential receptors (500m to 1 500m buffer). Table 6-3: Table Residential Areas
RESIDENTIAL AREAS DESCRIPTION Ngodwana Village The ‘Village”, as it is known, comprises Sappi-owned formal housing, including small gardens, tarred roads, as well as a primary school, sports and social facilities. The Village has only three access points, which are strictly monitored by security guards. The population is characterised by mixed racial groups and comprises family and single units. The majority of residents are permanent employees at the mill, and therefore live in the Village with their families.
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RESIDENTIAL AREAS DESCRIPTION New & Old Jabulani These two areas were constructed to provide housing for semi-skilled and skilled permanent and contract staff at the mill. The residents here are predominantly Black African males, who have travelled alone from other provinces to work at the Mill. New and Old Jabulani comprise formal, adjoining housing units, and are monitored by 24-hour security. Old Jabulani also has an extension comprising 14 family units. Mbokodo The Mbokodo village comprises family units for Mill and forestry contractor staff members who chose to settle with their families near the Mill. The area has 24-hour security, and is located away from the other areas, so as to remain peaceful and family-orientated. Bamjees The Bamjees informal settlement developed as a result of casual labourers and work-seekers relocating to this area during periods of high labour demand and settling informally on privately-owned land. This was originally allowed, as there were approximately 10 formal houses constructed at the site and rent was paid to the previous owner (neighbouring farmer). Subsequently, due to the previous owner abandoning the property, informal dwellings began to be built, and the shop and petrol garage were replaced by a “spaza” shop and tavern. This property has subsequently been reallocated to some of the tenants who had established rights there. There are approximately 350 people living in the Bamjees settlement and is predominantly comprised of women. The settlement appears to have become known as a hub of ‘undesirable activities’ within Ngodwana. The spaza shop and tavern service the numerous truck drivers who travel along the N4 between Johannesburg and Maputo, Mozambique. People involved in unregulated and illegal activities, such as sex-workers and diesel thieves, are also drawn to this area. Spearville Spearville is a hostel for the farm workers who work at the Mill effluent and cattle farm. Rural area Rural area comprises old farm dwellings that are occupied by Mill employees as alternative housing to the Ngodwana village.
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Figure 6-6: Land Use
Figure 6-7: Surrounding Residential Areas
6.6 AMBIENT AIR QUALITY
Sappi undertakes continuous ambient monitoring at the Sappi Training Centre, as well as adhoc passive sampling. The continuous monitoring station measures SO2, NO2, TRS and PM10 and PM2.5.
NO2 concentrations during the monitoring period (2012-2014) remained low, with no exceedances of the relevant standards monitored. SO2 concentrations were high in 2014 and 2015, with exceedances of the annual standard occurring in both years, as well as the permitted number of hourly and daily exceedances being exceeded in both years. PM10 and PM2.5 concentrations are high, with exceedances of the annual standards occurring in all monitored years, while the permitted number of daily exceedances were exceeded for both parameters in all years. The exceedances must be viewed with caution due to the low data recovery in 2014 and 2015. Further to the continuous monitoring undertaken at the Sappi Training Centre, passive diffusive sampling was undertaken in 2012 – 2014, with monitoring undertaken for SO2, NO2, HCl and H2S. The monitoring was conducted at various locations, mostly focusing on neighbouring sensitive receptors, in line with those receptors selected in the dispersion modelling. All monitored concentrations remain well below their respective standards or guidelines, with NO2 concentrations being the most elevated. SO2 concentrations monitored at the receptors are substantially lower than those monitored at the continuous monitoring station. Sappi Single Quarters is the nearest receptor, although concentrations are substantially lower than those monitored at the continuous station, possibly due to the short sampling period of the passive sampling.
6.7 NOISE
The information in this section are obtained from WSP’s Acoustic Impact Assessment conducted in May 2015 for Sappi at the Ngodwana Mill. Daytime Noise Monitoring – Receivers.
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6.7.1 DAY-TIME NOISE MONITORING – RECEIVERS
The results from the daytime noise monitoring performed at each receiver identified in the vicinity of Sappi are presented in Figure 6-8. Sound level measurements were logged, and noise sources identified. In this instance, noise levels measured over the 15-minute period were considered representative of the reference period. Noise levels at all locations were assessed against the SANS 10103 typical rating level for noise (SANS, 2008) for urban receptors (with one or more of the following: workshops, business premises and main roads) for daytime (60 dB LAeq,1hour). During the monitoring period, calm, clear conditions were observed with the average ambient air temperature being estimated at 24 °C.
Figure 6-8: Daytime Noise Monitoring Results. LAeq is compared with the SANS 10103 guideline
The highest average (LAeq,15minute) noise level of 64.0 dB was recorded at the Ngodwana Shopping Centre (receiver 8) while the lowest average (LAeq,15minutes) noise level of 47.6 dB was measured at the Ngodwana Dam (receiver 5). Average ambient noise levels (LAeq) measured at Upper Ngodwana Village (receiver 7) and Ngodwana Shopping Centre (receiver 8) were above the SANS urban guidelines, while sound levels measured at all other points were below the SANS urban guidelines. Key noise sources during the daytime period included people walking and talking, insects and birds, and vehicles traveling along the main road (N4) as well as the road to Kaapschehoop. The Mill could be heard operating at all monitoring points.
6.7.2 NIGHT-TIME NOISE MONITORING – RECEIVERS
The results from the night-time noise monitoring performed at each receiver identified in the vicinity of Sappi are presented in Figure 6-9. Sample points were identical to the daytime monitoring points for consistency. Night- time noise levels at all locations were compared with the SANS 10103 (2008) typical rating level for noise for urban receptors (with one or more of the following: workshops, business premises and main roads) (50 dB LAeq,1hour). During the monitoring period, calm and clear conditions were observed to occur, clear skies and average ambient air temperature was estimated at 16 °C.
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Figure 6-9: Night-time noise monitoring results. LAeq is compared with the SANS 10103 guideline.
The highest average (LAeq,15minute) noise level of 60.7 dB was recorded at Upper Ngodwana Village (receiver 7) while the lowest average (LAeq,15minutes) noise level of 45.5 dB was measured at the Ngodwana Dam (receiver 5). Average ambient noise levels (LAeq) measured at the Waste Removal Site Office (receiver 2), Upper Ngodwana Village (receiver 7), Ngodwana Shopping Centre (receiver 8) and New Jabulani Hostel (receiver 9) were above the SANS urban guidelines for night-time, while sound levels measured at all other points were below the SANS urban guidelines for night-time. Key noise sources during the night-time period included people walking and talking, insects and vehicles traveling along the main road (N4) as well as the road to Kaapschehoop. The Mill could be heard operating in the background at all monitoring points.
6.8 BIODIVERSITY
The Biodiversity Company conducted a terrestrial baseline and impact (risk) for the proposed project. A wet season terrestrial biodiversity survey was conducted in February 2019. The survey primarily focussed on the development footprint area, referred to as the project area herein. The identification and description of any sensitive receptors were recorded across the project area, and the manner in which these sensitive receptors may be affected by the activity was also investigated. The Biodiversity Assessment is attached as Appendix F.
6.8.1 FLORA
The botanical study encompassed an assessment of all the vegetation units and habitat types within the project area. The focus was on a biodiversity assessment of habitat types as well as identification of any Red Data species within the known distribution of the project area. Due to the survey being conducted in the wet season this represented a limitation to the number of species identified. The methodology included the following survey techniques: — Sensitivity analysis based on structural and species diversity; and — Identification of potential floral red-data species. The vegetation assessment was conducted throughout the extent of the project area and a 200 m area surrounding the direct project area. The habitat types identified during the field survey can be seen in Figure 6-10. The project area was divided into three habitats classed as follows; degraded, dense mountain woodlands and transformed. A portion of project area has been transformed to a large extent, mainly due to anthropogenic impacts. Existing water treatment works infrastructure, maintenance roads and human presence have had an impact on these areas, and they are considered to have a low ecological state. Lantana camara (Lantana) dominated most of this habitat and many other alien invader plants, such as Bidens pilosa and Psidium guajava, could be found throughout. The
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degraded areas are regarded as areas where their ecological state has been degraded, but not entirely transformed. The degradation of these areas can predominately be attributed to anthropogenic impacts. This habitat is in a semi- natural ecological state and continues to function as a refuge for fauna and, if left undisturbed, will continue recovering to a more natural state. Dense Mountain Woodland is habitat that still contains natural vegetation and plays a crucial role in the ecosystem, i.e. can still be defined as a functioning CBA (Figure 6-11).The importance of this habitat to collectively provide refuge, food and corridors for dispersal within the local area is very high and is thus regarded as sensitive. A total of 61 tree, shrub and herbaceous plant species were recorded in the project area during the field assessment. Plants listed as Category 1 alien or invasive species under the National Environmental Management: Biodiversity Act (NEM:BA) appear in green text.
Figure 6-10: Pictures representing the 3 habitat types identified: A) Dense Mountain Woodland, B) Degraded, C & D) Transformed The majority of project area falls within a CBA-Irreplaceable, with a small portion to the East which is considered a Heavily Modified Areas (HMA) according to the Mpumalanga Biodiversity Sector Plan (MBSP) Terrestrial C- Plan (Figure 6-11).
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Figure 6-11: The project area superimposed on the MBSP (MTPA, 2014)
ALIEN AND INVASIVE PLANTS Declared weeds and invader plant species have the tendency to dominate or replace the canopy or herbaceous layer of natural ecosystems, thereby transforming the structure, composition and function of these systems. Therefore, it is important that these plants are controlled and eradicated by means of an eradication and monitoring programme. Some invader plants may also degrade ecosystems through superior competitive capabilities to exclude native plant species. Below is a brief explanation of the three categories in terms of the NEM:BA: — Category 1a: Invasive species requiring compulsory control. Remove and destroy. Any specimens of Category 1a listed species need, by law, to be eradicated from the environment. No permits will be issued. — Category 1b: Invasive species requiring compulsory control as part of an invasive species control programme. Remove and destroy. These plants are deemed to have such a high invasive potential that infestations can qualify to be placed under a government sponsored invasive species management programme. No permits will be issued. — Category 2: Invasive species regulated by area. A demarcation permit is required to import, possess, grow, breed, move, sell, buy or accept as a gift any plants listed as Category 2 plants. No permits will be issued for Category 2 plants to exist in riparian zones. — Category 3: Invasive species regulated by activity. An individual plant permit is required to undertake any of the following restricted activities (import, possess, grow, breed, move, sell, buy or accept as a gift) involving a Category 3 species. No permits will be issued for Category 3 plants to exist in riparian zones. Eight (8) Category 1b invasive plant species were recorded within the project area and it is recommended that an alien invasive plant management programme be implemented in compliance of section 75 of the Act as stated above. The NEM:BA listed species identified within the project area are marked in green.
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PROTECTED TREE SPECIES According to the list of protected tree species under the National Forests Act, 1998 (Act No.84 of 2014) in terms of section 15 (1) of the Forests Act, 1998 (DAFF, 2014), no person may cut, disturb, damage or destroy any protected tree or possess, collect, remove, transport, export, purchase, sell, donate, or in any other manner acquire or dispose of any protected tree or any product derived from a protected tree, except under a license or exemption granted by the Minister to an applicant and subject to such period and conditions as may be stipulated. Contravention of this declaration is regarded as a first category offence. Several individual Marula Trees (Sclerocarya birrea subsp. caffra) were observed within the property. Should the proposed development impact on these areas, then application for a relocation or destruction permit needs to be made OR to move the proposed development footprint in order to avoid the trees currently present.
6.8.2 FAUNA
AVIFAUNA Eleven (11) bird species were recorded in the project area during the February 2019 survey based on either direct observation, vocalisations, or the presence of visual tracks and signs (Table 6-4). No avifaunal SCC were recorded during the survey. Based on the presence of suitable avifaunal habitat, there is a high probability that bird SCC may still occur within the project area. Table 6-4: Avifaunal Species Recorded
CONSERVATION STATUS
SPECIES COMMON NAME Regional (SANBI, 2016) IUCN (2017)
Bostrychia hagedash Ibis, Hadeda Unlisted LC
Chalcomitra amethystina Sunbird, Amethyst Unlisted LC
Chrysococcyx caprius Cuckoo, Diderick Unlisted LC
Estrilda astrild Waxbill, Common Unlisted LC
Hirundo abyssinica Swallow, Lesser Striped Unlisted LC
Lagonosticta rubricata Firefinch, African Unlisted LC
Lanius collurio Shrike, Red-backed Unlisted LC
Lonchura cucullata Mannikin, Bronze Unlisted LC
Onychognathus morio Starling, Red-winged Unlisted LC
Pycnonotus tricolor Bulbul, Dark-capped Unlisted Unlisted
Tauraco porphyreolophus Turaco, Purple-crested Unlisted LC
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MAMMALS Overall, mammal diversity in the project area was low, with only two mammal species being recorded during the February 2019 survey based on direct observations and/or the presence of visual tracks and signs. The species included the Vervet Monkey and the Chacma Baboon.
HERPETOFAUNA Herpetofauna diversity was considered to be low with one reptile and no amphibian species observed or recorded in the project area during the February 2019 survey. No SCCs were recorded in the project area, but a moderate chance exists that some could be present.
6.8.3 HABITAT SENSITIVITY MAPPING
Areas that were classified as having low sensitivities (transformed and degraded habitats) are those areas which were deemed by the specialists to have been most impacted upon and/or were modified from their original condition due to factors such as human activity and/or presence of alien invasive species. In this project area, areas designated as having a low sensitivity are those areas which have been heavily transformed by impacts such as existing infrastructure and the maintenance of these structures. The areas given a low-moderate sensitivity rating are those areas with transformed vegetation that do not exist in their natural form anymore. This area still functions as part of the ecosystem but will be less sensitive. Dense Mountain Woodland was given a high sensitivity as this area was found by the specialist to still be in its natural state and form a crucial part of the ecosystem and is habitat to many faunal species observed in this study. The habitat sensitivity map is shown in Figure 6-12 below.
Figure 6-12: Habitat Sensitivity Map
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6.9 TRAFFIC
The current road classification surrounding the Mill site is shown in Figure 6-13. According to the Road Infrastructure Strategic Framework for South Africa (RISFSA) a national route is classified as a Class 1 Primary Distributor which is characterised as a high mobility road with limited access for rapid movement of large volumes of people, raw materials, manufactured goods and agricultural produce of national importance. The section of the N4 located alongside the Mill is considered as a Rural Class 1 Primary Distributor. In addition, several minor roads also surround the Mill site. These are classified as Class 2 roads i.e. mobility roads providing regional connectivity with more frequent access along the road. The accessibility function of Class 2 roads is higher than Class 1 roads but it is important to note that the mobility function is still the predominate function.
Figure 6-13: RISFSA Road Classification
6.10 SOCIO-ECONOMIC
This section focuses on the socio-economic aspects of the area Mpumalanga Province, Mbombela Local Municipality and Ngodwana Area within which the proposed project falls. The following reports and publications were used as sources of information: — The National Statistical Services of South Africa (Stats SA) Census Surveys (2001 and 2011); — Community Survey (CS) (2016) as published by the Stats SA; and — Sappi Ngodwana Mill: Socio-Economic Impact Assessment Scenario Description (UrbanEcon, 2015).
6.10.1 DEMOGRAPHICS
The population and household growth for Mpumalanga, Mbombela and Ngodwana Regions are presented in Table 6-5. It can be deduced that between 2011 and 2015, an annual population growth rate of 14.6% was observed within the Ngodwana Region.
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According to Stats SA CS 2016 results, the Ngodwana Area has recorded a rapid increase in the number of households in the past 15 years. The results reveal that, as of 2015, the Ngodwana Area had a total of 1 886 households. This means an increase of 172 between 2001 and 2011, while the number has increased by 246 in the past 15 years. Table 6-5: Population and Household Growth
GROWTH
REGION 2001 2011 2015 (2001 - 2015) (%)
Population
Mpumalanga 3 366 213 4 039 942 4 345 788 29.1%
Mbombela 476 627 588 796 640 736 34.4%
Ngodwana 3 164 3 487 3 625 14.6%
Households
Mpumalanga 831 028 1 075 486 1 192 341 43.5%
Mbombela 122 874 161 774 180 588 47.0%
Ngodwana 1 640 1 812 1 886 15.0%
Source: Urban-Econ Calculations based on Statistics SA Census Surveys 2001, 2011 and CS 2016
6.10.2 STRUCTURE OF THE ECONOMY
Production structure measured by Gross Value Added (GVA) identifies economic sectors contribution to the economy for a specific area. Figure 6-14 (Urban-Econ calculations, 2015) indicates the economic growth rate in Mpumalanga Province and Mbombela Local Municipality. The sectors that contribute the most to the GVA of Mbombela include: — Finance and business sector; — Manufacturing; — General government services, and — Trade and accommodation.
25%
20%
15%
10%
5% Mpumalanga
0% Mbombela
Figure 6-14: GVA contribution by Economic Sector, 2013
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6.10.3 MANUFACTURING SUB-SECTOR STRUCTURE
The food and beverages sub-sector is performing best by contributing 42% to overall manufacturing sector in Mbombela. Wood and paper sector follows with a contribution of nearly 20% in Mbombela. This is reflecting the wood and paper manufacturing activity in Ngodwana. Metals and metal products sector is also important in Mpumalanga, which is the indication of steel production taking place in Nkangala District. Figure 6-15 (Urban-Econ calculations, 2015) presents the contribution of the manufacturing sub-sectors.
45% 40% 35% 30% 25% 20% 15% 10% 5% Mpumalanga 0% Mbombela
Figure 6-15: Manufacturing sub-sector GVA, 2013
6.10.4 MANUFACTURING SECTOR GROWTH
The food, beverages and tobacco sector has the highest growth for Mpumalanga and Mbombela with increments of 9.8% and 8.1% respectively. Wood and Paper manufacturing increases have been reported as 3.1% in Mpumalanga and 2.7% in Mbombela. The Manufacturing Sector growth is presented in Table 6-6. Table 6-6: Manufacturing sector growth (2003 – 2013)
SECTOR MPUMALANGA MBOMBELA
Food and beverages 9.8% 8.1%
Textiles and clothing 0.1% -0.3%
Wood and paper 3.1% 2.7%
Petroleum products and chemicals -0.8% 4.6%
Other non-metal mineral products 5.4% 5.6%
Metals and metal products 6.5% 6.6%
Electrical machinery and apparatus 5.8% 5.5%
Radio, TV and other instruments 7.2% 6.0%
Transport equipment 5.3% 5.2%
Furniture and other manufacturing 1.8% 2.2%
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6.10.5 SECTORAL EMPLOYMENT
In Mpumalanga, most people are employed in the tertiary sector for both Mpumalanga Province and Mbombela Local Municipality. This is in line with the production structure in Mpumalanga Province. Employment in the past 10 years has increased significantly in government services and mining sectors. Other mining related services also contribute to the significant increase in mining industry. Figure 6-16 (Urban-Econ calculations, 2015) indicates the structure of employment in Mpumalanga and Mbombela. Table 21 (Urban-Econ calculations, 2015) indicates employment growth between 2003 and 2013 in the Mpumalanga and Mbombela.
25%
20%
15%
10% Mpumalanga 5% Mbombela 0%
Figure 6-16: Employment structure, 2013 Table 6-7 (Urban-Econ calculations, 2015) indicates employment growth between 2003 and 2013 in the Mpumalanga and Mbombela. Table 6-7: Employment growth (2003 – 2013)
SECTORS MPUMALANGA MBOMBELA
Agriculture -1.8% -0.8%
Mining 7.0% 12.6%
Manufacturing -0.9% -0.7%
Utilities 5.9% 3.7%
Construction 0.7% 0.4%
Trade and Accommodation 1.4% 0.7%
Transport 2.9% 1.4%
Business services 4.3% 4.7%
Community services 1.4% 3.1%
General government 5.1% 7.4%
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7 IMPACT ASSESSMENT
This Chapter identifies the perceived environmental and social effects associated with the proposed Project. The assessment methodology is outlined in Section 3.4. The issues identified stem from those aspects presented in Chapter 6 of this document as well as the project description provided. The impact assessment will be based on the preferred alternative at all project phases. This section only assesses the preferred option along with the no-go section. The mitigation hierarchy criteria for each mitigation measure is indicated in brackets after each measure indicated. Furthermore, decommissioning will be considered as part of the decommissioning of the broader facility which will be subject to a separate authorisation and impact assessment process. Any decommissioning impacts will be assessed at this stage.
7.1 AIR QUALITY
7.1.1 CONSTRUCTION PHASE
DUST AND PARTICULATE MATTER Air quality guidelines are provided by the ambient dust concentration limits prescribed by SANS 1929:2005. Whilst these guidelines are currently not enforceable they do serve as recommendations for good practice. SANS 1929:2005 sets out dust deposition rates, expressed in units of mg.m-2.day-1 over a typical 30-day averaging period. During the construction phase, dust and vehicular emissions will be released as a result of excavations as well as earth moving machinery and trucks transporting construction material. The emissions will, however, have short term impacts on the immediate surrounding areas which can be easily mitigated and thus the authorisation of such emissions will not be required. All construction phase air quality impacts will be minimised with the implementation of dust control measures contained within the EMPr (Appendix G) and the dust impacts will be short term in nature. The impact of the construction phase on the generation of dust and PM is shown in Table 7-1 below. Table 7-1: Construction Impact on Generation of Dust and PM
Potential Impact:
Generation of Dust and PM Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 2 2 3 1 4 32 Medium (-) High With Mitigation 1 1 3 1 3 18 Low (-) High Mitigation and Management Measures — Implement dust suppression methods during construction to minimise dust emissions from the site activities; — All stockpiles must be restricted to designated areas and may not exceed a height of two (2) metres; — Ensure that all vehicles and machines are adequately maintained to minimise emissions; — It is recommended that the clearing of vegetation from the site should be selective and done just before construction so as to minimise erosion and dust; — All materials transported to site must be transported in such a manner that they do not fly or fall off the vehicle. This may necessitate covering or wetting friable materials; — No burning of waste, such as plastic bags, cement bags and litter is permitted; and
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Potential Impact:
Generation of Dust and PM Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility — All issues/complaints must be recorded in the complaints register.
7.1.2 OPERATIONAL PHASE
There are no anticipated air quality impacts during the operational phase.
7.2 NOISE EMISSIONS
7.2.1 CONSTRUCTION PHASE
Elevated noise levels are likely to be generated by the construction activities (machinery and vehicles) and the workforce. It is important to note that noise impacts (nuisance factor) may vary in the different areas as a result of the surrounding land uses and will be temporary in nature. There are residential quarters and villages within a 500 – 1 500 m radius of the proposed site. Noise impacts associated with this project are not regarded as a significant impact as it is expected to be restricted to construction activities. Furthermore, the ambient noise regime influenced by the Mill is higher than the project specific noise levels. The construction impact on noise is indicated in Table 7-2 below. Table 7-2: Construction Impact on Noise
Potential Impact:
Noise Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 2 1 3 1 4 28 Low (-) High With Mitigation 2 1 1 1 3 15 Low (-) High Mitigation and Management Measures — The equipment must be in good working order, within service dates, and inspected before use; — Align working times with station related construction times; and — Install noise reducing fittings on machinery (if required).
7.2.2 OPERATIONAL PHASE
There are no anticipated noise impacts during the operational phase.
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7.3 SOIL EROSION AND CONTAMINATION
7.3.1 CONSTRUCTION PHASE
SOIL EROSION During the construction phase, measures should be implemented to manage stormwater and water flow on the site. If the stormwater and water flow is not regulated and managed onsite, it could cause significant erosion of soil on the stockpiles, as well as the pollution and siltation of water bodies. During the construction phase, the installation of services could leave soils exposed and susceptible to erosion. The construction impact on soil erosion is indicated in Table 7-3 below. Table 7-3: Construction Impact on Soil Erosion
Potential Impact:
Soil Erosion Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 2 1 3 2 4 32 Medium (-) High With Mitigation 1 1 3 2 3 21 Low (-) High Mitigation and Management Measures — Where possible, consider conducting construction activities during winter where rainfall is minimal; — Only the identified areas should be cleared of vegetation. This should be done in stages as construction works progress, if possible; — Implement stormwater management measures that will help to reduce the speed of the water. These measures must also assist with the prevention of water pollution, erosion and siltation; — Temporary and permanent erosion control methods may include silt fences, flotation silt curtains, retention basins, detention ponds, interceptor ditches, seeding and sodding, riprap of exposed embankments, erosion mats, and mulching; — Any exposed earth should be rehabilitated promptly, and this could include planting suitable vegetation (vigorous indigenous grasses) that mimics the surrounding environment to protect the exposed soil; — If excavations or foundations fill up with stormwater, these areas should immediately be drained and measures to prevent access to these areas should be implemented; — Erosion control measures should be implemented during the construction phase on large exposed areas and where stormwater is temporarily channelled; and — Landscape the area so that there is a free flow of water, without being erosive, thus increasing the catchment area.
SOIL CONTAMINATION During construction activities, construction vehicles/trucks/machinery as well as hazardous substances stored on the site might spill and contaminate the soil. The impact of the construction phase on soil pollution is indicated in Table 7-4 below.
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Table 7-4: Construction Impact on Soil Contamination
Potential Impact:
Soil Contamination Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 2 1 3 3 4 36 Medium (-) High With Mitigation 1 1 3 2 3 21 Low (-) High Mitigation and Management Measures — All construction vehicles, plant, machinery and equipment must be properly maintained to prevent leaks; — Plant and vehicles are to be repaired immediately upon developing leaks; — Drip trays shall be supplied for all idle vehicles and machinery; — No repair work may be undertaken on machinery onsite or campsite area; — Drip trays are to be utilised during daily greasing and re- fuelling of machinery and to catch incidental spills and pollutants; — Drip trays are to be inspected daily for leaks and effectiveness and emptied when necessary. This is to be closely monitored during rain events to prevent overflow; — Ensure appropriate handling of hazardous substances; — Keep spill kits onsite and train personnel to use them appropriately; — Fuels and chemicals must be stored in adequate storage facilities that are secure, enclosed and bunded; and — Implement stormwater management measures that will help to reduce the speed of the water flows. These measures must also assist with the prevention of wider range of the site.
7.3.2 OPERATIONAL PHASE
SOIL EROSION No operational soil erosion impacts are expected as the area will be rehabilitated. The vegetation will compact and hold the soil in place.
SOIL CONTAMINATION The proposed reservoir stores clean water, therefore, no contamination is expected during the operational phase.
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7.4 SURFACE WATER
7.4.1 CONSTRUCTION PHASE
CHANGE OF FLOW VOLUMES AND DRAINAGE PATTERNS The construction activities which include onsite traffic, equipment, machinery and human presence results in hardening of surface areas due to compaction as well as alteration of the general terrain. This leads to alteration of the surface and sub-surface flow volumes and change of flow patterns, however, this is temporary as construction activities occur over a short period. This is perpetuated during construction from continuous vehicle activity, and the continued presence of personnel at the site office, laydown and storage areas. The construction phase impact is indicated in Table 7-5 below. Table 7-5: Construction Impact on Change in Flow Volumes and Drainage Patterns
Potential Impact:
Change in Flow Volumes and Drainage Patterns Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 2 2 3 4 4 44 Medium (-) High With Mitigation 1 2 3 3 3 27 Low (-) High Mitigation and Management Measures — Construction method statements are to be adhered to. These method statements should consider the environmental facets associated with the wetland such as hydrological flow regimes, flora and fauna; — Stormwater channels and preferential flow paths should be delineated, filled with aggregate and/or logs (branches included) to dissipate and slow flows limiting erosion; and — Prevent uncontrolled access of vehicles through the surface water channels that can cause a significant adverse impact on the hydrology and alluvial soil structure of these areas.
DETERIORATION IN WATER QUALITY There is a potential to affect the surface water quality in the area due to construction activities. This is influenced by spills and leaks, the storage of chemicals, mixes and fuel, location and protection of stockpiles, onsite waste management and the management of stormwater. The stormwater runoff will wash the potential contaminants to the nearby Ngodwana River. The impact of construction on deterioration in water quality is shown in Table 7-6 below.
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Table 7-6: Construction Impact on Deterioration in Water Quality
Potential Impact:
Deterioration in Water Quality Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 4 4 3 3 3 42 Medium (-) High With Mitigation 2 2 3 2 3 27 Low (-) High Mitigation and Management Measures — Construction areas should be demarcated in order to prevent the unnecessary impact to and loss of these systems; — Construction method statements are to be adhered to. These method statements should consider the environmental facets associated with the wetland such as hydrological flow regimes, flora and fauna; — Stormwater channels and preferential flow paths should be delineated, filled with aggregate and/or logs (branches included) to dissipate and slow flows limiting erosion; — During construction, contractors used for the project must have spill kits available to ensure that any fuel or oil spills are clean-up and discarded correctly; — As much material must be pre-fabricated and then transported to site to avoid the risks of contamination associated with mixing, pouring and the storage of chemicals and compounds on site; — All chemicals and toxicants during construction and operation must be stored in bunded areas; — All machinery and equipment should be inspected regularly for faults and possible leaks, these should be serviced off-site; — All contractors and employees should undergo induction which is to include a component of environmental awareness. The induction is to include aspects such as the need to avoid littering, the reporting and cleaning of spills and leaks and general good “housekeeping”, as well as an understanding of environmental risks in their various areas of work; — Adequate sanitary facilities and ablutions must be provided for all personnel throughout the project area. Use of these facilities must be enforced (these facilities must be kept clean so that they are a desired alternative to the surrounding vegetation); and — Have action plans on site, and training for contactors and employees in the event of spills, leaks and other impacts to the aquatic systems.
7.4.2 OPERATIONAL PHASE
No operational phase impacts are expected as the reservoir stores clean water.
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7.5 GROUNDWATER
7.5.1 CONSTRUCTION PHASE
CHANGE OF GROUNDWATER FLOW VOLUMES The construction activities which include onsite traffic, equipment, machinery and human presence results in hardening of surface areas due to compaction as well as alteration of the general terrain. This leads to alteration of the sub-surface flow and recharge volumes. This is perpetuated during construction from continuous vehicle activity, and the continued presence of personnel on the site office, laydown and storage areas. The construction phase impact is indicated in Table 7-7 below. Table 7-7: Construction Impact on Change in Flow Volumes
Potential Impact:
Change in Flow Volumes Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 3 2 3 4 4 48 Medium (-) High With Mitigation 2 1 3 3 3 27 Low (-) High Mitigation and Management Measures — Construction areas should be demarcated in order to prevent creation of pathways to contaminating groundwater through these systems.
DETERIORATION IN GROUNDWATER QUALITY There is a potential to affect the groundwater quality in the area. This is influenced by spills and leaks, the storage of chemicals, mixes and fuel. Any contaminants that are not cleaned from the ground will seep into underground water resources. The impact of construction on change in water quality is shown in Table 7-8 below. Table 7-8: Construction Impact on Deterioration in Water Quality
Potential Impact:
Deterioration in Water Quality Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 3 2 3 2 3 30 Medium (-) High With Mitigation 2 2 3 2 2 18 Low (-) High Mitigation and Management Measures — Construction areas should be demarcated in order to prevent the unnecessary impact to and loss of these systems; — During construction contractors used for the project must have spill kits available to ensure that any fuel or oil spills are cleaned-up and discarded correctly; — As much material must be pre-fabricated and then transported to site to avoid the risks of contamination associated with mixing, pouring and the storage of chemicals and compounds on site; — All chemicals and toxicants during construction and operation must be stored in bunded areas;
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Potential Impact:
Deterioration in Water Quality Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility — All machinery and equipment should be inspected regularly for faults and possible leaks, these should be serviced off-site; — All contractors and employees should undergo induction which is to include a component of environmental awareness. The induction is to include aspects such as the need to avoid littering, the reporting and cleaning of spills and leaks and general good “housekeeping”; — Adequate sanitary facilities and ablutions on the servitude must be provided for all personnel throughout the project area. Use of these facilities must be enforced (these facilities must be kept clean so that they are a desired alternative to the surrounding vegetation); and — Have action plans on site, and training for contactors and employees in the event of spills, leaks and other impacts to the aquatic systems.
7.5.2 OPERATIONAL PHASE
There are no operational phase impacts envisaged for the proposed clean water reservoir.
7.6 BIODIVERSITY
7.6.1 CONSTRUCTION PHASE
LOSS AND FRAGMENTATION OF FLORA The construction phase involves the clearance of vegetation which leads to further loss and fragmentation of the vegetation community (including a portion of an area classified as a CBA-irreplaceable and EN vegetation type), however, this is limited to the proposed project footprint. From an ecological perspective the development is situated within an area which has been somewhat disturbed, both historically and currently. The construction impact on loss and fragmentation of flora is indicated in Table 7-9 below.
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Table 7-9: Construction Impact on Loss and Fragmentation of Flora
Potential Impact:
Loss and Fragmentation of Flora Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 4 3 3 5 4 60 Medium (-) High With Mitigation 2 2 3 2 3 27 Low (-) High Mitigation and Management Measures — The Dense Mountain Woodland habitat or Highly sensitive area should be avoided. As far as possible, the proposed reservoir construction should be restricted to areas that have already been disturbed (low sensitivity areas) or in association with the current infrastructure if possible, and limited further loss of primary or secondary vegetation; — It is recommended that areas to be developed be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon and prevent movement of workers into sensitive surrounding environments, i.e. Dense Mountain Woodland habitat; — The existing access routes (maintenance roads) and walking paths must be made use of, and the creation of any new routes should be limited as far as possible; — All building materials should be mixed off site and storage of all building materials limited to the clarifier area and transported along the existing roads, to limit the development footprint to transformed areas; — The access route and laydown areas for the construction of the reservoir should to the north, to the less sensitive area; — Areas that are denuded during construction need to be re- vegetated with indigenous vegetation to prevent erosion during flood events. This will also reduce the likelihood of encroachment by alien invasive plant species; — The area (topsoil) overlying the pipeline must be vegetated with an indigenous grass / seed mix; and — A vegetation rehabilitation plan needs to be compiled for the proposed development. Quarterly monitoring needs to be conducted of vegetation communities associated with the infrastructure and along the pipeline in order to assess the state of rehabilitation and encroachment of alien vegetation, for the first year of the operation phase.
INCREASED ALIEN VEGETATION SPECIES Construction activities have the potential to lead to an increase in alien invasive species in the area. These are brought by site personnel on their clothing or via the truck tyres or as a result of pioneer species following a construction activity. The construction impact on increase in alien species in the area is shown in Table 7-10 below.
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Table 7-10: Construction Impact on Increase in Alien Vegetation Species
Potential Impact:
Increase in Alien Vegetation Species Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 2 2 3 4 4 44 Medium (-) High With Mitigation 2 1 3 3 2 18 Low (-) High Mitigation and Management Measures — It is recommended that all NEM:BA Category 1b alien plant species found during construction, be removed according to best practice guidelines and all efforts should be made to prevent further growth of other alien or invasive plant species; — Limiting the construction area to the defined project areas and only impacting those areas where it is unavoidable to do so otherwise; — It is recommended that areas to be developed be specifically demarcated so that during the construction phase and operational phase, only the demarcated areas are impacted upon. All work areas, offices and access roads must be clearly demarcated from surrounding natural areas and no persons should be allowed to enter these areas under any circumstances; — It should be made an offence for any staff to bring any plant species into any portion of the project site, including offices. No plant species whether indigenous or exotic should be brought into the project area, to prevent the spread of exotic or invasive species; and — Compilation of and implementation of an alien vegetation management plan for the entire site, including the surrounding project area. — Rehabilitation and de-weeding of areas that have been disturbed by construction activities, to avoid occupation by alien species.
DESTRUCTION OF PROTECTED TREE SPECIES Several individual nationally protected Marula trees that may need to be removed or destroyed due to development were observed in the proposed project footprint. The proposed construction impact on the destruction of protected tree species is indicated in Table 7-11 below. Table 7-11: Destruction of Protected Tree Species
Potential Impact:
Destruction of Protected Tree Species Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 3 3 3 5 4 56 Medium (-) High With Mitigation 2 2 3 2 3 27 Low (-) High Mitigation and Management Measures — Apply for a relocation or destruction permit for any individual tree that may be removed or destroyed during the development; or — Relocate the trees within the property without a permit or otherwise be left unharmed.
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DISPLACEMENT AND FRAGMENTATION OF FAUNA The construction activities will lead to the displacement, direct mortalities and disturbance of faunal community due to habitat loss and disturbances (such as dust, noise, vibrations and direct mortalities). Recommended mitigation and rehabilitation measures for faunal community’s hinge largely on protecting their habitats and ensuring it remains intact. The construction impact on displacement of fauna is indicated in Table 7-12 below. Table 7-12: Construction Impact on Displacement of Fauna
Potential Impact:
Displacement of Fauna Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 3 3 3 5 4 56 Medium (-) High With Mitigation 2 2 3 2 3 27 Low (-) High Mitigation and Management Measures — If any faunal species are recorded during construction, activities should temporarily cease, to allow fauna to move away. Faunal species that have not moved away should be carefully and safely removed, if permitted, to a suitable location beyond the extent of the development footprint; — No trapping, killing or poisoning of any wildlife is to be allowed, including snakes, birds, lizards, frogs, insects or mammals, and all workers (including contractors) need to be informed of this; — If permissible, construction shouldn’t take place within the period from dusk to dawn, as much as possible; — Have a schedule drawn up to monitor all infrastructure, especially the pipeline for any leaks, weekly monitoring is advisable; and — Have action plans on site, and training for contactors and employees in the event of spills, leaks and other impacts to the surrounding environment.
7.6.2 OPERATIONAL PHASE
CONTINUED ENCROACHMENT AND DISPLACEMENT OF FLORA During the operational phase, there is a continued encroachment and displacement of the vegetation community due to alien invasive plant species, particularly in previously disturbed areas. The operational impact is indicated in Table 7-13 below. Table 7-13: Operational Impact on Continued Encroachment and Displacement of Flora
Potential Impact:
Continued Encroachment and Displacement of
Extent
Duration
Character
Magnitude
Confidence Flora Probability
Significance
Reversibility Without Mitigation 3 3 3 4 4 52 Medium (-) High With Mitigation 2 2 3 2 3 27 Low (-) High Mitigation and Management Measures — It is recommended that all NEM:BA Category 1b alien plant species found during construction, be removed according to best practice guidelines and all efforts should be made to prevent further growth of other alien or invasive plant species; — It should be made an offence for any staff to bring any plant species into any portion of the project site, including offices. No plant species whether indigenous or exotic
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Potential Impact:
Continued Encroachment and Displacement of
Extent
Duration
Character
Magnitude
Confidence Flora Probability
Significance
Reversibility should be brought into the project area, to prevent the spread of exotic or invasive species; — Compilation of and implementation of an alien vegetation management plan for the entire site, including the surrounding project area; and — Rehabilitation and de-weeding of areas that have been disturbed by construction activities, to avoid occupation by alien species.
CONTINUED DISPLACEMENT AND FRAGEMENTATION OF FAUNA During the operational phase, there is a continued and fragmentation of the faunal community due to ongoing anthropogenic disturbances (noise, traffic, dust and vibrations). The operational impact is indicated in Table 7-14 below. Table 7-14: Operational Impact on Continued Displacement and Fragmentation of Fauna
Potential Impact:
Continued Displacement and Fragmentation of
Extent
Duration
Character
Magnitude
Confidence Fauna Probability
Significance
Reversibility Without Mitigation 3 3 3 3 3 36 Medium (-) High With Mitigation 2 1 3 2 3 24 Low (-) High Mitigation and Management Measures — No trapping, killing or poisoning of any wildlife is to be allowed, including snakes, birds, lizards, frogs, insects or mammals, and all workers (including contractors) need to be informed of this; — Have a schedule drawn up to monitor all infrastructure, especially the pipeline for any leaks, weekly monitoring is advisable; and — Have action plans on site, and training for contactors and employees in the event of spills, leaks and other impacts to the surrounding environment.
LOSS OF FAUNA During the operational phase, there is a potential loss of faunal species due to road mortalities and / or poaching. The operational impact is indicated in Table 7-15 below. Table 7-15: Operational Impact on Loss of Fauna
Potential Impact:
Loss of Fauna Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 3 3 3 3 3 36 Medium (-) High With Mitigation 2 1 3 2 3 24 Low (-) High Mitigation and Management Measures — No trapping, killing or poisoning of any wildlife is to be allowed, including snakes, birds, lizards, frogs, insects or mammals, and all workers (including contractors) need to be informed of this;
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Potential Impact:
Loss of Fauna Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility — Have a schedule drawn up to monitor all infrastructure, especially the pipeline for any leaks, weekly monitoring is advisable; and — Have action plans on site, and training for contactors and employees in the event of spills, leaks and other impacts to the surrounding environment.
HABITAT DEGRADATION During the operational phase, there is potential habitat degradation due to litter and alien vegetation encroachment. The operational impact is indicated in Table 7-16 below. Table 7-16: Operational Impact on Habitat Degradation
Potential Impact:
Habitat Degradation Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 3 3 3 3 3 36 Medium (-) High With Mitigation 2 1 3 2 3 24 Low (-) High Mitigation and Management Measures — Ensure good housekeeping and prevent littering on the site; — It is recommended that all NEM:BA Category 1b alien plant species found during construction, be removed according to best practice guidelines and all efforts should be made to prevent further growth of other alien or invasive plant species; — It should be made an offence for any staff to bring any plant species into any portion of the project site, including offices. No plant species whether indigenous or exotic should be brought into the project area, to prevent the spread of exotic or invasive species; — Compilation of and implementation of an alien vegetation management plan for the entire site, including the surrounding project area; and — Rehabilitation and de-weeding of areas that have been disturbed by construction activities, to avoid occupation by alien species.
7.7 TRAFFIC
7.7.1 CONSTRUCTION PHASE
The impact of additional traffic during construction is expected to be minimal and short term. The proposed site is to the south of the Sappi Ngodwana Mill, which is just off from the N4. The construction impact on traffic is indicated in Table 7-17 below.
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Table 7-17: Construction Impact on Increased Local Traffic
Potential Impact:
Increased Local Traffic Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 2 1 3 1 4 28 Low (-) High With Mitigation 2 1 1 1 3 15 Low (-) High Mitigation and Management Measures — Ensure deliveries are done as and when required; — The road network which surrounds the proposed development will have to be correctly maintained in order to support additional movement of vehicles. Transport should be limited to non-peak hours; — Since the access road is narrow, ensure that all vehicles do not park along the road but within the farm boundary; and — All site vehicles must limit the idle time on the access road.
7.7.2 OPERATION PHASE
No operational phase impacts are expected as the clean water reservoir will operate uninterrupted and any work on it limited.
7.8 HEALTH AND SAFETY
7.8.1 CONSTRUCTION PHASE
During construction, the employees are exposed to health and safety hazards from the mechanical machines and equipment used on the site. Furthermore, there is a potential for snakes and other dangerous animals in the area, to which the employees must be warned about and trained on how to handle situations if any encounters occur. The construction impact on health and safety is indicated in Table 7-18 below. Table 7-18: Construction Impact on Employee Health and Safety
Potential Impact:
Employee Health and Safety Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility Without Mitigation 4 2 3 4 4 52 Medium (-) High With Mitigation 2 1 3 4 2 20 Low (-) High Mitigation and Management Measures — An HSE officer is to be appointed who will monitor safety conditions during construction activities; — Ensure employees are properly trained to use specific equipment or machinery; — Train personnel on how to deal with snake encounters, as well as encounters with other dangerous animals known to occur in the area; — Provide suitable personal protective equipment (PPE); — Conduct site and safety induction to raise awareness of the risks associated with the site;
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Potential Impact:
Employee Health and Safety Extent
Duration
Character
Magnitude
Confidence
Probability
Significance
Reversibility — Conduct regular toolbox talks as refreshers to improve health and safety; — Develop safe work instruction method statements that should be used by employees in completing their tasks; — Train all relevant personnel on handling, use and storage of hazardous substances; — Provide MSDS for all hazardous substances kept onsite; and — All visitors should undergo site induction and be made aware of the risks associated with the site.
7.8.2 OPERATIONAL PHASE
No operational phase impacts are expected as the clean water reservoir will operate uninterrupted and any work on it limited.
7.9 SOCIO-ECONOMIC
7.9.1 CONSTRUCTION PHASE
EMPLOYMENT OPPORTUNITIES The proposed development will create a limited number of employment opportunities for individuals in the surrounding area. The positive impact of this phase is limited as it is temporary as well. The construction impact on employment opportunities is indicated in Table 7-19 below. Table 7-19: Construction Impact on Employment Opportunities
Potential Impact:
Employment Opportunities
Magnitude Extent Reversibility Duration Probability Significance Character Confidence Without Mitigation 2 1 3 1 3 24 Low (+) High With Mitigation 2 2 3 2 3 36 Medium (+) High Mitigation and Management Measures — The project must aim to use local labour in order to benefit the local community, where possible and applicable for the project; and — Consult with local communities to boost local business.
7.9.2 OPERATIONAL PHASE
No operational phase impacts are expected as the clean water reservoir will operate uninterrupted and any work on it limited.
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7.10 NO-GO ALTERNATIVE
The no-go alternative will mean none of the negative and positive impacts described above will come into effect.
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8 ENVIRONMENTAL IMPACT STATEMENT
The essence of any impact assessment process is aimed at ensuring informed decision-making, environmental accountability, and to assist in achieving environmentally sound and sustainable development. In terms of NEMA, the commitment to sustainable development is evident in the provision that “development must be socially, environmentally and economically sustainable…. and requires the consideration of all relevant factors…” NEMA also imposes a duty of care, which places an obligation on any person who has caused, is causing, or is likely to cause damage to the environment to take reasonable steps to prevent such damage. In terms of NEMA’s preventative principle, potentially negative impacts on the environment and on people’s environmental rights (in terms of the Constitution of the Republic of South Africa, Act No. 108 of 1996) should be anticipated and prevented, and where they cannot be prevented altogether, they must be minimised and remedied in terms of “reasonable measures”. In assessing the environmental feasibility of the proposed construction of the clean water reservoir, the requirements of all relevant legislation have been considered. The identification and development of appropriate mitigation measures that should be implemented in order to minimise potentially significant impacts associated with the project, has been informed by best practice principles, past experience and the relevant legislation (where applicable). The conclusions of this BA are the result of a comprehensive assessment. The assessment was based on issues identified through the BA process and the parallel process of public participation that will be conducted when submitting for public review. The public consultation process will be undertaken according to the requirements of NEMA and every effort was made to include representatives of all stakeholders within the process.
8.1 ENVIRONMENTAL SENSITIVITIES
The following environmental sensitivities were identified on the site and will require specific applications or measures for mitigation to minimise impact. The proposed project area falls within an area classified as CBA- irreplaceable. The project is located in an Endangered ecosystem. The Legogote Sour Bushveld vegetation type which is Endangered is also encountered in the proposed project area. Furthermore, ten (10) of the identified 680 plant species are listed as being Species of Conservation Concern (SCC).
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Figure 8-1: Ecological Sensitivity
8.2 SPECIALIST CONCLUSIONS
8.2.1 BIODIVERSITY ASSESSMENT
Based on the impact rating (and after mitigation measures have been implemented) the development is considered to not have a major impact on the environment.
FLORA The following further conclusions were reached based on the results of this assessment: — The entire project area and the associated development falls within an area classified as CBA-irreplaceable, however within the project area only a small portion, the identified Dense Mountain Woodland area, is regarded as CBA-Irreplaceable; — The proposed project was superimposed on the terrestrial ecosystem threat status. Based on this, the project area falls within one ecosystem, which is listed as Endangered; — The project area was superimposed on the ecosystem protection level map to assess the protection status of terrestrial ecosystems associated with the proposed reservoir. Based on this analysis the terrestrial ecosystems associated with the proposed project area are rated as poorly protected; — Based on the SANBI (2010) Protected Areas Map and the National Protected Areas Expansion Strategy (NPAES) the project area does not overlap with, nor will it impact on, any formally protected area. However, the project area can be found approximately 2.8 km south-east of the Coetzeestroom nature reserve; — The Ngodwana FEPA river runs along the edge of the water treatment works and the closest wetland is a Non-FEPA wetland that is approximately 1 km south-east of the project area;
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— The project area is situated within the Legogote Sour Bushveld vegetation type. This vegetation type is listed as Endangered; — Based on the Plants of Southern Africa database, 680 plant species are expected to occur in the project area. Of these, ten (10) species are listed as being SCC; and — A total of 61 tree, shrub and herbaceous plant species were recorded in the project area during the field assessment. Several Marula Trees (Sclerocarya birrea subsp. caffra) were observed within the property. Should the proposed development impact on these trees, then application for a relocation or destruction permit needs to be made OR the proposed development footprint should be moved in order to avoid the trees currently present.
FAUNA The following further conclusions were reached based on the results of this assessment: — No Important Bird and Biodiversity Areas (IBAs) occur within, or adjacent to, the proposed project area; — Eleven (11) bird species were recorded in the project area during the February 2019 survey based on either direct observation, vocalisations, or the presence of visual tracks & signs; and — Overall, mammal diversity in the project area was low, with two mammal species being recorded during the February 2019 survey, they are the Vervet Monkey (Chlorocebus pygerythrus) and the Chacma Baboon (Papio ursinus). Based on the results and conclusions presented in this report, and the outcomes of the field survey, it is the opinion of the specialists that the proposed project can be favourably considered and that no fatal flaws are presented for the project, this is based on the assumption that all mitigation measures will be achieved.
8.3 IMPACT SUMMARY
A summary of the identified impacts and corresponding significance ratings for the proposed clean water reservoir is provided in Table 8-1 below. Table 8-1: Impact Summary
WITHOUT MITIGATION WITH MITIGATION
IMPACT NO. PHASE DESCRIPTION SIGNIFICANCE SIGNIFICANCE
STATUS STATUS
C1 Generation of Dust Construction Medium (-) Low (-) and Particulate Matter C2 Noise Construction Low (-) Low (-)
C3 Soil Erosion Construction Medium (-) Low (-)
C4 Soil Contamination Construction Medium (-) Low (-)
C5 Change of Flow Construction Medium (-) Low (-) Volumes and Drainage Patterns (Surface Water) C6 Deterioration in Construction Medium (-) Low (-) Water Quality (Surface Water)
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WITHOUT MITIGATION WITH MITIGATION
IMPACT NO. PHASE DESCRIPTION SIGNIFICANCE SIGNIFICANCE
STATUS STATUS
C7 Change of Flow Construction Medium (-) Low (-) Volumes and Drainage Patterns (Groundwater) C8 Deterioration in Construction Medium (-) Low (-) Water Quality (Groundwater) C9 Loss and Construction Medium (-) Low (-) fragmentation of flora C10 Increased alien Construction Medium (-) Low (-) vegetation species C11 Destruction of Construction Medium (-) Low (-) protected tree species C12 Displacement and Construction Medium (-) Low (-) Fragmentation of Fauna C13 Increase in Local Construction Low (-) Low (-) Traffic C14 Employee Health Construction Medium (-) Low (-) and Safety C15 Employment Construction Low (+) Medium (+) Opportunities O1 Continued Operation Medium (-) Low (-) Encroachment and Displacement of Flora O2 Continued Operation Medium (-) Low (-) Displacement and Fragmentation of Fauna O3 Loss of Fauna Operation Medium (-) Low (-)
O4 Habitat Operation Medium (-) Low (-) Degradation
8.4 IMPACT STATEMENT
The overall objective of the BA is to provide sufficient information to enable informed decision-making by the authorities. This was undertaken through consideration of the proposed project components, identification of the aspects and sources of potential impacts and subsequent provision of mitigation measures.
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It is the opinion of WSP that the information contained in this document (read in conjunction the EMPr) is sufficient for the MDARDLEA to make an informed decision for the environmental authorisation being applied for in respect of this project. Based on the results and conclusions presented in the Biodiversity Assessment, it is the opinion of the specialists that the proposed project can be favourably considered and that no fatal flaws are presented for the project. This is based on the assumption that all mitigation measures will be achieved. Mitigation measures have been developed, where applicable, for the above aspects and are presented within the EMPr (Appendix G). It is imperative that all impact mitigation recommendations contained in the EMPr, of which the Environmental Impact Assessment took cognisance, are legally enforced.
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9 CONCLUSION
Sappi proposes to construct a 14.4 ML clean water reservoir for supply to the Sappi Ngodwana Mill on Farm Grootgeluk, 477/JT, Portion 0, Ngodwana, Mbombela Local Municipality, Mpumalanga Province. This report provides a description of the proposed project and details the aspects associated with the construction and operation. The report also includes the methodology followed to undertake the BA process. A detailed description on the existing environment (bio-physical as well as socio-economic) is provided based on findings from the specialist surveys and existing information. Stakeholder engagement was undertaken from the onset of the project in a transparent and comprehensive manner. Outcomes of all comments received from the public review period will be recorded and responded to in the final BAR. Based on the environmental description, specialist surveys as well as the stakeholder engagement, a detailed impact assessment was undertaken and, where relevant, the necessary management measures have been recommended. In summary, the BA process assessed both biophysical and socio-economic environments and identified appropriate management and mitigation measures. The biophysical impact assessment revealed that there are no environmental fatal flaws and no significant negative impacts associated with the proposed project should mitigation and management measures be implemented. In addition, it should be noted that the socio-economic impacts associated with the project are positive but limited. Only the construction related impacts were assessed and not the operational phase since the reservoir is mainly for storage of water with operational activities limited to intermittent maintenance as and when required. Decommissioning will be considered as part of the decommissioning of the broader facility which will be subject to a separate authorisation and impact assessment process as according Activity 31 of Listing Notice 1 of GNR 327. The Draft BAR was made available for public review from 11 September 2019 to 14 October 2019. All issues and comments submitted to WSP have been incorporated in the CRR which is attached in Appendix E of this final BAR. The Draft BAR was also submitted to the competent authorities. It is the opinion of WSP that the information contained in this document is sufficient for the MDARDLEA to make an informed decision for the Environmental Authorisation being applied for in respect of this project. If you have any further enquiries, please feel free to contact: WSP Environmental (Pty) Ltd Attention: Anri Scheepers PO Box 98867, Sloane Park, 2152 Tel: 011 300 6089 Fax: 011 361 1301 E-mail: [email protected]
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APPENDIX
A EAP AND SPECIALIST CV
APPENDIX
A-1 ANRI SCHEEPERS
APPENDIX
A-2 TUTAYI CHIFADZA
APPENDIX
A-3 MARTINUS ERASMUS
APPENDIX
A-4 MICHAEL ADAMS
APPENDIX
B EAP AND SPECIALIST DECLARATIONS
APPENDIX
B-1 ANRI SCHEEPERS (EAP)
APPENDIX
B-2 MARTINUS ERASMUS
APPENDIX
B-3 MICHAEL ADAMS
APPENDIX
C STAKEHOLDER DATABASE
APPENDIX
D MAPS
APPENDIX
D-1 LOCALITY MAP
APPENDIX
D-2 LAYOUT MAP
APPENDIX
D-3 LAND USE MAP
APPENDIX
D-4 RIVERS AND WETLANDS MAP
APPENDIX
D-5 ENVIRONMENTAL SENSITIVITY
APPENDIX
E PUBLIC PARTICIPATION
APPENDIX
E-1 COMMENT AND RESPONSE REPORT
APPENDIX
E-2 ADVERT
APPENDIX
E-3 SITE NOTICE
APPENDIX
E-4 EMAIL NOTIFICATIONS
APPENDIX
E-5 AUTHORITY NOTIFICATION
APPENDIX
F SPECIALIST STUDIES
APPENDIX
F-1 BIODIVERSITY ASSESSMENT
APPENDIX
G EMPR
APPENDIX
H DESIGNS
APPENDIX
I IMPACT ASSESSMENT METHODOLOGY
APPENDIX
J THE BIODIVERSITY COMPANY SITE LOCATION MOTIVATION