BASIC ASSESSMENT REPORT and ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

DRAFT BASIC ASSESSMENT REPORT - PROPOSED JOHN READMAN BORROW PIT

BASIC ASSESSMENT REPORT And ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

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

NAME OF APPLICANT: Mr John Readman TEL NO: 082 801 1160 FAX NO: 0821 318 011 / 160 POSTAL ADDRESS: PO Box 14, Empangeni, 3880 PHYSICAL ADDRESS: Pogela Farm, Empangeni, 3880 FILE REFERENCE NUMBER SAMRAD: KZN 30/5/1/3/2/10514 MP

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TABLE OF CONTENTS 1. IMPORTANT NOTICE ...... 3 2. SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT ...... 5 2.1 Contact Person and correspondence address ...... 5 2.2 Location of the overall Activity ...... 6 2.3 Description of the scope of the proposed overall activity ...... 8 2.4 Listed and specified activities ...... 9 2.5 Description of the activities to be undertaken...... 11 2.6 Policy and Legislative Context ...... 14 2.7 Need and desirability of the proposed activities...... 17 2.8 Motivation for the overall preferred site, activities and technology alternative...... 17 2.9 Full description of the process followed to reach the proposed preferred alternatives within the site...... 18 2.10 Details of the development footprint alternatives considered...... 18 2.11 Details of the Public Participation Process Followed ...... 20 2.12 Summary of issues raised by I&APs ...... 22 2.13 The Environmental attributes associated with the alternatives...... 26 2.14. Impacts and risks identified including the nature, significance, consequence, extent, duration and . probability of the impacts, including the degree to which these impacts ...... 45 Construction, Operational and Cumulative Impacts and Mitigations ...... 45 2.15. Methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks; ...... 52 2.16. The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected...... 53 2.17. The possible mitigation measures that could be applied and the level of risk...... 54 2.18. Motivation where no alternative sites were considered...... 59 2.19. Statement motivating the alternative development location within the overall site...... 60 2.20. Full description of the process undertaken to identify, assess and rank the impacts and risks the ...... activity will impose on the preferred site ...... 60 2.21. Assessment of each identified potentially significant impact and risk...... 70 2.22. Summary of specialist reports...... 75 2.23. Environmental Impact Statement ...... 77 2.24. Financial Provision ...... 84 2.25. Specific Information required by the competent Authority ...... 86 2.26. Other matters required in terms of sections 24(4)(a) and (b) of the Act...... 87

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

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

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

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

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

1.1 Objective of the basic assessment process The objective of the basic assessment process is to, through a consultative process – (a) determine the policy and legislative context within which the proposed activity is located and how the activity complies with and responds to the policy and legislative context, (b) identify the alternatives considered, including the activity, location, and technology alternatives; (c) describe the need and desirability of the proposed alternatives,

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(d) through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which focused on determining the geographical, physical, biological, social, economic, heritage, and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on the these aspects to determine: (i) the nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and (ii) the degree to which these impacts – (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be managed, avoided or mitigated; (e) through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will impose on the sites and location identified through the life of the activity to – (i) identify and motivate a preferred site, activity and technology alternatives; (ii) identify suitable measures to manage, avoid or mitigate identified impacts; and (iii) identify residual risks that need to be managed and monitored.

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PART A

2. SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT

2.1 Contact Person and correspondence address

Details of the EAP

Name of the Practitioner: Giles John Churchill

Tel No:035 3402715

Fax No: 035 3402232

E-mail address:[email protected]

Postal Address:

ACER (Africa) Environmental Consultants P.O.Box 503 Mtunzini 3867

Expertise of the EAP

The qualifications of the EAP

Year: 1999 BSc - Zoology and Geography (Rhodes University) Year: 2000 BSc Hons – Fisheries Science (Rhodes University) Year: 2003 MSc – Fisheries Science (Rhodes University)

SACNASP Registration Number: 116348 in the Field of Environmental Science

See Appendix 1 for Academic Transcripts

Summary of the EAP’s past experience.

(In carrying out the Environmental Impact Assessment Procedure)

Mr G Churchill who is currently an Environmental Consultant and Director of ACER (Africa) Environmental Consultants (ACER) was originally trained as an ichthyologist and was involved in a number of community aquaculture initiatives in KwaZulu-Natal, South Africa. He then became interested in the ecological and social environment branching out into environmental consulting in 2007. Since then he has over 9 years of experience in conducting environmental impact assessments within both South Africa and SADC countries (Mozambique). He has

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undertaken numerous environmental assessments across a range of sectors including irrigated agriculture (including sugar cane and processing), transport, ports, renewable energy, and, protected areas management and conservation. His role in the assignments successfully completed has ranged from project manager, team leader, environmental assessment practitioner, specialist, internal reviewer, to team member, each role having different responsibilities and levels of accountability. In addition, he has been actively involved in compensation related activities in Mozambique in accordance to World Bank Standards and has an in depth knowledge of stakeholder engagement, compensation procedures and identification of beneficiaries. He has also been involved in a number of projects as an Environmental Compliance Officer over the last 7 years and has extensive experience in the drafting of Environmental Management Programmes (EMPr) and the implementation of these programmes with a focus on waste management and applicable legislation.

See Appendix 1 for the EAPs Curriculum Vitae

2.2 Location of the overall Activity

Farm Name: Pogela Farm Applications area (Ha) 3.11 Ha Magisterial district: City of uMhlathuze Local Municipality Distance and direction from 4.5 km southeast from Heatonville or 9.7 km northwest of nearest town Empangeni 21 digit Surveyor General N0GU00000001228000001 Code for each farm portion

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2.2.1 Locality map

Figure 1 Locality Map

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

Figure 2 Proposed Mining Plan for the Borrow Pit within which all activities will take place.

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2.4 Listed and specified activities

NAME OF ACTIVITY Aerial LISTED APPLICABLE LISTING (E.g. For prospecting – drill site, site extent of ACTIVITY NOTICE camp, ablution facility, the Mark with an (GNR 983, GNR 984 or GNR accommodation, equipment Activity X where 985) storage, sample storage, site office, Ha or m² applicable or access route etc….etc…etc affected.

E.g. for mining,- excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc…etc…etc.) John Readman Borrow Pit GNR 983, Listing Notice The proposed activity involves the 1,Activity 21 establishment of a Borrow Pit on 3.1 Ha or X Any activity including the Pogela Farm (Farm 1/12280) located 31,000 m2 (The listed operation of that activity which approximately 4.5 km to the southeast activities requires a mining permit in of Heatonville on the north coast of triggered by terms of section 27 of the KwaZulu-Natal. The Borrow Pit will the proposed Mineral and Petroleum have a footprint of 3.1 Ha. development Resources Development Act, are 2002 (Act No. 28 of 2002), Activities and infrastructure associated applicable for including associated with the Borrow Pit include the all infrastructure, structures and following: components earthworks directly related to of the Borrow the extraction of a mineral • Site establishment and Mining Pit). resource, including activities footprint – material will be removed for which an exemption has from the proposed Borrow Pit been issued in terms of footprint on a progressive basis in 2 section 106 of the Mineral and m high benches. Petroleum Resources • Site office – An existing building on Development Act, 2002 (Act site will be used for the site office. No. 28 of 2002). • Security Booth and boom gate – access to the Borrow Pit will be The proposed development controlled through the use of a requires a mining permit from boom gate which will be manned by the DMR. As such this listed security personnel. activity is triggered by the • Spoil stockpile sites – overburden proposed development. and topsoil will be stockpiled within the proposed 3.1 Ha Borrow Pit Activity 22 footprint for later rehabilitation of The decommissioning/closure the site. of any activity requiring – • Plant on site – plant on site will be (i) a closure certificate in limited to an excavator which will be terms of section 43 of the used to excavate material and Mineral and Petroleum

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stockpile the material on site. The Resources Development landowner currently has an Act, 2002 (Act No. 28 of excavator currently being 2002); or maintained and used on the farm. a prospecting right, mining As such it will not be required to right, mining permit, purchase any additional machinery production right or exploration during the operational phase of the right, where the throughput of proposed Borrow Pit. the activity has reduced by 90% or more over a period of 5 years excluding where the competent authority has in writing agreed that such reduction in throughput does not constitute closure.

Activity 27 The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous vegetation

Although most of the proposed Borrow Pit site has been transformed this listed activity may be triggered as much of the site is vegetated (grasses) and as such this activity has been applied for.

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2.5 Description of the activities to be undertaken (Describe Methodology or technology to be employed, including the type of commodity to be prospected/mined and for a linear activity, a description of the route of the activity)

2.5.1 Project description The proposed Borrow Pit on Pogela Farm (Farm 1/12280) located approximately 4.5 km to the southeast of Heatonville on the north coast of KwaZulu-Natal will be established to mine and sell weathered Dolerite to local and regional end users.

Weathered Dolerite which will be mined at the proposed Borrow Pit

The proposed Borrow Pit site is located on a commercial agriculture farm where most of the land use within the surrounding area consists of commercial sugar cane fields. The proposed site for the Borrow Pit is highly transformed and is currently used for the following activities:

 Small borrow area for material which is used to maintain farm roads  Storage area for organic fertiliser (Vinasse)  Loading zone for harvested sugarcane  Staff accommodation

The proposed Borrow Pit will require the demolition of some existing staff accommodation units which are currently in a state of disrepair. Mr Readman will move the staff from these accommodation units to a newer staff accommodation complex which has improved amenities and is fenced off for additional security. It is anticipated that the staff currently living at the proposed Borrow Pit site will see a marked improvement in their living conditions once moved to the other staff accommodation complex.

Given the small scale of the proposed Borrow Pit and the fact that the site is located on private property very little infrastructure is required on site in the form of fencing, security huts and mine infrastructure. Based on the information provided by Mr Readman (Land owner and Borrow Pit operator) infrastructure on site will be limited to the following:

 Site office/security office which will consist of one of the renovated accommodation units presently on site. Once mining has been completed this unit will be used as an office for the sugar cane loading zone to be established on this site.

Given the secure location of the proposed Borrow Pit and surrounding land uses no other infrastructure will be erected on site. In addition to the above the following infrastructure will not be required on site:

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 No fencing is required as the Borrow Pit is located on private property and no members of the public are anticipated to enter the proposed site. Security on site will also ensure that no unauthorized access to the Borrow Pit takes place.  Post operation, the Borrow Pit site will be utilized as a sugar cane loading zone by the landowner and as such rehabilitation of slopes and exposed areas on site will be limited to the outer slopes. Given the topography of the land and materials on site the potential for erosion is limited.  No access roads are required to access the site as the landowner already has access roads which enter the proposed Borrow Pit site. These access roads will be retained post operation to transport sugarcane to and from the loading zone which will be created within the Borrow Pit footprint.  Very limited spoil is anticipated from the Borrow Pit during operation due to the limited depth of overburden and topsoil over the weathered Dolerite which is to be mined on site. Topsoil removed during mining operations will be used to rehabilitate the outer exposed slopes within the Borrow Pit footprint.

The proposed primary mining activity will be limited to the 3.1 Ha project area (See Map M in Appendix 2 and/or Figure 1 above) and will include the following secondary operational activities:

 Site establishment.  Clearing of Vegetation.  Stockpiling of Topsoil.  Excavations/mining operations.  Loading of material.  Landscaping of mine area.  Progressive rehabilitation of mine area (as per the Rehabilitation Plan).  Closure of mine area (as per the Closure Plan).  Post closure monitoring.

All of the above activities will be undertaken within the ‘Borrow Pit footprint’ as shown in Figure 2. Due to the nature and size of this project, all these activities will be taking place within the project area in a progressive manner. This will result in no fixed location for the majority of activities, however it is expected that the following activities will have semi-permanent or permanent locations during the Operational, Rehabilitation and Closure Phases:

 Borrow Pit, Access Roads and Site Office (converted accommodation unit currently located on site).  Storm Water Management infrastructure such as drains.

2.5.2 Methodology used to assess the Borrow Pit site

Phase 1: Data Collection and Review

During this phase all available information concerning the proposed project was collected and accessed. The data accessed included, but was not limited to, property information (such as description, tenure and access to property), accessibility, biophysical characteristics (such as climate, geology, topography and vegetation) and potential heritage resources on site. The purpose of this phase of the assessment was to:

 Gain a thorough understanding of the background and issues related to the project and to identify sensitive environments within the study area.  Identify and assess alternatives for environmental flaws or concerns. These impacts will be rated for significance and placed in a matrix that will allow for the different alternatives to be compared and considered according to their potential impacts on the environment.

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 Review the existing data and identify information gaps in order to specifically focus the specialist study terms of reference to avoid repeating work.

Phase 2: Assessment and identification of impacts and mitigation measures

During this phase of the environmental impact assessment process specialists were appointed to investigate unknown variables pertinent to the project site and surrounding areas. This included the following specialist input:

 Heritage Specialist  Vegetation Specialist  Social Specialist

Findings from these studies and the assessment undertaken by the EAP were then assessed to identify any sensitive environments within the development footprint and surrounding areas. The appointed specialists were also tasked with identifying suitable mitigation measures to minimise potential impacts on the biophysical, social and economic environments.

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2.6 Policy and Legislative Context

Table 1 Applicable legislation. APPLICABLE LEGISLATION REFERENCE HOW DOES THIS AND GUIDELINES USED TO WHERE APPLIED DEVELOPMENT COMPLIY COMPILE THE REPORT WITH AND RESPOND TO (a description of the policy and legislative THE LEGISLATION AND context within which the development is POLICY CONTEXT. proposed including an identification of all legislation, policies, plans, guidelines, spatial (E.g. In terms of the National Water tools, municipal development planning Act a Water Use License has/ has not frameworks and instruments that are applicable been applied for) to this activity and are to be considered in the assessment process ) National Environmental Management The establishment of a Listed activities which require Act, No 107 of 1998 (as amended) Borrow Pit requires a authorisation in terms of (NEMA): mining permit from the NEMA and guides the various DMR as such this listed authorisation processes. Listed Activity no. 21 of Listing activity triggered and Notice 1 in terms of Regulation 983 requires environmental of 2014 approval.

National Environmental Management The decommissioning/ The decommissioning/ closure Act, No 107 of 1998 (as amended) closure of the proposed of the proposed Borrow Pit will (NEMA): Borrow Pit will require a require a closure certificate in closure certificate in terms of section 43 of the Listed Activity no. 22 of Listing terms of section 43 of Mineral and Petroleum Notice 1 in terms of Regulation 983 the Mineral and Resources Development Act, of 2014 Petroleum Resources 2002 (Act No. 28 of 2002). Development Act, 2002 (Act No. 28 of 2002). National Environmental Management The establishment of the Lists activities which require Act, No 107 of 1998 (as amended) Borrow Pit will result in authorisation in terms of (NEMA): the removal of over 1 Ha NEMA and guides the various of indigenous vegetation authorisation processes Listing Activity 27 of Listing Notice 1 (although highly in terms of Regulation 983 of 2014 disturbed) and will require environmental approval. Constitution of South Africa, The mining activity must An EMPr for the proposed specifically everyone has a right; be undertaken in a Borrow Pit has been drafted to a) to an environment that is not manner that does not ensure that mining activities harmful to their health or negatively impact on the shall be conducted in such a wellbeing; and environment and the manner that significant b) to have the environment rights of South African’s. environmental impacts are protected, for the benefit of avoided, where significant present and future generations, impacts cannot all together through reasonable legislative avoided be minimised and and other measures that: mitigated in order to protect i. prevent pollution and the environmental right of

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ecological degradation; South Africans ii. promote conservation; and iii. secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development

Minerals and Petroleum Development Need for a Mining Permit A Mining Permit Application Resources Act, Act 28 of 2002 has been submitted to the (MPRDA) section 16 ( as amended) DMR by the Applicant. The conditions and requirements attached to the granting of the mining permit will apply to the mining activities associated with the Borrow Pit.

National Environmental Management: Management of The EMPr which has been Biodiversity Act , 2004 biodiversity on site compiled will regulate the applicant’s implementation of biodiversity management measures. This is particularly relevant to the removal of indigenous vegetation and the control of alien invasive species on site.

National Environmental Management: Management of waste The EMPr which has been Waste Act, Act 59 of 2008 on site. compiled will regulate the (NEMWA)NEM: WA (as amended) applicant’s implementation of waste management measures on site. This is particularly relevant to the removal of existing buildings within the proposed Borrow Pit footprint and the disposal of this construction rubble.

It should be noted that no listed waste management activities are triggered by the proposed development and as such a Waste Permit is not required.

National Heritage Resources Act, 1999 Impact on Heritage This legislation aims to (Act No. 25 of 1999) Resources promote good management of the national estate, and to enable and encourage

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communities to nurture and conserve their legacy so that it may be bequeathed to future generations.

KwaZulu-Natal Heritage Act, 1997 (Act Impact on Heritage Amafa aKwaZulu-Natali is the No. 10 of 1997) Resources provincial department tasked with the protection of heritage resources. An application for exemption has been submitted to Amafa following an assessment of the area by Ethembeni Cultural Heritage who found no evidence of cultural heritage resources within the proposed development footprint.

National Water Act, Act 36 of 1998 National, Provincial and The proposed development (NWA) Regional Department of has impacts on wetlands and Water and Sanitation watercourses.

Conservation of Agricultural Resources Department of Relates to the control of alien Act, 1983 (Act 43 of 1983) Agriculture, Forestry, vegetation and Fisheries

National Forests Act (Act No. 84 of The development might If the development impacts on 1998) impact on protected tree protected tree species permit species. applications will be submitted to the Department of Agriculture, Forestry, and Fisheries for the translocation or destruction of these plant species.

KwaZulu-Natal Nature Conservation The development might If the development impacts on Ordinance 15. impact on protected protected plant species permit plant species. applications will be submitted to Ezemvelo KZN Wildlife for the translocation or destruction of these plant species.

Standards, Guidelines and Spatial Tools South African National Biodiversity The development may Based on a review of the Institute (SANBI) Biodiversity GIS be located within an area current biodiversity maps and (bgis.sanbi.org) identified as having a data available from SANBI and high level of biodiversity EKZNW the proposed Borrow or occur in a threatened Pit site is not located within a vegetation type. threatened or high biodiversity area. EKZNW Database The development may Based on a review of the

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be located within an area current EKZNW databases no which is known to be the vulnerable or endemic species habitat of threatened or were identified within or endangered plants, around the proposed Borrow animals and insects. Pit site.

Integrated Environmental Management Impact Assessment and Works in conjunction with (IEM) guideline series published by mitigation measures NEMA and is used to identify, DEA (various documents dated from predict and evaluate actual 2002 to present) and potential impacts and the risks, consequences and alternatives for mitigation of activities.

2.7 Need and desirability of the proposed activities. (Motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location).

The proposed Borrow Pit is being established to mining and selling weathered dolerite. This material is a crucial raw material in the construction process of various infrastructures.Currently there are no commercial sources of gravel locally or regionally available for the local construction industry. The establishment of the proposed Borrow Pit will seek to fill this gap and provide a source or local gravel to any end user.

Currently the proposed site for the Borrow Pit is highly transformed and is used for the following activities:

 Small borrow area for material which is used to maintain farm roads  Storage area for organic fertiliser (Vinasse)  Loading zone for harvested sugarcane  Staff accommodation

Taking the current land use into consideration and the input from the specialists, the proposed development will have no impacts that cannot be mitigated or controlled to environmentally and socially acceptable levels.

2.8 Motivation for the overall preferred site, activities and technology alternative.

Preferred site Site alternative A: The preferred site for the proposed Borrow Pit is Pogela Farm (Farm 1/12280) located approximately 4.5 km to the southeast of Heatonville on the north coast of KwaZulu-Natal. No other properties were considered as the current preferred site will not require the need for new mining equipment or machinery as the farm owner, Mr John Readman, already has an existing excavator and staff available which will be used during operations. Additionally, specialist studies conducted indicate the proposed Borrow Pit will not to have any impact on surrounding water resources or the receiving environment that cannot be effectively mitigated or controlledto acceptable levels. As such, no other site alternatives have been considered.

Preferred activity Activity alternative A: The type of activity to be undertaken is the phased removal of gravel through surface excavations from the proposed Borrow Pit site.No other activity alternatives have been considered as the plant, preferred site and monetary limitations limits the proposed development to the ActivityAlternative A: The preferred activity.

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Preferred technology Technology alternative A: Technology on site will be limited to one excavator already in operational use and being maintained by the Applicant. Staff already employed on the farm will be employed during operations. No other technology alternatives have been considered as the plant, preferred site and monetary limitations limits the proposed development to the technology alternativeA.

2.9 Full description of the process followed to reach the proposed preferred alternatives within the site. (NB!! – This section is about the determination of the specific site layout and the location of infrastructure and activities on site, having taken into consideration the issues raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout.)

The preferred alternatives for the proposed Borrow Pit are the only alternative considered. The activity will include the phased mining of the mining area in 2m high benches. With the completion of each phase, progressive rehabilitation as per the Rehabilitation Plan (Appendix 8) will be implemented before the commencement of mining activities on the following phase. After the cessation of mining activities, the areas that will not be used as a loading zone for the loading of sugarcane will be rehabilitated.

The stakeholder comment period has not been undertaken yet, and therefore comments raised by I&APs have not been included in this section. However, the sections will be updated in the final report.

2.10 Details of the development footprint alternatives considered. With reference to the site plan provided as Appendix 2 and in Figure 2 of this report and the location of the individual activities on site, provide details of the alternatives considered with respect to:

The property on which or location where it is proposed to undertake the activity

The property on which the proposed Borrow Pit is to be established, Pogela Farm, is an operational farm owned and operated by Mr John Readman. The Borrow Pit will have a footprint of 3.1 Ha. The preferred alternative is the only alternative considered. It does involve the relocation of the farm workers homes, which will be done by Mr J Readman. The staff compounds that are currently located at the area proposed for this Borrow Pit, will be demolished and the staff will be relocated to the south-western section of the farm to existing staff accommodation units. The new location will improve the standard of living of the staff; this is due to the buildings being newer and therefore including running water, electricity and ablution facilities.

The type of activity to be undertaken

The type of activity to be undertaken is the phased removal of gravel through surface excavations from the proposed Borrow Pit site.

The design or layout of the activity

Material will be removed from the proposed Borrow Pit footprint on a progressive basis in 2 m high benches with one existing excavator owned by the Applicant which will be used to excavate material and stockpile the material on site at the demarcated areas. During operations, excavations will commence on the western portion of the mining area, indicated as phase 1 on Figure 2. Once all of the material is removed from the phase one area, progressive rehabilitation as indicated in the Rehabilitation Plan (See Appendix 8) will be implemented. Subsequently, excavations will continue on the area indicated on Figure 2 as phase 2 which

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will be rehabilitated progressively. This will continue for phases one to four. Phase five as shown on the mining plan (Figure 2) indicates the location of the new staff living quarters reserved for the staff that will be relocated from the proposed mining area.

The technology to be used in the activity

Only one exactor will be used for excavations. A site office and a security booth are the only infrastructure that will be built up at the Borrow Pit site. A spoil stockpile site will also be established for the depositing of overburden soil and topsoil, which will be located within the proposed 3.1 Ha Borrow Pit footprint at an area agreed upon by the Applicant, the ECO and the competent authority. The material from the spoil stockpile will be used to rehabilitate the Borrow Pit site on a progressive basis as indicated in the Rehabilitation Plan (Appendix 8).

It is important to note that the proposed location and preferred technology option as described above will not require the purchase of any new mining equipment or vehicles, additionally; it will provide a limited amount of job opportunities and increase the standard of living of the staff being relocated from the proposed mining footprint. As such, no additional technology alternative has been considered.

The operational aspects of the activity

The proposed primary mining activity will be limited to the 3.1 Ha project area (See Map “L” in Appendix 2) and will include the following secondary operational activities:

 Site establishment.  Clearing of Vegetation.  Stockpiling of Topsoil.  Excavation of overburden material.  Loading of material.  Landscaping of mine area.  Progressive rehabilitation of mine area (as per the Rehabilitation Plan).  Closure of mine area (as per the Closure Plan).  Post closure monitoring.

All of the above activities will be undertaken within the ‘Borrow Pit footprint’ as shown in Figure 1 and in Map “L” in Appendix 2. Due to the nature and size of this project, all these activities will be taking place within the project area in a progressive manner. This will result in no fixed location for the majority of activities, however it is expected that the following activities will have semi-permanent or permanent locations during the Operational, Rehabilitation and Closure Phases:

 Borrow Pit, Access Roads and Site Office (converted accommodation unit currently located on site).  Storm Water Management infrastructure such as drains.

The option of not implementing the activity

The option of not implementing the activity has been considered, however due to the low-medium potential of long-term negative impacts to the receiving environment and the beneficial indirect and cumulative impacts on the social, economic and development potential of the project on a regional scale, The ‘No-Go’ option is considered to be the least favoured project alternative.

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

A total of 19 Individuals and/or organisations/departments were registered in relation to the proposed John Readman Borrow Pit Project. Interested and Affected Parties can be separated into the following groupings:

 National, Provincial and Local Government: 13  Private Property Owners: 4  Other: 2

The following Public Participation activities were undertaken in terms of the proposed John Readman Borrow Pit Project:

 Notification of the surrounding landowners, adjacent to the Pogela Farm.  Email sent to all identified Interested and Affected Parties – both for the Project Announcement and the Announcement of the availability of the Draft Basic Assessment Report.  Consultation with relevant government departments: . Department of Mineral Resources and Energy . Department of Economic Development, Environmental Affairs and Tourism . Department of Water and Sanitation . Department of Agriculture, Forestry and Fisheries . Amafa AkwaZulu Natali . Ezemvelo KZN Wildlife  City of uMhlathuze Municipality (Local Municipality).  King Cetshwayo District Municipality.  Placed an on-site notice board at the location of the borrow pit, on the Pogela Farm.  Placed an Advert in the local paper (Zululand Observer 17 November 2016).  All information pertaining to the project was placed on the ACER (Africa) Website.

The following standardised documents were created in regards to the Public Participation Process:

 On-site Notice Board English  Newspaper Advert English  Project Notification Document English  Project Notification Letter English  Background Information Document English  Comment Sheet English  Landowner Notification Form English  Draft Basic Assessment Report and Draft Environmental Management Programme including the following stand-alone document: . Appendix 1: Principal Environmental Consultant – Curriculum Vitae . Appendix 2: Map Suite . Appendix 3: Photo Report . Appendix 4: Draft Public Participation Report . Appendix 5: Specialist Studies . Appendix 6: Financial and Technical Report . Appendix 7: Quantum of Closure . Appendix 8: Rehabilitation Plan

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. Appendix 9: Closure Plan . Appendix 10: Stormwater Management Plan . Appendix 11: Mitigation Plan . Appendix 12: Bank Confirmation

Meeting and Site Visit Register

 Pre-application Meeting with Department of Mineral Resources and Energy on the 25 October 2016 to discuss the proposed project and to establish what project specific requirements they might have.

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2.12 Summary of issues raised by I&APs

(Complete the table summarising comments and issues raised, and reaction to those responses) Interested and Affected Parties Date Issues raised EAPs response to issues as mandated by Section and Comments the applicant paragraph List the names of persons consulted in this Received reference in this column, and report where the Mark with an X where those who must be issues and or consulted were in fact consulted. response were incorporated. AFFECTED PARTIES Landowner/s X APPLICABLE Mr John Readman X Signed Landowner Notification 1) Signed Land Owner Notification Form 1) No response required Not Applicable Form 16 March 2017 Lawful occupier/s of the land NOT APPLICABLE: The farm is owned by Mr Readman Landowners or lawful occupiers on X APPLICABLE adjacent properties Victor Smith X Signed Landowner Notification 1) Signed Land Owner Notification Form 1) No response required Not Applicable Form 4 March 2017 Brett Hume X Signed Landowner Notification 1) Signed Land Owner Notification Form 1) No response required Not Applicable Form 4 March 2017 Jonathan James X Signed 1) Signed Land Owner Notification Form 1) No response required Not Applicable

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Landowner Notification Form 4 March 2017 Chris de Beer X Signed Landowner Notification 1) Signed Land Owner Notification Form 1) No response required Not Applicable Form 5 January 2017 Municipality X APPLICABLE Mr. N.J Sibeko X Not applicable 1) No feedback received to date. 1) No response required. Not Applicable Municipal Manager uMhlathuze Local Municipality Ms. S Govender X Not applicable 1) No feedback received to date. 1) No response required. Not Applicable Project Manager: Environmental Planning uMhlathuze Local Municipality Mr. M.H Nkosi X Not applicable 1) No feedback received to date. 1) No response required. Not Applicable Municipal Manager King Cetshwayo District Municipality Mr. B Dlamini X Not applicable 1) No feedback received to date. 1) No response required. Not Applicable Environmental Health Manager King Cetshwayo District Municipality Organs of state And Competent X APPLICABLE Authorities Department of Agriculture, Forestry and X 23 November The Department of Agriculture, Forestry Noted. Not Applicable Fisheries (DAFF). 2016 and Fisheries (DAFF) appreciates the opportunity given to review and comment Sent the Department the Draft Basic on the Background Information Document Assessment for review and comment during (BID) received on the 17 November 2016 the legislated comment period. for the above mentioned project. DAFF

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through the Sub-Directorate Forestry Regulations and Support is mandated to regulate activities affecting natural forests and tree species protected in terms of the National Forests Act, 1998 (Act No. 84 of 1998) in South Africa.

The information provided on the Background Information Document is not sufficient for the department to provide informed decisions. However the Department will comment further upon receipts and review of Draft Basic Assessment Report including Vegetation Specialist Report. Department of Water and Sanitation X Not applicable 1) No feedback received to date. 1) No response required. Not Applicable Ezemvelo KZN Wildlife X 24 February Thank you for forwarding the Noted Not Applicable 2017 abovementioned application to Ezemvelo KZN Wildlife (Ezemvelo) for review and comment. Ezemvelo will not be providing comment on this application, but trust that all significant biodiversity related concerns have been clearly identified and made known in this assessment together with appropriate measures to safeguard the ecological integrity (viz. avoid, mitigate and thereafter ameliorate) of the developable area. Please be advised that the potential impacts upon biodiversity will be evaluated by the Competent Authority who may, upon receipt, refer the application this

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organization for evaluation and advice prior to making a decision. In such case, the environmental principles prescribed in the National Environmental Management Act 107 of 1998, the objectives of the National Environmental Management Biodiversity Act 10 of 2004 and best practice will be applied. Department of Mineral Resources and X Meeting on the Pre- Application meeting. ACER met with Department of Mineral Refer to Appendix Energy 25 October Resources (DMR) on the 25 October 2016 in 4 - Public 2016 the Durban offices to discuss the project and to Participation establish a way forward. Report Amafa AkwaZulu Natali X Application Lodged an application for exemption with No response received to date. Refer to Appendix lodged on the Amafa on the 24 January 2017 5 - Specialist 24 January Studies 2017 DEDTEA X Not applicable 1) No feedback received to date. 1) No response required. Not Applicable Communities NOT APPLICABLE: No communities as it is private land Traditional Leaders NOT APPLICABLE: No Traditional Authorities as it is private land. OTHER INTERESTED AND AFFECTED No other comments received to date. PARTIES

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

2.13.1 Baseline Environment

a. Type of environment affected by the proposed activity. (Its current geographical, physical, biological, socio- economic and cultural character).

Socio-economic

The proposed Borrow Pit site is located on Mr J Readman’s farm (Farm Number 1/12280) which is located approximately 4.8 km southeast of Heatonville on the north coast of KwaZulu-Natal within The City of uMhlathuze (KZ 282) and the King Cetshwayo District Municipality (DC 28).

Figure 3 Map showing the 5 Local Municipalities within the King Cetshwayo District Municipality.

The King Cetshwayo District Municipality (previously known as the uThungulu District Municipality) is a Category C municipality and covers an in the north-eastern region of the KwaZulu-Natal Province. It covers an area of approximately 8213m2 and includes the areas from the uMfolozi River in the north, to KwaGingindlovu (previously known as Gingindlovu) in the south, and inland to Nkandla. The district is home to five local municipalities: City of uMhlathuze, uMlalazi, Mthonjaneni, Nkandla and uMfolozi. Cities and towns within the district include:Empangeni, Eshowe, KwaGingindlovu, KwaMbonambi, Melmoth, Mtunzini, Nkandla, Ntambanana and Richards bay.

The development of the Richards Bay Industrial Development Zone (RBIDZ) and the big manufacturing companies located within Richards bay i.e. Hillside, Foskor, Richards bay Minerals

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(RBM) Richards Bay Coal Terminal (RBCT) and Mondi not only serves as a great attraction to international investors but also contributes significantly to manufacturing sector within region which is the largest economic sector at 40.9%. Other economic sectors include: mining (15.2%), community services (11.9%), finance (8.7%), transport (8.5%), trade (6.5%), agriculture (5.3%) and construction (2.1%).

Table 2 Demographic overview of the King Cetshwayo District Municipality.

2016 2011

Population 971 135 907 519

Age Structure

Population under 15 39.9% 34.8%

Population 15 to 64 55.9% 60.7%

Population over 65 4.2% 4.5%

Dependency Ratio

Per 100 (15-64) 78.8 64.7

Sex Ratio

Males per 100 females 89.9 89.0

Population Growth

Per annum 1.54% n/a

Labour Market

Unemployment rate (official) n/a 34.7%

Youth unemployment rate (official) 15-34 n/a 44.4%

Education (aged 20 +)

No schooling 13.3% 16.0%

Matric 36.0% 30.1%

Higher education 9.2% 8.5%

Household Dynamics

Households 225 797 202 976

Average household size 4.3 4.2

Female headed households 49.8% 48.9%

Formal dwellings 70.6% 70.0%

Housing owned 79.7% 51.8%

Household Services

Flush toilet connected to sewerage 27.4% 27.2%

Weekly refuse removal 27.3% 29.6%

Piped water inside dwelling 26.9% 30.5%

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2016 2011

Electricity for lighting 91.6% 75.8%

Source: https://www.localgovernment.co.za/districts/view/24/King-Cetshwayo-District-Municipality

The City of uMhlathuze Local Municipality is a Category B municipality situated within the King Cetshwayo District on the north-eastern coast of KwaZulu-Natal. It is the smallest of the five municipalities (See figure 2) that make up the district. After the 2016 Local Government elections parts of the land within the Ntambanana Municipality was incorporated into the uMhlathuze Municipality (uMhlathuze IDP, Final Review 2016/2017). The Ingonyama Trust owns 35% of the land in the uMhlathuze Municipality area, with 42% being privately owned and the remaining 23% being owned by either Water Bodies or other institutions.

It is a strategically placed, aspirant metropolitan due to its close proximity to Durban. Additionally, it is home to the country’s largest deep-water port with one of the leading coal export terminals in the world, Richards Bay Coal Terminal (RBCT). Opened in 1976 with an original capacity of 12 million tons per annum, it has grown into an advanced 24-hour operation with a design capacity of 91 million tons per annum.The area is the third most important in KZN in terms of economic production, contributing 16.7% to national Gross Domestic Product (GDP) whilst also the third most important primary manufacturing area in the province in terms of economic production.

Within the uMhlathuze Local Municipality, Richards Bay is considered to be the industrial and tourism hub, Empangeni the commercial hub and eSikhaleni the largest suburb.The main access into the municipal area is via the N2 in a north/south direction and in an east/west direction the R34 from Ntambanana. Other significant roads in the area include the MR431 (that provides a northerly entry into Richards Bay from the N2) as well as the Old Main Road that follow the N2. Railway lines are prevalent in the municipal area but do not provide a passenger service, only a commercial/industrial service is provided.

Table 3 Demographic overview of the City of uMhlathuze’s Local Municipality.

2016 2011

Population 410 465 362 778

Age Structure

Population under 15 34.7% 29.9%

Population 15 to 64 62.0% 66.8%

Population over 65 3.3% 3.3%

Dependency Ratio

Per 100 (15-64) 61.3 49.6

Sex Ratio

Males per 100 females 93.3 94.6

Population Growth

Per annum 2.81% n/a

Labour Market

Unemployment rate (official) n/a n/a

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2016 2011

Youth unemployment rate (official) 15-34 n/a n/a

Education (aged 20 +)

No schooling 5.9% 7.9%

Matric 44.3% 36.8%

Higher education 13.5% 12.6%

Household Dynamics

Households 110 503 91 843

Average household size 3.7 3.6

Female headed households 43.3% 41.3%

Formal dwellings 88.3% 87.5%

Housing owned 74.9% 52.2%

Household Services

Flush toilet connected to sewerage 45.7% 47.1%

Weekly refuse removal 43.1% 50.6%

Piped water inside dwelling 43.0% 47.7%

Electricity for lighting 98.8% 93.0%

Source: https://www.localgovernment.co.za/locals/view/110/City-of-uMhlathuze-Local-Municipality#demographic

Cultural

According to the findings of the heritage assessment practitioner, no graves are located or reported in the immediate precinct of the planned expansion and any associated plant and services proposed. The compound buildings are utilitarian, in a state of disuse and of no intrinsic significance.

The Ntabanana and Heatonville farms were granted in compensation to returning service-men after World War I (1918) and World War II (1945). These farms have been under sugar cane production for at least the last 40 to 50 years.

More than half a century of commercial agriculture has masked over any primary context archaeological material that may have been present on Pogela Farm. Furthermore, the specialist’s findings revealed that no significant archaeological remains are anticipated and the SAHRIS Palaeontology sensitivity map indicated that the area is of low sensitivity. Additionally, the basement rock to be quarried at the Borrow Pit is dolerite which is not fossil bearing. Consequently no further palaeontology assessment or monitoring is recommended.

As such, an application for exemption from an HIA has been submitted to Amafa for the proposed development.

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Climate

KwaZulu-Natal has a varied yet lush climate thanks to diverse and complex topography. Generally, the coast is sub-tropical with inland regions becoming progressively colder. Durban, the capital of KZN located approximately 150 km south of the proposed site, has an annual rainfall of 1009 mm.

The climate within the uMhlathuze Municipality is characterized as being warm to hot and humid subtropical climate, with warm moist winters. The maximum daily average temperatures range from 29°C in January to 23°C in July. The extremes temperatures can reach up to or more than 40°C in summer. Up to 80% of the annual rainfall occurs in the summer months, which are October to March, with the average annual rainfall being 1228 mm. Thunderstorms are a common occurrence in the Zululand Region, with extreme events resulting in extensive flooding that can lead to loss in property, life and infrastructure. There has been a trend increase in the frequency of cyclonic activity that should be considered in future planning of the uMhlathuze Municipality region.

The proposed site is located approximately 4.5 km from the small town of Heatonville, which is also the closest town. Due to the short distance and small difference in elevation, climatic conditions experienced at Heatonville will be almost identical to that expected on the proposed site. The information provided in the figures below has been accumulated between the years of 2000 and 2012.

Figure 4 Average rainfalls for Heatonville from year 2000-2012.

(Source: https://www.worldweatheronline.com).

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Figure5 Average temperature in Celsius Degrees for Heatonville from year 2000 – 2012.

(Source: https://www.worldweatheronline.com).

Wetlands and watercourses

The proposed borrow pit is not located within the regulated area of any wetland (500 m) or a watercourse (1:100 year floodline or riparian area).This is the distance at which an activity is deemed to have the potential to impact on the resource quality of a wetland or watercourse respectively, and for which authorisation for the undertaking of the activity is required from the Department of Water and Sanitation (DWS).

The specialist studies conducted revealed one farm dam, registered on the National Freshwater Ecosystem Priority Areas (NFEPA) database as a wetland, constructed on an NFEPA river, and an ephemeral drainage line within the study area (Figure 5). These watercourses are discussed below.

Farm Dam (NFEPA Wetland) A man made farm dam, built in a drainage line which drains in a south east direction, is located approximately 540 m from the site for the proposed borrow pit. The water resource is on the National Freshwater Ecosystem Priority Areas (NFEPA) database, which identifies a national network of freshwater conservation areas and institutional mechanisms for their implementation.

The proposed activity does not fall within the regulated area of this artificial wetland and will not impact negatively on the quality of this water resource. Therefore, no further assessment of the system was conducted or deemed necessary, and no authorisations from DWS are required.

Ephemeral Drainage Line An ephemeral drainage line that drains in a south westerly direction is located approximately 175 m north-west of the site for the proposed borrow pit. The valley consists of remnant clumps of riparian vegetation, typical for valley bottoms within the Zululand Coastal Thornveld vegetation type, and has been planted through with sugarcane in other areas.

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Ephemeral Drainage Line Farm Dam

Proposed

Borrow

Figure 6 Wetlands and watercourses within the proposed borrow pit study area.

Past disturbances include the clearing of indigenous vegetation for roads and sugarcane cultivation. Habitat fragmentation, infestations of alien invasive plants, erosion and sedimentation have all contributed to the poor current condition of this habitat, although it still holds important biodiversity value and provides refugia to fauna in the area.

The proposed development is located well outside the regulated area of the watercourse; which is the 1:100 year floodline, the edge of the riparian area, or whichever distance is greater. The National Water Act, 1998 (Act No. 36 of 1998), defines a riparian habitat as follows: “Riparian habitat includes the physical structure and associated vegetation of the areas associated with a watercourse, which are commonly characterised by alluvial soils, and which are inundated or flooded to an extent and with a frequency sufficient to support vegetation of species with a composition and physical structure distinct from those of adjacent land areas”.

Topography

The proposed Borrow Pit site is located on the north-westerly slope of a hill and occurs at an elevation of between 200 m and 170 m. The south eastern corner of the proposed site has the highest elevation of approximately 200 m above sea level (ASL) with the lowest point being located on the north western section with an elevation of between 170m and 176 m ASL. The proposed site will drain towards the east. The topography of the area is characterised by rolling green hills that rise from the coastal plain in the east to the end of the plateau in the west. It is surrounded by meandering valleys and sugarcane farms.

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Figure 7 Elevation profile from east to west.

Figure 8 Elevation profile from north to south.

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Vegetation Cover

The specialist studies conducted revealed that according to (Mucina and Rutherford, 2012), and confirmed by more recent vegetation mapping by EKZNW, the following two vegetation types occur naturally within the study area: Zululand Coastal Thornveld(SV1 24) and Zululand Lowveld (SVI 23). Figure 12 also shows Subtropical Alluvial Vegetation (AZa 7), Subtropical Freshwater Wetlands (AZf 6) and Northern Coastal Forest (FOz 7). However, these vegetation types are not represented in the study area and will therefore not be discussed further.

The proposed site has been delineated into the relevant current land use areas. As such, the vegetation present within these areas has been described in the sections below.

Existing Borrow Pit (0.51 ha) The northern corner of the proposed site is an existing borrow area (Figure 8), from which material has previously been mined out for use on the Pogela Farm, for activities such as the construction and maintenance of farm roads. The borrow area is also currently being used to store a large tank containing sugarcane vinasse, a by-product in the sugar production process, which is being used by Mr J. Readman as an organic fertiliser on his farm.

The tank storing the sugarcane vinasse has an over flow pipe leading into the borrow area where the thick black substance has pooled in some areas. The disturbances as described above have resulted in an infestation of alien invasive and pioneer plant species, thriving in the disturbed environment with a lack of competition from indigenous species.

Existing borrow area within the proposed Borrow Pit site

Figure 9 Existing borrow area within the proposed J. Readman Borrow Pit site

Species observed within the existing borrow area include: Bidens pilosa*, Chromolaena odorata*, Lantana camara* Lepidium bonariense*, Leucaena leucephala*,Melia azedarach*, Psidium guajava*, Ricinus communis*, Schinus terebinthifolius*, Senna didymobotrya*, Solanum mauritianum*, Tagetes minuta*, Tridax procumbens*, and Verbena aristigera*.

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Indigenous vegetation in this area is limited to young medium sized individual plants which have established themselves on the perimeter of the pit. The following indigenous species were recorded within the existing borrow area: Acacia robusta, Ficus sycamorous, Harpephyllum caffra, Melinis repens and Trichilia emetica.

Staff Accommodation Compound (2.6 ha) The remainder of the site for the proposed borrow pit currently serves as a compound for farm workers. Disturbances since the initial earth works and site clearance for the building of the compound include dumping of general waste and the maintenance of grassed areas between units. As a result of these past and current disturbances, vegetation is limited to informal rows of large fruit and shade providing trees and alien invasive shrubs which have become established on the cut/fill slopes between the terraces on which the compound units have been built.

Staff Compound within proposed Borrow Pit site

Figure 10 Staff compounds within the proposed Borrow Area

Despite these disturbances, the large established trees, indigenous and exotic, offer some biodiversity value in terms of habitat and food to fauna in the area, particularly birds. Indigenous plant species recorded onsite include: Acacia robusta, Ekbergia capensis,Ficus sycamorous,Harpephyllum caffra, Panicum maximum, Syzigium cordatum, Trichilia emetica, and Trema orientalis.

Alien species recorded included: Cassuarina equesitifolia*, Mangifera indica*,Psidium guajava*, Schinus terebinthifolius*, Melia azedarach*, Chromolaena odorata*, Cestrum laevigatum*,Bidens pilosa*, Senna didymobotrya*, Ricinus communis*,Lantana camara*,and Solanum mauritianum*.

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Recovering Zululand Coastal Thornveld The area immediately south of the site for the proposed borrow pit is considered an early successional, recovering representation of the Zululand Coastal Thornveld vegetation type. The species composition and aerial imagery suggest that at least parts of the area were once under cultivation which is now making a recovery. Although still strongly comprised of alien invasive and pioneer plants that originally colonised the disturbed area, the vegetation shows strong characteristics of the Zululand Coastal Thornveld vegetation type.

Recovering Zululand Coastal Thornveld

Figure 11 Early successional, recovering Zululand Coastal Thornveld vegetation type immediately south of the proposed J. Readman Borrow Pit site.

Since the initial disturbances, as described above, the lack of fire and grazing have resulted in the vegetation recovering to a densely wooded representation of the Zululand Coastal Thorveld vegetation type. The area is dominated with woody species such as: Acacia karroo, Acacia nilotica, Dichrostachys cinerea, Phoenix reclinata, Gymnosporia buxifolia, Schinus terebinthifolius, Ficus natalensis, Ficus sycamorous, Albizia adianthifolia, Ziziphus mucronata, Trichilia emetica, Syzygium cordatum, Trema orientalis, and Sclerocarya birrea subspecies caffra.

Riverine Bushland Thicket An ephemeral drainage line that drains in a south westerly direction is located approximately 175 m north-west of the proposed borrow pit. The valley has remnant clumps of riverine bushland thicket, typical for valley bottoms within the Zululand Coastal Thornveld, and has been planted through with sugarcane in other areas.

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Riverine Bushland Thicket

Figure 12 Fragmented Riverine Bushland Thicket in the valley north-west of the proposed site.

Different species show dominance along different parts of the valley, however, the canopy is for the most part dominated by Ficus sycamorous, Rauvolfia caffra, Bridelia micrantha, Albizia adianthifolia, Ziziphus mucronata, Trichilia emetica, Syzygium cordatum, Trema orientalis, Strelitzia nicolai, and Phoenix reclinata. The fragmentation of the riverine bushland thicket has resulted in the edges becoming infested with alien invasive species, including: Psidium guajava*, Schinus terebinthifolius*, Melia azedarach*, Solanum mauritianum*, Lantana camara*, and Chromolaena odorata*.

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Figure 13 Vegetation Map of the proposed Borrow Pit and surrounding areas.

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(a) Description of the current land uses.

• Small borrow area for material which is used to maintain farm roads • Storage area for organic fertiliser (Vinasse) • Loading zone for harvested sugarcane • Staff accommodation

The proposed Borrow Pit will require the demolition of some existing staff accommodation units which are currently in a state of disrepair. Mr Readman will move the staff from these accommodation units to another staff accommodation complex which has improved amenities and is fenced off for additional security. It is anticipated that the staff currently living at the proposed Borrow Pit site will see a marked improvement in their living conditions once moved to the other staff accommodation complex.

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

As most of the land use consists of commercial sugar cane fields, most of the proposed Borrow Pit site and the surrounding areas have been previously disturbed through the following activities:

1. Staff accommodation (the proposed Borrow Pit site has approximately 15 dwellings on it, some of which are dilapidated and no longer used by the farmer). 2. Small Borrow Pit for material to maintain farm roads on the property. 3. Storage area for organic fertiliser which is used to fertilise the sugar cane fields. 4. Commercial sugarcane fields. 5. Farm infrastructure (roads, drains, etc.).

The area has been significantly transformed through benching to create the platforms for the existing accommodation units.

Small borrow area within the proposed Borrow Pit site where the land owner has removed material to use on the maintenance of farm roads

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Dilapidated accommodation units and benched terraces within the proposed Borrow Pit Development footprint.

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Current land use features at the proposed borrow pit site include the following:

1. Existing borrow area where the farmer has removed material for the maintenance of farm roads (Figure 14)

Figure 14: Existing borrow area (shaded area) within the proposed Borrow Pit footprint.

2. Existing staff accommodation complex

Figure 15: Staff accommodation complex (shaded area) located within the proposed Borrow Pit footprint.

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Current environmental features near the proposed borrow pit site include the following:

1. Recovering Zululand Coastal Thornveld

Figure 16: Zululand Coastal Thornveld vegetation type located immediately south of the proposed Borrow Pit site (Yellow shaded area)

2. Patches of Riverine Bushland Thickets located approximately 180 m to the west of the proposed Borrow Pit site.

Figure 17: Patches of Riverine Bushland Thicket (Green shaded areas) located approximately 180 m west of the proposed Borrow Pit site.

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3. Drainage lines and farm dams.

Figure 18: Ephemeral drainage lines to the west and north east of the proposed Borrow Pit site as well as a small farm dam on the north-eastern drainage line.

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Figure 19: Wetlands within the proposed project area. PROPOSED BORROW PIT ON POGELA FARM NEAR HEATONVILLE BASIC ASSESSMENT REPORT 44

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2.14. Impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts (Provide a list of the potential impacts identified of the activities described in the initial site layout that will be undertaken, as informed by both the typical known impacts of such activities, and as informed by the consultations with affected parties together with the significance, probability, and duration of the impacts. Please indicate the extent to which they can be reversed, the extent to which they may cause irreplaceable loss of resources, and can be avoided, managed or mitigated).

Construction, Operational and Cumulative Impacts and Mitigations

The impacts associated with the establishment and operation of the proposed Borrow Pit on the natural environment is listed below, together with the recommended mitigation measures. The significance of these impacts was assessed in terms of the impact assessment criteria provided in the section below (Section IV).

Table 4 Construction and Operational Impacts with Mitigations

IDENTIFIED IMPACTS AND RCOMENDED MITIGATIONS MEASURES: RISK: Dust and air pollution Dust-suppression techniques (e.g. the spray of water) must be employed on all exposed surfaces during periods of high wind. Potential methods include:

. Remove only limited vegetation to accommodate mining activities during periods of heavy winds. . Spray unpaved roads and construction areas, including stockpiles and spoil, with water routinely throughout construction to contain dust. . Re-vegetate verges and cuttings as soon as possible.

Should dust become an issue or dust related complaints be received, then the Applicant must install a temporary cover (shade cloth) over the exposed mining stockpiles and sub-soil stockpiles and vegetate top-soil stockpiles with indigenous grass species.

Storm water impacts . Appropriate drainage measures must be taken to ensure that excessive run-off, and as a result, soil erosion, does not occur from the mining area. . Where directed by the ECO, embankments must be grassed to minimise erosion. . Clearing activities must only be undertaken during agreed working times and permitted weather conditions. If heavy rains are expected clearing activities should be put on hold. In this regard, the contractor must be aware of weather forecasts. . Any steep or large embankments expected to be exposed during the ‘rainy’ months should either be armoured with fascine like structures/silt fences or grassed immediately with strip sods established at regular

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intervals (50-100 cm) down the bank with hydro-seeding between the strip sods. . Where the bare surface of platforms slope towards the edge of an embankment, silt fences and sandbags must be established along the crest of the embankment. If preferential flow routes on the sloped site occur, these flow routes must be intercepted with a series of sandbags. . After every rainfall event, the contractor must check the site for erosion damage and rehabilitate this damage immediately. Erosion rills and gullies must be filled-in with appropriate material and silt fences or fascine work must be established along the gulley for additional protection until grass has re-colonised the rehabilitated area.

Vegetation clearance. . Vegetation clearance should occur only in the demarcated and approved areas. . If necessary, the Applicant will demarcate sensitive areas as ‘No-Go Areas’. . Reasonable steps to be undertaken to identify and relocate protected species within the project area to adjacent areas, surrounding properties or as per the ECO specifications. . Use of burning to clear vegetation is prohibited. No cleared vegetation may be burnt under any circumstances. . Where feasible, vegetation cleared from the project area should be utilised in the rehabilitation process. . Where feasible, indigenous vegetation rescued from the project area should be utilised in the erection of vegetative screens to minimise dust impacts. . Indigenous vegetation outside the project area must not be removed, damaged or disturbed.

Pollution of soils. . The storage for any substance, which causes or is likely to cause pollution must not be located within a horizontal distance of 100 m of a watercourse, drainage line or identified wetland. . Waste or foreign material must not be dumped anywhere on site or off site without authorisation. . The discharge of water containing polluting matter or visible suspended materials, fines and sediments directly into drainage lines or wetlands must be prevented. . Unpolluted water/runoff must be deflected away from any dirty area. . Special care during rainy periods must be taken to prevent the contents of sumps and drip trays from overflowing. . The Contractor must ensure that accidental oil or fuel spills and leakages (other than those classed as emergency) are immediately contained and cleaned up. . Oil or fuel spills must not be hosed into a storm water drain or sewer, or into the surrounding natural environment. . Small oil or fuel spills must be cleaned with an approved absorbent material, such as 'Drizit' or ‘Spill-sorb’. . Oil or fuel spills must be contained in water using an approved oil absorbent fibre. . Soil contaminated by oil or fuel must be treated using one of the following approved methods, as per instruction of the ECO:

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o The soil to the depth of the contamination must be removed and disposed at a registered hazardous waste disposal site. o The soil to the depth of the contamination must be removed and regenerated using approved bio-remediation methods. . All on-site operations that involve the use of cement and concrete must be carefully controlled.

Compaction of soils through . Restrict vehicular traffic onsite to designated areas only. increased vehicular traffic. . Prior to rehabilitation and re-vegetation, all areas disturbed during construction must be: o Appropriately shaped to blend in with the surrounding landscape. o Top soil must be replaced to the original depth. o Rip and/or scarify soils to break up and facilitate mixing of the upper most layers. . Vehicles used during construction must have the minimum impact on the environment and other road users. . Vehicles, machinery and equipment must be checked regularly to ensure that none have leaks or cause spills of oil, diesel, grease or hydraulic fluid. Problematic vehicles, machinery or equipment must be sent for repair and removed from site immediately. . Drip trays must be provided for any machinery that will be in position for longer than one day. Drip trays are to be watertight, and must be emptied regularly and before rain events. The contents of drip trays are to be treated as hazardous waste. . All the necessary handling and safety equipment for vehicles, machinery and equipment must be provided by the Contractor and used or worn by staff.

Increased potential for soil . All areas susceptible to erosion must be protected to ensure that there is erosion. no undue soil erosion resultant from activities within and adjacent to the mining area. . Vehicular or pedestrian access must not be permitted into areas beyond the demarcated boundary of the mining. . Shoring must occur where excavation is in loose sand and/or swamp areas. . Erosion problems must be repaired on a progressive basis throughout the life cycle of the project. . Slopes steeper than 1(V):3(H), or slopes where the soils are by nature dispersive or sandy, must be stabilised (in consultation with the ECO). One or more of the following methods may be required: o Topsoil covered with a geotextile, plus a specified grass seed mixture. o A 50:50 by volume rock: topsoil mix 200 mm thick, plus specified grass seed mixture. o Logging or stepping (logs placed in continuous lines following the contours). o Earth or rock-pack cut-off berm. o Benches (sand bags). o Packed branches. o Ripping and/or scarifying along the contours. o Storm water berms. . The ECO may identify additional slopes in need of stabilisation and will

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specify actions in terms of the most appropriate approved method and technology. . Any steep or large embankments expected to be exposed during the ‘rainy’ months should either be armoured with fascine like structures/silt fences or grassed immediately with strip sods established at regular intervals (50-100 cm) down the bank with hydro-seeding between the strip sods.

Establishment and spread of . All alien species found on site are listed in Annexure 2 of the Mitigation alien invasive plant species. Plan. . Specific alien and invasive species are to be controlled according to the specific recommendation listed in Annexure 3 of the Mitigation Plan. . All sites disturbed by mining activities shall be monitored for colonisation by invasive alien plant species. . The ECO shall provide advice as to effective methods of removal and control of alien plant species. . Existing alien plants are to be removed and their spread prevented. . The Applicant is responsible for the control of weeds and invader plants within the mining footprint for the duration of the rehabilitation phase. . Weeds and invader plants will be controlled in the manner prescribed for that category by the Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) (as amended) or in terms of Working for Water guidelines. . The use of herbicides is not permitted within the mining footprint. The removal of weeds and invader plants within these areas must be undertaken by hand. . Affected areas must be reinstated and rehabilitated as soon as practically possible.

Contamination of surface and . Vehicles, machinery and equipment must be checked regularly to ensure ground water resources. that none have leaks or cause spills of oil, diesel, grease or hydraulic fluid. Problematic vehicles, machinery or equipment must be sent for repair and removed from site immediately. . Drip trays must be provided for any machinery that will be in position for longer than one day. Drip trays are to be watertight, and must be emptied regularly and before rain events. The contents of drip trays are to be treated as hazardous waste. . All the necessary handling and safety equipment for vehicles, machinery and equipment must be provided by the Contractor and used or worn by staff. . In the event the contractor has a diesel tank on site, the diesel tank must be on a stand, within a bunded area, with a metal drip tray under the dispensing hose. The dispensing hose must have a control pump with a valve, tap, hose and funnel. . An impervious layer (paving or PVC sheeting with a layer of sand) must be provided adjacent to the diesel tank upon which vehicles must park during refuelling. This will help accommodate fuel spills during refuelling. . All spills (within the bund and dispensing area) must be directed to a collection sump. . The storage for any substance, which causes or is likely to cause pollution must not be located within a horizontal distance of 100 m of a

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watercourse, drainage line or identified wetland. . Waste or foreign material must not be dumped anywhere on site or off site without authorisation. . The discharge of water containing polluting matter or visible suspended materials, fines and sediments directly into drainage lines or wetlands must be prevented. . Unpolluted water/runoff must be deflected away from any dirty area. . Special care during rainy periods must be taken to prevent the contents of sumps and drip trays from overflowing. . The Contractor must ensure that accidental oil or fuel spills and leakages (other than those classed as emergency) are immediately contained and cleaned up. . Oil or fuel spills must not be hosed into a storm water drain or sewer, or into the surrounding natural environment. . Small oil or fuel spills must be cleaned with an approved absorbent material, such as 'Drizit' or ‘Spill-sorb’. . Oil or fuel spills must be contained in water using an approved oil absorbent fibre. . Soil contaminated by oil or fuel must be treated using one of the following approved methods, as per instruction of the ECO: o The soil to the depth of the contamination must be removed and disposed at a registered hazardous waste disposal site. o The soil to the depth of the contamination must be removed and regenerated using approved bio-remediation methods. . All on-site operations that involve the use of cement and concrete must be carefully controlled.

Potential health and safety . Demarcate any open excavations. risks. . Ensure no unauthorised entry onto the farm on mining area is allowed. . Ensure that all workers are aware of the general safety standards as per the Occupational Health and Safety Act (Act no. 85 of 1993) and regulations. . Control through vehicles and equipment control measures in the Mitigation Plan which includes: o Prior to any contractors or customers coming to collect material they should be informed of the need to be aware of other road users, in particular farm workers. o It is recommended that the applicant determine a speed limit that all contractors or customers using the access roads should abide by. Suitable signage detailing speed limits should be put up. o All contractors coming onsite should abide by their companies journey management systems for driving on gravel roads. o Signage should be constructed on the access route to the borrow pit warning road users of potential presence of heavy duty vehicles and pedestrians. o In the event the contractor has a diesel tank on site, the diesel tank must be on a stand, within a bunded area, with a metal drip tray under the dispensing hose. The dispensing hose must have a control pump with a valve, tap, hose and funnel. o An impervious layer (paving or PVC sheeting with a layer of sand) must be provided adjacent to the diesel tank upon which vehicles

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must park during refuelling. This will help accommodate fuel spills during refuelling. o All spills (within the bund and dispensing area) must be directed to a collection sump.

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Table 5 Impact Assessment summary table with mitigation.

lity ability Impact Description Nature Duration Intensity eversibility Frequency Probabi Confidence Significance R Spatial Extent Irreplace

1. Construction, Operation and Closure Phase

Direct impacts 1.1 Dust and air pollution. High Negative Site specific Long term Medium Continuous Low High Medium High probability 1.2 Loss of remaining indigenous plant species. Negative Site specific Long term Low Once off Definite Low High Medium High 1.3 Contamination and pollution of Medium Highly Negative Site specific Medium Intermittent Low High Medium High soils. term Probable 1.4 Compaction of soils. Medium Negative Site specific Medium Continuous Definite Low High Medium High term 1.5 Increased soil erosion. Medium Highly Negative Local Medium Intermittent Low High Medium High term Probable

1.6 Establishment and spread of alien Medium Highly Negative Local Medium Continuous Low High Medium High invasive plant species term Probable

1.7 Contamination of surface and Medium Negative Local Medium Intermittent Probable Low High Medium Medium ground water resources. term 1.8 Potential health and safety risks. Negative Local Long term Medium Once off Probable Low Low Medium High

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

The following methodology has been applied to predict and assess the potential impacts associated with the proposed development:

Table 6 Criteria applied to predict and assess the significance of the potential impacts

Nature –the evaluation of the nature of Positive. the impact. Negative.

Spatial extent –the size of the area that Site specific will be affected by the impact Local (limited to the immediate areas around the site; <2 km from site).

Regional (would include a major portion of an area; within 30 km of site).

National or International.

Duration – the timeframe during which Short-term (0-3 years or confined to the period of construction). the impact will be experienced: Medium-term (3-10 years).

Long-term (the impact will only cease after the operational life of the activity).

Permanent (beyond the anticipated lifetime of the project).

Intensity – an order of magnitude of the Negligible (inconsequential or no impact). intensity (magnitude / size / frequency) of the impact. Low (small alteration of systems, patterns or processes).

Medium (noticeable alteration of systems, patterns or processes).

High (severe alteration of systems, patterns or processes).

Frequency – a description of any Once off (occurring any time during construction). repetitive, continuous or time-linked characteristics of the impact: Intermittent (occurring from time to time, without specific periodicity).

Periodic (occurring at more or less regular intervals).

Continuous (without interruption).

Probability – the likelihood of the impact Improbable (very low likelihood that the impact will occur). occurring: Probable (distinct possibility that the impact will occur).

Highly probable (most likely that the impact will occur)

Definite (the impact will occur).

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Irreplaceability – of resource loss High Irreplaceability of resources (the project will destroy unique caused by impacts: resources that cannot be replaced).

Moderate Irreplaceability of resources (the project will destroy resources, which can be replaced with effort).

Low Irreplaceability of resources (the project will destroy resources, which are easily replaceable).

Reversibility – the degree to which the Impacts are non-reversible (impact is permanent). impact can be reversed / the ability of the impacted environment to return/be Low reversibility. returned to its pre-impacted state (in the Moderate reversibility of impacts. same or different location):

High reversibility of impacts (impact is highly reversible at end of project life).

Significance – the significance of the Low (significant influence on the environment and, thus, will not be impact on components of the affected required to be significantly accommodated in the project design). environment (and, where relevant, with respect to potential legal infringement) is Medium (adverse effect or influence on the environment, which will described: require modification of the project design, the implementation of mitigation measures or both).

High (serious effect on the environment to the extent that, regardless of mitigation measures, it could block the project from proceeding).

Confidence – the degree of confidence Low. in predictions based on available information and specialist knowledge: Medium.

High.

2.16. The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected. (Provide a discussion in terms of advantages and disadvantages of the initial site layout compared to alternative layout options to accommodate concerns raised by affected parties)

Potential negative impacts The potential negative impacts on the biophysical environment include the potential loss of remaining natural vegetation during site clearance, increased dust and noise and the potential for soil compaction from increased vehicular movement and the potential for pollution of soils and water resources from hydrocarbon spills and littering during construction/operations and closure/decommissioning of the mine. Additionally during all phases where physical establishment of the site through to the closure of the site, the potential health and safety related impacts to staff and visitors to the mine remains. Additionally, vegetation clearance and the trucks loading the mined materials create the risk of the spreading of alien and invasive species into the local vegetation.

However, provided the relevant mitigation and control measures are implemented, negative impacts on the biophysical will be minimal, restricted to the project area and short term.

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Potential positive impacts Positive impacts stemming from the proposed development include the local availability of the mined material. Additionally, staff currently residing in the residential units that are going to be demolished, will be relocated to the south-western potion of the farm where their socio-economic conditions will improve.

Negative impacts will not be significant or detrimental if the relevant mitigation measures are implemented and strict monitoring and compliance with the EMPr and the conditions of the EA (once issues) are adhered to.

2.17. The possible mitigation measures that could be applied and the level of risk. (With regard to the issues and concerns raised by affected parties provide a list of the issues raised and an assessment/ discussion of the mitigations or site layout alternatives available to accommodate or address their concerns, together with an assessment of the impacts or risks associated with the mitigation or alternatives considered).

The proposed site for the Borrow Pit is located on private property surrounded by privately owned farms with the majority being used for the production of sugarcane. The small scale of the planned operation and the remote location has resulted in very little feedback from the community despite providing Background Information Documents, Site Notices and Comment Sheets. No concerns were raised from the general public and the identified I&APs to date. Additionally, two organs of sate namely, DAFF and EKZNW have acknowledged receipt of, and responded to the information provided in the Background Information Document. No initial objections or special recommendation were received from either department. However, DAFF has reserved their final comments after they have reviewed the Draft Basic Assessment Report. See table 2.12 in this report for full comment

As such, the assessment and mitigation measures were based on the EAP’s understanding of the physical and ecological status of the receiving environment, information obtained from various site visits, discussions with experienced mining personnel, results of the Public Participation Process and a broad scale literature review of the mining industry and similar projects (both undertaken by the EAP and similar consultancies). Additionally, the recommendations and mitigation measures from the specialist’s studies were also used to during the assessment process and to provide the appropriate mitigation measures. All of the identified risks and impacts can be mitigated to an acceptable level that does not negatively impact the receiving environment in any way. Table 7 below is a summary of the identified risks and impacts, and with the associated recommended mitigation measure.

Table 7 Identified impacts and risks and associated mitigation measures

Should dust become an issue or dust related complaints be received, then the Applicant must install a temporary cover (shade cloth) over the exposed

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mining stockpiles and sub-soil stockpiles and vegetate top-soil stockpiles with indigenous grass species.

Should dust become an issue or dust related complaints be received, then the Applicant must install a temporary wind break (shade cloth) around the active mining area and progressive rehabilitation areas as well as plant a vegetative screen using indigenous shrubs and trees to act as a long term wind break. Storm water impacts . Appropriate drainage measures must be taken to ensure that excessive run-off, and as a result, soil erosion, does not occur from the mining area. . Where directed by the ECO, embankments must be grassed to minimise erosion. . Clearing activities must only be undertaken during agreed working times and permitted weather conditions. If heavy rains are expected clearing activities should be put on hold. In this regard, the contractor must be aware of weather forecasts. . Any steep or large embankments expected to be exposed during the ‘rainy’ months should either be armoured with fascine like structures/silt fences or grassed immediately with strip sods established at regular intervals (50-100 cm) down the bank with hydro-seeding between the strip sods. . Where the bare surface of platforms slope towards the edge of an embankment, silt fences and sandbags must be established along the crest of the embankment. If preferential flow routes on the sloped site occur, these flow routes must be intercepted with a series of sandbags. . After every rainfall event, the contractor must check the site for erosion damage and rehabilitate this damage immediately. Erosion rills and gullies must be filled-in with appropriate material and silt fences or fascine work must be established along the gulley for additional protection until grass has re-colonised the rehabilitated area. Vegetation clearance. . Vegetation clearance should occur only in the demarcated and approved areas. . If necessary, the Applicant will demarcate sensitive areas as ‘No-Go Areas’. . Reasonable steps to be undertaken to identify and relocate protected species within the project area to adjacent areas, surrounding properties or as per the ECO specifications. . Use of burning to clear vegetation is prohibited. No cleared vegetation may be burnt under any circumstances. . Where feasible, vegetation cleared from the project area should be utilised in the rehabilitation process. . Where feasible, indigenous vegetation rescued from the project area should be utilised in the erection of vegetative screens to minimise dust impacts. . Indigenous vegetation outside the project area must not be removed, damaged or disturbed. Pollution of soils. . The storage for any substance, which causes or is likely to cause pollution must not be located within a horizontal distance of 100 m of a watercourse, drainage line or identified wetland. . Waste or foreign material must not be dumped anywhere on site or off site without authorisation.

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. The discharge of water containing polluting matter or visible suspended materials, fines and sediments directly into drainage lines or wetlands must be prevented. . Unpolluted water/runoff must be deflected away from any dirty area. . Special care during rainy periods must be taken to prevent the contents of sumps and drip trays from overflowing. . The Contractor must ensure that accidental oil or fuel spills and leakages (other than those classed as emergency) are immediately contained and cleaned up. . Oil or fuel spills must not be hosed into a storm water drain or sewer, or into the surrounding natural environment. . Small oil or fuel spills must be cleaned with an approved absorbent material, such as 'Drizit' or ‘Spill-sorb’. . Oil or fuel spills must be contained in water using an approved oil absorbent fibre. . Soil contaminated by oil or fuel must be treated using one of the following approved methods, as per instruction of the ECO: o The soil to the depth of the contamination must be removed and disposed at a registered hazardous waste disposal site. o The soil to the depth of the contamination must be removed and regenerated using approved bio-remediation methods. . All on-site operations that involve the use of cement and concrete must be carefully controlled. Compaction of soils through . Restrict vehicular traffic onsite to designated areas only. increased vehicular traffic. . Prior to rehabilitation and re-vegetation, all areas disturbed during construction must be: o Appropriately shaped to blend in with the surrounding landscape. o Top soil must be replaced to the original depth. o Rip and/or scarify soils to break up and facilitate mixing of the upper most layers. . Vehicles used during construction must have the minimum impact on the environment and other road users. . Vehicles, machinery and equipment must be checked regularly to ensure that none have leaks or cause spills of oil, diesel, grease or hydraulic fluid. Problematic vehicles, machinery or equipment must be sent for repair and removed from site immediately. . Drip trays must be provided for any machinery that will be in position for longer than one day. Drip trays are to be watertight, and must be emptied regularly and before rain events. The contents of drip trays are to be treated as hazardous waste. . All the necessary handling and safety equipment for vehicles, machinery and equipment must be provided by the Contractor and used or worn by staff. Increased potential for soil . All areas susceptible to erosion must be protected to ensure that there is erosion. no undue soil erosion resultant from activities within and adjacent to the mining area. . Vehicular or pedestrian access must not be permitted into areas beyond the demarcated boundary of the mining. . Shoring must occur where excavation is in loose sand and/or swamp areas. . Erosion problems must be repaired on a progressive basis throughout the

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life cycle of the project. . Slopes steeper than 1(V):3(H), or slopes where the soils are by nature dispersive or sandy, must be stabilised (in consultation with the ECO). One or more of the following methods may be required: o Topsoil covered with a geotextile, plus a specified grass seed mixture. o A 50:50 by volume rock: topsoil mix 200 mm thick, plus specified grass seed mixture. o Logging or stepping (logs placed in continuous lines following the contours). o Earth or rock-pack cut-off berm. o Benches (sand bags). o Packed branches. o Ripping and/or scarifying along the contours. o Storm water berms. . The ECO may identify additional slopes in need of stabilisation and will specify actions in terms of the most appropriate approved method and technology. . Any steep or large embankments expected to be exposed during the ‘rainy’ months should either be armoured with fascine like structures/silt fences or grassed immediately with strip sods established at regular intervals (50-100 cm) down the bank with hydro-seeding between the strip sods. Establishment and spread of . All alien species found on site are listed in Annexure 2 of the Mitigation alien invasive plant species. Plan. . Specific alien and invasive species are to be controlled according to the specific recommendation listed in Annexure 3 of the Mitigation Plan. . All sites disturbed by mining activities shall be monitored for colonisation by invasive alien plant species. . The ECO shall provide advice as to effective methods of removal and control of alien plant species. . Existing alien plants are to be removed and their spread prevented. . The Applicant is responsible for the control of weeds and invader plants within the mining footprint for the duration of the rehabilitation phase. . Weeds and invader plants will be controlled in the manner prescribed for that category by the Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) (as amended) or in terms of Working for Water guidelines. . The use of herbicides is not permitted within the mining footprint. The removal of weeds and invader plants within these areas must be undertaken by hand. . Affected areas must be reinstated and rehabilitated as soon as practically possible. Contamination of surface and . Vehicles, machinery and equipment must be checked regularly to ensure ground water resources. that none have leaks or cause spills of oil, diesel, grease or hydraulic fluid. Problematic vehicles, machinery or equipment must be sent for repair and removed from site immediately. . Drip trays must be provided for any machinery that will be in position for longer than one day. Drip trays are to be watertight, and must be emptied regularly and before rain events. The contents of drip trays are to be treated as hazardous waste. . All the necessary handling and safety equipment for vehicles, machinery

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and equipment must be provided by the Contractor and used or worn by staff. . In the event the contractor has a diesel tank on site, the diesel tank must be on a stand, within a bunded area, with a metal drip tray under the dispensing hose. The dispensing hose must have a control pump with a valve, tap, hose and funnel. . An impervious layer (paving or PVC sheeting with a layer of sand) must be provided adjacent to the diesel tank upon which vehicles must park during refuelling. This will help accommodate fuel spills during refuelling. . All spills (within the bund and dispensing area) must be directed to a collection sump. . The storage for any substance, which causes or is likely to cause pollution must not be located within a horizontal distance of 100 m of a watercourse, drainage line or identified wetland. . Waste or foreign material must not be dumped anywhere on site or off site without authorisation. . The discharge of water containing polluting matter or visible suspended materials, fines and sediments directly into drainage lines or wetlands must be prevented. . Unpolluted water/runoff must be deflected away from any dirty area. . Special care during rainy periods must be taken to prevent the contents of sumps and drip trays from overflowing. . The Contractor must ensure that accidental oil or fuel spills and leakages (other than those classed as emergency) are immediately contained and cleaned up. . Oil or fuel spills must not be hosed into a storm water drain or sewer, or into the surrounding natural environment. . Small oil or fuel spills must be cleaned with an approved absorbent material, such as 'Drizit' or ‘Spill-sorb’. . Oil or fuel spills must be contained in water using an approved oil absorbent fibre. . Soil contaminated by oil or fuel must be treated using one of the following approved methods, as per instruction of the ECO: o The soil to the depth of the contamination must be removed and disposed at a registered hazardous waste disposal site. o The soil to the depth of the contamination must be removed and regenerated using approved bio-remediation methods. . All on-site operations that involve the use of cement and concrete must be carefully controlled. Potential health and safety . Demarcate any open excavations. risks. . Ensure no unauthorised entry onto the farm on mining area is allowed. . Ensure that all workers are aware of the general safety standards as per the Occupational Health and Safety Act (Act no. 85 of 1993) and regulations. . Control through vehicles and equipment control measures in the Mitigation Plan which includes: o Prior to any contractors or customers coming to collect material they should be informed of the need to be aware of other road users, in particular farm workers. o It is recommended that the applicant determine a speed limit that all contractors or customers using the access roads should abide by.

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Suitable signage detailing speed limits should be put up. o All contractors coming onsite should abide by their companies journey management systems for driving on gravel roads. o Signage should be constructed on the access route to the borrow pit warning road users of potential presence of heavy duty vehicles and pedestrians. o In the event the contractor has a diesel tank on site, the diesel tank must be on a stand, within a bunded area, with a metal drip tray under the dispensing hose. The dispensing hose must have a control pump with a valve, tap, hose and funnel. o An impervious layer (paving or PVC sheeting with a layer of sand) must be provided adjacent to the diesel tank upon which vehicles must park during refuelling. This will help accommodate fuel spills during refuelling. o All spills (within the bund and dispensing area) must be directed to a collection sump.

2.18. Motivation where no alternative sites were considered.

The proposed Borrow Pit site was selected based on the following parameters:

• Availability of suitable material • Proximity to sensitive environments • Current land use on PogelaFarm (agricultural fields, roads, pockets of natural vegetation) • Accessability • Existing levels of disturbance

The site selected for the proposed Borrow Pit took all of the abovementioned parameters into consideration and is the most suitable site for a Borrow Pit on PogelaFarm. Other sites that could be available on Pogela Farm, in close proximity to the proposed Borrow Pit site,were discarded as vialble alternatives due to the following reasons:

• The other site alternatives considered for a Borrow Pit would result in the loss of commercial agricultural land (Sugarcane). • The other site alternatives considered for a Borrow Pit would result in the loss of natural vegetation in a relitavely undisturbed area (area to the south of the proposed Borrow Pit site). • The other site alternatives considered for a Borrow Pit would be located closer to the drainage lines present to the west of the prefferred Borrow Pit site.

Based on the parameters considered for the selection of the most suitable Borrow Pit site the following attributes make the proposed site preferable as opposed to the other site alternatives considered:

• Site is highly disturbed with little natural vegetation remaining on site. • The accomodation units on site are being decomissioned and the staff moved to another staff accomodation facility which has improved amenities (electricity, pottable water) and is fenced for increase security.

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• The preffered site is currently used by the farmer as a source of material to maintain farm roads.

2.19. Statement motivating the alternative development location within the overall site. (Provide a statement motivating the final site layout that is proposed)

The final layout proposed for the proposed Borrow Pit was selected based on the following parameters:

• Availability of suitable material • Proximity to sensitive environments • Current land use • Accessability • Existing levels of disturbance • Vegetation on site • Topography

The layout of the proposed Borrow Pit was selected as it will not result in the loss of natural vegetation (footprint has been limited to areas currently disturbed and relatively free of any natural vegetation) or the loss of agricultural lands. In addition to the above, the proposed site has already been terraced during the construction of the exisiting staff accomodation units.it has been proposed thatthese terraces will be used as the benches that will be mined during the operational phase ofthe Borrow Pit.

2.20. Full description of the process undertaken to identify, assess and rank the impacts and risks the activity will impose on the preferred site (In respect of the final site layout plan) through the life of the activity. (Including (i) a description of all environmental issues and risks that were identified during the environmental impact assessment process and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures.)

The process undertaken to identify, assess and rank the impacts and risks of the proposed development on the preferred site included:

 Review of government guidelines.  Discussion with relevant industry personnel.  Analysis of proposed mining methodology.  Desktop analysis of similar projects.  Review of Basic Assessment findings.  Review of Public Participation Process findings.  Site inspection.  Specialist input.

Subsequently, nine (9) potential risks and impacts were identified:

Direct Impacts:  Dust and air pollution.  Storm water impacts.  Loss of vegetation and groundcover due to vegetation clearance.  Loss of faunal habitat and biodiversity value of the site.  Contamination and pollution of soils.

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 Compaction of soils through increased vehicular traffic.  Increased potential for soil erosion.  Establishment and spread of alien invasive plant species.  Contamination of surface and ground water resources.  Potential health and safety risks.

All the possible risks including those that appear to be insignificant were identified and ranked firstly according to ACER’s criteria (outlined in Table 5) to predict and assess the significance of each potential impact. Table 6 indicates the risk, the risk rating according to ACER’s criteria and the proposed mitigation measures.

Secondly, the identified risks were ranked according to regulation 60 of the Mineral and Petroleum Resources Development Regulations (MPRDA) (R.527 in Government Gazette 26275, 23 April 2004).According to regulation 60 of the MPRDA, all of the identified risks need to be ranked as (aa) potential significant risk; (bb) uncertain risk; or (cc) insignificant risk. Table 7 indicates the risk and the associated ranking before and after mitigation.

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Table 6 Identified risks and impacts associated with the proposed development ranked according to ACER’s rating with proposed mitigation measures.

RISK: RATING MITIGATIONS: RATING ACCORDING TO ACCORDING TO ACER (AFTER MITIGATION): ACER (BEFORE MITIGATION): Dust and air pollution High Dust-suppression techniques (e.g. the spray of water) must be Low employed on all exposed surfaces during periods of high wind. Potential methods include:

Storm water impacts. High . Appropriate drainage measures must be taken to ensure that Medium excessive run-off, and as a result, soil erosion, does not occur from the mining area. . Where directed by the ECO, embankments must be grassed to minimise erosion.

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. Clearing activities must only be undertaken during agreed working times and permitted weather conditions. If heavy rains are expected clearing activities should be put on hold. In this regard, the contractor must be aware of weather forecasts. . Any steep or large embankments expected to be exposed during the ‘rainy’ months should either be armoured with fascine like structures/silt fences or grassed immediately with strip sods established at regular intervals (50-100 cm) down the bank with hydro-seeding between the strip sods. . Where the bare surface of platforms slope towards the edge of an embankment, silt fences and sandbags must be established along the crest of the embankment. If preferential flow routes on the sloped site occur, these flow routes must be intercepted with a series of sandbags. . After every rainfall event, the contractor must check the site for erosion damage and rehabilitate this damage immediately. Erosion rills and gullies must be filled-in with appropriate material and silt fences or fascine work must be established along the gulley for additional protection until grass has re-colonised the rehabilitated area.

Vegetation clearance. High . Vegetation clearance should occur only in the demarcated and Medium approved areas. . If necessary, the Applicant will demarcate sensitive areas as ‘No-Go Areas’. . Reasonable steps to be undertaken to identify and relocate protected species within the project area to adjacent areas, surrounding properties or as per the ECO specifications. . Use of burning to clear vegetation is prohibited. No cleared vegetation may be burnt under any circumstances. . Where feasible, vegetation cleared from the project area should be utilised in the rehabilitation process.

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. Where feasible, indigenous vegetation rescued from the project area should be utilised in the erection of vegetative screens to minimise dust impacts. . Indigenous vegetation outside the project area must not be removed, damaged or disturbed.

Contamination and High . The storage for any substance, which causes or is likely to cause Medium pollution of soils. pollution must not be located within a horizontal distance of 100 m of a watercourse, drainage line or identified wetland. . Waste or foreign material must not be dumped anywhere on site or off site without authorisation. . The discharge of water containing polluting matter or visible suspended materials, fines and sediments directly into drainage lines or wetlands must be prevented. . Unpolluted water/runoff must be deflected away from any dirty area. . Special care during rainy periods must be taken to prevent the contents of sumps and drip trays from overflowing. . The Contractor must ensure that accidental oil or fuel spills and leakages (other than those classed as emergency) are immediately contained and cleaned up. . Oil or fuel spills must not be hosed into a storm water drain or sewer, or into the surrounding natural environment. . Small oil or fuel spills must be cleaned with an approved absorbent material, such as 'Drizit' or ‘Spill-sorb’. . Oil or fuel spills must be contained in water using an approved oil absorbent fibre. . Soil contaminated by oil or fuel must be treated using one of the following approved methods, as per instruction of the ECO: o The soil to the depth of the contamination must be removed and disposed at a registered hazardous waste disposal site. o The soil to the depth of the contamination must be removed and regenerated using approved bio-remediation methods.

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. All on-site operations that involve the use of cement and concrete must be carefully controlled.

Compaction of soils High . Restrict vehicular traffic onsite to designated areas only. Low through increased . Prior to rehabilitation and re-vegetation, all areas disturbed during vehicular traffic. construction must be: o Appropriately shaped to blend in with the surrounding landscape. o Top soil must be replaced to the original depth. o Rip and/or scarify soils to break up and facilitate mixing of the upper most layers. . Vehicles used during construction must have the minimum impact on the environment and other road users. . Vehicles, machinery and equipment must be checked regularly to ensure that none have leaks or cause spills of oil, diesel, grease or hydraulic fluid. Problematic vehicles, machinery or equipment must be sent for repair and removed from site immediately. . Drip trays must be provided for any machinery that will be in position for longer than one day. Drip trays are to be watertight, and must be emptied regularly and before rain events. The contents of drip trays are to be treated as hazardous waste. . All the necessary handling and safety equipment for vehicles, machinery and equipment must be provided by the Contractor and used or worn by staff.

Increased potential for High . All areas susceptible to erosion must be protected to ensure that Medium soil erosion. there is no undue soil erosion resultant from activities within and adjacent to the mining area. . Vehicular or pedestrian access must not be permitted into areas beyond the demarcated boundary of the mining. . Shoring must occur where excavation is in loose sand and/or swamp areas. . Erosion problems must be repaired on a progressive basis

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throughout the life cycle of the project. . Slopes steeper than 1(V):3(H), or slopes where the soils are by nature dispersive or sandy, must be stabilised (in consultation with the ECO). One or more of the following methods may be required: o Topsoil covered with a geotextile, plus a specified grass seed mixture. o A 50:50 by volume rock: topsoil mix 200 mm thick, plus specified grass seed mixture. o Logging or stepping (logs placed in continuous lines following the contours). o Earth or rock-pack cut-off berm. o Benches (sand bags). o Packed branches. o Ripping and/or scarifying along the contours. o Storm water berms. . The ECO may identify additional slopes in need of stabilisation and will specify actions in terms of the most appropriate approved method and technology. . Any steep or large embankments expected to be exposed during the ‘rainy’ months should either be armoured with fascine like structures/silt fences or grassed immediately with strip sods established at regular intervals (50-100 cm) down the bank with hydro-seeding between the strip sods.

Establishment and High . All alien species found on site are listed in Annexure 2 of the Medium spread of alien invasive Mitigation Plan. plant species. . Specific alien and invasive species are to be controlled according to the specific recommendation listed in Annexure 3 of the Mitigation Plan. . All sites disturbed by mining activities shall be monitored for colonisation by invasive alien plant species. . The ECO shall provide advice as to effective methods of removal

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and control of alien plant species. . Existing alien plants are to be removed and their spread prevented. . The Applicant is responsible for the control of weeds and invader plants within the mining footprint for the duration of the rehabilitation phase. . Weeds and invader plants will be controlled in the manner prescribed for that category by the Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) (as amended) or in terms of Working for Water guidelines. . The use of herbicides is not permitted within the mining footprint. The removal of weeds and invader plants within these areas must be undertaken by hand. . Affected areas must be reinstated and rehabilitated as soon as practically possible. . Contamination of surface High . Vehicles, machinery and equipment must be checked regularly to Low and ground water ensure that none have leaks or cause spills of oil, diesel, grease or resources. hydraulic fluid. Problematic vehicles, machinery or equipment must be sent for repair and removed from site immediately. . Drip trays must be provided for any machinery that will be in position for longer than one day. Drip trays are to be watertight, and must be emptied regularly and before rain events. The contents of drip trays are to be treated as hazardous waste. . All the necessary handling and safety equipment for vehicles, machinery and equipment must be provided by the Contractor and used or worn by staff. . In the event the contractor has a diesel tank on site, the diesel tank must be on a stand, within a bunded area, with a metal drip tray under the dispensing hose. The dispensing hose must have a control pump with a valve, tap, hose and funnel. . An impervious layer (paving or PVC sheeting with a layer of sand) must be provided adjacent to the diesel tank upon which vehicles

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must park during refuelling. This will help accommodate fuel spills during refuelling. . All spills (within the bund and dispensing area) must be directed to a collection sump. . The storage for any substance, which causes or is likely to cause pollution must not be located within a horizontal distance of 100 m of a watercourse, drainage line or identified wetland. . Waste or foreign material must not be dumped anywhere on site or off site without authorisation. . The discharge of water containing polluting matter or visible suspended materials, fines and sediments directly into drainage lines or wetlands must be prevented. . Unpolluted water/runoff must be deflected away from any dirty area. . Special care during rainy periods must be taken to prevent the contents of sumps and drip trays from overflowing. . The Contractor must ensure that accidental oil or fuel spills and leakages (other than those classed as emergency) are immediately contained and cleaned up. . Oil or fuel spills must not be hosed into a storm water drain or sewer, or into the surrounding natural environment. . Small oil or fuel spills must be cleaned with an approved absorbent material, such as 'Drizit' or ‘Spill-sorb’. . Oil or fuel spills must be contained in water using an approved oil absorbent fibre. . Soil contaminated by oil or fuel must be treated using one of the following approved methods, as per instruction of the ECO: o The soil to the depth of the contamination must be removed and disposed at a registered hazardous waste disposal site. o The soil to the depth of the contamination must be removed and regenerated using approved bio-remediation methods. . All on-site operations that involve the use of cement and concrete must be carefully controlled.

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Potential health and High . Demarcate any open excavations. Medium safety risks. . Ensure no unauthorised entry onto the farm on mining area is allowed. . Ensure that all workers are aware of the general safety standards as per the Occupational Health and Safety Act (Act no. 85 of 1993) and regulations. . Control through vehicles and equipment control measures in the Mitigation Plan which includes: o Prior to any contractors or customers coming to collect material they should be informed of the need to be aware of other road users, in particular farm workers. o It is recommended that the applicant determine a speed limit that all contractors or customers using the access roads should abide by. Suitable signage detailing speed limits should be put up. o All contractors coming onsite should abide by their companies journey management systems for driving on gravel roads. o Signage should be constructed on the access route to the borrow pit warning road users of potential presence of heavy duty vehicles and pedestrians. o In the event the contractor has a diesel tank on site, the diesel tank must be on a stand, within a bunded area, with a metal drip tray under the dispensing hose. The dispensing hose must have a control pump with a valve, tap, hose and funnel. o An impervious layer (paving or PVC sheeting with a layer of sand) must be provided adjacent to the diesel tank upon which vehicles must park during refuelling. This will help accommodate fuel spills during refuelling. o All spills (within the bund and dispensing area) must be directed to a collection sump.

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Table 7 Identified risks and impacts associated with the proposed development ranked according to MPRDA rating with proposed before and after the implementation of mitigation measures.

RISK: RATING ACCORDING TO RATING ACCORDING TO MPRDA MPRDA REGULATIONS REGULATIONS (AFTER (BEFORE MITIGATION): MITIGATION): Dust and air pollution Potential significant risk Insignificant risk

Storm water impacts. Potential significant risk Insignificant risk

Vegetation clearance. Potential significant risk Insignificant risk

Contamination and pollution of Potential significant risk Insignificant risk soils.

Compaction of soils through Potential significant risk Insignificant risk increased vehicular traffic.

Increased potential for soil Potential significant risk Insignificant risk erosion.

Establishment and spread of alien Potential significant risk Insignificant risk invasive plant species.

Contamination of surface and Potential significant risk Insignificant risk ground water resources.

Potential health and safety risks. Potential significant risk Insignificant risk

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

(See next page)

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NAME OF ACTIVITY POTENTIAL IMPACT PHASE SIGNIFICANCE MITGATION TYPE SIGNIFICANCE (AFTER (BEFORE MITIGATION) MITIGATION) Dust and air pollution . Construction/ Operational Medium Control through the Mitigation Plan with specific reference to the following sections: Low Phase. . Closure Phase . Control through dust control and management methods. . Control through equipment control methods.

Storm water impacts . Construction/ Operational High Control and manage potential storm water impacts through the stormwater Medium Phase. management plan (Appendix 10). . Closure Phase Vegetation clearance . Construction/ Operational High Control through the Mitigation Plan with specific reference to the following sections: Medium (Listed activity) Phase. . Remedy through re-vegetation management methods. . Control through staff training methods. . Control through site management methods.

Control and remedy through the Rehabilitation Plan (Appendix 8).

Pollution of soils. . Construction/ Operational High Control through the Mitigation Plan with specific reference to the following sections: Medium Phase. . Closure Phase . Control through pollution preventative measures. . Control through equipment control measures. Activity: . Control through management and monitoring. Site establishment Listed activities under site establishment include Compaction of soils through . Construction/ Operational High Control through the Mitigation Plan with specific reference to the following sections: Low Vegetation clearance (see increased vehicular traffic. Phase. adjacent column) . Closure Phase . Control and manage through implementing the traffic and increased vehicular movement measures. . Control through implementing erosion management measures. . Control through equipment control and measures. . Control through management and monitoring.

Control and remedy though the Stormwater management Plan (Appendix 10).

Increased potential for soil . Construction/ Operational High . Control and remedy through the Stormwater management plan (Appendix 10). Medium erosion. Phase. . Control through the Mitigation Plan with specific reference to the erosion . Closure Phase management measures.

Establishment and spread of . Construction/ Operational High Control through the Mitigation Plan with specific reference to the following sections: Medium alien invasive plant species. Phase. . Closure Phase . Control through implementing and adhering to the alien invasive species control methods.

Control and remedy through the Rehabilitation Plan (Appendix 8).

Contamination of surface and . Construction/ Operational High Control through implementing and adhering to the Mitigation Plan with specific Medium

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ground water resources. Phase. reference to the following sections: . Closure Phase . Pollution control and management methods. . Control through equipment control measures. . Control through management and monitoring. . Control through staff training methods. . Control through site management methods.

Remedy though the Rehabilitation Plan (Appendix 8).

Potential health and safety . Construction/ Operational High Control through the Mitigation Plan with specific reference to the following sections: Medium risks. Phase. . Closure Phase . Control through the health and safety control measures and methods. . Control through staff training methods. . Control through site management methods.

Dust and air pollution . Construction/ Operational Medium Control through the Mitigation Plan with specific reference to the following sections: Low Phase. . Closure Phase . Control through dust control and management methods. . Control through equipment control methods.

Activity: Establishment and spread of . Construction/ Operational High Control through the Mitigation Plan with specific reference to the following sections: Medium Stockpiling of topsoil alien invasive plant species. Phase. . Closure Phase . Control through implementing and adhering to the alien invasive species control methods.

Control and remedy through the Rehabilitation Plan (Appendix 8).

Activity: Control and remedy through the Rehabilitation Plan (Appendix 8). Excavations/Mining operations Potential health and safety . Construction/ Operational High Control through the Mitigation Plan with specific reference to the following sections: Medium risks. Phase. . Closure Phase . Control through the health and safety control measures and methods. . Control through staff training methods. . Control through site management methods. . Control though vehicles and equipment control.

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Loading of mined Phase. material. . Closure Phase . Control through dust control and management methods. . Control through equipment control methods.

Control and remedy through the Rehabilitation Plan (Appendix 8).

Activity: Dust and air pollution . Construction/ Operational Medium Control through the Mitigation Plan with specific reference to the following sections: Low Landscaping Phase. . Closure Phase . Control through dust control and management methods. . Control through equipment control methods.

Not applicable. . Construction/ Operational Not applicable. Rehabilitation of the mining area will be controlled and remedied through the Not applicable. Activity: Phase. implementation and adherence to the Rehabilitation Plan (Appendix 8) and the Progressive A method of progressive . Closure Phase Mitigation Plan (Appendix 11). . rehabilitation. rehabilitation will be utilised Rehabilitation Phase. parallel to operational activities during all phases of the project.

Storm water impacts . Construction/ Operational High Control and manage potential storm water impacts through the stormwater Medium Activity: Phase. management plan (Appendix 10). Closure/ . Closure Phase Decommissioning of Pollution of soils. . Construction/ Operational High Control through the Mitigation Plan with specific reference to the following sections: Medium the mine. Phase. . Closure Phase . Control through pollution preventative measures. . Control through equipment control measures. . Control through management and monitoring.

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Control and remedy through the Rehabilitation Plan (Appendix 8).

Contamination of surface and . Construction/ Operational High Control through implementing and adhering to the Mitigation Plan with specific Medium ground water resources. Phase. reference to the following sections: . Closure Phase . Pollution control and management methods. . Control through equipment control measures. . Control through management and monitoring. . Control through staff training methods. . Control through site management methods.

Remedy though the Rehabilitation Plan (Appendix 8).

Activity: Post closure monitoring Phase. Not applicable. Bi-annual site visits and environmental audit reports to be compiled and submitted Not applicable. to the competent authority. Post closure No impacts anticipated. monitoring.

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

SPECIALIST REFERENCE TO APPLICABLE RECOMMENDATION/S SECTION OF REPORT WHERE LIST OF THAT HAVE BEEN SPECIALIST RECOMMENDATIONS OF SPECIALIST REPORTS INCLUDED IN THE EIA RECOMMENDATIONS HAVE STUDIES REPORT BEEN INCLUDED. UNDERTAKEN (Mark with an X where applicable) Vegetation Study • Any protected trees requiring removal may only commence X Mitigation Plan once a permit has been obtained from DAFF. Stormwater Management Plan • Clear demarcation of the extent of the borrow pit footprint, Rehabilitation Plan including access roads, parking and stockpile areas. Closure Plan • Retaining as much indigenous vegetation as possible, X particularly large indigenous trees on the perimeter of the

proposed borrow pit.

• Immediate implementation of an ongoing, active and X intensive alien invasive plant control programme for the proposed site and adjacent areas using the best available practice methods. • Implementation of appropriate stormwater management measures, to prevent clean surface runoff from entering the X pit, and dirty water and sediment from the leaving the pit • Progressive rehabilitation of the perimeter of the borrow pit during and after construction, which must include: . Appropriate shaping (no slopes steeper than 1(V):3(H)). New slopes should resemble natural topography of the X surrounding area. . Replacement of topsoil that was removed and stored during site clearance to the original depth.

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. Ripping and scarifying of all areas (along the contour) following the application of topsoil. X . Establishment of an indigenous ground cover, using locally sourced grass seed mix. . Ongoing removal and control of alien invasive plants. • Planting of species typical of the Zululand Coastal Thornveld vegetation type, viz.; Trichilia emetica, Ficus sycamorous, Acacia nigrescens, Sclerocarya birrea subsp. X caffra, Phoenix reclinata, Ekbergia capensis, Harpephylum caffrum, Aloe arborescens and Aloe marlothii. • Post rehabilitation monitoring must be conducted over a period of 24 months, to ensure that the re-vegetated areas have established, and alien invasive plants are being adequately controlled X Social Impact • Prior to any contractors or customers coming to collect X Mitigation Plan Assessment Study material they should be informed of the need to be aware Storm water Management Plan of other road users, in particular farm workers. Rehabilitation Plan • It is recommended that the applicant determine a speed X Closure Plan limit that all contractors or customers using the access

roads should abide by. Suitable signage detailing speed limits should be put up. • All contractors coming onsite should abide by their X companies journey management systems for driving on gravel roads. • Signage should be constructed on the access route to the X borrow pit warning road users of potential presence of

heavy duty vehicles and pedestrians. • During times of strong winds exposed stock piles should be watered to reduce dust. X • In the event of any employment opportunities being created X ensure that local staff are appointed. Attach copies of Specialist Reports as appendices

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2.23. Environmental Impact Statement

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

Alternative A (preferred site):

Site alternative A is the preferred site as it has minimal environmental concerns. Through progressive rehabilitation and implementation of mitigation measures, no significant negative impact on the biophysical, socio or economical aspects are anticipated in the activity phases for the proposed project.

The potential negative impacts on the biophysical environment include the potential loss of remaining natural vegetation and faunal habitation during site clearance, increased dust and noise and the potential for soil compaction from increased vehicular movement and the potential degradation and pollution of soils and water resources. Potential health and safety issues and the risk of the spread of alien and invasive species occur throughout all phases of the proposed development. However, provided the relevant mitigation measures are implemented, negative biophysical impacts will be minimal, restricted to the project area, short term and the environment will recover and will return to its natural state.

Positive impacts stemming from the proposed development include the availability local of materials for the construction purposes in the region. Additionally, staff currently residing in the residential units that are going to be demolished, will be relocated to the south-western potion of the farm where their socio-economic conditions will improve.

Negative impacts will not be significant if the relevant mitigation measures are implemented and strict monitoring and compliance in terms of the EMPr and the conditions of the EA (once issues) is enforced.

The No-Go Alternative:

Final Site Map (Provide a map at an appropriate scale which superimposes the proposed overall activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers .Attach as Appendix 2.)

All of the relevant maps associated with the proposed Borrow Pit can be found in Appendix 2 of this report. These maps include:

 Map A - Readman Borrow pit General Zoom  Map B - Readman Borrow pit General Locality  Map C - Readman Borrow pit General Cadastral  Map D - Readman Borrow pit General Contours  Map E – Readman Borrow Pit General Drainage Lines  Map F - Readman Borrow pit General Wetlands  Map G - Readman Borrow pit General Sensitivity  Map H1 - Readman Borrow pit General Vegmap2012  Map H2 - Readman Borrow pit Vegetation and Buffer Map

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 Map I - Readman Borrow pit General Geology  Map J - Readman Borrow pit General Soils  Map K - Readman Borrow pit Buffer Map  Map L - Borrow Pit Co-ordinates  Map M - Readman Borrow Pit Mining Plan

2.23.2. Summary of the positive and negative impacts and risks of the proposed activity and identified alternatives;

Potential negative impacts The potential negative impacts on the biophysical environment include the potential loss of remaining natural vegetation and faunal habitation during site clearance, increased dust and noise and the potential for soil compaction from increased vehicular movement and the potential degradation and pollution of soils and water resources. Potential health and safety issues and the risk of the spread of alien and invasive species occur throughout all phases of the proposed development. However, provided the relevant mitigation measures are implemented, negative biophysical impacts will be minimal, restricted to the project area, short term and the environment will recover and will return to its natural state.

Potential positive impacts Positive impacts stemming from the proposed development include the availability of local dolerite for construction purposes. Additionally, staff currently residing in the residential units that are going to be demolished, will be relocated to the south-western potion of the farm where their socio-economic conditions will improve. Surplus material will be sold to end users predominantly in the local construction industry.

2.23.3. Proposed impact management objective and the impact management outcomes for inclusion in the EMPr; (Based on the assessment and where applicable the recommendations from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation.)

Vegetation Assessment

Although highly transformed, and degraded by past and current land uses, the site still holds biodiversity value, with the large trees and grasses providing food and a refuge to fauna in the region, particularly birds. The anticipated negative impacts associated with the establishment of the J. Readman Borrow Pit can be mitigated to acceptable levels through strict compliance with the specifications set out in the EMPr which should include the following:

 Clear demarcation of the extent of the borrow pit footprint, including access roads, parking and stockpile areas.

 Retaining as much indigenous vegetation as possible, particularly large indigenous trees on the perimeter of the proposed borrow pit.

 Immediate implementation of an ongoing, active and intensive alien invasive plant control programme for the proposed site and adjacent areas using the best available practice methods.

 Implementation of appropriate stormwater management measures, to prevent clean surface runoff from entering the pit, and dirty water and sediment from the leaving the pit.

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 Progressive rehabilitation of the perimeter of the borrow pit during and after construction, which must include:

. Appropriate shaping (no slopes steeper than 1(V):3(H)). New slopes should resemble natural topography of the surrounding area. . Replacement of topsoil that was removed and stored during site clearance to the original depth. . Ripping and scarifying of all areas (along the contour) following the application of topsoil. . Establishment of an indigenous ground cover, using locally sourced grass seed mix. . Ongoing removal and control of alien invasive plants.

 Planting of species typical of the Zululand Coastal Thornveld vegetation type, viz.; Trichilia emetica, Ficus sycamorous, Acacia nigrescens, Sclerocarya birrea subsp. caffra, Phoenix reclinata, Ekbergia capensis, Harpephylum caffrum, Aloe arborescens and Aloe marlothii.

 Post rehabilitation monitoring must be conducted over a period of 24 months, to ensure that the re- vegetated areas have established, and alien invasive plants are being adequately controlled.

Heritage Assessment

An application for exemption from a phase 1 Heritage Assessment has been submitted to Amafa by Ethembeni Cultural Heritage on behalf of Mr J Readman for the proposed development. (See Appendix 5 for full Application).As such, the following observations and recommendations were provided by the specialists:

Observations No graves are located or reported in the immediate precinct of the planned expansion and any associated plant and services proposed. The compound buildings are utilitarian, in a state of disuse and of no intrinsic significance. They are due to be demolished. The Ntabanana and Heatonville farms were granted in compensation to returning service-men after WWI (1918) and WWII (1945). These farms have been under sugar cane production for at least the last 40 to 50 years.

More than half a century of commercial agriculture has masked over any primary context archaeological material that may have been present on Pogela Farm. Consequently, no significant archaeological remains are anticipated. The SAHRIS Palaeontology sensitivity map indicates the area to be of low sensitivity (blue).

Recommendations The basement rock to be quarried at the expanded borrow pit is dolerite which is not fossil bearing. Consequently no further palaeontology assessment or monitoring is recommended. Additionally, we (Ethembeni Cultural Heritage) request that Amafa grant an exemption from an HIA for the proposed expansion of the borrow pit, allowing the enterprise to proceed with no further heritage resource mitigation.

Social Impact Assessment

The following mitigation measures have been indentified to reduce the potential negative impacts and management measures to enhance possible positive impacts which may occur during the construction and operational phase of the project.

Reduced road safety  Prior to any contractors or customers coming to collect material they should be informed of the need to be aware of other road users, in particular farm workers.  It is recommended that the applicant determine a speed limit that all contractors or customers using the access roads should abide by. Suitable signage detailing speed limits should be put up. PROPOSED BORROW PIT ON POGELA FARM NEAR HEATONVILLE BASIC ASSESSMENT REPORT 79

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 All contractors coming onsite should abide by their companies journey management systems for driving on gravel roads.  Signage should be constructed on the access route to the borrow pit warning road users of potential presence of heavy duty vehicles and pedestrians.

Increased dust  During times of strong winds exposed stock piles should be watered to reduce dust.

Increased employment  In the event of any employment opportunities being created ensure that local staff are appointed.

Following the careful consideration of the project design as well as the receiving environment it has been concluded that there are no significant social impacts (either direct or indirect) that will result from the proposed development and as such, from a social perspective, there is nothing that should prevent the project going ahead.

2.23.4. Aspects for inclusion as conditions of Authorisation.

(Any aspects which must be made conditions of the Environmental Authorisation)

 The Applicant to keep copies of the following project documents on site at all times: . Environmental Authorisation (Once issued) . Environmental Management Programme . Mitigation Plan . Rehabilitation Plan . Closure Plan

 The Applicant to appoint an ECO to undertake bi-annual monitoring of the proposed Borrow Pit and associated activities.

 The ECO to undertake annual site inspections during the Post-Closure Phase.

 The ECO to produce and provide annual Environmental Compliance Report during the Post-Closure Phase.

 The ECO to assess project compliance in terms of the following documents: . Environmental Authorisation (Once issued) . Environmental Management Programme . Mitigation Plan . Rehabilitation Plan . Closure Plan . Vegetation Assessment Report . Social Impact Assessment Report

2.23.5. Description of any assumptions, uncertainties and gaps in knowledge. (Which relate to the assessment and mitigation measures proposed)

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Information Documents, Site Notices and Comment Sheets. No concerns were raised from the general public and the identified I&APs to date.

2.23.6. Reasoned opinion as to whether the proposed activity should or should not be authorised

1 Provincial, district and local construction industries are in constant need of materials for construction, upgrading and maintenance projects. As such, the material to be mined will be sold to the local and regional construction industries. 2 The project will be utilising a progressive rehabilitation process thereby limiting un-rehabilitated areas. This limitation will minimise environmental degradation should the mining operation cease prior to closure. 3 The Applicant has an existing Borrow Pit onsite which is fully operational. As such, mining experience, plant and necessary staff are already available. 4 The preferred site for the Borrow Pit is the ideal location. An alternative site selection will have the following drawbacks:  The other sites considered for a Borrow Pit would result in the loss of commercial agricultural land (Sugarcane).  The other sites considered for a Borrow Pit would result in the loss of natural vegetation in a relatively undisturbed area (area to the south of the proposed Borrow Pit site).  The other sites considered for a Borrow Pit would be located closer to the drainage lines present to the west of the preferred Borrow Pit site.

5 All known potential impacts associated with the proposed development can be mitigated to an acceptable level. 6 The project area can be rehabilitated to an environmentally stable condition.

(i) Conditions that must be included in the authorisation

 The Applicant to appoint an ECO to undertake bi-annual monitoring of the proposed Borrow Pit and associated activities.

 The ECO to undertake annual site inspections during the Post-Closure Phase.

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 The ECO to produce and provide annual Environmental Compliance Report during the Post-Closure Phase.

2.23.7. Period for which the Environmental Authorisation is required. It is proposed that the Environmental Authorisation be issued for an Eight (8) year period. This proposal is based on the following timeframes:  5 Year Mining Permit (including extensions) (Design Phase, Operational Phase & Rehabilitation Phase)  1 Year Mine Closure (Closure Phase)  2 Year Post Closure (Post-Closure Phase)

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2.23.8. Undertaking

Confirm that the undertaking required to meet the requirements of this section is provided at the end of the EMPr and is applicable to both the Basic assessment report and the Environmental Management Programme report.

The EAP herewith confirms:

 The correctness of the information provided in the reports  The inclusion of comments and inputs from stakeholders and I&APs;  The inclusion of inputs and recommendations from the specialist reports where relevant; and  That the information provided by the EAP to interested and affected parties and any responses by the  EAP to comments or inputs made by I&APs are correctly reflected herein.

Signature:

Company: ACER (Africa) Environmental Consultants EAP: Giles Churchill Date: 5 April 2017

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2.24. Financial Provision

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

Based on the closure components, risk class and sensitivity of the area the calculation of cost closure has been calculated as R 70,534.99 (Incl. VAT) as outlined in Table 8 Below.

Table 8 Quantum of financial provision.

2.24.1. Explain how the aforesaid amount was derived.

As per the DMR guidelines the closure components for the mine must be identified based on the type of mining to be undertaken as well as the site specific conditions within the mining area. The proposed Borrow Pit can be considered an open-cast activity which will involve the removal of material in benches from the proposed Borrow Pit footprint.

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Given the small scale of the proposed Borrow Pit and the fact that the site is located on private property very little infrastructure is required on site in the form of fencing, security huts and mine infrastructure. Based on the information provided by Mr Readman infrastructure on site will be limited to the following:

 No fencing is required as the Borrow Pit is located on private property and no members of the public are anticipated to enter the proposed site. Security on site will also ensure that no unauthorized access to the Borrow Pit takes place.  Post operation, the Borrow Pit site will be utilized as a sugar cane loading zone by the landowner and as such rehabilitation of slopes and exposed areas on site will be limited to the outer slopes. Given the topography of the land and materials on site the potential for erosion is limited.  No access roads are required to access the site as the landowner already has access roads which enter the proposed Borrow Pit site. These access roads will be retained post operation to transport sugarcane to and from the loading zone which will be created within the Borrow Pit footprint.  Very limited spoil is anticipated from the Borrow Pit during operation due to the limited depth of overburden and topsoil over the weathered Dorerite which is to be mined on site. Topsoil removed during mining operations will be used to rehabilitate the outer exposed slopes within the Borrow Pit footprint.

2.24.2. Confirm that this amount can be provided for from operating expenditure.

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

An amount of R 70,534.99 (Incl. VAT) is currently being secured as a Bank Guarantee against the project. This amount will be reviewed and updated on an annual basis as per the Applicants ‘Undertaking’ within the Financial Provision Assessment. For additional information, please see the following:

 Appendix 6: Financial and Technical Report  Appendix 7: Quantum of Financial Provision

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2.25. Specific Information required by the competent Authority

2.25.1. Compliance with the provisions of sections 24(4)(a) and (b) read with section 24 (3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998). The EIA report must include the:-

(1) Impact on the socio-economic conditions of any directly affected person. (Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any directly affected person including the landowner, lawful occupier, or, where applicable, potential beneficiaries of any land restitution claim, attach the investigation report as an Appendix 5 (specialist reports).

Social Impact Assessment

Reduced road safety  Prior to any contractors or customers coming to collect material they should be informed of the need to be aware of other road users, in particular farm workers.  It is recommended that the applicant determine a speed limit that all contractors or customers using the access roads should abide by. Suitable signage detailing speed limits should be put up.  All contractors coming onsite should abide by their companies journey management systems for driving on gravel roads.  Signage should be constructed on the access route to the borrow pit warning road users of potential presence of heavy duty vehicles and pedestrians.

Increased dust  During times of strong winds exposed stock piles should be watered to reduce dust.

Increased employment  In the event of any employment opportunities being created ensure that local staff are appointed.

(2) Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act. (Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) with the exception of the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act, attach the investigation report as Appendix 2.19.2 and confirm that the applicable mitigation is reflected in 2.5.3; 2.11.6.and 2.12.herein).

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Heritage Assessment

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

The Application for Environmental Authorisation, The Basic Assessment Report, The Environmental Management Programmes and approximately 11 appendices have been submitted to the Competent Authority in terms of the above requirements. Any additional information requested will be provided promptly.

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