Appendix E10: Heritage

Heritage Impact Assessment

Lephalale Coal and Power Project (LCPP)

Proposed Lephalale Coal and Power Project (LCPP) near Lephalale, Lephalale Local Municipality, Waterberg District, Limpopo Province

Issue Date: 26 June 2017 Revision No.: 1.0 Client: Kongiwe Environmental Services Project No: 229HIA

PGS Heritage (Ptyt) Ltd PO Box 32542 Totiusdal 0134, T +27 12 332 5305 F: +27 86 675 8077 Reg. No 2003/008940/07

Declaration of Independence I, Wouter Fourie, declare that – General declaration: • I act as the independent heritage practitioner in this application • I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant • I declare that there are no circumstances that may compromise my objectivity in performing such work; • I have expertise in conducting heritage impact assessments, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity; • I will comply with the Act, Regulations and all other applicable legislation; • I will take into account, to the extent possible, the matters listed in section 38 of the NHRA when preparing the application and any report relating to the application; • I have no, and will not engage in, conflicting interests in the undertaking of the activity; • I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; • I will ensure that information containing all relevant facts in respect of the application is distributed or made available to interested and affected parties and the public and that participation by interested and affected parties is facilitated in such a manner that all interested and affected parties will be provided with a reasonable opportunity to participate and to provide comments on documents that are produced to support the application; • I will provide the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not • All the particulars furnished by me in this form are true and correct; • I will perform all other obligations as expected from an heritage practitioner in terms of the Act and the constitutions of my affiliated professional bodies; and • I realise that a false declaration is an offence in terms of regulation 71 of the Regulations and is punishable in terms of section 24F of the NEMA.

Disclosure of Vested Interest (delete whichever is not applicable)

• I do not have and will not have any vested interest (either business, financial, personal or other) in the proposed activity proceeding other than remuneration for work performed in terms of the Regulations;

HERITAGE CONSULTANT: PGS Heritage (Pty) Ltd CONTACT PERSON: Wouter Fourie Tel: +27 (0) 12 332 5305 Email: [email protected]

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ACKNOWLEDGEMENT OF RECEIPT

CLIENT: Kongiwe Environmental (Pty) Ltd

CONTACT PERSON: Bradly Thornton Cell: +27 (82) 361 4581 [email protected]

SIGNATURE: ______

Report Title Heritage Impact Report for the proposed Lephalale Coal and Power Project (LCPP) near Lephalale, Lephalale Local Municipality, Waterberg District, Limpopo Province Control Name Signature Designation Author Wouter Fourie Heritage Specialist

Reviewed Environmental Consultant Bradly Thornton

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EXPLANATION OF ABBREVIATIONS USED IN THIS DOCUMENT

ABBREVIATIONS DESCRIPTION AIA Archaeological Impact Assessment ASAPA Association of Southern African Professional Archaeologists CMP Conservation Management Plan CRM Cultural Resource Management EIA Environmental Impact Assessment EMPR Environmental Management Programme Report ESA Early Stone Age GPS Global Positioning System HIA Heritage Impact Assessment HSR Heritage Scoping Report LIA Late Iron Age LSA Later Stone Age MSA Middle Stone Age NEMA National Environmental Management Act NHRA National Heritage Resources Act PGS PGS Heritage PHRA Provincial Heritage Resources Authority SAHRA South African Heritage Resources Agency SAHRIS South African Heritage Resources Information System

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Terminology and Abbreviations

Archaeological resources i. material remains resulting from human activity which are in a state of disuse and are in or on land and which are older than 100 years including artefacts, human and hominid remains and artificial features and structures; ii. rock art, being any form of painting, engraving or other graphic representation on a fixed rock surface or loose rock or stone, which was executed by human agency and which is older than 100 years, including a 10m buffer area; iii. wrecks, being any vessel or aircraft, or any part thereof which was wrecked in South Africa, whether on land, in the internal waters, the territorial waters or in the maritime culture zone of the republic as defined in the Maritimes Zones Act, and any cargo, debris or artefacts found or associated therewith, which is older than 60 years or which SAHRA considers to be worthy of conservation; iv. features, structures and artefacts associated with military history which are older than 75 years and the site on which they are found.

Cultural significance This means aesthetic, architectural, historical, scientific, social, spiritual, linguistic or technological value or significance.

Development This means any physical intervention, excavation or action other than those caused by natural forces, which may according to the heritage agency result in a change to the nature, appearance or physical nature of a place or influence its stability & future well-being, including:

i. construction, alteration, demolition, removal or change in use of a place or a structure at a place; ii. carrying out any works on or over or under a place; iii. subdivision or consolidation of land comprising a place, including the structures or airspace of a place; iv. constructing or putting up for display signs or boards; v. any change to the natural or existing condition or topography of land; and vi. any removal or destruction of trees, or removal of vegetation or topsoil

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Facies Any subgroup of elements within an industry or main culture tradition that is distinguished from the whole on the basis of some aspect of appearance or composition.

Fossil Mineralised bones of animals, shellfish, plants and marine animals. A trace fossil is the track or footprint of a fossil animal that is preserved in stone or consolidated sediment.

Heritage That which is inherited and forms part of the National Estate (historical places, objects, fossils as defined by the National Heritage Resources Act 25 of 1999).

Heritage resources This means any place or object of cultural significance.

Heritage site A heritage resources proclaimed under section 27 of the NHRA and protected and managed by the relevant heritage authority as designated in the province

Later Stone Age The archaeology of the last 20 000 years, associated with fully modern people.

Late Iron Age (Early Farming Communities) The archaeology of the last 1000 years up to the 1800’s associated with ironworking and farming activities such as herding and agriculture.

Middle Stone Age The archaeology of the Stone Age, dating to between 20 000-300 000 years ago, associated with early modern humans.

Palaeontology Any fossilised remains or fossil trace of animals or plants which lived in the geological past and any site which contains such fossilised remains or trace.

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Figure 1: Human and Cultural Time line in Africa (Morris, 2008)

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EXECUTIVE SUMMARY

PGS Heritage (Pty) Ltd (PGS) was appointed by Kongiwe Environmental (Pty) Ltd (Kongiwe) to undertake an HIA which forms part of the EIA for the proposed Lephalale Coal and Power Project (LCPP) near Lephalale, Lephalale Local Municipality, Waterberg District, Limpopo Province.

The Heritage Scoping Report has shown that the proposed LCPP may have heritage resources present in the study area. This has been confirmed through archival research and evaluation of aerial photography and topographical maps of the sites.

Evaluation of aerial photography has indicated the area that may be sensitive from a heritage perspective.

These findings provided the basis for the recommendation of further field truthing through a heritage field study and palaeontological desktop study covering the site. The current stakeholder engagement process has identified only one grave located on the farm Stellenbosch 203 LQ. This identified grave will be followed up during the field work phase of the HIA.

The fieldwork for the HIA identified 8 heritage resources with different heritage significance ratings. These sites consist of 6 ruined homesteads and two burial grounds. Of these eight resources only two with heritage significance (LCPP 001 (low heritage significance), and 006 (high heritage significance)) will be directly impact by the project activities.

The impact significance before mitigation on the heritage resources varies between HIGH negative(LCPP006), MEDIUM negative (LCPP001) to LOW negative (LCPP 003, 004, 005, 007 and 008). Implementation of the recommended mitigation measures will reduce this impact rating to LOW negative or MEDIUM positive in the case of LCPP008.

The management and mitigation measures as described in Section 7 of this report has been developed to minimise the project impact on heritage resources.

It is my considered opinion that overall impact on heritage resources after the implementation of the recommended mitigation measures is acceptably low and that the project can be approved from a heritage perspective.

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CONTENTS PAGE

Lephalale Coal and Power Project (LCPP) ...... i Proposed Lephalale Coal and Power Project (LCPP) near Lephalale, Lephalale Local Municipality, Waterberg District, Limpopo Province ...... i 1 INTRODUCTION ...... 1 1.1 Scope of the Study ...... 1 1.2 Specialist Qualifications ...... 1 1.3 Assumptions and Limitations ...... 1 1.4 Legislative Context ...... 2 1.5 International Requirements ...... 3 1.5.1 The International Finance Corporation ...... 3 1.5.2 Equator Principles ...... 5 2 SITE LOCATION AND DESCRIPTION ...... 10 2.1 Locality ...... 10 2.2 Project background ...... 11 3 ASSESSMENT METHODOLOGY ...... 13 3.1 Methodology for Assessing Heritage Resources significance ...... 13 3.1.1 Site Significance ...... 14 3.2 Methodology used in determining the significance of environmental impacts 15 4 DESKTOP STUDY FINDINGS ...... 17 4.1 Historic Overview of Study Area and Surrounding Landscape ...... 17 4.2 Spatial analysis findings ...... 23 4.3 Archival and Historic Maps of the Study Area and Surrounding Landscape .... 23 4.3.1 First Edition of the 2327DB Topographical Sheet ...... 23 4.3.2 Google Earth Aerial photo analysis ...... 24 4.3.3 Heritage sensitivities ...... 24 4.3.4 Possible finds ...... 24 4.3.5 Stakeholder Engagement ...... 27 5 FIELDWORK FINDINGS ...... 27 5.1 Methodology ...... 27 5.2 Findings ...... 29 6 PALAEONTOLOGICAL BACKGROUND ...... 44 7 IMPACT ASSESSMENT ...... 48 7.1 Impact on recent historic structures ...... 48

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7.2 Impact on burial grounds ...... 48 7.3 Impact on Paleontological Resources...... 49 7.4 Impact assessment table for heritage resources ...... 50 7.5 Management recommendations and guidelines ...... 53 7.5.1 Construction phase ...... 53 7.5.2 Chance find procedure ...... 53 7.6 Possible finds during construction ...... 54 7.7 Timeframes ...... 54 7.8 Heritage Management Plan for EMP implementation ...... 55 8 CONCLUSIONS ...... 57 9 REFERENCES ...... 58 9.1 Published References ...... 58 9.2 Unpublished References ...... 58 9.3 Historic Topographic Maps ...... 60 9.4 Google Earth ...... 60

APPENDICES

Appendix A Legislative Requirements – Terminology and Assessment Criteria

List of Figures

Figure 1: Human and Cultural Time line in Africa (Morris, 2008) ...... vii Figure 2: The proposed development within its local context...... 11 Figure 3: Structures as present on 1969 topographical map 2327DB ...... 25 Figure 4: Landforms and structures identified from the aerial photographic analysis ...... 26 Figure 5: Footprint area with fieldwork tracklogs ...... 27 Figure 6: General bushveld conditions ...... 28 Figure 7: Wooded grass land in the area...... 28 Figure 8: General view of LCPP 001 ...... 30 Figure 9: Remains of one of the structures at LCPP 001 ...... 30 Figure 10: Main house at LCPP 002 ...... 31 Figure 11: Labourers cottage at LCPP 002 ...... 31 Figure 12: View of LCPP 003 ...... 33

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Figure 13: One of the structures at LCPP 003 ...... 33 Figure 14: Outline of small rondavel foundation at LCPP 004 ...... 35 Figure 15: Rubbish dump at LCPP 004 ...... 35 Figure 16: General view of LCPP 005 ...... 36 Figure 17: Some of the metal artefact on site at LCPP 005 ...... 36 Figure 18: General view of burial ground at LCPP 006 ...... 38 Figure 19: One of the Stone packed grave ...... 38 Figure 20: remains of house at LCPP 007 ...... 40 Figure 21:Remains of foundation at LCPP 007 ...... 40 Figure 22: View of the burial ground at LCPP 008 ...... 42 Figure 23: Stone lined grave at LCPP 008 ...... 42 Figure 24: Distribution of heritage resources in relation to infrastructure ...... 43 Figure 25: The surface geology of the proposed proposed development of the Lephalale coal and power project, Lephalale, Lmpopo Province, Republic of South Africa. The proposed footprint is underlain by sediments of the Karoo Basin and the proposed project is underlain by the Clarens, Dwyka, Kransberg Subgroup, Waterberg Group, Lebowa Granite, Lisbon, Palala Granite and Villa Nora Grabbo-Anorthosite (Banzai Environmental, July 2017) ) ...... 47

List of Tables

Table 1 :Sections of IFC Standards relevant to heritage resources and their management ...... 4 Table 2: List of Prospecting Rights ...... 12 Table 3: Site significance classification standards as prescribed by SAHRA...... 14 Table 4: Significance Rating Methodology ...... 15 Table 5: Landform to heritage matrix ...... 23 Table 6: Landform to heritage matrix ...... 24 Table 7: Heritage resources found ...... 29 Table 8: Summary of the Geological and Palaeontological History (Banzai Environmental, July 2017) ...... 44 Table 9: Heritage Impact Table ...... 50 Table 10: Lead times for permitting and mobilisation ...... 54

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1 INTRODUCTION PGS Heritage (Pty) Ltd (PGS) was appointed by Kongiwe Environmental (Pty) Ltd (Kongiwe) to undertake a Heritage Impact Assessment (HIA) which forms part of the Environmental Impact Assessment (EIA) for the proposed Lephalale Coal and Power Project (LCPP) near Lephalale, Lephalale Local Municipality, Waterberg District, Limpopo Province.

1.1 Scope of the Study

The aim of the study is to identify possible heritage resources and finds that may occur in the proposed development area. The HIA aims to inform the Environmental Assessment Practitioner (EAP) in the development of a comprehensive EIA and Environmental Management Plan (EMP) to assist the developer in managing the identified heritage resources in a responsible manner to protect, preserve, and develop them within the framework provided by the National Heritage Resources Act of 1999 (Act 25 of 1999) (NHRA).

1.2 Specialist Qualifications

This HIA was compiled by PGS Heritage, the staff of which has a combined experience of nearly 70 years in the heritage consulting industry and have extensive experience in managing the HIA processes.

Wouter Fourie, Principal Heritage Specialist for this project, is registered as a Professional Archaeologist with the Association of Southern African Professional Archaeologists (ASAPA) and has CRM accreditation within the said organisation, as well as being accredited as a Professional Heritage Practitioner with the Association of Professional Heritage Practitioners – Western Cape (APHP).

1.3 Assumptions and Limitations

Without detracting in any way from the comprehensiveness of the fieldwork undertaken, it is necessary to realise that the heritage resources located during the fieldwork do not necessarily represent all the possible heritage resources present within the area. Various factors account for this, including the subterranean nature of some archaeological sites and the current dense vegetation cover. As such, should any heritage features and/or objects not included in the present inventory be located or observed, a heritage specialist must immediately be contacted.

HIA - Lephalale Coal and Power Project (LCPP) Page 1 Such observed or located heritage features and/or objects may not be disturbed or removed in any way until such time that the heritage specialist has been able to make an assessment as to the significance of the site (or material) in question. This applies to graves and cemeteries as well. In the event that any graves or burial places are located during the development, the procedures and requirements pertaining to graves and burials will apply as set out below.

1.4 Legislative Context

The identification, evaluation and assessment of any cultural heritage resources, artefact or find in the South African context is required and governed by the following legislation:

i. National Environmental Management Act (NEMA) Act 107 of 1998 ii. National Heritage Resources Act (NHRA) Act 25 of 1999 iii. Mineral and Petroleum Resources Development Act (MPRDA) Act 28 of 2002

The NHRA stipulates that cultural heritage resources may not be disturbed without authorization from the relevant heritage authority. Section 34(1) of the NHRA states that, “no person may alter or demolish any structure or part of a structure which is older than 60 years without a permit issued by the relevant provincial heritage resources authority…” The NHRA is utilized as the basis for the identification, evaluation and management of heritage resources and in the case of CRM those resources specifically impacted on by development as stipulated in Section 38 of NHRA, and those developments administered through NEMA, and MPRDA legislation. In the latter cases the feedback from the relevant heritage resources authority is required by the State and Provincial Departments managing these Acts before any authorizations are granted for development. The last few years have seen a significant change towards the inclusion of heritage assessments as a major component of Environmental Impacts Processes required by NEMA and MPRDA. This change requires us to evaluate the Section of these Acts relevant to heritage (Fourie, 2008).

The NEMA 23(2)(b) states that an integrated environmental management plan should, “…identify, predict and evaluate the actual and potential impact on the environment, socio-economic conditions and cultural heritage”.

HIA - Lephalale Coal and Power Project (LCPP) Page 2 1.5 International Requirements

The regulatory aspects dealt with above relate solely to the in house South African laws and regulations and would usually be the only requirements for an application for a Mining Right. However, it may be that international financing is required for a large-scale project, in which case Project Finance Advisory Services, Project Finance, Project-Related Corporate Loans or Bridging Loans may be required. In such a case, the applicant for international financing will need to comply with the requirements of the International Finance Corporation (IFC) Performance Standards and the Equator Principles observed by most large international financial institutions. Summaries of these requirements are set out below.

1.5.1 The International Finance Corporation

The IFC Performance Standards are an international benchmark for identifying and managing environmental and social risk and has been adopted by many organizations as a key component of their environmental and social risk management. IFC’s Environmental, Health, and Safety (EHS) Guidelines provide technical guidelines with general and industry-specific examples of good international industry practice to meet IFC’s Performance Standards (PS).

In many countries, the scope and intent of the IFC Performance Standards is addressed or partially addressed in the country’s environmental and social regulatory framework. The IFC Performance Standards encompass eight topics of which PS7 and PS8 have direct relevance on heritage resources: i. PS 1 - Environmental and Social Assessment and Management System: ii. PS 2 - Labour and Working Conditions: iii. PS 3 - Pollution Prevention and Abatement: iv. PS 4 - Community Health, Safety and Security: v. PS 5 - Land Acquisition and Involuntary Resettlement: vi. PS 6 - Biodiversity Conservation and Sustainable Natural Resource Management: vii. PS 7 - Indigenous Peoples: viii. PS 8 - Cultural Heritage:

Table 1 provides a listing of the relevant sections pertaining to cultural heritage.

HIA - Lephalale Coal and Power Project (LCPP) Page 3 Table 1 :Sections of IFC Standards relevant to heritage resources and their management DESCRIPTION OF THE GUIDELINE RELEVANT CHAPTER REQUIREMENT International Finance Standard (PS) 5 – Paragraph 3 Minimization and avoidance of Corporations (IFC) impacts from project related Performance activities. Standard Standard (PS) 5 – Paragraph 10 Engagement with affected (Community Engagement) communities and the disclosure of (2012). relevant information of the relocation process. Standard (PS) 5 – Paragraph 20 Respecting the social and cultural institutions of the displaced persons and any host communities. Standard (PS) 8 – Paragraph 9 The need for consultation with (Consultation) (2012). affected communities to identify cultural heritage of importance and involve affected communities and involve the relevant national or local regulatory authorities in the decision-making processes. Standard (PS) 8 – Paragraph 12 The removal of cultural heritage (Removal of Non-Replicable must only be considered when no Cultural Heritage) (2012). other alternative is available.

The IFC’s Performance Standards offer a framework for understanding and managing environmental and social risks for high profile, complex, international or potentially high impact project. The financial institution is required to verify as part of its environmental and social due diligence process that the commercial client/investee complies with the IFC Performance Standards. To do so, the financial institution needs to be knowledgeable of the environmental and social laws of the country in which it operates and compare the regulatory requirements against those of the IFC Performance Standards to identify gaps. A good understanding of both sets of requirements as well as potential gaps ensures that the financial institution will effectively identify and assess the key environmental and social risks and impacts that might be associated with a financial transaction.

HIA - Lephalale Coal and Power Project (LCPP) Page 4 If non-compliances with the IFC Performance Standards are identified and depending on the severity of the issue, the financial institution can require the commercial client/investee to develop a corrective action plan for addressing the issue within a reasonable timeframe and stipulate this as a condition of the financial transaction with the commercial client/investee.

The IFC Performance Standards help IFC and its clients manage and improve their environmental and social performance through an outcomes-based approach and also provide a solid base from which clients may increase the sustainability of their business operations. The desired outcomes are described in the objectives of each Performance Standard, followed by specific requirements to help clients achieve these outcomes through means that are appropriate to the nature and scale of the project and commensurate with the level of environmental and social risks (likelihood of harm) and impacts.

1.5.2 Equator Principles

The Equator Principles (EP) is a risk management framework, adopted by financial institutions, for determining, assessing and managing environmental and social risk in projects and is primarily intended to provide a minimum standard for due diligence to support responsible risk decision- making. The EP apply globally, to all industry sectors and to four financial products – 1) Project Finance Advisory Services; 2) Project Finance; 3) Project-Related Corporate Loans; and 4) Bridge Loans. The relevant thresholds and criteria for application are described in detail in the Scope section of the EP.

Equator Principles Financial Institutions (EPFI) commit to implementing the EP in their internal environmental and social policies, procedures and standards for financing projects and will not provide Project Finance or Project-Related Corporate Loans to projects where the client will not, or is unable to, comply with the EP.

The EP have greatly increased the attention and focus on social/community standards and responsibility, including robust standards for indigenous peoples, labour standards, and consultation with locally affected communities within the Project Finance market. They have also promoted convergence around common environmental and social standards. Multilateral

HIA - Lephalale Coal and Power Project (LCPP) Page 5 development banks, including the European Bank for Reconstruction & Development, and export credit agencies through the Organisation for Economic Co-operation and Development (OECD) Common Approaches are increasingly drawing on the same standards as the EP. The EP have also helped spur the development of other responsible environmental and social management practices in the financial sector and banking industry (for example, Carbon Principles in the US, Climate Principles worldwide) and have provided a platform for engagement with a broad range of interested stakeholders, including non-governmental organisations (NGOs), clients and industry bodies.

The EP consist of 10 Principles, outlined below. i. Principle 1: Review and Categorisation When a Project is proposed for financing, the EPFI will, as part of its internal environmental and social review and due diligence, categorise it based on the magnitude of its potential environmental and social risks and impacts. Such screening is based on the environmental and social categorisation process of the International Finance Corporation (IFC). Using categorisation, the EPFI’s environmental and social due diligence is commensurate with the nature, scale and stage of the Project, and with the level of environmental and social risks and impacts. The categories are: Category A – Projects with potential significant adverse environmental and social risks and/or impacts that are diverse, irreversible or unprecedented; Category B – Projects with potential limited adverse environmental and social risks and/or impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures; and Category C – Projects with minimal or no adverse environmental and social risks and/or impacts ii. Principle 2: Environmental and Social Assessment For all Category A and Category B Projects, the EPFI will require the client to conduct an Assessment process to address, to the EPFI’s satisfaction, the relevant environmental and social risks and impacts of the proposed Project. The Assessment Documentation should propose measures to manage impacts in a manner relevant and appropriate to the nature and scale of the proposed Project. One or more specialised studies may also need to be undertaken for the Assessment Documentation. It may in some cases be appropriate for the client to complement its Assessment Documentation with specific human rights due diligence.

HIA - Lephalale Coal and Power Project (LCPP) Page 6 For all Projects, in all locations, when combined Scope 1 and Scope 2 Emissions are expected to be more than 100,000 tonnes of CO2 equivalent annually, an alternatives analysis will be conducted to evaluate less Greenhouse Gas (GHG) intensive alternatives. iii. Principle 3: Applicable Environmental and Social Standards The Assessment process should, in the first instance, address compliance with relevant host country laws, regulations and permits that pertain to environmental and social issues. EPFIs operate in diverse markets: some with robust environmental and social governance, legislation systems and institutional capacity designed to protect their people and the natural environment; and some with evolving technical and institutional capacity to manage environmental and social issues. The EPFI will require that the Assessment process evaluates compliance with the applicable standards for what are known as Designated Countries (the First World countries with robust regulatory systems), where the Assessment process evaluates compliance with relevant host country laws, regulations and permits that pertain to environmental and social issues; and Non-Designated Countries, where the Assessment process evaluates compliance with the then applicable IFC Performance Standards iv. Principle 4: Environmental and Social Management System and Equator Principles Action Plan For all Category A and Category B Projects, the EPFI will require the client to develop or maintain an Environmental and Social Management System (ESMS). Further, an Environmental and Social Management Plan (ESMP) will be prepared by the client to address issues raised in the Assessment process and incorporate actions required to comply with the applicable standards. Where the applicable standards are not met to the EPFI’s satisfaction, the client and the EPFI will agree an Equator Principles Action Plan (AP). The Equator Principles AP is intended to outline gaps and commitments to meet EPFI requirements in line with the applicable standards. v. Principle 5: Stakeholder Engagement For all Category A and Category B Projects, the EPFI will require the client to demonstrate effective Stakeholder Engagement as an ongoing process in a structured and culturally appropriate manner with Affected Communities and, where relevant, Other Stakeholders. For Projects with potentially significant adverse impacts on Affected Communities, the client will conduct an Informed Consultation and Participation process. The engagement process should be free from external manipulation, interference, coercion and intimidation. The client will take account of, and document, the results of the Stakeholder Engagement process, including any actions agreed resulting from such process. For Projects with environmental or social

HIA - Lephalale Coal and Power Project (LCPP) Page 7 risks and adverse impacts, disclosure should occur early in the Assessment process, in any event before the Project construction commences, and on an ongoing basis. EPFIs recognise that indigenous peoples may represent vulnerable segments of project-affected communities. Projects affecting indigenous peoples are subject to a more rigorous process of Informed Consultation and Participation. vi. Principle 6: Grievance Mechanism For all Category A and, as appropriate, Category B Projects, the EPFI will require the client, as part of the ESMS, to establish a grievance mechanism designed to receive and facilitate resolution of concerns and grievances about the Project’s environmental and social performance. The grievance mechanism will seek to resolve concerns promptly, using an understandable and transparent consultative process that is culturally appropriate, readily accessible, at no cost, and without retribution to the party that originated the issue or concern. The mechanism should not impede access to judicial or administrative remedies. The client will inform the Affected Communities about the mechanism in the course of the Stakeholder Engagement process. vii. Principle 7: Independent Review: Project Finance For all Category A and, as appropriate, Category B Projects an Independent Environmental and Social Consultant, not directly associated with the client, will carry out an Independent Review of the Assessment Documentation including the ESMPs, the ESMS, and the Stakeholder Engagement process documentation to assist the EPFI's due diligence, and assess Equator Principles compliance. Project-Related Corporate Loans An Independent Review by an Independent Environmental and Social Consultant is required for Projects with potential high risk impacts including, but not limited to, any of the following adverse impacts on indigenous peoples, Critical Habitat impacts, Significant cultural heritage impacts and Large-scale resettlement. In other Category A, and as appropriate Category B, Project-Related Corporate Loans, the EPFI may determine whether an Independent Review is appropriate or if internal review by the EPFI is sufficient. This may take into account the due diligence performed by a multilateral or bilateral financial institution or an OECD Export Credit Agency, if relevant. viii. Principle 8: Covenants An important strength of the Equator Principles is the incorporation of covenants linked to compliance. For all Projects, the client will covenant in the financing documentation to comply with all relevant host country environmental and social laws, regulations and permits in all material respects.

HIA - Lephalale Coal and Power Project (LCPP) Page 8 Furthermore, for all Category A and Category B Projects, the client will covenant the financial documentation: a) to comply with the ESMPs and Equator Principles AP (where applicable) during the construction and operation of the Project in all material respects; b) to provide periodic reports in a format agreed with the EPFI (with the frequency of these reports proportionate to the severity of impacts, or as required by law, but not less than annually), prepared by in-house staff or third party experts, that document compliance with the ESMPs and Equator Principles AP (where applicable), and provide representation of compliance with relevant local, state and host country environmental and social laws, regulations and permits; and c) to decommission the facilities, where applicable and appropriate, in accordance with an agreed decommissioning plan. d) Where a client is not in compliance with its environmental and social covenants, the EPFI will work with the client on remedial actions to bring the Project back into compliance to the extent feasible. If the client fails to re-establish compliance within an agreed grace period, the EPFI reserves the right to exercise remedies, as considered appropriate. ix. Principle 9: Independent Monitoring and Reporting Project Finance To assess Project compliance with the Equator Principles and ensure ongoing monitoring and reporting after Financial Close and over the life of the loan, the EPFI will, for all Category A and, as appropriate, Category B Projects, require the appointment of an Independent Environmental and Social Consultant, or require that the client retain qualified and experienced external experts to verify its monitoring information which would be shared with the EPFI. Project-Related Corporate Loans For Projects where an Independent Review is required under Principle 7, the EPFI will require the appointment of an Independent Environmental and Social Consultant after Financial Close, or require that the client retain qualified and experienced external experts to verify its monitoring information which would be shared with the EPFI. x. Principle 10: Reporting and Transparency Client Reporting Requirements The following client reporting requirements are in addition to the disclosure requirements in Principle 5. For all Category A and, as appropriate, Category B Projects: The client will ensure that, at a minimum, a summary of the ESIA is accessible and available online.

HIA - Lephalale Coal and Power Project (LCPP) Page 9 The client will publicly report GHG emission levels (combined Scope 1 and Scope 2 Emissions) during the operational phase for Projects emitting over 100,000 tonnes of CO2 equivalent annually.

EPFI Reporting Requirements The EPFI will report publicly, at least annually, on transactions that have reached Financial Close and on its Equator Principles implementation processes and experience, taking into account appropriate confidentiality considerations. There are two important Attachments to the Equator Principles: Annex A dealing with Climate Change: Alternatives Analysis, Quantification and Reporting of Greenhouse Gas Emissions; and Annex B dealing with Minimum Reporting Requirements on: - Data and Implementation Reporting - Project Finance Advisory Services Data - Bridge Loans Data - Implementation Reporting - Project Name Reporting for Project Finance

2 SITE LOCATION AND DESCRIPTION 2.1 Locality

The project is located within the Lephalale Local Municipality in the Waterberg District Municipality of Limpopo Province, South Africa. The LCPP lies approximately 6 km north of the R518 provincial road linking the town of Lephalale and the village of Marken (see map).

The project is made up of 12 farms. Lephalale Coal Mines (Pty) Limited (LCM), a subsidiary of Dedicoal, which in turn is a company within the Masimong Group, has secured the prospecting rights for the associated farms, as set out in Table 2 below and depicted in Figure 2.

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Figure 2: The proposed development within its local context.

2.2 Project background

LCM proposes to develop a new Open Pit Coal Mine and Independent Power Producer (IPP) plant approximately 22km northeast of the town of Lephalale. The project is known as the Lephalale Coal and Power Project (LCPP) and is in the Lephalale Local Municipality. The proposed site is 10 km north of the R518 provincial road which links the town of Lephalale and the village of Marken. The project area is made up of the 12 farms referred to in Table 2.

Kongiwe Environmental (Pty) Ltd has been appointed by LCM to undertake the Environmental Impact Assessment (EIA) process as part of the Mining Right Application (MRA) and other Environmental Authorisations (EA’s) required for the proposed Mine and IPP. It is noted that the economic base case includes the discharge of the coal through the IPP, but alternative markets and optimisation options are being investigated. Importantly, the applications at this stage will only be made for the mining section, applications for the IPP will be done in the future once the detailed design of the IPP has progressed.

LCM, although it is not the freehold owner of any of the relevant properties, is the holder of the Prospecting Rights (PRs) granted in terms of the provisions of the Mineral and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA). The PRs were originally granted to Thandululo Coal Mining (Pty) Limited and duly ceded in terms of the provisions of Section 11 of the MPRDA to LCM.

HIA - Lephalale Coal and Power Project (LCPP) Page 11

Table 2: List of Prospecting Rights

FARM PROSPECTING RIGHT LAND OWNER

Honingshade 427 LQ Robbertse Besigheidstrust

Garibaldi 480 LQ Garibaldi Boerdery CC

Philippus Johannes & Pretoria 483 LQ Johanna Petronella Jacobs

Wellington 432 LQ Marthinus Phillipus van Staden LP 30/5/1/1/2/1359PR Forfarshire 419 LQ Johanna Catarina Nortje

Stutgard 420 LQ Stutgard Boerdery CC

CID Prop Inv CC & Billiards 428 LQ Johannes Albertus Beukes

Franschoek 207 LQ Turquoise Moon Trading 167 Pty Ltd

Langriem Boerdery CC & Grootgenoeg 426 LQ Cornelis Jacobus Alant

EBS Boerdery Beleggings Pty Ltd & Weltevreden 482 LQ Meromi Beleggings Pty Ltd LP 30/5/1/1/2/1046PR Handak Eiendomme CC, Sebright 205 LQ Turquoise Moon Trading 167 Pty Ltd & George Sebastian Geringer

Botmansdrift 423 LQ Madjimoto Boerdery CC

The total area of LP 1046 PR is about 3927.6 hectares and for LP 1359 PR about 7866.9. Both PRs cover the minerals coal, pseudocoal and torbanite.

Prospecting Right LP 1046 was granted in 2007 and subsequently renewed for a further period of three years by virtue of a Notarial Deed of Renewal executed in August 2014. Prospecting Right LP 1359 PR was originally granted in 2008 and subsequently renewed by a Notarial Deed of

HIA - Lephalale Coal and Power Project (LCPP) Page 12 Renewal, the exact date of which is not known. However, the letters from the Regional Manager confirming the granting of the renewal of LP 1046 PR and LP 1359 PR1 are dated 24 April 2014.

3 ASSESSMENT METHODOLOGY The section below outlines the assessment methodologies utilised in the study.

3.1 Methodology for Assessing Heritage Resources significance

This HIA report was compiled by PGS Heritage (PGS) for the proposed LCPP project. The applicable maps, tables and figures are included as stipulated in the NHRA and the NEMA. The HIA process, of which the HSR and HIA documents forms part, consisted of three steps:

Step I – Literature Review and site analysis (completed in the HSR): The background information to the field survey relies greatly on the Heritage Background Research.

Step II – Physical Survey (completed as part of the HSR): A physical survey was conducted on foot through the proposed project area by a qualified archaeologist (January 2017), aimed at locating and documenting sites falling within and adjacent to the proposed development footprint.

Step III (This HIA document) – The final step involved the recording and documentation of relevant archaeological resources, the assessment of resources in terms of the HIA criteria and report writing, as well as mapping and constructive recommendations.

The significance of heritage resources was based on four main criteria: • Site integrity (i.e. primary vs. secondary context), • Amount of deposit, range of features (e.g., stonewalling, stone tools and enclosures), • Density of scatter (dispersed scatter) o Low - <10/50m2 o Medium - 10-50/50m2 o High - >50/50m2 • Uniqueness; and • Potential to answer present research questions.

1 There is a subsequent letter addressed to Thandululo Coal (Pty) in respect of LP 1359 PR which is dated 17 July 2014 but this does not change the position.

HIA - Lephalale Coal and Power Project (LCPP) Page 13 Management actions and recommended mitigation, which will result in a reduction in the impact on the sites, will be expressed as follows: A - No further action necessary; B - Mapping of the site and controlled sampling required; C - No-go or relocate development activity position; D - Preserve site, or extensive data collection and mapping of the site; and E - Preserve site.

Impacts on these sites by the development will be evaluated as follows:

3.1.1 Site Significance

Site significance classification standards prescribed by the SAHRA (2006) and approved by the ASAPA for the Southern African Development Community (SADC) region, were used for the purpose of this report.

Table 3: Site significance classification standards as prescribed by SAHRA. FIELD RATING GRADE SIGNIFICANCE RECOMMENDED MITIGATION National Grade 1 - Conservation; National Site Significance (NS) nomination Provincial Grade 2 - Conservation; Provincial Site Significance (PS) nomination Local Significance Grade 3A High Significance Conservation; Mitigation not (LS) advised Local Significance Grade 3B High Significance Mitigation (Part of site should (LS) be retained) Generally Protected - High / Medium Mitigation before destruction A (GP.A) Significance Generally Protected - Medium Recording before destruction B (GP.B) Significance

Generally Protected - Low Significance Destruction C (GP.A)

HIA - Lephalale Coal and Power Project (LCPP) Page 14 3.2 Methodology used in determining the significance of environmental impacts

The impact significance rating process serves two purposes: firstly, it helps to highlight the critical impacts requiring consideration in the management and approval process; secondly, it shows the primary impact characteristics, as defined above, used to evaluate impact significance. The impact significance rating system is presented in Table 4 and involves three parts: Part A: Define impact consequence using the three primary impact characteristics of magnitude, spatial scale/ population and duration; Part B: Use the matrix to determine a rating for impact consequence based on the definitions identified in Part A; and Part C: Use the matrix to determine the impact significance rating, which is a function of the impact consequence rating (from Part B) and the probability of occurrence.

Table 4: Significance Rating Methodology PART A: DEFINING CONSEQUENCE IN TERMS OF MAGNITUDE, DURATION AND SPATIAL SCALE Use these definitions to define the consequence in Part B Impact Definition Criteria characteristics

Substantial deterioration or harm to receptors; receiving environment has an inherent value to Major - stakeholders; receptors of impact are of conservation importance; or identified threshold often exceeded

Moderate/measurable deterioration or harm to receptors; receiving environment moderately Moderate - sensitive; or identified threshold occasionally exceeded

Minor deterioration (nuisance or minor MAGNITUDE deterioration) or harm to receptors; change to Minor - receiving environment not measurable; or identified threshold never exceeded

Minor improvement; change not measurable; or Minor + threshold never exceeded

Moderate improvement; within or better than the Moderate + threshold; or no observed reaction

Substantial improvement; within or better than Major + the threshold; or favourable publicity

Site specific or confined to the immediate project SPATIAL SCALE OR Site or local area POPULATION

HIA - Lephalale Coal and Power Project (LCPP) Page 15 May be defined in various ways, e.g. cadastral, Regional catchment, topographic

National/ Nationally or beyond International Up to 18 months. Short term Medium term 18 months to 5 years DURATION Long term Longer than 5 years

PART B: DETERMINING CONSEQUENCE RATING Rate consequence based on definition of magnitude, spatial extent and duration SPATIAL SCALE/ POPULATION

National/ Site or Regional internation Local al

MAGNITUDE Long term Medium Medium High

Medium term Low Low Medium Minor DURATION Short term Low Low Medium

Long term Medium High High

Moderate Medium term Medium Medium High DURATION Short term Low Medium Medium

Long term High High High

Major DURATION Medium term Medium Medium High

Short term Medium Medium High

PART C: DETERMINING SIGNIFICANCE RATING Rate significance based on consequence and probability CONSEQUENCE

Low Medium High

Definite Medium Medium High PROBABILITY (of exposure Possible Low Medium High to impacts) Unlikely Low Low Medium

HIA - Lephalale Coal and Power Project (LCPP) Page 16 4 DESKTOP STUDY FINDINGS 4.1 Historic Overview of Study Area and Surrounding Landscape

DATE DESCRIPTION The Earlier Stone Age is the first and oldest phase identified in South Africa’s archaeological history and comprises two technological phases. The earliest of these is known as Oldowan and is associated with crude flakes and hammer 2.5 million to 250 stones. It dates to approximately 2 million years ago. The second technological 000 years ago phase is the Acheulian and comprises more refined and better made stone artefacts such as the cleaver and bifacial hand axe. The Acheulian dates back to approximately 1.5 million years ago.

The Middle Stone Age (MSA) is the second oldest phase identified in South Africa’s archaeological history. This phase is associated with flakes, points and blades manufactured by means of the so-called ‘prepared core’ technique. A number of MSA sites are known from the surroundings of the study area, 250 000 to 40 000 many of which were identified during previous heritage and archaeological years ago studies. For example, a total of 11 MSA sites were identified in an area roughly 20km north-west of the study area (Huffman & Van der Walt, 2013). Furthermore, a total of seven MSA sites were identified in an area roughly 5.8km north-west of the study area. For the most part these latter sites comprise findspots consisting of one or two lithics (Higgitt et. al., 2013).

The Later Stone Age is the third archaeological phase identified and is associated with an abundance of very small artefacts known as microliths. This period in human history can also be associated with rock art in the form of 40 000 years ago to engravings and paintings. the historic past Nelson’s Kop, situated roughly 36km south-east of the present study area, is a rock engraving site comprising cupules, animal spoor and incisions (Van Schalkwyk, 2005).

The Bambata facies of the Benfica Sub-Branch of the Kalundu Ceramic Tradition represents the earliest known Iron Age period within the surroundings of the study area. The decoration on the ceramics from this AD 150 – AD 650 facies is characterised by “...fine decoration, multiple bands and cross- hatching on long rim, alternating blocks of stamped and incised lines in neck.” (Huffman, 2007:215).

The Happy Rest facies of the Happy Rest Sub-Branch of the Kalundu Ceramic Tradition represents the second known Iron Age period within the AD 500 – AD 750 surroundings of the study area. The decoration on the ceramics from this facies is characterised by “...thickened rim, multiple bands of mixed decoration techniques, ladder stamping.” (Huffman, 2007:221).

The Diamant facies of the Kalundu Ceramic Tradition represents the third known Iron Age period within the surroundings of the study area. The AD 750 – AD 1000 decoration on the ceramics from this facies is characterised by “...tapered rims with broadly incised herringbone.” (Huffman, 2007:225).

AD 1000 – AD 1300 The Eiland facies of the Kalundu Ceramic Tradition represents the fourth known Iron Age period within the surroundings of the study area. The

HIA - Lephalale Coal and Power Project (LCPP) Page 17 decoration on the ceramics from this facies is characterised by “...fine herringbone with stamping.” (Huffman, 2007:221).

The Madikwe facies of the Moloko Branch of the Urewe Ceramic Tradition represents the fifth known Iron Age period within the surroundings of the AD 1500 – AD 1700 study area. The decoration on the ceramics from this facies is characterised by “...multiple bands of cord impressions, incisions, stabs and punctates separated by colour.” (Huffman, 2007:201).

The Letsibogo facies of the Moloko Branch of the Urewe Ceramic Tradition represents the sixth known Iron Age period within the surroundings of the study area. The decoration on the ceramics from this facies is characterised AD 1550 – AD 1750 by “...lines of punctuates separating black and red zones.” (Huffman, 2007:189). For example, Letsibogo sites were identified in an area roughly 20km north- west of the study area (Huffman & Van der Walt, 2013).

1836 The first Voortrekker parties started crossing the Vaal River (Bergh, 1999).

1840s These years saw the first arrival of Voortrekkers in the general vicinity of the study area (Bergh, 1999). However, the establishment of farms by the Voortrekkers in the direct vicinity of the study area appears to have been isolated and sporadic during these early years with some settlement only taking place during the 1870s. The presence of tsetse fly across sections of present-day Limpopo Province represented a significant hindrance to the permanent settlement of Voortrekkers in this area.

1848 The area that was later to be known as the district of Soutpansberg was established in this year (Bergh, 1999). The study area fell within this district.

1866 The study area now fell within the Waterberg District of the Zuid-Afrikaansche Republiek (Bergh, 1999). The study area remained within this district until c. 1990 when the Ellisras District was established.

1920 In this year F.F. Pienaar applied for permission to peg 50 claims each on the Commented [J1]: Claims for what? As far as I know, after farms Kringgatspruit, Hooikraal, Grootegeluk and Enkelbult (National 1908, the Transvaal Gold Law applied and claims only related to previous metals Archives, MNW, 535, MM1713/20). Commented [WF2]: Claims are referred to in the Archival document) 1920s Coal was first discovered in the vicinity of Lephalale during drilling activities for water (Erasmus, 2004).

1941 - 1952 Exploration activities during this time revealed vast reserves of medium grade coal in the vicinity of where Ellisras (present-day Lephalale) would later be established (Lang, 1995).

December 1960 The town of Ellisras was laid out on the farm Waterkloof. The name of the town was derived from the two owners of the farm at the time, namely Patrick Ellis and Piet Erasmus (Erasmus, 2004).

1973 Iscor commenced with extensive exploration activities in proximity to the study area which located “...exploitable measures estimated at around two billion tons, of which 500 million was classified as blend coking coal.” (Lang, 1995:184).

HIA - Lephalale Coal and Power Project (LCPP) Page 18 1975 A box cut was developed on the farm Enkelbult 462 LQ to mine approximately 30 000 m3 of coal bearing shale during early 1975 (South African Mining and Engineering Journal, 1978). The box cut produced approximately 1500 tons of metallurgical coal as well as a large volume of middlings for large-scale testing at Iscor’s Pretoria and Vanderbijlpark works. Following on successful tests an opencast operation was started during the latter part of 1975. Activities slowed down shortly thereafter due to the economic climate and the financial problems faced by Iscor at the time (Rand Daily Mail, 1977).

1986 The town of Ellisras received municipal status in this year (Erasmus, 2004).

Late 1980s During the mid-1980s the 2 Transvaal Scottish Regiment was deployed on the border with Botswana and had its battalion headquarters at Ellisras. The deployment took place during the Border War and counter-insurgency efforts of the South African Army at the time. It represented the first deployment of a South African Citizen Force on the borders with Botswana and Zimbabwe during this war (Mitchell, 1994). At one stage during this deployment the military base of A Company 2 Transvaal Scottish was established on the farm Appelvlakte (Mitchell, 1994).

2002 The name of the town of Ellisras was changed to Lephalale (Erasmus, 2004).

5.3 Previous Archaeological and Heritage Studies in and around the Study Area

An electronic web search was undertaken and relevant archaeological and historical texts were also consulted. In this regard, the South African Heritage Resources Information System (SAHRIS) was especially helpful (see http://www.sahra.org.za/sahris). A large number of previous archaeological and heritage studies had been undertaken in the general vicinity of Lephalale but not close to the present study area, with many of these studies undertaken for proposed coal mining or related activities. Furthermore, none of these studies indicate the presence of known heritage sites within the study area. The three closest previous studies to the present study area appear to have been the heritage survey undertaken by Dr. J. van Schalkwyk of the Kumba Properties at the Grootegeluk Mine (37km to the southwest of the current study area) (Van Schalkwyk, 2005), the HIA Report undertaken by Dr. J. van Schalkwyk for the proposed establishment of the Exxaro PV Plant on the farm Nelson’s Kop (36 km southwest from the current study area)(Van Schalkwyk, 2011`) as well as the Archaeological Impact Assessment conducted by J. van der Walt for the proposed Thabametsi Coal-Fired Power Station.

A number of heritage sites were identified in the vicinity of the Grootegeluk Mine. The closest identified site to the present study area that could be found in these previous studies is a rock art site located at Nelson’s Kop, which is roughly 36km southwest of the present study area. The site consists of a panel of rock engravings comprising cupules, cut marks and animal tracks located on

HIA - Lephalale Coal and Power Project (LCPP) Page 19 the southern end of the hill as well as circular stone enclosures on the summit of the hill. The hill may have been used as a site of potency during both the Later Stone Age as well as Late Iron Age and was assessed to be of High Significance (Van Schalkwyk, 2005).

The heritage sites identified during the survey undertaken by Dr. J. van Schalkwyk of the Kumba Properties at the Grootegeluk Mine (Van Schalkwyk, 2005) provide a good understanding of the type of heritage sites found within the surroundings of Lephalale. He identified five sites in this area namely the Later Stone Age and Late Iron Age rock art site at Nelson’s Kop referred to above, two cemeteries associated with local farms, a site consisting of non-diagnostic pottery as well as an historic headgear associated with early mining activities in the area. Furthermore, Van Schalkwyk also observed Middle Stone Age lithics associated with outcrops and pans in the study area. Incidentally, the Heritage Impact Assessment Report undertaken by Dr. J. van Schalkwyk for the proposed establishment of the Exxaro PV Plant on the farm Nelson’s Kop identified a single site, namely the rock art site at Nelson’s Kop (Van Schalkwyk, 2011).

These sites are typical of the heritage sites identified during previous heritage studies undertaken in the Lephalale landscape. For example, an HIA undertaken for the Thabametsi Project roughly 40 km southwest from the current study area by Higget et. al. (2013) identified four Late Iron Age sites comprising findspots or low density surface scatters of non-diagnostic pottery, six Middle Stone Age findspots, one Stone Age surface scatter, two historical farmsteads and eight cemeteries. Similarly, an archaeological impact assessment undertaken by Dr. F. Roodt for the proposed development of a heavy industrial area on the farm Grootestryd 465 LQ (36 km southwest from the current study area) identified a number of Middle Stone Age flakes in disturbed contexts (Roodt, 2001).

A number of the previous archaeological and heritage studies refer to the fact that the Lephalale area was never intensively settled by prehistoric and historic communities. In this regard refer for example Van Schalkwyk (2005) and Van der Walt (2012). The reasons behind this lack of intensive human settlement are explained on the basis of climatic, geographical and biological conditions. The study area and surroundings for example are characterised by a landscape that is hot and very dry with limited availability for surface water. Furthermore, tsetse fly was found in the area which would have curtailed any permanent settlement by communities for whom cattle farming was an important socio-economic activity. As a result, Late Iron Age and Voortrekker communities would have preferred establishing themselves in other areas where the rigours of extreme climatic conditions, limited water sources as well as illnesses affecting their animals and

HIA - Lephalale Coal and Power Project (LCPP) Page 20 livelihoods would have been less strenuous. As such it is not surprising that a number of the archaeological and heritage surveys undertaken here did not identify any sites.

A list of some of the previous archaeological and heritage surveys from the larger Lephalale area are provided below:

• Birkholtz, P.D. & M. Hutten. 2014. Heritage Impact Assessment for the proposed development of the Grootegluk Mine Construction Camp for the Market Coke and Co- Generation Plant on a Part of the Farm Enkelbult 462 LQ near Lephalale, Lephalale Local Municipality, Limpopo Province. An unpublished report by PGS Heritage.

• Fourie, W. & van der Walt, J. 2006. Heritage Impact Assessment: Paarl Eco Estate Portion 2 of the Farm Paarl 522 LQ, near Ellisras (Lephalale) in the Suburb of Onverwacht, Limpopo Province. An unpublished report by Matakoma.

• Gaigher, S. 2007a. Heritage Impact Assessment for the Proposed Ellisras Extension 67 Housing Project on the Farm Waterkloof 502 LQ, Limpopo. An unpublished report by Archaeo-Info.

• Gaigher, S. 2007b. Heritage Impact Assessment for the Proposed Ellisras Extension 66 Housing Project on the Farm Waterkloof 502 LQ, Limpopo Province. An unpublished report by Archaeo-Info.

• Higget, N. 2012. Phase 1 Archaeological Impact Assessment for the MBET Pipeline. An unpublished report by Digby Wells Environmental.

• Higget, N. & S. Karodia. 2013. Heritage Impact Assessment for the Proposed Thabametsi Project, Lephalale, Limpopo Province. An unpublished report by Digby Wells.

• Huffman, T.N. & J. van der Walt. 2013. Sasol Limpopo West Heritage Report. An unpublished report by the University of the Witwatersrand.

• Roodt, F. 2001. Archaeological Impact Assessment: Proposed Heavy Industrial Area on Portion 5 of the farm Grootestryd 465 LQ, Ellisras. An unpublished report by R & R Cultural Resource Consultants.

HIA - Lephalale Coal and Power Project (LCPP) Page 21 • Van der Walt, J. 2006. Heritage Impact Assessment: Township establishment on the Remainder of Portion 8 of the farm Onverwacht 503 LQ, near Ellisras (Lephalale), Limpopo Province. An unpublished report by Matakoma.

• Van der Walt, J. 2012. Archaeological Scoping Report for the proposed Sekoko Waterberg Colliery, Lephalale, Limpopo Province. An unpublished report by Heritage Contracts and Archaeological Consulting.

• Van der Walt, J. 2014. Archaeological Impact Assessment for the proposed Thabametsi Coal-Fired Power Station, Lephalale, Limpopo Province. An unpublished report by Heritage Contracts and Archaeological Consulting.

• Van Schalkwyk, J.A. 2005a. Heritage Impact Scoping Report for the Proposed New Matimba B Power Station. Lephalale District, Limpopo Province. An unpublished report by the National Cultural History Museum.

• Van Schalkwyk, J.A. 2005b. Heritage Survey Report of the Kumba Properties at Grootegeluk Mine, Lephalale Area, Limpopo Province. An unpublished report compiled by the National Cultural History Museum.

• Van Schalkwyk, J.A. 2006. Environmental Scoping Report for the Proposed Establishment of a New Coal-Fired Power Station in the Lephalale Area, Limpopo Province. An unpublished report by the National Cultural History Museum.

• Van Schalkwyk, J.A. 2011. Heritage Impact Assessment Report for the Proposed Establishment of the Exxaro PV Plant on the farm Nelsonskop, North-West of Lephalale, Limpopo Province. An unpublished report compiled by Dr. J.A. van Schalkwyk.

• Van Vollenhoven, A.C. 2008a. A Report on a Cultural Heritage Impact Assessment for the Proposed Housing Development at Erf 1522 Ellisras on the Farm Onverwacht 503 LQ, Lephalale, Limpopo Province. An unpublished report by Archaetnos.

• Van Vollenhoven, A.C. 2008b. A Report on a Cultural Heritage Impact Assessment for the Proposed Housing Development at Extension 88 and 90 Ellisras on the Farm Onverwacht 503 LQ, Lephalale, Limpopo Province. An unpublished report by Archaetnos.

HIA - Lephalale Coal and Power Project (LCPP) Page 22 • Van Vollenhoven, A.C. 2008c. A Report on a Cultural Heritage Impact Assessment for the Proposed Housing Development at Extension 89 Ellisras on the Farm Onverwacht 503 LQ, Lephalale, Limpopo Province. An unpublished report by Archaetnos. 4.2 Spatial analysis findings

A spatial and landscape analysis was conducted through the analysis of historical maps, topocadastral maps and aerial photography. The aim was to identify landscape forms, natural features and structures that can potentially have heritage significance or have associated features and structures that can have heritage significance.

The analysis of the studies conducted in the area assisted in the development of the following landform type to heritage find matrix in Table 6.

Table 5: Landform to heritage matrix LAND FROM TYPE HERITAGE TYPE Crest and foot hill LSA and MSA scatters Crest of small hills Small LSA sites – scatters of stone artefacts, ostrich eggshell, pottery and beads Pans Dense LSA sites Dunes Dense LSA sites Outcrops Occupation sites dating to LSA Farmsteads Historical archaeological material

4.3 Archival and Historic Maps of the Study Area and Surrounding Landscape

4.3.1 First Edition of the 2327DB Topographical Sheet

A portion of the First Edition of the 2327DB Topographical Sheet is depicted below (Figure 3). The map was based on aerial photography undertaken in 1965 and was surveyed in 1969 and drawn in 1970 by the Trigonometrical Survey Office.

The following observations can be made from the map:

• Farm buildings are shown on most of the farms within the project area as well as the footprint area of the study (Figure 3).

HIA - Lephalale Coal and Power Project (LCPP) Page 23 4.3.2 Google Earth Aerial photo analysis

After the analysis of the historical topocadastral maps were completed, an analysis of available aerial photographs was done. The aim was to identify man-made structures as well as landforms that can possible be associated with settlement patterns of historical people. These landforms as identified in Table 5 will guide focussed field work and assist in the identification of potential heritage resources. Attention was given to making a distinction between man-made watering holes and naturally occurring watering holes as the latter can have associated heritage resources and features (Figure 4).

4.3.3 Heritage sensitivities

The evaluation of the possible heritage resource finds and their heritage significance linked to mitigation requirements was linked to types of landscape. This enabled the development of a heritage sensitivity map (Figure 4). These landforms do not indicate no-go areas but the possibility of finding heritage significant site that could require mitigation work.

4.3.4 Possible finds

Evaluation of aerial photography has indicated the following area that may be sensitive from a heritage perspective. The analysis of the studies conducted in the area assisted in the development of the following landform type to heritage find matrix in Table 6. Table 6: Landform to heritage matrix LAND FROM TYPE HERITAGE TYPE Crest and foot hill LSA and MSA scatters Crest of small hills Small LSA sites – scatters of stone artefacts, ostrich eggshell, pottery and beads Watering holes Dense LSA sites Dunes Dense LSA sites Outcrops Occupation sites dating to LSA Farmsteads Historical archaeological material

HIA - Lephalale Coal and Power Project (LCPP) Page 24

Figure 3: Structures as present on 1969 topographical map 2327DB

HIA - Lephalale Coal and Power Project (LCPP) Page 25

Figure 4: Landforms and structures identified from the aerial photographic analysis

HIA - Lephalale Coal and Power Project (LCPP) Page 26 4.3.5 Stakeholder Engagement

The current stakeholder engagement process has identified only one grave located on the farm Stellenbosch 203 LQ. This identified grave will be followed up during the field work phase of the HIA.

Data was also received from the Soils specialist indicating man-made structures identified during their fieldwork. All these identified structures were evaluated and where relevant these were included and evaluated in this HIA.

5 FIELDWORK FINDINGS

5.1 Methodology

A survey of the footprint was conducted from 25-27 April 2017. Due to the nature of cultural remains, with the majority of artefacts occurring below surface, an archaeologist and field assistant of PGS conducted a vehicle and foot-survey that covered the study area. The fieldwork was logged with a GPS to provide a background of the areas covered (Figure 5).

Figure 5: Footprint area with fieldwork tracklogs

HIA - Lephalale Coal and Power Project (LCPP) Page 27

The proposed site is characterised by a bushveld landscape with dense tree and bush vegetation. Most of the properties are utilised as game farms.

Figure 6: General bushveld conditions Figure 7: Wooded grass land in the area

HIA - Lephalale Coal and Power Project (LCPP) Page 28 5.2 Findings

During the survey 8 heritage resources were identified during the fieldwork. Table 7: Heritage resources found

2 Site Heritage Lat Lon Infrastructure Description Heritage Rating number Significance

The remains and foundations of three separate structures were identified at this location. They were indicated by the farm manager Mr. Willem Nel, who said that he did not know who stayed here. The remains and foundations are situated approximately 250m south of the main farmstead of the farm Honingshade.

The foundations and remains are that of three separate structures. LCPP 001 23º 31’ 38.7” S 27º 54’ 30.4” E Pit 1 Low GP.C The first structure was a hut which measured approximately 4m in diameter. It was constructed with sundried mudbrick and had a clay- brick foundation. Next to it was a square brick and cement built structure which measured approximately 5m x 5m in size. The third structure was another hut which also measured approximately 4m in diameter. This hut was constructed with bricks and cement.

2 Site in this context refers to a place where a heritage resource is located and not a proclaimed heritage site as contemplated under s27 of the NHRA.

HIA - Lephalale Coal and Power Project (LCPP) Page 29 Table 7: Heritage resources found

2 Site Heritage Lat Lon Infrastructure Description Heritage Rating number Significance

Most of the material of the demolished structures was removed from site and only a little building rubble and some remains of the foundations were left to be identified. These structures most probably formed the basis of a farm labourer compound or settlement and were demolished. Site size: Approximately 20m x 20m.

Figure 8: General view of LCPP 001 Figure 9: Remains of one of the structures at LCPP 001

HIA - Lephalale Coal and Power Project (LCPP) Page 30

Table 8: Heritage resources found

Site Lat Lon Infrastructure Description Significance Heritage Rating number A modern brick and cement built farm house and its associated structures LCPP 002 23º 31’ 30.2” S 27º 54’ 29.5” E Pit 1 were identified at this location. None No grading Site size: Approximately 60m x 60m.

Figure 10: Main house at LCPP 002 Figure 11: Labourers cottage at LCPP 002

HIA - Lephalale Coal and Power Project (LCPP) Page 31

Table 8: Heritage resources found

Site Lat Lon Infrastructure Description Significance Heritage Rating number The remains and foundations of another three separate structures were identified at this location. They were indicated by the farm worker Mr. Johannes Masinya, who also said that he did not know who used to stay here. The remains and foundations are situated approximately 280m south of the main farm stead on Portion 1 of the farm Weltevreden 482 LQ. The structures were placed in close proximity of each other. The structures were demolished and only the foundations and some building rubble remained.

LCPP 003 23º 33’ 11.7” S 27º 56’ 23.2” E None Low GP.C The foundations and remains are those of four separate structures. The first structure was a hut which measured approximately 4m in diameter. It was constructed with bricks and cement and had a clay-brick foundation. Next to it was a rectangular shaped brick and cement built structure which measured approximately 4m x 8m in size. The third and fourth structures were placed right across from each other and they both measured approximately 4m x 4m in size. Rocks were used in the foundations of all the four identified structures as well.

HIA - Lephalale Coal and Power Project (LCPP) Page 32 Table 8: Heritage resources found

Site Lat Lon Infrastructure Description Significance Heritage Rating number Most of the material of the demolished structures was removed from site and only a little building rubble and some remains of the foundations were left to be identified. These structures most probably formed the basis of a farm labourer compound or settlement and were demolished.

Some metal artefacts and glass bottle remains were also identified laying scattered across the site. Site size: Approximately 20m x 20m.

Figure 12: View of LCPP 003 Figure 13: One of the structures at LCPP 003

HIA - Lephalale Coal and Power Project (LCPP) Page 33 Table 8: Heritage resources found

Site Significanc Heritage Lat Lon Infrastructure Description number e Rating The remains and foundations of another two separate structures were identified at this location. They were also indicated by the farm worker Mr. Johannes Masinya, who also said that he did not know who used to stay here. The remains and foundations are situated approximately 300m south of the main farm stead on Portion 1 of the farm Weltevreden 482 LQ. The structures were placed in close proximity of each other. The structures were demolished and only the foundations and some building rubble remained.

LCPP 004 23º 33’ 12.1” S 27º 56’ 21.6” E None The foundations and remains are those of two separate structures. The Low GP.C first structure was a hut which measured approximately 4m in diameter. It was constructed with bricks and cement and had a clay-brick foundation. Next to it was another hut structure which had a brick and cement foundation, but the walls consisted mainly of mudbricks. Rocks were used in the foundations of all the two identified structures as well.

HIA - Lephalale Coal and Power Project (LCPP) Page 34 Table 8: Heritage resources found

Site Significanc Heritage Lat Lon Infrastructure Description number e Rating formed the basis of another farm labourer compound or settlement and were demolished.

Some metal artefacts and glass bottle remains were also identified laying scattered across the site. Site size: Approximately 10m x 20m.

Figure 14: Outline of small rondavel foundation at LCPP 004 Figure 15: Rubbish dump at LCPP 004

HIA - Lephalale Coal and Power Project (LCPP) Page 35

Table 8: Heritage resources found

Site Lat Lon Infrastructure Description Significance Heritage Rating number

This location was indicated by the farm worker Mr. Johannes Masinya. He indicated that it was the yard of a farm worker’s homestead. No physical evidence of any structures or the remains of structures were identified. A few glass and metal artefacts were identified within the LCPP 005 23º 33’ 13.5” S 27º 56’ 28.2” E None indicated area. Mr. Masinya explained that everything was removed and Low GP.C that the open space remained. The open space, described as a yard, measures approximately 25m x 30m in size.

Site size: Approximately 25m x 30m

Figure 16: General view of LCPP 005 Figure 17: Some of the metal artefact on site at LCPP 005

HIA - Lephalale Coal and Power Project (LCPP) Page 36

Table 8: Heritage resources found

Site Lat Lon Infrastructure Description Significance Heritage Rating number Two informal stone packed graves were identified at this location. The graves were pointed out by farm labourer Mr. Barnabas Shongwane. The two graves were placed next to each other and were orientated from west to east. They were situated underneath a cluster of trees and bushes.

Both graves have large oval shaped mounds of packed rocks as grave dressings. Rather large rocks were used to form part of these dressings. LCPP 006 23º 32’ 33.8” S 27º 54’ 46.9” E Discard dump High GP.A It seems as if both dressings were disturbed some while ago as the rocks were laying around a bit haphazardly.

The graves are not maintained and are overgrown with grass, weeds and other vegetation. Neither Mr. Shongwane nor any of the other farm labourers knew who the deceased were or to whom the graves belonged.

Site size: Approximately 10m x 5m.

HIA - Lephalale Coal and Power Project (LCPP) Page 37 Table 8: Heritage resources found

Site Lat Lon Infrastructure Description Significance Heritage Rating number

Figure 18: General view of burial ground at LCPP 006 Figure 19: One of the Stone packed grave

HIA - Lephalale Coal and Power Project (LCPP) Page 38 Table 8: Heritage resources found

Site Lat Lon Infrastructure Description Significance Heritage Rating number The remains and foundations of a structure was identified at this location. They were also indicated by the farm worker Mr. Barnabas Shongwane, who indicated that the house was occupied by white people.

The farm owner, Mr. Neels Alant said that the house most probably originated from the 1940s, but was bulldozed by the previous owners due to its poor condition. Most of the building rubble was removed from site, with only the foundations and a few pieces of rubble found scattered around. LCPP 007 23º 32’ 33.0” S 27º 54’ 47.2” E None None No rating The house was rectangular and measured approximately 15m x 5m in size. It was constructed with bricks and cement and the walls were plastered and painted over. The house had a cement floor as base. An outside oven is situated in a nearby bush, but it is almost completely destroyed by the bush and an anthill that is inside it. No other structures were associated with the house.

Site size: Approximately 25m x 15m.

HIA - Lephalale Coal and Power Project (LCPP) Page 39 Table 8: Heritage resources found

Site Lat Lon Infrastructure Description Significance Heritage Rating number

Figure 20: remains of house at LCPP 007 Figure 21:Remains of foundation at LCPP 007

HIA - Lephalale Coal and Power Project (LCPP) Page 40

Table 8: Heritage resources found

Site Significanc Heritage Lat Lon Infrastructure Description number e Rating A small, informal cemetery was identified at this location. The cemetery was pointed out by farm labourer Mr. Barnabas Shongwane. He also indicated that the graves belonged to Annetjie Tshimule, one of the other farm workers and that she stays nearby.

The cemetery is fenced off and has three graves in it. The graves were placed in a line next to each other and they were all orientated from west to east. Two of the graves have informal oval shaped outlines of LCPP 008 23º 33’ 31.8” S 27º 54’ 24.4” E None High GP.A packed rocks as dressings. Large rocks were placed upright at the western and eastern ends to serve as head and feet stones. The third grave only had one rock placed upright at the western end to serve as headstone.

The cemetery and graves were recently cleared of any unwanted vegetation and is well maintained. Site size: Approximately 10m x 10m.

HIA - Lephalale Coal and Power Project (LCPP) Page 41 Table 8: Heritage resources found

Site Significanc Heritage Lat Lon Infrastructure Description number e Rating

Figure 22: View of the burial ground at LCPP 008

Figure 23: Stone lined grave at LCPP 008

HIA - Lephalale Coal and Power Project (LCPP) Page 42

Figure 24: Distribution of heritage resources in relation to infrastructure

HIA - Lephalale Coal and Power Project (LCPP) Page 43 6 PALAEONTOLOGICAL BACKGROUND

Table 8: Summary of the Geological and Palaeontological History (Banzai Environmental, July 2017)

Palaeontological Group Group/Formation Lithology Period Fossils Sensitivity /Exposures Almond et al (2008) and Groenewald et al., (2014) High to very high Undifferentiat Sandstone, Permian- Very poor Palaeontological ed Karoo conglomeratesha Triassic levels of sensitivity/vulnerabil le, mudstone, surface ity and coal deposits exposure (most data obtained from borehole cores Very High Karoo Clarens Formation Aeolian Triassic Dinosaur Palaeontological sandstones,mino remains and sensitivity/vulnerabil r ephermeral trackways can ity stream deposits be expected. coal Very poor levels of surface exposure (most data obtained from borehole cores) High Karoo Lisbon FM Red mudrocks Triassic Trace fossils Palaeontological with calcareous (“Cruziana , sensitivity/vulnerabil concretions “Skolithos ”, ity. widespread bioturbation, possible fossil

HIA - Lephalale Coal and Power Project (LCPP) Page 44 Palaeontological Group Group/Formation Lithology Period Fossils Sensitivity /Exposures Almond et al (2008) and Groenewald et al., (2014) termitaria, rhizoliths) Large sauropodomor ph dinosaurs (probably “Euskelesaurus ” and / or Massospondyl us ) Sandstones; Early records of dinosaur remains from 1920s No plant material is preserved (Johnson et al., 2006: 489). ( Moderate Karoo Dwyka Diamictite Carbonifero Glossopterid Palaeontological undifferentiat (polymictic us to coal flora; very sensitivity/vulnerabil ed clasts, set in a Permian poor levels of ity poorly sorted, surface fine-grained exposure matrix) with (most data varved shale, obtained from mudstone with borehole cores dropstones and fluvioglacial gravel common in the north Low Waterberg Kransberg Sanstone and Cambruim Earliest known Palaeontological Group, Subgroup conglomerate terrestrial sensitivity/vulnerabil cyanobacterial ity mats recorded from playa lake deposits

HIA - Lephalale Coal and Power Project (LCPP) Page 45 Palaeontological Group Group/Formation Lithology Period Fossils Sensitivity /Exposures Almond et al (2008) and Groenewald et al., (2014) Very Low Bushveld Rustenburg Granite Vaalian No fossils Palaeontological Complex Layered Suite recorded sensitivity/vulnerabil • Lebowa ity grey Granite Suite • Villa Nora Grabbo- Anorthos ite

Very Low ARCHAEAN Palala Granite; Intrusive Early to Late No fossils Palaeontological GRANITE- Limpopo belt granitoids, Archaean recorded sensitivity/vulnerabil GNEISS gneisses, (3.6 –2.4 ity grey BASEMENT migmatites Ga) (Swazian / Randian)

In the Ellisras Basin the Karoo Supergroup is poorly exposed. Most data were thus obtained from borehole data. The Undifferentiated Karoo deposits in this area are known to contain coal seams, but the topography of the area is flat and exposed fossiliferous outcrops lack. The palaeontological sensitivity of the study region is thus rated as moderate to low. But, regardless of the sparse and sporadic occurrence of fossils in this biozone a single fossil can have a huge scientific importance as many fossil taxa are known from a single fossil (Banzai Environmental, July 2017).

HIA - Lephalale Coal and Power Project (LCPP) Page 46

Figure 25: The surface geology of the proposed proposed development of the Lephalale coal and power project, Lephalale, Lmpopo Province, Republic of South Africa. The proposed footprint is underlain by sediments of the Karoo Basin and the proposed project is underlain by the Clarens, Dwyka, Kransberg Subgroup, Waterberg Group, Lebowa Granite, Lisbon, Palala Granite and Villa Nora Grabbo-Anorthosite (Banzai Environmental, July 2017) )

HIA - Lephalale Coal and Power Project (LCPP) Page 47 7 IMPACT ASSESSMENT

The aim of the impact evaluation is to determine the extent of the impact of the proposed project on the identified heritage resources and predict possible impacts on unidentified heritage resources.

During the field work a total of eight heritage related sites were identified. These can be subdivided into burial grounds, and recent historic structures. It must be considered that the heritage significance of the identified site plays a role in the evaluation of the impact and must influence the magnitude rating of the impact tables. Thus a heritage resource with a high heritage significance rating will have a higher impact magnitude rating as a resources with a low or no heritage significance rating. Consequently, mitigation measures will be more extensive for a heritage resource with a high heritage significance than those with a low heritage significance.

Refer to Table 9 for the impact assessment tables as described in the following subsections.

All the impacts are envisaged to happened during construction activities. Where there is an impact during Operations/Mining this is mentioned pertinently in the following section.

7.1 Impact on recent historic structures

A total of six recent historic structures were identified of which two (LCPP 002 and 007) have no heritage significance. The remaining four heritage resources (LCPP 001, 003, 004 and 005) are all rated as having a low heritage significance. This is based on the probability of infant or stil born burials occurring around the structures. Such burials are a part of African customs (and must be considered during vegetation and soil clearing around these sites.

Only LCPP 001 will be directly impacted by mining activities in Pit 1 of the proposed layout. LCPP 003, 004 and 005 are outside any of the proposed impact zones and will not be affected. The impact significance rated as MEDIUM negative before mitigation and with the implementation of the mitigation measures the impact significance is reduced too LOW negative.

7.2 Impact on burial grounds

Two burial ground (LCPP 006 and 008) consisting of 4 graves in total have been identified during the field work. Due to the social and cultural significance of burial grounds and graves a high heritage significance is given to these two sites. Site LCPP 006 is located in an area designated to

HIA - Lephalale Coal and Power Project (LCPP) Page 48 be utilised as a discard dump. LCPP 008 is outside any proposed infrastructure zones and will not be directly impacted on.

The impact of the proposed project on the burial ground at LCPP 006 is rated as having a HIGH negative significance before mitigation and with the implementation of mitigation measures as having a LOW negative significance.

The burial ground at LCPP 008 could be impacted during MINING ACTIVITIES during the operations of the mine, however this is unlikely and a LOW negative impact significance is projected. However, by implementing the recommended mitigation measures this impact can be changes to a MEDIUM positive impact significance.

7.3 Impact on Paleontological Resources

The proposed footprint is underlain by sediments of the Undifferentiated Karoo; Ellisras Sedimentary Basin while the proposed project is underlain by the Clarens and Lisbon Formations and the Dwyka Group of the Karoo Supergroup, the Rustenburg layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt. • The intrusive igneous rocks of the Rustenburg Layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt are completely unfossiliferous. This layers thus has NO significance in terms of local palaeontological heritage. • The Waterberg group is known for the earliest known terrestrial cyanobacterial mats which were recorded from playa lake deposits. This Group has a low Palaeontological sensitivity. • In the Ellisras Basin the Karoo Supergroup is poorly exposed. Most data were thus obtained from borehole data. The Undifferentiated Karoo deposits in this area are known to contain coal seams, but the topography of the area is flat and exposed fossiliferous outcrops lack. The palaeontological sensitivity of the study region is thus rated as moderate to low. But, regardless of the sparse and sporadic occurrence of fossils in this biozone a single fossil can have a huge scientific importance as many fossil taxa are known from a single fossil.

HIA - Lephalale Coal and Power Project (LCPP) Page 49 7.4 Impact assessment table for heritage resources

Table 9: Heritage Impact Table

BEFORE MITIGATION Mitigation AFTER MITIGATION Affected Impact Cumulat Spati measures / Spati Environm Activity Descriptio Magnit Durati Conseque Probabil SIGNIFICA ive Magnit Durati Conseque Probabil SIGNIFICA N al Recommenda al ent n ude on nce ity NCE Impact ude on nce ity NCE o. Scale tions Scale Construct

ion Implement design elements in the discard dump foot print to exclude the burial ground with a 30- Vegetatio metre buffer. Short n Destructio Long Site If this is not Term < Site clearance n of graves Term > Heritage Major - or High Definite High No possible a Minor - 18 or Low Possible Low for at LCPP 5 Local detailed grave month Local infrastruct 006 years relocation s ure process must be implemented as required under the NHRA and National Health Act 1 regulations Monitor during site Vegetatio Destructio clearance for Short n Long n of Site possible infant Term < Site clearance Term > Heritage ruined Minor - or Medium Definite Medium No and still born Minor - 18 or Low Unlikely Low for 5 homestea Local burials and month Local infrastruct years ds implement s ure chance find 2 procedure if

HIA - Lephalale Coal and Power Project (LCPP) Page 50 BEFORE MITIGATION Mitigation AFTER MITIGATION Affected Impact Cumulat Spati measures / Spati Environm Activity Descriptio Magnit Durati Conseque Probabil SIGNIFICA ive Magnit Durati Conseque Probabil SIGNIFICA N al Recommenda al ent n ude on nce ity NCE Impact ude on nce ity NCE o. Scale tions Scale any finds are made.

Monitor site clearing at the site by a Vegetatio Destructio qualified Short n n of infant Long Site archaeologist. Term < Site clearance and Modera Term > Heritage or Medium Possible Medium No Implement Minor - 18 or Low Unlikely Low for stillborn te - 5 Local chance find month Local infrastruct graves at years procedures in s ure LCPP 001 the case of any remains 3 discovered 4 Heritage Mining Damage to Modera Short Site Low Unlikely Low No Demarcate Minor + Long Site Medium+ Possible Medium burial te + Term < or and fence the Term > or grounds at 18 Local cemetery and 5 Local LCPP 008 month monitor years s quarterly during life of mine Recommende d mitigation of the inevitable damage and destruction of fossil heritage within the Fossil Long proposed site Long Heritage Excavatio Destructio Site Site Modera Term > would involve Modera Term > 5 in ns and site n of fossil or Medium Possible Medium Yes or Medium Unlikely Low te - 5 the surveying, te - 5 developm clearance Heritage Local Local years recording, years ent area description and collecting of fossils within the development footprint by a professional

HIA - Lephalale Coal and Power Project (LCPP) Page 51 BEFORE MITIGATION Mitigation AFTER MITIGATION Affected Impact Cumulat Spati measures / Spati Environm Activity Descriptio Magnit Durati Conseque Probabil SIGNIFICA ive Magnit Durati Conseque Probabil SIGNIFICA N al Recommenda al ent n ude on nce ity NCE Impact ude on nce ity NCE o. Scale tions Scale palaeontologi st. This work should take place after the initial vegetation clearance has taken place but before the ground is levelled for construction. However, the significance of the impact following the mitigation will remain low. Operatio

n Demarcate Short and fence the Damage to Long Term < Site cemetery and Site burial Modera Term > Heritage Mining 18 or Medium Unlikely Medium No monitor Minor + or Low Possible Low grounds at te + 5 month Local quarterly Local LCPP 008 years s during life of 5 mine ECO Mediu monitoring m Long Impact on Site during mining Term > Site Term > Heritage Mining palaeontol Minor - or Medium Possible Medium No after training Minor + 18 or Low Possible Low 5 ogy Local by month Local years palaeontologi s < 5 6 st years

HIA - Lephalale Coal and Power Project (LCPP) Page 52 7.5 Management recommendations and guidelines

7.5.1 Construction phase

The project will encompass a range of activities during the construction phase, including ground clearance, establishment of construction camps area and small-scale infrastructure development associated with the project.

It is possible that cultural material will be exposed during construction and may be recoverable, keeping in mind delays can be costly during construction and as such must be minimised. Development surrounding infrastructure and construction of facilities results in significant disturbance, however foundation holes do offer a window into the past and it thus may be possible to rescue some of the data and materials. It is also possible that substantial alterations will be implemented during this phase of the project and these must be catered for. Temporary infrastructure, such as construction camps and laydown areas, is often changed or added to the project as required. In general, these are low impact developments as they are superficial, resulting in little alteration of the land surface, but still need to be catered for.

During the construction phase, it is important to recognize any significant material being unearthed, making the correct judgment on which actions should be taken. It is recommended that the following chance find procedure is implemented.

7.5.2 Chance find procedure

• A heritage practitioner should be appointed to develop a heritage induction program and conduct training for the ECO as well as team leaders in the identification of heritage resources and artefacts. • An appropriately qualified archaeologist must be identified to be called upon in the event that any possible heritage resources or artefacts are identified. • Should an archaeological site or cultural material be discovered during construction (or operation), the area should be demarcated and construction activities halted. • The qualified archaeologist will then need to come out to the site and evaluate the extent and importance of the heritage resources and make the necessary recommendations for mitigating the find and impact on the heritage resource. • The contractor therefore should have some sort of contingency plan so that operations could move elsewhere temporarily while the material and data are recovered.

HIA - Lephalale Coal and Power Project (LCPP) Page 53 • Construction can commence as soon as the site has been cleared and signed off by the archaeologist.

7.6 Possible finds during construction The study area contains numerous old homesteads as identified during the fieldwork. Site LCPP 001 is located in the footprint of Pit 1. Excavations of foundations and soil clearance can uncover the following: • Stone foundations; • Ash middens associated with the farmsteads and homesteads that can contain bone, glass and clay ceramics, ash, metal objects such as spoons, knives, and knives. • Possible infant burials;

7.7 Timeframes It must be kept in mind that mitigation and monitoring of heritage resources discovered during construction activity will require permitting for collection or excavation of heritage resources and lead times must be worked into the construction time frames. Table 10 gives guidelines for lead times on permitting.

Table 10: Lead times for permitting and mobilisation Action RESPONSIBILITY Timeframe

Preparation for field monitoring and The contractor and 1 months finalisation of contracts service provide Application for permits to do necessary Service provider – 1 month mitigation work Archaeologist and SAHRA Documentation, excavation and Service provider – 3 months archaeological report on the relevant site Archaeologist Handling of chance finds – Graves/Human Service provider – 2 weeks Remains Archaeologist and SAHRA Relocation of cemetery or graves in the Service provider – 6 months way of construction Archaeologist, SAHRA, local government and provincial government

HIA - Lephalale Coal and Power Project (LCPP) Page 54 7.8 Heritage Management Plan for EMP implementation

NO. MITIGATION MEASURES PHASE TIMEFRAME RESPONSIBLE MONITORING TARGET PERFORMANCE COST PARTY FOR PARTY INDICATORS IMPLEMENTATIO (FREQUENCY) (MONITORING N TOOL) Possible finds

A Implement chance find procedures in Construction During Applicant ECO (weekly) Ensure compliance ECO Monthly Possibly R50 000 case where possible heritage finds construction ECO with relevant Checklist/Report area made Heritage Specialist legislation and recommendations from SAHRA under Section 36 and 38 of NHRA Known sites

LCPP • Monitor during site clearance Construction During Applicant Applicant Ensure compliance ECO Monthly Less than R10 000 001 for possible infant and still born construction ECO ECO with relevant Checklist/Report burials and implement chance legislation and find procedure if any finds are recommendations made. from SAHRA under Section 36 and 38 of NHRA LCPP • Implement design elements in Construction During Applicant Applicant Ensure compliance ECO Monthly Less than R200 006 the discard dump foot print to construction ECO ECO with relevant Checklist/Report 000 exclude the burial ground with legislation and a 30-metre buffer. If this is not recommendations possible a detailed grave from SAHRA under relocation process must be Section 36 and 38 implemented as required under of NHRA the NHRA and National Health Act regulations.

HIA - Lephalale Coal and Power Project (LCPP) Page 55 NO. MITIGATION MEASURES PHASE TIMEFRAME RESPONSIBLE MONITORING TARGET PERFORMANCE COST PARTY FOR PARTY INDICATORS IMPLEMENTATIO (FREQUENCY) (MONITORING N TOOL) LCPP • Demarcate and fence the Construction Construction Applicant Applicant Ensure compliance ECO Monthly Less than R20 000 008 cemetery and monitor through to Operational ECO ECO with relevant Checklist/Report quarterly during life of mine Operational legislation and recommendations from SAHRA under Section 36 and 38 of NHRA Palaeon • Recommended mitigation of the Construction Construction Applicant Applicant Ensure compliance ECO Monthly Less than R100 tology inevitable damage and through to Operational ECO ECO with relevant Checklist/Report 000 destruction of fossil heritage Operational Palaeontologist legislation and within the proposed site would recommendations involve the surveying, recording, from SAHRA under description and collecting of Section 36 and 38 fossils within the development of NHRA footprint by a professional palaeontologist. This work should take place after the initial vegetation clearance has taken place but before the ground is levelled for construction. However, the significance of the impact following the mitigation will remain low.

HIA - Lephalale Coal and Power Project (LCPP) Page 56 8 CONCLUSIONS PGS Heritage (Pty) Ltd (PGS) was appointed by Kongiwe Environmental (Pty) Ltd (Kongiwe) to undertake an HIA which forms part of the EIA for the proposed Lephalale Coal and Power Project (LCPP) near Lephalale, Lephalale Local Municipality, Waterberg District, Limpopo Province.

The HSR completed as part of the HIA process has shown that the proposed LCPP may have heritage resources present in the study area. This has been confirmed through archival research and evaluation of aerial photography and topographical maps of the sites.

Evaluation of aerial photography has indicated the following area that may be sensitive from a heritage perspective.

The management and mitigation measures as described in Section 7 of this report have been developed to minimise the project impact on heritage resources.

HIA - Lephalale Coal and Power Project (LCPP) Page 57 9 REFERENCES 9.1 Published References

Bergh, J.S. (ed.). 1999. Geskiedenis Atlas van Suid-Afrika: Die Vier Noordelike Provinsies. J.L. van Schaik. Pretoria.

Erasmus, B.J. On Route in South Africa. Jonathan Ball Publishers, Johannesburg.

Fourie, W. 2008. Archaeological Impact Assessments within South African Legislation. South African Archaeological Bulletin 63 (187): 77–85, 2008

Huffman, T.N. 2007. Handbook to the Iron Age: The archaeology of Pre-Colonial Farming Societies in Southern Africa. University of KwaZulu-Natal Press, Scottsville.

Lang, J. 1995. Power Base: Coal Mining in the Life of South Africa. Jonathan Ball Publishers, Johannesburg.

Mitchell, J.H. 1994. Tartan on the Veld: the Transvaal Scottish 1950 – 1993. Transvaal Scottish Regimental Council.

Rand Daily Mail, 19 December 1977. Iscor Mine Start-Up in 1980

Mining Mirror, 2007. Volume 20. Brooke Pattrick Publications.

The Finweek, 30 September 1980. Yskor wys slag by Grootegeluk.

9.2 Unpublished References

Fourie, W. & van der Walt, J. 2006. Heritage Impact Assessment: Paarl Eco Estate Portion 2 of the Farm Paarl 522 LQ, near Ellisras (Lephalale) in the Suburb of Onverwacht, Limpopo Province. An unpublished report by Matakoma.

Gaigher, S. 2007a. Heritage Impact Assessment for the Proposed Ellisras Extension 67 Housing Project on the Farm Waterkloof 502 LQ, Limpopo. An unpublished report by Archaeo-Info.

HIA - Lephalale Coal and Power Project (LCPP) Page 58 Gaigher, S. 2007b. Heritage Impact Assessment for the Proposed Ellisras Extension 66 Housing Project on the Farm Waterkloof 502 LQ, Limpopo Province. An unpublished report by Archaeo- Info.

Higget, N. 2012. Phase 1 Archaeological Impact Assessment for the MBET Pipeline. An unpublished report by Digby Wells Environmental.

Higget, N. & S. Karodia. 2013. Heritage Impact Assessment for the Proposed Thabametsi Project, Lephalale, Limpopo Province. An unpublished report by Digby Wells Environmental.

Huffman, T.N. & J. van der Walt. 2013. Sasol Limpopo West Heritage Report. An unpublished report by the University of the Witwatersrand.

Roodt, F. 2001. Archaeological Impact Assessment: Proposed Heavy Industrial Area on Portion 5 of the farm Grootestryd 465 LQ, Ellisras. An unpublished report by R & R Cultural Resource Consultants.

Van der Walt, J. 2006. Heritage Impact Assessment: Township establishment on the Remainder of Portion 8 of the farm Onverwacht 503 LQ, near Ellisras (Lephalale), Limpopo Province. An unpublished report by Matakoma.

Van der Walt, J. 2012. Archaeological Scoping Report for the proposed Sekoko Waterberg Colliery, Lephalale, Limpopo Province. An unpublished report by Heritage Contracts and Archaeological Consulting.

Van der Walt, J. 2014. Archaeological Impact Assessment for the proposed Thabametsi Coal-Fired Power Station, Lephalale, Limpopo Province. An unpublished report by Heritage Contracts and Archaeological Consulting.

Van Schalkwyk, J.A. 2005a. Heritage Impact Scoping Report for the Proposed New Matimba B Power Station. Lephalale District, Limpopo Province. An unpublished report by the National Cultural History Museum.

HIA - Lephalale Coal and Power Project (LCPP) Page 59 Van Schalkwyk, J.A. 2005b. Heritage Survey Report of the Kumba Properties at Grootegeluk Mine, Lephalale Area, Limpopo Province. An unpublished report compiled by the National Cultural History Museum.

Van Schalkwyk, J.A. 2006. Environmental Scoping Report for the Proposed Establishment of a New Coal-Fired Power Station in the Lephalale Area, Limpopo Province. An unpublished report by the National Cultural History Museum on file at SAHRA as 2006-SAHRA-0096.

Van Schalkwyk, J.A. 2011. Heritage Impact Assessment Report for the Proposed Establishment of the Exxaro PV Plant on the farm Nelsonskop, North-West of Lephalale, Limpopo Province. An unpublished report compiled by Dr. J.A. van Schalkwyk.

Van Vollenhoven, A.C. 2008a. A Report on a Cultural Heritage Impact Assessment for the Proposed Housing Development at Erf 1522 Ellisras on the Farm Onverwacht 503 LQ, Lephalale, Limpopo Province. An unpublished report by Archaetnos.

Van Vollenhoven, A.C. 2008b. A Report on a Cultural Heritage Impact Assessment for the Proposed Housing Development at Extension 88 and 90 Ellisras on the Farm Onverwacht 503 LQ, Lephalale, Limpopo Province. An unpublished report by Archaetnos.

Van Vollenhoven, A.C. 2008c. A Report on a Cultural Heritage Impact Assessment for the Proposed Housing Development at Extension 89 Ellisras on the Farm Onverwacht 503 LQ, Lephalale, Limpopo Province. An unpublished report by Archaetnos Archival References

National Archives, MNW, 535, MM1713/20

National Archives, Maps, 2/207

9.3 Historic Topographic Maps

The historic topographic maps used in this report were obtained from the Directorate: National Geo-spatial Information of the Department of Rural Development & Land Reform, Cape Town.

9.4 Google Earth

All the aerial depictions used in this report are from Google Earth.

HIA - Lephalale Coal and Power Project (LCPP) Page 60

HIA - Lephalale Coal and Power Project (LCPP) Page 61 Appendix A LEGISLATIVE REQUIREMENTS – TERMINOLOGY AND ASSESSMENT CRITERIA

General principles

In areas where there has not yet been a systematic survey to identify conservation worthy places, a permit is required to alter or demolish any structure older than 60 years. This will apply until a survey has been done and identified heritage resources are formally protected.

Archaeological and palaeontological sites, materials, and meteorites are the source of our understanding of the evolution of the earth, life on earth and the history of people. In terms of the heritage legislation, permits are required to damage, destroy, alter, or disturb them. Furthermore, individuals who already possess heritage material are required to register it. The management of heritage resources is integrated with environmental resources and this means that, before development takes place, heritage resources are assessed and, if necessary, rescued.

In addition to the formal protection of culturally significant graves, all graves which are older than 60 years and are not located in a cemetery (such as ancestral graves in rural areas), are protected. The legislation also protects the interests of communities that have an interest in the graves: they should be consulted before any disturbance takes place. The graves of victims of conflict and those associated with the liberation struggle are to be identified, cared for, protected and memorials erected in their honour.

Anyone who intends to undertake a development must notify the heritage resources authority and, if there is reason to believe that heritage resources will be affected, an impact assessment report must be compiled at the construction company’s cost. Thus, the construction company will be able to proceed without uncertainty about whether work will have to be stopped if an archaeological or heritage resource is discovered.

According to the National Heritage Act (Act 25 of 1999 section 32) it is stated that: An object or collection of objects, or a type of object or a list of objects, whether specific or generic, that is part of the national estate and the export of which SAHRA deems it necessary to control, may be declared a heritage object, including –

HIA - Lephalale Coal and Power Project (LCPP) Page 62 • objects recovered from the soil or waters of South Africa, including archaeological and palaeontological objects, meteorites and rare geological specimens;

• visual art objects;

• military objects;

• numismatic objects;

• objects of cultural and historical significance;

• objects to which oral traditions are attached and which are associated with living heritage;

• objects of scientific or technological interest;

• books, records, documents, photographic positives and negatives, graphic material, film or video or sound recordings, excluding those that are public records as defined in section 1 (xiv) of the National Archives of South Africa Act, 1996 ( Act No. 43 of 1996), or in a provincial law pertaining to records or archives; and

• any other prescribed category.

Under the National Heritage Resources Act (Act No. 25 of 1999), provisions are made that deal with, and offer protection to, all historic and prehistoric cultural remains, including graves and human remains.

Graves and cemeteries

Graves younger than 60 years fall under Section 2(1) of the Removal of Graves and Dead Bodies Ordinance (Ordinance no. 7 of 1925) as well as the Human Tissues Act (Act 65 of 1983) and are under the jurisdiction of the National Department of Health and the relevant Provincial Department of Health and must be submitted for final approval to the Office of the relevant Provincial Premier. This function is usually delegated to the Provincial MEC for Local Government and Planning, or in some cases the MEC for Housing and Welfare. Authorisation for exhumation and re-internment must also be obtained from the relevant local or regional council where the grave is situated, as well as the relevant local or regional council to where the grave is being relocated. All local and regional provisions, laws and by-laws must also be adhered to. To handle and transport human remains, the institution conducting the relocation should be authorised under Section 24 of Act 65 of 1983 (Human Tissues Act).

HIA - Lephalale Coal and Power Project (LCPP) Page 63

Graves older than 60 years, but younger than 100 years, fall under Section 36 of Act 25 of 1999 (National Heritage Resources Act) as well as the Human Tissues Act (Act 65 of 1983) and are under the jurisdiction of the South African Heritage Resources Agency (SAHRA). The procedure for Consultation regarding Burial Grounds and Graves (Section 36(5) of Act 25 of 1999) is applicable to graves older than 60 years that are situated outside a formal cemetery administrated by a local authority. Graves in the category located inside a formal cemetery administrated by a local authority will also require the same authorisation as set out for graves younger than 60 years, over and above SAHRA authorisation.

If the grave is not situated inside a formal cemetery but is to be relocated to one, permission from the local authority is required and all regulations, laws and by-laws set by the cemetery authority must be adhered to.

HIA - Lephalale Coal and Power Project (LCPP) Page 64

PALAEONTOLOGICAL DESKTOP ASSESSMENT OF THE PROPOSED DEVELOPMENT OF THE LEPHALALE COAL AND POWER PROJECT, LEPHALALE, LIMPOPO PROVINCE, REPUBLIC OF SOUTH AFRICA

Prepared for:

PGS HERITAGE (PTY) LTD

DATE: 1 Julyl 2017

BANZAI ENVIRONMENTAL (PTY) LTD P.O. BOX 11023 UNIVERSITAS BLOEMFONTEIN 9323

EXECUTIVE SUMMARY

Banzai Environmental Pty (Ltd) was appointed by PGS Heritage to undertake a Palaeontological desktop assessment assessing the potential palaeontological impact of the planned new coal mine and energy project in the Waterberg Coalfield, Lephalale area of Limpopo Province, Republic of South Africa. This report forms part of the Environmental Impact Assessment in support of the Mining Right Application (MRA) and other Environmental Assessment’s required for the proposed mine and Independent Power Plant and complies with the requirements of the South African National Heritage Resource Act No 25 of 1999. According to the latter Act, a palaeontological impact assessment is required to detect the presence of fossil material within the proposed development footprint and to assess the impact of the construction and operation of the project on the palaeontological resources.

The proposed footprint is underlain by sediments of the Undifferentiated Karoo; Ellisras Sedimentary Basin while the proposed project is underlain by the Clarens and Lisbon Formations and the Dwyka Group of the Karoo Supergroup, the Rustenburg layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt • The intrusive igneous rocks of the Rustenburg Layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt are completely unfossiliferous. This layers thus has NO significance in terms of local palaeontological heritage. • The Waterberg group is known for the earliest known terrestrial cyanobacterial mats which were recorded from playa lake deposits. This Group has a low Palaeontological sensitivity. • In the Ellisras Basin the Karoo Supergroup is poorly exposed. Most data were thus obtained from borehole data. The Undifferentiated Karoo deposits in this area are known to contain coal seams, but the topography of the area is flat and exposed fossiliferous outcrops lack. The palaeontological sensitivity of the study region is thus rated as moderate to low. But, regardless of the sparse and sporadic occurrence of fossils in this biozone a single fossil can have a huge scientific importance as many fossil taxa are known from a single fossil.

It is therefore considered that the construction and operation of the proposed development is deemed appropriate and feasible and will not lead to detrimental impacts on the palaeontological resources of the area. Thus, the construction and operation of the mine and associated infrastructure may be authorised as the whole extent of the development footprint is not considered sensitive in terms of palaeontological resources.

Should fossil remains be discovered during any phase of construction, either on the surface or exposed by fresh excavations, the ECO responsible for these developments should be alerted

2 immediately. Such discoveries ought to be protected (preferably in situ) and the ECO should alert SAHRA (South African Heritage Research Agency) so that appropriate mitigation (e.g. recording, sampling or collection) can be taken by a professional palaeontologist.

The specialist involved would require a collection permit from SAHRA. Fossil material must be curated in an approved collection (e.g. museum or university collection) and all fieldwork and reports should meet the minimum standards for palaeontological impact studies developed by SAHRA.

CONTENTS

1 INTRODUCTION ...... 5

2 SCOPE ...... 9

2.1 ASSUMPTIONS AND LIMITATIONS ...... 10 2.2 LEGISLATION ...... 10 3 GEOGRAPHICAL LOCATION OF THE SITE ...... 12

4 GEOLOGICAL AND PALAEONTOLOGICAL HISTORY ...... 12

5 IMPACT ASSESSMENT ...... 17

6 Methodology used in determining the significance of environmental impacts ...... 18

7 FINDINGS AND RECOMMENDATIONS...... 22

A) REFERENCES ...... 23

B) QUALIFICATIONS AND EXPERIENCE OF THE AUTHOR ...... 24

C) DECLARATION OF INDEPENDENCE ...... 24

1 INTRODUCTION Dedicoal (Pty) Ltd proposes the development of a new coal mine and energy project in the Waterberg Coalfield in the Lephalale area of Limpopo Province, Republic of South Africa. The project, is known as the Lephalale Coal and Power Project (LCPP or the Project) and will consist of an open pit coal mine and, in time, an Independent Power Plant (IPP). Several other mining and exploration projects is present in the Waterberg Coalfield near the LCPP.

The project consists of 12 farms. Lephalale Coal (Pty) Limited, a subsidiary of Dedicoal, has secured the prospecting rights for the associated farms. Prospecting right LP 30/5/1/1/2/1359PR: the farms Honingshade 427 LQ, Garibaldi 480 LQ, Pretoria 483 LQ, Wellington 432 LQ, Forfarshire 419 LQ, Stutgard 420 LQ, Billiards 428 LQ, Franschoek 207 LQ, and Grootgenoeg 426 LQ. Prospecting right LP 30/5/1/1/2/1046PR: the farms Grootgenoeg 426 LQ, Weltevreden 482 LQ, Sebright 205 LQ, and Botmansdrift 423 LQ.

Project Information

The proposed mine will be an open pit operation, mined using the truck and shovel method. It is predicted that the mine will produce approximately 6 million tonnes of coal per annum and most of the coal will be used to supply the onsite IPP. The Life of Mine of more than 35 years. The mine will operate in three eight hour shifts, seven days a week, 52 weeks year and 24 hours a day. Trucks will take the coal from the mine pit to a single stage washing plant and from there by conveyor to the IPP. At full production, the mine is expected to employ approximately 400 people, with most of the labour coming from the Lephalale Local Municipality and the surrounding areas. All employment will take place in line with all the relevant legislation, codes and statutes. The proposed IPP will be a fluidised bed power station producing 600 Megawatts of peak power. Power generated in the IPP will hopefully be sold onto the Eskom grid.

The infrastructure will include: • offices, workshops, change house, storehouses, warehouses, • internal roads and haul roads, fuel storage facilities, • open pit, crushing circuit, wash plant, conveyors, • water supply network, storm water network, pollution control dams, raw water dam, effluent dam, water treatment works, • topsoil stockpiles, discard dump, Run of Mine stockpiles, ash dump, and • power station.

Water for the project is expected to come from groundwater from the pit, rainwater, sewage effluent and potable water will come from MCWAP Phase 2 project. The water usage strategy for the LCPP is designed to operate as a closed water system and most of the water on site will be recycled.

Electricity for the project is to be supplied by Eskom. Investigations have indicated that the Eskom grid in the area will not have capacity to service the LCPP until the new Medupi power station is online in 2020.

Regulations and licences

Kongiwe Environmental (Pty) Ltd has been appointed by Dedicoal to undertake the Environmental Impact Assessment (EIA) process in support of the Mining Right Application (MRA) and other EA’s required for the proposed mine and IPP. The following applications will be made to the Department of Mineral Resources (DMR) as competent authority for the proposed project:

• Mining Right Application (MRA) in terms of the Minerals and Petroleum Resource Development Act, 2002 (Act No. 28 of 2002) (MPRDA); • Application for EA for listed activities triggered in Listing Notices GN R983, 984 and 985 and in accordance with the Environmental Impact Assessment (EIA) Regulations, 2014, promulgated in terms of National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA); and • Application for listed waste activities in terms of GN R. 921 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008), as amended (NEMA).

In addition, the following applications will be made to the relevant competent authorities: • Application for an Atmospheric Emission License (AEL), in terms of the National Environmental Management: Air Quality Act, 2004, (Act 39 2004) (NEM: AQA) the Lephalale Local Municipality (LLM) is the competent authority; • Integrated Water Use Licence (IWUL) in terms of the National Water Act, 1998 (Act 36 of 1998), as amended (NWA). The Department of Water and Sanitation (DWS) is the competent authority; and • Relevant permit applications will also be made in terms of sections 34,35 and 36 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). The South African Heritage Resources Agency (SAHRA) and or the Limpopo Heritage Resources Authority (LIHRA) will be the competent authorities.

These applications require a Scoping and Environmental Impact Assessment as per regulations 21 and regulation 24 of the Environmental Impact Assessment (EIA) Regulations, 2014, of the NEMA. Possible mitigation measures to lessen the possible negative impacts identified will be developed and enhancements for positive impacts will be proposed. An Environmental Management Programme (EMPr) will also be developed to manage identified impacts. The EMPr Report will be available for public review together with the Environmental Impact Assessment Report (EIAR).

Figure 1. Locality map of proposed development of the Lephalale coal and power project, Lephalale, Limpopo Province, Republic of South Africa.

2 SCOPE According to the South African Heritage Resources Agency (SAHRA) Archaeology, Palaeontology and Meteorites (APM) Guidelines: Minimum Standards for the Archaeological and Palaeontological Components of Impact Assessment Reports, the aims of the palaeontological impact assessment are: • To identify exposed and subsurface rock formations that are considered to be palaeontologically significant; • To assess the level of palaeontological significance of these formations; • To comment on the impact of the development on these exposed and/or potential fossil resources; and • To make recommendations as to how the developer should conserve or mitigate damage to these resources.

The objective is therefore to conduct a Palaeontological Impact Assessment, which forms of part of the Heritage Impact Assessment (HIA) and the EIA Report, to determine the impact of the development on potential palaeontological material at the site.

When a palaeontological desktop/scoping study is conducted, the potentially fossiliferous rocks (i.e. groups, formations, members, etc.) represented within the study area are determined from geological maps. The known fossil heritage within each rock unit is collected from published scientific literature; fossil sensitivity maps; consultations with professional colleagues, previous palaeontological impact studies in the same region and the databases of various institutions may be consulted. This data is then used to assess the palaeontological sensitivity of each rock unit of the study area on a desktop level. The likely impact of the proposed development on local fossil heritage is subsequently established on the basis of the palaeontological sensitivity of the rocks and the nature and scale of the development itself (extent of new bedrock excavated).

If rocks of moderate to high palaeontological sensitivity are present within the study area, a Phase 1 field-based assessment by a professional palaeontologist is necessary. Generally, damaging impacts on palaeontological heritage occur during the construction phase. These excavations will modify the existing topography and may disturb, damage, destroy or permanently seal-in fossils at or below the ground surface that are then no longer available for scientific study.

When specialist palaeontological mitigation is suggested, it may take place prior to construction or, even more successfully, during the construction phase when new, potentially fossiliferous bedrock is

7 still exposed and available for study. Mitigation usually involves the careful sampling, collection and recording of fossils, as well as relevant data concerning the surrounding sedimentary matrix. Excavation of the fossil heritage will require a permit from SAHRA and the material must be housed in a permitted institution. With appropriate mitigation, many developments involving bedrock excavation will have a positive impact on our understanding of local palaeontological heritage.

2.1 ASSUMPTIONS AND LIMITATIONS The accuracy and reliability of desktop Palaeontological Impact Assessments as components of heritage impact assessments are normally limited by the following restrictions: • Old fossil databases that have not been kept up-to-date or are not computerised. These databases do not always include relevant locality or geological information. South Africa has a limited number of professional palaeontologists that carry out fieldwork and most development study areas have never been surveyed by a palaeontologist. • The accuracy of geological maps where information may be based solely on aerial photographs and small areas of significant geology have been ignored. The sheet explanations for geological maps are inadequate and little to no attention is paid to palaeontological material. • Impact studies and other reports (e.g. of commercial mining companies) - is not readily available for desktop studies.

Large areas of South Africa have not been studied palaeontologically. Fossil data collected from different areas but in similar Assemblage Zones might however provide insight on the possible occurrence of fossils in an unexplored area. Desktop studies therefore usually assume the presence of unexposed fossil heritage within study areas of similar geological formations. Where considerable exposures of bedrocks or potentially fossiliferous superficial sediments are present in the study area, the reliability of a Palaeontological Impact Assessment may be significantly improved through field- survey by a professional palaeontologist.

2.2 LEGISLATION Cultural Heritage in South Africa is governed by the National Heritage Resources Act (Act 25 of 1999). This Palaeontological Environmental Impact Assessment forms part of the Heritage Impact Assessment (HIA) and complies with the requirements of the above mentioned Act. In accordance with Section 38, an HIA is required to assess any potential impacts to palaeontological heritage within the site.

SECTION 35 OF THE NATIONAL HERITAGE RESOURCES ACT 25 OF 1999

In Section 3 of The National Heritage Resources Act, various categories of heritage resources are recognized as part of the National Estate. This include among others: • geological sites of scientific or cultural importance • palaeontological sites • palaeontological objects and material, meteorites and rare geological specimens

• The protection of archaeological and palaeontological sites and material and meteorites is the responsibility of a provincial heritage resources authority. • All archaeological objects, palaeontological material and meteorites are the property of the State. • Any person who discovers archaeological or palaeontological objects or material or a meteorite in the course of development or agricultural activity must immediately report the find to the responsible heritage resources authority, or to the nearest local authority offices or museum, which must immediately notify such heritage resources authority. • No person may, without a permit issued by the responsible heritage resources authority— o Destroy, damage, excavate, alter, deface or otherwise disturb any archaeological or palaeontological site or any meteorite; o Destroy, damage, excavate, remove from its original position, collect or own any archaeological or palaeontological material or object or any meteorite; o Trade in, sell for private gain, export or attempt to export from the Republic any category of archaeological or palaeontological material or object, or any meteorite; or o Bring onto or use at an archaeological or palaeontological site any excavation equipment or any equipment which assist in the detection or recovery of metals or archaeological and palaeontological material or objects, or use such equipment for the recovery of meteorites. • When the responsible heritage resources authority has reasonable cause to believe that any activity or development which will destroy, damage or alter any archaeological or palaeontological site is under way, and where no application for a permit has been submitted and no heritage resources management procedure in terms of section 38 has been followed, it may— o Serve on the owner or occupier of the site or on the person undertaking such development an order for the development to cease immediately for such period as is specified in the order; and/or

o Carry out an investigation for the purpose of obtaining information on whether or not an archaeological or palaeontological site exists and whether mitigation is necessary.

3 GEOGRAPHICAL LOCATION OF THE SITE The project is located within the Lephalale Local Municipality in the Waterberg District Municipality of Limpopo Province, South Africa. The LCPP lies approximately 6 km north of the R518 provincial road linking the town of Lephalale and the village of Marken (Fig.1).

4 GEOLOGICAL AND PALAEONTOLOGICAL HISTORY The proposed footprint is underlain by sediments of the Undifferentiated Karoo; Ellisras Sedimentary Basin while the proposed project is underlain by the Clarens and Lisbon Formation and the Dwyka Group, of the Karoo Supergroup, the Rustenburg layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt (Fig.2).

Table 1: Summary of the Geological and Palaeontological History. Palaeontological Group Group/Format Lithology Period Fossils Sensitivity ion /Exposures Almond et al (2008) and Groenewald et al., (2014) High to very high Undifferentiate Sandstone, Permian- Very poor Palaeontological d Karoo conglomer Triassic levels of sensitivity/vulnera ateshale, surface bility mudstone, exposure and coal (most data deposits obtained from borehole cores Very High Karoo Clarens Aeolian Triassic Dinosaur Palaeontological Formation sandstones remains and sensitivity/vulnera ,minor trackways bility ephermeral can be

stream expected. deposits Very poor coal levels of surface exposure (most data obtained from borehole cores) High Karoo Lisbon FM Red Triassic Trace fossils Palaeontological mudrocks (“Cruziana , sensitivity/vulnera with “Skolithos ”, bility. calcareous widespread concretions bioturbation, possible fossil termitaria, rhizoliths) Large sauropodom orph dinosaurs (probably “Euskelesaur us ” and / or Massospondy lus ) Sandstones; Early records of dinosaur remains from 1920s No plant material is preserved

(Johnson et al., 2006: 489). ( Moderate Karoo Dwyka Diamictite Carbonifer Glossopterid Palaeontological undifferentiate (polymictic ous to coal flora; sensitivity/vulnera d clasts, set in Permian very poor bility a poorly levels of sorted, surface fine- exposure grained (most data matrix) obtained with varved from shale, borehole mudstone cores with dropstones and fluvioglacial gravel common in the north Low Waterberg Kransberg Sanstone Cambruim Earliest Palaeontological Group, Subgroup and known sensitivity/vulnera conglomer terrestrial bility ate cyanobacteri al mats recorded from playa lake deposits Very Low Bushveld Rustenburg Granite Vaalian No fossils Palaeontological Complex Layered Suite recorded sensitivity/vulnera • Lebow bility grey a

Granit e Suite • Villa Nora Grabb o- Anorth osite

Very Low ARCHAEAN Palala Granite; Intrusive Early to No fossils Palaeontological GRANITE- Limpopo belt granitoids, Late recorded sensitivity/vulnera GNEISS gneisses, Archaean bility grey BASEMENT migmatites (3.6 –2.4 Ga) (Swazian / Randian)

• The intrusive igneous rocks of the Rustenburg Layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt are completely unfossiliferous. This layers thus has NO significance in terms of local palaeontological heritage. • The Waterberg group is known for the earliest known terrestrial cyanobacterial mats which were recorded from playa lake deposits. This Group has a low Palaeontological sensitivity. • In the Ellisras Basin the Karoo Supergroup is poorly exposed. Most data were thus obtained from borehole data. The Undifferentiated Karoo deposits in this area are known to contain coal seams, but the topography of the area is flat and exposed fossiliferous outcrops lack. The palaeontological sensitivity of the study region is thus rated as moderate to low. But, regardless of the sparse and sporadic occurrence of fossils in this biozone a single fossil can have a huge scientific importance as many fossil taxa are known from a single fossil.

Figure 2: The surface geology of the proposed proposed development of the Lephalale coal and power project, Lephalale, Lmpopo Province, Republic of South Africa. The proposed footprint is underlain by sediments of the Karoo Basin and the proposed project is underlain by the Clarens, 11 Dwyka, Kransberg Subgroup, Waterberg Group, Lebowa Granite, Lisbon, Palala Granite and Villa Nora Grabbo-Anorthosite.

5 IMPACT ASSESSMENT The proposed footprint is underlain by sediments of the Undifferentiated Karoo; Ellisras Sedimentary Basin while the proposed project is underlain by the Clarens and Lisbon Formations and the Dwyka Group of the Karoo Supergroup, the Rustenburg layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt. • The intrusive igneous rocks of the Rustenburg Layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt are completely unfossiliferous. This layers thus has NO significance in terms of local palaeontological heritage. • The Waterberg group is known for the earliest known terrestrial cyanobacterial mats which were recorded from playa lake deposits. This Group has a low Palaeontological sensitivity. • In the Ellisras Basin the Karoo Supergroup is poorly exposed. Most data were thus obtained from borehole data. The Undifferentiated Karoo deposits in this area are known to contain coal seams, but the topography of the area is flat and exposed fossiliferous outcrops lack. The palaeontological sensitivity of the study region is thus rated as moderate to low. But, rregardless of the sparse and sporadic occurrence of fossils in this biozone a single fossil can have a huge scientific importance as many fossil taxa are known from a single fossil.

6 Methodology used in determining the significance of environmental impacts The impact significance rating process serves two purposes: firstly, it helps to highlight the critical impacts requiring consideration in the management and approval process; secondly, it shows the primary impact characteristics, as defined above, used to evaluate impact significance.

The impact significance rating system is presented in Table 2 and involves three parts:

Part A: Define impact consequence using the three primary impact characteristics of magnitude, spatial scale/ population and duration;

Part B: Use the matrix to determine a rating for impact consequence based on the definitions identified in Part A; and

Part C: Use the matrix to determine the impact significance rating, which is a function of the impact consequence rating (from Part B) and the probability of occurrence.

Table 2: Significance Rating Methodology

PART A: DEFINING CONSEQUENCE IN TERMS OF MAGNITUDE, DURATION AND SPATIAL SCALE Use these definitions to define the consequence in Part B Impact Definition Criteria characteristics

Moderate/measurable deterioration or harm to receptors; receiving environment moderately Moderate - sensitive; or identified threshold occasionally MAGNITUDE exceeded

Minor deterioration (nuisance or minor deterioration) or harm to receptors; change to Minor - receiving environment not measurable; or identified threshold never exceeded

Minor + Minor improvement; change not measurable; or

threshold never exceeded

Moderate improvement; within or better than the Moderate + threshold; or no observed reaction

Substantial improvement; within or better than the Major + threshold; or favourable publicity

Site specific or confined to the immediate project Site or local area

SPATIAL SCALE OR May be defined in various ways, e.g. cadastral, Regional POPULATION catchment, topographic

National/ Nationally or beyond International Up to 18 months. Short term

Medium term 18 months to 5 years DURATION

Long term Longer than 5 years

PART B: DETERMINING CONSEQUENCE RATING

Rate consequence based on definition of magnitude, spatial extent and duration

SPATIAL SCALE/ POPULATION

National/

Site or Local Regional internation al

MAGNITUDE Long term Medium Medium High

Medium term Low Low Medium Minor DURATION

Short term Low Low Medium

Moderate Long term Medium High High DURATION

Medium term Medium Medium High

Short term Low Medium Medium

Long term High High High

Major DURATION Medium term Medium Medium High

Short term Medium Medium High

PART C: DETERMINING SIGNIFICANCE RATING

Rate significance based on consequence and probability

CONSEQUENCE

Low Medium High

Definite Medium Medium High

PROBABILITY (of exposure to Possible Low Medium High impacts)

Unlikely Low Low Medium

Summary of Tables Nature of Impact • offices, workshops, change house, storehouses, warehouses, • internal roads and haul roads, fuel storage facilities, • open pit, crushing circuit, wash plant, conveyors, • water supply network, storm water network, pollution control dams, raw water dam, effluent dam, water treatment works, • topsoil stockpiles, discard dump, Run of Mine stockpiles, ash dump, and • power station.

Spatial Scale The impact on fossil materials and thus palaeontological heritage will be limited to the construction phase when new excavations into fresh potentially fossiliferous bedrock take place. The extent of the area of potential impact is thus restricted to the project site and therefore categorised as local.

Duration of impact The expected duration of the impact is assessed as potentially permanent to long term. In the absence of mitigation procedures (should fossil material be present within the affected area) the damage or destruction of any palaeontological materials will be permanent

7 FINDINGS AND RECOMMENDATIONS The proposed footprint is underlain by sediments of the Undifferentiated Karoo; Ellisras Sedimentary Basin while the proposed project is underlain by the Clarens and Lisbon Formations and the Dwyka Group of the Karoo Supergroup, the Rustenburg layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt • The intrusive igneous rocks of the Rustenburg Layered Suite of the Bushveld Complex, and the Palala Granite of the Limpopo belt are completely unfossiliferous. This layers thus has NO significance in terms of local palaeontological heritage. • The Waterberg group is known for the earliest known terrestrial cyanobacterial mats which were recorded from playa lake deposits. This Group has a low Palaeontological sensitivity. • In the Ellisras Basin the Karoo Supergroup is poorly exposed. Most data were thus obtained from borehole data. The Undifferentiated Karoo deposits in this area are known to contain coal seams, but the topography of the area is flat and exposed fossiliferous outcrops lack. The palaeontological sensitivity of the study region is thus rated as moderate to low. But, rregardless of the sparse and sporadic occurrence of fossils in this biozone a single fossil can have a huge scientific importance as many fossil taxa are known from a single fossil.

Should fossil remains be discovered during any phase of construction, either on the surface or exposed by fresh excavations, the ECO responsible for these developments should be alerted immediately. Such discoveries ought to be protected (preferably in situ) and the ECO should alert SAHRA (South African Heritage Research Agency) so that appropriate mitigation (e.g. recording, sampling or collection) can be taken by a professional palaeontologist.

A) REFERENCES ALMOND, J., PETHER, J, and GROENEWALD, G. 2013. South African National Fossil Sensitivity Map. SAHRA and Council for Geosciences. Schweitzer et al. (1995) pp p288.

ANDERSON, J.M., ANDERSON, H.M., 1985. Palaeoflora of Southern Africa: Prodromus of South African megafloras, Devonian to Lower Cretaceous. A.A. Balkema, Rotterdam. 423 pp.

BARKER, O.B., BRANDL, G., CALLAGHAN, C.C., ERIKSSON., VAN DER NEUT, M., 2006. The Soutpansberg and Waterberg Groups and the Blouberg Formation. In: Johnson, M.R., Anhaeusser, C.R. and Thomas, R.J., (Eds). The Geology of South Africa. Geological Society of South Africa, Johannesburg / Council for Geoscience, Pretoria. Pp301-318.

CAWTHORN, R.G., EALES, H.V., WALRAVEN, F., UKEN, R. & WATKEYS, M.K. 2006. The Bushveld Complex. In: Johnson. M.R., Anhaeusser, C.R. & Thomas, R.J. (eds.) The geology of South Africa, pp. 261-281. Geological Society of South Africa, Johannesburg & the Council for Geoscience, Pretoria.

Cowan, R., 1995. History of Life. 2nd Edition. Blackwell scientific Publications, Boston. 462pp.

EALES, H.V. 2001. A first introduction to the geology of the Bushveld Complex and those aspects of South African geology that relate to it, 84 pp. Council for Geoscience, Pretoria. ERIKSSON, P.G., SCHWEITZER, J.K., BOSCH, P.J.A., SCHREIBER, U.M., VAN DEVENTER, J.L. & HATTON, C.J. 1993. The Transvaal Sequence: an overview. Journal of African Earth Sciences (and the Middle East) 16, 25-51.

ERIKSSON, P.G., HATTINGH, P.J. & ALTERMANN, W. 1995. An overview of the geology of the Transvaal Sequence and Bushveld Complex, South Africa. Mineralium Deposita 30, 98-111. ERIKSSON, P.G., ALTERMANN, W. & HARTZER, F.J. 2006. The Transvaal Supergroup and its precursors. In: Johnson, M.R., Anhaeusser, C.R. & Thomas, R.J. (Eds.) The geology of South Africa, pp. 237-260. Geological Society of South Africa, Marshalltown.

Johnson, M.R., van Vuuren, C.J., Visser, J.N.J., Cole, D.I., Wickens, H.deV., Christie, A.D.M., Roberts, D.L., Brandl, G., 2006. Sedimentary rocks of the Karoo Supergroup. In: Johnson, M.R., Anhaeusser, C.R. and Thomas, R.J., (Eds). The Geology of South Africa. Geological Society of South Africa, Johannesburg / Council for Geoscience, Pretoria. Pp 461 – 499. . MCCARTHY, T & RUBIDGE, B. 2005. The Story of Earth Life: A southern African perspective on a 4.6- billion-year journey. Struik. Pp 333

MacRae, C.S. 1988. Palynostratigraphic correlation between the Lower Karoo sequence of the Waterberg and Pafuri coal-bearing basins and the Hammanskraal plant macrofossil locality, Republic of South Africa. Memoirs Geological Survey of South Africa 75: 1–217.

MACRAE, C. 1999. Life etched in stone. Fossils of South Africa. 305 pp. The Geological Society of South Africa, Johannesburg.

SAHRA 2013. Minimum standards: palaeontological component of heritage impact assessment reports, 15 pp. South African Heritage Resources Agency, Cape Town.

Snyman, C.P., 1998. Coal. In: Wilson, M.G.C., and Anhaeusser, C.P., (Eds) The Mineral Resources of South Africa: Handbook, Council for Geosciences 16, 136-205.

B) QUALIFICATIONS AND EXPERIENCE OF THE AUTHOR The author (Elize Butler) has an MSc in Palaeontology from the University of the Free State, Bloemfontein, South Africa. She has been working in Palaeontology for more than twenty three years. She has been conducting Palaeontological Impact Assessments since 2014.

C) DECLARATION OF INDEPENDENCE I, Elize Butler, declare that – General declaration: • I act as the independent palaeontological specialist in this application • I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant

• I declare that there are no circumstances that may compromise my objectivity in performing such work; • I have expertise in conducting palaeontological impact assessments, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity; • I will comply with the Act, Regulations and all other applicable legislation; • I will take into account, to the extent possible, the matters listed in section 38 of the NHRA when preparing the application and any report relating to the application; • I have no, and will not engage in, conflicting interests in the undertaking of the activity; • I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; • I will ensure that information containing all relevant facts in respect of the application is distributed or made available to interested and affected parties and the public and that participation by interested and affected parties is facilitated in such a manner that all interested and affected parties will be provided with a reasonable opportunity to participate and to provide comments on documents that are produced to support the application; • I will provide the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not • All the particulars furnished by me in this form are true and correct; • I will perform all other obligations as expected a palaeontological specialist in terms of the Act and the constitutions of my affiliated professional bodies; and • I realise that a false declaration is an offence in terms of regulation 71 of the Regulations and is punishable in terms of section 24F of the NEMA.

Disclosure of Vested Interest

PALAEONTOLOGICAL CONSULTANT: Banzai Environmental (Pty) Ltd CONTACT PERSON: Elize Butler Tel: +27 844478759 Email: [email protected]

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