Basic Assessment for the Proposed Babanango Travelers Camp, Adjacent to the White Mfolozi River, Ulundi Local Municipality, Zululand District, Kwazulu-Natal

Basic Assessment for the Proposed Babanango Travelers Camp, Adjacent to the White Mfolozi River, Ulundi Local Municipality, Zululand District, KwaZulu-Natal

Consultation (Draft) Basic Assessment Report for Comment July 2020

Prepare for: Emcakwini Community Trust 19 Wilson Street, Babanango, 3850 Northern KwaZulu-Natal

Prepared by: Integrated Development Management Services Environmental (IDME) Consultants Ocean Dune, FMI House, 2 Heleza Boulevard Hillhead Umhlanga, 4320

Client: Emcakwini Community Trust (ECT)

Reference Document as: Basic Assessment for the Proposed Babanango Travelers Camp, Babanango Game Reserve, KwaZulu- Natal, Draft I for Comment, IDME, 2020

Client Reference Number: Babanango Travelers Camp

Competent Authority Reference: To be issued

Report Compiled by: Novashni Sharleen Moodley Pr.Sci.Nat

Date of Report: July 2020

Report reviewed and approved by: Karl Wiggishoff

Applicant: Emcakwini Community Trust

Competent Authority: The Department of Economic Development, Tourism and Environmental Affairs (EDTEA)

Environmental Assessment Practitioner (EAP): Novashni Sharleen Moodley of IDM Environmental Ocean Dune, FMI House, 2 Heleza Boulevard Hillhead Umhlanga, Sibaya Precinct, 4320 [email protected]

NOTICE

This document and its appendices are a public document and made available to the Competent Authority (CA), commenting authorities, stakeholders, Interested and Affected Parties (I&APs), and the general public. This Consultation Basic Assessment Report (cBAR) is available for comment for a period of 30 days from 30 July to 30 August 2020. This report will then be amended and updated in response to the comments received during this review period. Once finalised the BAR will be submitted to the KwaZulu-Natal Department of Economic Development, Tourism and Environmental Affairs, Zululand District (KZN EDTEA), for decision-making.

A copy of the Draft BA and WUL Reports are available for review from 30 July 2020, at the Zulu Rock Lodge (R34 between Vryheid and, Ulundi) and for download and on the Phelamanga website home page (http://www.phelamanga.co.za).

PUBLIC REVIEW Phelamanga has been appointed as the independent public participation consultant. If you consider yourself an I&AP for this proposed project, we urge you to become involved. ▪ By responding (by phone, fax or e-mail) to our invitation for your involvement in the process. ▪ By completing the Background Information Document (BID, circulated on site) comment form and emailing it to Mrs Rose Owen. ▪ By reviewing and commenting on the draft / consultation BAR within the allowed 30-day review period (30 July to 30 August 2020), and the WUL within the allowed 60-day period (30 July to 30 September 2020) and submitting comment to the public participation consultant. THE DEADLINE FOR COMMENTS ON THE DRAFT BAR IS 30 AUGUST 2020 THE DEALINE FOR COMMENTS ON THE DRAFT WULA IS 30 SEPTEMBER 2020

Once you register yourself as an I&AP for this project it will be ensured that your comments, concerns and/or queries raised regarding the project are noted and addressed.

SUBMIT COMMENTS AND QUERIES TO:

Mrs Rose Owen (MSoc Sci) T: 031 765 8236; C: 082 506 0093 E: [email protected] Web: http://www.phelamanga.co.za

Directions, measures and protocols were followed at all times, including the “General measures to contain the spread of COVID-19” set out in Regulation 5 of Chapter 2 of the 29 April 2020 Lockdown Regulations, e.g. to wear a cloth face mask/appropriate item that covers the nose and mouth when in a public place; observance social/physical distancing requirements; a person may only leave his/her place of residence to perform an essential or permitted service, to go to work where a permit has been issued, to buy a permitted good, to obtain services that are allowed to operate; etc.

Disclaimer

The opinions expressed in this report are based on the information supplied to IDME Consulting. IDME Consulting has exercised all due care in reviewing the supplied information. While IDME Consulting has compared key supplied data with expected outcomes, and duly interrogated all information supplied to us, the accuracy of the results and conclusions from the review are entirely reliant on the accuracy and completeness of the supplied data. The results of this study are further based on a literature review and other data obtained from published articles, reference books, field guides, official databases or any other official published or electronic sources. These are assumed to be correct and no review of these were undertaken by IDME Consulting. Opinions presented in this report apply to the site conditions and features as they existed at the time of investigations, and those reasonably foreseeable. These opinions do not necessarily apply to conditions and features that may arise after the date of this report, about which IDME Consulting had no prior knowledge nor had the opportunity to evaluate.

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Contents

1. Basic Assessment Process ...... 1 1.1. Approach to the Basic Assessment ...... 1 1.2. Objectives of the Study ...... 1 1.3. Details of the Project Proponent ...... 2 1.4. Details of the Environmental Assessment Practitioner ...... 3 1.5. Structure of the Report ...... 4 2. Project Context and Motivation ...... 4 2.1. Background of Study ...... 4 2.1.1. The Greater Babanango Game Reserve...... 4 2.1.2. The proposed Babanango Travellers Camp (The Project) ...... 6 2.2. Property Description ...... 9 2.2.1. Land Use Zoning ...... 10 2.2.2. Site Coordinates ...... 11 2.2.3. Access / Directions ...... 11 2.2.4. Dimensions of the Activity ...... 12 2.2.5. Surrounding Land Uses ...... 12 2.3. Project Motivation and Need and Desirability ...... 13 2.4. Socio-Economic Value of the Activity ...... 14 3. Technical Data ...... 15 3.1. The Conceptual Engineering Scheme ...... 15 3.1.1. Particular Building Guidelines of the Babanango Game Reserve ...... 15 3.1.2. Pool Structure ...... 16 3.1.3. Floors, Foundations and Reinforced Concrete ...... 16 3.1.4. Earthworks ...... 16 3.1.5. Bulk Water ...... 17 3.1.6. Stormwater ...... 17 3.1.7. Sewer ...... 19 3.1.8. Recycling and Solid Waste ...... 21 3.1.9. Electrical Provision ...... 21 3.1.10. Pedestrian Bridge over Tributary ...... 23

3.2. Design Standards and Sources of Reference ...... 27 4. Environmental Legislative Context ...... 27 4.1. The Constitution of South Africa ...... 27 4.2. National Environmental Management Act (Act No. 107 of 1998) ...... 28 4.2.1. EIA Regulations (2014) (as amended in 2017) ...... 29 4.3. National Water Act (Act No. 36 of 1998) (as amended) ...... 35 4.4. National Environmental Management: Biodiversity Act (Act No. 10 of 2004) ...... 36 4.4.1. National Spatial Biodiversity Assessments (2004, 2011) ...... 37 4.4.2. National Biodiversity Strategy and Action Plans (2005) ...... 37 4.4.3. National Environmental Management: Protected Areas Act (Act No. 57 of 2003) ...... 38 4.4.4. KZN Nature Conservation Ordinance (Ordinance No. 15 of 1974) ...... 38 4.5. National Environmental Management: Waste Act (Act No. 59 of 2008) (as amended) .38 4.6. National Heritage Resources Act (Act No. 25 of 1999) ...... 39 4.7. National Forests Act (Act No. 84 of 1998) ...... 40 4.8. Occupational Health and Safety Act (Act No. 85 of 1993) ...... 40 4.9. National Environmental Management: Air Quality Act (Act No. 39 of 2004) ...... 40 4.10. Hazardous Substance Act (Act No. 15 of 1973) and Regulations ...... 41 4.11. Sustainable Development ...... 41 4.12. Climate Change Consideration ...... 42 5. The Study ...... 43 5.1. Project Alternatives ...... 43 5.1.1. Site and Type of Activity Alternatives ...... 44 5.1.2. Layout and Design Alternatives ...... 44 5.1.3. No-go Alternative ...... 44 5.2. Description of the Study Area ...... 44 5.2.1. General study area in the BGR ...... 44 5.2.1. Biophysical Environment ...... 45 5.3. Public Participation Process ...... 53 5.3.1. Notice of activity ...... 55 5.3.2. BID – Distribution ...... 55 5.3.3. BID: hardcopy distribution ...... 56 5.3.4. BAR - Access ...... 56

5.3.5. BAR Electronic access ...... 56 5.3.6. Advertising ...... 56 5.3.7. Other Activities...... 56 5.3.8. Notes ...... 57 5.3.9. Measuring effectiveness ...... 57 6. Specialist Findings ...... 57 6.1. Hydrogeological Investigation – Babanango Game Reserve, KwaZulu Natal ...... 58 6.1.1. Geophysical Investigation ...... 59 6.1.2. Drilling Target/s...... 60 6.1.3. Production Borehole Drilling...... 61 6.1.4. Aquifer Testing ...... 62 6.1.5. Recommended Pumping schedule ...... 63 6.1.6. Lab Analyses ...... 64 6.1.7. Groundwater Management Program ...... 68 6.1.8. Soil Augering ...... 69 6.1.9. Infiltration Tests ...... 70 6.1.10. Risk Assessment ...... 71 6.1.11. Analytical Model Calculations ...... 72 6.1.12. Additional Water Supply ...... 73 6.2. Watercourse Assessment ...... 74 6.2.1. Regional Context ...... 76 6.2.2. Present Ecological State (PES) ...... 80 6.2.2.1...... 80 6.2.3. Ecological Importance & Sensitivity Assessment ...... 82 6.3. Faunal Assessment ...... 83 6.3.1. Protected and conservation areas of South Africa ...... 86 6.3.2. South African Bird Atlas Project 2 ...... 87 6.3.3. Animal Demographic Unit databases ...... 88 6.3.4. Avifauna ...... 89 6.3.5. Butterflies...... 90 6.3.6. Amphibians ...... 91 6.3.7. Mammals ...... 91

6.3.8. Reptiles ...... 92 6.4. Vegetation Assessment ...... 92 6.4.1. Vegetation- Mucina and Rutherford ...... 93 6.5. Geotechnical Assessment ...... 100 6.4.1. Topography and Drainage ...... 100 6.6. Flood Assessment ...... 104 6.6.1. Gauged versus Ungauged Catchments ...... 104 6.6.2. Flood Line Determination ...... 105 6.6.3. Desktop Hydrological Assessment ...... 105 6.6.4. Flow Analysis ...... 106 6.6.5. Hydraulic Modelling ...... 106 6.7. Hydrological Assessment ...... 108 6.8. Agricultural Land Potential and Impact Assessment ...... 109 6.8.1. SMU A1, A2 and A3: Lithosols on Strongly Sloping Land ...... 112 6.8.2. SMU B1, B2, B3, B4: Lithosols on Moderately Steep Land with Outcrops ...... 113 6.8.3. SMU C: Alluvial Soils on the Floodplain of the White Mfolozi River ...... 113 6.8.4. SMU D1, D2, D3, D4, D5: Ephemeral Channels ...... 113 6.8.5. Vegetation evaluation ...... 113 6.9. Heritage Impact Assessment ...... 116 6.9.1. Heritage Background ...... 116 6.9.2. Study Results ...... 118 7. Impacts and Residual Risks Assessment ...... 121 7.1. Introduction ...... 121 7.2. Methodology ...... 122 7.3. Rating of Potential Impacts...... 123 7.4. The Mitigation Hierarchy ...... 124 7.5. Impact Assessment ...... 125 8. Study Findings and Conclusions ...... 142 8.1. Environmental Impact Statement ...... 142 8.1.1. Introduction ...... 142 8.1.2. Key Findings of the Study ...... 142 8.1.3. Key Conclusions and Recommendations of the Specialist Assessments ...... 142

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8.1.4. Sensitivity Map...... 152 8.1.5. EAP Opinion ...... 153 8.1.6. Conclusion ...... 154 8.1.7. Assumptions, Gaps and Limitations of the study ...... 154 8.1.8. Recommendations ...... 154 8.2. Declarations by the EAP ...... 155

List of Tables Table 1: Applicant Details ...... 2 Table 2: EAP Details ...... 3 Table 3: Surveyor General Numbers ...... 10 Table 4: Land Use Zoning ...... 10 Table 5: Site Coordinates ...... 11 Table 6: Dimensions of development ...... 12 Table 7: Proposed project need, desirability and benefits ...... 13 Table 8: Socio-economic value of the proposed project ...... 14 Table 9: Summary of the development areas: ...... 17 Table 10: Stormwater soak away volumes and sizes ...... 18 Table 11: Effluent loading based on the likely maximum occupancy of the development ...... 21 Table 12: Applicable Listed Activities According to Listing Notices 1, 2 and 3 of the EIA Regulations 2014 (2017 Amendment) ...... 29 Table 13: Employment opportunities created with the formulation of the Babanango Game Reserve ...... 50 Table 14: DEFF Screening Tool Site Sensitivity Rating ...... 57 Table 15: DEFF Recommended Specialist Studies ...... 58 Table 16: Tented Camp Geophysical Survey - Traverse Details ...... 59 Table 17: Tented Camp - Drill Target ...... 60 Table 18: Tended Camp Production Borehole Drilling Table ...... 61 Table 19: Aquifer Test - Borehole Details ...... 62 Table 20: TC BH1 - Aquifer Test Results ...... 63 Table 21: TC BH1 Recommended Pumping Schedule ...... 63 Table 22: TC BH1 - Groundwater Quality Results ...... 65 Table 23: TC BH1 - Water Level Monitoring Plan ...... 69 Table 24: TC BH1 - Groundwater Sampling Schedule ...... 69 Table 25: Tented Camp - Soil Auger Hole Details ...... 69 Table 26: Tented Camp - Infiltration Tests Results ...... 71 Table 27: Groundwater Seepage Travel Time Towards Possible Receptors ...... 73 Table 28: Traverse Line 9 ...... 74 Table 29: Description of HGM units ...... 79

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Table 30: EWR PES Score for the White Mfolozi ...... 80 Table 31: Pre-development PES score using the Index of Habitat Integrity tool (Kleynhans, 1999) for the White Mfolozi ...... 82 Table 32: EIS category scoring summary for the ephemeral tributary ...... 82 Table 33: EIS category scoring summary for the White Mfolozi ...... 83 Table 34: Species occurring on the TSCP Minset database ...... 86 Table 35: Avifaunal species of conservation concern according to SABAP 2...... 88 Table 36: Amphibians of conservation concern occurring on site according to the ADU FrogMAP...... 88 Table 37: Mammal species of conservation concern potentially occurring on site according to the ADU MammalMAP...... 89 Table 38: Reptile species of conservation concern potentially occurring on site according to the ADU ReptileMAP...... 89 Table 39: Species of conservation importance ...... 93 Table 40: Features of conservation Importance ...... 93 Table 41: Comparison of values from some of the gauging stations that were assessed during the data analysis ...... 106 Table 42: Description of land potential classes...... 114 Table 43: Agricultural land potential per SMU ...... 116 Table 44: Field rating of heritage sites found ...... 120 Table 45: Significance ratings ...... 123 Table 46: Planning Phase Impact Assessment ...... 126 Table 47: Planning Phase Impact Assessment – No-Go Alternative ...... 128 Table 48: Construction Phase Impact Assessment ...... 129 Table 49: Construction Phase Impact Assessment – No-Go Alternative ...... 137 Table 50: Operational Phase Impact Assessment ...... 138 Table 51: Operational Phase Impact Assessment – No-Go Alternative ...... 140 Table 52: Decommissioning Phase – Not Applicable ...... 141 Table 53: Summary of Significance Ratings per Phase ...... 142

List of Figures Figure 1: Basic Assessment process ...... 2 Figure 2: Broader Babanango Game Reserve...... 5 Figure 3: Locality Map of the study site ...... 10 Figure 4: Proposed Eskom Off-take point ...... 22 Figure 5: Power Reticulation from Eskom Point of Supply to the BTC site (and passing through the other proposed Madwaleni lodge (applied for under a separate application))...... 23 Figure 6: Pedestrian Bridge Annotation and illustration (inset) ...... 25 Figure 7: Conceptual Design of Pedestrian Bridge ...... 26 Figure 9: Average monthly rainfall in the Babanango Valley...... 45 Figure 9: Geology Map ...... 47

Figure 10: Change in geological formation from Swaziland towards the south (Kranskop) ...... 49 Figure 11: Responsibilities of I&APs in the different PPP stages ...... 54 Figure 12: The stakeholder engagement spectrum (DEAT, 2002) ...... 54 Figure 13: Tented Camp - Depiction of Electrical Resistivity and Magnetometer Geophysical Traverse Results ...... 60 Figure 14: TC BH1 - Aquifer Test Results ...... 62 Figure 15: Piper Diagram ...... 68 Figure 16: Typical vegetation on-site ...... 77 Figure 17: Current land use within and around the site boundary, showing the mostly natural areas ...... 78 Figure 18: HGM units identified within 500m of the proposed tented camp ...... 80 Figure 36: DWA (2014) EIS category scoring summary for the White Mfolozi ...... 81 Figure 20: CBA’s of the proposed study site...... 85 Figure 21: Protected Areas around the study site from the DEA Screening Tool ...... 87 Figure 22: Vegetation type on the proposed development site ...... 95 Figure 23: Protected Areas in proximity to the proposed development site ...... 96 Figure 24: Image indicating historical vegetation and present vegetation on the site...... 97 Figure 25: Location of protected plant species within proposed footprint ...... 98 Figure 26: (From left to right) Aloe spectabilis, Sansevieria metallica and Albuca sp...... 99 Figure 27: Longitudinal profile and channel cross sections developed for the While Umfolozi River ...... 105 Figure 28: : Steady state analysis of the 1:100 year flood event through some of the cross sections...... 107 Figure 29: 1:100 year flood line for the tented camp adjacent to the White Mfolozi river ...... 107 Figure 30: Monthly rainfall and evaporation for Quaternary Catchment W21G ...... 109 Figure 31: Location of soil observations ...... 111 Figure 32: Soils map with SMUs ...... 112 Figure 33: Agricultural Land Potential ...... 115 Figure 34: The Mitigation Hierarchy ...... 125 Figure 75: Recommended relocation boundary for the tented camp ...... 146

List of Appendices A – Locality / Layout Map in A3 A1 – Sensitivity Maps A2 – Shapefiles A3 – Coordinates of Site B – Site Photographs from Centre in 8 Directions with Descriptions C – Facility Illustrations / Site Development Plan D – Specialist Reports D1 – Hydrogeological Investigation

D2 –Geotechnical Assessment D3 – Reticulation Layout D4 – Faunal Assessment D5 – Floodline Assessment D6 – Vegetation Assessment D7 - Watercourse Assessment D8 – Engineering Report D9 – Heritage Impact Assessment D10 – Hydropedological Assessment D11 – Hydrological Assessment D12 – Traffic Statement D13 – Water Supply Report D14 – Agricultural Assessment E – Public Participation Process Report F – Complete Impact Assessment G – Draft EMPr H – Details and Expertise of EAP I – Specialist Declarations (Copies) J – Other Information: J1 – Pre-application meeting correspondence J2 -- Acceptance of Application Form (to be provided in Final BAR) J3 – On-Line DEFF Screening Tool Report

Glossary

Activity (Development) – an action either planned or existing that may result in environmental impacts through pollution or resource use. Alternative / Option – a possible course of action, in place of another, of achieving the same desired goal of the proposed project. Alternatives can refer to any of the following but are not limited to site alternatives, site layout alternatives, design or technology alternatives, process alternatives or a no-go alternative. Applicant – the project proponent or developer responsible for submitting an environmental application to the relevant environmental authority for environmental authorisation. Biodiversity – the diversity of animals, plants and other organisms found within and between ecosystems, habitats, and the ecological complexes. Construction – means the building, erection or establishment of a facility, structure or infrastructure that is necessary for the undertaking of a listed or specified activity but excludes any modification, alteration or expansion of such a facility, structure or infrastructure and excluding the reconstruction of the same facility in the same location, with the same capacity and footprint. Cumulative Impacts – impacts that result from the incremental impact of the proposed activity on a common resource when added to the impacts of other past, present or reasonably foreseeable future activities to produce a greater impact or different impacts. Direct Impacts – impacts that are caused directly by the activity and generally occur at the same time and at the same place of the activity. These impacts are usually associated with the construction, operation or maintenance of an activity and are generally quantifiable. Ecological Reserve – the water that is necessary to protect the water ecosystems of the water resource. It must be safeguarded and not used for other purposes. The Ecological Reserve specifies both the quantity and quality of water that must be left in the national water resource. The Ecological Reserve is determined for all major water resources in the different water management areas to ensure sustainable development. Ecosystem – a dynamic system of plant, animal (including humans) and micro-organism communities and their non-living physical environment interacting as a functional unit. The basic structural unit of the biosphere, ecosystems are characterised by interdependent interaction between the component species and their physical surroundings. Each ecosystem occupies a space in which macro-scale conditions and interactions are relatively homogenous. Environment – In terms of the National Environmental Management Act (NEMA) (Act No 107 of 1998) (as amended), “Environment” means the surroundings within which humans exist and that are made up of:

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a) the land, water and atmosphere of the earth; b) micro-organisms, plants and animal life; c) any part or combination of (a) or (b) and the interrelationships among and between them; and d) the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and wellbeing. Environmental Assessment– the generic term for all forms of environmental assessment for projects, plans, programmes or policies and includes methodologies or tools such as environmental impact assessments, strategic environmental assessments and risk assessments. Environmental Authorisation (EA) – an authorisation issued by the competent authority in respect of a listed activity, or an activity which takes place within a sensitive environment. Environmental Assessment Practitioner – the individual responsible for planning, management and coordination of environmental impact assessments, strategic environmental assessments, environmental management programmes or any other appropriate environmental instrument introduced through the EIA Regulations. Environmental due diligence - a formal process that assesses real estate for potential risk of environmental contamination, such as soil or groundwater contamination. Environmental Impact – a change to the environment (biophysical, social and / or economic), whether adverse or beneficial, wholly or partially, resulting from an organisation’s activities, products or services. Environmental Impact Assessment (EIA) – the process of identifying, predicting, evaluating and mitigating the biophysical, social, and other relevant effects of development proposals prior to major decisions being taken and commitments made. Environmental Issue – a concern raised by a stakeholder, interested or affected parties about an existing or perceived environmental impact of an activity. Environmental Management – ensuring that environmental concerns are included in all stages of development, so that development is sustainable and does not exceed the carrying capacity of the environment. Environmental Management Programme – A detailed plan of action prepared to ensure that recommendations for enhancing or ensuring positive impacts and limiting or preventing negative environmental impacts are implemented during the life cycle of a project. This EMPr focuses on the construction phase, operation (maintenance) phase and decommissioning phase of the proposed project. Expansion – means the modification, extension, alteration or upgrading of a facility, structure or infrastructure at which an activity takes place in such a manner that the capacity of the facility or the footprint of the activity is increased.

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Fatal Flaw – issue or conflict (real or perceived) that could result in developments being rejected or stopped. Greenfield – is land that is undeveloped land in a city or rural area either used for agriculture, landscape design, or left to evolve naturally. These areas of land are usually agricultural, or amenity properties being considered for urban development. Indirect Impacts – indirect or induced changes that may occur as a result of the activity. These types if impacts include all of the potential impacts that do not manifest immediately when the activity is undertaken, or which occur at a different place as a result of the activity. Integrated Environmental Management – a philosophy that prescribes a code of practice for ensuring that environmental considerations are fully integrated into all stages of the development and decision-making process. The IEM philosophy (and principles) is interpreted as applying to the planning, assessment, implementation and management of any proposal (project, plan, programme or policy) or activity – at local, national and international level – that has a potentially significant effect on the environment. Implementation of this philosophy relies on the selection and application of appropriate tools for a particular proposal or activity. These may include environmental assessment tools (such as strategic environmental assessment and risk assessment), environmental management tools (such as monitoring, auditing and reporting) and decision-making tools (such as multi-criteria decision support systems or advisory councils). Interested and Affected Party – for the purposes of Chapter 5 of the NEMA and in relation to the assessment of the environmental impact of a listed activity or related activity, means an interested and affected party contemplated in Section 24(4) (a) (v), and which includes – (a) any person, group of persons or organisation interested in or affected by such operation or activity; and (b) any organ of state that may have jurisdiction over any aspect of the operation or activity. Mitigate – the implementation of practical measures designed to avoid, reduce or remedy adverse impacts or enhance beneficial impacts of an action. No-Go Option – in this instance the proposed activity would not take place, and the resulting environmental effects from taking no action are compared with the effects of permitting the proposed activity to go forward. Rehabilitation– a measure aimed at reinstating an ecosystem to its original function and state (or as close as possible to its original function and state) following activities that have disrupted those functions. Sensitive Environment – any environment identified as being sensitive to the impacts of the development. Significance – significance can be differentiated into impact magnitude and impact significance. Impact magnitude is the measurable change (i.e. magnitude, intensity, duration and likelihood). Impact significance is the value placed on the change by different affected parties (i.e. level of

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significance and acceptability). It is an anthropocentric concept, which makes use of value judgements and science-based criteria (i.e. biophysical, social and economic). Stakeholder Engagement – the process of engagement between stakeholders (the proponent, authorities and I&APs) during the planning, assessment, implementation and / or management of proposals or activities. Sustainable Development – development which meets the needs of current generations without hindering future generations from meeting their own needs. Watercourse – means: a) a river or spring; b) a natural channel or depression in which water flows regularly or intermittently; c) a wetland, lake or dam into which, or from which, water flows; and d) any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse as defined in the National Water Act, 1998 (Act No. 36 of 1998) and a reference to a watercourse includes, where relevant, its bed and banks. Wetland – means land, which is transitional between terrestrial and aquatic systems where the water table is usually at or near the surface, or the land is periodically covered with shallow water, and which land in normal circumstances supports or would support vegetation typically adapted to life in saturated soil.

Acronyms

BA Basic Assessment BAR Basic Assessment Report BGIS Biodiversity Geographic Information Systems BGR Babanango Game Reserve BPA Biodiversity Protected Area BTC Babanango Travellers Camp CBA Critical Biodiversity Area CMA Catchment Management Agency C-PLAN Conservation Plan DAFF Department of Agriculture, Forestry and Fisheries DEFF Department of Environment, Forestry and Fisheries DWS Department of Water and Sanitation EAP Environmental Assessment Practitioner ECT Emcakwini Community Trust EDTEA (Department of) Economic Development, Tourism and Environmental Affairs EIA Environmental Impact Assessment (refers to environmental management tool) EIS Ecological Importance and Sensitivity EKZNW Ezemvelo KwaZulu-Natal Wildlife ESA Ecological Support Area GA General Authorisation (refers to type of water use licence authorisation) GA General Arrangement (refers to drawing / illustration of structures) GIS Geographic Information System GPS Geographical Positioning System IDP Integrated Development Plan I&AP Interested and Affected Parties IQ Interpretation Query KZN KwaZulu-Natal MAP Mean Annual Precipitation NBSAP National Biodiversity Strategy and Action Plans NEMA National Environmental Management Act (Act No. 107 of 1998) (as amended) NEM:BA National Environmental Management Biodiversity Act (Act No. 10 of 2004) NEM:WA National Environmental Management Waste Act (Act No. 36 of 1998) (as amended) NEM:AQA National Environmental Management Air Quality Act (Act No. 39 of 2004) NFA National Forests Act (Act No. 84 of 1998) NFEPA National Freshwater Ecosystem Priority Area NHRA National Heritage Resources Act NWA National Water Act NGO Non-Governmental Organisation OHSA Occupational Health and Safety Act (Act No. 85 of 1993) PES Present Ecological State

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PPP Public Participation Process RA Risk Assessment REC Recommended Ecological Category SAHRA South African Heritage Resources Agency SANBI South African National Biodiversity Institute SDF Spatial Development Framework SID Strategic Infrastructure Development SWMP Stormwater Management Plan WMA Water Management Agency WUL Water Use Licence

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Executive Summary

Project Background and Introduction This Consultation Basic Assessment Report (cBAR) has been compiled in accordance with the stipulated requirements in Government Notice Regulation (GNR) 326 Appendix 1 of the EIA Regulations (2014 as amended in 2017), which outlines the legislative Basic Assessment (BA) process and requirements for assessment of outcomes, impacts and residual risks of the proposed development. The cBAR further incorporates the findings and recommendations of the specialist study conducted for the project.

The proposed development of the Babanango Travelers Camp will include the following: (a) A main reception area (comprising reception, covered entrance, retail area, reception ablutions, General Manager Office, open office, server room, library, lounge and bar building, dining building and private dining, pool area and gun safe); (b) 14 tented accommodation units; (c) A spa and wellness centre; (d) A riverbank boma area; (e) Main area circulation (pathways etc.); (f) Staff accommodation; and (g) A sewage treatment plant (Septic tank); (h) services (kitchen and laundry etc.). This totals a site development area of 5640m2 as per adjacent Table.

The Basic Assessment (BA) This BA follows the legislative process prescribed in the EIA Regulations (2014 as amended in 2017), as this application will be lodged under the EIA Regulations (2014, as amended in 2017). The process is explained in the diagram below.

• July 2020 (see BA phase below) Application •Continual public consultation and participation •Specialist studies •Drafting of cBAR •Submission of Application form: July 2020 BA Phase •Public Review of cBAR: July- August 2020 •Finalisation of BAR: September 2020

•Submission of Final BAR to Competent Authority – assumed Submission September 2020 •Competent Authority Decision – assumed November 2020: Decision •Environmental Authorisation – Approval or Rejection

•Opportunity for Appeal Appeal

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Principal Objective of Report This report constitutes the cBAR, which details the environmental outcomes, impacts and residual risks of the proposed activity. The report aims to assess the key environmental issues and impacts associated with the development, and to document I&APs issues and concerns. Furthermore, it provides background information of the proposed project, a motivation and details of the proposed project, and describes the public participation undertaken to date.

The objective of this report is to provide the project's I&APs, stakeholders, commenting authorities, and the CA, with a thorough project description and BA process description. The outcome being to engender productive comment / input, based on all information generated to date and presented herein.

The document concludes by proposing what is believed to be a sound and environmentally risk calculated decision. In order to protect the environment and ensure that the development is undertaken in an environmentally responsible manner, there are a number of significant portions of environmental legislation that were taken into consideration during this study and are elaborated on in this report.

Regulatory Environmental Requirements The KZN EDTEA (Zululand district office) is the lead / competent authority for this BA process and the development needs to be authorised by this Department in accordance with the NEMA. The EIA Regulations under the NEMA consist of three (3) categories of activities namely: Listing Notice 1 Activities (GNR 327 of 2017) which require a BA Process, Listing Notice 2 Activities (GNR 325 of 2017) which require S&EIR process, and Listing Notice 3 Activities (GNR 324 of 2017) which requires a BA process for specific activities in identified sensitive geographical areas.

Public Participation Process (PPP) IDME as the EAP is undertaking the PPP for this project as professional facilitators. The figure below depicts the approach taken by IDME, where one-way information flow is avoided and information exchange is promoted, thereby enabling a higher level of engagement.

Information Exchange: One Way Information Flow: Consult Protest Involve Inform Collaborate Empower Increasing Level of Engagement

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Key Findings and Conclusions Overall, the results of the BA process emerge as having a “Positive low” or “Negative Low” or “Positive low” environmental significance after mitigation. Refer to table below for a summary of the phases.

EAP Opinion and Recommendation to CA This BAR provides an assessment of both the benefits and potential negative impacts anticipated as a result of the proposed Babanango Travelers Camp. The findings conclude that there are no environmental fatal flaws that could prevent the proposed development from proceeding, provided that the recommended mitigation and management measures contained within the EMPr are implemented. Given the findings of the specialist study conducted, as outlined in summary above, it is safe to say that no significant impacts have been identified by these studies. This has resulted in an impact assessment yielding an overall result of having “negative low” impact. This is attributed mostly to the short-term negative impacts, which are likely to occur during the construction phase, which can be adequately mitigated and rehabilitated to an acceptable state of environment. It is therefore the recommendation of the EAP that the environmental authorisation is granted for the proposed Babanango Travelers Camp, KwaZulu-Natal. Indeed, the proposed development will have more long-term benefits than negative impacts, the latter of which are more short-termed and associated with the construction phase. The benefits stated above, far outweigh the negative impacts. The upgrades will lead to an improvement to the social status quo. It is recognised that the proposed BTC will see the intended result to lease and merge the area controlled by the community to the developer, and join the Zulu Rock Private Game Lodge to the Babanango Private Game Reserve, thereby creating a private, “Big 5” game reserve. This will result in the conservation of many faunal species of conservation concern. The following recommendations / conditions, although not exhaustive, may be considered for inclusion in the environmental authorisation: ▪ The EMPr and conditions thereto must be adhered to; ▪ An ECO must be appointed and all Contractor staff to be trained on the EMPr requirements prior to commencement of activities; ▪ Alien vegetation and invader species within the vicinity of construction zone are to be removed and indigenous vegetation, where appropriate, to be introduced and managed; ▪ Environmental compliance monitoring should be conducted twice every month (or a frequency stipulated by the competent authority) during construction and incidents recorded and addressed accordingly; ▪ All mitigation measures must be adhered to; ▪ Construction must be undertaken according to a site-specific approved Environmental Management Programme (EMPr ▪ All solid waste must be removed to an appropriate disposal facility, and recycled as per the plans outlined in the Engineering Services Report; ▪ No discharge of any pollutants, such as fuels, cements, concrete, lime, and chemicals are allowed into the White Mfolozi River or tributaries and streams.

▪ Waste receptacles should be provided and regularly cleaned, and waste moved to an appropriate disposal facility. Having duly considered the proposal, there is unlikely to be any significant negative environmental impacts, and the social benefits are evident, and therefore it is the EAP’s opinion that the project be issued with a positive Environmental Authorisation.

Conclusion This study provided a quantified analysis of the impacts associated with the proposed development. The EAP is of the opinion that the project should be positively authorised, outlining the key findings of the study. It is the opinion of the EAP that the BA process and report complies with the EIA Regulations of 2014 (as amended in 2017), under which this project has applied and therefore meets all relevant requirements.

Way Forward The impacts identified and assessed by way of risk ratings, have been extensively reported herein. The report at hand (i.e. cBAR) will now be made available for comment (as per the timeline diagram presented above) and amended post comment period to form the final BAR (i.e. fBAR). The fBAR report will, together with a comprehensive issues trail; the final draft of the EMPr; and all addenda as referred to, will be submitted to the KZN EDTEA for decision making. The fBAR report will thus be a culmination of scientific specialist study findings, public contribution via formal comment, and the drawing of conclusions by the EAP as the environmental specialist.

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1. Basic Assessment Process 1.1. Approach to the Basic Assessment This Consultation Basic Assessment Report (cBAR) has been compiled in accordance with the stipulated requirements in Government Notice Regulation (GNR) 326 Appendix 1 of the EIA Regulations (2014 as amended in 2017), which outlines the legislative Basic Assessment (BA) process and requirements for assessment of outcomes, impacts and residual risks of the proposed development. The cBAR further incorporates the findings and recommendations of the specialist studies conducted for the project. The proposed Babanango Travellers Camp (BTC) falls within the greater Babanango Game Reserve (BGR), The site is located approximately 51km south east of Vryheid, approximately 28km west of Ulundi and approximately 7km to the north of the small town of Babanango in the Zululand Region of KwaZulu Natal. Therefore, the Competent Authority (CA) is the Department of Economic Development, Tourism and Environmental Affairs, Zululand District (KZN EDTEA), for decision-making. Error! Reference source not found. below outlines the approach undertaken for this BA.

1.2. Objectives of the Study The BA aims to achieve the following: ▪ Conduct a consultative process; ▪ Determine the policy and legislative context within which the proposed activity is undertaken and how the activity complies with and responds to the policy and legislative context; ▪ Identify the alternatives considered, including the activity, location, and technology alternatives (however, due to the nature of the project, only the No-Go alternative is considered); ▪ Describe the need and desirability of the proposed project; ▪ Undertake an impact and risk assessment process inclusive of cumulative impacts (where applicable). The focus being; determining the geographical, physical, biological, social, economic, heritage and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on the these aspects to determine: ▪ the nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and ▪ the degree to which these impacts: ▪ can be reversed; ▪ may cause irreplaceable loss of resources; and ▪ can be avoided, managed or mitigated; ▪ Through a ranking of the site sensitivities and possible impacts the activity will impose on the site to:

▪ identify suitable measures to avoid, manage or mitigate identified impacts; and ▪ Identify residual risks that need to be managed and monitored.

Figure 1 illustrates the approach / methodology employed. Basic Assessment Process – Formal 197-day process (or 247 days) Prior to formal Screening of project scope process Pre-application meeting Compile application Conduct specialist studies Conduct PPP (BIDs, Site notices and Advertisement if permitted by CA) Develop consultation BAR to completion Develop EMPr Submit Application form to CA 30 Place consultation BAR for review days 197 (or 247) Incorporate comments 90 days (or 60 days of Finalise for submission to CA (or request 50-day extension, 140 days) days formal BA 30 of which must include a repeat of placement for public (or process review) 110) Submit to CA 107 days Decision by CA 90 days Complete appeal process No less than 3 Application for amendment of EA months prior to expiry of EA 30 days CA must acknowledge amendment application BA = Basic Assessment BAR = Basic Assessment Report CA = Competent Authority (EDTEA eThekwini) EA = Environmental Authorisation EMPr = Environmental Management Programme PPP = Public Participation Process

Figure 1: Basic Assessment process 1.3. Details of the Project Proponent The Applicant for the proposed project is Mr Johannes Moses Tabo Madondo, representing the Emcakwini Community Trust (ECT). The details of the Applicant are as follows:

Table 1: Applicant Details

Applicant Emcakwini Community Trust Representative Mr Johannes Moses Tabo Madondo 19 Wilson Street, Physical Address Babanango, 3850 Northern KwaZulu-Natal Postal Address As above Telephone 0823715064 2

Applicant Emcakwini Community Trust Facsimile N/A E-mail [email protected]

1.4. Details of the Environmental Assessment Practitioner Novashni Sharleen Moodley of IDME has been appointed as the Environmental Assessment Practitioner (EAP) by the Applicant of the project. Mrs Moodley is therefore undertaking the appropriate environmental studies for this proposed project. Novashni (Sharleen) Moodley is an Environmental Scientist and an Environmental Assessment Practitioner (EAP) by profession, with eleven years of experience. She holds a BSc in Environmental Science; a BSc (Honours) in Environmental Management (cum laude) and an MSc in Environmental Science. Novashni is registered as a Professional Natural Scientist with the South African Council for Natural Scientific Professions (SACNASP), Pr.Sci.Nat: 400305/15, and is currently applying for registration as an EAP with the Environmental Assessment Practitioners Association of South Africa (EAPASA), and is a trained Assessor for the EAPASA registration board. Novashni has credible experience in environmental planning and consulting, as well as in project management and Geographical Information Systems (GIS). She specialises in the suite of IEM tools, viz. Environmental Impact Assessments (EIA), Basic Assessments (BA), Water Use Licence Applications (WULA), Strategic Environmental Assessment (SEA), Screening Assessments, Public Participation Processes (PPP), and Environmental Control Officer (ECO) audits. Novashni applies these tools within the principles of quality, inclusivity, and environmental sustainability. Novashni has experience in a range of projects, with a range of clients, such as mixed-use developments, water treatment, energy production, strategic (regional) planning and linear developments (including roads and pipelines). Novashni is the External Moderator for the Environmental Engineering (ENEL2ENH2) Module within the College of Agriculture, Engineering and Science at the University of KwaZulu-Natal. For the detailed experience of the EAP, refer to Appendix H of this cBAR.

Table 2: EAP Details1

EAP IDME Contact Persons Mrs Novashni Sharleen Moodley Ocean Dune, FMI House, 2 Heleza Boulevard Address Hillhead Umhlanga, 4320 Telephone 082 571 1425 Facsimile N/A E-mail [email protected] MSc Environmental Science Qualification Pr.Sci.Nat IAIAsa Experience 11 Years

1 Refer to Appendix H for EAP CV 3

1.5. Structure of the Report This report has been structured to comply with the format required by the National Environmental Management Act (NEMA) (Act No. 107 of 1998) (as amended). The contents are as follows:

Chapter Content

Chapter 1 This chapter includes the approach to the study and details of Basic Assessment Process the project proponent and EAP.

Chapter 2 Contextualises the study area and provides a motivation and Project Context and Motivation need for the proposed development.

Chapter 3 Includes a detailed description of the proposed activities. Technical Data

Chapter 4 Includes an explanation on all applicable legislation and the Environmental Legislative relevant listed activities applied for. Context

A description of the biophysical and social environment. Consideration of alternatives (design / layout and no-go) for the project. Overview of the public participation process conducted Chapters 5-7 to date. This section also highlights the key findings of the The Study specialist studies conducted and other environmental considerations. Includes the impact assessment methodology. The impacts identified are rated and a significance score obtained.

Chapter 8 Conclusions and recommendations of the Environmental Impact Study Findings and Conclusions Assessment. Declaration of independence by the EAP.

2. Project Context and Motivation 2.1. Background of Study 2.1.1. The Greater Babanango Game Reserve The study site falls within the broader Babanango Game Reserve (BGR) which is an amalgamation of community owned and privately owned land. The largest area is owned by a The Emcakwini Community who successfully claimed 38 000 ha of land into the north of Babanango area, stretching from the hills of Zululand to the banks of the White Mfolozi River. The claimant community, represented by the Emcakwini Community Trust (hereinafter referred to as ECT), were forced off the land in the 1950s and today comprise 192 households. The BGR is made up of several parcels of land including private farms and two game farms. It incorporates forestry land (wattle, pine and gum) plus good cattle grazing land. The game farms, situated in the White Mfolozi River valley, include some 4 200 ha of typical indigenous Zululand veldt (Environmental Planning and Design, 2018).

ECT have also liaised with Ezemvelo KwaZulu-Natal Wildlife (EKZNW) to incorporate approximately 13,000ha immediately south of the White Mfolozi River within its Bio-Diversity 4

Stewardship Programme with the aim of having the area declared a Nature Reserve under the National Environmental Management: Protected Areas Act, 2003 (Act 57 of 2003) (NEMPAA) (Environmental Planning and Design, 2018). The ECT’s aim, with the support of other investors, is to develop the land area into a game reserve in order that the community will benefit from inter alia job creation, community benefit projects and eco-tourism income from the operation of the game reserve. The ECT has been working with a Non-Government Organisation, Conservation Outcomes, to undertake background assessment work and prepare the necessary applications. The long term goal (in keeping with the principles of the Biodiversity Stewardship Programme) is to develop and manage a financially viable private game reserve (Big Five) focusing on the restoration of the biodiversity, the cultural history and scenic splendour of the region. A private investor (African Habitat Conservancy (Pty) Ltd) (AHC)) has already invested substantially in the project to date. The greater BGR site is comprised of twenty properties in total. ECT own fifteen properties that are located to the south of the White Mfolozi River.

Figure 2: Broader Babanango Game Reserve.

The development of the Babanango Travellers Camp forms part of the proposed new Babanango Game Reserve (Error! Reference source not found.). The proposed BTC forms one component of the broader programme and conservation goals for the area which includes: 5

• The leasing / purchasing of land to form part of the Babanango Game Reserve (Figure 1). This includes Zulu Rock Game Reserve (green boundary), Fairview Cattle Farm, Doornkroon Farm, Lulu Cattle Farm (blue boundary) and the Matatane River Lodge. The red boundary depicts ECT land. • The rehabilitation of the sensitive environment forming part of the proposed Reserve; • Re-instate (or if this is not possible) simulate, through the implementation of sustainable management principles, those ecological processes and regulatory mechanisms endemic to the region; • The removal of invasive alien species; • The reintroduction of biodiversity into the Reserve. This includes large game and the ‘Big Five’; • The installing of game fences around the Reserve (which will form part of a separate environmental impact assessment); • The creation of significant community employment opportunities and socio-economic upliftment; • The establishing and refurbishment of various eco-lodges within the proposed Reserve (also to form part of separate environmental impact assessment). There are two existing lodges in the proposed Reserve which will be upgraded, and two new lodges are proposed at this time; and • The establishment of various community upliftment projects, to create sustainable opportunities for the local community and the beneficiaries of the Trusts and assist in alleviating poverty and unemployment in the area. 2.1.2. The proposed Babanango Travellers Camp (The Project) Tented architecture is on trend today more than ever. From the U.S. and Europe to Thailand and India, resort owners and operators are employing the light-on-earth approach in order to capitalize on the rapidly growing eco-conscious and adventure-seeking travel market. In fact, tented resorts are consistently ranked among the best hotels in guest surveys, such as Condé Nast Traveler Reader’s Choice Awards, and discerning travelers are willing to pay rate premiums for luxury tented hotel experiences, with these rooms generating 20-40% rate premiums over traditional rooms at luxury properties with both types of inventory. In the 2018 Bloomberg article "Tented Camps are Fast Becoming the World's Best Resorts," it was stated that "tents lured the ultra-rich" through "novelty, digital disconnection, and access to experiences that are at once authentic and Instagrammable.” The 2019 Virtuoso Luxe Report reinforced these points, observing that affluent families are voyaging all over the globe in search of active, unique, and adventurous experiences. In North America, glamorous camping or “glamping” has taken off. The glamping market in the U.S. is projected to reach a revenue of about USD $1 billion by 2024, growing at a CAGR of over 15% during the years 2018 to 2024. Globally, the glamping industry was valued at USD $2.07 billion in 2018 and is projected to reach USD $4.60 billion by 2026, growing at a CAGR of 10.71% from 2019 to 2026. Some of the key aspects of these types of developments are:

• Embracing a "live fully, tread lightly" philosophy, most leading tented resorts range from four to 45 units, and about half of those offer at least one multi-bedroom unit. The takeaway: the more "boutique" an experiential concept is, the higher the demand. • Architectural styles run the gamut from classic African safari designs to wild west pioneer tents and modern Asian pavilions. Tents have been designed as permanent, semi- permanent, and fully dismountable (effectively leave-no-trace) structures. • To accentuate their tented architecture, these camps have memorable amenities such as freestanding bathtubs, outdoor showers and plunge pools, and decks with ample al fresco lounging areas. • "Glamping is much more than pitching a fancy tent. The tent is only one layer." Indeed, leading tented resorts further appeal to the active traveler with activity programming that is oriented around wildlife, nature exploration, wellness, and/or culture. Their various design elements—wildlife observation decks, starbeds, outdoor spa suites, and discovery centers—support guest discovery and immersion in nature. The proposed development of the Babanango Travellers Camp will include the following: (a) A main reception area (comprising reception, covered entrance, retail area, reception ablutions, General Manager Office, open office, server room, library, lounge and bar building, dining building and private dining, pool area and gun safe); (b) 14 tented accommodation units; (c) A spa and wellness centre; (d) A riverbank boma area; (e) Main area circulation (pathways etc.); (f) Staff accommodation; and (g) A sewage treatment plant (Septic tank); (h) services (kitchen and laundry etc.). This totals a site development area of 5640m2. The following architects’ impressions provide a visual of the development aesthetic.

Plate 1: Accommodation Unit Exterior Plate 2: Overall view and ambiance

Plate 3: River view from BTC Plate 4: Reception Exterior

Plate 5: Main Area Exterior

Plate 6: BTC Unit Exterior

2.2. Property Description The site is located on the farm Doornhoek 391 to the North of the White Mfolozi River and falls within a greater development known as the Babanango Game Reserve (BGR). The site is accessed from the R34 National Road in the North, via a gravel road through the farm Jordaan 3-656 and 5-656 on which the current Zulu Rock Lodge is located, Bloemhof 34 and Lulu No:722. The farm Lulu No:722 is included within the Babanango Game Reserve boundary of March 2019 and is located North of the White Mfolozi River which forms the Northern boundary of the proposed travellers camp site. The following depicts the project site.

Figure 3: Locality Map of the study site

The proposed activity is situated on the following property. The 21-digit surveyor-general code is provided in Error! Reference source not found. below.

Table 3: Surveyor General Numbers

21 Digit Reference Number Erf, Farm and Portion Number

N0GU000000000391000030 Farm portion: 3/391, Farm name: DOORNHOEK 391

2.2.1. Land Use Zoning Table 4: Land Use Zoning

There is no town planning scheme for the study area, thus there will not be an application for a zone, but rather for a Development Application outside of a scheme area which warrants the need for accurate site development plans. The site is zoned Unlike a zoning that will give you a set of development parameters to develop within in a flexible manner, a development application is more rigid, approval is granted based on what you applied for with little room to expand or adjust. 10

Is a change of land use or a consent Yes use application required? Must a building plan be submitted to Yes the local authority?

2.2.2. Site Coordinates Table 5: Site Coordinates

Central Latitude /Longitude Degrees Minutes Seconds South 28° 13’ 52.50” East 31° 05’ 22.14” North West Corner Latitude /Longitude Degrees Minutes Seconds South 28° 13’ 35.27” East 31° 05’ 08.85” South west Corner Latitude /Longitude Degrees Minutes Seconds South 28° 13’ 48.83” East 31° 04’ 59.88” North East Corner Latitude /Longitude Degrees Minutes Seconds South 28° 13’ 54.43” East 31° 05’ 45.34” South East Corner Latitude /Longitude Degrees Minutes Seconds South 28° 14’ 05.99” East 31° 05’ 39.53”

2.2.3. Access / Directions Externally, access to the greater area of the BGR is via access from the south via the R68; and an access from the north via the R34. Internally, no private vehicle will be allowed, and the Babanango Travellers Camp will have internal low impact road access. While not forming part of this application, the following is planned for access to the BGR, and will be applied for at the required time: Southern Access Via the R68 The proposal is to utilise the existing un-surfaced road (D139) that runs from the R68 to the west of the town of Babanango and terminates at the Babanango Valley Lodge. This road is a high- quality local access road approximately 6 – 7m wide. In addition to providing access to the existing Lodge, it provides access to a small local settlement and a number of farmsteads. Currently very few vehicles were seen while travelling on this road (Environmental Planning and Design, 2018). Northern Access Via the R34 The proposal is to utilise the existing un-surfaced road that runs from the R34 through Zulu Rock directly to the existing Farmstead / proposed Reserve Service Centre and to the Zulu Rock Lodge

/ proposed Visitor Reception Centre. This access would provide easy access to Vryheid and to battlefields sites for visitors. The access from the R34 is existing. The internal road is a well maintained un-surfaced road that is likely to require upgrading (Environmental Planning and Design, 2018). Internal reserve routes are likely to include the following:

• Upgrading of existing tracks and roads; • New access roads; and • River and stream crossings. 2.2.4. Dimensions of the Activity The extent of the total building area for the BTC is 5640m2, refer to Appendix C for the full area schedule. Total Development Area (including uncovered walkways and vehicle circulation is 8579m2, thus the total site area is 46.3ha. The following table presents the planned development area per development. Table 6: Dimensions of development

2.2.5. Surrounding Land Uses Natural area Y Light industrial N Low density residential Y Medium industrial N Medium density residential Y Heavy industrial N High density residential N Power station N Informal residential Y Military or police base/station/compound N Retail commercial & warehousing N Spoil heap or slimes dam N Office/consulting room N Dam or reservoir Y

Quarry, sand or borrow pit N Hospital / medical centre Y School Y Tertiary education facility N Church Y Old age home N Sewage treatment plant N Train station or shunting yard N Railway line N Major road (4 lanes or more) N Harbour N Plantation N Sport facilities N Agriculture N Golf course N River, stream or wetland Y Polo fields N Nature conservation area Y Filling station Y Mountain, koppie or ridge Y Landfill or waste treatment site N Museum N Historical building N Protected Area Y Graveyard P Archaeological site P Airport N Other: N Key: Y = Yes P = Possibly N = No

2.3. Project Motivation and Need and Desirability Table 7: Proposed project need, desirability and benefits

Project Need 1. Was the relevant provincial planning department involved in the application? YES NO Does the proposed land use fall within the relevant provincial planning framework? 2. The proposed development is a design in soft engineering and eco-lodges, which YES will also be in line with the types of development acceptable for the Babanango Game Reserve.

If the answer to questions 1 and / or 2 was NO, please provide further motivation / 3. Explanation Desirability Does the proposed land use / development fit the surrounding area? 1. YES The proposed development is low impact eco-lodges and supporting infrastructure. Does the proposed land use / development conform to the relevant structure plans, SDF and planning visions for the area?

2. The site does not fall within the formal town planning scheme and is therefore not YES zoned. Given the natural state of the site, the proposed BTC is designed to be of minimal impact, leaving no impact if removed, in line with current eco-design “glamping.” 3. Will the benefits of the proposed land use / development outweigh the YES 13

negative impacts of it? It is believed that if constructed responsibly and in compliance with the Environmental Management Programme (EMPr), the project will not have any significant negative impacts, and that the minor negative impacts can be avoided / mitigated to satisfactory level. Indeed, the benefits outweigh any negatives as community upliftment will be ensured to these indigent communities. If the answer to any of the questions 1-3 was NO, please provide further motivation / 4. Explanation – N/A. Will the proposed land use / development impact on the sense of place?

5. It is believed that the proposed development will have a positive impact on the YES NO sense of place. The BTC will facilitate the promulgation of the BGR and the stewardship thereof. Will the proposed land use / development set a precedent? 6. NO The BTC itself is not expected to set a precedent. Will any person’s rights be affected by the proposed land use / development? 7. NO All neighbouring landowners have been notified. 8. Will the proposed land use / development compromise the “urban edge”? NO If the answer to any of the question 5-8 was YES, please provide further motivation / 9. explanation – The answer to question 5 was yes due to a positive impact. Benefits 1. Will the land use / development have any benefits for society in general? YES NO 2. Explain: The project will generate several jobs and opportunities for the surrounding community. Will the land use / development have any benefits for the local 3. YES communities where it will be located? Explain: The project will provide jobs while sustaining the natural habitat of the “Big 5” under the 4. BGR.

2.4. Socio-Economic Value of the Activity The social-economic value of the project is illustrated below.

Table 8: Socio-economic value of the proposed project

Description Value What is the expected capital value of the activity on R10 million completion?

What is the expected yearly income that will be generated R20 million by or as a result of the activity? Will the activity contribute to service infrastructure? Yes Is the activity a public amenity? Yes How many new employment opportunities will be created 50

in the development phase of the activity? What is the expected value of the employment R400 000 – R500 000 opportunities during the development phase? What percentage of this will accrue to previously Although a contractor has yet to be disadvantaged individuals? appointed, we believe that due to majority of the work being undertaken with local labour that at least 80-90% will accrue to previously disadvantaged individuals How many permanent new employment opportunities will Approximately 100 be created during the operational phase of the activity? What is the expected current value of the employment Approximately R600 000 opportunities during the first 10 years? What percentage of this will accrue to previously 100% disadvantaged individuals?

3. Technical Data There is a set of regulations incorporating Building and Contractor regulations for development within the Reserve. It is noted that these are not expected to impact on the structural design for the buildings within the Architectural scheme as presented to date. Suffice to say that care and attention needs to be made in the conceptual design phase to economise, and act with sensitivity to the site location when decisions are made as to materials and methods of construction. The Conceptual design and engineering report was completed by Andrew Jamieson (Pr Tech Eng 2008 70008), of NJV CONSULTING (PTY) LTD Consulting Engineers & Project Managers. Numerous materials will be used for the development of the BTC and associated services, such as timber, steel and concrete. The full reports can be found in Appendix D8.

3.1. The Conceptual Engineering Scheme 3.1.1. Particular Building Guidelines of the Babanango Game Reserve

The Front of House complex will comprise composite buildings constructed of variously loadbearing walls, steel and timber support structure, with structural steelwork framed feature roofs and walkways comprising timber boarded canopies. The raised deck that will form the floor level of these buildings will be a timber deck structure suspended off the natural ground levels below.

Columns and shear walls will be connected onto concrete plinths and stub columns off the foundations. Fenestration and sliding/folding glazed screens will be co-ordinated to be supported within the structural modularisation methodology.

The individual residents units will comprise a structural steelwork frame off which the overhead stretch tend canopies are attached, and the tent unit suspended below. The raised deck that will

form the floor level of these units will be a timber deck structure suspended off the natural ground levels below.

The Back of House buildings will comprise traditional loadbearing brick walls supported off strip footings. The roof format for these buildings will be either sheeting roof or reinforced concrete slabs. 3.1.2. Pool Structure It is envisaged that a structural box format will be used for the approach to the pool structure. This can be achieved either with a shuttered and cast wall system, or alternatively and reinforced infill masonry structural wall system. It is envisaged that the pool based will be supported onto a series of RC columns in turn supported at bedrock level on spot bases. 3.1.3. Floors, Foundations and Reinforced Concrete All columns will be supported off concrete pad footings designed in accordance with the ground pressure limitations recommended in the Geotechnical report, and the general typology foundation systems described above. Generally it is not anticipated that there will be significant concrete structure above ground level. Where necessary, walls will be supported off reinforced concrete footings cast onto adequately compacted layer works. Floors have been discussed as either of the following:

• Raised timber decks. These have the advantage of allowing underfloor reticulation of services. Spans and in particular, cantilvere spans, may require structural steelwork frames at floor level. • On grade concrete surface beds. 3.1.4. Earthworks Due to the sensitive nature of the area to be developed, very limited earthworks, consisting mainly of localised levelling is envisaged. The geotechnical report indicates that shallow excavation is expected to be easy and as such the limited earthworks could potentially be undertaken using manual labour rather than mechanical equipment. Any new roads will be designed as a cambered gravel road as per Draft TRH 20. The Structural Design, Construction and Maintenance of Unpaved Roads. Side drains will be used where natural dispersion of surface water is disrupted, as the concentration of stormwater is the root cause of erosion. The side drains should run parallel to the road, collecting the surface water from the pavement and shoulders and removing it through mitre drains (or turnouts) as far from the road as practically possible, where it can soak into the ground or flow into a natural drainage course without influencing the road structure. The distance between mitre drains (which need not necessarily always be associated with sidedrains) depends on their grade with a smaller spacing on flat grades and greater spacing (not far enough to cause excessive flow velocities) between them on steeper grades. The principle is to place the mitre drains at intervals which avoid ponding adjacent to the road but not far apart enough to allow the build-up of high concentrations and flow velocities which lead to scouring. The width of mitre banks should generally be 1 to 1,5 metres. The importance of the road surface being raised above the surrounding area is obvious. When the surrounding area is higher than

the road surface, the road becomes the drain during periods of heavy rainfall and rapidly becomes deformed or even impassable if the water soaks in. 3.1.5. Bulk Water The source of potable water will be from two existing boreholes off site which will be pumped to elevated tanks and pressurised with a variable speed pump system to the main lodge, tented units, wellness centre and staff accommodation. GCS report reference 20-0409 (Tented Camp Water Supply – Babanango Game Reserve, KwaZulu Natal) dated 02 June 2020 indicates that the two boreholes TC BH1 and TC BH2 will provide a total volume of 17,136 litres of water per day. The water reticulation will be designed as per the indicated in the “Guidelines for the Provision of Engineering Services and Amenities in Residential Township Development”. The design criteria used is SANS 10252-1. An allowance of 150l/day/occupant has been used in the water demand calculations for staff and 250l/day/ occupant for guest. The internal water pipes will be sized to cater for the proposed developments peak water demand and fire requirements. The internal water reticulation system will be a pressure main with the twin booster connection and water meter remaining in its current position.. Below is a summary of the development areas:

Table 9: Summary of the development areas:

The following are assumed: 1. Demand rates are according to SANS 10252-1 2. Reticulation losses assumed at 20%

3.1.6. Stormwater The design intent is to create landscaping commensurate with the existing bushland and there is no intention to create berms or other such natural features which would change the natural stormwater runoff in open areas. Open timber decks are intended to be open jointed such that 17

the rainwater runoff simply drains onto the ground below and drains away naturally or percolates into the ground. Stormwater management is therefore limited to:

• The water draining off the roof structures. There are no gutters on the roofs, which are monopitched towards back of house and allow a sufficient overhang from the building walls to allow for runoff from the roof to fall directly onto the ground. • At the ground line zone strip that will be situated under the roof edge, the Architectural treatment will be such that the landscaping can accept this runoff without degradation or erosion and the rainwater will be allowed to fall away from the building without concentration into the natural soils surrounding the lodge complex. • Any areas that require concentrated collection of stormwater as a result of design development, will be piped using a below ground piped system to a stormwater stormwater soakaway, which will then slowly percolate into the ground below. The criteria of 1m³ attenuation provided for every 40m² of hardened property area has been used, which results the following stormwater soakaway volumes and sizes:

Table 10: Stormwater soak away volumes and sizes

3.1.7. Sewer The waste water effluent from each unit will be gravity fed to a series of lift pit sumps positioned at suitable locations. Waste from the sumps will be pumped up to a centrally located sewage treatment plant.

The Sewage treatment plant will consist of the following:

Primary Anaerobic Septic Tanks

There will be a three stage 15,000L Septic Tank consisting of 3 x 5000L chambers. The septic tank will start the biological anaerobic process of breaking down solid partials allowing for setting and separation.

Lift Pumps

Two Lift pumps will be installed in the third chamber of the septic tank. The reason for this is twofold. Firstly it allows a controlled flowrate to be passed to the Secondary Aerobic Bio-Reactor stage. Secondly it allows a positive feed pressure to push through a Screen Filter.

Upfront Screen Filter.

This will be a serviceable stainless steel basket to screen out particles that may have passed the septic tank stage. This will protect the bio reactors and improve efficiency of the plant.

Secondary Aerobic MBBR Bio-Reactors

This will consist of 2 x 5000L Bio-Reactors. The bio-reactors will allow for an aerobic bacterial treatment. The reactors will be fitted with a Double Rotary Vein Oxygen Blower that will pump oxygenated air to a Fine Bubble Diffuser which will infuse oxygen into the water. The reactor contains a biofilm carrier media that naturally breaks down waste water and Reduces BOD’s, COD’s Ammonia and Nitrate Levels.

Clarifier

A 2500L Clarifier will be installed to allow settlement of any fine particulate passing the Bio reactors. A submersible pump will be installed at the bottom of the Clarifier. This will pump activated bacterial sludge back to the front of the Septic Tank Anaerobic Stage.

Disinfection Tank

The disinfection stage will consist of a 2500L tank fitted with a side stream chlorination system. A small pump will circulate water from the bottom of the tank and an ORP sensor will measure the residual chlorine in the water. The Sensor Probe is connected to a digital chemical dosing pump with ORP controller. The controller will signal the dosing pump to control to required set point ensuring that the water in the disinfection tank remains disinfected and sterile. 19

Filtration Plant

As a final filtration and treatment process. Water will be filtered using FRP Vessel charged with AFM® media. AFM® Activated Glass Filter Media is a direct replacement for sand, doubling the performance of sand filters and reducing the required Chlorine concentrations. AFM® resists biofouling, bio coagulation and transient wormhole channelling of unfiltered water. AFM® never needs to be recharged or replaced for the lifespan of the filtration plant. Conventional Sand would typically need to be replaced every one or two years. The Filter Vessel will be fitted with an Auto Backwash Valve Head which will be programmed to backwash the filter automatically once a day.

Activated Carbon Filtration will be done using a FRP Vessel charged with activated carbon media. The carbon will improve the smell, taste and colour of the water but also more importantly reduce the residual Chlorine in the Water from the disinfection process. The Filter Vessel will be fitted with an Auto Backwash Valve Head which will be programmed to backwash the filter automatically once a day.

Final Treated Water Tank

Water from the filtration plant will flow into a 5000L final treated water tank for Non – Potable Use such as Toilet Flushing, Washing Machines / Laundry or Irrigation. The tank will be fitted with a Level Control valve such that if there is insufficient water supplied from the Sewage Treatment Plant the system will be toped up with Water from the Water Treatment Plant.

Boost Pump

The system will be fitted with a 2.2kW Boost Pump complete on base plate with associated valves, inline strainer, Non Return Valve, Hydrosphere Bladder tank and Automatic Pressure Controller.

Manual Bypass Valve.

A manual bypass valve will be installed across the treatment system for redundancy and back up. This will enable water from the water treatment plant boost pump to supply the toilets in an emergency situation.

(Refer to Annexure A of the Engineering Services Report in Appendix D of this cBAR for the Proposed Sewer Layout)

The sewer reticulation will be designed as per the indicated in the “Guidelines for the Provision of Engineering Services and Amenities in Residential Township Development”. The design criteria used is SANS 10252-1. An allowance of 200l/day/occupant has been used in the sewer demand calculations.

In terms of the layout provided and the likely maximum occupancy of the development, the effluent loading based on the Code of Practice for the application of National Building Regulations SABS 0400 of 1990 and the Building Standard Act No.103 of 1997, is estimated to be the following;

Table 11: Effluent loading based on the likely maximum occupancy of the development

3.1.8. Recycling and Solid Waste A plastic shredder with the capacity of ±350kg/per hour will be used to cut down all waste collected from bins positioned in areas all around the site. The waste will be then collected and recycled as necessary.

A vertical baler with the capacity of ±600kg/per hour will be used to compress paper, plastic, cans and cardboard collected from bins positioned in areas all around the site. This compressed material will then be recycled.

A glass crusher with the capacity of ±80kg/per hour will be used to crush glass, bottles and other glass items that will be collected from bins positioned in areas all around the site. The crushed glass will then be then collected and recycled.

An earth probiotic composter will be used to handle all biodegradable waste such as food via a regulated mechanical process that provides quality fertilizer in a minimized time frame. This would create sustainable compost for farming areas. The composter produces on average 5000kg’s per month.

3.1.9. Electrical Provision The estimated total diversified power requirement for Travellers’ Camp is calculated to be 270kVA. This calculation is based on the latest architectural layouts and the preliminary power requirements received from Luxury Frontiers.

The local supply authority is ESKOM. An application has been submitted to ESKOM for a bulk 22kV supply of 500kVA which will feed the Travellers’ Camp. The proposed ESKOM point of supply is located at 31° 6'44.68"E / 28°11'12.21"S. Refer to Error! Reference source not found.. The ESKOM application reference number is 299045697.

Figure 4: Proposed Eskom Off-take point

Power will be reticulated from ESKOM’s point of supply to the Travellers’ Camp site using a combination of 22kV overhead line and 22kV underground cable. Refer to Figure 5. The estimated length of the bulk power supply line from ESKOM’s point of supply to Travellers’ Camp is 8km.

Figure 5: Power Reticulation from Eskom Point of Supply to the BTC site (and passing through the other proposed Madwaleni lodge (applied for under a separate application)).

Travellers’ Camp will have a miniature substation installed to step the supply voltage down from 22kV to 415V. Power will then be reticulated internally at 415V. The following miniature substation is proposed for Travellers’ Camp:

a) Specification: 315kVA, 22kV/415V, DYN11 oil transformer; 12kV 3way ring main unit, coastal treatment, light brown colour, concrete plinth mounted b) Dimensions: 3200mm (long) x 1445mm (wide) x 2200mm (high) c) Location: Behind main building

A formal response from ESKOM confirming the suitability of the proposed point of supply and the availability of spare capacity on their existing distribution network to accommodate the estimated 270kVA power requirement for Travellers’ Camp, is outstanding.

A standby 300kVA diesel generator will be installed adjacent to the minisub and will provide backup power for the entire lodge site (NJV, 2020).

3.1.10. Pedestrian Bridge over Tributary Basis of Design and Motivation

A pedestrian bridge (annotated and illustrated in Figure 6) is required over the tributary to the West of the BTC lodge to allow safe on grade passage for Clients to visit the Wellness Centre

Complex. The total reach of the suspended bridge in the position indicated by the Architect is some 47m long end to end.

The estimated coordinates of river abutments / pillars

▪ C1 = Y: 8547.992, X:-3123793.838 ▪ C2 = Y: 8556.849, X:-3123798.482 ▪ C3 = Y: 8570,267 X:-3123805.188 ▪ C4 = Y: 8579.184, X:-3123809.714

The height of the structure (the vertical difference between the lowest downstream ground elevation on the structure and the crest level or the general top level of the structure)

▪ 4355mm NGL to the underside of the bridge walkway ▪ 8090mm NGL to the highest point of the bridge

The width of the structure at its widest point is: 2600mm / 2.6m. The length of the structure is 47 000mm/ 47m.

Figure 6: Pedestrian Bridge Annotation and illustration (inset)

The narrow, straight, bridge structure is positioned for walking access by pedestrians over the tributary (location defined elsewhere). It is an open walkway with requisite handrails and safety aspects considered elsewhere by the Architect. The bridge will be flat, or near flat and will be accessible at both ends off grade. The form of the structure will be featured architecturally.

Due to economics of design and also buildability, at least two primary support pillars will be located within the 1 in 100 year flood line levels.

Additionally, water supply pipes and an electrical supply conduit will be underslung below the walkway, out of reach other than for maintenance and adequately protected.

Form of Structure

The bridge structure is conceptually designed as free spanning structural steelwork truss and beam structure supported off primary bridge pillars supported on the insitu rock (refer to Figure

7). Comprising a twin pair of beams located below the timber decking which are horizontally connected to form a horizontal truss, the twin beams will be structurally jointed (for expansion) and terminated to ground (for longitudinal stability) at either end.

The bridge pillars will terminate on fin shaped reinforced concrete abutments within the 1:100 flood line, which will be drill dowelled directly into the gross rock-bed of the tributary.

Materials

The reinforced concrete abutment sections at ground will be approximately 2m high and will be orientated and shaped in accordance with the flow direction of the tributary. The primary bridge structure is conceptualised as a mix of mild steel, painted with a suitable exterior paint specification, and Corten steel which will be left bare to patina. The secondary structure and deck will be timber of a suitable exterior grade. Handrails along both sides will either be steel or timber.

Interface with the Ground

A strategy of minimal interruption will be applied to the design and construction of the abutments. It is envisaged that the pouncing points of the abutments will be identified on site as the most suitable, bare intact rock. A pattern of rock drilled dowels will be utilised to anchor the abutment directly to the rock, so it is envisaged that there will be no visible foundations and minimal interruption to the immediate environs of the tributary.

Figure 7: Conceptual Design of Pedestrian Bridge

3.2. Design Standards and Sources of Reference Statutory Regulations and Bye-Laws Reference is made to the local municipalities building guidelines and controls. Statutory Regulations and Bye-Laws ▪ SANS 10160: 2008 o Basis of structural design and actions for buildings and industrial structures. o Parts 1 to 8 ▪ SANS 10100-1 Ed.2.2 o The structural use of concrete Part 1: Design ▪ SANS 10100-2 o The structural use of concrete Part 2: Materials and execution of work ▪ SANS 10144-1995 o Detailing of steel reinforcement for concrete ▪ SANS 10162-1: 1993 o The limit states design of hot rolled steelwork ▪ SABS 0164 Part 1-1980 o The structural use of masonry Part 1: Unreinforced masonry walling ▪ SANS 2001-CS1:2005 o Construction works Part CS1: Structural steelwork ▪ SANS 0163-1:1994 o The Structural use of Timber Refer to Appendix D8 for the full Engineering Services Report which includes imposed conditions such design loadings and Other Performance Requirements.

4. Environmental Legislative Context In order to protect the environment and ensure that the development is undertaken in an environmentally responsible manner, there are a number of significant pieces of environmental legislation that need to be considered during this study. These include the following items of legislation.

4.1. The Constitution of South Africa Section 24 of the Constitution of South Africa (No. 108 of 1996) states that

“…everyone has the right – … (a) to an environment that is not harmful to their health or well-being; and … (b) to have the environment protected, for the benefit of present and future generations through reasonable legislative and other measures that … (c) secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.”

This protection encompasses preventing pollution and promoting conservation and environmentally sustainable development. These principles are embraced in the NEMA and given further expression.

4.2. National Environmental Management Act (Act No. 107 of 1998) The National Environmental Management Act (Act No. 107 of 1998) (as amended), or otherwise known as NEMA, is South Africa’s overreaching environmental legislation and has, as its primary objective to provide for co-operative, environmental governance by establishing principles for decision-making on matters affecting the environment, institutions that will promote co-operative governance and procedures for co-ordinating environmental functions exercised by organs of state, and to provide for matters connected therewith.

The principles of the Act are the following:

▪ Environmental management must place people and their needs at the forefront of its concern; ▪ Development must be socially, environmentally and economically sustainable; ▪ Environmental management must be integrated, acknowledging that all elements of the environment are linked and interrelated; ▪ Environmental justice must be pursued so that adverse environmental impacts shall not be distributed in such a manner as to unfairly discriminate against any person; ▪ Equitable access to environmental resources, benefits and services to meet basic human needs and ensure human well-being must be pursued; ▪ Responsibility for the environmental health and safety consequences of a policy, programme, project or activity exists throughout its life cycle. ▪ The participation of all interested and affected parties in environmental governance must be promoted; ▪ Decisions must take into account the interests need and values of all interested and affected parties, and this includes recognizing all forms of knowledge including traditional and ordinary knowledge; ▪ Community well-being and empowerment must be promoted through environmental education, the raising of environmental awareness; ▪ The social, economic and environmental impacts of activities including disadvantages and benefits, must be considered, assessed and evaluated and decisions must be appropriate in the light of such consideration and assessment; ▪ The right of workers to refuse work that is harmful to human health or the environment; ▪ Decisions must be taken in an open and transparent manner, and access to information must be provided in accordance with the low; ▪ There must be intergovernmental co-ordination and harmonisation of policies, legislation and actions relating to the environment; 28

▪ The environment is held in public trust for the people, the beneficial use of the environment resources must serve the public interest and the environment must be protected as the people’s common heritage; ▪ The cost of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment; and ▪ The vital role of women and youth in environmental management and development must be recognised and their full participation therein must be promoted. 4.2.1. EIA Regulations (2014) (as amended in 2017) On April 7th 2017, the Minister of Environmental Affairs, Bomo Edith Edna Molewa, made amendments to the EIA Regulations, 2014, published under Government Notice No. 982 in Gazette No. 3822 of 4 December 2014, in terms of sections 24(5) and 44 of the NEMA, 1998 (Act No. 107 of 1998), as well as to Listing Notice 1 of 2014, published under Government Notice No. 983 in Gazette No. 38282 on 4 December 2014, as well as Listing Notice 2 of 2014, published under Government Notice No. 984 in Gazette No. 38282 on 4 December 2014, and Listing Notice 3 of 2014, published under Government Notice No. 985 in Gazette No. 38282 on 4 December 2014 in terms of sections 24(2), 24(5), 24D and 44, read with section 47A(1)(b) of the NEMA, 1998 (Act No. 107 of 1998). For ease of reading, the 2017 Amendments of the EIA Regulations, 2014 are published in full, inclusive of amendments made thereto. These amendments commenced on the date that these regulations were published in the Gazette, 07 April 2017.

The nature of the proposed project includes activities listed in the following Listing Notice – GNR 327 (Listing Notice 1) of the EIA Regulations (2014 as amended in 2017) – refer to Error! Reference source not found. below.

Table 12: Applicable Listed Activities According to Listing Notices 1, 2 and 3 of the EIA Regulations 2014 (2017 Amendment)

Indicate the Provide the relevant Activity (ies) as set out in Describe each listed activity as per the Activity Listing Notice 1, 2 & 3 (GN R327, GNR325 & project description (and not as per wording Number: GNR324) of the relevant Government Notice)2: GNR 327 The development of— The facilities / structures proposed will exceed Activity 100m2 and in some cases be located within 12(ii) (c) (i) dams or weirs, where the dam or weir, 32m of the White Mfolozi River. including infrastructure and water surface area, exceeds 100 square metres; or

2Please note that this description should not be a repetition of the listed activity as contained in the relevant Government Notice, but should be a brief description of activities to be undertaken as per the project description, i.e. describe the components of the desired development. 29

(ii) infrastructure or structures with a physical footprint of 100 square metres or more; where such development occurs— (a) within a watercourse; (b) in front of a development setback; or (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse; — excluding— (aa) the development of infrastructure or structures within existing ports or harbours that will not increase the development footprint of the port or harbour; (bb) where such development activities are related to the development of a port or harbour, in which case activity 26 in Listing Notice 2 of 2014 applies; (cc) activities listed in activity 14 in Listing Notice 2 of 2014 or activity 14 in Listing Notice 3 of 2014, in which case that activity applies; (dd) where such development occurs within an urban area; (ee) where such development occurs within existing roads, road reserves or railway line reserves; or (ff) the development of temporary infrastructure or structures where such infrastructure or structures will be removed within 6 weeks of the commencement of development and where indigenous vegetation will not be cleared. GNR 327 The development and related operation of Applicable for the storage of diesel on site for Activity 14 facilities or infrastructure, for the storage, or for the operations and power provision. The combined storage and handling, of a dangerous good, storage (for the BTC and the other proposed where such storage occurs in containers with a Madwaleni Lodge) will not exceed 500m3 combined capacity of 80 cubic metres or more but not exceeding 500 cubic metres. GNR 327 The infilling or depositing of any material of more A pedestrian bridge is required over the Activity 19 than 10 cubic metres into, or the dredging, tributary to the West of the BTC lodge to allow excavation, removal or moving of soil, sand, safe on grade passage for Clients to visit the

shells, shell grit, pebbles or rock of more than 10 Wellness Centre Complex. The total reach of cubic metres from a watercourse; the suspended bridge in the position indicated by the Architect is some but excluding where such infilling, depositing, dredging, excavation, removal or moving— 45m long end to end. The narrow, straight, bridge structure is positioned for walking (a) will occur behind a development setback; access by pedestrians

(b) is for maintenance purposes undertaken over the tributary (location defined elsewhere). in accordance with a maintenance It is an open walkway with requisite handrails management plan; and safety aspects considered elsewhere by (c) falls within the ambit of activity 21 in this the Architect. The bridge will be flat, or near flat Notice, in which case that activity applies; and will be accessible at both ends off grade. (d) occurs within existing ports or harbours The form of the structure will be featured that will not increase the development architecturally. Due to economics of design and footprint of the port or harbour; or also buildability, at least two primary support (e) where such development is related to the pillars will be located within the 1 in 100 year development of a port or harbour, in which flood line levels. case activity 26 in Listing Notice 2 of 2014 applies. Water supply pipes and electrical supply conduit will be underslung below the walkway, out of reach other than for maintenance and adequately protected. The above will require infilling into the tributary. GNR 327 The development and related operation of The waste water effluent from each unit will be Activity 25 facilities or infrastructure for the treatment of gravity fed to a series of lift pit sumps effluent, wastewater or sewage with a daily positioned at suitable locations. Waste from throughput capacity of more than 2 000 cubic the sumps will be pumped up to a centrally metres but less than 15 000 cubic metres. located sewage treatment plant. The Sewage treatment plant will consist of the following; Primary Anaerobic Septic Tanks There will be a three stage 15,000L Septic Tank consisting of 3 x 5000L chambers. The septic tank will start the biological anaerobic process of breaking down solid partials allowing for setting and separation. The septic tank treatments process will also include Lift Pumps, Upfront Screen Filter, Secondary Aerobic MBBR Bio-Reactors, Clarifier, Disinfection Tank, Filtration Plant, Activated Carbon Filtration, Final Treated Water Tank, Boost Pump, Manual Bypass Valve. Full explanation on the operation of the septic take is provided in the Basic Assessment Report. GNR 324 The development of resorts, lodges, hotels, The Travelers Camp will accommodate more Activity tourism or hospitality facilities that sleeps 15 than 15 people in a hospitality facility under the 6 [d] [v] [i] people or more. sensitive areas applied for in preceding [vi][ii][aa][cc] d. KwaZulu-Natal columns.

i. In an estuarine functional zone; ii. Trans-frontier protected areas managed under international conventions; iii. Community Conservation Areas; iv. Biodiversity Stewardship Programme Biodiversity Agreement areas; v. A protected area identified in terms of NEMPAA, excluding conservancies; vi. Sites or areas identified in terms of an international convention; i. Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; ii. Core areas in biosphere reserves; iii. World Heritage Sites; iv. Areas designated for conservation use in Spatial Development Frameworks adopted by the competent authority or zoned for a conservation purpose; v. Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority; vi. Outside urban areas: (aa) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any terrestrial protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; (bb) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined; or (cc) Areas within a watercourse or wetland; or within 100 metres from the edge of a watercourse or wetland; or vii. Inside urban areas: 32

(aa) Areas zoned for use as public open space; (bb) Areas seawards of the development setback line or within 100m from the high- water mark of the sea if no such development setback line is determined; or (cc) Areas within 500 metres from terrestrial protected areas identified in terms of NEMPAA. GNR 324 The clearance of an area of 300 square metres The removal of 300m2 of vegetation will be Activity or more of indigenous vegetation except where removed for the development of the proposed 12 [d] [v] such clearance of indigenous vegetation is travellers camp. This will be applicable for [viii] [xii] required for maintenance purposes undertaken in removal of vegetation within the CBA’s. accordance with a maintenance management plan. d. KwaZulu-Natal i. Trans-frontier protected areas managed under international conventions; ii. Community Conservation Areas; iii. Biodiversity Stewardship Programme Biodiversity Agreement areas; iv. Within any critically endangered or endangered ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004; v. Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; vi. Within the littoral active zone or 100 metres inland from high water mark of the sea or an estuarine functional zone, whichever distance is the greater, excluding where such removal will occur behind the development setback line on erven in urban areas; vii. On land, where, at the time of the coming into effect of this Notice or thereafter such land was zoned open space, conservation or had an equivalent zoning;

viii. A protected area identified in terms of NEMPAA, excluding conservancies; ix. World Heritage Sites; x. Sites or areas identified in terms of an international convention; xi. Areas designated for conservation use in Spatial Development Frameworks adopted by the competent authority or zoned for a conservation purpose; xii. Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority; or xiii. In an estuarine functional zone.

GNR 324 The development of— Infrastructure of 10m2 and more will be Activity 14 developed for the development of the (i) dams or weirs, where the dam or weir, [ii] [c] within proposed travellers camp. including infrastructure and water surface [d] [iv] [vii] area exceeds 10 square metres; or [xi] (ii) infrastructure or structures with a physical footprint of 10 square metres or more; where such development occurs— [a] within a watercourse; [b] in front of a development setback; or [c] if no development setback has been adopted, within 32 metres of a watercourse, measured from the edge of a watercourse; excluding the development of infrastructure or structures within existing ports or harbours that will not increase the development footprint of the port or harbour. d. KwaZulu-Natal i. In an estuarine functional zone; ii. Community Conservation Areas; iii. Biodiversity Stewardship Programme Biodiversity Agreement areas; iv. A protected area identified in terms of NEMPAA, excluding conservancies; v. World Heritage Sites; vi. Sites or areas identified in terms of an international convention; vii. Critical biodiversity areas or ecological support areas as identified 34

in systematic biodiversity plans adopted by the competent authority or in bioregional plans; viii. Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority; ix. Core areas in biosphere reserves; x. Outside urban areas: (aa) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any terrestrial protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or (bb) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined; or xi. Inside urban areas: (aa) Areas zoned for use as public open space; (bb) Areas designated for conservation use in Spatial Development Frameworks adopted by the competent authority, zoned for a conservation purpose; or (cc) Areas seawards of the development setback line or within 100 metres from the high-water mark of the sea if no such development setback line is determined.

4.3. National Water Act (Act No. 36 of 1998) (as amended) The National Water Act (NWA) is a legal framework for the effective and sustainable management of water resources in South Africa. Central to the NWA is recognition that water is a scarce resource in the country, which belongs to all the people of South Africa and needs to be managed in a sustainable manner to benefit all members of society. The NWA places a strong emphasis on the protection of water resources in South Africa, especially against its exploitation, and the

insurance that there is water for social and economic development in the country for present and future generations. Water use in South Africa is managed through a water use authorisation process, which requires that every water use is authorised by the Department of Water and Sanitation (DWS, previously known as the Department of Water Affairs) or an established Catchment Management Agency (CMA, if applicable for that region), once the water requirements for the Reserve have been determined. A water use must be licenced unless it (a) is listed in Schedule 1, (b) is an existing lawful use, (c) is permissible under a general authorisation (GA), or (d) if a responsible authority waives the need for a licence. If none of these are relevant a so-called water use licence (WUL) must be applied for and obtained prior to the commencement of such listed activity. In terms of such a WUL, the Minister may choose to limit the amount of water, which a responsible authority (e.g. CMA, water board, municipality) may allocate. In making regulations and determining items such as GAs, the Minister may differentiate between different water resources, classes of water resources, and geographical areas. The NWA defines a water resource to be a watercourse, surface water, estuary, or groundwater (aquifer). Included under surface water are manmade water channels, estuaries and watercourses. The proposed development will trigger water uses (a), (c), (g) and (i) under Section 21 of the NWA. The following water uses of Section 21 of the NWA are being applied for: (a) Taking water from a watercourse; (c) Impeding or diverting the flow of water in a watercourse; (g) Disposing of waste in a manner that may detrimentally impact a water resource; and (i) Altering the bed, banks, course, or characteristics of a watercourse The Department of Water and Sanitation will receive a copy of this cBAR for comment, as well as act as the Competent Authority for the issue of a Water Use Licence. 4.4. National Environmental Management: Biodiversity Act (Act No. 10 of 2004) The project must comply with the National Environmental Management: Biodiversity Act (Act No. 10 of 2004) (NEM: BA) in providing the cooperative governance in biodiversity management and conservation.

NEM: BA provides for the Minister to publish a notice in the Government Gazette that issues norms and standards, and indicators for monitoring progress for the achievement of any of the objectives of the Act.

The NEM: BA also provides for: ▪ The National Biodiversity Framework;

▪ Bioregional Plans; ▪ Biodiversity Management Plans; ▪ Biodiversity Management Agreements; ▪ The identification, listing and promotion of threatened or protected ecosystems; and ▪ Alien invasive species control and enforcement.

No protected areas have been identified within the study area.

4.4.1. National Spatial Biodiversity Assessments (2004, 2011) This informs the policies, plans and day-to-day activities of a wide range of sectors both public and private. A spatial biodiversity assessment can take place at different spatial scales, from global to local.

It involves mapping information about biodiversity features such as species, habitats and ecological processes, protected areas and current and future patterns of land and resource use. It provides a national context for assessments at the sub national scale and points to broad priority areas where further investigation, planning and action are warranted.

It identifies three keys strategies for conserving South Africa’s biodiversity existence from the assessment, namely:

▪ Pursuing opportunities to link biodiversity and socio-economic development in priority geographic areas; ▪ Focusing on emergency action on threaten ecosystem, to prevent further loss of ecosystem functioning; and ▪ Expanding of the protected area network.

4.4.2. National Biodiversity Strategy and Action Plans (2005) The National Biodiversity Strategy and Action Plans (NBSAP) aims to conserve and manage terrestrial and aquatic biodiversity to ensure sustainable and equitable benefits to the people of South Africa, now and in the future.

In South Africa, terrestrial, inland water, coastal and marine ecosystems and their associated species are widely used for commercial, semi-commercial and subsistence purposes through both formal and informal markets.

While some of this use is well managed and / or is at levels within the capacity of the resource for renewal, much is thought to be unsustainable. “Use” in this case refers to direct use, such as collecting, harvesting, hunting, fishing, etc. for human consumption and production, as well as more indirect use such as ecotourism.

4.4.3. National Environmental Management: Protected Areas Act (Act No. 57 of 2003) Protected areas are a fundamental tool for achieving biodiversity objectives and protecting essential natural heritage areas and ecosystems services, since these often provide greater security for conservation-worthy land than the agreements or land use limitations provided for in the National Environmental Management: Biodiversity Act.

The National Environmental Management: Protected Areas Act (Act No. 57 of 2003) (NEM:PAA) creates a legal framework and management system for all protected areas in South Africa as well as establishing the South African National Parks (SANParks) as a statutory board. Each conservation area will have its own set of land use restrictions or regulations that stem either from generic restrictions under NEM: PAA, or customized regulations for individual protected areas. No protected areas are found within the study area.

4.4.4. KZN Nature Conservation Ordinance (Ordinance No. 15 of 1974) Protected indigenous plants in general are controlled under the relevant provincial Ordinances or Acts dealing with nature conservation.

In KwaZulu-Natal, the relevant statute is the 1974 Provincial Nature Conservation Ordinance. In terms of this Ordinance, a permit must be obtained from Ezemvelo KZN Wildlife to remove or destroy any plants listed in the Ordinance.

No red data species were identified to be impacted by the proposed development.

4.5. National Environmental Management: Waste Act (Act No. 59 of 2008) (as amended) The National Environmental Management Waste Act (Act No. 59 of 2008) (NEM:WA) – the ‘Waste Act’ reforms the law regulating waste management in order to protect health and the environment by providing reasonable measures for the prevention of pollution and ecological degradation and for securing ecologically sustainable development; to provide for institutional arrangements and planning matters; to provide for national norms and standards for regulating the management of waste by all spheres of government; to provide for specific waste management measures; to provide for the licencing and control of waste management activities; to provide for the remediation of contaminated land; to provide for the national waste information system; to provide for compliance and enforcement; and to provide for matters connected therewith.

The objectives of this Act are: a) “to protect health, well-being and the environment by providing reasonable measures for – i. minimising the consumption of natural resources; ii. avoiding and minimising the generation of waste; 38

iii. reducing, re-using, recycling and recovering waste; iv. treating and safely disposing of waste as a last resort; v. preventing pollution and ecological degradation; vi. securing ecologically sustainable development while promoting justifiable economic and social development; vii. promoting and ensuring the effective delivery of waste services; viii. remediating land where contamination presents, or may present, a significant risk of harm to health or the environment; and ix. achieving integrated waste management reporting and planning; b) to ensure that people are aware of the impact of waste on their health, well-being and the environment; c) to provide for compliance with the measures set out in paragraph (a); and d) generally, to give effect to section 24 of the Constitution in order to secure an environment that is not harmful to health and well-being.”

The NEM: WA has been considered; however, no activities have been identified for the proposed development. The EMPr addresses waste management and all construction waste will be disposed of at a registered landfill and not dumped illegally.

4.6. National Heritage Resources Act (Act No. 25 of 1999) In terms of Section 38 of the National Heritage Resources Act (NHRA) (subject to the provisions of subsections (7), (8) and (9) of the Act), any person who intends to undertake a development categorised as:

▪ The construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300 m in length; ▪ The construction of a bridge or similar structure exceeding 50 m in length; ▪ Any development or other activity which will change the character of a site: ▪ Exceeding 5 000 m² in extent; ▪ Involving three or more existing erven or subdivisions thereof; or ▪ Involving three or more erven or divisions thereof which have been consolidated within the past five years; or ▪ The costs of which will exceed a sum set in terms of regulations by the South African Heritage Resource Agency (SAHRA) or a provincial heritage resource authority; ▪ The re-zoning of a site exceeding 10 000 m2 in extent; or ▪ Any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority, must at the very earliest stages of initiating such a 39

development, notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development.

A Heritage Impact Assessment is not required for this project. 4.7. National Forests Act (Act No. 84 of 1998) According to this Act, the Minister may declare a tree, group of trees, woodland or a species of trees as protected. The prohibitions provide that;

‘no person may cut, damage, disturb, destroy or remove any protected tree, or collect, remove, transport, export, purchase, sell, donate or in any other manner acquire or dispose of any protected tree, except under a licence granted by the Minister’. In essence the National Forests Act (NFA) prohibits the destruction of indigenous trees in any natural forest without a licence.

In terms of the NFA and Government Notice 1339 of 6 August 1976 (promulgated under the Forest Act, 1984 (Act No. 122 of 1984) for protected tree species), the removal, relocation or pruning of any protected plants will require a licence.

4.8. Occupational Health and Safety Act (Act No. 85 of 1993) The Occupational Health and Safety Act (OHSA) provides for the health and safety of persons at work and for the health and safety of persons in connection with the use of plant and machinery; the protection of persons other than persons at work, against hazards to health and safety arising out of or in connection with the activities of persons at work.

4.9. National Environmental Management: Air Quality Act (Act No. 39 of 2004) The NEMA Air Quality Management Act (NEM: AQA) states the following as its primary objective:

“To reform the law regulating air quality in order to protect the environment by providing reasonable measures for the prevention of pollution and ecological degradation and for securing ecologically sustainable development while promoting justifiable economic and social development; to provide for national norms and standards regulating air quality monitoring, management and control by all spheres of government, for specific air quality measures, and for matters incidental thereto.

Whereas the quality of ambient air in many areas of the Republic is not conducive to a healthy environment for the people living in those areas let alone promoting their social and economic advancement and whereas the burden of health impacts associated with polluted ambient air falls most heavily on the poor, And whereas air pollution carries a high social, economic and environmental cost that is seldom borne by the polluter, And whereas atmospheric emissions of ozone-depleting substances, greenhouse gases and other 40

substances have deleterious effects on the environment both locally and globally, and whereas everyone has the constitutional right to an environment that is not harmful to their health or well-being, and whereas everyone has the constitutional right to have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures that:

▪ Prevent pollution and ecological degradation; ▪ Promote conservation; and ▪ Secure ecologically sustainable development and use of natural resources.

And whereas minimisation of pollution through vigorous control, cleaner technologies and cleaner production practices is key to ensuring that air quality is improved, and whereas additional legislation is necessary to strengthen the Government’s strategies for the protection of the environment and, more specifically, the enhancement of the quality of ambient air, in order to secure an environment that is not harmful to the health or well-being of people.”

4.10. Hazardous Substance Act (Act No. 15 of 1973) and Regulations The object of the Act is inter alia to

‘provide for the control of substances which may cause injury or ill health to or death of human beings by reason of their toxic, corrosive, irritant, strongly sensitising or flammable nature or the generation of pressure thereby in certain circumstances; for the control of electronic products; for the division of such substances or products into groups in relation to the degree of danger; for the prohibition and control of such substances’.

In terms of the Act, substances are divided into schedules, based on their relative degree of toxicity, and the Act provides for the control of importation, manufacture, sale, use, operation, application, modification, disposal and dumping of substances in each schedule.

Pollution control in South Africa is affected through numerous national statutes, provincial ordinances and local authority by-laws. Only the more significant legislation pertaining to the regulation of water, air, noise and waste pollution is dealt with in this section.

4.11. Sustainable Development The principle of Sustainable Development has been established in the Constitution of the Republic of South Africa (Act No. 108 of 1996) and given effect by NEMA. Section 1(29) of NEMA states that sustainable development means the integration of social, economic and environmental factors into the planning, implementation and decision-making process so as to ensure that development serves present and future generations.

Therefore, Sustainable Development requires that:

▪ The disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied; ▪ That pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied; ▪ The disturbance of landscapes and sites that constitute the nation’s cultural heritage is avoided, or where it cannot be altogether avoided, is minimised and remedied; ▪ Waste is avoided, or where it cannot be altogether avoided, minimised and re-used or recycled where possible and otherwise disposed of in a responsible manner; ▪ A risk-averse and cautious approach is applied, which takes into account the limits of current knowledge about the consequences of decisions and actions; and ▪ Negative impacts on the environment and on people’s environmental rights be anticipated; and, prevented and where they cannot altogether be prevented, are minimised and remedied. 4.12. Climate Change Consideration When considering a development of this nature, it cannot be assessed in isolation of the social and economic aspects, and the triple bottom line must therefore be considered. This section aims to engender a holistic and “business-unusual” approach to the project, with a long-term vision in mind, which considers the impacts of climate change on natural corridors, resilience, vulnerability, mitigation and adaptation. Africa is likely to be the continent most vulnerable to climate change. Among the risks the continent faces are reductions in food security and agricultural productivity, particularly regarding subsistence agriculture, increased water stress and, as a result of these and the potential for increased exposure to disease and other health risks, increased risks to human health (Turpie and Visser, 2014). In South Africa, about 40% of the country’s underprivileged population resides in rural areas and depends either directly or indirectly on land as a source of livelihood. (Turpie and Visser, 2014). Climate change in rural areas will take place in the context of many important economic, social, and land-use trends. Poverty rates in rural areas are higher than overall poverty rates, making this population less resilient to climate change and more indigent, and therefore, the proactive, responsible development of the BGR under the ECT will create resilience and approve adaptability. Rural people in developing countries are subject to multiple non-climate stressors, including under-investment in agriculture (though there are signs this is improving), problems with land and natural resource policy, service delivery and processes of environmental degradation. In developing countries, the levels and distribution of rural poverty are affected in complex and interacting ways by processes of commercialization and diversification, food policies, and policies on land tenure (Dasgupta et al, 2018). The distinctive characteristics of rural areas make them uniquely vulnerable to the impacts of climate change because:

• Greater dependence on agriculture and natural resources makes them highly sensitive to climate variability, extreme climate events, and climate change. • Existing vulnerabilities caused by poverty, lower levels of education, isolation, and neglect by policymakers can all aggravate climate change impacts in many ways. Conversely, rural people in many parts of the world have, over long-time scales, adapted to climate variability, or at least learned to cope with it. They have done so through farming practices and use of wild natural resources (often referred to as indigenous), as well as through diversification of livelihoods and through informal institutions for risk-sharing and risk management. Similar adaptations and coping strategies can, given supportive policies and institutions, form the basis for adaptation to climate change, although the effectiveness of such approaches will depend on the severity and speed of climate change impacts (Dasgupta et al, 2018) Governance arrangements in rural areas are also challenging as authority is demarcated in a dual governance system of traditional authorities and local authorities. This may not always be done democratically. It must be recognized that the situation with respect to rural land rights and traditional authorities is complex and uniform solutions are unlikely to be appropriate in all situations. While the status of communal lands has certainly in many cases acted as an impediment to investment, it has also provided for allocation of land in rural areas to be driven by social rather than market imperatives and provides access to land for households that may not Adaptation to climate change needs to be viewed as an integral part of the broader developmental challenges facing South Africa’s planning and development. But this must also be considered against the backdrop of a declining natural resource base, which warrants innovative and green alternatives to the delivery of services in these communities, and others (DEA, undated), such as those proposed by the BTC.

5. The Study 5.1. Project Alternatives In terms of the EIA Regulations (2014 as amended in 2017), feasible alternatives are required to be considered as part of the environmental investigations. In addition, the obligation that alternatives are investigated is also a requirement of Section 24(4) of the NEMA (Act No. 107 of 1998) (as amended).

An alternative in relation to a proposed activity refers to the different means of meeting the general purpose and requirements of the activity, which may include alternatives to:

▪ the property on which or location where it is proposed to undertake the activity; ▪ the type of activity to be undertaken; ▪ the design or layout of the activity; ▪ the technology to be used in the activity; ▪ the operational aspects of the activity; and ▪ the option of not implementing the activity.

5.1.1. Site and Type of Activity Alternatives No off-site or other site-specific alternatives have been investigated.

5.1.2. Layout and Design Alternatives No layout or design alternatives have been assessed because the design has had eco-design and nature-based design at its core from the outset. However, based on the recommendation of the Watercourse Assessment and floodline Assessment, these tents were retreated outside of the 1:100-year floodline, and the layout was therefore amended.

5.1.3. No-go Alternative The no-go alternative will see the status quo of area remain. This will not be ideal, as the current site is vacant and not well maintained.

Should the status quo remain, the direct and indirect social benefits of the great BGR will not be realised.

5.2. Description of the Study Area 5.2.1. General study area in the BGR

Emcakwini Community Trust Land Conservation Outcomes (CO) have undertaken a significant amount of assessment and planning work in order to position the proposed project so that it can be moved forward towards the Emcakwini Community Trust land being declared a Nature Reserve in accordance with the NEMPAA (Environmental Planning and Design, 2018). Much of the proposed site has been managed for game farming. Also, from discussion a large amount of game remains on or in the vicinity of the proposed site including approximately 800 impalas. There are also reported to be six pairs of blue cranes using the site. During the site visit two pairs were seen (Environmental Planning and Design, 2018). Zulu Rock This property has been used as a game farm and hunting resort. Development includes one large farmstead from where the property is managed and a five-unit lodge which overlooks the White Mfolozi River (Environmental Planning and Design, 2018). Lulu This property has been used as a cattle farm. Because of this there are degraded areas particularly in the vicinity of the farmstead (Environmental Planning and Design, 2018). Kwanqono Community Trust Land This property was the subject of a successful land claim by the Trust. It is understood that they have owned the property for approximately 10 years. Prior to the land claim the property was

operated as a game farm. A lodge (Leopard Rock) was also operated from the property (Environmental Planning and Design, 2018). There are numerous existing developments within the greater BGR, such as the existing Zulu Rock Homestead, Zulu Rock Lodge and Rock Pools.

5.2.1. Biophysical Environment 5.2.1.1. Climate The climate of the region is warm and temperate with a mean annual precipitation average of 861mm, falling mainly in the warmer months of October to March. Rainfall events are often intermittent and include dramatic thunderstorm events in the spring and summer months. The site is further largely frost free. The average evapotranspiration rate is between 1601 to 1800 mm per annum. The average daily mean temperature in February (the hottest average month) is 23.1 C and 16 C in June (the coldest average month). Summer maximums can reach in the upper 30 C.

The climate at Babanango is a subtropical highland climate identified as CWB according to the Köppen-Geiger climate classification. The monthly rainfall data was obtained from Climatic- Data.org (an online source) for Babanango but it did not state the recording period (Figure 8). The wet season is from October to March and the dry season is from April to September. The average annual rainfall is approximately 861 mm per year.

Ulundi Municipality Spatial Development Framework (2016) states that the evaporation in the Babanango region is 0-1400 mm per annum (GCS, 2019).

Average Monthly Rainfall at Babanango

140

120

100

Rainfall (mm) Rainfall 40

0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Months

Figure 8: Average monthly rainfall in the Babanango Valley.

5.2.1.2. Landuse and Landcover Historically the majority of the site area has been used for low intensity grazing and particularly for game farming. A section of the higher plateau area to the south of the greater BGR has been used extensively for timber production. Since the Emcakwini Community Trust land claim settlement, the Trust has been the working the timber production area by selling timber to Mondi and also producing charcoal. They have also been allowing communal grazing over much of the site and firewood collection. Poaching is currently a significant problem on the Emcakwini Community Trust land. From discussion with the Trust, this is undertaken by a variety of people for both sport and profit. During the site visit a group of 30-40 people were seen with a pack of hunting dogs towards the southern section of the proposed site (Environmental Planning and Design, 2018).

From reference to the SANBI Landcover Data Set, the majority of the site area is in a natural state. There are areas that are indicated as degraded, including:

• An area to the north west of the Emcakwini Community Trust land; • An area to the north east of the Kwanqono Community Trust land; and • A small area within Zulu Rock (Environmental Planning and Design, 2018).

The areas of degraded land within Community Trust land is generally due to cattle grazing. The degraded area of Zulu Rock coincides with the farmstead. The other obvious landcover elements are forestry plantations that are generally located on higher plateau areas to the south of the proposed site. It is obvious from the site visit, that in many higher areas of the site, wattle in particular has spread over the site from the formal plantations (Environmental Planning and Design, 2018).

5.2.1.3. Topography and Geology The site for the proposed lodge slopes relatively gently to moderately towards the White Mfolozi River. The site for the wellness centre is located on the crest of small rockery hill adjacent to the river (NJV, 2020).

The undulating topography is moulded by a suite of rocks and deposits that ranges between 1400m above mean sea level (amsl) from the ridges to 800m amsl at the Wit Mfolozi Riverbank. The high lying area is located in the central to south sections of the reserve and the low-lying area is located in the north where the Wit Mfolozi River is flowing in a south easterly direction. The highest point is situated on a ridge in the central part of the reserve which subsequently creates two sub catchments in the north and south-east (GCS, 2019).

According to the 1:250 000 Geological Map 2830 Dundee (Council of Geoscience, 1988) the site is largely underlain by granite from the Swazium Era (Figure 9). The granite is mainly composed of plagioclase, K-feldspar and quartz, with minor amounts of biotite and muscovite (Hicks and

Botha, 2014). The geological map also indicates that the site is also overlain by dolerite intrusions from the Jurassic Era and tillite (minor shale, varved shale and sandstone) from the Dwyka Formation of the Ecca Group. The north trending dolerite intrusion is associated with the volcanic activity from the Karoo Igneous Province and has been dated to be approximately 183 Ma.

The southern portions of the site are underlain by dark grey shales from the Pietermaritzburg Formation of the Ecca Group from the Permian Era (GCS, 2019).

Figure 9: Geology Map

The tented camp site natural ground slopes relatively gently to moderately from the upper southern portion of the site towards the White Mfolozi River. The bank directly adjacent to the river is steep comprising terraced cliffs and ledges (NJV, 2019). 5.2.1.4. Soils A Geotechnical Engineering investigation has been carried out by Drennan Maud (Pty) Ltd, dated 14th October 2019. The regional geology of the immediate area is dominated by Swazian intrusive granite and the colluvial and residual soils derived therefrom. The granite in the area has been intruded into by both Randium diabase dykes and Jurassic dolerite dykes. In addition, as the site is located on the mid to lower slopes adjacent to the river and river tributary, some alluvial sediments overlie the weathered bedrock.

Founding of the structures can be supported on normal strip or column base foundations which must found below all loose sandy colluvial and alluvial material, to bear into firm weathered granite or dolerite bedrock. If individual building platforms are constructed in each of the development areas, it is likely that in the cut portion of the building platforms, bedrock may be exposed on surface. The founding level of both external and internal walls should not be less than 0.5m below final ground level. The maximum allowable bearing pressure of foundations taken into the weathered granitic bedrock, requiring hard handpicking for excavation, should be restricted to 150kPa, but can be increase significantly to up to 450kPa when the use of pneumatic tools or blasting is required for excavation.

The soils have developed from the granite and intrusive diorite dykes are mainly shallow lithosols (<1m). This suggests the granite and diorite has been moderately weathered to medium to fine sand with low clay content. The erodibility index has classified the area as highly erodible. The shallow vadose zone groundwater that flows over the granite bedrock has led to the formation of bleached, eluvial horizon (E horizon) in area (Maaud, 2019), (GCS, 2019).

The regional geology of the immediate area is dominated by Swazian intrusive granite and the colluvial and residual soils derived therefrom. The granite in the area has been intruded into by both Randium diabase dykes and Jurassic dolerite dykes. In addition, as the site is located on the mid to lower slopes adjacent to the river and river tributary, some alluvial sediments overlie the weathered bedrock (NJV, 2019).

The maximum allowable bearing pressure of foundations taken into the weathered granitic bedrock, requiring hard handpicking for excavation, should be restricted to 150kPa, but can be increase significantly to up to 450kPa when the use of pneumatic tools or blasting is required for excavation (NJV, 2019).

5.2.1.5. Hydrology The reserve drains to two perennial rivers, the White Mfolozi river located in the northern sections of the reserve and the Nsubeni river on the South Western Portions of the site according to the observations on site as well as the 1:50 000 topographical maps (2831 AA and AC; 2830 BD). The reserve has 3 dams where two are situated in the central high lying area and the other in the North west approximately 1km from the Wit Mfolozi river. The reserve has a natural spring in the central area that is located just off the Mhlanganeni River (GCS, 2019).

5.2.1.6. Hydrogeology In South Africa, there are upwards of 400 000 boreholes each yielding an average of 2 681 L.day- 1 (0.75 L.s-1). Approximately one in three boreholes drilled are regarded as a failure (Mountain, 1968). There is a correlation between areas of higher rainfall and areas that have higher yielding

boreholes. Additionally, yield varies with geological formation. The following formations are known to produce high yields:

• Dolomite formations; • Ventersdorp formation (basic lavas); • Quartzite and shale (alternate) – providing a reliable yield but limited due to cracks; and • Dolorite dikes (obtained on the upper side of the dike). Formations that are known to provide poor yields are as follows:

• Granite sheets; • Dolorite sheets; • Shale (particularly shale that has been weathered at the surface resulting in a low infiltration clay surface); and • Dwyka tillite (particularly in KZN). The study area consists of one core aquifer type. It is a weathered and fractured aquifer with an estimated yield of between 0.5 to 3 L.s-1. The identified group is (KwaZulu-Natal Groundwater Plan, 2008): Northeastern Middleveld Hydrogeological Region Activities include coal mining, plantations and farming forms the brunt of the economic activities of this region. Many rural settlements occur within the boundaries of this region but their level of dependence on groundwater for domestic water supplies is at best only conjecture. The aquifer types are mapped (Vryheid) as fractured with a low development potential and intergranular and fractured with a low development potential. The diamictites forms the fractured aquifers and the arenaceous and argillaceous rocks forms the intergranular and fractured aquifers. The development potential of this region is uniformly low, thus able to supply basic water to small rural settlements with at least some capacity for community gardens (NatureStamp Hydropedological Report, 2020 (Appendix D10).

Figure 10: Change in geological formation from Swaziland towards the south (Kranskop)

According to 1:50 000 Hydrogeological Map Series (2730-Vryheid) the aquifer classification maps of South Africa the site is underlain by a minor aquifer and has a vulnerability varying from the least vulnerable to moderately vulnerable. The granite and dolerite are generally massive rocks with low porosity (Hicks and Botha, 2014). The minor, secondary aquifer is a fractured aquifer as well as fractured and intergranular aquifer in places (GCS, 2019). 49

The intergranular aquifer is a shallower weathered zone where the original rock structure has been changed to a mass of loose rock fragments in a matrix of fine products of weathering sand, silt and clay underlain by a fractured zone, down to a depth where the rock is becoming solid and fresh in appearance. The transition to this deeper zone is usually gradual. The lateral movement of groundwater in the top zone is very slow and boreholes abstractions are weak. The static water levels are controlled by the topography relative to the phreatic groundwater table (GCS, 2019).

No groundwater was noted on the steeper upper slopes where the development is proposed. However, during periods of high rainfall groundwater seepage may occur at the contact between the gravelly and sandy colluvial soils and alluvial soils and the underlying weathered bedrock (NJV, 2019).

5.2.1.7. Vegetation The reserve is mainly covered in savannah and grassland vegetation however the area is under threat of potential invasive alien plant growth (Ulundi Municipality Spatial Development Framework, 2016).

5.2.1.8. The Surrounding Local Socio-Economic Profile The proposed BTC is situated on Emcakwini Community land awarded to the community as part of a successful land claim lodged in 1998. The ECT was then formed to represent the interests of the community which is made up of around 192 households. Currently, there are no dwellings located on the proposed site or immediately adjacent. However, there is a mixture of formal and informal dwellings located on the hilltops overlooking the valley bottom. These communities utilise the proposed causeway crossing area for occasional livestock farming.

The proposed creation of the Babanango Game Reserve will have positive economic and social impacts for the local community and will result in local economic growth and the growth of supporting industries. The Reserve will create an estimated 272 direct job opportunities. These employment opportunities will be created through the operation of the lodges and conservation management (Error! Reference source not found.).

Table 13: Employment opportunities created with the formulation of the Babanango Game Reserve

Skilled Opportunities Semi-skilled Unskilled opportunities opportunities Conservation 4 52 17 Management Operation of tourism 78 112 24 lodges Total direct employment opportunities created 272

Additional employment/work opportunities will be created for the community through the supplying of services to the Reserve. These include transport, provision of charcoal and wood, sale of small crafts, sale of fresh produce.

The community will further benefit from training opportunities, profit sharing from the creation of the game reserve, and community projects such as community gardens and infrastructure development

The construction of the BTC itself will also create temporary and permanent employment opportunities, in the form of operations and management of the Camp.

ULUNDI LOCAL MUNICIPALITY

The Ulundi Local Municipality is a rural municipality located on the southern boundary of the Zululand District Municipality in the north eastern section of the KwaZulu-Natal province. The Ulundi municipal area is approximately 3,250 km2 in extent and according to the 2018 Integrated Development Plan includes the includes the towns and settlements of Ulundi, Nqulwane, Mahlabathini, Babanango, Mpungamhlophe and Ceza as well as the Traditional Authorities of Buthelezi, Buthelezi Mbatha, Mpungose, Ndebele, Ntombela, Ximba, Zungu and Zulu.

The Municipality has a population of approximately 205 762 (2016 census) with over 50% of the population being under 21 years old. This indicating that a high percentage of the population is economically dependent. The Municipality experienced a positive population growth rate from the previous census undertaken in 2011. The population size increased by approximately 17 177 people. The gender profile within Ulundi LM is dominated by females that constitute 54,83% with males constituting 45,17% of the population. This high female proportion is attributed young males moving to urban areas for further employment opportunities.

The economy is largely rural and underdeveloped. The economy is based on:

• Agriculture (Large commercial to subsistence); • Tourism (focusing on game reserves and heritage resources); • Mining (coal); • Retail (concentrated in Ulundi); and • Informal economy.

The Municipality experiences numerous social challenges persistent of rural municipalities throughout the province. This includes a high poverty rate of 43%, a high rate of child headed households, large unemployment at 49%, a high rate of HIV/AIDS and a lack of basic services to the remote areas of the Municipality. Low annual income and low education levels are further social problems.

ZULULAND DISTRICT MUNICIPALITY

The Zululand District Municipality is one of eleven district municipalities making up the province of KwaZulu-Natal. It is a Category C municipality situated in the north-eastern part of KwaZulu- Natal and is the biggest district in the province, making up 16% of its geographical area. It 51

comprises of five local municipalities namely: Ulundi, Nongoma, uPhongolo, eDumbe and AbaQulusi. The town of Vryheid is a commercial and business hub, while the Ulundi Town is mainly an administrative centre. It is primarily a rural district with about half the area falls under the jurisdiction of traditional authorities.

5.2.1.9. Heritage There is a rich history within the area surrounding Babanango. There are also a number of known artefacts that have been found within the site area (Environmental Planning and Design, 2018).

The BGR and surrounding areas is the original home of the influential Buthelezi Clan. This makes the area important for this group of people. The town of Babanango was founded in 1904. Initially the town was part of land granted to White farmers, in 1885, for their support of King Dinuzulu who succeeded his father Chief Cetshwayo as King of the Zulu nation in 1884, upon his death. The betterment planning programme was initiated by the Department of Bantu Affairs through Proclamation 31 of 1939 and regulated by Proclamation R 169 of 1967 with effective from the 1930s onwards as the major form of rural development planning in an attempt to regulate these areas and control land usage particularly those on trust land in accordance with the Land Act of 1936. This programme was implemented in the former homelands and other so-called black areas. A vast number of people lost their stock which was their only source of wealth, subsequent to the application of the Stock Limitation Act (1950) introduced by the state under the pretext of land betterment. The Act thus paved the way for the forced removal or slaughter of cattle belonging to African people in the reserves. In terms of the Act, the number of livestock was limited and stock owners (individual or families) paid a small grazing fee annually. This consisted of restrictions on ploughing, prohibitions on cutting trees and the culling of cattle (Environmental Planning and Design, 2018).

Betterment type controls were placed over the agricultural land in an attempt to prevent overgrazing. Betterment type controls refer to the schemes that were used to regulate homelands under the pretext of improving the areas. More than any other type of apartheid dispossession, betterment resulted in mass removals, of particularly the underprivileged who resided in rural areas. Moreover, some of the evictees were considered to be squatters, because an individual farmer wanted to take over their land. In addition, Babanango evictees were old, disabled or unsatisfactory workers whom the farmers considered ineffectual hence they were driven off the land. Babanango experienced a massive number of farm workers’ or tenants’ evictions predominantly in the 1950s and early 1960s (Environmental Planning and Design, 2018).

There are a number of areas of heritage interest within the BGR. The fact that the site and surrounding area is the ancestral home of the Buthelezi Clan also provides the site with heritage importance. From initial discussion with the Trust, the Buthelezi’s undertake an annual clan

gathering in the vicinity of the site. Following the meeting, groups of people visit several areas within the proposed site that are important to them (Environmental Planning and Design, 2018).

From the site visit there is evidence of contemporary settlement in the form of rondavels, stone walls and as Farmhouse buildings. The majority of these are ruins. It does seem likely that many of these are likely to date from the early to mid-20th century (Environmental Planning and Design, 2018).

5.3. Public Participation Process Public participation is a process that is designed to enable all interested and affected parties (I&APs) to voice their opinion and / or concerns which enables the practitioner to evaluate all aspects of the proposed development, with the objective of improving the project by maximising its benefits while minimising its adverse effects.

Phelamanga (Mrs Rose Owen) has been appointed as the independent public participation consultant.

I&APs include all interested stakeholders, technical specialists, and the various relevant organs of state who work together to produce better decisions.

The primary aims of the public participation process are:

▪ to inform I&APs and key stakeholders of the proposed application and environmental studies; ▪ to initiate meaningful and timeous participation of I&APs; ▪ to identify issues and concerns of key stakeholders and I&APs with regards to the application for the development (i.e. focus on important issues); ▪ to promote transparency and an understanding of the project and its potential environmental (social and biophysical) impacts (both positive and negative); ▪ to provide information used for decision-making; ▪ to provide a structure for liaison and communication with I&APs and key stakeholders; ▪ to ensure inclusivity (the needs, interests and values of I&APs must be considered in the decision-making process); ▪ to focus on issues relevant to the project, and issues considered important by I&APs and key stakeholders, and; ▪ to provide responses to I&AP queries.

The public participation process must adhere to the requirements of Regulations 41 and 42 (GNR 982) under the NEMA (as amended).

The public participation process will be undertaken according to the phases outlined below.

cBAR PHASE DECISION MAKING PHASE ▪ Raise issues of concern ▪ May appeal the ▪ Make suggestions for project development decision ▪ Contribute relevant local and indigenous knowledge to the environmental assessment ▪ Comment on the findings of the study and the rating of the impacts Figure 11: Responsibilities of I&APs in the different PPP stages

Figure 12 (below) depicts the approach taken by IDM, where one-way information flow is avoided and information exchange is promoted, thereby enabling a higher level of engagement.

Information Exchange: One Way Information Flow: Consult Protest Involve Inform Collaborate Empower

Figure 12: The stakeholder engagement spectrum (DEAT, 2002)

The following Public Participation Process Plan has been approved by EDTEA:

The COVID-19 Pandemic National Lockdown (Alert Level 3) required that a Public Participation Process Plan be developed for approval. This is to ensure that directions, measures and protocols are followed at all times, including the “General measures to contain the spread of COVID-19” set out in Regulation 5 of Chapter 2 of the 29 April 2020 Lockdown Regulations, e.g. to wear a cloth face mask/appropriate item that covers the nose and mouth when in a public place; observance 54

social/physical distancing requirements; a person may only leave his/her place of residence to perform an essential or permitted service, to go to work where a permit has been issued, to buy a permitted good, to obtain services that are allowed to operate; etc.

The following Public Participation Process Plan was approved by EDTEA on 24 June 2020. Refer to Appendix E for the full Public Participation Process Report.

PUBLIC PARTICIPATION PLAN – Babanango Travellers Camp

COVID-19 Hygiene protocols considered:

▪ no meetings of more than 10 people ▪ meeting venue must allow for space of at least 1.5 – 2m between attendees ▪ all attendees will be requested to complete a screening questionnaire which will be kept with project file ▪ all attendees will be required to make use of hand sanitiser before the meeting ▪ all attendees will be required to make use of masks where appropriate ▪ no sharing of equipment / pens / paper / etc. ▪ where community interviews are required, interviews should be done in a space that is not the persons primary residence – e.g. do the interview outside in the open ▪ when moving through the community to erect site notices or notices within a community space – all posters to be laminated and sprayed with sanitizer prior to placement ▪ all CLOs to be equipped with sanitizer and facemasks at all times

These protocols will be followed by any person involved in the PP aspect of the project, including but not limited to: all specialists and CLO when meeting with any person involved in the project or any stakeholder / I&AP interactions. 5.3.1. Notice of activity • Phone calls to the pre-existing I&AP list to inform them of the activity and that an SMS with further information would be provided (in addition confirmation of possible access to internet / WhatsApp etc. will be determined for ongoing engagement) • Send SMS and email to all registered I&APs informing them of the activity and process. • SMS will ask for a response Yes if they can receive documents etc. to a smartphone or No, they are not able to • This will then assist in determining next steps

5.3.2. BID – Distribution • BID: electronic distribution o Create “infographic slides” o Distribute link to website via email, SMS, WhatsApp o Distribute BID as infographic via WhatsApp / MMS o Load on website – dedicated page – with BID and reports and Comment form links

o Distribute Comment register via Google forms link for “online completion” via smartphones or computer to registered I&APs – Link that can easily be shared with I&Aps

5.3.3. BID: hardcopy distribution o Critical / strategic I&APs to receive a hardcopy of the BID this will require coordination with the CLO and relevant PPE / hygiene and support. o CLO to keep additional BID copies to hand for further distribution to those who do not have access to internet / smartphone for electronic access, all relevant PPE / hygiene and support will be undertaken

5.3.4. BAR - Access • BAR: Hardcopy for review o A determination will be made if the local municipal offices or the library is open for placement of the hardcopy. o A copy to be placed on site, in the event the local library is not available due to COVID-19

5.3.5. BAR Electronic access o BAR will be loaded on the website – dedicated page – with BID and reports and Comment form links

5.3.6. Advertising • Advertising and Notice: advertising in a local newspaper, liaise with CLO to erect notice of activity in relevant site and community spaces. • I&AP Database: Update and manage the I&AP database, include new registered I&APs, follow up to ensure I&AP details are correct where “bounce/undeliverable” notices are received.

5.3.7. Other Activities • Comment Register: Manage comment register and issue trail; forward queries, comments and concerns to specialists for responses; provide responses to I&APs as received from specialists. • Liaison with EAP / Consultants / CLO: Maintain open communication and liaise with the EAP and the other consultants appointed to the project (e.g. Afzelia Consulting for the WULA). Liaise with the CLO as necessary for the management of the PP aspects of the project. • Report: Prepare a PP Report for inclusion in the EIA Report, include I&AP Database, comment register and evidence of PP activities.

5.3.8. Notes In discussion with the EAP it was noted that the PP process undertaken for the Greater Babanango Game Reserve (not part of a formal EA Application process) had been very robust and thorough. It is advisable that the PP activities undertaken at that point and the report be reviewed to determine the narratives and for the PP facilitator to ensure the Comment forms for the tented camp and lodge create space for any follow up questions.

The COVID-19 pandemic prevents public meetings from occurring. If there is a critical issue in the initial reports that has not been addressed or is raised during the BID stage it is proposed that “one-on-one” interviews be established with I&APs to ensure all COVID-19 hygiene standards and protocols may be adhered to. 5.3.9. Measuring effectiveness Determining the effectiveness of the PP plan will be done through the following mechanisms as included in the PP report:

• Monitoring the delivered notifications for Bulk SMS / WhatsApp communications • Report from the website on the number of access/reads of the website that has been done • Bulk email report on open, and click through to links for documents • Report on the number of requests for CLO delivery of hardcopy BID

6. Specialist Findings Reference is made to the on-line National Department of Environment, Forestry and Fisheries (DEFF) Screening Tool Report (full report provided in Appendix J3). This report identifies site sensitivities based on the nine themes outlined in Error! Reference source not found.. The level of sensitivity for these nine themes then inform the specialist studies required. However, it is important to note that the DEFF Tool itself acknowledges that these are only recommendations, and that is the duty of the EAP to adjudicate the specialist assessments required to duly assess impact of the proposed development. Table 14 presents the site sensitivity from the DEFF Screening Tool Report.

Table 14: DEFF Screening Tool Site Sensitivity Rating

Based on the selected classification, and the environmental sensitivities of the proposed development footprint, the following list of specialist assessments have been identified for inclusion in the assessment report. It is the responsibility of the EAP to confirm this list and to motivate in the assessment report, the reason for not including any of the identified specialist study including the provision of photographic evidence of the site situation. Refer to column two of Table 15 for the specialist studies / activity to address the specialist recommended by the DEFF Screening Tool, and refer to Appendix B for site photographs.

Table 15: DEFF Recommended Specialist Studies

DEFF Recommended EAP way forward Specialist Assessment Agricultural Assessment Commissioned an Agricultural Agro-Ecosystems Assessment in accordance with GNR 320 of 20 March 2020 (refer to Appendix D14) Landscape/Visual Impact Not deemed necessary due to the minimal impact, minimal Assessment footprint and eco-deign of the proposed development Archaeological and Cultural Addressed in the Heritage Impact Assessment (refer to Heritage Impact Assessment Appendix D9) Palaeontology Impact Addressed in the Heritage Impact Assessment (refer to Assessment Appendix D9) Terrestrial Biodiversity Impact Addressed in the Vegetation and Faunal Assessments (refer Assessment to Appendices D4 and D6). Aquatic Biodiversity Impact Addressed in the Floodline, Watercourse, Hydrological and Assessment Water Supply Assessments (refer to Appendices D5, D7, D11 and D13). Hydrology Assessment Addressed in the Hydrological and Water Supply Assessments (refer to Appendices D11 and D13). Socio-Economic Assessment Addressed in the Feasibility Report completed for the Greater BGR and incorporated herein. Plant Species Assessment Addressed in the Vegetation (refer to Appendix D4). Animal Species Assessment Addressed in the Faunal Assessments (refer to Appendix D4).

6.1. Hydrogeological Investigation – Babanango Game Reserve, KwaZulu Natal This assessment was conducted by GCS Water and Environmental Consultants (2019, and updated July 2020). See Appendix D1. The aim of the investigations was to secure a water supply at each of the lodges and to carry out a risk assessment for two of the lodges (Tented Camp and Five Star Lodge) based on the proposed septic tank systems.

6.1.1. Geophysical Investigation

Traverse Line 9 was carried out on a north-west to south-east alignment with a total length of 195 m (Refer to Table 16). A definite contact zone between dolerite and granite can be seen at 90m. From Electrical resistivity sounding an area of high conductivity and low resistivity is also visible on the same station position. Table 16: Tented Camp Geophysical Survey - Traverse Details

Coordinates Traverse Traverse Traverse Latitude Longitude Latitude Longitude Distance Direction Start End

- (m) (DD) (DD) (DD) (DD) -

9 175 -28.22816 31.087057 -28.22957 31.086183 West - East

Note/s:

(-) - not applicable

(DD) - decimal degrees

(m) - metres

Coordi Projection: - nates Geographic

Figure 13: Tented Camp - Depiction of Electrical Resistivity and Magnetometer Geophysical Traverse Results

6.1.2. Drilling Target/s

Drill target 2 was cited on station 60 m on traverse 9 as shown in Table 17. The drill target was cited on the opposite side of a possible dyke. The target ensures optimal drilling location to target possible fractures or zones of weathering associated with the contact zone between the granite and intrusive dolerite dyke.

Table 17: Tented Camp - Drill Target

Traverse Coordinates Traverse Drill Target/s Number Latitude Longitude Station

- - (DD) (DD) (m)

2 9 -28.228529 31.086871 60

Note/s:

(-) - not applicable

(DD) - decimal degrees

(m) - metres Coordinates - Projection: Geographic Datum: WGS84

6.1.3. Production Borehole Drilling

Table 18: Tended Camp Production Borehole Drilling Table

Description:

BH ID TC BH1

Coordinates WGS 84 Southing Easting

-28.228529 31.086871

Borehole Type: Production

Method of Drilling Air- rotary

Total Depth: 84m

Drilling (mbgl):

From: 0 Drilling 10" To: 12

From: 13 Drilling 6.5" To: 84

Water Strikes and Cumulative Yield:

Water Strike (mbgl); Yield (l/s) 0.33l/s

Water Strike (mbgl); Yield (l/s) (mbgl; l/s) Seepage

Water Strike (mbgl); Yield (l/s) 0.4l/s

Casing Information (mbgl):

177 mm Solid Steel Casing 4.5mm wall From: 0 thickness To: 12

6.1.4. Aquifer Testing A short duration constant rate test was conducted on the on the newly drilled production borehole TC BH1. A CR test is a field experiment in which a well is pumped at a controlled rate and water- level response (drawdown) is measured, after which the borehole is left to recover. The response data from the aquifers are used to estimate the hydraulic properties of the aquifer. The borehole details can be seen summarized in Error! Reference source not found..

Table 19: Aquifer Test - Borehole Details

Static Borehole Pump Inlet Available Test Borehole ID Water Depth Depth Drawdown Duration Level

(-) (mbgl) (mbgl) (mbgl) (m) (hrs:min)

TC BH1 9.8 84 80 70.2 08:00

Note/s:

(-) - not applicable

(mbgl) - decimal degrees

(m) - metres

(hrs:min) - hours : minutes

Figure 14: TC BH1 - Aquifer Test Results

The well was pumped at a constant rate of 0.33 l/s (1 188 l/hr) for 8 hours until a total drawdown of 68.2 m was reached as presented in Figure 14 and Error! Reference source not found. The water level recovered to within 90% of the SWL within 5:09 hours after pumping stopped and a total recovery of 99% was measured after 12 hours.

Table 20: TC BH1 - Aquifer Test Results

Total Total Total BH ID Recovery Pump Yield Transmissivity Drawdown Duration Recovery

(-) (hrs:min) (%) (m) (l/s) (m2/day)

TC BH1 08:00 99 65 0.33

Note/s:

(-) - not applicable

(%) - Percentage

(l/s) - litres / second

(m) - metres

(m2/day) - cubic meters / day

6.1.5. Recommended Pumping schedule

Based on the aquifer tests data (as seen in Table 21), it is recommended that the borehole be pumped for a period of 8 hours and left to recover for 16 hours. A total volume of 9 504 liters of water can be abstracted per day from the borehole.

Table 21: TC BH1 Recommended Pumping Schedule

Recovery BH ID Pump Depth Pump Cycle Recommended Yield Time

(-) (mbgl) (hrs) (hrs) (l/s) (l/hr) (l/d)

TC BH1 80 8 16 0.33 1 188 9 504

Note/s:

(-) - not applicable

(mbgl) - meters below ground level

(hrs) - hours

(l/s) - liters / second

(l/hr) - liters / hour

(l/d) - liters / day

It is recommended that the run dry protection system be installed on the borehole and a float system installed in the storage tank.

6.1.6. Lab Analyses Groundwater samples were collected and submitted to an accredited laboratory for inorganic analysis. The laboratory certificate is attached in Appendix B. The laboratory results for borehole TC BH1 were compared to the SANS 241-1:2015 Drinking Water Quality Standards (SABS, 2015). The results are summarized in Error! Reference source not found. below.

Table 22: TC BH1 - Groundwater Quality Results

SANS 241-1:2015 Drinking Water Parameters Standard TC BH1

Standard limits

General Parameters pH at 22oC (pH units) ≥5 to ≤9.7 O 7.7

Conductivity mS/m @ 25°C ≤170 A 54

Total dissolved solids (TDS) ≤1200 A 290

Total Alkalinity as CaCO3 NS 287

Turbidity (NTU) NS 10

Bicarbonate, HCO3 NS 287

Carbonate, CO3 NS <12

Anions

Chloride, Cl ≤300 A 18

≤500 AH Sulphate, SO4 2.5 ≤250 A

Nitrate as N ≤11AH 1.2

AH Nitrate as NO3 ≤50 5.31

Nitrite as N ≤0.9 AH <0.5

AH Nitrite as NO2 ≤3.0 <1.64 Fluoride, F ≤1.5 CH 1.9

Cations and Metals

Calcium, Ca NS 43

Magnesium, Mg NS 9.8

Sodium, Na ≤200 A 53

Potassium, K NS 2.2

≤2 CH Iron, Fe <0.05 ≤0.3 A

SANS 241-1:2015 Drinking Water Parameters Standard TC BH1

Standard limits

Aluminium, Al ≤0.3 O <0.003

≤0.4 CH Manganese, Mn 0.005 ≤0.1 A

Ammonia NS 0.016

Ammonia as N NS 0.01

Arsenic, As ≤0.01 CH 0.001

Mercury, Hg ≤0.006 CH <0.001

Cadmium, Cd ≤0.003 CH <0.0001

Boron, B ≤2.4 CH 0.024

Barium, Ba ≤0.7 CH <0.005

Chromium, Cr NS 0.025

Copper, Cu ≤2.0 CH <0.0009

Nickel, Ni ≤0.07 CH 0.002

Lead, Pb ≤0.01 CH <0.0005

Zinc, Zn ≤5.0 A <0.01

Antimony, Sb ≤0.02 CH <0.01

Selenium, Se ≤0.04 CH <0.002

Strontium, St NS 0.17

Uranium, U ≤0.03 CH 0.02

Vanadium, V NS 0.003

Microbiological

Total Plate Count NS > 2420

Escherichia coli (cfu/100ml) No detection AH Not Detected

Total coliforms (cfu/100ml) ≤10 O > 2420

Faecal Coliforms (cfu/100ml) No detection AH Not Detected

SANS 241-1:2015 Drinking Water Parameters Standard TC BH1

Standard limits

All parameters in mg/l unless specified otherwise

Blue Shading: Exceedance in terms of SANS 241-1:2015 Drinking Water Standard

A - SANS 241-1 Aesthetic Risk Limit

CH - SANS 241-1 Chronic Health Risk Limit

AH - SANS 241-1 Acute Health Risk Limit

O - SANS 241-1 Operational Risk Limit

NS- No Standard

All general parameters, Anions, Cations and Metals analysed for were compliant with the SANS241-1:2015 Drinking Water Quality Standards.

A piper diagram represents the chemistry of a water sample graphically. It is a tri-linear diagram that implements major cations calcium, magnesium, sodium and potassium) and anions (chloride, sulphate and bicarbonate) to reveal the chemistry of water samples. This is then used to characterize different types of water. The water that was analysed for TC BH1 can be seen in Figure 15 classified as a sodium-bicarbonate type water, typical of unpolluted groundwater.

Piper Diagram

80% 80%

60% 60%

40% 40%

20% 20% TC BH1 BVL BH1 5SL BH1

Cations Sodium & Potassium Anions 80% 20% 20% 80%

Sulphate

60% 40% 40% 60%

40% 60% 60% 40% Magnesium Total Alkalinity

20% 80% 80% 20%

80% 60% 40% 20% 20% 40% 60% 80% Calcium Chloride & Nitrate

Figure 15: Piper Diagram

6.1.7. Groundwater Management Program It is recommended that the water level in TC-BH1 be manually measured on a quarterly basis (refer to Error! Reference source not found.). The data should be sent to a hydrogeologist to analyze the data and evaluate the abstraction volume. The data would also be used in order to determine if water levels are decreasing over time (wet and dry seasons).

Table 23: TC BH1 - Water Level Monitoring Plan

Sampling Borehole ID Latitude Longitude Method Frequency

(-) (DD) (DD) (-) (-)

BVL BH 1 -28.28935 31.016084 Annually Manual

Note/s: (-) - not applicable (DD) - decimal degrees Coordinates - Projection: Geographic

Datum: WGS84

The boreholes should also be sampled according to Table 23 and the sample should be analyzed according to the parameters set out in Table 24.

Table 24: TC BH1 - Groundwater Sampling Schedule

Borehole Water used for Sampling Frequency Analysis ID

SANS 241-1 Drinking TC BH 1 Domestic Bi-Annually Water

6.1.8. Soil Augering Hand Soil auger holes were drilled in and around the proposed site were the conservancy tanks are to be installed (summary provided in Table 25). Three (3) auger holes in total were drilled. No groundwater seepage was encountered in any of the auger holes.

The auger holes were drilled until refusal was encountered. It was found that the soil profile was very shallow in and around the site with the deepest auger hole at 0.96 mbgl and the shallowest hole at 0.25mbgl. Refusal was found at the transition zone between the top unconsolidated colluvium and the bedrock.

Table 25: Tented Camp - Soil Auger Hole Details 69

Coordinates AH ID Depth Elevation Soil Type South East

(-) (DD) (DD) (mbgl) (mamsl) (-)

AH5 -28.228196 31.086908 0.36 742 Sandy Clay

AH6 -28.231326 31.091226 0.5 748 Sand

AH7 -28.231565 31.095345 0.66 729 Clay

Note/s:

(-) - not applicable

(DD) - decimal degrees

(mbgl) - meters below ground level (mamsl) - meters above mean sea level Coordinates - Projection: Geographic

Datum: WGS84

6.1.9. Infiltration Tests

Infiltration tests were performed on the three (3) auger holes to determine the hydraulic properties of the shallower soil. The infiltration test results are presented in Table 26 below.

The Bouwer-Rice method was used to determine the Hydraulic Conductivity (K) based on the recovery data of the infiltration tests. The hydraulic conductivity is defined as the measure of the ease with which water will pass through the earth’s material; defined as the rate of flow through a cross-section of one square meter under a unit hydraulic gradient at right angles to the direction of flow given in m/day.

Table 26: Tented Camp - Infiltration Tests Results

Auger Hole Auger Hole Test Hydraulic Hydraulic Recovery ID Depth Duration Conductivity Conductivity

(-) (m) (min) (%) (m/sec) (m/d)

AH5 0.36 130 98 3.46E-07 0.03

AH6 0.5 9 100 2.40E-05 2.073

AH7 0.66 90 95 2.46E-07 0.021

Average 0.51 76 98 8.20E-06 0.708

Note/s:

(-) - not applicable

(m) - metrs

(min) - minutes

(m/sec) - meters / second

(m/d) - meters / day

Based on the infiltration tests, hydraulic conductivity values were calculated using the FC method and ranged from 2.46 x 10-7 to 2.40 x 10-5 m/sec (0.021 to 2.073 m/day). The average Hydraulic conductivity for the shallow soil around the Tented Camp is 0.708 m/day. This value is considered the representative value for colluvial deposits and the clayey soils found in the study area.

6.1.10. Risk Assessment

A detailed risk assessment for surface and groundwater was compiled to outline the potential risks involved with the conservancy tanks. The Information gathered during the previous phase 1 of the study along with the auger holes drilled and infiltration tests were used in order to compile the risk assessment.

6.1.10.1. Surface Water Risk Assessment

In the event that seepage does occur from the conservancy tanks the the waste water will possibly contain Bacterial viruses such as Salmonella, Shigella, Vibrio, Campylobacter and pathogen strains such as E.coli (Francy et al, 2011). The seepage would most likely impact the Wit Mfolozi River in the form of surface runoff. The river would be considered the first receptor to any seepage/surface runoff. The conservancy tanks would be installed up-gradient from the river, thus any runoff would eventually drain into the river that is situated below the site, following typical water courses and the path of least resistance. However, the runoff should be sufficiently contained by the designing a closed system with sufficient capacity for the sewage water.

6.1.10.2. Groundwater Contamination Risk Assessment

From the first phase of the study it was found during the hydrocensus that the groundwater levels in this area ranges between 3.38mbgl to 31mbgl and has an average water level of 17. 03mbgl. The groundwater level is assumed to correlate with topography. The total distance the seepage would have to travel in order to contaminate any groundwater in the area, would therefore be the distance from the surface to the SWL at 17.03mbgl. The K-value infiltration tests can then be used to estimate the time it would take for this seepage to travel through the subsurface in order to reach the groundwater level and can be seen summarized in Error! Reference source not found.Error! Reference source not found..

6.1.11. Analytical Model Calculations Given the K-value with the hydraulic gradient (i) assumed and traveling through a given unit of the sub-surface and n is the porosity value given in percentage (%) as a constant value derived from Morris and Johnson (1967) as 0.55 for colluvium.

From the equation:

v = Ki/n Equation (1)

The velocity is calculated as summarised by Table 27 given the assumption that the sub-surface is homogeneous.

Table 27: Groundwater Seepage Travel Time Towards Possible Receptors

Groundwater Calculated Travel Travel Time Possible Receptor Gradient Velocity Distance

(i) (m/day) (m) (days) (-)

Average Static Groundwater 1 0.71 17.03 23.9859155 level from hydrocensus study during phase 1

Note/s:

(-) - not applicable

(i) - groundwater gradient (m) - meters

(days) - days

For the full report, refer to Appendix D1. 6.1.12. Additional Water Supply

Additionally, in September 2019, GCS conducted another assessment for additional water supply to the BTC. Refer to Appendix D13 for this full report. The study found that all general parameters, Anions, Cations and Metals analysed for were compliant with the SANS241-1:2015 Drinking Water Quality Standards. 6.1.12.1. Geophysical Investigation Traverse Line 9 was carried out on a north-west to south-east alignment with a total length of 195 m (Refer to Table 28). A definite contact zone between dolerite and granite can be seen at 90m. From Electrical resistivity sounding an area of high conductivity and low resistivity is also visible on the same station position. Traverse TC 1 was carried out in the same regional area, reaching across TC-BH 1 to gain a better understanding of the geological contact targeted. The borehole was cited on an area of high conductivity on a geological contact zone.

Table 28: Traverse Line 9

6.2. Watercourse Assessment The stormwater management for the site has been conducted and reported on by Dr Bruce Scott- Shaw of NatureStamp (Pty) Ltd and the full report is included as Appendix D7.

A watercourse assessment is required to determine all wetlands and/or rivers within 500 meters of the proposed tented camp. The site has been open tribal lands. Prior to this it was terraced and cultivated. The proposed camp needs to be strategically located so that it has minimal impact on nearby water resources (NatureStamp, 2019).

Plate 7: View of the White Mfolozi River from one of the proposed tented travelers camps

The site is located within Quaternary Catchment W21G; falling under the Usutu to Mhlatuze Water Management Area (WMA) and the Mhlatuze waterboard. The proposed area sits on a large catchment area modified by land use practices. The site is within the catchment area of the Mfolozi system (NatureStamp, 2019). Rainfall in the Babanango region occurs in the summer months (mostly December to February), with a mean annual precipitation of 782 mm (observed from rainfall station 0337006 W). The reference potential evaporation (ETo) is approximately 1667 mm (A-pan equivalent, after Schulze, 2011) and the mean annual evaporation is between 1300 – 1400 mm, which exceeds the annual rainfall. This suggests a high evaporative demand and a water limited system. Summers are warm to hot and winters are cool. The mean annual temperature is approximately 22.4 ºC in summer and 15.8 ºC in the winter months (Table 2). The underlying geology of the site is Natal group Arenite Shale and the soils overlain are sandy-clay-loam ranging from Glenrosa to Hutton form in this particular area(NatureStamp, 2019). In terms of the Section 21 National Water Act (NWA) water uses, the camp itself will not be impeding or diverting flow of water, nor altering bed, banks, course or characteristics of water - however, the developments are within the ‘regulated area of a watercourse’, which is described as (GN 509, August 2016) –

• The outer edge of the 1:100-year floodline and/or delineated riparian habitat whichever is the greatest distance, measured from the middle of the watercourse of a river, spring, natural channel, lake or dam; • In the absence of a determined 1:100-year floodline or riparian area, the area within 100m from the edge of a watercourse where the edge of the watercourse is the first identifiable annual bank fill flood bench; or

• A 500m radius from the delineated boundary (extent) of the wetland or pan. 6.2.1. Regional Context 6.2.1.1. NFEPA assessment The ‘National Freshwater Ecosystem Priority Areas’ (NFEPA) project is a systematic biodiversity planning tool developed by the CSIR (2011) to identify freshwater areas considered the most important for biodiversity conservation. The key objectives of the NFEPA project are to ensure that all ecosystems and species are represented and that key ecological processes remain intact – achieving biodiversity targets within the smallest, most efficient area possible, with attention to connectivity over large areas (CSIR, 2011). The White Mfolozi River borders the sites proposed for a tented camp. The river is classified as National Freshwater Ecosystem Priority Areas (NFEPA), Class B: Largely Natural (Driver et al., 2005, Nel et al., 2011, SANBI 2011). Protection and sustainable use of NFEPA’s is required to meet national biodiversity goals for freshwater ecosystems. 6.2.1.2. Vegetation The vegetation of the sites comprises of Northern Zululand Sourveld (svl 22), threat status: poorly protected with 78.5 % remaining (Mucina & Rutherford, 2006). This vegetation type has the following features –

• Distribution: KwaZulu-Natal Province and Swaziland: From the Lusthof area in Swaziland southwards with scattered patches in northern Zululand in the surrounds of Hlomohlomo, east of Louwsburg, Nongoma and the vicinity of Ulundi including Nkandla. In the HluhluweiMfolozi Park it occurs at highest altitudes in the park. • Altitude: mainly 450– 900 m. • Vegetation and Landscape features: The dominant structural vegetation type is wooded grassland, in places pure sour grasslands and rarely also dense bushveld thickets. Terrain is mainly low, undulating mountains, sometimes highly dissected, and also some moderately undulating plains and hills. 6.2.1.3. Extent, Classification and Habitat Characteristics The current land cover was obtained from various databases and the site visits. The site was previously transformed with historical cultivation. Riparian systems are slightly invaded and there are some eroded channels and cattle paths. However, the site is mostly natural and has recovered well from historical disturbances. The ephemeral watercourse areas on site are intact. However, the severe lack of water has led to a loss of riparian species. The larger established tree species (Acacia, Ficus and Trichillia) are still present.

Figure 16: Typical vegetation on-site

The site consists of some areas of hydrological interest and these areas have described in detail. The river bank area associated with the camp was classified as a riparian area, any areas that could otherwise be considered wetlands (e.g. areas identified in the aerial imagery/historical images) were noted to ensure that the authors did not exclude any features which may be viewed as important. These features were also flagged during the desktop study for identification. The majority of the soils identified adjacent to the watercourse were sandy soils (Alluvium - yellowish- brown sand). An example of the sampling characteristics from the site visit has been provided in Annexure B of Appendix D7. The zonation of the active channel bank, the macro-channel bank and the terrace was identified. These zones were identified using the soils, vegetation and terrain where relevant. The objective was to determine whether the area between the active channel and the terrestrial/upland area is a riparian zone or a wetland situated adjacent to the river. The results were as follows: 1. No hydric soil characteristics were found outside of the active channel (these soils were only found within the floodplain of the active river channel, overlain by recent alluvial deposits). The hydric soils, identified by gleyed or mottled characteristics, were found at a depth of 30 cm which is close to the surface water mark of the river. 2. Outside of this active channel bank, all soil samples contained a high sand texture with no other redoximorphic characteristics. This was classed as the macro-channel bank. 3. The vegetation along the macro-channel bank of the river differed to the vegetation in the terrestrial area (more woody species relative to upslope areas, Figure 17). The vegetation in each of the channel areas has been described in Figure 17 and Table 11.

4. The active channel bank and the macro-channel bank has been delineated in Figure 17, with the various soil characteristics provided in Table 29.

Figure 17: Current land use within and around the site boundary, showing the mostly natural areas

Table 29: Description of HGM units

Figure 18: HGM units identified within 500m of the proposed tented camp 6.2.2. Present Ecological State (PES) 6.2.2.1. River Intermediate Ecological Water Requirement (EWR) – DWA 2014 The PES rating from the EWR assessment indicated that the White Mfolozi systems is in a stable state. However, water quality, geomorphology and vegetation issues may be at risk in the future (Error! Reference source not found.).

Table 30: EWR PES Score for the White Mfolozi

Component Trend Confidence Water Quality Stable 4 Geomorphology Stable 4 Vegetation Stable 4 Macroinvertebrates Stable 1 Fish Stable 2

The results for the White Mfolozi show that there are some rare and endangered biota (Crocodylus and some rare plants). Approximately 27 invertebrate taxa were present with riparian vegetation differing due to rocky banks and bedrock. The gorge areas in the system allow for a greater diversity of plants due to various Hillslope positions and therefore contrast of ground areas. This 80

system is an important migration corridor which is important in this setting due to the presence of fences. The overall EIS score for this system was considered to be moderate (Table 13).

Figure 19: DWA (2014) EIS category scoring summary for the White Mfolozi

The Index of Habitat Integrity tool (Kleynhans, 1996) was used to determine the integrity of the riparian zone associated with the White Mfolozi. The results have been provided in Table 31. The relevant reach of the system shows a PES category of B: “Largely natural: with few modifications. A small change in natural habitats and biota may have taken place but the ecosystem functions are essentially unchanged.” Some bush encroachment has occurred as well as some evidence of erosion. However, the primary impacts on water in particular are from upstream impacts. 81

Table 31: Pre-development PES score using the Index of Habitat Integrity tool (Kleynhans, 1999) for the White Mfolozi

6.2.3. Ecological Importance & Sensitivity Assessment The results of the EIS assessment for the relevant HGM units are summarized below. 6.2.3.1. Ephemeral Tributary: For the small tributaries (Table 32), the EIS was assessed as being Low indicating that:

• Features are not ecologically important and sensitive at any scale; • The biodiversity of these areas is typically ubiquitous; and • The system plays a role in providing ecological services.’ The tributaries have a vulnerable conservation status although they have very little connectivity with the linear habitat. Due to the lack of water, these systems do not provide a transition between terrestrial and aquatic vegetation. It would be important to source natural vegetation for these systems in a rehabilitation plan and should be a focus area for local scale rehabilitation

Table 32: EIS category scoring summary for the ephemeral tributary

6.2.3.2. White Mfolozi: For this system (Table 33), the EIS was assessed as being Very High indicating that:

• Features are considered to be unique on a national or even international level based on unique biodiversity (habitat diversity, species diversity, unique species, rare and endangered species); • in terms of biota and habitat this system is very sensitive to flow modifications and has no or only a small capacity for use; and • The system plays a significant role in providing ecological services.

Table 33: EIS category scoring summary for the White Mfolozi

Considering the PES and EIS scores, the recommended management objective for the Babanango area would be to maintain the present integrity and ecosystem functioning of the system and ensure no flow modifications and water quality impacts. Additionally, ensure the connectivity of the riparian system is maintained. 6.2.4. Risk Assessment A risk assessment was undertaken at the proposed tented camp site. Information from spatial datasets, as well as the site visit was used to populate the risk matrix which emerged will all “Low” impact /risk ratings, refer to Appendix D7. The ephemeral/non-perennial systems were not included due to their distance and dis-connectivity from the proposed development. The results indicate that there would be a low risk during construction for the system on site. During construction the risks are generally higher due to active machinery on site and potential for storm water wash. The low risk assumes that a rehabilitation plan is strictly followed. Operational activities pose a low risk in contrast to the pre-development state. This is primarily due to the low impact materials used for a tented camp and the common goal of an eco-lodge which promotes environmental conservation. The risk assessment is specific to activity c and i. Although most of the activities pose a low risk strict adherence to prevention and mitigation measures should still be applied. In the current layout, there is a high risk of damage to the structures from flooding of the White Mfolozi. This is separate to the risk assessment as the focus of this assessment is the impacts on the receiving environment rather than potential natural disaster risks on the infrastructure. 6.3. Faunal Assessment The faunal assessment was completed by Ross Goode of Zanemvula Environmental (Pty) Ltd. The full report can be found in Appendix D4. Undeveloped areas are valuable in providing habitat, forage areas and breeding grounds for faunal species. These areas are often associated with drainage lines and wetland systems which are often undevelopable, and provide the necessary ecological corridors linking habitats. The presence of fauna is of vital importance in maintaining ecological diversity and ecosystem health. Indicator species are species which tend to decrease in presence and diversity when the ecological state of the system is under pressure. Additionally, species of conservation concern and Red Data species are protected on a provincial, national and international level and the presence of such species needs to be verified (Zanemvula Environmental, 2019).

It is recognised that the proposed BTC will see the intended result to lease and merge the area controlled by the community to the developer, and join the Zulu Rock Private Game Lodge to the Babanango Private Game Reserve, thereby creating a private, “Big 5” game reserve. This will result in the conservation of many faunal species of conservation concern (Zanemvula Environmental, 2019). Fauna is directly related to the presence of vegetation, botanical composition and botanical diversity. It is therefore important to mention the vegetation occurring at the proposed location of the Babanango Tented Camp. Site comprises of rehabilitated grasslands and mixed savanna (Zanemvula Environmental, 2019). Mucina and Rutherford (2006), updated by Scott-Shaw and Escott (2011), have classified the site as Northern Zululand Sourveld. The vegetation type is Vulnerable with the conservation target not being reached. The following information was collected for the vegetation unit SVI22 (Mucina & Rutherford, 2006; Scott-Shaw & Escott, 2011). The characteristics of this veld are described as:

Figure 20: CBA’s of the proposed study site.

According to C-Plan (TSCP Minset), six species of conservation concern may occur in the area (Table 34 below)

Table 34: Species occurring on the TSCP Minset database

6.3.1. Protected and conservation areas of South Africa The Department of Environmental Affairs (DEA) have released an online map tool detailing the protected areas and associated 5km buffer. No sites under the Protected Areas Act fall within the 5km buffer set by the DEA. There are however, protected areas and heritage areas around the site, as seen blow in Figure 21 (Zanemvula Environmental, 2019).

Figure 21: Protected Areas around the study site from the DEA Screening Tool

6.3.2. South African Bird Atlas Project 2 Seven species of conservation concern occur within the pentad according to SABAP 2 (Error! Reference source not found.). The likelihood of each of these species occurring on site is relatively high as the habitat types for each of these species to occur in is present. Additionally, species highlighted in bold in Table 35 below were seen on site during the assessment (Zanemvula Environmental, 2019).

Table 35: Avifaunal species of conservation concern according to SABAP 2.

6.3.3. Animal Demographic Unit databases No butterfly species of conservation concern were highlighted in the LepiMAP; however, butterflies are referred to in the site verification section. FrogMAP highlights that one amphibian species of conservation concern may occur in the area. The potential for Bilbo’s Rain Frog occurring on site is low as the species prefers areas with grassy verges alongside exotic plantations. There are no exotic plantations within the site area (Zanemvula Environmental, 2020).

Table 36: Amphibians of conservation concern occurring on site according to the ADU FrogMAP.

According to MammalMAP, 9 mammal species of conservation concern may occur in the area (Table 37). Of these species, it is likely that Spotted Hyena, Southern African Vlei Rat, Dark- footed Mouse Shrew, Sclater’s Mouse Shrew and Leopard occur on site, while the other species will need to be introduced back into this area, which is possible (Zanemvula Environmental, 2019).

Table 37: Mammal species of conservation concern potentially occurring on site according to the ADU MammalMAP.

According to ReptileMAP, two reptile species of conservation concern may occur within the site (Table 38). The Natal Black Snake is unlikely to occur here as this species prefers coastal bush, while the Natal Hinged Tortoise may occur here due to its preference for tropical lowveld to mesic thickets in the south of its range (Zanemvula Environmental, 2019).

Table 38: Reptile species of conservation concern potentially occurring on site according to the ADU ReptileMAP.

The species seen on site are listed in Appendices 1 and 2 of Appendix D4 of this cBAR and are highlighted in bold. Only species seen and potential for species to occur have been assessed. 6.3.4. Avifauna A total of 144 bird species are predicted to occur on site and at the reference site of Emakhosini- Opathe Game Reserve. The full protocols – and hence reporting rates – for SABAP2 in this area are low. It is likely that more bird species are present within the area, and with time, a more accurate estimation of bird species richness will be available. Seven species of conservation concern were noted to potentially occur on site. Three species of conservation concern according to SABAP were seen – White-backed Vulture, Southern Ground- hornbill (four individuals), and Southern Bald Ibis – with a juvenile Martial Eagle (endangered), which has not been recorded on SABAB2 database being seen (Plate 8). A total of 55 bird species were observed during the verification, and no nesting was seen. The four Southern Ground-hornbills were seen flying over the area. These birds are territorial and occur in family groups, which can have a home range of up to 100km2. The low reporting rate suggests that this species has occurred in the area but is not seen on a regular basis. This suggests that either these birds were flying into the area to establish a home range, or already 89

have a home range in the area. Declines in these species have been attributed to habitat loss and loss of nesting trees (amongst other threats). It is of utmost importance to conserve these species through protection of their habitat. White-backed Vultures (and other vulture species) are present within the area. These species are currently under threat from mass poisoning episodes brought on by poaching of game and the muthi trade. These vultures roost at the top of trees, of which there are many in the area, which could assist the breeding potential of these species in the future. Large portions of protected habitat are essential for this species to survive. Southern Bald Ibis was seen flying over site. It is possible that this species may be roosting and possibly nesting on the cliffs in the surrounding hills. This species is increasingly using pasture fields and ploughed farmland to forage and may have been flying to one of these foraging sites. Martial Eagles are usually resident and territorial species, with juveniles dispersing widely. It is likely that the juvenile seen was dispersing from its natal range and could potentially be establishing a territory of its own. These birds have extremely large home ranges (up to 1000km2). Threats to this species come in the form of range contraction due to habitat loss and associated negative effects. Large portions of protected habitat are essential for this species to survive. The site as a whole does provide ample habitat for nesting and foraging for avifauna. With the merging and official protection of the proposed reserve, this site can act as a core ecological area, and an overall positive impact will be seen on all avifauna of the area, if protection is afforded (Zanemvula Environmental, 2019).

Plate 8: Juvenile Martial Eagle (Polemaetus Plate 9: Klaas’s Cuckoo (Chrysococcyx klaas) bellicosus).

6.3.5. Butterflies A total of 121 butterfly species are predicted to be occur on site, with only three being seen. No butterflies of conservation concern were seen on site. Some species seen can be found below from Plate 10 to Plate 12.

Plate 10: Biblia ilithya. Plate 11: Junonia hiereta cebrene.

Plate 12: Ypthima asterope.

6.3.6. Amphibians A total of 17 species are predicted to occur on site with none being seen on site. Potential for them to occur on site are very high due to the White Mfolozi River being right at the proposed camp site. Additionally, amphibians will occur within drainage lines within the project area (Zanemvula Environmental, 2020). 6.3.7. Mammals A total of 54 species are predicted to occur on site, with the only mammal being seen was a Common Duiker (Sylvicapra grimmia). The Heritage Specialist had reported that the owner of some cattle grazing in the area had seen a leopard (Panthera pardus) earlier on the day of the Heritage Specialist’s sampling. Leopard are extremely adaptable and are likely to thrive in areas of low-density human settlement, provided food sources are available. The fencing off of this area, and reintroduction of many game species would boost the potentially existing leopard population by affording formal protection and a regular food source (Zanemvula Environmental, 2020). 91

On the day of sampling, a Conservation Officer from Zulu Rock noted the presence of Greater Kudu (Tragelaphus strepsiceros), Bushbuck (Tragelaphus scriptus), Spotted Hyena (Crocuta crocuta) and Brown Hyena (Hayena brunnea) currently existing within the area. However, as the area is currently still under communal land, regular hunting with packs of dogs is present, which has put great strain on population numbers of the mammals within the area. Formal protection through the creation of the proposed reserve would assist in increasing population numbers of the existing mammals. Additionally, it has been proposed that a reintroduction of species may occur, so that the reserve has “Big 5” status (Zanemvula Environmental, 2019). 6.3.8. Reptiles A total of 26 species are predicted to occur on site, with only two reptile species being seen – Variable skink (Trachylepis varia; Plate 6) and Rainbow Skink (Trachylepis margaritifer; Plate 7), with none of them being species of conservation concern. The area provides ample habitat for reptiles.

Plate 13: Variable skink (Trachylepis varia) Plate 14: Rainbow skink (Trachylepis margaritifer).

The faunal assessment concludes with several mitigation measures focused on the need to avoid disturbance around the construction site, which is viewed as the main negative impacts of the proposed development. These mitigation measures have been included in the EMPr. 6.4. Vegetation Assessment The vegetation assessment was completed by Ross Goode of Zanemvula Environmental (Pty) Ltd. The full report can be found in Appendix D6. There are several features and species within the features present within the footprint which are of conservation importance. These are included in Table 39 and Table 40 below:

Table 39: Species of conservation importance

Table 40: Features of conservation Importance

In terms of the desktop analysis undertaken, the site is irreplaceable1, i.e. These planning units are referred to as totally irreplaceable and the conservation of the features within them is critical to meet conservation targets. (environmental assessment very definitely required and depending on the nature of the proposal unlikely to be granted). The CBA data (Figure 20 in the faunal assessment section) indicates that the site is CBA Irreplaceable, and this was confirmed during the ground truthing exercise. 6.4.1. Vegetation- Mucina and Rutherford The general classification is made at a very coarse scale, i.e. low resolution and falls within the Northern Zululand Sourveld (SVI 22) vegetation type which has dominant structural vegetation that is wooded grassland, in places pure sour grasslands and rarely also dense bushveld thickets. Terrain is mainly low, undulating mountains, sometimes highly dissected, and also some moderately undulating plains and hills. This vegetation type has the following features – Distribution: KwaZulu-Natal Province and Swaziland: From the Lusthof area in Swaziland southwards with scattered patches in northern Zululand in the surrounds of Hlomohlomo, east of Louwsburg, Nongoma and the vicinity of Ulundi including Nkandla. In the Hluhluwe –iMfolozi Park it occurs at highest altitudes in the park. Altitudes mainly 450 – 900 m. Indicative Plant Species:

Small Trees: Acacia sieberiana var. woodii, A. natalitia, A. nilotica, A. tortilis subsp. heteracantha, Plectroniella armata. Tall Shrubs: Gardenia volkensii, Gnidia caffra, G. kraussiana. Low Shrubs: Agathisanthemum bojeri, Chaetacanthus burchellii, Crossandra fruticulosa, C. greenstockii, Diospyros galpinii, Phyllanthus glaucophyllus, Ruellia cordata, Syncolostemon argenteus, Tetraselago natalensis. Succulent Shrub: Aloe vanbalenii. Woody Climber: Cryptolepis oblongifolia. Herbaceous Climber: Cyphostemma schlechteri.

Graminoids: Eragrostis curvula, Hyparrhenia hirta, Microchloa caffra, Themeda triandra, Tristachya leucothrix, Alloteropsis semialata subsp. semialata, Digitaria argyrograpta, D. tricholaenoides, Diheteropogon amplectens, Elionurus muticus, Loudetia simplex, Trachypogon spicatus. Herbs: Alepidea longifolia, Argyrolobium adscendens, Aster bakerianus, Berkheya speciosa, Chascanum hederaceum, Crabbea hirsuta, Gazania krebsiana subsp. serrulata, Gerbera ambigua, Helichrysum mixtum, H. nudifolium var. pilosellum, Hemizygia pretoriae subsp. pretoriae, Hermannia grandistipula, Hypericum aethiopicum, Lichtensteinia interrupta, Pimpinella caffra, Senecio glaberrimus, S. latifolius, Stachys nigricans, Vernonia galpinii, V. oligocephala. Geophytic Herbs: Hypoxis hemerocallidea, Pachycarpus concolor. Succulent Herbs: Aloe minima, A. parvibracteata, Senecio oxyriifolius. Geoxylic Suffrutex: Salacia kraussii

Conservation: Vulnerable. Target 19%. Only 4% statutorily conserves, mainly in the Hluhluwe- iMfolozi Park and ithala Game Reserve.

Figure 22: Vegetation type on the proposed development site

The proposed site falls within the 5km buffer of Ntinini Reserve (Figure 23).

Figure 23: Protected Areas in proximity to the proposed development site

The site is completely natural and the vegetation cover indicates that the veld is relatively well managed, due to the inclusion of fire by local communities, this is evident in Figure 24 below, as the vegetation footprint appears to not have changed in four decades. Dominant woody species include specie such as Acacia species, Gymnosporia species, Euclea species and Spirostachys africana, which are pioneer species that can outcompete the grass and herbaceous layer thus, in time, reducing the overall biodiversity of the ecosystem if not managed. There is indication of past farming practices, but the veld is mostly indigenous on site with the odd alien Prickly pear (Opuntia ficus-indica).

Plate 15: Natural vegetation on-site

Figure 24: Image indicating historical vegetation and present vegetation on the site.

A total of 74 plant species that were recorded during this field survey. One (1) tree species that are protected by Provincial Legislation and seven (7) that are protected by National Legislation were noted within the site. The plant species that fall under the protection of the KwaZulu-Natal

Nature Conservation Management Act and National legislation are listed below (refer to Appendix 3 of Appendix D6, for the complete species list). Provincially protected:

• Albuca sp. • Aloe suffulta • Aloe parvibracteata • Aloe spectabilis • Aloe maculata • Sansevieria metallica • Hypoxis hemerocallidea Nationally protected:

• Sclerocarya birrea subsp. caffra A list of the relevant protected species and their coordinates can be found in Appendix 4 of Appendix D6. Figure 25 indicates the location of these species in relation to the proposed development footprint.

Figure 25: Location of protected plant species within proposed footprint

The site is mapped as Northern Zululand Sourveld (SVi22) which is considered vulnerable. It is also within the 5km buffer of the protected area, Ntinini Nature Reserve. The site is completely natural, and the vegetation cover indicates that the veld is relatively well managed, due to the inclusion of fire by local communities. Woody species such as Acacia species, Gymnosporia species, Euclea species and Spirostachys africana are pioneer species that can outcompete the grass and herbaceous layer thus reducing the overall biodiversity of the ecosystem and as such 98

should continue to be managed by fire. There were several nationally and provincially protected species on site, however none of them are considered rare and thus their removal would not be to the detriment of the species existence.

Figure 26: (From left to right) Aloe spectabilis, Sansevieria metallica and Albuca sp.

There are a few sensitive species on site. The site exhibits signs of past agricultural practices, and thus in parts, consists of secondary grassland. Having undertaken the assessment of the proposed development footprint the following findings were noted.

• The site is CBA irreplaceable; • The site is Northern Zululand Sourveld (SVi22) which is considered vulnerable; • The site is within 5km of a protected area, Ntinini Forest Nature Reserve; • As the site is within 5km of a protected area, the clearance of 300m2 natural endangered vegetation would trigger a Basic Assessment as per the Environmental Impact Assessment Regulations Listing Notice 1, Activity 30 of 2014 as amended in 2017; • The site on the whole is mostly indigenous with a few protected species within the grassland and in the understory of the woody clumps; • Provincially and Nationally protected trees and bulbous species were present on site It is important to mention that additional species may have been overlooked during the field survey due to the plant life history characteristics exhibited by certain plant species. However, the vegetation that was recorded provides enough information to make inferences and extrapolations as to the quality, and the likely impacts associated with a development of this nature. Should the need arise for indigenous trees to be cut and / or destroyed in the developable area, a DAFF permit will need to be obtained. The permit and application will need to be made and an offset for the loss of these individuals will be required, usually planting 5 individuals of the same species for each tree that will be lost. These trees could be retained as part of the indigenous landscaping. If relocation of some of the provincially protected species is required, a permit for their removal will need to be obtained by Ezemvelo KZN Wildlife. Removal and should occur during the summer months by a qualified botanist or similarly qualified individual. The plants should be relocated into areas with the same aspect, soil conditions and elevation to ensure that the relocations are successful. In addition, the plants should be placed into good-sized holes that are at least twice

the size of underground organs. It is very important for survival for underground organs not to be damaged and for plants to be watered for a period of time. 6.5. Geotechnical Assessment The Geotechnical assessment has been conducted by M Hadlow of Drennan Maude, and the full report is in Appendix D2. The report outlines the geology of the site, an assessment of the geotechnical conditions in the area and our preliminary recommendations for the proposed development of the site, 6.4.1. Topography and Drainage The site is located on the mid to lower generally northerly to north easterly facing slopes of an approximately east- west trending ridge, forming the southern bank of the White Mfolozi River which flows in a south easterly direction, on the northern to north eastern boundary of the site. The western edge of the spur comprises a moderately incised northerly flowing stream valley tributary of the White Mfolozi River, the Mhlanganeni River. This river crosses the north eastern edge of the proposed Babanango Tented Camp site (Drennan Maud, 2019). The natural ground slopes relatively gently to moderately from the upper southern portion of the site towards the White Mfolozi River. The bank directly adjacent to the river is steep comprising terraced cliffs and ledges. The drawing provided by NatureStamp showing the 100yr flood line indicates that the flood line appears to occur above the ledges adjacent to the river (Drennan Maud, 2019). The Mhlanganeni River which dissects the western portion of the site forms a moderately incised gently sloping stream valley approximately 15 to 20 m wide with steep sloping, greater than 15° valley sides. The area to the west of the stream valley slopes relatively gently towards the White Mfolozi River at the mouth of the tributary, and to the west and north, towards an elevated ridge located between the site and the river. (Drennan Maud, 2019). The site is currently accessed by a gravel road extending from the south where the road forks and extends directly north to the relatively level area behind the ridge on the western side of the stream tributary, or crosses the tributary approximately 500m up slope of the mouth and extends in a northerly direction above the eastern bank of the tributary towards the BTC site (Drennan Maud, 2019). Drainage of the site is dominated by the Mhlanganeni River in the west and the White Mfolozi River in the north which flow in a south easterly direction. The approximate extent of the Travellers Camp site development, including access roads and proposed staff accommodation units is shown on the Site Development Plan, Drawing ¹ 19017 - S1 100-01 Rev G, Prepared by Luxury Frontiers, which is used to prepare DML Site Plan Drawing ¹ 32687TC-01. 6.4.2. Geology and Soils The general location of the development, showing the general geology from the 1:250,000 Dundee geological plan, Plan ¹ 2830, is included herewith as Drawing ¹ 32687TC-02. The regional geology of the immediate area is dominated by Swazian intrusive granite and the colluvial and residual soils derived therefrom. The granite in the area has been intruded into by both Randium diabase dykes and Jurassic dolerite dykes. In addition, as the site is located on the mid to lower 100

slopes adjacent to the river and river tributary, some alluvial sediments overlie the weathered bedrock. A site walk over was carried out at the time of the inspection with the following being general observations. Main Area Building The main building area is located on the central portion of the proposed Travellers Camp site development, on the gently sloping terrace area above and to the south of the steep cliffs/exposed rock, on the southern bank of the White Mfolozi River. The main area building comprises the following; various back of house structures, including kitchen, bakery and laundry with an entrance service yard, the main lodge comprising access turning circle, reception area, dining area, lounge and bar area and library, a wine cellar is to be located below the service bar and a portion of the dining area, a terrace and pool area are to be located to the north of the main area. Examination of the subsoils in the Main Area indicates that the area is underlain by shallow to very shallow soils and slightly weathered, hard rock granite bedrock with shallow granitic bedrock outcrop with overlying boulders or very shallow soils in the position of the proposed Main Area where the wine cellar is to be located. Staff Accommodation Units The staff accommodation units are located on the upper south eastern portion of the site. Slopes in the area are relatively gentle and the area is underlain by shallow sandy and gravelly soils overlying the granite bedrock. Accommodation Units, Units 9 - 14 The accommodation Units 9 to 13 are located on the gently sloping terrace area above and to the south of the steep cliffs/exposed rock, on the southern bank of the White Mfolozi River, to the east of the Main Area. Unit 9 comprises a double unit and Unit 10 to 14 comprise single units. Slopes in the area are relatively gentle and the area is underlain by very shallow to shallow sandy soils and boulders overlying the granite bedrock. The depth to slightly weathered, very hard rock granitic bedrock is likely to vary from surface to no greater than 1m. The accommodation Units 9 to 13 are located on the gently sloping terrace area above and to the south of the steep cliffs/exposed rock, on the southern bank of the White Mfolozi River, to the east of the Main Area. Unit 9 comprises a double unit and Unit 10 to 14 comprise single units. Slopes in the area are relatively gentle and the area is underlain by very shallow to shallow sandy soils and boulders overlying the granite bedrock. The depth to slightly weathered, very hard rock granitic bedrock is likely to vary from surface to no greater than 1m. Accommodation Units, Units 1 - 3 The accommodation Units 1 to 3 are located on the more elevated spur to the east of the Mhlanganeni River on the gently to moderately sloping area above and to the south of the steep cliffs/exposed rock, on the southern bank of the White Mfolozi River. Slopes in the area are relatively gentle and the area is underlain by very shallow to shallow sandy soils and boulders overlying the granite bedrock. The depth to slightly weathered, very hard rock granitic bedrock is likely to vary from surface to no greater than 1m. 101

Wellness Centre The proposed Wellness Centre is located on the north western side of the area, on a more elevated spur to the north west of the Mhlanganeni River. The original proposed location has been changed such that the centre is now located on a saddle on the spur where the natural ground slope is gently to moderate. The spur is underlain at a relatively shallow depth by medium to slightly weathered, very hard rock, closely to very closely jointed dolerite bedrock. IP 2 was excavated in the approximate location of the Wellness Centre. Timber Suspension Bridge A timber suspension bridge is to be located across the Mhlanganeni River approximately 80 metres upstream of its confluence with the White Mfolozi River. The subsoils in this area comprise loose alluvial sands on both the eastern and western banks of the proposed crossing. 6.4.3. General Based on the development proposals and the results of our assessment and observations on site, it is evident that the proposed development is feasible. There are however a number of geotechnical aspects likely to influence the proposed development. The geotechnical aspects likely to influence the proposed development can be summarised as follows:-

• Relatively moderate to severe topography with moderate slopes and possible cliffs and rock outcrop on surface. • Relatively shallow hard rock. • Possible deep loose alluvial sands. The primary influences of these features on the development are likely to include, but not be limited to the following;

• Excavatability of the subsoils/bedrock for the construction of platforms, service trenches, structures foundations and any basement structures such as a wine cellar. • Collapse potential of the shallow sandy colluvial and alluvial subsoils. The suitability of the in-situ materials for use in the various aspects of the development of the site. 6.4.4. Excavatability Based on the site assessment it is evident that shallow granitic bedrock occurs underlying the entire site development area except on the area comprising the banks of the Mhlanganeni River which are underlain by alluvial sandy soils and boulders. Very hard rock, highly becoming slightly weathered granitic bedrock either crops out on surface or is overlain by shallow soils containing sandy gravel and boulders comprising the colluvial scree overlying the bedrock. Excavation of inspection pits using a TLB, testing the approximate depth of rippability, revealed that hard to very hard rock jointed, spalled, showing onion weathering, granite bedrock underlies the proposed development area. The degree of weathering and excavatability of bedrock varies depending on its position relative to joints and shears in the granite and the accumulation of colluvial or alluvial soils and boulders, gravels overlying the bedrock. In general, easy excavation is not likely to be possible greater than 500mm below the existing ground level.

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Taking the above into consideration, it is evident that hard excavation, requiring the use of pneumatic tools or even blasting is likely to be necessary for the excavation of service trenches, foundations and any basement structures such as the wine cellar. 6.4.5. Founding Conditions Founding conditions across the site are considered favourable in the sense that shallow bedrock occurs across almost the entire site area. In this regard, shallow column bases or strip footings can be taken into the weathered bedrock for founding of structures. Materials Suitability Based on the available laboratory test results and the results of the tests carried out on the granitic material occurring on this site, it is evident that in general, the weathered granite material comprises a well graded gravelly sand and is good to excellent as a subgrade material and for use in bulk filling and selected layers in road construction. 6.4.5. Excavatability Colluvium/Alluvium Excavation through the colluvial, residual and alluvial materials occurring on the site is expected to be easy although some difficulty may be encountered with the larger alluvial boulders. It must be noted that the sandy alluvial materials on the gentler slopes adjacent to the stream tributary will be unstable and side wall collapse should be expected when excavating foundations. For deeper excavations, within the loose sandy alluvium, shoring of sidewalls will be required. Granite Excavation through the weathered granite bedrock at a shallow depth up to about 1m on the upper slopes is likely to be soft. However, excavation will become soft to medium hard rapidly with depth and intermediate excavation at depths less than 500mm may occur on the slopes above riverbank. Dolerite Excavation in the weathered dolerite will be similar to that of the granitic bedrock. 6.4.6. Groundwater Conditions No groundwater was noted on the steeper upper slopes where the development is proposed. However, during periods of high rainfall groundwater seepage may occur at the contact between the gravelly and sandy colluvial soils and alluvial soils and the underlying weathered bedrock. 6.4.7. Slope Stability The existing natural slope is considered gentle except on the steeper cliffs adjacent to the river and the sandy alluvial banks of the river tributary. No areas of gross slope instability were identified on the preliminary assessment. However, it must be noted that sandy soils overlying the granitic bedrock and the alluvial derived sandy soils, will be susceptible to erosion by both wind and water.

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6.6. Flood Assessment The Flood assessment was conducted by Dr Bruce Scott-Shaw and Nick Davis of NatureStamp (Pty) Ltd and the full report is appended as Appendix D5. 6.6.1. Gauged versus Ungauged Catchments Flood hydrology assessments can be limited if the information available is scant. In the Mfolozi area (which is currently experiencing a severe on-going drought) most of the smaller tributaries (excluding large rivers) do not flow all year round as they have done in the past. This can be explained by changes in land use through intensification and increased areas under crops or commercial forests, an increase in water extraction (irrigation, dams, industrial needs and human needs), cyclic drought and climate change. Much of the flow in these rivers is not always accurately recorded by weirs. When a flood hydrology assessment is undertaken, depending on the data available, either gauged or ungauged catchments can be assessed. Gauged data are the most accurate approach assuming that the data quality is reliable and over a long period of time. In the absence of such data, an ungauged catchment is assessed using observed rainfall. This data (assuming it is of good quality) is used as an input to a rainfall-runoff model. The design flood is determined using a statistical analysis of the rainfall and the catchment characteristics. In large catchment areas the antecedent moisture content is important for 1:100-year flood events. If the catchment is very dry before such an event, dams may fill up first from the flood waters and part of the rainfall may infiltrate, resulting in a reduced flow through the system, whereas a saturated catchment would result in a shorter lag time and a larger flow volume in the channel. This can lead to a difference in a simulated flood using design rainfall (ungauged) and a flood using observed streamflow (gauged). Furthermore, the large flood events are often poorly recorded in weirs due to poor maintenance and overtopping. For the study area, streamflow data is available at one gauging weirs (with the other potential site having only a very short data record). A detailed desktop assessment was undertaken for the site. A site visit was conducted by Bruce Scott-Shaw of NatureStamp and Mark Summers of SiVEST (PTY) Ltd. Undertook a site visit in on the 18th August 2019. The pre-development conditions were assessed as follows:

• The vegetation characteristics of the watercourse were assessed for the determination of the Manning’s n-values; • The presence and dimensions of any crossings, such as culverts and bridges, that would act as a barrier to a flood event and that may be damaged during the occurrence of such an event were noted; • The overall state of drainage channels, streams and rivers was assessed; • The slope of the study site as well as evidence of flood damage and erosion around the site were noted; • The state of existing gauging stations was assessed to determine if the structure is accurately recording streamflow (e.g. evidence of under cutting or damaged features); and • The elevation at the water level and camp area level in order to verify contour data. The White Mfolozi was flowing at the time of the site visit, albeit at a low flow level given the size of the catchment and the time of year. As a result, a full river profile analysis was possible using a Trimble GPS.

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6.6.2. Flood Line Determination Modelling of the flood lines was undertaken using the U.S. Army Corps of Engineers’ HEC-RAS v4.1 programme, which is commonly used throughout South Africa. Numerous cross sections were created throughout the contributing area (Error! Reference source not found.). Ineffective areas/hydraulic structures were digitized and included in the model. Land use coverage was used to determine the Manning’s n-values in a GIS platform. Each cross section may have had numerous values on either side of the channel depending on the site characteristics. Manning’s N-values were obtained from the HEC-RAS Hydraulic Reference Manual (2010) for the channel areas (a value of between 0.03 and 0.04 was used depending on the presence or absence of rock features and debris). Design flood values were used as an input for the relevant reaches.

Given the slope of the catchment and the distance to downstream hydrological infrastructure, no inundation within the study site would occur from external features on the watercourse. As such, Normal Depth was selected for the reach boundary conditions. The slope of the channel was used as the value for the backwater calculation of the initial condition. Some inundation structures were included in the cross sections where there were structures present Figure 27).

Figure 27: Longitudinal profile and channel cross sections developed for the While Umfolozi River

6.6.3. Desktop Hydrological Assessment A detailed assessment of the rainfall stations and weirs was undertaken for the contributing catchment area. Rainfall stations were considered based on their proximity to the site, altitude and length/reliability of the data record. In similar vein, flow gauging stations were considered only if good quality data with a reasonable record length was available. Table 41 provides an overview of the stations within the contributing catchment area.

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Table 41: Comparison of values from some of the gauging stations that were assessed during the data analysis

Plate 16: Images showing the 1984 Demoina floods which exceeded the White Mfolozi Bridge (Kovacs et al., 1985)

6.6.4. Flow Analysis Data from the gauging stations W2H005 near Ulundi was analysed. This data was compared to upstream and downstream gauges in order to isolate potential errors and check the consistency of the data. The data shows that the peak flow was during the 1984 Demoina flood was not recorded. Many of the gauges in this area were exceeded during this period. This flood is widely believed to be a 1:100-year flood in this area.

Given the missing data for this important period, an investigation was undertaken to determine the actual flood event so that a full record could be synthesized. A detailed study commissioned by the Department of Water Affairs in 1985 (Kovacs et al., 1985) provided valuable data for this study.

6.6.5. Hydraulic Modelling Various hydraulic models were produced in HEC-RAS and exported to HEC-geoRAS by importing river centreline, cross sections, water surfaces and flow data from GIS layers and the hydrologic model. This allowed for inundation mapping and flood line polygons to be generated. The water surface TIN was converted to a GRID, and then actual elevation model was subtracted from the water surface grid. The area with positive results (meaning the water surface is higher than the

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terrain) illustrated the flood area, whereas the area with negative results illustrated the dry areas not inundated by the flood. Inundation can be seen along the watercourse (Figure 29).

Figure 28: : Steady state analysis of the 1:100 year flood event through some of the cross sections

Figure 29: 1:100 year flood line for the tented camp adjacent to the White Mfolozi river 107

6.7. Hydrological Assessment NatureStamp was appointed to conduct a 1:5, 1:10 and 1:100-year flood line assessment of any significant stream or river system that may impact on the proposed development. An average annual water balance will be provided including an average dry and average wet month water balance. A set of recommendations are provided to inform the Environmental Impact Assessment and Water Use License application processes and help the landowners to manage the BTC water appropriately. Refer to Appendix D11 for the full report. The data obtained for the site showed a mean annual evaporation of 1 500 mm. The naturalized flow mean annual runoff for the greater catchment is 34.47 million m3 for the catchment area of 563 km2. The water balance for the greater Mfolozi system shows a low yield with a net loss of water. Irrigation is the biggest users of water in the catchment followed by urban and rural uses. There is a small component used by afforestation. This shows that there is no available water in this system. Groundwater resources are also low in this catchment. A water balance calculation was undertaken for the catchment, pre- and post-development. Naturalised flow and rainfall values were obtained from the WR2012 database. All surface areas in the catchment area was calculated. A second calculation was undertaken including the proposed BTC. The end water balance indicates whether the development should include flow requirements for downstream users and any mitigation measures to prevent flow changes. At the current design, there was no rainwater harvesting included in the water balance. The annual water balance shows that the only loss of water is through the two existing boreholes. The water balance incorporated a worst-case scenario which assumes 100 % abstraction for the borehole. This is unlikely as the camp would not be fully occupied all year round. However, it shows a small loss to groundwater resources and a gain in surface water discharge (Figure 30). Given the small footprint of the site, these changes to the hydrological state are negligible. There are a greater number of water users in the White Mfolozi system, particularly that of Ulundi town. Ulundi has ongoing developments such as the upgrade of waste treatment. Given the catchment analysis, it is clear that this system is stressed, and the highest priority water users are the community and the environment through a series of game reserves. Given the very small footprint of the development and that there is a net gain (although very small) of surface water contribution, there would be no impact on the downstream users. There are very little impervious surfaces on the site so peak flows would be minimal. Furthermore, the design of the structures is such that 1m3 of water would be attenuated for every 40m2 of hardened surface.

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Figure 30: Monthly rainfall and evaporation for Quaternary Catchment W21G

6.8. Agricultural Land Potential and Impact Assessment The Agricultural Land Potential and Impact Assessment was completed by VUNA Africa, and the full report can be found in Appendix D14. Agricultural land potential, under rainfed conditions, is determined by spatially assessing the occurring agroecosystems (soils, climate, terrain, vegetation and hydrology) and the interpretation thereof for agricultural use. The objective of this investigation is thus to investigate and report on the agro-ecosystems occurring at the proposed Travellers Camp extent (46.3 ha), with particular reference to:

• Climate; • Topography; • Soils; • Hydrology; and • Vegetation. Interpretation of these agroecosystems allows:

• Delineation of the spatial extent of relatively homogeneous sites for agricultural land use and the attributes thereof; • Deduction of the agricultural land potential of the delineated sites; and

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• Determination of impacts of the proposed change in land use on the current and potential agricultural land use at the study footprint. The Agricultural assessment found that the calculated annual water balance is negative (-1205 mm) indicating the absolute necessity of very deep, heavy textured soils to mitigate the negative annual climatic water balance. Unfortunately, such soil conditions do not occur at BTC. In summary, the climate limitations to cropping are severe to very severe due to low temperatures in winter, frost and moisture stress. Fairly recent digital satellite imagery was sourced and georeferenced. 10 m georeferenced contours were draped onto the imagery, plotted at 1: 5 000 scale and used as a base map in the field. The imagery also forms the backdrop to some of the maps contained in this report. Soils were assessed at a semi detail scale of mapping. Soil observations were cited in the landscape based on pedological, hydropedological and terrain unit considerations to determine soil patterns. Observations were not on a rigid grid. Soils were identified by auguring to 150 cm diagnostic depth or to impervious strata. Pedological and site data for each of the five observations are presented in Annexure A of Appendix 14, with their locations shown in Figure 31. The codes used in Annexure A are described in Annexure B of Appendix 14. Soil properties at each observation were recorded according to standard soil survey procedure for rainfed agriculture, with the following soil attributes recorded per observation and per soil horizon: horizon lower depth, horizon clay content, horizon sand grade, horizon Munsell colour, horizon structure, horizon wetness hazard and horizon cultivation factors. Effective root depth, depth limiting material, ground roughness, topsoil organic carbon and lithology were also determined at each observation. Soils were classified according to Soil Classification (2018). Soil classification, soil properties, ground roughness, climate and slope were interpreted and two soil management units (SMU’s) or sites defined. Each respective SMU has relatively homogeneous natural resources (soils, climate and terrain) and will thus provide a relatively similar growth climate for agriculture. A map indicating the SMUs across the site is shown in Figure 32.

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Figure 31: Location of soil observations

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Figure 32: Soils map with SMUs

6.8.1. SMU A1, A2 and A3: Lithosols on Strongly Sloping Land Extent: 26.9 ha or 58.1% Climate: 638 mm MAP and 18.1 ºC MAT Topography: 12% slope gradient, smooth surface Iswepe2220 (40 cm) soil form occurs. Orthic topsoils overlie albic subsoils which overlie hard rock (granite). Effective rooting depth is mostly 40 cm with the granite restricting root development. Profile texture is coarse sandy loam. The effective rooting soil depth together with the soil texture renders the water holding capacity and water storage capacity low, with total available soil moisture (TAM) calculated at 32 mm. Soil moisture in the profile will thus rapidly reach a wilting point after a rainfall event. The profile is very well-drained. Topsoil colour is yellowish-brown (Munsell values 10YR54) becoming paler in the underlying albic subsoil. Soil structure is massive (occasionally single grain) throughout and will provide a somewhat suitable rooting medium. There is no wetness hazard in the soil profile. The inherent profile fertility is gauged at being low with significant shortages of both macro- and micronutrients. Topsoil organic carbon is low medium, indicating a restrictive nitrogen mineralisation potential. Surface rock is absent. The soil profile carries an erosion risk. Limitations to agricultural production are soil depth, poor inherent 112

soil fertility, low water storage capacity and an erosion risk. Such soil conditions do not present a favourable cropping scenario. SMU A is nonarable. 6.8.2. SMU B1, B2, B3, B4: Lithosols on Moderately Steep Land with Outcrops Extent: 15.5 ha or 33.5% Climate: 638 mm MAP and 18.1 ºC MAT Topography: 15% slope gradient, surface rock and outcrops This SMU occurs just upslope and beyond the riparian extent of the White Mfolozi River. Mispah 1120 (10 cm) (Gra Bou) and minor occurrences of Milkwood 1200 (Bou) soil forms occur. Mostly orthic topsoils overlie hard rock. Effective rooting depth seldom exceeds 10 cm depth with hard granite and dolerite being the limiting materials to rooting. Profile texture is medium to coarse sandy loam to sandy clay loam. The effective rooting soil depth together with the soil texture renders the water holding capacity and water storage capacity low, with total available soil moisture (TAM) calculated at 20 mm. Soil moisture in the profile will thus reach a wilting point very soon after rainfall is received. Topsoil colour is brownish (Munsell values 10YR33 and 43) and occasionally black (Munsell value 10YRR21). 10 to 30% surface rock and boulders occur. Limitations to agricultural development are the moderately steep slope gradients (15%), shallow effective rooting depth and surface rock and boulders. SMU B is non-arable. 6.8.3. SMU C: Alluvial Soils on the Floodplain of the White Mfolozi River Extent: 0.4 ha or 0.9% Climate: 638 mm MAP and 18.1 ºC MAT Topography: 2% slope gradient, boulders, flood risk SMU C occupies the north-western corner of the study area. It occupies the riparian habitat of the White Mfolozi River. Alluvial soils (Lepelale 3100 soil form) occurs, together with riparian vegetation. A seasonal flood risk is in place. SMU C must be excluded from the development footprint of Travelers Camp as it carries a flood risk and occurs within a sensitive riparian habitat. SMU C is non-arable. 6.8.4. SMU D1, D2, D3, D4, D5: Ephemeral Channels Extent: 3.5 ha or 7.55% Climate: 638 mm MAP and 18.1 ºC MAT Topography: 12% slope gradient, outcrops, channels the occurring ephemeral channels only flow after extreme rainfall events. Their riparian habitats often extend beyond the channel beds, often occupied by riparian vegetation. Outcrops occur in places. Obvious limitations to agricultural development are the riparian habitat and associated vegetation, alluvial soils and outcrops. This SMU is non arable. 6.8.5. Vegetation evaluation Based on the dominant occurring grasses, information from BRU (2006) and methodologies to calculate veld score (Smith, 2006), veld condition is 55%. Average grazing capacity is determined at 5.5 ha/AU where an animal unit (AU) is defined as an animal that weighs 450 Kg and consumes 10 Kg of dry matter per day. This implies that the 46.3 ha Travelers Camp has the potential to support 8 animal units.

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Agricultural Land Potential The agricultural land potential was determined according to the method of Smith (2006) which is endorsed by the KwaZulu-Natal Department of Agriculture and Rural Affairs. Each of the 8 land potential classes is described in further details in Table 42.

Table 42: Description of land potential classes

The classification has been conducted for each SMU, with the agricultural land potential outcome shown in Figure 33 and Table 43. The agricultural land potential ranking is at an eight-class scale and is as follows: Arable classes Class L1 – very high agricultural land potential Class L2 – high agricultural land potential Class L3 – good agricultural land potential arable Class L4 – moderate agricultural land potential Non-arable classes Class L5 – restricted agricultural land potential Class L6 – very restricted agricultural land potential Class L7 – low agricultural land potential non-arable Class L8 – very low agricultural land potential

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Figure 33: Agricultural Land Potential

Criteria used to determine agricultural land potential per SMU are slope class, topsoil texture, effective root depth, soil permeability, wetness hazard, rockiness, soil crusting, bio-resource group, rainfall, evaporation, temperature, wind and hail. The entire Travelers Camp (46.3 ha) is non-arable with associated severe limitations for agriculture. The land is suitable for grazing and wildlife.

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Table 43: Agricultural land potential per SMU

6.9. Heritage Impact Assessment A Heritage Impact Assessment was conducted for the greater BGR area, by Jean Beater and Roy Muroyi. Refer to Appendix D9 for the full report.

6.9.1. Heritage Background Archaeological evidence shows that Bantu-speaking agriculturists first settled in southern Africa around AD 300. The earliest agricultural sites in KwaZulu-Natal date to between AD 400 and 550. All were situated close to sources of iron ore, and within 15 km of the coast. From 650 onwards, climatic conditions improved, and agriculturists expanded into the valleys of KwaZulu-Natal, where they settled close to rivers in savanna or bushveld environments. Metal production was a key activity since it provided the tools of cultivation and hunting. In general, sites dating between 1050 and 1250 are smaller than most earlier agriculturist settlements. This new pattern of settlement was in some way influenced by a changing climate, for there is evidence of increasing aridity from about AD 900. A new pattern of economic inter-dependence evolved that continued into the colonial period nearly 500 years later.

The survey noted the existence of many Iron Age Zulu stone walled homesteads. The stone walled sites consist of at least two distinct circular stone walled enclosures (livestock/cattle kraal), various sections of stone walling, some other less visible and distinct enclosures, with concentrations of stone cairns of varying sizes and other features. Iron Age studies have also noted the existence of these sites in the wider area. Archaeologists have also excavated some of these Iron Age sites in the interior grasslands of KwaZulu-Natal. These have aided in the interpretations for homestead patterns among the Zulu in the game reserve.

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The Babanango or Type B settlement sites consisted of primary stone enclosures arranged in a roughly circular plan and linked by secondary walls to form secondary enclosures. The entrances to the Babanango enclosures were often distinctive with carefully cobbled passages that were invariably placed to lead up the slope of the hill (Mitchell 2002:354).

The eMakhosini Cultural Landscape is a combination of historic sites, landscapes and history bound by oral traditions and cultural significance defining the Zulu culture. eMakhosini (literally “the valley of the chiefs”) lies south-east of the project area. Much of the area is defined by the presence of several stone walled sites associated with the powerful Buthelezi and Khumalo clans. These clans among others were key players in the formation of the Zulu kingdom. The famous King Shaka Zulu was born here around 1785 and it is here that his forbearers, Nkosinkulu Zulu, Phunga, Mageba, Ndaba, Jama and Senzangakhona lie buried. The graves and royal residences of four paramount rulers of the Zulu – Shaka, Dingane, Mpande and Cetswayo - are located in and around the eMakhosini Valley (G&A Heritage 2011:25).

During the Anglo-Boer, 1899-1902, the wider area saw action when the Boer forces invaded northern Natal and Zululand in 1901. Gelykwater, near Babanango was used by Louis Botha as a base for his attack on the British forces based at Mount Itala and Fort Prospect on 26 September 1901. His attack was eventually repelled, and the old farmhouse was used as a temporary hospital. The graves of several Boers who died in the attacks were buried in the farm cemetery (Carter 1971:6-7).

The field survey noted the existence of two disused mines in the game reserve, a copper mine and a kalk (lime) mine. According to oral history, the copper mine belonged to Paul Pollitzer, a geologist who committed suicide in 1910 after failing to get enough returns from the copper mine to pay bank loans he had taken to establish the copper mine. Using the date of the death of Pollitzer, the copper mine is dated to +/-110 years old. There is a possibility however that the copper mine might be older than this. Mining history of South Africa started much earlier. Generally, metallurgy was brought to southern Africa by early Iron Age farmers who, about 2000 years ago, made the journey across the Limpopo River and moved down along the eastern coast into southern Africa. Along with domesticated animals and plants, these farmers brought knowledge of metalworking. Initially iron, lime and copper were mined, smelted and traded in southern Africa on a small scale. But by the beginning of the 18th century metal goods from iron hoes to copper bangles were widely consumed across southern Africa and fed into a global trading system that linked the Indian Ocean rim, from the Mozambican coast to the Middle East, India and as far as China.

In 1498 on his first voyage to India, Vasco da Gama landed at the mouth of a 'small river', possibly the Limpopo, on the east coast of Southern Africa. The copper armlets and other ornaments worn by the local people were so plentiful that he called it the Rio de Cabre - the River of Copper. Two

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centuries later, Simon van der Stel, the Governor at the Cape, led an expedition northward into Namaqualand. His instructions were to find the source of the ore samples and metal artefacts that had been brought to the colony by local people. In the 1840s and 1850s, this part of Namaqualand and the north-western Cape Province became the scene of South Africa's first mining rush, which was for copper, and not for diamonds or gold as is commonly believed. Although many ventures failed, the mining of copper ores and the production of metal became firmly established at O'kiep in Namaqualand where operations continue to the present day. It is now also evident that most of the other major copper deposits, as well as the tin and iron deposits of South Africa, had been found and worked by local people long before the arrival of Europeans (Beale 1985:75). This may have been the case with the copper mine in the BGR.

Lime mines were used to extract lime that was used for plastering huts and other buildings. The evidence indicates that these mines were excavated by Iron Age Black people, who moved into South Africa from about A.D. 100 onwards. Of the well-known lime mines the Northern Lime Company was founded in 1907 to exploit a high-grade limestone deposit on the farm Uitloop in the Waterberg district of the then Northern Transvaal. In 1917 the company merged with the Nolan Lime Works at Taungs. The Taungs deposit consisted of a high-grade secondary limestone formation along the escarpment of the Kaap plateau. The deposit became known to the world following the discovery there of the famous Taungs Skull in 1924. The Taungs operation was gradually expanded to satisfy the growing demand, as the Uitloop operation had been closed down in 1925. A company called White Limes Limited was operating crude kilns in the Pietersburg (Pololwane) district burning limestone quarried in the caves at Makapansgat. The third of the major lime producers, Marble, Lime and Associated Industries, operated at Marble HaIl in the then North-Eastern Transvaal which was first worked in 1922 to produce monumental marble (Douglas 1969:18). No information could be found regarding the lime mine in the BGR.

6.9.2. Study Results Heritage

The tented camp is situated on the southern bank of the White Umfolozi River about 1.5 km south- east of the site of the proposed Madwaleni Lodge. The site was extensively walked including the riverbanks. It had a very thick grass layer with several rocky outcrops. No heritage resources were found in the proposed area of development during the site inspection.

Archaeology

Many of the Zulu homesteads found within the development footprint had minimal traces of the original structures. In some sections, the foundations of the huts and the cattle kraals are still visible whereas at other sites, only the cattle kraals are still standing, and the original homestead is no longer visible

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Plate 17: Overview of cattle kraals within development footprint

Iron Age farming community studies suggests that the type of cattle kraals found represent the ‘Central Cattle Pattern’ (CCP) where cattle were kept in the middle of the homestead, representing the wealthy of the family as well as their importance in the community. The field survey also noted the close proximity these sites to water sources. Iron Age sites of this nature were sited near water and good soils that could be cultivated with an iron hoe.

Certain patterns where noted on these homesteads across the game reserve. Surrounding the cattle kraals are smaller circles that are visible with standing walls at times and at times with faint foundations showing. In ethnographic literature, there is consensus on the form of the typical Zulu homestead, or umizi (plural imizi) that it is founded on three concentric circles. The outer of these rings is a fence of timber, bushes or stone walling. Inside the perimeter are the round, dome-shaped grass huts in which the occupants of the homestead live, while the innermost ring is a fenced cattle byre.

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Overall Findings for the greater BGR

Table 44: Field rating of heritage sites found

Name of the Coordinates Description/Condition Significance Field Rating & resource Actions

Zulu homesteads Various Iron Age Zulu stone walled Medium Generally Protected B homestead (see homesteads. The stone walled sites (GP.B) Appendix 1 for consist of at least two circular stone coordinates) walled enclosures (livestock/cattle The sites need to be kraal), various sections of stone recorded before walling, some homesteads are less destruction visible with less distinct enclosures, concentrations of stone cairns of varying sizes and other features.

Grinding Stone 28o 13I 00.8II S A lower grinding stone was within Medium Generally Protected B 31O 04I 52.8II E one of the abandoned homesteads. (GP.B) The grinding stone is evidence of the growing and use of crops such The artefact needs to as maize, millet or sorghum. be recorded before destruction

Stone Age hand Approximate: Stone Age hand axe found in Medium Generally Protected B axe 28o 13I 16.6II S isolation in a koppie in the vicinity of (GP.B) 31O 05I 54.3II E Lulu Farm The artefact needs to be recorded before destruction

China potsherd Approximate Piece of ceramic usually owned by Medium Generally Protected B 28°16’51.1” S the royal family as a symbol of (GP.B) 31°01’16.4” E status. The artefact needs to be recorded before destruction

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Copper mine and Approximate Two disused mines in the game High Copper mine: kalk mine centre copper reserve Local Grade IIIA mine: 28°17’11.2” S Site must be retained 31°00’49.3” E as a heritage site

Lime mine: Local Grade IIIB Lime mine: 28°13’52.7” S The site should be 31°10’03.9” E mitigated & part retained as a heritage site

Graves Many graves in Graves are protected by heritage High Local Grade IIIA BGR (see and other legislation Appendix 1 for Sites must be retained coordinates) as heritage sites Structures Several structures Several protected structures, i.e. Medium Generally Protected B in BGR (see >60 years (GP.B) Appendix 1 for coordinates) The structures need to be recorded before destruction

7. Impacts and Residual Risks Assessment 7.1. Introduction Impact assessment must take into account the nature, scale and duration of effects on the environment, whether such effects are positive (beneficial) or negative (detrimental).

It is also imperative that each issue / impact is also assessed according to the project stages from planning, through construction and operation to the decommissioning phase.

Where necessary, the proposal for mitigation or optimisation of an impact is noted.

The environmental impact assessment is focused on the following phases of the project namely: Pre-Construction, Construction, and Operational Phases only. The impacts associated with decommissioning phase are not applicable to this project, however, responsible methods of post- construction clean-up are provided in the EMPr. As the project entails rebuild of a residence which will be permanent, decommissioning is not applicable to this project, however, impacts associated with post construction clean-up are considered.

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7.2. Methodology The potential environmental impacts associated with the project are evaluated according to it nature, extent, duration, intensity, probability and significance of the impacts, whereby:

1. Nature This is a brief written statement of the environmental aspect being impacted upon by a particular action or activity.

2. Extent (E) Extent refers to the area over which the impact will be expressed. Typically, the severity and significance of an impact have different scales and as such bracketing ranges are often required. This is often useful during the detailed assessment phase of a project in terms of further defining the determined significance or intensity of an impact. • Site (1) – Within the construction site. • Local (2) – Within a radius of 2 km of the construction site. • Regional (3) – the scale applies to impacts on a provincial level and parts of neighbouring provinces. • National (4) – the scale applies to impacts that will affect the whole South Africa.

3. Duration (D) Duration indicates what the lifetime of the impact will be. • Short-term (1) – less than 5 years. • Medium-term (2) – between 5 and 15 years. • Long-term (3) – between 15 and 30 years. • Permanent (4) – over 30 years and resulting in a permanent and lasting change that will always be there.

4. Intensity (I) Intensity describes whether an impact is destructive or benign. • Very High (4) - Natural, cultural and social functions and processes are altered to extent that they permanently cease. • High (3) - Natural, cultural and social functions and processes are altered to extent that they temporarily cease. • Moderate (2) - Affected environment is altered, but natural, cultural and social functions and processes continue albeit in a modified way. • Low (1) - Impact affects the environment in such a way that natural, cultural and social functions and processes are not affected.

5. Probability (P) Probability describes the likelihood of an impact actually occurring. • Improbable (1) - Likelihood of the impact materialising is very low. • Possible (2) - The impact may occur. • Highly Probable (3) - Most likely that the impact will occur. • Definite (4) - Impact will certainly occur.

6. Cumulative (C) In relation to an activity, means the impact of an activity that in itself may not be significant but may become significant when added to the existing and potential impacts eventuating from similar or diverse activities or undertakings in the area.

7. Significance (S) Significance is determined through a synthesis of impact characteristics. Significance is an indication of the importance of the impact in terms of both physical extent and time scale, and therefore indicates the level

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of mitigation required. The total number of points scored for each impact indicates the level of significance of the impact.

7.3. Rating of Potential Impacts The potential impacts identified are explained per phase of the project and mitigation measures are provided. The impacts are explained per pre-construction, construction and operational phases.

Table 45: Significance ratings

Score Elaboration Permanent and important impacts. The design of the site may be NEGATIVE - (13 - 16 points) affected. Intensive remediation is needed during construction and / VERY HIGH or operational phases. Any activity which results in a “very high impact” is likely to be a fatal flaw. These are impacts which individually or combined pose a significantly high negative risk to the environment. These impacts NEGATIVE pose a high risk to the quality of the receiving environment. The - (10 - 12 points) design of the site may be affected. Mitigation and possible HIGH remediation are needed during the construction and / or operational phases. The effects of the impact may affect the broader environment. These are impacts which individually or combined pose a moderate negative risk to the quality of health of the receiving environment. These systems would not generally require immediate action but the NEGATIVE deficiencies should be rectified to avoid future problems and - (7 - 9 points) associated cost to rectify once in HIGH risk. Aesthetically and / or MODERATE physically non-compliance can be expected over a medium term. In this case, the impact is medium term, moderate in extent, mildly intense in its effect and probable. Mitigation is possible with additional design and construction inputs. These are impacts which individually or combined pose a deleterious or adverse impact and low negative risk to the quality of the receiving environment, and may lead to potential health, safety and environmental concerns. Aesthetically and / or physical non- NEGATIVE - (4 - 6 points) compliance can be expected for short periods. In this case, the LOW impact is short term, local in extent, not intense in its effect and may not be likely to occur. A low impact has no permanent impact of significance. Mitigation measures are feasible and are readily instituted as part of a standing design, construction or operating procedure. Impact is neither beneficial nor adverse. These are impacts which 0 NEUTRAL cannot be classified as either positive or negative or classified and null and void in the case of a negative impact being adequately mitigated to a state where it no longer renders a risk. These are impacts which individually or combined pose a low positive impact to the quality of the receiving environment and POSITIVE +(4 - 6 points) health, and may lead to potential health, safety and environmental LOW benefits. In this case the impact is short term, local in extent, not intense in its effect and may not be likely to occur. A low impact has no permanent impact of significance. 123

Score Elaboration These are impacts which individually or combined pose a moderate POSITIVE positive effect to the quality of health of the receiving environment. +(7 - 9 points) In this case the impact is medium term, moderate in extent, mildly MODERATE intense in its effect and probable.

These are impacts which individually or combined pose a significantly high positive impact on the environment. These impacts POSITIVE pose a high benefit to the quality of the receiving environment and +(10 - 12 points) health, and may lead to potential health, safety and environmental HIGH benefits. In this case the impact is longer term, greater in extent, intense in its effect and highly likely to occur. The effects of the impact may affect the broader environment. These are permanent and important beneficial impacts which may arise. Individually or combined, these pose a significantly high positive impact on the environment. These impacts pose a very high POSITIVE benefit to the quality of the receiving environment and health, and + (13 - 16 points) may lead to potential health, safety and environmental benefits. In VERY HIGH this case the impact is long term, greater in extent, intense in its effect and highly likely or definite to occur. The effects of the impact may affect the broader environment.

7.4. The Mitigation Hierarchy The suitability and feasibility of all proposed mitigation measures will be included in the assessment of significant impacts. This will be achieved through the comparison of the significance of the impact before and after the proposed mitigation measure is implemented. Mitigation measures identified as necessary will be included in an EMPr.

An important aspect of impact assessment is the identification and application of methods which mitigate against the impacts. In order to aid selection of mitigation measures, the mitigation hierarchy is used (Figure 34). The mitigation hierarchy is a tool that guides users toward limiting as far as possible the negative impacts on biodiversity from development projects. It emphasises best practice of avoiding and minimising any negative impacts, and then restoring (rehabilitating) sites no longer used by a project, before lastly considering off-setting residual impacts.

The mitigation hierarchy is crucial for all development projects aiming to achieve no overall negative impact on biodiversity or on balance a net gain (also referred to a No Net Loss and the Net Positive Approach). It is based on a series of essential, sequential steps that must be taken throughout the project’s life cycle in order to limit any negative impacts on biodiversity.

A recent cross-sector guide for implementing the Mitigation Hierarchy provides practical guidance, innovative approaches and examples to Mitigation Hierarchy support operationalizing the mitigation hierarchy effectively. The publication is aimed at environmental professionals working in, or with, extractive industries and financial institutions, who are responsible for overseeing the

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application of the mitigation hierarchy to biodiversity conservation, while balancing conservation needs with development priorities.

The sequential steps of the mitigation hierarchy are annotated on the diagram below (Figure 34).

Refers to considering options in project location, sitting, scale, layout, technology and phasing to avoid impacts on biodiversity, associated ecosystem services, and people. Avoid or Prevent This is the best option but is not always possible. Where environmental and social factors give rise to unacceptable negative impacts the activity should not take place. In such cases it is unlikely to be possible or appropriate to rely on the latter steps in the mitigation.

P Minimise Refers to considering alternatives in the project location, siting, scale, layout, technology and phasing that would minimise impacts on biodiversity and ecosystem R services. In cases where there are environmental and social constraints every effort E must be made to minimise impacts. F E Refers to rehabilitation of areas where impacts are unavoidable, and measures are R Rehabilitate provided to return impacted areas to near-natural state or an agreed land use. Although rehabilitation may fall short of replicating the diversity and complexity of a natural system. E N C E Off-set Refers to measures over and above rehabilitation to compensate for the residual negative effects on biodiversity, after every effort has been made to minimise and then rehabilitate impacts. Offsets can provide a mechanism to compensate for significant residual impacts.

Figure 34: The Mitigation Hierarchy

7.5. Impact Assessment This section presents the impact assessment according the methodology in the preceding sections, in a tabular form.

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Table 46: Planning Phase Impact Assessment

No. Impact Alternative Mitigation Interpretation Phase: Planning and Design Sub-phase: Direct Impacts

Inadequate or incompetent Planning and Design for the house and Without Negative high garage (taking into consideration the best environmental solutions which can be accommodated by the budget assigned)

1 With Negative low Mitigation: (a) Ensure best practicable solutions of design which is best suited to the study area and receiving environment. (b) Ensure correct, peer and supervisor reviewed designs are developed. Furthermore, it is paramount that the findings of this BAR and the associated specialist findings are incorporated into the design to avoid sensitive areas.

The dramatic memorable landscape setting of the broad White Mfolozi valley with its largely indigenous vegetation flanked by the tall steep ridgeline that forms the southern valley side could be impacted on if not Without Negative high properly planned to avoid

1 With Negative low

Mitigation: All elements of the EMPr must be abided by. The construction areas should be clearly identified including access roads, stockpile or excavation areas, storage facilities and parking areas. “No Go” areas should be clearly identified for the entirety of the construction phase. Demarcated areas should be marked using easily visible fencing and should be properly maintained during construction. All demarcated areas need to be agreed upon with an ECO before construction begins. Work conducted in the river channel and banks needs to be overseen by an ECO so that sediment loads are controlled (by appropriate control 2 techniques).

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Consideration for national, provincial and local plans in the planning for the development Without Negative Moderate 1 With Positive high

3 Mitigation: All relevant plans for the area must be considered and adequate consultation with the relevant planning officials in the area.

Development in sensitive habitats could lead to the diminishing of the socio-economic benefits. Without Negative Moderate 1 With Positive high Mitigation: No construction work is permitted across the road or beyond the existing platform. The social impact is a positive which is expected to outweigh any negative impact. 4

Appropriate planning of exclusion of sensitive vegetation and steep areas. Without Negative high 1 With Negative low Mitigation: No construction work is permitted across the road or beyond the existing platform. Avoidance of the areas with severe current gully erosion in the area and steep areas. No-go areas must be clearly marked off.

5 Possible lack of consideration of what the environment can Without Negative high accommodate. 1 With Negative low

Mitigation: All measures and considerations for the design of the house must consider the triple bottom line and ensure optimisation of social, 6 economic, environmental and practical benefits. Without Negative Moderate Unstable design which will require maintenance in the near future 1 With Negative low Mitigation: Ensure that the best practicable design is used and that the professionalism and integrity of the design is maintained.

7 Sub-phase: Indirect Impacts

Erosion will be lessened / controlled by the BTC Without Positive low 8 1 With Positive high

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Mitigation: Responsible design and planning for the residential rebuild.

Sub-phase: Cumulative Impacts

THE BTC will develop the BGR with has a broader scale benefit Without Positive moderate 1 With Positive very high Mitigation: Implement the BTC 9 Average without mitigation Negative low Average with mitigation Positive low

Table 47: Planning Phase Impact Assessment – No-Go Alternative

No. Impact Alternative Mitigation Interpretation

Phase: Planning and Design - No-go

The status quo would remain, and the short-term impacts will not occur 1 N/A Positive moderate Mitigation: N/A 1

Maintaining the status quo also means that the key opportunity for conservation and nature-based tourism revenue and stewardship is lost 1 N/A Negative very high

2 Mitigation: The development should go ahead to prevent social ills of vandalism and degradation.

The community and ECT will lose the development environmental, social and economic benefits 1 Without Negative very high

3 Mitigation: The development should be approved in the interest of fairness. 128

Average without mitigation Negative Low Average with mitigation Neutral

Table 48: Construction Phase Impact Assessment

No. Impact Alternative Mitigation Interpretation Phase: Construction Sub-phase: Direct Impacts

Loss of natural/indigenous vegetation and alien invasion: clearing of riparian vegetation in and around the development footprint and change in the composition and structure of the riparian vegetation. This will/may be caused by: Direct removal of indigenous species for construction clearing and by workers for medicinal purposes. Due to a disturbance of the channel bed and banks the removal of indigenous species and further ruderal and alien plant Without Negative high invasion will occur. This may also further increase the rate of erosion as previously discussed. The likely introduction of alien seeds in spoil obtained from nearby areas. The removal of topsoil will further encourage alien pioneers which can grow under such conditions.

Additionally, there is the Impact of loss of grazing veld and grazing potential.

1 With Negative low Mitigation: All growth forms of Category 1 weeds and invader plants shall actively be removed from all works areas, at all times; Areas for re- vegetation/alien clearing should be demarcated in order to prevent further disturbance. Furthermore, access roads for machinery should avoid any of the vegetation focus areas and areas with existing natural vegetation; All Category 2 and 3 weeds and invader plants shall be actively removed all prior to flowering. All riparian areas disturbed during the construction phase must be rehabilitated and re-vegetated according to a construction phase rehabilitation plan compiled by an aquatic specialist in conjunction with a vegetation specialist; and Follow up assessments should be undertaken to prevent alien re-growth in alignment with time frames identified by a re-vegetation plan/vegetation specialist. Loss of 46.3 ha of grazing veld with a carrying capacity of 8 animal units is negligible. 1 Hydrocarbon spills from Heavy Machinery and vehicle movement causing Groundwater contamination and surface seepage runoff 2 1 Without Negative high

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With Negative low

Mitigation: Containment for all fuel stored on site; Implementation of a groundwater monitoring programme. Accurate oil records must be kept (purchased, disposal, and recycled). Ensure that clean-up protocols are in place and adhered to.

Pollution caused during construction. An increase in pollution due to air emissions from heavy machinery, potential leaks of fuel, grease and oil from the heavy machinery. Wash related to the above-mentioned changes during rainfall events will lead to the movement of these waste substances into the soil and the river. o the storage of hazardous chemicals such as fuel, ablution facilities that may leak, and any spills, such as concrete, during construction. If not properly Without Negative Moderate managed, this may lead to impacts long after the construction is completed. o As the Mfolozi system is a River FEPA, water quality is of high importance. Aquatic species may be poisoned thus resulting in death (in the localised area) or movement away from the site. This may influence the ability of the aquatic species from breeding successfully as the lack of breeding species may disrupt upstream and downstream populations. Changes to Dissolved Oxygen (DO) and Total Dissolved Solids (TDS) as a result of a reduction in aquatic plants may detrimentally impact on invertebrate and vertebrate species. o Noise pollution by machinery and labourers may affect nearby and wildlife. Fauna that would otherwise cross through this system may avoid this area resulting in reduction in local biodiversity.

3 1 With Negative low

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Mitigation: (a) The construction storage area must be sited away from drainage lines. (b) Construction must be undertaken according to a site- specific approved Environmental Management Programme (EMPr) and must be monitored by the Municipalities Building Control office. (c) All solid waste must be removed to an appropriate disposal facility. (d) No discharge of any pollutants, such as fuels, cements, concrete, lime, and chemicals are allowed into coastal habitats. (e) Waste receptacles should be provided and regularly cleaned, and waste moved to an appropriate disposal facility. (f) A Stormwater Management System to be implemented during both construction and operational phases of the development. It is recommended that groundwater level and quality monitoring be conducted to ensure no detrimental impact is posed to groundwater resources due to abstraction. A groundwater monitoring plan is compiled in Section 6 of the Geohydrological Assessment. The data obtained from the monitoring should be assessed after 12 months to re-evaluate the recommended abstraction volumes. Groundwater sampling of all boreholes should be conducted to ensure water is safe for human consumption. Septic tanks must be monitored, and the designs must allow for a closed system with sufficient volumes for the amount of people catered for at the lodges. If the mitigation measures are followed in the form of a detailed rehabilitation plan, the overall impact should be reduced. The following points were identified in the study: 1. The Mfolozi system has been identified as a priority area. 2. There will be some impacts that need to be rehabilitated on-site. 3. All of these impacts should follow the recommended rehabilitation, mitigation and monitoring. 4. Some of the units should be moved further away from the river to ensure impacts are minimal and the flood risk is avoided. 5. Wastewater treatment should be located 100 meters away from the river. 6. The general site location is suitable for the tented camp in relation to other potential areas

Construction of the tented camp will result in a disturbance to the White Mfolozi habitat within the construction footprint and possibly locally downstream during the construction/implementation phase. These potential impacts include:

Change in the land cover and roughness characteristics: by the removal of vegetation and topsoil, addition of spoil sites leading to wash, and compaction by heavy machinery resulting in increased runoff. This impact is linked to subsequent changes in the hydrological partitions and modifications to the slope and soil characteristics (changes to vegetation cover, root content and infiltration rates). Each of these are further described as: o The potential increase in slope with the addition of spoil sites and bank construction will enhance existing erosion potential (greater energy for sediment wash); The reduction in vegetation cover will expose bare soil to the elements (rain and wind) and reduce surface roughness that will lead to increased surface 4 runoff and increased rates of erosion, particularly if erosion and runoff control 1 Without Negative Moderate

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measures are not implemented. This will lead to sheet wash, rill and gully erosion and may also lead to the collapse or slumping of bank areas. Such impact would in turn lead to the burying of the marginal riparian and edge instream habitat. Compaction (due to traversing of heavy machinery) and hardening (change from previous areas to impervious areas i.e. roads) would result in increased runoff and the likely transport of sediment into the river; An increase in the turbidity of the river may occur as a result of the washing of sediment into the water during construction. Contaminants from spoil sites may infiltrate the river leading to a reduction in water quality. The placement of the spoil site is likely to be invaded by alien vegetation which are, by nature, excellent pioneer species.

With Negative low Mitigation: The construction areas should be clearly identified including access roads, stockpile or excavation areas, storage facilities and parking areas. o “No Go” areas should be clearly identified for the entirety of the construction phase. o Demarcated areas should be marked using easily visible fencing and should be properly maintained during construction. o All demarcated areas need to be agreed upon with an ECO before construction begins. o Work conducted in the river channel and banks needs to be overseen by an ECO so that sediment loads are controlled (by appropriate control techniques).

Erosion control measures (such as silt traps) need to be placed around all stockpiles to prevent sediment wash. o Topsoil stripped from the construction footprint must not be spoiled but stockpiled and preserved for use in rehabilitation. Top-soil and sub-soil stockpiles to be placed on flat areas away from the watercourse where they will cause the least impact. o Vehicles should be parked at suitable construction zoned areas when not in use in order to prevent compaction of the soil profile. o the construction camp should be located more than 100m from watercourses. o Topsoil should be replaced in the correct order it was extracted and erosion prevention measures be put in place on areas with a steep gradient (such as geo-textiles). o Any excess subsoil must be removed from the road area once back filling is completed and spoiled at an agreed spoil site.

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Stockpiles must be clearly demarcated and be kept free of weeds and compaction. The condition of the banks around the development need to be checked by the ECO during operation and signed off if in a controlled, stabilized state. Bank areas need to be stabilized before re-vegetation occurs. Bare, exposed areas need to be stabilized by permeable geo-textiles (e.g. hessian) in order to give the vegetation a chance to establish. All growth forms of Category 1 weeds and invader plants shall actively be removed from all works areas, at all times; Areas for re- vegetation/alien clearing should be demarcated in order to prevent further disturbance. Furthermore, access roads for machinery should avoid any of the vegetation focus areas and areas with existing natural vegetation; All Category 2 and 3 weeds and invader plants shall be actively removed all prior to flowering. All riparian areas disturbed during the construction phase must be rehabilitated and re-vegetated according to a construction phase rehabilitation plan compiled by an aquatic specialist in conjunction with a vegetation specialist; and Follow up assessments should be undertaken to prevent alien re-growth in alignment with time frames identified by a re-vegetation plan/vegetation specialist.

Pollution caused during construction and Groundwater contamination during Without Negative high fuel spillages from heavy machinery and vehicle movement 1 With Negative low Mitigation: All chemicals should be appropriately stored and handled. Storerooms must be more than 100m from watercourse zones and have appropriate concrete flooring and bunding. o A Spill Contingency Plan should form part of the Environmental Management Programme (EMPr). The Spill Contingency Plan should address measures to prevent and mitigate the spillage of hazardous materials, which include oil, grease and petrochemicals as well as herbicides which may be used as part of the alien clearing operation. No washing of construction equipment and vehicles must be done on site. Any remnant rubbish, spoil, machinery and contaminants need to be removed from the development area. Vehicles or machinery must not be serviced or re- fuelled within 100m of the watercourse zones. Pumping from the river needs to be done from a controlled point in the river to prevent the disruption to aquatic species. Furthermore, the pump needs to be placed above a drip tray. Appropriate ablution facilities should be more than 100m from the river. Systems should be completely self-contained with no effluent released into the environment. Rubbish bins need to be placed on site so that no litter or food waste is left around the development. The mitigation measures would include containment for all fuel stored on site and implementing a groundwater monitoring programme. This would allow for the early detection of water quality deterioration associated with the site. Accurate oil records must be kept (purchased, disposal 5 and recycled). Ensure that clean-up protocols are in place and adhered to.

Disturbance to fauna around the construction site. This is seen as the main Without Negative high negative impacts of the proposed development. 1 With Negative Moderate Mitigation: Construction activities must be limited to the allowed working area only, with all areas outside of this being demarcated as strictly no- go areas. An independent Environmental Control Officer should conduct monthly site inspections to assess the Contractors compliance with the EMPr. Permits for the removal and relocation of plants and animals must be in place before any construction can commence. A search and rescue operation, undertaken by a suitably qualified person, must be undertaken before construction commences. Strictly no trapping, hunting or poaching or fauna may occur. A fine system should be considered by the EAP for the illegal hunting of fauna. Clearance in the construction phase is to be remove in a phased approach, as and when it becomes necessary. The contractor should implement an alien invasive control programme, particularly in areas where soil disturbance occurs. community outreach regarding poaching of fauna should be undertaken; Rehabilitation must occur once construction is complete in the relevant area; 6

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The preliminary siting of the proposed main lodge and accommodation units of the proposed development, is likely to be close to, or Without Negative high below the 100yr flood level. 1 With Negative Moderate Mitigation: Accurate determination of the 50 and 100yr flood level is carried out and this position is demarcated on the site to assist in the final location and siting of the proposed development. The siting of units and the proposed main lodge should then be based on whether the structures can be located below the 100-year flood level and the type of structure. In this regard, it may be possible to suspend the structures over the 100- year flood level. Should the structures be located at or close to the100 year flood level we consider it likely that relatively shallow colluvial/alluvial soils overlie the weathered granite bedrock. The proposed structures can be supported on normal strip or column base foundations which must found below all loose sandy colluvial and alluvial material, to bear into firm weathered granite or dolerite bedrock. If individual building platforms are constructed in each of the development areas, it is likely that in the cut portion of the building platforms, bedrock may be exposed on surface. The founding level of both external and internal walls should not be less than 0.5m below final ground level. Where the depth to suitable founding exceeds the practical and economic depth for normal strip footings, as may occur on the fill side of cut fill platforms constructed on the steeper slopes, then deep founding measures will be required. In this regard, isolated piers on spread footings or auger piles should be used to support reinforced concrete ground beams. Both spread footings and piles should be founded into the bedrock. Should the option of suspending the structures on a slab or deck be considered, the slab or deck can be supported on columns supported by column bases founded into the weathered granite bedrock. The maximum allowable bearing pressure of foundations taken into the weathered granitic bedrock, requiring hard handpicking for excavation, should be restricted to 150kPa, but can be increase significantly to up to 450kPa when the use of pneumatic tools or blasting is required for excavation. Earthworks: Careful cutting of the site to accommodate the individual units’ building platforms will be beneficial in that it will reduce the required depth of founding below the final ground level. Cut slopes in the sandy and gravelly colluvial soils overlying the weathered bedrock and the sandy alluvial soils, should not exceed a batter of 1:2 (26°). Where cuts are taken into the highly to completely weathered granite bedrock, the cut angle may be increased to a batter of 1:1,5 (33°) or steeper at the discretion of the Engineer. Prior to the placement of any fills, the natural ground should be stripped of all vegetation. The fills should be constructed on surfaces benched into firm in-situ soils and should be constructed in layers a maximum loose thickness of 300mm, each layer being compacted to 93% Mod AASHTO density for the sandy materials occurring on the site. The maximum particle size of the fill material must be restricted to b of the layer thickness. 7

People are at risk during the construction phase due to exposure to heavy duty Without Negative Moderate vehicles and increased traffic. .

1 With Negative low Mitigation: (a) Social responsibility by the construction staff must be ensured at all times. (b) Furthermore, all applicable safety regulations must be adhered to and clear signage erected.

8 Due to the likely shallow colluvial/residual soils overlying the weathered bedrock it is likely that it will difficult to bury all the services in the positions of the proposed main development 9 and it may be more suitable to suspend services below walkways. Subgrade 1 Without Negative high

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conditions in the area are generally considered good and the subsoil materials on site and in the area are likely to be suitable for use in the construction.

With Negative Moderate Mitigation: Due to the location of the structures on either side of the Mhlanganeni River it will be necessary to cross the river by bridge or causeway up slope of the proposed development. In this regard an existing rudimentary crossing is present but will require upgrading and formalisation. In addition, it will be necessary to construct a pedestrian bridge or walkway on the lower portion of this river to access the units and the proposed Boma. Once the details of these crossings are available, detailed geotechnical investigation of each of the crossings must be carried out.

There exists the possibility of an encounter of a gravesite during construction Without Negative Moderate 1 With Negative low Mitigation: (a) In the event that a grave is encountered during construction, all work must immediately cease and AMAFA called to the site. (b) Contact must be made with AMAFA and the family contacted, if possible, to begin negotiations for possible relocations. It is recommended that the development designs take into account the positive and negative characteristics of the existing cultural landscape type and that they endeavour to promote the positive aspects while at the same time mitigating the negative aspects. The grave must be demarcated as a No-Go area. 10

Without Negative high Potential for fires 1 With Negative low Mitigation: No open fires to be permitted within the construction footprint. Ensure that no refuse waste is burnt on the site or on surrounding premises. Ensure that all workers on site are aware of the proper procedure in case of a fire occurring on-site. Ensure adequate fire-fighting equipment is available and train workers on how to use it. 11 Sub-phase: Indirect Impacts

Due to an increased worker population and potentially non-locals in the area, Without Negative low there may be incidents of increased crime, violence (domestic), and security incidents. 1 With Negative low Mitigation: To as great an extent as possible, local labour must be sourced. The Contractor must be regularly engaged, and the community must 12 be encouraged to work together to limit any possible crime.

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Because the proposed structures and main area are located directly adjacent to the southern bank of the river, there is no suitable area for wastewater disposal Without Negative high by means of subsoil percolation in the vicinity of these developments

1 With Negative Moderate Mitigation: As such, wastewater will need to be collected and pumped to a suitable location up slope from the development and either treated in a package treatment plant or, a suitably designed septic tank soak pit system with suitable evapotranspiration areas. Once the development proposals are finalised and details of the lodge area, various units and other facilities are available, detailed design of the wastewater disposal 13 system must be carried out. Sub-phase: Cumulative Impacts

Without Negative Moderate Mismanagement of Stormwater

1 With Negative low Mitigation: Control of stormwater on the site both during and after construction is essential. After construction, the area and individual sites should be suitably graded to facilitate stormwater runoff and prevent ponding of stormwater on surface. Stormwater from all roofed and paved areas should be piped or carried in surface channels to discharged into soakpits located well away from the structures. Alternatively, stormwater should be piped to discharge into rainwater harvesting tanks located across the site. Due to the location of the proposed units and main development being directly adjacent to the river, it will not be feasible to use a septic tank and French drain system for the disposal of effluent for the development. Effluent will need to be collected and piped to a suitable location upslope to be treated by a package treatment plant or a suitably designed septic tank soak pit waste water disposal system. Control of stormwater on site is essential both during and post construction. It should be noted that this report is a preliminary report outlining the concept and feasibility of the development and a detailed geotechnical assessment will be required prior to final design and during the 14 development of the site. Average without mitigation Negative high Average with mitigation Negative low

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Table 49: Construction Phase Impact Assessment – No-Go Alternative

No. Impact Alternative Mitigation Interpretation

Phase: Construction - No-go

The status quo would remain, and the short-term impacts will not occur 1 N/A Positive moderate Mitigation: N/A 1

Maintaining the status quo also means that the key opportunity for conservation and nature-based tourism revenue and stewardship is lost 1 N/A Negative very high

2 Mitigation: The development should go ahead to prevent social ills of vandalism and degradation.

The community and ECT will lose the development environmental, social and economic benefits 1 Without Negative very high

3 Mitigation: The development should be approved in the interest of fairness. Average without mitigation Negative Low Average with mitigation Neutral

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Table 50: Operational Phase Impact Assessment

No. Impact Alternative Mitigation Interpretation Phase: Operational

Sub-phase: Direct Impacts

Groundwater contamination due to spillages or overflow from the septic Without Negative Moderate tanks.

1 With Negative low Mitigation: The mitigation measures would include surface water runoff drains and maintenance of equipment and a closed system with water being treated before released or removed from the site. 1

Without Positive high Stabilisation of soil / prevention of erosion. 1 With Positive very high Enhancement: N/A 2

The BTC will deter dumping / littering on the site Without Positive high 1 With Positive very high

3 Enhancement: N/A

Without Negative high Spillages or leakages from routine removal or overflow from Waste site operation and Chemical spillages or leakages from operations

1 With Negative low Enhancement: Ensure adequate lining and drainage systems are installed; Ensure surface water runoff is contained and treated before disposal. Ensure aprons are kept intact and in good working condition. 4 Sub-phase: Indirect Impacts

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Within and surrounding the proposed tented camp development footprint, the existing impacts on the watercourse and respective catchment area includes - The clearance of natural habitat for roads; Poor land Without Negative Moderate management in the tribal areas that has led to bush encroachment; Concentrated flow paths from dongas along the roads and some natural erosion areas; Some siltation from upstream areas (high erosion catchment); Erratic cattle grazing in the area; Historically contoured land for cultivation; Fences that have inhibited animal migration; and The presence and potential encroachment by alien plant species including Lantana camara and Chromolaena ordata.

1 With Negative low Mitigation: The ECT and AHC must manage the BTC well and ensure that it contributes no pollution to the watercourse and catchment. 5 Sub-phase: Cumulative Impacts

Without Positive high Improved community opportunities and job opportunities 1 With Positive high Mitigation: N/A 6 Average without mitigation Negative low Average with mitigation Positive low

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Table 51: Operational Phase Impact Assessment – No-Go Alternative

No. Impact Alternative Mitigation Interpretation

Phase: Operational - No-go

The status quo would remain, and the short-term impacts will not occur 1 N/A Positive moderate Mitigation: N/A 1

Maintaining the status quo also means that the key opportunity for conservation and nature-based tourism revenue and stewardship is lost 1 N/A Negative very high

2 Mitigation: The development should go ahead to prevent social ills of vandalism and degradation.

The community and ECT will lose the development environmental, social and economic benefits 1 Without Negative very high

3 Mitigation: The development should be approved in the interest of fairness. Average without mitigation Negative Low Average with mitigation Neutral

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Table 52: Decommissioning Phase – Not Applicable

No. Impact Alternative Mitigation Significance = E+D+I+P Interpretation Phase: Decommissioning Not Applicable Phase: Decommissioning - No-Go Alternative Not Applicable

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8. Study Findings and Conclusions 8.1. Environmental Impact Statement 8.1.1. Introduction Potential environmental impacts (biophysical and social) associated with the Babanango Travellers Camp in KwaZulu-Natal, have been identified herein.

This BA assesses and addresses all potentially significant environmental issues to provide the KZN EDTEA with sufficient information to make an informed decision regarding the proposed project.

8.1.2. Key Findings of the Study Overall, the results of the BA process emerge as having a “Positive low” or “Negative Low” or “Positive low” environmental significance after mitigation. Refer to table below for a summary of the phases.

Table 53: Summary of Significance Ratings per Phase

8.1.3. Key Conclusions and Recommendations of the Specialist Assessments The geophysical survey was conducted, and three targets were identified in the areas indicated.

• Three new boreholes have been drilled and constructed at Babanango Valley Lodge (BVL BH 1), the proposed BTC (TC BH 1) and the proposed Madwaleni Lodge (separate application) (5SL BH 1) on the White Mfolozi river. • The borehole yields ranged between 0.1 l/s and 0.56 l/s • The water quality within all three boreholes are of good quality. • 7 Infiltration tests were conducted and the hydraulic conductivity for the proposed Madwaleni Lodge was calculated to be 1.21m/day and 0.71 m/day for the proposed BTC.

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• The risk for contamination of the groundwater by the waste on site was calculated to have a potential high impact before mitigation and a low impact after mitigation measures are implemented. .

Based on the findings of this investigation, the following recommendations were made:

• It is recommended that groundwater level and quality monitoring be conducted to ensure no detrimental impact is posed to groundwater resources due to abstraction. A groundwater monitoring plan is compiled in Section 6 of Appendix D1. • The data obtained from the monitoring should be assessed after 12 months to re-evaluate the recommended abstraction volumes. • Groundwater sampling of all boreholes should be conducted to ensure water is safe for human consumption. • Septic tanks must be monitored, and the designs must allow for a closed system with sufficient volumes for the amount of people catered for at the lodges. • Based on the impact assessment determined from a Hydrogeological perspective it can be concluded that all impacts identified have a low negative significance, given good on- site management of infrastructure the risk to the surrounding environment and possible receptors is considered low.

The additional water supply report concluded that the Geophysical surveys were conducted at the Travelers camp for additional water supply and one target were depicted.

• One new borehole has been successfully drilled and constructed. • The borehole yields ranged between 0.1 l/s and 0.33l/s. • The total volume of water in combination with the previously drilled borehole at the Travelers camp is 17 136 l/d. • The water quality within the newly drilled borehole as well as the previous borehole is of good quality and safe for human consumption.

The Watercourse Assessment concludes that the site is in a visibly good condition. The primary surrounding impacts are erosion which has led to severe sediment wash and loss of the seasonal hydrological functioning. The geomorphology is in a modified state due to erosion and contouring. The actual site was historically transformed for many years. However, the natural vegetation is intact in and around the watercourse areas (NatureStamp, 2019).

Within and surrounding the proposed Babanango Travelers Camp development footprint, the existing impacts on the watercourse and respective catchment area includes -

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• The clearance of natural habitat for roads; • Poor land management in the tribal areas that has led to bush encroachment; • Concentrated flow paths from dongas along the roads and some natural erosion areas; • Some siltation from upstream areas (high erosion catchment); • Erratic cattle grazing in the area; • Historically contoured land for cultivation; • Fences that have inhibited animal migration; and • The presence and potential encroachment by alien plant species including Lantana camara and Chromolaena ordata.

In the broader Water Management Area (WMA), similar impacts are present as noted for the Mfolozi site. Additional existing impacts on the watercourses and respective catchment areas include –

• Infrastructure development within wetland systems (wetland encroachment) or riverbanks – leading to a direct loss of wetland systems and decrease in provision of ecosystem services; • Intensive agricultural activities such as crop production, forestry, cattle production - increased nutrients in the watercourses, dams and an altered hydrological regime; • Cattle grazing in wetlands and the riparian edge – drastic change in vegetation species composition occur in the catchment area, as well as soil erosion (cattle path erosion is prevalent in the area) and water pollution; • Canalisation of streams and rivers – leading to change in the hydrological regime. This can be caused by bank erosion relating to the removal of vegetation, active channel construction to create more agricultural land and compaction by cattle resulting in reduced runoff and concentrated flow paths; • Inadequate disposal of litter and solid waste – direct water pollution; and • Poor or absent sanitation – direct water pollution.

The delineation process identified a riparian area associated with the White Mfolozi River channel and some small ephemeral tributaries to the River. The development proposed for the site should have a moderate to low impact on the surrounding environment. This is partly due to the proximity of the camp to the river and the importance of the Mfolozi system. This can be seen in

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the PES assessments and the Importance and Sensitivity assessments. It is recommended by the author that some of the units be relocated further away from the riverbanks. If this is done, the relocation should consider the height difference to the riverbed at each site. Guidance should be taken from the flood assessment (NatureStamp, 2019).

It must be noted that the site was previously cultivated and grazed. The overall conversion of this site to a protected area is a net gain. In order for this to be achieved, monetary input in the form of tourism needs to be accommodated in the form of an aesthetically pleasing camp. A key component of this is to have a view of the river. As such, the camp needs to be strategically located so that environmental impacts are low and flood risk is minimal while still maintaining the tourist requirements that will ensure the success of the reserve (NatureStamp, 2019).

If the mitigation measures are followed in the form of a detailed rehabilitation plan, the overall impact should be reduced. The following points were identified in the study:

• The Mfolozi system has been identified as a priority area. • There will be some impacts that need to be rehabilitated on-site. • All of these impacts should follow the recommended rehabilitation, mitigation and monitoring. • Some of the units should be moved further away from the river to ensure impacts are minimal and the flood risk is avoided. • Wastewater treatment should be located 100 meters away from the river. • The general site location is suitable for the tented camp in relation to other potential areas (NatureStamp, 2019).

The developers of the proposed camp must note that watercourses are protected by nine Acts and two Ordinances in KwaZulu-Natal, which verifies that both national and provincial authorities recognise these systems as highly valuable multiple-use resources and are committed to their conservation. The figure below indicates, based on the terrain and the identified impacts, the line (in dashed red) where the units should be relocated to (NatureStamp, 2019). This retreat has been applied to final Layout / Site Development Plan.

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Figure 35: Recommended relocation boundary for the tented camp

For the Hydrological Assessment and Water Balance, design floods were calculated using verified data from gauging station W2H005. The Demoina flood event was synthesised into this record. Hotographical evidence shows that floods in this system can exceed 1000 m3.s-1 and cause severe damage to road infrastructure. The water balance showed a very small use of water on site. Given the minimal footprint of the development and that there is a net gain (although very small) of surface water contribution, there would be no impact on the downstream users. There are very little impervious surfaces on the site so peak flows would be minimal. Furthermore, the design of the structures is such that 1m3 of water would be attenuated for every 40m2 of hardened surface. The results provided indicate that given the gentle channel shape of the White Mfolozi in this area, the extent of the flood is not excessive. However, the flow velocity in the channel would be very high. A preliminary flood assessment was used which guided the layout of the camp. This allowed for the final camp area to be located outside of the 1:100-year flood extent. As these units are stilted, they have a lower risk of damage. However, due to potential debris during the flood, the units have been placed to account for this. The key findings from the Hydropedological Assessment indicates that: 1. Soils are limited for cultivation/agriculture; 2. Development along any slope’s steeper than 18° and within the 1:100-year floodline is not recommended; 3. The fluvial soils are consistent with the previously identified watercourses and their associated buffers;

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4. Flow dissipation points must not be concentrated towards these sensitive areas; 5. Wastewater treatment should be located 100 meters away from the river. Although infiltration is high, it is in close proximity to an important river system; 6. Effective stormwater management will minimise maintenance of the slopes. 7. There is limited groundwater recharge at the site; 8. There may be a slight risk of erosion on the site; 9. The site is structurally unsuitable for large infrastructure and there may be some movement in certain areas. 10. The proposed development, i.e. the Babanango Traveller Camp is suitable for such a site. The faunal assessment concluded the following:

The key findings and recommendations from this assessment are as follows -

1. The desktop assessment identified avian, reptile, amphibian and mammalian species of conservation importance. Species of conservation importance were noted on site, and there is potential for these species to be using the project area as a home range. 2. Potential for grasshopper, millipede and mollusc species predicted by EKZNW CBA data to occur on site is there, however time and budgetary constraints limited the search for these species. A search and rescue operation will need to be done before site clearance is to occur. 3. The tented camp is being built on stilts, thereby reducing the clearance footprint and the environmental impact. 4. The site is being used for communal grazing. Additionally, hunting by the community with packs of dogs is occurring, which is reducing the fauna significantly on site. 5. Permits for the removal and relocation of plants and animals must be in place before any construction can commence. 6. A search and rescue operation, undertaken by a suitably qualified person, must be undertaken before construction commences. 7. Community outreach regarding poaching of fauna should be undertaken. 8. Rehabilitation of vegetation communities would improve faunal diversity across the site. 9. Increased activity during construction phase will result in the small-scale movement of fauna away from the construction site. It must be noted that the type of construction associated with the Babanango Travelers Camps results in a minimal loss of habitat. Fauna will return to the area around the lodges once construction is complete. 10. The long-term positive result of formally protecting the area through the establishment of a large game reserve, and lodges to accommodate tourists far outweighs the potential negative impact of building a stilted lodge. Additionally, the surrounding community will be benefiting from the conservation of the land through the leasing of their land to the

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developers, through the provision of jobs through construction phase and operation phase, and the community outreach and education that will occur. 11. The development is supported by the Faunal Specialist, provided mitigation measures mentioned above are included in the Basic Assessment and EMPr.

The geotechnical recommendations are as follows:

Based on the results of the preliminary geotechnical assessment and the more detailed geotechnical investigation carried out on the site, the geotechnical specialist considers that the proposed development of the BTC and associated facilities is feasible.

As the terrain in the area of proposed development is topographically moderate to steep directly adjacent to the river and the area is underlain at a relatively shallow depth by weathered bedrock, depending on the type of structure proposed, individual cut/fill building platforms will need to be constructed for each aspect of the development or, where not practical on the slopes above the river bank, it may be more practical to suspend the structures on concrete slabs or decks.

Conventional structural development on the individual building platforms, comprising shallow founding on normal strip or column base foundations, taken through all loose colluvial, residual, alluvial and fill soils to bear into weathered bedrock, is considered feasible on sites located upslope of the river bank such as the staff quarters area.

Due to the location of the proposed units and main development being directly adjacent to the river, it will not be feasible to use a septic tank and French drain system for the disposal of effluent for the development. Effluent will need to be collected and piped to a suitable location upslope to be treated by a package treatment plant

The vegetation assessment identified a few sensitive species on site. The site exhibits signs of past agricultural practices, and thus in parts, consists of secondary grassland. Having undertaken the assessment of the proposed development footprint the following findings were noted.

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It is important to mention that additional species may have been overlooked during the field survey due to the plant life history characteristics exhibited by certain plant species. However, the vegetation that was recorded provides enough information to make inferences and extrapolations as to the quality, and the likely impacts associated with a development of this nature. Should the need arise for indigenous trees to be cut and / or destroyed in the developable area, a DAFF permit will need to be obtained. The permit and application will need to be made and an offset for the loss of these individuals will be required, usually planting 5 individuals of the same species for each tree that will be lost. These trees could be retained as part of the indigenous landscaping. If relocation of some of the provincially protected species is required, a permit for their removal will need to be obtained by Ezemvelo KZN Wildlife. Removal and should occur during the summer months by a qualified botanist or similarly qualified individual. The plants should be relocated into areas with the same aspect, soil conditions and elevation to ensure that the relocations are successful. In addition, the plants should be placed into good-sized holes that are at least twice the size of underground organs. It is very important for survival for underground organs not to be damaged and for plants to be watered for a period of time. Any applicable approvals/permits/consents/licenses relating to the environment should be in place prior to any site clearing and development. Should any development take place it is to do so in the areas indicated in Figure 1 of the Vegetation Report, the following is recommended but not limited to:

• Alien plants should be removed and managed, preferably mechanically and not chemically so as to have minimal ecological and biological impacts; • Special attention should be given to protecting and enhancing the existing natural vegetation on site by incorporating the already established trees on site as part of the landscaping of the tented camp. This will help to maintain a corridor of natural vegetation; • In the event that any natural vegetation is required to be removed or destroyed, a vegetation specialist should be appointed to assist with the identification, recovery and relocation of the plant species by way of DAFF and Ezemvelo KZN Wildlife permit applications. The plants should then be utilised as part of the ongoing landscaping for the development. In conclusion the vegetation ecologist in in support of the development should strict adherence to the recommendations be followed. Good housekeeping and management of the construction and operational impacts will result in limited impacts on the environment. The Flood assessment stated that Design floods were calculated using verified data from gauging station W2H005. The Demoina flood event was synthesised into this record. Photographical evidence shows that floods in this system can exceed 1000 m3.s-1 and cause severe damage to road infrastructure. The results provided indicate that given the gentle channel shape of the White Mfolozi in this area, the extent of the flood is not excessive. However, the flow velocity in the channel would be very

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high. A preliminary flood assessment was used which guided the layout of the camp. This allowed for the final camp area to be located outside of the 1:100-year flood extent. As these units are stilted, they have a lower risk of damage. However, due to potential debris during the flood, the units have been placed to account for this. It is the professional opinion of the Agricultural Specialist that the impacts of the development of Travelers Camp (footprint being 46.3 ha) associated with agriculture are minor, except for the 0.4 ha riparian extent of the White Mfolozi River where the impact is rated high:

• The negative impacts regarding pollution and erosion can be mitigated via adaptive management thereof; • The loss of veld implies the potential loss of grazing for 8 animal units that is negligible; and • The inclusion of the 0.4 ha riparian habitat and flood zone of the White Mfolozi River in the development footprint has a high negative impact. In conclusion, it is the professional opinion of the Agricultural Specialist that the project should proceed, provided attention is given to the mitigation impact measures identified in this report. In addition, the 0.4 ha riparian habitat of the White Mfolozi River should be excised from the study footprint. While it is recommended that this tract of land be excised from the developmental area the Floodline Report has been updated such that the tented structures that were located in the 1:100-year floodline have been moved further back. Therefore, while 0.4 ha of riparian habitat will be lost, all effort will be made to negate this impact. This includes strategically locating structures around larger vegetation (i.e.: around aloes/ trees/ shrubs etc), incorporating larger trees into the design of buildings and keeping vegetation clearance to an absolute minimum etc. Furthermore, rehabilitation will take place. Many of the riparian areas are degraded, and these will be restored. Thus the 0.4 ha in the context of the full development is negligible. The Heritage Impact Assessment assessed the greater BGR area. The site inspection revealed many graves and remains of homesteads throughout the proposed game reserve. The remains of stonewalling are protected by section 37 (1)(a) of the Amafa and Research Institute Act (2018), which states that no structure which is, or which may reasonably be expected to be older than 60 years, may be demolished, altered or added to without prior written approval of the Institute having been obtained on written application to the Institute. The remains of homesteads have a medium heritage significance. Besides the historical significance the homesteads hold, most of the homesteads have been reduced to foundation level leaving minimal possibilities of conservation. The homesteads are there therefore assigned a medium heritage significance and should be recorded before destruction. It should be noted however, that the possibility of graves being found within old kraals would make such sites significant from a heritage perspective. The Amafa and Research Institute Act (2018) also applies to some of the ‘colonial’ buildings found in the game reserve. The specialists who undertook the site survey are not built heritage specialists hence if any of the buildings identified as being older than 60 years are to be altered, added to or demolished, then a built heritage specialist must be appointed to undertake an assessment of these structures prior to such actions been undertaken.

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All human remains have high heritage significance at all levels for their spiritual, social and cultural values. Graves and burial sites are protected by section 39 (1) of the KwaZulu-Natal Amafa and Research Institute Act, which refers to the general protection of informal and private burial grounds. In terms of sub-section (1) no grave or burial ground older than 60 years, or deemed to be of heritage significance by a heritage authority – (a) not otherwise protected by this Act; and (b) not located in a formal cemetery managed or administered by a local authority, may be damaged, altered, exhumed, inundated, removed from its original position, or otherwise disturbed without the prior written approval of the Institute having been obtained on written application to the Institute and in terms of the regulations to this Act. The relocation of graves is not recommended as graves are highly significant to people and there are many traditional, cultural and personal sensitivities and norms concerning the removal of graves. However, if graves are to be removed, then this needs to be done with a high degree of consultation and sensitivity. It is stated in section 39 (2) of the above-mentioned Act, that the Institute may only issue written approval once it is satisfied that- (a) the applicant has provided evidence of efforts to consult with communities or descendants who may have an interest in the grave/s, using the guidelines and criteria for consultation set out in regulations; and (b) the applicant and relevant communities or descendants have reached agreement regarding the grave/s. Some of the graves and remains of stonewalling are found in close proximity to roads within the game reserve. If these roads are to be upgraded, then it is recommended that the graves and stonewalling are fenced, and a 2 m buffer must be placed between the roads and such sites. If, during the construction of new developments or roads, graves, archaeological material or any other heritage resources are found then work within 5 m of the find must stop immediately and the contractor and project manager informed as well as the Institute. A heritage specialist will need to be called to site to ascertain the significance of the find/s. If the heritage site/s found cannot be avoided by the work, then application must then be made to the Institute for the rescue and relocation of such sites or destruction thereof. It is understood by the BGR and recommended that the BGR allow relatives of those buried in the game reserve access to the graves in order for the families to undertake any ceremonies, etc., as required. It is recommended that the remains of the copper mine and lime mine found on the BGR, their associated buildings and slag heaps are left intact as evidence of early mining in the province. Due to the size of the BGR, it is doubtful that all heritage resources were found during the site inspection. Therefore, if new lodges or camp sites or any other developments are to be undertaken in the BGR, it is recommended that a Phase 1 HIA is undertaken of the specific sites in order to ascertain if any heritage resources will be impacted by the proposed developments.

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The proposed Babanango Game Reserve, and the proposed Travellers Camp can proceed as long as the recommendations and mitigation measures proposed in this report are implemented. In response to the Heritage Impact Assessment, Kwazulu-Natal Amafa and Research Institute issued comment and noted that the survey that was conducted did not cover all ground and therefore any proposed development within and in the vicinity of the proposed game reserve should be subjected to a Phase I Heritage Impact Assessment. This includes any envisaged establishment of human/animal activity, fencing, construction , bush clearance and earth-moving activities that have the potential to disturb both intangible and tangible heritage resources in the area including spaces to which oral history is attached. A Cultural Heritage Management Plan should therefore be developed for the reserve. The Institute has no objection to the proposed development of the Babanango Game Reserve within limits of the stipulated conditions and mitigation measures, but prescribed conditions, which are included in the EMPr. The Traffic Statement Letter issued by TraffSmart Consulting (refer to Appendix D12) concluded that according to TMH 17 Volume 1 South African Trip Data Manual V1.0, September 2012 the trip rate for a hotel type development is as follows:

• 0,5 trips/100m² during the AM Peak hour • 0,5 trips/100m² during the PM Peak hour • 0,7 trips/100m² during the Saturday Peak hour Applying the above rates, the BTC will generate 7, 7 and 10 trips during the respective peak hours. According to item 2.6.2 of the TMH 16 Volume 1 South African Traffic Impact and Site Traffic Assessment Manual: “A Traffic Impact Assessment shall be undertaken and submitted when an application is made for a change in land use and when the highest total additional hourly vehicular trip generation (including pass-by and diverted trips) as a result of the application exceeds 50 trips per hour.” Considering the above, it is concluded that the proposed project does not warrant a Traffic Impact Assessment. Notwithstanding the above, access to the site may be taken via the existing site access located on the R34. Suitable road safety improvements may be considered as per the civil engineers’ recommendations. 8.1.4. Sensitivity Map The sensitivity map consolidates the sensitivities of the study area as identified in the BA process and by the coastal report. This map must be considered when assessing this application, noting that each of these sensitivity findings have been addressed and mitigation measures have been provided for any possible impacts associated with these areas of sensitivity. This map is Appended as Appendix A1.

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8.1.5. EAP Opinion This BAR provides an assessment of both the benefits and potential negative impacts anticipated from the proposed Babanango Travellers Camp.

The findings conclude that there are no environmental fatal flaws that could prevent the proposed development from proceeding, provided that the recommended mitigation and management measures contained within the EMPr are implemented.

Given the findings of the specialist study conducted, as outlined in summary above, it is safe to say that no significant impacts have been identified by these studies. This has resulted in an impact assessment yielding an overall result of having “negative low” impact. This is attributed mostly to the short-term negative impacts, which are likely to occur during the construction phase, which can be adequately mitigated and rehabilitated to an acceptable state of environment. It is therefore the recommendation of the EAP that the environmental authorisation is granted for the proposed Babanango Travelers Camp, KwaZulu-Natal.

Indeed, the proposed development will have more long-term benefits than negative impacts, the latter of which are more short-termed and associated with the construction phase.

The benefits stated above, far outweigh the negative impacts. The upgrades will lead to an improvement to the social status quo. It is recognised that the proposed BTC will see the intended result to lease and merge the area controlled by the community to the developer, and join the Zulu Rock Private Game Lodge to the Babanango Private Game Reserve, thereby creating a private, “Big 5” game reserve. This will result in the conservation of many faunal species of conservation concern. The following recommendations / conditions, although not exhaustive, may be considered for inclusion in the environmental authorisation:

▪ The EMPr (including the SWMP and Plans appended to the EMPr) and conditions thereto must be adhered to; ▪ An ECO must be appointed and all Contractor staff to be trained on the EMPr requirements prior to commencement of activities; ▪ Alien vegetation and invader species within the vicinity of construction zone are to be removed and indigenous vegetation, where appropriate, to be introduced and managed; ▪ Environmental compliance monitoring should be conducted twice every month (or a frequency stipulated by the competent authority) during construction and incidents recorded and addressed accordingly; ▪ Construction must be undertaken according to a site-specific approved Environmental Management Programme (EMPr)

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▪ All solid waste must be recycled and disposed of as per the details of the Engineering Services Report in Appendix D8. ▪ No discharge of any pollutants, such as fuels, cements, concrete, lime, and chemicals are allowed into the Aquatic system (White Mfolozi River and tributaries). ▪ Waste receptacles should be provided and regularly cleaned, and waste moved to an appropriate disposal facility. ▪ It is recommended that a road management plan be developed for the BGR at this stage.

Having duly considered the proposal, there is unlikely to be any significant negative environmental impacts, and the social benefits are evident, and therefore it is the EAP’s opinion that the project be issued with a positive Environmental Authorisation.

8.1.6. Conclusion This study provided a quantified analysis of the impacts associated with the proposed development. The EAP is of the opinion that the project should be positively authorised, outlining the key findings of the study.

The BA process and report complies with the EIA Regulations of 2014 (as amended in 2017), under which this project has applied and therefore meets all relevant requirements.

The project is envisaged to have a “negative low” significance rating post application of mitigations proposed.

8.1.7. Assumptions, Gaps and Limitations of the study The BA process followed the legislated process required and as governed and specified by the EIA Regulations (2014 as amended in 2017). Inevitably, when undertaking scientific studies, challenges and limitations are encountered. For this specific BA, the following limitations were encountered:

▪ The study is limited to the information provided to the EAP; and ▪ Limited to the state of the site at the time of the site visit / assessment.

8.1.8. Recommendations

8.1.8.1. Recommendations to the CA

It is advised that the application be assessed holistically, taking into consideration the study area and the fact that the development is in line with the broader Babanango Game Reserve, which has support from EKZNW. The negative impacts associated with the proposed project are not significant but are temporary.

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The project, in the EAP’s opinion, does not pose a detrimental impact on the receiving environment and its inhabitants and can be mitigated to an acceptable level.

The Applicant should be bound to stringent conditions to maintain compliance and a responsible execution of the project.

The construction period is planned to commence only once all approvals and authorisations are in place (i.e. EA and local authority building approvals). The construction period is expected to span 9 – 12 months. The Environmental Authorisation (EA) is therefore requested to be valid for a minimum of five years from date of issue, to accommodate any unforeseen delays.

Post-construction monitoring is specified in this BA, specifically for the borehole/ groundwater analyses.

8.1.8.2. Recommendations to the Applicant

The Applicant must adhere to the recommendations provided by the specialist and the EAP. The EMPr summarises these recommendations.

The Applicant must take full responsibility for the execution of the project in a manner which does not negatively impact on the environment by ensuring that responsible decisions are made.

8.2. Declarations by the EAP The following is hereby affirmed by the EAP to be included in this report:

▪ the correctness of the information provided in the reports; ▪ the inclusion of all comments and inputs from stakeholders and l&APs; ▪ the inclusion of all inputs and recommendations from the specialist reports where relevant; and ▪ any information provided by the EAP to I&APs and any responses by the EAP to comments or inputs made by interested and affected parties.

______Novashni Sharleen Moodley Pr.Sci.Nat (EAP)

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